NUREG-1262 

Answers to Questions at 

Public Meetings Regarding 

Implementation of Title 10, 

Code of Federal Regulations, 

Part 55 on Operators' Licenses 

U.S. Nuclear Regulatory 

Commission 

Office of Nuclear Reactor Regulation 
NOTICE 

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American National Standards Institute, 1430 Broadway, New York, NY 10018. 
Answers to Questions at 

Public Meetings Regarding 

Implementation of Title 10, 

Code of Federal Regulations, 

Part 55 on Operators' Licenses 

Manuscript Completed: June 1987 

Date Published: November 1987 

Division of Licensee Performance and Quality Evaluation 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555 

NUREG-1262 

ABSTRACT 

This document presents questions and answers based on the transcripts of four 

public meetings (and from written questions submitted after the meetings) 

conducted from April 9 to April 20, 1987 by the staff of the U.S. Nuclear 

Regulatory Commission. The meetings discussed implementation of the Commission 1 s 

final rule governing Operators 1 Licenses and Conforming Amendments (10 CFR 

Parts 55 and 50). The rule became effective May 26, 1987 and is intended to 

clarify the regulations for issuing licenses to operators and senior operators; 

revise the requirements and scope of written examinations and operating tests 

for operators and senior operators, require a simulation facility; clarify 

procedures for administering requalification examinations; and describe the 

form and content for operator license applications. 

iii 

TABLE OF CONTENTS 

Page 

ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i i i 

PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix 

ACRONYMS AND INITIALISMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvi 

GENERAL ISSUES PERTAINING TO 10 CFR PART 55 ............... ... ........ 1 

Background to the Regulation.................................... 1 

Definitions (Subpart A, Section 55.4) ................. ... ....... 3 

Communications (Subpart A, Section 55.5) . . . . . . . . . . . . . . . . . . . . . . . . 3 

General Exemptions (Subpart B, Section 55.13) ......... ... ....... 4 

APPLICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 

How to Apply (Subpart D, Section 55.31; NRC Form 398) . .. . . ...... 7 

Medical Examination (Subpart C, Section 55.21) ....... .. . . ....... 18 

Certification (Subpart C, Section 55.23; NRC Form 396) .. . ....... 19 

Incapacitation Because of Disability or Illness (Subpart C, 

Section 55.25) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 

Documentation (Subpart C, Section 55.27) ............. .... ....... 22 

Regulatory Guide 1.8 and ANSI/ANS 3.1 ................ .. .. ....... 22 

WRITTEN EXAMINATIONS AND OPERATING TESTS............................. 31 

General Issues (Including Learning Objectives and Examination 

Question Bank) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 

Written Examinations and Operating Tests (Statement of 

Considerations) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 

Written Examination: Operators (Subpart E, Section 55.41) ....... 35 

Written Examination: Senior Operators (Subpart E, Section 

55.43) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 

Operating Tests: Content (Subpart E, Section 55.45(a)) ... ....... 40 

Waiver of Examination and Test Requirements (Subpart E, 

Section 55.47) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 

SIMULATION FACILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 

Written Examinations and Operating Tests: Implementation 

(Subpart E, Section 55.45(b)) .......................... .. ... .. 42 

Regulatory Gui de 1.149 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 

ANSI/ANS 3. 5, 1985 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 

Simulation Facility Certification (Including Performance 

Testing, NRC Form 474, NUREG-1258) ................. ... ...... .. 55 

v 
TABLE OF CONTENTS (Continued) 

Page 

LICENSES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 

Special Senior Operator Licenses (Including Instructor 

Cert i fi cation) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 

"Actively Performing the Functions of an Operator or Senior 

Operator" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 

Conditions of Licenses (Subpart F, Section 55.53) .... ........... 73 

REQUALIFICATION AND RENEWAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 

Requalification and Renewal (Statement of Considerations) ..... .. 82 

Renewal of Licenses (Subpart H, Section 55.57) ....... ... ........ 82 

Requalification (Subpart H, Section 55.59) ..... ...... ........... 88 

CONFORMING AMENDMENTS IN 10 CFR PART 50 ............... ... . ........... 115 

OPERATOR LICENSING EXAMINER STANDARDS (NUREG-1021) ...... .. ... ........ 117 

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122 

APPENDICES 

A 

B 

c 

D 

E 

Generic Letter 87-07 ...................................... . 10 CFR Parts 50 and 55 -- Operators' Licenses and 

Conforming Amendments ..................................... . Regulatory Guide 1.134 -- Medical Evaluation of Licensed 

Personnel for Nuclear Power Plants ........................ . Regulatory Guide 1.149 -- Nuclear Power Plant Simulation 

Facilities for Use in Operator License Examinations ....... . Regulatory Guide 1.8 -- Qualification and Training for 

Personnel for Nuclear Power Plants ........................ . 

vi 

A-1 

B-1 

C-1 

D-1 

E-1 
I PREFACE 

On March 25, 1987, the U.S. Nuclear Regulatory Commission published in the 

Federal Register (52 FR 9453) revisions to 10 CFR 55 to meet NRC responsibilities under Section 306 of the Nuclear Waste Policy Act of 1982. The rule, 

Operators• Licenses and Conforming Amendments, became effective on May 26, 1987 

and is intended to: 

1. clarify the regulations for issuing licenses to operators and senior 

operators; 

2. revise the requirements and scope of written examinations and 

operating tests for operators and senior operators; 

3. require a simulation facility; 

4. clarify procedures for administering requalification examinations; 

and, 

5. describe the form and content for operator license applications. 

From April 9, 1987 to April 20, 1987, the NRC staff held four public meetings 

to discuss implementation of the requirements of this rule and related issues. 

Those attending asked numerous questions which the staff answered. This document presents the answers to those questions taken from the transcripts of the 

four meetings, as well as to written questions which were submitted at the conclusion of the meetings. The questions are grouped to eliminate excessive 

duplication. However, where different questions addressed similar concerns, 

they were retained in this report if they provided clarification or a different 

perspective. Questions related to Regulatory Guides, industry standards, and 

other documents associated with the rule are included with the applicable portion of the rule. 

This report attempts to retain the intent, tone, and nuance of each question 

without reproducing each verbatim from the transcripts. Jn.some cases, questions submitted or recorded by the transcriber contained unintended or inadvertent factual errors. When identified, these errors were corrected. Similarly, verbatim answers in the transcripts have been edited where necessary 

for clarity and conciseness. 

NRC staff discussions held since the final public meeting indicate that the 

answers provided to questions in the area of 11 Conditions of Licenses, 11 specifically the proficiency requirements in 10 CFR 55.53(e), may have conveyed 

the impression that the staff advocated minimum shift staffing, and that this 

might have been construed to be counterproductive to safety. The apparent 

confusion stems from the definition of 11 Actively performing the functions of 

an operator or senior operator11 in Section 55.4 of the regulation, which 

appears to tie the proficiency issue to a minimum staffing requirement in the 

facility licensee's technical specifications. The intent of the 10 CFR 55.53(e) 

requirements regarding maintenance of active operator or senior operator status 

is that personnel maintain proficiency by actively performing the functions and 

duties of the licensed operator positions. Because facility licensees assign 

to a shift more than the minimum number of operators required by their Technical Specifications, concerns have been raised since the public meetings that 

vii 
10 CFR 55.53(e), if implemented in the manner discussed at these meetings, might discourage utilities from augmenting shift crews. 

It is not NRC's intent to discourage augmenting shift crews; clearly, this 

practice can result in a significant safety enhancement. However, assigning 

a large number of operators to a shift could reduce the range of responsibilities of any one operator to a level where sufficient experience in directing 

shift operations and/or in manipulating controls is not being obtained. NRC's 

intent in 10 CFR 55.53(e) is that operators taking credit for watchstanding on 

shift to maintain an active license engage meaningfully and fully in the functions and duties of the positions required by the Technical Specifications. 

The intent is not to have licensees augment a shift with a contingent of operators whose main purpose is to acquire the minimum number of watches to meet 

10 CFR 55.53(e) requirements. Their role is to fulfill the duties that the 

facility licensee judges are necessary and prudent for safe operations. 

Facility licenses can take credit for more than the minimum number of watchstanders required by Technical Specifications provided that there are administrative controls which assure that functions and duties are divided and rotated 

in a manner which provides each watchstander meaningful and significant opportunity to maintain proficiency in the performance of the functions of an operator and/or senior operator as appropriate. Normally, more than one additional 

watchstander at each Technical Specification position would not be considered 

acceptable with respect to the proficiency issue. 

Any answers to questions on this subject that were raised during the public 

meetings, and which might have conveyed the impression that NRC advocated such 

minimum shift staffing, have been revised in this report to reflect the staff's 

position as clarified above. Such answers are identified in this report by an 

asterisk next to the question number. 

Similarly, NRC staff discussions held during the preparation of this report have 

identified a number of answers given during the public meetings which either misstated an NRC policy or may have been open to misinterpretation. These answers 

have been revised for this report and are identified by an asterisk next to the 

question number. 

The views expressed in this report represent office practices and policies on 

how the staff will implement the rule. These views are intended as guidance and 

are meant to reflect the rule and its statement of considerations. The views 

expressed are not intended to interpret the rule or any of its provisions. Although any request for formal interpretation should be sought from the Office of 

General Counsel under 10 CFR 55.6, the NRC staff may provide informal guidance 

as needed and as appropriate. This report does not impose any requirements on 

facility licensees nor does it replace or supersede any existing regulations. 

II INTRODUCTION 

This rule (10 CFR 55) represents a significant move toward less prescriptive 

regulatory requirements for utilities that have accredited training programs 

and acceptable simulation facilities. It attempts to differentiate clearly 

between training programs sponsored through industry initiatives by the Nuclear 

viii 
Utility Management and Resources Committee (NUMARC) and the Institute for Nuclear Power Operations (INPO), and Nuclear Regulatory Commission (NRC) licensing and examination requirements. One of the most important changes to the 

regulation is the flexibility it affords licensees in reviewing the content of 

continuing training (requalification) programs, and tailoring those programs to 

the needs of the job incumbents. This degree of flexibility represents a major 

change from the way NRC has implemented regulations in the past in that it 

relies on industry initiatives to provide both training and qualifications for 

license applicants. With this rulemaking NRC has moved out of the area of 

specifying training program content and qualifications for instructors. 

INPO Accreditation 

It is a precedent-setting move, and NRC is pleased that the industry has taken 

this initiative to improve its training of licensed operators and others. 

Although moving out of the training areas potentially leaves a void, particu~ 

larly as it relates to some of the more prescriptive requirements used in the 

past, NRC has placed great importance in the INPO accreditation process. In 

its review of INPO accreditation criteria, the staff has concluded that they 

are equivalent to NRC's. If a utility implements an accredited training program, the accreditation will constitute the basis for NRC acceptance of that 

certification from a responsible utility officer, as indicated in Generic 

Letter 87-07. 

The Appeal Process 

NRC is also implementing a change to the appeal process for operator license 

candidates to clarify the process. The following figures describe the proposed 

appeal process. 

Figure 1. NRC's appeal process has always permitted both informal reviews and 

hearing rights on issues which were in dispute between the candidate and the 

examiner. Informal reviews were conducted by regional management and, when 

requested, further review was conducted at NRC headquarters. The exercise of 

hearing rights, described in 10 CFR Part 2 of the Commission's regulations, 

becomes operable should there be a license application denial. 

Figure 2. Informal reviews and hearing rights are available to the candidate 

for any adverse action, whether for a failure of the written examination or 

operating test, or for an application rejected for other reasons. The informal 

review will go first to the regional Division Director responsible for the 

operator licensing function, and then, should the candidate so choose, to the 

Director, Division of Licensee Performance and Quality Evaluation (OLPQE). 

In the past, on occasion, NRC has not completed action on appeals in a timely 

manner and, in some cases, candidates have not submitted information that is 

necessary to review an appeal. We have tightened up the schedule by allowing 

20 days for the candidate to decide to appeal and 30 days for informal management review. 

Figure 3. Those schedules will work as follows. The day that the candidate 

gets the notification letter of a failure or notification of a rejected application, we have called day zero. He has 20 days to decide whether to request 

an informal review. 

ix 
If the candidate does not act within that 20-day period, the notification letter 

automatically converts to a Proposed Denial of License Application, which will 

avail him of hearing rights under 10 CFR Part 2 of the Commission's regulations. 

If he requests an informal review, he submits the information to the responsible 

regional division director, who reviews it, and either sustains or overturns the 

examination failure or the rejected application. 

If it is sustained such that the situation is still adverse to the candidate, 

he may, then, request another informal review. The second letter he received 

would, in the manner similar to the first, become a proposed denial after 

20 days. If, during the 20-day period after he receives the letter from the 

regional Division Director, he decides to ask for an informal review, he submits the requested information to the Director, DLPQE, where another review 

of the merits of his contentions would be conducted. 

If the candidate's examination failure or application rejection is sustained, a 

Notice of Proposed Denial of License Application will be issued. The candidate 

can then request a hearing under 10 CFR Part 2. 

When a Proposed Denial has become effective, the applicant can choose to accept 

the Proposed Denial, waive his hearing rights, and have the denial become final. 

It takes an affirmative action by the candidate to waive his hearing rights 

through an NRC form letter which provides information about the date of his 

examination, his docket number, and the like. He simply signs the letter and 

returns it to NRC. 

Or, the applicant may request a hearing. In order to implement the hearing 

process, he would have to notify the NRC Office of General Counsel. The Examiner Standards will contain sample letters and procedures that describe this 

process. The 80-day time frame for this process does not include mailing time. 

We will be using certified mail, request return receipts, and will place the 

correspondence associated with the appeal in the docket file. 

In addition, we will provide copies of all relevant correspondence to the facility licensee's authorized representative who signed the application. This will 

be done at the time we mail it out to the individual. The reason for this is 

that the authorized representative is a part of this process, in that he certified the completion of training. Further, the facility reviewed a written 

exam and provided comments on the exam and the answers. 

Figure 4. This figure shows the proposed denial/hearing process, beginning with 

the administration of the examination. NRC will complete the grading, make an 

initial determination within 30 days, and mail the results to the candidate. 

If the candidate requests an informal review, he must send in a complete information package to the responsible regional division director. He has 20 days 

to decide to make the request, and 10 more days to submit the information. The 

regional division director would review the submittal and make a determination 

within 30 days. If the regional division director sustains the failure or the 

application rejection, the candidate could at that point request an informal 

review by the Director, DLPQE, a hearing, or accept the results. If the candidate accepts the results, NRC would issue a final denial and put it into his 

x 
docket file. After the required length of time from the date of final denial 

(immediately in the case of an application denial) he could start the reapplication process. 

Alternatively, if the candidate requests an informal review by the Director, 

DLPQE, he must submit the requested information within the prescribed time. 

The Director, DLPQE, would make a determination within 30 days. If the Director sustains the failure or the application rejection, NRC would issue a proposed denial. At that time the candidate would have the option of requesting 

a hearing or accepting the results. 

This process is more formal than past practice. A candidate may not reapply 

under the provisions of 10 CFR 55.12 until he has a final denial in hand. The 

only way he can get a final denial is either to agree with the staff 1s proposed 

denial, waive his hearing rights and accept the outcome, or go to hearing, where 

an independent determination will be made in his case. The types of hearings 

under Part 2 may vary from informal to formal adjudicatory hearings. It is the 

candidate who controls the process. It is the staff 1

s responsibility to ensure 

that the candidate understands his rights. 

The review process as outlined is currently under staff review for ways in which 

it can be expedited. 

xi 
>< 

..... 

..... 

INFORMAL APPEAL PROCESS AND HEARING RIGHTS 

Can be stopped at any point by candidate accepting 

proposed denial and waiving hearing rights. 

Candidate may reapply following examination failure only 

after application finally denied· under 1 0 CFR 55.35 . 

Candidate accepts Proposed Denial 

Hearing decision Final Denial 

Candidte may reapply at any time for rejection of 

application for reasons other than examination failure. 

Figure 1 
>< 

...... 

...... 

...... 

INFORMAL APPEAL PROCESS AND HEARING RIGHTS 

Process has been clarified to assure candidate 

understands his rights 

Applicable to any decision by the staff adverse 

to the candidate 

Applicant always has the right to request 

informal regional management review 

informal headquarters management review 

formal hearing before an administrative judge 

Schedule specified to ensure timely action upon 

informal review 

20 days for candidate to decide 

30 days for informal review 

Figure 2 
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Notification of Examination failure 

or Application rejection 

Request informal review by Region 

Notification of Region's review results 

Request informal review by Headquarters 

Notification of Proposed License Denial 

Request for Hearing 

NOTE: Does not include .mailing times 

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xvi 
GENERAL ISSUES PERTAINING TO 10 CFR PART 55 
__,, ________ --- -- -- -~---~-----~-- ------- ----~---~------

Background to the Regulation 

Q. 1. The Supplemental Information to NRC Generic Letter 87-07 states that, 

"These rules supersede all current regulations for operator licenses.•; Are 

training requirements from Mr. H. R. Denton 1s March 28, 1980 letter superseded 

by the new rule?* 

A. The rule supersedes all requirements where those requirements are less 

restrictive. Where individual commitments are more restrictive, you must follow those commitments until you change them. 

In some cases that change may require an amendment to the license. In other 

cases it can be done by yourself under 10 CFR Part 50.59, and you simply inform 

us of what you're doing. That would include any change within your authority 

to do under Part 50.59 that does not constitute a reduction in the effectiveness of the program, because it's being done to conform to the rule. Additionally, as a matter of interest, we are no longer, under the rule, permitted to 

certify instructors. 

Q. 2. Will the revision to 10 CFR 55 cancel NUREG-0737, NUREG-0094, and the 

Denton letter? If so, will references to these documents be removed from 

NUREG-1021? 

A. NUREG-1021, "Operator Examiner Licensing Standards, 11 has been reviewed and 

the items left are required by the Regulation, or by Regulatory Guide 1.8. The 

items from NU~EG-0737 and NUREG-0094 that are superseded have only to do with 

operator licensing. Items from Regulatory Guide 1.8 Revision 2, will be incorporated into NUREG-1021 when Regulatory Guide 1.8 becomes effective on March 31, 

1988. Some items may be very similar to what was there in the past, due to 

NUREG-0737 or NUREG-0094. For example, four years of power plant experience are 

incorporated into NUREG-0737 and Denton's letter, and it's still in Regulatory Guide 1.8 and NUREG-1021. 

Q. 3. Is it true that the NUREG-0737 requirements being incorporated in 10 

CFR Part 55 are only those that relate to operator training and licensing? 

A. The requirements pertain only to operator licensing, not training. 

Q. 4. We also make commitments in NUREG-0737 for training and mitigating core 

damage of other work groups. Also, there is training related to STAs. For instance, Reg Guide 1.8 talks about the number of shifts that an STA must serve. 

So, nothing in this regulation affects these commitments even though there is 

some reference to it? 

A. Yes, that's correct. It does not modify those prior commitments regarding 

training for STAs and other work groups. 

*H. R. Denton, NRC, Letter to All Power Reactor Applicants and Licensees. 

Subject: Qualification of Reactor Operators, March 28, 1980. 

NUREG-1262 1 
Q. 5. If NUREG-0737 is still applicable in areas not applicable to regulations for operator licenses, are you going to publish a NUREG that supersedes NUREG-0737 in those areas? 

A. No, we 1ll not issue a new NUREG that applies to the areas that have not 

been superseded. 

Q. 6. Are experience requirements in NUREG-1021 for the RO and the SRO super- seded by this change? 

A. No. NUREG-1021 will be revised to reflect the changes that have been 

adopted in ANSI 3.1 as endorsed by Regulatory Guide 1.8. We anticipate these 

changes will be made in about one year. 

Q. 7. Can licensees file an FSAR amendment for Commission approval to modify existing initial licensing and requalification training programs? 

A. Yes. See Generic Letter 87-07 for guidance on how to file such FSAR 

amendments. 

Q. 8. What other means are available for filing for program changes? 

A. You can write a letter and say that you have substituted an accredited 

training program, which is performance-based, for the previously NRC-approved 

program, and indicate the date(s) your new program was accredited. See Generic 

Letter 87-07 for further guidance on how to submit such a letter. 

Q. 9. Our FSAR commits us to ANSI/ANS-3.1-1978. 

A. Recall that this Regulation and associated documents supersede all prior requirements. The rule identifies the Regulatory Guides that are part of the 

rulemaking package. The implementation of Reg Guide 1.8, which endorses, with 

exceptions, ANSI/ANS 3.1, 1981, takes effect March 31, 1988, to allow for a 

phase-in period. 

Q. 10. Will we do anything different in the inspection of requalification activities due to the end of the two-year moratorium in INPO accreditation? Has 

the new rule been timed to coincide with the end of the two-year period? 

A. This issue is currently under advisement by the Commission. No decision 

has been made to date. Publication of the regulation was independent of the 

two-year period. 

Q. 11. Is failure to meet an INPO program requirement that was in the benchmarkaccredited program grounds for issuance of a Notice of Violation? 

A. Failure to meet INPO Guidelines, or loss of accreditation status through action taken by the National Nuclear Accreditation Board, will result in further 

evaluation by NRC. Such failure in itself would not be grounds for a Notice 

of Violation. However, per the 11 Policy Statement on Training and Qualification 

of Nuclear Power Plant Personnel 11 (50 FR 11147), "Nothing in this Policy Statement shall limit the authority or responsibility of the NRC to follow up on 

operational events or place any limit on NRC 1 s enforcement authority when 

regulatory requirements are not met. 11 

NUREG-1262 2 
Definitions (Subpart A, Section 55.4) 

Q. 12. Why did you change terms from 11 reactivity manipulations 11 to 11 control 

manipulations? 11 

A. For the purposes of Part 55, 11 controls 11 refers to the controls that affect 

reactivity or power. 

Q. 13. By what means are utilities to determine NRC's interpretation of "reference plant 11 as it applies to multi-unit plants at one site (from the same vendor 

and vintage)? It seems that compliance with Part 55 is contingent on a clear 

interpretation of this term. 

A. The definition of 11 reference plant" has been provided in Section 55.4 of 

the regulation. Section D, which is the implementation section of Regulatory 

Guide 1.149, provides clear guidance for the use of one simulation facility for 

more than one plant or unit, since each plant has a unique docket number. 

The greater the similarity between the units, of course, the more likely it is 

that you'll be able to submit one certification form for each, identifying any 

exceptions as necessary against ANSI/ANS-3.5. 

If your operators are dual-licensed, certification,. with exceptions, would be 

considered satisfactory for multiple units or plants. If your operators are 

not dual-licensed, it is still possible to certify with exceptions, although 

more work may need to be done to justify acceptability of the simulation facility 

for the conduct of operating tests. 

Q. 14. In the discussion of the term, 11 plant-referenced simulator, 11 mention 

was made of the simulator being required to use controlled copies of procedures? 

What do you mean by the word control? 

A. Controlled copies refers to procedures that are identical to those you use 

in the control room of the plant, and are maintained current through administrative contro 1. 

Q. 15. Do they necessarily have to be up to date to the minute or to the hour? 

A. We expect them to be up to date. 

Q. 16. As far as the references go? 

A. Yes. 

Q. 17. Revisions? 

A. Yes. 

Communications (Subpart A, Section 55.5) 

*Q. 18. Section 55.5(b)(2)(iv) states that applications and correspondence 

should be submitted to the Regional Administrator. Should copies be submitted 

to the Regional Section Chief for Operator Licensing? 

NUREG-1262 3 
A. No. Copies of applications and correspondence under Section 55.5 need not 

be sent to the Regional Section Chiefs. 

Q. 19. Is Form 474 to be submitted directly to the Director of the Office of 

Nuclear Reactor Regulation (NRR) in Washington, D.C., as opposed to Regional Administrators? 

A. Yes. We made a conscious effort to ensure that Form 474 certifications 

and the applications for approval be submitted to NRR at Headquarters. Offi- cially~ they should be filed in accordance with 10 CFR Part 50.4, which specifies that those submittals go to ATTN: Document Control Desk, Washington, DC 20555. 

Q. 20. Who specifically receives the certification referred to in Generic 

Letter 87-07, the region or headquarters? 

A. Generic Letter 87-07 describes the form of notification to the NRC, which 

basically is a letter telling U5 that you have an INPO-accredited program, or 

an otherwise systematic approach to training at your facility. That submittal 

is made to NRC Headquarters in accordance with 10 CFR 50.4. ·It comes to the 

Director of the Office of Nuclear Reactor Regulation, and is to be submitted in 

accordance with 10 CFR 50.4, ATTN: Document Control Desk, Washington, DC 20555. 

Q. 21. 10 CFR 50.4 is explicit regarding written communications and volume 

reduction; however, this part of the regulation seems to be inconsistent with 

55.5. Which regulation do we follow? 

A. For communications concerning 10 CFR 55, licensees should follow 55.5. 

General Exemptions (Subpart B, Section 55.13) 

Q. 22. With regard to Section 55.13, can you clarify the intent behind these 

exemptions? 

A. Yes. There are certain skills and knowledge that an operator must have, 

for example, to perform a reactor start up. Hopefully, he would understand 

some reactor theory, the effects of subcritical multiplication, and other aspects of the controls he is manipulating. 

If the candidate has not completed those phases of training, he should not perform reactor startup, whether or not it's included in the instruction. That's 

the concept. Now, if in your program, i~formation is transmitted to him such 

that he is prepared to perform the function because he understands what he is 

doing -- he has either had the systems training, or he's had the theory training, or he's gotten it in some other earlier program, such that you are assured 

that the sequence of training is appropriate and the potential for him making 

an error is small--then the exemption applies. 

We don't want to repeat an event which occurred a few years ago where an individual performed a startup soon after entering training. They had a high 

startup rate, short-period transient, and the individual did not understand 

what he was doing. He had no appreciation for the procedure because he had 

not received the appropriate on-the-job training for the evolution. There were 

NUREG-1262 4 
two concerns with that event: First, they put the plant at risk because someone manipulating the controls didn't know what he was doing and, second, they 

provided negative training. 

The sequence of training that leads to on-the-job-performance is important. 

That approach is consistent, by the way, with the INPO accreditation process 

and criteria. If you look at the objectives in INPO 85-002 for on-the-job 

training, you will find that they intend that the person adequately understand 

the task before performing it. 

Q. 23. Can trainees manipulate facility controls under the appropriate supervision of licensed personnel? 

A. If their training program leads to a license if carried to completion, 

they may manipulate controls under instruction if they have been properly 

trained. Properly trained means that the sequence of training that has led 

them up to that point is appropriate for the manipulations they perform. 

Q. 24. In Section 55.13, Item 1, are you using training and education 

interchangeably? 

A. No. Students at test or research reactors receive training on a reactor 

as part of a course of study to further their education. They may manipulate controls as a part of that course of instruction. 

Q. 25. With respect to Section 55.13, is someone who is in a course, but from 

a visiting institution, considered a student? Would a group of high school 

students visiting a university for a couple weeks to familiarize themselves 

with the school be considered students; that is, could I sit them down at the 

control panel and tell them what steps to go through to operate the panel? 

A. Both groups are considered students. There are colleges and universities that have exchange programs with high schools and other institutions 

where you bring students in to attend courses. If these students attend some 

part of classroom training, and as a part of that activity they manipulate 

the controls, then that's part of their instruction as students. 

We want to avoid the situation where an individual comes in off the street 

without any training and starts manipulating the controls. 

Q. 26. If the facility career path program considers all nonlicensed operators 

to be license candidates, can nonlicensed operators manipulate the controls 

under the direction and in the presence of the reactor operator's senior operator if the candidate is not currently in a hot licensed class? 

A. No. The candidate must officially be enrolled in the hot license class. 

Simply being a nonlicensed operator on a designated career path is not sufficient to meet the intent without being enrolled in the hot license class. 

More importantly, the candidate must have completed the necessary classroom 

or simulator training in accordance with the appropriate training sequence 

prior to manipulating the controls of the facility. 

NUREG-1262 5 
Q. 27. If the operator is in a licensing class, has completed the classroom 

and the simulator portion, and has an opportunity to take part in an unplanned evolution, can he receive credit toward the training program for that 

participation? 

A. Yes. 

Q. 28. Is a senior operator license required to move fuel in a dry storage 

area, .or away from the reactor vessel? 

A. The Regulation doesn't specifically talk about the dry storage area or the 

refueling pool. It specifically talks about moving fuel in .and out of the 

vessel. If there is a potential for criticality, a senior operator would be 

required to be there, as in some instances in a refueling pool. If not, no. 

Q. 29. Can the licensed senior operator who supervised fuel handling be a 

senior operator licensed for fuel handling only? 

A. Yes. 

NUREG-1262 6 
APPLICATIONS 
·----------............. .. 

How to Apply (Subpart D, Section 55.31; NRC Form 398) 

Q. 30. For a person who has dropped his license, what, if anything, must be 

done to later upgrade his status to an SRO beyond meeting the requirements of 

an accredited SRO training program? 

A. He must submit completed Forms 398 and 396 and.be examined as an SRO. 

Q. 31. Has Form 398 changed? 

A. Not yet, but a change is in process. It is scheduled to be available for 

ordering by the end of May 1987. 

Q. 32. Will the current Regional requirements for complete licensee history 

on Form 398 for license renewal be reduced to the data included in the OMB 

approval, 8150-0090? 

A. If you have an INPO-accredited program with an acceptable simulation 

facility (approved or certified), you can eliminate giving us information under 

blocks 11, 12, and 13, with the exception of the five significant control manipulations. Those still must be included. 

For renewal, the same rules would apply; there is a block specifically on the 

Form for renewal. You will only have to provide information on candidate training, education, and experience dating from that last application for a license 

renewal. 

There will be a block on the Form 398 to indicate the number of on-shift hours, 

or the experience that has been received. That 1 s all you will have to provide 

if you meet the two other criteria, i.e., having been INPO accredited, and having an acceptable simulation facility. If you do not meet these two check 

points, then you will have to provide the additional data on training, education, and experience. 

Q. 33. On Form 398, since test and research reactors don 1 t have simulators, 

are we required to completely fill out the form? 

A. What you are currently doing will continue to be acceptable. For all test 

and research reactors, there is no change to the process except in terms of 

license operators being re-examined during the six year license. 

Your requalification programs basically ·stay the same. We still intend for you 

to use ANSI 15.4 for selection, training, and medical certification. We've 

also adjusted the requirements for resuming an active license to six hours of 

parallel watch-standing. 

Q. 34. I understand that the designation of the authorized representative for 

a facility is changing. Is that true? 

A. We will accept, as the authorized representative, the senior individual on 

site responsible for operations. Some companies have a vice president on site, 

some have a site manager. Others may choose to designate someone at a higher 

NUREG-1262 7 
level, and send it off site to the corporate office. That is acceptable to us. 

It is also acceptable for it to b done on site. It need not be the same 

authorized representative who re~"~sts license amendments under Part 50. 

There is, under the facility license, only one authorized representative; 

generally that is somebody at the corporate level, a senior vice president. If 

that is the authorized representative for the facility, that 1 s who signs Part 50 

license amendment requests and makes other certifications. We will accept, for 

Part 55 licensing, the senior person responsible for operations on site. 

Please note a new requirement on Forms 396, 474, and 398. Above the signature 

there is now a statement that any false statement or omission in this document, 

including attachments, may be subject to civil and criminal sanctions, to the 

person signing it. The statement says: 11 I certify, under penalty of perjury, 

that the information in this document and attachments is true and correct. 11 

That 1s why we 1re adjusting the requirement so that the person on site, who 1 s 

closer to the information, can be absolutely sure when attesting to the 

accuracy of the information. 

Q. 35. Is it the intent of the Commission to limit the number of licensees at 

a facility .to a specific position? 

A. No. It is the facility licensee 1 s decision as to whether to have a person 

in a licensed position or not, and how many of them are needed. We will not 

question the judgment of facility management. 

Q. 36. Is it the NRC 1 s intent that the facility licensee identify organizational positions as needing an NRC Operator License beyond those required by 

Tech Specs? 

A. No. The facility licensee determines the need for whom they want licensed 

beyond the requirements of the Technical Specifications. However, all individuals who are licensed must be enrolled in the facility licensee 1

s requalification program. 

Q. 37. Does an applicant for a license have to be a member of the shift crew 

to obtain a license? 

A. No. An applicant doesn 1t have to be a member of the shift crew to obtain 

it, but the facility must certify that there is a need for him to have a license. 

Q. 38. In answer to the question: 

for the RO and SRO superseded, 11 you 

quirements that would still apply. 11 

an accredited program? 

11Are experience requirements in NUREG-1021 

said, 11 no, that there were experience reIs that still in effect even if you have 

A. The accreditation process has its own experience requirements identified 

within that program. For those facilities which have an INPO-accredited program 

and a simulation facility acceptable to the NRC, you do not have to designate 

on the Form 398 those experience requirements for those individuals. You need 

only check the blocks associated with the simulation facility and the accredited 

program. 

NUREG-1262 8 
Q. 39. Other than as stated in 10 CFR 55, are there any other requirements that must be included in initial or continuing training programs for licensed 

personnel? 

A. Yes. All previous requirements are in effect unless superseded by the rule, 

until the training program is accredited. 

Q. 40. Is accreditation by INPO's National Academy of Training sufficient? 

A. As indicated in Generic Letter 87-07, if it is based on a systems approach 

to training, it is sufficient. We believe that a program developed following 

the INPO guidelines for continuing operator training for licensed operators, 

issued in October, constitutes an adequate basis for concluding that the program has been developed in accordance with the systems approach to training. 

If you follow that, and you are accredited, that 1 s sufficient. 

Q. 41. Is the systems approach to training development referred to in the new 

10 CFR 55 based on the systems approach described in NUREG-1220 or on INPO 

standards? 

A. It's both. The Commission has specifically endorsed the INPO accreditation objectives and criteria as being a systems approach to training. 

NUREG-1220 simply repeats the criteria that are contained in the policy statement. It then has subordinate questions that we use for information gathering 

to determbe whether a systems approach to training is in place. 

There have been questions in the past about the level of detail we are 

looking for in some areas. They generally relate to conditions and standards 

associated with learning objectives and whether you need to develop K/As or 

not. 

We've reached agreement with INPO on that process; on how you're back-fitting 

existing programs that do not have K/As but have learning objectives. 

In general the agreement has been that if it's a new task or new training, it 

should be developed with K/As. If it's an existing task or training, a panel 

of subject matter experts (job incumbents) could conclude that the existing 

training programs adequately cover the material, and therefore, it need not be 

back-fit. 

Q. 42. Generic Letter 87-07 speaks of substituting an accredited training 

program for initial and requalification training programs previously approved 

by NRC. What if the initial training program was never formally approved by 

the NRC? 

A. By virtue of your having been issued a license, your 

described in your FSAR, can be considered NRC-approved. 

submitted a change to your program for NRC approval, you 

approved, unless NRC has notified you to the contrary. 

training program, as 

If you subsequently 

can assume it was 

Q. 43. Is this true even if it's not currently in the updated FSAR? 

A. Yes. See Generic Letter 87-07 for guidance on how to revise your current 

training program to conform to the new regulation. 

NUREG-1262 9 
Q. 44. Programs developed using a systems approach to training are, by intent 

of the systematic approach, subject to revision on the basis of feedback and 

input to the system from legitimate sources. Once a training program is accredited and appropriate certifications are made to the NRC, do subsequent revisions 

to these programs need to be certified to the Commission? 

A. No. For accredited programs, the particular evaluation, feedback and 

modification of your program is part of the process. For those programs that 

are not accredited or SAT-based, then, in accordance with 50.54, you will have 

to notify the Commission when you make changes that would decrease the scope of that program. 

The program of record is the program to be implemented until such time as you 

change it, whether it be an SAT-based program or an NRC-approved program. We 

do not intend for the change process to be used after the fact, to justify what 

training has already been done; that is, a failure to implement your existing 

program -- you cannot get out of that failure-to-implement loop by going back 

and changing it after the fact. 

Q. 45. Is it the Commission 1s intention that approved training programs will 

continue to be approved until accredited, and that the use of the simulators 

referenced therein will be acceptable for use until May 26, 1991? 

A. Yes. 

Q. 46. If a facility licensee does not include an approved systems approach to 

training, can operators be trained and licensed? 

A. Yes. Until the program is accredited, they still have to abide by their 

current approved program, as upgraded by the requirements of the Regulation. 

We will still license those individuals. 

Q. 47. When the new rule becomes effective, will all training programs previously accredited by the National Nuclear Accreditation Board be considered 

approved in accordance with the final policy statement on training and qualification of nuclear power plant personnel? 

A. Yes, but for clarification, they won 1t be approved in accordance with the 

oolicy statement; they will be approved in accordance with the regulation, with 

the intent as expressed in the Statement of Considerations that if you have 

been accredited by the National Nuclear Accreditation Board, you 1re considered 

to have NRC approval. 

Q. 48. Will utilities with INPO-accredited training programs be required to 

submit these programs to the NRC for approval? 

A. No. Programs that have been accredited by INPO are assumed to have NRC 

approval. All that is needed is an update to your FSAR in accordance with 

10 CFR 50.71(e)(4). However, programs must be available for NRC review and 

inspection on site. 

But since it is still Commission approval that you need, there may be cases 

where an accredited program is not implemented appropriately and, therefore, 

NRC approval might be removed. 

NUREG-1262 10 
Q. 49. If the utility has an INPO-accredited operator training program, but 

does not yet use a simulation facility acceptable to the Commission, will an 

application that states that the operator training program is accredited by 

INP.O and gives details of the simulator instructions be adequate for the 

license application? 

A. The Form 398 will have a block on it to indicate 'whether or not the applicant has graduated from an INPO-accreqited training program. If the answer is 

yes, and the facility has an approved or a certified simulation facility, then 

the in~ormation on education, experience, and training need not be filled out 

on the Form 398. 

On the other hand, if the individual is a graduate of an INPO-accredited training program and the facility does not have an approved or certified simulation 

facility, then all that information will need to be submitted. 

We would like you to begin certifying simulation facilities early on, and since 

nearly everyone has accredited programs with graduates, the process gets much 

simpler when you reach those two major milestones; otherwise, it stays difficult with you providing all of the details, which we subsequently review to 

verify eligibility, training and experience. 

Q. 50. If the facility certifies the training program as being based on the 

SAT process, will NUREG-1220, "Training Review Criteria and Procedures," audit 

findings and comments be considered violations of 10 CFR 55? 

A. If we did go to an accredited program, and we used NUREG-1220 to do a post-accredit~tion audit, and found problems, they would be addressed in one 

of two ways. Depending on their severity, they would be either left to the 

utility to resolve with INPO or, if they were of a more severe nature, we might ask for a performance-based inspection. Depending on the results of that inspection, there may or may not be any need for enforcement action. 

Q. 51. If the SAT process is evaluated to be unsatisfactory during inspection, 

can operators be trained and licensed? 

A. That will have to be determined on a case by case basis. If your program is deemed unsatisfactory, it would obviously depend on what the problems are. 

Q. 52. When filing an application, the facility is required to provide evidence that the applicant has successfully completed the facility licensee 1 s requirements to be licensed as an operator or senior operator. 

Part of the training program is not complete prior to filing the application 

for the license due to the Examiner Standard (NUREG-1021) guidance to file an 

application 60 days prior to the examinations. This has been acceptable in 

the past due to the statement on the application above the facility repre- sentative signature. It states that: "The individual has or will have completed by the time of the examination all the required training." Will this 

continue to be an acceptable approach under the new rule? 

A. No. This will not be continued. The Form 398 will be revised to remove 

the words 11 or will have. 11 

NUREG-1262 11 
The Commission has stated in the rulemaking that the authorized representative 

certifies that the individual has completed all training. It's not a future 

completion, and we don't want to get into situations such as 11 at the time I 

signed it I thought he was going to complete, but he didn 1 t. 11 You are certify- ing that training is complete. . 

We have had some experiences in the past where commitments that were made were 

not completed, and they resulted in significant enforcement actions associated 

with the failure to complete training programs, even after examining, let alone 

at the time of examining. 

Q. 53. The Regulation requires INPO accreditation for NRC approval, while 

Mr. Denton 1s Generic letter 87-07 requires that the training program be both 

accredited, and based on an SAT process. Which is the governing document? 11 

A. The Regulation governs. The Generic Letter just restated what was in the 

Regulation. To receive relief under the Regulation, the program must be based 

upon a systems approach to training. And some of the earlier plants, which 

were accredited very early, were based upon the INPO guidelines, and not upon 

the INPO accreditation objectives and criteria as endorsed by the Commission in 

the Policy Statement. 

In that case, what they are doing now by way of updating their program and 

revising it, and the fact that they now understand the process, would be the 

basis for them to certify to us that they have, indeed, done it on an SAT 

pasis. They need not go back and wait until the next time through with the 

Accrediting Board. 

Q. 54. Is a Commission-approved training program defined as an INPO-accredited 

training program, or are there other criteria for approval by the Commission of 

a utility's training program? How is a training program approved by the 

Commission? 

A. NRC is getting out of the approval process for training programs. If there 

is an INPO-accredited training program, it only needs to be certified to us as 

indicated in Generic Letter 87-07. If a utility wishes to submit a revision to 

the present NRC-approved training program and asks for an NRC review and approval of that, while we are not prepared to do that now, we would probably 

have to deal with that using the SAT-based, performance-based approach specified in NUREG-1220. 

-,To clarify, if a utility has a program that has been accredited by INPO, we expect that it will be the program of record. The Commission endorsed this program based upon the industry commitments to improve training, and the Commission 

is moving out of the role of reviewing and approving training programs. 

The staff does not see that there is any need for, or value in, doing a review 

to come up with a lesser regulatory standard, because SAT-based programs are 

now the standard of record with NRC. If you are accredited, we expect you to 

follow the accredited program. We have revised the approach to the inspection 

of training programs, and we do not expect you to maintain a lesser standard 

for licensing with NRC than you have for training the people. 

NUREG-1262 12 
Therefore, the staff would consider a review of amendments or modifications to 

the cold license training program, which is SAT-based, and we would use as 

guidance in doing that review the kind of information that is contained in 

NUREG-1220, or you could propose that you have done it in accordance with the 

TSO process, which INPO is using. If you show that it's comparable to that, we 

would also consider it. That is a vehicle for getting a Commission approval of 

a performance-based or SAT-based program on a case-by-case basis for a cold 

plant. We don't mean to exclude you from being able to do performance-based training. 

Q. 55. ·Are you still going to want Form 398 60 days prior to an examination? 

A. We want to get to the point where, if you are accredited and have an 

approved simulation facility, all that is required is the certification. No 

prior review of the application will be necessary to determine eligibility, so 

the time between submittal of the application and the conduct of the exam could 

be very short. 

However, until then, the Region needs time to review applications to determine 

whether the candidate is eligible, and to have an opportunity to interact with 

the training department to supplement that application in some cases. In those 

instances, we're still going to want to see it on the order of 60 days prior 

to the examination to start the review. However, we cannot take action on an 

application until the final completed application is filed. 

Q. 56. There is one situation where you say you can administer the written 

exam and operating test but not issue a license until required evidence of control manipulations is supplied. It would seem a logical extension of this to 

allow us to put somebody up who hasn't completed all the requirements, pass him, 

and make the request, "Do not issue a license until he's subsequently certified." 

Does that make sense or is that completely prohibited? 

A. The exception for manipulating the controls to which you refer is only for 

the individual who has not had an opportunity to perform the manipulations because the facility has been in extended shutdown. It is a condition beyond that 

candidate's control. However, we are moving into the role of accepting facility 

certification, and we want that certification to be unconditional. So the two 

situations are not comparable. 

Q. 57. With respect to the logistics of submitting NRC Form 398 only after all 

program requirements have been completed, and; in addition, having to submit 

it 60 days prior to the examination date, would a reasonable compromise be to 

submit the 398s, unsigned by the facility, merely for a screening by the 

region, given that the the 60-day requirement is due to the time involved in 

such a screening? We could then follow them up once the program's been completed, maybe a day or a week before the examination, for approval by the 

Region. 

A. Although those types of issues need to be worked out on an individual basis, 

it is preferable not to have licensing decisions made upon draft materials, particularly when there may be changes to them during the 60-day time frame. 

Advance copies (unsigned) may be submitted on a case-by-case basis if there is 

a concern about a particular candidate's eigibility, experience, or training. 

NUREG-1262 13 
However, what we review and base our licensing decisions on should be the 

application as it is submitted. The R 'lation does not provide for review of 

drafts and other documents along thos ines. 

The time between submission of the document and when the candidate takes the 

examination appears to be the issue that•s of greatest concern. There is one 

way you can shorten that time frame. Certify your simulation facilities early. 

That's one of the things that we would like people to pursue. The other thing 

we can do is to expedite the review, give the applications a review when they 

first come in, and see if we can't shorten the time needed since we can shorten 

the submission times between the time it has to come in and when we finalize 

for the exam. In other words, we will reconsider the 60-day time frame that 

was in the earlier version of the examiner standards in light of this 

requirement. 

Q. 58. If a facility has an accredited initial program that's SAT based and 

has a plant-referenced simulator acceptable to the staff, then the time between 

submittal of the application and the exam can be of the order of a couple weeks? 

A. Well, we're going to need to know well in advance of that how many candidates there are for licenses, but the review for eligibility, training and 

experience requirements is significantly reduced if all we have to do is look 

at two blocks on the form. 

The intent of the rulemaking is to make the application process easier, and to 

put the burden of the determination of completion and eligibility on the facility, rather than on the staff, and accept that certification. 

The issue that is significant is one of managing our own resources and knowing 

how many candidates are going to be put up and how many examiners we have to 

arrange for. Because it's a resource-intensive effort, we have to know, at 

about the time of the 90-day letter, how many candidates you are going to have 

for an exam on a given date. However, we don't need to know the specifics of 

who is being scheduled for the exam at that point. 

Q. 59. Is there any difference between an 11 approved simulation facility" and a 

"certified simulation facility? 11 

A. In the context of applications, there is no difference. An acceptable 

simulation facility is one that is either certified or approved. 

*Q. 60. What is a significant control manipulation? 

A. Significant control manipulations are defined in Regulatory Guide 1.8. 

Examples can be found in items A-F of 55.59(c)(3) (On-the-Job Training for 

Requalification), although that's not an inclusive list. Basically, "significant control manipulations" involve situations that affect either power or 

reactivity, and that require manipulation of controls. Therefore, the plant 

should not be shutdown when these manipulations are performed, except for those 

manipulations required for fuel handling. 

Q. 61. Will manipulations on a simulator be adequate? 

NUREG-1262 14 
A. Those five control manipulations have to be performed on the plant, unless 

the plant has not completed preoperational testing and is in its initial startup test program. 

Q. 62. Where does the requirement for five reactivity manipulations on the 

plant come from? Why can't they be performed on the.simulator? 

A. The control manipulation on the plant has been required for some time. 

That's not a change. We have now put it in the Regulation to make it explicit. 

In fa~t. for a long time, if you had not performed a start up and shut down of 

the plant, we actually had you perform them as a part of the NRC examination. 

So this is not, per se, a change in practice. 

Q. 63. Must the five control manipulations be different? 

A. Regulatory Guide 1.8 asks for diversity. Therefore, the intent is to have 

different manipulations; however, this is not necessarily required. If reactivity manipulations are repeated, this fact should be indicated in the comment 

section on the application. 

Q. 64. As far as the five significant control manipulations are concerned, 

what's going to constitute evidence? 

A. Documentation on the OJT qualification cards consisting of a simple 11 per- formed11 code next to the signature of someone on shift is sufficient evidence. 

Q. 65. What constitutes an extended shutdown? 

A. An extended shutdown would be anything that is long enough to prevent an 

applicant from completing required manipulations or training prior to taking 

the examination. 

As an example, if the plant is in a refueling outage that lasts for a year and 

the candidate did not get an opportunity to perform the control manipulations 

because the plant never got to Mode 2 or Mode 1, we would consider giving that 

individual an exam, and even issuing him a license limited to shutdown 

conditions. 

When he completes the control manipulations on a hot plant, we would then remove the condition on his license that limits it to shutdown. We do not intend 

to penalize individuals because of an extended outage, but we also don't i'ntend 

to give waivers for what's clearly a requirement of the regulations. 

Q. 66. If you have to complete the initial simulator and classroom training 

prior to allowing a nonlicensed operator to manipulate the controls from the 

control room, how can a person get their initial license? After the time 

needed for your simulator and classroom training, and for the NRC exam, there 

is not much time left to complete the five reactivity manipulations. 

A. This applies only to a hot license. If the individual has not had the 

opportunity to perform control manipulations on shift because of an extended shut 

down, we would consider examining him. And if he passes that exam, we may 

issue a license which is limited to shutdown. 

NUREG-1262 15 
Q. 67. Will startup and shutdown experience gained on a certified simulation 

facility be considered adequate experience for operator and senior operator candidates? 

A. Yes. The same answer applies to the use of an approved simulation facility. 

The application goes to whatever is in your NRC-approved training program, or 

your INPO-accredited program for startup and shutdown experience. 

Q. 68. How much time can pass before the five control manipulations must be 

completed before the written exam and operating tests are completed? 

A. Up to six years. If, for example, we had given a shutdown license to a 

plant experiencing an extended shutdown, and we had given a license to a candidate who was constrained to shutdown mode, he could actually serve out the term 

of that license for a period of six years. 

Q. 69. Does NRC intend to make start-up certifications a part of the operating 

test for every new licensed applicant? If so, what is the status of the present start-up certification? 

A. Start-up certifications are done on an audit basis, and it is left to the 

chief examiner to determine which initial license candidates will be audited. 

Therefore, there are no changes from our past practice. 

Q. 70. For NRC licensing examinations which have already been scheduled for 

the remainder of 1987, will relief be granted from the new requirement that all 

training program requirements be 100 percent completed prior to the submittal 

of NRC-398 and NRC-396 forms? These 1987 licensing exams were scheduled in the 

fall of 1986. 

A. Forms 398 submitted after May 26, 1987 must comply with the new regulation. 

Q. 71. What kind of 11written request" is discussed in paragraph 55. 31(a)(3)? 

A. An authorized representative of the facility licensee is required to request that the written examination and operating test be administered to the 

applicant. This request may be included in the transmittal letter forwarding 

the applications to the NRC. In order for the NRC to approve such a request, 

the facility licensee must provide suitable facilities for the administration 

of the written examination and operating test. 

Q. 72. If an approved training program based on SAT is used for initial or requal ification training pursuant to 55.31(a)(4) and 55.59(c), are there any NRC 

imposed minimum training requirements? Of specific interest is the 3 months 

of on-th-job training for initial training and the annual requirements of 

55.59(c)(3)(i) and (ii)? 

A. There are no additional requirements provided that the response cited in 

Generic Letter 87-07 is filed and the facility plans to or has incorporated 

INPO guidelines 86-025 and 86-026. We are aware that INPO guideline 83-022 

"PWR Control Room Operator, Senior Control Room Operator and Shift Supervisor 

Qualification" does contain the three months on shift training period. 

NUREG-1262 16 
Q. 73. Reg Guide 1.8 endorses ANSI/ANS 3.1 for ROs and SROs. In reviewing the 

ANSI/ANS 3.1 annual and biennial manipulation requirements, it was noted that 

the ANS 3.1 manipulation list does not agree with the 10CFR55 manipulation list 

for five manipulations. This deviation was not stated as an exception in Reg. 

Guide 1.8. Please clarify whether Regulatory Guide 1.8 should have taken exception to this deviation. 

A. The five manipulations specified in the rule are necessary for eligibility, 

not for requalification. 

Q. 74. At a minimum, five significant control manipulations must be performed 

which affect reactivity or power level. For a facility that has not completed 

pre-operational testing and the initial startup test program as described in 

its FSAR, the Commission may accept evidence of satisfactory performance of 

simulated control manipulations as part of a Commission approved training program by a trainee on a simulation facility. If the facility is in an extended 

shutdown, the NRC may administer the examinations, but may not issue the license until the required evidence of control manipulations is supplied. 

Do we need to submit waivers since we don't have full power license yet? Does 

this apply only to initial license candidates, or to all license holders, e.g. 

renewal? Does the NRC accept in lieu of the above simulator manipulations the 

use of a research reactor? 

A. If a plant has not completed the initial startup test program, successful 

completion of an approved training program on a simulation facility satisfies 

this requirement, and no waiver is required. 

These requirements apply to initial and replacement license applicants. Requirements for renewal of licenses are covered in part 55.57. For plants that 

have completed their initial startup test program, applicants must complete the 

control manipulations on their actual plant. 

*Q. 75. How will NRC evaluations of INPO-accredited programs affect NRC's 

willingness to allow use of a Commission approved program developed by using a 

systems approach to training? Notwithstanding the generality of this initial 

question, please address the following two specific situations within the 

answer. 

(1) How would an 11 unfavorable 11 NRC review of an accredited program affect a 

facility's ability to use an approved program in lieu of paragraphs 

55.59(c)(2), (3) and (4) pursuant to 55.59(c)? 

(2) How will the NRC determine that a requal and/or initial program is based 

on a SAT during their evaluations? Of particular interest is the evaluation 

of element (5) under the 55.4 definition of SAT. 

A. For clarification, an INPO-accredited program and an NRC-approved program 

are the same. (1) Unfavorable NRC review may be due to a number of conditions 

as outlined in the Commission Policy Statement of March 20, 1985, and continuing 

evaluations using NUREG-1220 or examinations administered by the region. 

NUREG-1262 17 
An unfavorable review would not have any direct effect on your program. NRC 

would work with INPO to resolve identified deficiencies. However, NRC has discretionary enforcement authority under the Policy Statement, and this could be 

imposed if continuing problems were identified as a result of performance-based inspect ions. 

(2) The criteria used by NRC may be found in NUREG-1220. 

Q. 76. Will any combination of significant control manipulations be acceptable 

as dictated by the facility's modes of operation during which the applicant is 

in training? 

A. Refer to Reg Guide 1.8 Regulatory Position C.1.h for guidance on what the 

Commission considers to be acceptable. 

The acceptability of any alternatives will have to be determined on a case-bycase basis by the facility and indicated in the comments sections of the 

application. 

Obviously, some significant manipulations may not be possible in Mode 4 of a 

plant. It may be possible in Mode 5 or 6, whichever you use for refueling, in 

the case of a fuel-handling foreman, so it's going to have to be on a case-bycase determination. 

Q. 77. In the staff's presentations under Training Program Approval, it was 

mentioned that in order to implement §SS.31(a)(4) and §55.59(c), the next 

annual FSAR update could delete training program details. Please clarify what 

(event or achievement) is meant by 11 implementation11 of §55.31(a)(4) and 

§55.59(c): what would the staff expect to see in the FSAR update different 

from that information which would be provided under Reg Guide 1.70 and the 

basis for development of the information sought (Reg Guide 1.70, Standard 

Review Plan, etc.). Should utilities assume that besides stating that the 

training program is INPO accredited the FSAR should retain revised program 

details in accordance with details sought under Reg Guide 1.70? 

A. The staff plans to revise Section 13.2, Training of NUREG-0800 to provide 

guidance for information contained in revisions to the FSAR. There are no 

plans at this time to revise Regulatory Guide 1.70. In lieu of additional 

guidance at this time the staff recommends that the licensed training programs 

which are accredited and are based on a systems approach to training only need 

reference Generic Letter 87-07 and the dates the programs were accredited. 

Plans for certification of simulation facilities should also be included. 

With regard to other training programs contained in Section 13.2 of the FSAR, 

those training programs listed in the March 20, 1985 Commission Policy 

Statement on Training and Qualification of Nuclear Power Plant Personnel 

which are accredited need to reference the date of accreditation. For those 

facilities which are developing programs under the accreditation process the 

FSAR should identify the programs and provide the dates that SERs were or !.!:! 

planned to be submitted. 

Medical Examination (Subpart C, Section 55.21) 

Q. 78. How long before administration of a license exam must an individual 

have had a medical exam? 

NUREG-1262 18 
A. The form verifying the medical exam should come in at the same time the 

license application comes in. It will be good for six months from the date it 

is signed by the physician; waivers, as stated in ES-111, will apply. 

Q. 79. Assume a physician may not desire to release personnel medical data due 

to a patient-doctor relationship. What does the utility do if the information 

is treated as privileged by the physician? 

A. The Privacy Act Statement contained in NRC Form 396, 11Certification of Medic~l Examination by Facility Licensee, 11 does not allow for privileged information being withheld by the facility or the physician if it is requested by 

NRC. It is the utility 1 s responsibility to ensure that the records can be made 

available for inspection. Utilities should ensure that the physician understands this requirement. 

Q. 80. For individuals who are currently under either license conditions or 

letters from the regions to submit continuing medical follow-up information 

(e.g., quarterly blood pressure readings) for review and analysis, do these 

conditions continue to apply after May 26, or should the individual submit this 

information to the utility 1 s physician for evaluation and analysis (without a 

copy to the regions)? 

A. Continue to report quarterly blood pressure or other restrictions. High 

blood pressure or other restrictions are usually associated with some remedial 

programs (diet, medication, or a combination) and should result in normal or acceptable conditions. At that time the physician can request termination of 

these reporting requirements. 

Certification (Subpart C, Section 55.23; NRC Form 396) 

Q. 81. Has NRC Form 396 changed? 

A. Yes. A copy of the new version has been distributed to everyone at the 

public meetings. 

Q. 82. Must a Form 396 be submitted for every license application? 

A. Yes, but the detailed medical information only has to be submitted when a 

conditional license is requested. 

Q. 83. Under the new Rule will you receive a Form 396 only upon license 

renewal? 

A. That is correct. We expect to receive a Form 396, 11Certification of Medical 

Examination by Facility Licensee, 11 at the end of the appropriate license period, when the renewal application is submitted. 

Q. 84. Is the examining physician an authorized representative of the facility 

licensee and thus allowed to complete and sign an NRC Form 396? 

A. No. The Form 396 does not have a place for the physician to sign. The 

physician's name and license number are required, but the authorized representative is the highest level of corporate management who signed the application. 

That will be the same person who signs the Form 398. 

NUREG-1262 19 
Q. 85. Can Form 396 be held by the licensees for the two-year update or do 

:hey have to be submitted to the Commission? If the latter, how often do they 

.ave to be submitted? 

A. You don't have to keep the Form 396 on file, but you must keep some documentation that the medical exam was performed and that the operator meets the 

ANSI standard. The Form 396 is only the means by which you transmit that information to us upon renewal of a six-year license. 

Q. 86 .. For a multiple-unit site, can the signature on the application be from 

the individual responsible for operations, the highest ranking individual at 

that site? So that you could have different signatures; i.e., Sequoyah applications would different signatures than those of Brown's Ferry? 

A. Yes. 

Q. 87. Will the Commission develop a protocol to ensure that detailed medical 

records will be forwarded to the NRC medical experts and not made available to 

lay persons? 

A. This is an issue for which industry initiative may be appropriate, and it 

has been discussed by NRC, INPO and the accrediting board. 

The staff needs to have assurance that the medical examination was done in 

accordance with the ANSI standard. The staff does not need to see the private 

medical record from the doctor, because it.may include other medical information not related to the standard, or may get into the area of privileged information between doctor and patient. 

It might be appropriate for the industry to develop an examination form which 

would track the standard, such that the doctor would provide a statement to the 

responsible officer that the examination had been completed and which would 

identify the areas evaluated. Such a report would be all that is necessary for 

the individual's file, and it would be available on site. 

If, in the case of a request for a license condition based upon some medically 

disqualifying condition that can be accommodated through medication, therapy, 

or something else, the doctor would submit the examination form and any additional supporting information for the staff medical doctor to review to make a 

determination as to whether to issue a conditioned license. 

That information would be handled in the same manner as we now handle confidential information that is covered by the Privacy Act. Once submitted to NRC, the 

information would be exempt from further public disclosure, and it would be the 

basis for our review. 

We don't anticipate developing any new protocols for handling that type of 

information, but we recommend that you have evidence available on site showing 

that the medical doctors conducted the examination in accordance with the ANSI 

standard, or that you provide the physician a copy of the standard and let him 

complete whatever form you use now for that type of examination. It's only a 

suggestion. The actual requirement is that the examination be conducted in 

accordance with the standard. 

NUREG-1262 20 
Incapacitation Because of Disability or Illness (Subpart C, Section 55.25) 

*Q. 88. Must the felony blocks on Form 396 be completed in order for the form 

to be considered complete and to be accepted by the NRC? 

A. The form has been revised to delete the felony blocks. A certification 

is now required that the individual meets the safeguards requirements of the 

facility. 

Q. 89. Will a standardized form be provided by the Commission for notification 

of disability or illness? 

A. The intent is that licensees keep the records. We don't need to be involved 

when someone breaks an arm or may be out for an extended illness. If it's a 

temporary condition, no notification is required. 

We ask the question, "can the operator perform licensed duties?" If the individual is going on shift, and there is any question in your mind, we would 

say submit a revised Form 396 to describe the condition/remedy. We may tell 

you it's not necessary to make a ruling on it. But you can have a problem if 

you don't notify us and some individual has a problem in performing licensed 

duties. If a person is to resume duties after a disabling condition, then we 

would need to be notified with a Form 396. 

Q. 90. What is the relationship between the facility licensee and the individual with regard to responsibility for notification on medical issues? The Regulations indicate that we have a 30-day notification period upon learning the 

diagnosis. The question really is, what's the mechanism for the facility to 

become aware of the diagnosis; and what responsibility does the individual 

licensee have to make that notification to the facility? There's the potential 

to get into a problem if we don't learn of a licensee's medical condition. 

A. It is the operator's responsibility not to operate that plant in a disabled 

condition. The Regulation says that the facility licensee shall notify the 

Commission, but we believe that, logically, the operator should have enough responsibility to tell you there's a problem. Facility procedures should be set 

up to ensure that that occurs. 

There is nothing in the Regulation that obligates the operator, or the senior 

operator, to let the facility know. But there is an obligation for you, on 

the biennial medical examination, to identify and report disabling medical 

conditions. 

Q. 91. If the individual has a medical problem during the period of the 

license, for instance a broken arm, does this need to be reported to NRC if the 

operator is not carrying on licensed duties? For example, if he is training 

individuals in a classroom, do we still have to report it, or only if he's 

carrying on licensed duties per the Tech Specs? 

A. It's when that person serves on shift that we have to know about a disability. Usually, if he has a temporary disability that would preclude him 

from performing regular duties, he's not to perform those duties with that 

temporary disability. We need not know if it's temporary. When you return him 

NUREG-1262 21 
to shift duties, if he has been absent for a period of time, you control that 

process with the 40-hour parallel shift duties and maintain the certification 

on file. It 1s only in case of a permanent disability that we would have to be 

notified. In that circumstance you want to include a qualification in the 

license to allow the operator to perform licensed duties with the medical condition if some compensatory measure effectively offsets that condition. 

Q. 92. Can an individual be returned to active licensed duties after the medical di~ability has been corrected if a portion of the requal program has been 

missed? 

A. The operator must be current in the requalification program before he 

returns to duty, and he must receive 40 hours of parallel watch standing. 

Documentation (Subpart C, Section 55.27) 

Q. 93. The utilities must maintain some records in fire proof vaults. I don 1 t 

feel that the physician 1 s offices meet those requirements. Yet this is a 

qualification record, as defined by that ANSI Standard. Are we going to have 

to provide physicians some type of fire proof storage? How do we handle that 

aspect of this record keeping? 

A. We recommended to INPO, and they are considering the development of, an 

examination report form which would cover the areas in the ANSI Standard and 

which would be submitted from the medical examiner to the facility for 

retention. 

Q. 94. Can private physicians maintain medical records for the facility licensee, as is currently practiced? 

A. You may choose to delegate that responsibility to them, but it is, indeed, 

your responsibility to ensure that the appropriate records are available for 

inspection. 

Regulatory Guide 1.8 and ANSI/ANS 3.1 

Q. 95. When we want to go from a non-accredited status to an accredited status, 

what would the step-by-step progression, and the changes in the regulatory 

environment be for us? 

A. The date you receive accreditation from the Academy, you would send NRC a 

letter that says 11we 1 ve been accredited on this date. 11 You then begin that 

program because the previous training program is superseded. You need not tell 

us about it until the next FSAR update, which is required pursuant to 

10 CFR 50.71(e)(4). 

Simply send a letter saying that you were accredited, and the date of accreditation, and certify that your requalification program is based on a systems approach 

to training; this supersedes any prior commitments to NRC by way of additional 

training. 

NUREG-1262 22 
Q. 96. For the FSAR update following accreditation, it would not be necessary 

to have the extent of detail in that update, as previously was the case, is 

that correct? 

A. That is correct. It can be blank, except for the information about the 

date of accreditation. It need not say anything, other than you were accredited, 

and the date you achieved the accreditation. All records associated with your 

training program, following accreditation, are available to the staff on site 

for review; they need not be submitted. 

Q. 97. If the facility does not certify its training programs in accordance 

with Generic Letter 87-07, when must FSAR Chapter 13 be revised and how do I 

do it? 

A. The Rule becomes effective on May 26th, 1987, and at that time, you must 

comply with the new provisions in the requalification program. So, there would 

need to be a change to the FSAR submitted in accordance with 10 CFR 50.54(i) 

and 55.59(c), to conform to the regulation, if you chose not to certify the 

training program. 

The Commission endorsed the INPO Program for accreditation in the Policy Statement. We said we would accept a program after it was accredited and certified 

to be based on a systems approach to training. A utility that perceives they 

get some advantage by leaving an old training program on the docket because 

that's all NRC is going to inspect is misguided. That is not consistent with 

the intent of improving training in the industry. We do not require that you 

tell us all the details about an accredited program, but we do expect you to 

implement them. 

We have heard rumors that some facilities intend to have one standard for NRC, 

and a different standard for INPO. That is not the Commission's intent in the 

Policy Statement and we would bring such a practice to the Commission's attention promptly. We expect you to follow the accredited program when it is 

accredited. Failure to implement that program will be of concern both to INPO 

and to NRC. 

Q. 98. Will NRC be prepared to approve or disapprove FSAR Chapter 13 changes 

within the 60 days allowed for implementing 10 CFR 55 requirements? 

A. The approval is effective automatically, if you have an accredited program 

and have certified that it is based on a systems approach in accordance with 

GL 87-07. You shouldn't expect to see any· response from the Commission on 

changes that are implemented as a result of this rule, with the exception of 

any license amendments which are required because of something in your Technical 

Specifications. There are a number of facilities that have a more restrictive 

requirement in their Technical Specifications than that for which they would 

have to apply; amending their Technical Specifications to obtain relief is per- mitted under the rule. It would be an administrative change in order to conform with the Regulation. But it would not have to be acted on within 60 days 

and would be processed as any routine change to the Technical Specifications. 

If you do not plan to certify that your program is based on a systems approach, 

we cannot act on it until we receive it in accordance with 10 CFR 50.54(i). 

NUREG-1262 23 
It will then be reviewed in the usual way. In this case, it would not be reasonable to expect it to be completed by May 26, 1987. 

Q. 99. But in the meantime, is Revision 1 of Regulatory Guide 1.8 our commitment, as approved in our FSAR? 

A. Yes. Your commitment is that which is approved in the FSAR. It is binding, 

as are any of the more restrictive requirements in the Rule, until you are accredited and so inform us by letter. At that point, you can make changes pursuant ·to 50.59 to remove things from your FSAR and your program. When you 

need to amend a license, you submit the application for an amendment to strike 

the sections in the Technical Specifications or in the license which have been 

superseded by accreditation. 

Q. 100. Upon achieving accreditation, would we then become committed to 

Regulatory Guide 1.8, Revision 2? 

A. No. Regulatory Guide 1.8, Rev. 2, goes into effect for all facilities, as 

is indicated in the implementation section of the Guide, on March 31, 1988. 

However, if you have an accredited program, you are no longer obligated to 

follow the Guide. At that point, you can put the Regulatory Guide aside, but 

you now must implement your commitment to the Accrediting Board. We have looked 

at that information, and we've concluded that INPO guidelines in this area are 

equivalent to the staff guidelines in Regulatory Guides. 

Q. 101. This question addresses NRC approval of training programs. Do revisions to requal programs which reduce their scope require NRC review and approval per 10 CFR 50.54.i-l if the program is INPO accredited? And can the 

term "reduction of scope" be clarified? 

A. NRC review is not required if the program is accredited and is certified 

to be based upon a systems approach to training. Element 5 of the SAT includes 

revision of training in order to meet the needs of the job incumbents; therefore, we expect you to update your program based on this feedback. 

The intent is that if you are SAT based, and are revising the program based 

upon an evaluation of the needs of the trainees, that the result of that evaluation is the program you are going to conduct. And you have a basis for that 

evaluation. Reducing the scope does not apply. The intent is to give you the 

flexibility to modify the program in order to provide the training that you, 

the facility licensee, determines appropriate for your job incumbents. 

We have seen that process work through the INPO-accreditation process. We have 

confidence in the process. And even though we are sure that there are going to 

be cases where there is content left out, where we are going to have some 

concerns about something not having been covered, the process is there so that 

you can cover what's needed. 

The training and the feedback process you provide will permit the training to 

be job-relevant. It is training which the trainees agree is important. 

Probably the only exception is for the instructor who has had that training. 

But the old test-out exemption is gone. You can't take an exam, do well on it, 

NUREG-1262 24 
and eliminate training in a systems approach. If someone misses a portion of 

the training program because he has been ill or been away, you may use something like a required reading program and a test to ensure that he has covered 

the material. But when the Rule says training on a continuing basis, it refers 

to whatever cycle you have designed that has been accepted by the accrediting 

board. 

NRC has separated itself from the training review. We would prefer, after you 

are accredited, that you certify you have a systems approach in place to us, 

and ~liminate the details from your FSAR. Certification is all that we need 

because the periodic reviews through the accreditation process are the vehicle 

for keeping your training programs current. We think that the separation of 

training from examining is the most significant part of this rule-making. 

Q. 102. There are a lot of documents involved with the accreditation process, 

so if an IE inspector came in and said, 11We think that your program is less 

than the scope, 11 what is he basing that on? 

A. Regional inspectors are governed by inspection module IP 41701, which requires 

a performance-based inspection. If you make a change to your program through the 

accreditation process using the mechanisms for revising and updating your program, based upon feedback and need, and that's the reason that you're revising 

it, we don't see that that is an issue of lessening the scope. 

The lessening of a scope issue had to do with the old program when it was 

regulatory-based, where we required a certain number of hours in the classroom 

and certain types of content. The approach now is one of modeling the program 

based upon performance and need, and the process is one that has been endorsed 

by the Commission through the policy statement. To the extent that you need to 

change the program based upon feedback of your own performance, that's 

appropriate. 

If you have an approved program today that calls for administering a comprehensive written exam annually and you want to change that to a comprehensive written exam every two years, the regulation is the basis for concluding that that 

is acceptable; that is not reducing the scope. That is simply conforming to 

the regulation. You can make changes to match the regulation either through 

the 50.59 review process or by amending your license. There are a few facilities which have commitments to operator training programs associated with a 

staffing requirement section in Section 6 of the Technical Specifications. If 

you are in that category, you can submit an amendment request to the Commission 

for an administrative change to your Technical Specifications to conform to the 

requirements of the regulation, but you may not do less if it is, in fact, a 

requirement in your license now. You can't do less than what's currently in 

the license. If it's in your approved program, you can do a 50.59 review to 

conform to the regulation. 

Q. 103. Let's say that in my systematic approach to training, I have determined 

that it doesn't take three years of experience to meet the requirements. I complete the program with whatever experience we determine is appropriate, and 

we've got an accredited program. Do we still have to have the experience requirements in our program? Do we still have to meet them if we have an 

accredited program? 

NUREG-1262 25 
A. The ~n~ust:y, through.NUMARC, has made~ commitment to NRC in both training 

and q~alifications. We did not take exception to the three-year requirement for 

experience. In the past we have accepted two years for reactor operators. 

On the effective date of Regulatory Guide 1.8, March 31, 1988, we would expect people to meet ANS 3.1 unless they have already committed to that. 

Within the accreditation process, there is a hierarchy of guidelines just as 

within the regulations. An acceptable way of meeting the regulation, as it 

relates to experience requirements, is by conforming to ANS 3.1. Another way 

is through the accreditation process, which also has guidelines. 

In the case of a review and approval by the Staff, we would look at any bases 

for waivers of those requirements and alternatives that are proposed. In the 

accreditation process, the mechanisms are already built in for you to do that 

yourselves on a case-by-case basis. 

So accreditation criteria for entering into training as it relates to qualifications are described in the INPO training guidelines for each position. They 

articulate what the entry levels are for training and have in that process a 

mechanism for granting waivers to certain requirements. 

The Commission, through this rule making, has said, 11We will accept the candidate at the end of training if he is certified to have been a graduate of an 

accredited program. 11 We have done that through promulgation of the policy 

statement on training and qualification and an endorsement of the accrediation 

program. That means that you control the review and waiver process, through 

your vehicle with INPO. Now, if you want to deviate significantly from the 

INPO guidelines, I would suggest that you need to contact INPO and they may need 

to contact NUMARC if you want to come up with a radically new interpretation. 

But, in fact, if you have a basis for what you're doing which is documented, 

and you do that on an individual basis, we do not intend to second-guess your 

judgement. In fact, we would not see it on the application when you have both 

an accredited program and a simulation facility acceptable to the Commission 

for the conduct of operating tests. 

That's a major change in the way we have done business in the past; it puts 

a lot of trust in the industry through the self-initiative of INPO and NUMARC 

in order to provide both training and qualifications. 

Q. 104. Have the experience requirements to sit for an RO or SRO exam stated 

in Reg Guide 1.8 and NUREG-1021 changed? 

A. Yes, in that the experience requirements are not operative if you have an 

accredited program and have certified your simulation facility. ES-109 will 

be changed under the revision to NUREG-1021 and under Regulatory Guide 1.8, 

which becomes effective March 31, 1988 for nonaccredited programs. 

Q. 105. Will NRC change any of the eligibility requirements in the Examiner 

Standards for taking the SRO exam discussed as a result of implementing 10 CFR 

55? This question is being asked in light of the fact that 10 CFR 55 supersedes 

previous regulations. Specifically, will NRC require that someone have one 

NUREG-1262 26 
year of experience as an RO before entering the training program for an SRO? 

ANSI/ANS 3.1-1981 requires a minimum of six months. 

A. Yes, there is a change to the eligibility requirements except if a facility 

has an accredited program and an acceptable simulation facility. In that case, 

the requirement goes away because it becomes part of your accredited program. 

Q. 106. The way I understand the Examiner Standards presently, the experience 

requirement to take a reactor operator exam is two years of power plant experience, one of which is nuclear. ANSI Standard 3.1-1981, specifies three years 

of power plant experience, one of which is nuclear. The two remaining years 

should be as a nonlicensed operator, and of that, six months should be as a 

nonlicensed operator at the facility for which you seek the license. So, that 

would be, in my interpretation, a three-year requirement now, whereas in the 

past it was a two year. Is that correct? 

A. That is correct. The standard had not been imposed across the board in 

1981. There are some facilities that have committed to that standard in their 

application, and were reviewed against that standard. A previous version of the 

Examiner Standards was based upon ANSI N18.l-1971, because we had not endorsed 

ANSI 3.1. This rule making process endorses ANSI 3.1.-1981. 

Q. 107. And the same applies for the senior operator. Examiner Standard 109 

says four years, and ANSI 3.1 says three. So, you will be changing that one 

also? 

A. The Reg Guide takes exception to the ANSI Standard. Reg Guide 1.8 cites a 

four-year requirement for experience for the SRO. 

*Q. 108. Reg Guide 1.8 endorses certain positions through ANSI 3.1-1981 for 

training and qualifications. The ANSI Standard has experience requirements 

which are different from those in the Examiner Standards. For instance, for 

a reactor operator, ANSI 3.1 of 1981 requires three years power plant experience, one of which is nuclear. And I believe it says two years as a nonlicensed operator, with six months as a nonlicensed operator at the facility. 

Is the Reg Guide endorsing those eligibility requirements also, or just 

training? 

A. We have not taken exception to three years of experience for reactor 

operator. We have endorsed the ANSI Standard with respect to three years for 

RO, but have taken exception by requiring the four years for SRO. That's the 

same as the practice has been. We recognize the difference between the Examiner Standards and the Reg Guide in this area. The Examiner Standards will be 

changed to coincide with the implementation date of the Reg Guide, which is 

March 31, 1988. 

Q. 109. Are the experience requirements for operator licenses applicable also 

to research and training reactors? 

A. The requirements for test and research reactors have not changed. Whatever 

has been approved in the past, in terms of eligibility requirements, continues 

for test and research reactors. The eligibility requirements in Regulatory 

Guide 1.8 refer to power reactors. 

NUREG-1262 27 
Q. 110. I have an accredited SAT-based program. The simulator should be available next year and will meet ANSI/ANS 3.5 Standards. It's my understanding that 

we are okay because we meet those three elements, SAT, INPO accredited, and our 

simulator should meet your standards. Am I correct, that in meeting those 

standards, I don't have to worry about the ANSI Standards requiring two years 

as a nonlicensed operator with six months at the plant? 

A. No, that's not entirely correct. While you don't have to submit that information to NRC, the industry, through NUMARC and INP0 1 s training guidelines 

and accreditation, has standards comparable to those in the ANSI standard. 

Therefore, we feel that the qualification requirements are still being met. 

The only difference is that you don't have to submit all that information to us. 

We had a case recently where an individual was a graduate of an accredited program but did not meet the experience eligibility requirements. His plant experience was that of a chemist, a position not comparable either to that of a 

control room operator or a shift engineer. We denied the application, and it 

was denied on appeal. We aren't going to see that kind of information in the 

future, and we expect the industry to police itself with respect to ensuring 

that the NUMARC commitments are, indeed, met. Because we are stepping out of 

that area, and not requiring it to be submitted, does not mean that you can 

relax your standards. 

Q. 111. In the example that you just gave you were apparently talking about an 

SRO candidate, and I was referring, primarily, to RO candidates. In the past, 

particularly for those who weren't committed to the 1981 version of that ANSI 

Standard, there was no requirement for RO candidates to have been nonlicensed 

operators. Now we are faced with the new requirement, and I've got a .group of 

people who are in training now, who don't necessarily have that background. 

A. There is one aspect of the accreditation process that you may be missing. 

And it's a part of the process that pertains to meeting NRC eligibility requirements. The accreditation process does include a mechanism for you to exempt, 

or waive aspects, based upon having performed an evaluation of the candidate's 

experience and/or testing. That is the same kind of process that we use in 

making a judgement, on a case-by-case basis, about eligibility, where a person 

didn't cross all the 11 t 1 s 11 and dot all the" i 1 s 11 • 

We are looking for you to use that same process .. You may choose, for a documented reason, as a part of.your program, to waive a portion of the requirement, based upon experience and/or testing. That is a part of the accreditation process, and we understand that, and we expect that to continue. And the 

only difference is, you don't have to submit it to us to request a waiver. 

Q. 112. Will NRC continue to accept one year as a Navy reactor operator, engineering watch supervisor, etc., as meeting the one-year reactor operator experience requirement, if one year remains as a requirement? · 

A. Yes. 

Q. 113. The definition for related technical training in ANSI/ANS 3.1 says, 11 Formal training beyond the high school level in technical subjects associated wi~h.t~e position in question, such as.acquired in several programs: includin 

ut1l1t1es, and others. Such training program shall be of a scheduled and g 

NUREG-1262 28 
planned length, and include text materials and lectures. 11 All of our programs 

meet that definition of related technical training, and yet we can 1 t count it 

for experience. Why not? 

A. Experience is an eligibility requirement. If the person has the experience 

and the qualifications, then he goes i~to a training program. You have mechanisms, through your accreditation process, where you look at the entry level 

into your training program. You can count time and training prior to that program, but we have not been giving credit for experience for the training which 

is requi'red and has been approved by NRC as a part of the specific program leading up to license eligibility. 

Q. 114. Do radiation protection personnel now require three years experience 

per ANS 3.1-1981, even if Tech Specs require less experience? 

A. The requirements for radiation protection personnel in Reg Guide 1.8 are 

the same as those included in ANSI Standard 18.1 of 1971. 

Q. 115. About five years ago, we all wrote our response to the Denton letter 

and said that we would do specific punch list items to train our STAs. Now if 

we have an approved STA training program, per INPO, the old prescriptive hours 

that we committed to no longer apply. However, if that punch list item is in 

our FSAR, we need to remove it 11 per the INPO-accredited program. 11 Is that 

correct? 

A. That is correct, as it relates to licensed operator programs and other 

programs for which you have made training commitments which are covered by the 

Commission 1 s Policy Statement on training and qualifications. And in both 

cases, it is simply a 50.59 type review to amend or update your FSAR to indicate the date on which you received accreditation, for instance, for the STA 

position. The only exception relates to the Commission Policy Statement on 

engineering expertise on shift or the use of the dual role SRO/STA compared with a separate STA, as indicated in Reg Guide 1.8, Regulatory Position C.l.j. 

Q. 116. When an applied science degree is being considered, what constitutes 

an acceptable degree? How do we know what specific degree allows someone to be 

an instant SRO or whether he must first be an RO? 

A. The staff reviews those and we use our best judgment, as do the people in 

the regions, in making a determination based on an application. If you feel 

that an application has been unfairly rejected, you can request reviews by regional and headquarter 1 s management. If you want to bring it up through a review, we can certainly do that on a plant-specific basis. 

Q. 117. Is it true that in the future it won't be a problem, because you won't 

check up on us? If we send an application in saying someone 1 s an SRO, will you 

accept the application because you won't know what degree he has because it 

won't be listed? 

A. It's our understanding that the determination will be made in accordance 

with guidelines that have been established under your INPO-accredited program. 

NUREG-1262 29 
The Commissi?n has made a determination that we're going to trust the industry 

and let the industry programs be operative in the area of training and qualifications under the policy statement. We understand generically what those commitments mean, and we've reviewed them quite closely. 

If we find that they're being abused, either through an inspection program or 

through any other vehicle, that's going to cause grave concern as to whether 

the industry is able to police itself and act responsibly, given what we have 

delegated to you through those programs. 

We've been on team visits and at board meetings and we've seen utilities being 

put through their paces to describe what mechanisms they use to review and make 

determinations about the eligibility for candidates to enter into training and 

whether they are qualified to perform in that job position. 

What we're saying is that we believe that process is the appropriate one to use. 

If you do that in a straightforward, rigorous manner, that's what we're looking 

for. We're not going to nit-pick and second-guess your judgments, provided you 

have an adequate basis for them and provided they are consistent with what has 

been approved generically through the accreditation process and the guidance that INPO has issued. 

Q. 118. Are documents referred to, such as NUREG-0737, still required as 

references? 

A. Revision 2 of Regulatory Guide 1.8 supersedes NUREG-0737 as it relates to 

operator licensing. However, there may be some aspects of NUREG-0737 which 

have been committed to in a facility training program, and the initial program 

may not yet have been accredited. Those commitments are still in effect. They 

are part of the approved program, and remain so until that program is superseded by an accredited program, and you provide the letter to the staff, as is 

described in Generic Letter 87-07 which forwarded the Rule. 

Q. 119. It seems that Regulatory Guide 1.8 says a diploma or equivalent is 

required only for the shift supervisor and senior operator. ANS 3.1 requires only a high school diploma for licensed operators. ls that what you intend? 

A. Yes. The intent of the exception taken in regulatory position C.l.d. was 

to eliminate the 30 and 60 semester hours of college-level education from the 

shift supervisor and SRO positions. The definition section in ANS 3.1 includes 

the General Education Development Test as the equivalent to a high school 

diploma, and it would be acceptable for all three positions. 

Q. 120. 10 CFR 55 provides allowable training exceptions from this rule if a 

systematic approach to training is used. Reg. Guide 1.8 however, does not 

state that there are allowable training exceptions from following ANSI/ANS 3.1 

for ROs and SROs. Please explain why exceptions were not allowed for RO and 

SRO training when a systematic approach is used. 

A. Exemptions are allowed under Section D, Implementation, of Regulatory 

Guide 1.8, which states that the guidance in Section C does not apply to those 

training programs which have been accredited under an accreditation program 

which has been endorsed by the NRC. 

NUREG-1262 30 
WRITTEN EXAMINATIONS AND OPERATING TESTS 
General Issues (Including Learning Objectives and Examination Question Bank) 

Q. 121. Will the format of the written exams change? If so, how? 

A. At the present time the format of the examinations is not expected to 

change, although there are numerous initiatives under way which may lead to 

format changes in one way or another as we refine the process. 

Q. 122 .. The exam content states that Licensee Event Reports (LER) will be included in the exam. How is the scope of LERs determined and communicated to 

the individual taking the examination? 

A. We expect your training program to include relevant LERs. We would sample 

from your learning objectives, but we would not necessarily be limited to those. 

We would not take an LER from a significantly different plant and try to adapt 

it to your plant. But if there were LERs that reflect either training needs or 

operational safety, we are going to include those in the exam process. It may 

be in the written exam or on the operating test. 

Q. 123. Will there be any effort by NRC to ensure a consistent level of detail in the facility 1 s learning objectives? 

A. Yes. We have a major effort under way to evaluate the quality of learning 

objectives that are submitted for an exam. This is a significant issue because we have seen a large spectrum of differences in learning objectives. 

As a part of our examination development efforts, we have been reviewing the 

quality of the learning objectives submitted with materials for the 90-day 

letters. We 1 re evaluating their quality and using that as a feedback mechanism 

into the evaluation process for how well accreditation is working. 

Where we find that the learning objectives are not adequate, we 1 ll use other 

materials. Where they are adequate, we will use them. We intend to evolve 

over time to the point where we can construct an NRC exam solely using the 

facility learning objectives. 

We have also opened our examination development training program to INPO and 

others, providing information to them on how we construct examinations and on 

the training that we 1 re providing to examiners. There are also activities 

underway within INPO to improve development of testing objectives. 

Q. 124. How does the Commission intend to implement written examinations based 

upon the knowledge, skills, and abilities identified in the learning objectives 

derived from the systematic analysis of licensed operator duties? 

A. It 1 s our intent, as expressed in the Statement of Considerations, to reach 

the point where the training program 1 s learning objectives become the major 

source for our examination. We want to sample according to a scheme that looks 

at the most important job performance, knowledge, and abilities, and we have 

that area documented with our K/A Catalogs. In fact, there 1 s a supplement to 

the PWR Catalog being published that has the same sections as the BWR Catalog. 

NUREG-1262 31 
In addition, we asked a PWR and BWR panel of subject-matter experts to rate 

the testing emphasis they thought we should have. That rating forms the basis 

of NRC 1

s sampling plan, so we will sample the most important job content. What 

we expect in terms of conditions and standards of performance will be driven by 

the learning objectives, and that will form the basis of our testing objectives. 

The only slight difference between testing and learning objectives has to do 

with the context in which you judge performance, because one is a time-limited 

testing situation, and the other might allow a longer training or job performance period. 

We don 1t want our exam to be devoid of contact with your training program. The 

purpose is to get to the same spot. Of course we reserve the right to look at 

LERs and other events, and to further investigate other ques.tions, with your 

assistance, manuals, license amendments, or other materials, because even if we 

judge our question in terms of your learning objectives, the material to develop the question and the answer has to come from something other than the 

learning objective. 

Q. 125. What, if any, utility actions will NRC require to incorporate utility learning objectives into the NRC testing objectives? 

A. The better your materials are, the more closely they are keyed to our K/A 

catalog, the easier it is for us to use them. But we 1 re not going to require 

any actions. In the 90-day letters that go out prior to the administration of 

an exam, we 1 re requesting that learning objectives be submitted, and we're 

evaluating them, and if they are appropriate for use in our exam, both the 

written and the operating test, we would employ them to the extent that they 

are consistent with our sampling plan in the Examiner 1 s Handbook and the K/A 

Catalogs. 

We 1ve been training examiners to look at learning objectives and to use them 

for testing objectives. To the extent that you can provide material to the 

examiner where the learning objectives provide a standard of performance and 

you key the training materials in which the material to develop that question 

is available, and if you know a K/A in the catalog with an importance rating 

that 1s above 2.5, you will have provided the basis for developing a good question and a good examination. 

Our experience is that the learning objectives may have conditions and standards 

of performance, but the supporting training materials are not there to develop 

the appropriate questions or they 1 re cast in such a way that it 1 s unclear 

whether they are related to a K/A associated with job content having a relatively high safety significance. 

We also did not want to see the 11 enabling objectives, 11 because these are for 

training purposes and are not grounded in job performance. We want objectives 

that are 11 terminal, 11 and have to do with job performance; and the better the 

material is that you supply, the closer our exam will mirror those objectives. 

we•ve spent a great deal of time looking at how one judges a question based on 

the learning objective so that the question will elicit the kind of performance 

or knowledge or response that lets us infer that the person has mastered that 

particular aspect of the job. 

NUREG-1262 32 
There's a related issue. We issued Generic Letter 87-01, which announced the 

availability of the NRC Examination Question Bank, and indicated the mechanisms 

by which utilities could request the information on what's contained in the 

bank on their facility or similar facilities. It also indicated a mechanism 

for you to update questions on the bank, either where we have inaccurate references or the design of the facility has changed. 

We purged the bank of questions that were more than two years old because some 

of the older questions did not meet today's quality standards. In some cases, 

we have only four or five examinations on the bank for a particular utility. 

We want to improve that and are interested in your comments and/or questions 

for the bank. We'll also provide the bank to you for creating your own questions. To the extent you provide us information that's in a format which is 

compatible with loading into the bank, we can do that directly, either through 

hard copy or electronically. But for security reasons, we can't give you direct access to the bank. We have discussed with INPO the need for an industry 

initiative to validate a set of plant-specific questions that could be a source 

for NRC exams. 

Q. 126. If the utility has established some internal guidelines of what they 

expect of the individual, will you accept those guidelines for the purposes of 

written examinations? 

A. Yes. We would have an issue that we would discuss with the utility, that 

we would want to revise the guidelines if they did not conform to our testing 

blueprint based on the job-related knowledge and ability statements with high 

safety significance. 

Q. 127. Can we submit that in advance of the written examination, and then come 

to an agreement somewhere up front? 

A. It can be part of the materials that you submit in accordance with the 

90-day letter, and we would consider that in developing the exam. 

Q. 128. You mentioned a training program for the examiners on writing the 

learning objectives. How is that program being instructed; who's teaching 

that? 

A. We started several years back working on writing multiple choice questions, 

and have been doing one-week training sessions in all the regions, twice at 

headquarters, and once each for contractors. During the one-week training. 

session, examiners converted learning objectives into testing objectives and 

practiced writing testing objectives. 

We've shared that information with INPO and have had INPO staff participate and 

take the materials back with them, so the information that we're using to 

develop examinations is available to you through INPO, or even through the staff 

if you want to request it. 

Written Examinations and Operating Tests (Statement of Considerations) 

Q. 129. In the Statement of Considerations, under Part D, Written Examinations 

and Operating Tests, it says: "Learning objectives derived from job-task 

NUREG-1262 33 
analyses should form the basis for licensing written examinations and operating 

tests at a facility. Ultimately, the NRC testing objectives will reflect facility licensee-developed learning objectives. In the interim, while programs 

are being developed and reviewed for accreditation, the NRC has activities 

underway to improve the content validity of NRC examinations and operating 

tests." Will NRC commit to solely using the learning oojectives for plants that have accredited operator programs? 

A. .No. The rule states that the learning objectives will be used in part, but that other things, like LERs, etc., will also be used. 

Q. 130. Why are written examinations only taken in part from learning objectives? 

A. The hope is, eventually, to take the entire written examination from learning objectives. However, at this time, there are many places where the 

learning objectives are somewhat incomplete or inadequate. So, we utilize 

LERs and other training materials, such as lesson plans, system descriptions, and procedures, to supplement the learning objectives. 

Q. 131. When will NRC activities underway to improve the content validity of 

NRC examinations and operating tests be complete? 

A. We view this an an ongoing activity. We have a number of initiatives 

scheduled for completion in this fiscal year, including the revised Handbook 

(NUREG-1121), passing-point workshop, and the supplement to the PWR K/A Catalog (NUREG-1122) to conform to the BWR K/A Catalog (NUREG-1123). 

By the end of this fiscal year, a number of milestones toward meeting that 

objective will have been met. But this is a continuing process, as we work 

toward a common understanding of what's necessary for assessing job performance. With the advent of the K/A Catalogs, we've made significant improvements in basing test content on the operator's performance-based job requirements: that is the essence of content validity. We have used a systematic 

process involving subject matter experts. We have supplemented the PWR Catalog, which now has a theory and component section similar to that in the BWR 

Catalog. 

In addition to that, we have been looking at alternate ways to sample the content of the NRC written exam. At present ES-202 and 402 weight all four sections of the exam equally. We've looked at a way of sampling according to the 

sections in the Catalog. The differences would reflect differences between RO 

and SRO positions. We'll sample more heavily in plant systems for ROs and more 

heavily in emergencies that have fewer normal and more integrated plant responses 

for SROs. The final decision on that will be made based on the recommendation 

of a Panel made up cf industry representatives and NRC contractor personnel that 

will meet May 18th through the 22nd. 

We will consider the panel's recommendations to us before we make any recommendations to change the format of the NRC exam. That sampling plan from our Catalog and your input on your learning objectives should, in fact, be the essence 

of a content-valid exam. 

NUREG-1262 34 
Q. 132. I've heard different people say that all NRC exams are now based on the 

K/A Catalog. Are all NRC Examiner-Contractors held to that Catalog as a 

standard? 

A. Examinations prepared by Contract Examiners are reviewed in the Region so 

the standard for the regional Examiner and the Contract Examiner is not different. Like regional examiners, the Contractor Examiners are required to 

write an examination which meets the requirements of the Examiners' standards, 

which now reference the Catalog and will, in a future revision, also reference 

the handbook. 

We are sensitive to feedback from the exam process. We look at the facility 

comments generated during the exam review process. We intend to be very responsive to comments that point out any differences between a contract exam 

and one administered by NRC examiners. 

*Q. 133. Is the new rule going to change the format of the exams (e.g., largely essay-type)? 

A. The new rule does not alter the format of the exam. The current Examiner 

Standard, ES-202, permits a maximum of 25 percent objective-type questions 

(e.g. multiple-choice, true-false), a maximum of 25 percent longer essay-type 

questions, and a minimum of 50 percent short-answer questions in Sections 2-4 

and 6-8 of the exam. Exam Sections 1 and 5 (reactor theory and thermodynamics) 

can consist of a greater portion of objective-type questions. 

We're working on the issue of a generic exam--a prototype, objective exam for 

theory and component operation. 

Q. 134. Have you pilot-tested Form 157 or have you had any practice with it? 

A. No. The new Form 157 will be available after May 26. We'll be revising it 

as necessary, based on our feedback from field use. 

Written Examination: Operators (Subpart E, Section 55.41) 

Q. 135. The items in 55.4l(b)(10) and (13) have previously been for senior 

operator knowledge. What level of knowledge is expected for the reactor 

operator? 

A. Part of 55.4l(b)(l0), has been for operator knowledge in that it concerns 

normal, abnormal, and emergency operating procedures for the facility. For 

the administrative part, the reactor operator would be tested for the depth 

of knowledge required for his job position in the administrative area because 

operators get involved with administration at times. And Part (13), "Procedures 

and Equipment Available for Handling and Disposal of Radioactive Materials and 

Effluents," would also be geared to RO job requirements at your site. 

Q. 136. Part 55.41, "Content," does not specifically address that licensed 

operator candidates need to know Technical Specifications, yet the examiner 

standard, Section ES-202, discusses the need to know Technical Specifications. What is the reason for this difference? Is ES-202 correct in its application 

for Technical Specification knowledge? 

NUREG-1262 35 
A. Section 55.41(5) addresses the Technical Specifications. We expect operators to use Technical Specifications as appropric:e to their job. Reactor operators, as in 55.41(5), are expected to know limiting conditions, particularly 

those things they should recognize and communicate to the SRO in a timely manner. 

The same thing goes for the SRO. We don't expect SROs to be engineers. So 

required job performance in your systematic evaluation, plus our K/A Catalog, 

should give you an idea of the level of specificity. We intend to revise the 

examiner standards to give our examiners better guidance. Right now, it's not 

as clear as it could be, but required job performance is the key, and if, for · some reason, you feel you use Technical Specifications differently than we can 

interpret, you should call that to the Region's attention and discuss it long before the exam occurs. 

There is clearly a difference between our expectations for ROs and SROs by virtue 

of SROs directing the activities of others. The SRO must know all aspects of 

license conditions. He approves work, work orders, and other things which 

require a knowledge of Technical Specifications beyond the material covered in 

the operator's written exam. 

We don't expect the SRO to be able to develop a basis for a requirement on his 

own. We expect him to understand what the requirement is, and be able to carry 

it out. That's the difference that we tried to articulate in these two sections. 

An RO doesn't have to know about approving surveillances, yet surveillances are 

covered in the Technical Specifications. An RO does need to know about limits 

on operation of the plant, as they relate to the list of items under the written 

examination. 

Q. 137. For facilities that have an approved INPO-accredited performance-based 

training program, what percentage of the written and/or oral exam questions 

administered by NRC will come from the facilities• objective-based exam bank, 

or at least from the facilities• training objectives? From Attachment A (to 

Generic Letter 87-07) it appears that all the exam questions for accredited 

facilities will come from the facilities• training objectives. 

A. Eventually, we'd like to use the facilities• learning objectives. But, 

it's our experience that we have varying degrees of polished objectives. We've 

also found that even when there is a good objective, where the conditions of 

performance and the standards of performance are explicit, and the learning and 

the mastery is all tied to job performance, the supporting materials submitted 

with the 90-day letter do not allow examiners to develop the kind of question 

that will elicit the appropriate material to decide whether the candidate has 

mastered that objective. So while the objective may be good, the supporting 

material isn't sufficient to develop the right kind of question. 

We're working on this. And we key the content of our exam right now to the K/A 

Catalog. We do not sample those items that have been found to have a low importance to safety. But we have to rely on your analysis to help determine 

what's important on a plant-specific basis. 

And this is where there's some breakdown at the moment. The better the learning 

objectives in terms of their explicit statement of conditions and standards, the 

better the supporting material, and the better it's tied to our Catalog, the 

better the whole system works. 

NUREG-1262 36 
But don't read into that that we would be limited to those objectives. We would 

sample, we would tie it to those objectives; but if there isn't an objective in 

the safety-related system that we think is important, we may create our own 

test objective and cover it on the exam. 

We're going to try very hard to ensure that it is safety related, it is operationally oriented, and it is performance based. Obviously we would want to 

have good justification for asking that kind of a question. 

Many of·you have used the INPO Job Analysis in your own plant-specific analysis. 

And part of the reason that we tied our analysis at the generic level to the 

INPO Analysis was so that the system names and numbers, and the resulting 

material, would be easily keyed at the plant-specific level to the K/A Catalog. 

Q. 138. What will the Commission do to ensure that operator exams are both 

valid and reliable from a psychometric perspective? 

A. Many things. One: We 1 re working on a sampling plan developed by subjectmatter experts that will better reflect the job of the operator as opposed to 

the four evenly weighted written exam sections currently in the Examiner's 

Standard. 

Two: We'll be sampling only those items that received a high importance rating 

to ensure the exam's content validity. 

Three: We have a meeting on May 18th in which we're bringing together another 

panel of experts first to evaluate our proposed sampling plan and document the 

basis for our passing point. 

Four: We are conducting continuous, extensive training with our examiners on 

writing and reviewing questions, and we are evaluating feedback from the industry 

on the quality of our examinations. 

Finally, we are continuing to make improvements to the exam question bank, which 

will include a validation process using statistical techniques to eliminate poor 

questions. 

Q. 139. The statement of considerations makes the following statement: "Ultimately, the NRC test objectives will reflect facility licensee developed learning objectives ... 11 With an INPO-accredited program already developed from a 

job-task analysis (JTA), does our training standard (site-specific learning 

objectives) supersede the NRC Knowledge and Abilities Catalog? How do we get 

regional concurrence that they will test to our training standard? 

A. It's our intent to use site-specific learning objectives as the basis for 

our testing objectives. However, if we detect errors of commission or omission 

in the site-specific reference material (including learning objectives), we 

obviously will not shape our exam content to those errors. 

Q. 140. Criminal violation only covers persons who willfully violate the Atomic 

Energy Act or NRC's regulations, and does not apply to situations such as 

discussions after an examination is administered or when a previously administered examination is used as a practice exam. What is the attitude of the 

NRC concerning distribution of the facility 1 s examination bank to the examinees? 

NUREG-1262 37 
A. NRC has no specific policy concerning the distribution of the facility 1 s 

own examination bank to their examinees. While some portion of training may be 

given using previously administered examinations as references, this should not 

be interpreted as NRC endorsement or acceptance of such a practice exclusively. 

Written Examination: Senior Operators (Subpart E, Section 55.43) 

Q. 141. The Commission Policy Statement on Technical Specifications and improvements may result in a substantial increase in scope and documentation. 

Will any effort be made to limit the knowledge required of senior operators to 

those elements of the Technical Specification basis that are essential for safe 

operation? 

A. Yes. We have an ongoing program looking at the issue of what needs to be 

examined at the SRO level, as opposed to the RO level. And we are working with 

the people developing these new Tech Specs and intend to make sure that we are 

producing a performance-based exam. 

That 1s not to say that there won 1t be some additional exam material that comes 

from the new Technical Specifications. But, again, it will be performance 

based, job relevant, and safety-significant material, and we will provide ample 

guidance to the examiners, in the examiner standard, as this program develops. 

Q. 142. When we were developing standardized Techical Specifications, the requirement was that an operator know from memory, and be able to apply 11 onehour-or-less,11 action statements from the Tech Specs. Since standard Tech 

Specs have come in, there are now well over a hundred one-hour or less action 

statements from Technical Specifications. Is the policy, or the guidance from 

the Commission still the same, to commit those to memory, recognizing that the 

utilities do not rely on nor require the operators to act from memory in that 

situation? · 

A. We are dealing with performance-based knowledge that an operator needs to 

know. Specifically, if the information is appropriate to the job, if it is 

in the K/A Catalogs with a high importance rating, he should know that information. If there is not a specific knowledge or ability associated with it or 

those that are have a low importance rating, then normally it would not need 

to be examined. However, there may be procedual steps or other indications 

that cause him to look into the Technical Specifications. The method you use 

procedurally in the plant for these indica~ions, through performance-based 

testing under certain circumstances, such as procedural or event-related problems, would be the method that would be followed by NRC. We don't have any 

blanket rules that require memorization of everything in Technical Specifications that has to be done in less than an hour. That is not our policy. 

Ensuring that our examinations are operationally oriented and job related is 

our policy. 

Q. 143. Senior operators are required to know the facility operating limitations in 

the Technical Specifications and their bases. If and when the Westinghouse 

Owner's Group completes development work and gains acceptance for the Technical 

Specification MERITS program, this will vastly increase the bases section of the 

Technical Specification. Will the NRC position change regarding the requirements to know the Technical Specification bases if this new program is 

implemented? 

NUREG-1262 38 
A. No. As we implement improvements to Tech Specs, we hope to reduce their 

size substantially as a result of this program and to do a better job of 

describing the why 1 s associated with the limits and the underlying assumptions that relate to them. 

We hope that in the long run we will better define the knowledge that a senior 

operator should have related to the Technical Specifications and their bases. 

We don't expect that the volume of the bases to increase to several three-inch 

notebooks. It should be significantly reduced compared with what's contained 

in the FSAR. It's going to require a topical report submission and an approval 

by the staff before it can be implemented on a plant-specific basis. We will 

be looking at generic bases, and there will be an opportunity for utilities to 

comment. 

Our intent is not to add superfluous information; it needs to be related to the 

job. 

Q. 144. Section 55.43(b)(3) refers to the facility licensee procedures required to 

obtain authority for design and operating changes in the facility. What is the 

intent of this? Should the SRO understand the process the licensee goes about 

in obtaining a design change? 

A. There may be administrative procedures which would allow, for example, two 

SRO's on a back shift to change a procedure, as long as they don't change the 

intent of the procedure. Or, there may be other aspects of the 50.59 review 

process which an SRO is .he 1 d accountab 1 e for knowing. He may be the shift 

supervisor, on shift at the time, responsible for those activities. And it's 

that type of administrative procedure we are addressing. 

Q. 145. Therefore, are we talking about temporary alterations, not design 

changes, or permanent license changes? 

A. He needs to understand what he's approving when he approves the work to be 

done in the plant. We're looking principally at those things which he can approve; deviatation from a procedure, an alternative approach, etc. The 50.59 

type process, how those changes are controlled, and what it means when he signs off to approve a work package, is likewise important. This process may change the design of the facility, or change the way the facility is operated by a 

procedure. For clarification, there has been no change in this area from the 

previous Part 55. 

Q. 146. What maintenance activities are included in 55.43(b)(4)? 

A. Section (b)(4) talks about radiation hazards that may arise during normal 

and abnormal situations, including maintenance activities, and various contamination conditions. A common item may, for example, be a radiation work permit (RWP). He may be responsible for signing off, either in concurrence or approval, depending on the facility, on the RWP, so he would be expected to have sitespecific knowledge in that area. 

Q. 147. Part 55.43 does not specifically address emergency plan implementation. 

This is addressed in Part 55.45. Will the senior operators continue to be asked 

to classify events, given a specific scenario, into.four categories (UE, Alert, 

SAE, GE) from memory on the written examinations? 

NUREG-1262 39 
A. Item 5 in Section 55.43(b), stipulates that SROs must be able to address 

the "assessment of facility conditions and selection of appropriate procedures during normal, abnormal, and emergency conditions. 11 However, neither ROs nor 

SROs are required to classify events from memory. 

Operating Tests: Content (Subpart E, Section 55.45(a)) 

Q. 148. Is there a definition of plant equipment that could affect the release 

of radioactive materials to the environment, per 10 CFR 55.45(a)(8)? 

A. There are many systems and many controls that an individual can operate that could cause a release; operators are required to understand these systems and controls, which are the responsibility of licensed personnel. 

Q. 149. Does 10 CFR 55.45(a)(l0) imply that operators must perform exposure shielding calculations? 

A. That depends on how these calculations are made at your facility. If you have an on-shift health physicist or, in an emergency, an STA, then we would 

not ask operators to do the shielding calculations. But if the SRO typically checks such calculations, then we may ask the SRO to check one. 

Q. 150. Items 12 and 13 of Section 55.45(a), were reworded to include the 

phrase "as appropriate." What is the significance of this phrase for the Commission to classify this change as "major" in the final Regulation? 

A. The comparison that we're making in the Statement of Considerations, Section IID(2), is between the proposed rule published in November 1984 and the 

final rule. Items 12 and 13 were significantly rewritten between the proposed and the final rule. To clarify, we have made sure that you're held accountable 

for performing as appropriate to the assigned position. So ROs are not expected 

to pass a test at the SRO level. 

Q. 151. How will you evaluate Item 13, "Teamwork," in the operating test? I'm 

talking about the operating test itself, when you have to evaluate one single candidate on how he reacts and interreacts with the team? 

A. You could put some licensed operators on the team with him, and we would 

just put an examiner with the individual taking the exam. You could have one 

of your instructors standing there, as we have done in the past. 

Q. 152. How would you evaluate this if we didn't have a simulator? 

A. It is the responsibility of the examiner to structure his operating test 

scenarios for the Integrated Plant Operations portion of the test that would 

create situations that would challenge the candidate in competencies G 

(communication/crew interface) and H (responsibilities/supervision). ObviDusly this would require a discussion format since the operating test without a simulation facility is a one-on-one test. For example, a scenario could have an 

SRO candidate evacuate the control room. He would then be expected to shut down 

the reactor from the local shutdown panel. He should be able to talk through how he would utilize his resources, including direction, communication, and 

report backs. Questions would be phrased as follows: What would you direct 

NUREG-1262 40 
the BOP to do? What reports do you expect to receive from the RO upon reactor 

trip? How would you verify a questionable report from the BOP/RO? How do you 

evaluate the licensed operator's use of nonlicensed operators during local 

operation of an auxiliary feed pump? 

Q. 153. Part 55.45(a) contains a new evaluation criterion which requires an 

applicant to demonstrate the ability to function within the control room team 

as appropriate to the assigned position and in such a way that the facility licensee's procedures are adhered to and so that the limitations in its license 

and amendments are not violated. Is this criterion intended to be evaluated 

using the manipulation criteria addressed on the operating examination report 

contained in ES-302 which requires that an applicant: (1) follow procedures, 

(2) observe and check instrumentation, (3) exhibit dexterity and a feel for 

console operations? Or, will this evaluation be addressed in a future revision 

of ES-302? 

A. This criterion is addressed in the operating test using the existing ES-302 

with the new Form 157. Specifically, the form identifies, in competencies G and 

H (both with and without a simulator), the evaluation of communication/crew 

interaction and responsibility/supervision. 

Waiver of Examination and Test Requirements (Subpart E, Section 55.47) 

Q. 154. In 10 CFR 55.47, what is a comparable facility? 

A. This question addresses the waiver of written examination and operating 

test requirements. We would look at each waiver on a case-by-case basis, and 

make a determination as to whether or not the facility was, for licensing purposes, "close enough. 11 

NUREG-1262 41 
SIMULATION FACILITIES 
Written Examinations and 0 Tests: Im lementation (Sub art E 

Section 55.45 b 

Q. 155. Will NRC continue to examine operators on plant-referenced simulation 

facilities following the effective rule date, but prior to the submittal of the 

simulator certification? 

A. Yes. If we 1re giving exams on your simulator now, we will continue to do 

so. 

Q. 156. Will NRC examine operators on nonplant-referenced simulators for those 

utilities that have accredited training programs and use a nonplant-referenced 

simulators between the date that the new rule becomes effective and simulation 

facility approval by NRC is achieved? 

A. We anticipate no change from what we 1 re doing today. 

Q. 157. Our facility will not have a plant-referenced simulator available for 

training until the first quarter of 1990. It is assumed that operating tests 

will consist entirely of plant walk-throughs until such time as a plant referenced simulator is certified. Is this a correct assumption? 

A. Yes, but in the event the utility were to start using that simulator to 

evaluate candidates prior to the time at which they chose to certify it, we'd 

have no problem with the examiners using it to conduct operating tests. 

Q. 158. Are the provisions of 55.45(b)(2)(i), and 55.45(b)(2)(iii) mutually 

exclusive? In other words, if the utility plans to meet the provisions of 

55.45(b)(2)(iii) by purchasing a simulator during the 46-month period, does 

the utility need to submit a plan per (b)(2)(i) for the simulator to be used 

until the plant-referenced simulator is certified? 

A. No. If you intend to certify a simulation facility on Form 474, you have 

46 months from the effective date of the Rule to do that, and you do not need 

to submit to us a plan, or an application, prior to that time. If, however, 

we do not see any evidence that there are plans in the works for a certified 

simulation facility, and if we have not seen a plan from you for a noncertified 

simulation facility, we'll probably get in touch with you to find out what your 

intentions are. 

Q. 159. We currently have a site-specific simulator, and it has been used to 

administer the simulator portion of the operating tests. Do we have 46 months 

from the effective date of the rule to submit Form NRC-474, "Simulation Facility 

Certification"? Will the simulator tests continue to be administered on our 

noncertified simulator before we submit the Form 474? Under what conditions 

would NRC refuse to administer operating tests on the simulator? 

A. Yes, you have 46 months to submit Form 474, and, yes, the simulator will 

continue to be used for the conduct of exams until you submit that Form 474 or 

until you reach the four-year deadline. NRC would refuse to administer operating tests if the simulation facility has not been certified by the deadline or 

if, after it has been certified, an inspection proves that it is unable to meet 

NUREG-1262 42 
the requirements of conducting an operating exam. And, if certification is 

pulled, then it needs to be recertified. 

Q. 160. For simulators that are not plant specific, when the regulation goes 

into effect in May, are you going to start giving nonplant-specific simulator 

exams? 

A. No. We do not intend to administer such exams. Those few plants without 

plant-referenced simulators will be handled on a case-by-case basis. 

For clarification, once a utility begins to use a simulator to evaluate its 

operators, we would retain the option to use it to conduct our operating 

tests, even though it may not yet be approved or certified. 

It's our intent to continue with business as usual from the effective date of 

the regulation until such time as you either have an approved simulation facility, or you have certified a simulation facility. Or, of course, the four-year 

deadline arrives. 

In other words, if we presently conduct operating exams in a walk-through because 

you do not have a plant-referenced simulator or you do not have an acceptable 

simulation facility, we would continue to conduct exams on a walk-through basis. 

But if you do obtain a simulation facility between now and the date that you 

chose to certify it, if you find the sfmulation facility is acceptable for your 

use in evaluating operators then we will find that same simulation facility 

acceptable for our use in evaluating operators, even prior to the time it is 

certified or approved. 

One other clarification. It does not matter who owns a simulation facility, 

or where it is located--the key is the plant to which it is referenced. And 

the facility licensee is the one who must certify that simulation facility for 

use regardless of whether that facility licensee is the owner of that simulation 

facility or not. 

Q. 161. Several simulators are still in the manufacturing pipeline, to be delivered in the next two years, while a few are still just beginning their procurement activities. Is this plan required within one year regardless of 

whether the utility is in the process of procuring a simulator? 

A. The plan referred to is required only for those utilities which are not 

planning to submit a certification on Form 474. If you are procuring a certified simulation facility, there is no plan required and there is no application 

for approval required, regardless of where in the pipeline your procurement is. 

If you are not procuring a simulation facility that is to be certified on Form 

474, then there is a plan required and there is an application for approval. Then the answer is yes, we would expect that plan to be submitted to us within 

one year of the effective date of the regulation, regardless of where you may 

be in the procurement cycle. 

Q. 162. Consider the utility undergoing the simulator procurement process right 

now. There is certainly the realistic possibility that that simulator will 

NUREG-1262 43 
not be delivered and declared ready for training until sometime in 1990. At 

that time it will be approximately two and a half years since design data 

freeze. 

In that period it's reasonable to expect that the utility would not be able to 

meet the requirement of ANSI/ANS 3.5, 1985 that the plant reference simulator 

be current within 12 or 18 months of the reference plant, to which you are 

attesting when you sign the material-false-statement on Form 474. Does this 

mean that this utility would have to submit a plan for an alternative within 

12 months of May 1987? 

A. We would still expect a certification from those utilities on Form 474, 

rather than the application for approval. If necessary, you would take excep- tion to meeting some of the requirements of ANS 3.5. These would have to be 

identified and described, along with a description of when and how they would 

be resolved. There is a provision on Form 474 for this information to be 

supplied. 

Q. 163. In other words, they would not be held to the statement that says they 

are or are not in compliance with ANSI 3.5? 

A. That is correct. The facility licensee would address them as exceptions to 

AKS 3.5. 

Q. 164. I didn't see on the proposed Form 474 an area that addresses exceptions. 

A. Ther~ is such a block on the form. It might not have been on an early version pf the form; but on the final version you will see an area near the 

top which indicates exceptions taken to the standard. 

That's not an unusual circumstance just for those who are buying new simulation 

facilities. Because design modifications are made in the plant, you may at the 

time of certification have modifications made in the plant that you have not 

yet put into the simulation facility. 

The process provides for reference plant data and design data for the simulation facility, and there can be as much as two years' difference between the 

time these two conform with one another. If you're not in conformance at the 

time you certify, if there's some exception, identify that in the exceptions sections and indicate on what schedule you're going to correct it. 

If we disagree with the exceptions, we'll visit you. But if you've done a 

reasonable job of identifying them and we still conclude that we can conduct 

an operating test, we'll accept that certification. 

Q. 165. In Section 55.45, implementation schedule and simulation facility certifications, what is the relationship of the two timetables provided in 

(b)(2)(iii), which is 46 months, and (b)(3)(iii), which is 60 days? 

A. There is no relationship between them. The 46-month requirement in 

(b)(2)(iii) refers to facility licensees, which includes anyone who has a docketed application. The 60-day requirement in (b)(3)(iii) refers only to what 

we call facility applicants, which includes only those without docketed appli- cations. So you can ignore that 60-day requirement. 

NUREG-1262 44 
Q. 166. Do we have a requirement to certify a simulation facility to NRC prior 

to its being used for an operating exam? 

A. No. You have a requirement to certify a simulation facility to NRC no later 

than four years after the effective date of the regulation. Prior to that 

four-year deadline, it can still be used for conducting operating exams whether 

it is certified or not. 

Q. 167. Due to the extensive use of the simulator for training, there may be 

times that meeting the 25 percent performance testing requirements within 12 

months of the last set of tests is not possible. What is the allowable time 

table tolerance regarding this situation? For example, is it permissible to 

perform 50 percent testing in one year and no testing in the next year, as long 

as 100 percent testing occurs every four years? 

A. The regulation provides, in 55.45(b)(4)(vii) and (b)(5)(vi), that performance testing be done at the rate of approximately 25 percent per year on a 

continuing four-year cycle. The goal is to ensure the ongoing testing and up- grading of the simulation facility, and to assure that it is maintained on a 

consistent basis with the status of the plant. You must present to us, on Form 

474, your performance testing schedule. To the extent that it must deviate 

from 25 percent per year, if it must deviate, you need to let us know just what 

those deviations are and we will have to evaluate it case-by-case. It's safe 

to say that performing 50 percent of the tests in one year, and no tests in 

the next year would not meet the intent of the regulation. 

For clarification, we really don't want to see the minutiae of your performance testing schedule, which tests are to be run on which days of which months. 

We're looking at an annualized 25 percent per year basis, and that's the block 

of time in which we would like to see your performance testing scheduled. Any changes that may need to be made to that schedule, you need to tell us about, 

based on that annual block. 

Q. 168. What is the required retention period for simulation facility test 

procedures, modification documentation, and discrepancy reports? 

A. Four years is the record retention period. But at any given time, you may have accumulated and held on to more than four years' worth of data, because 

you are performing your performance tests at the rate of 25 percent per year. So if you certify, hypothetically, at time zero and then you submit your first 

four-year report on the four-year anniversary of that initial certification, at 

that time in year four you can discard the results of the performance testing that you had for the initial certification. Then when you submit your next 

four-year report at year eight, you can discard all the performance testing documentation that you used to submit the first four-year report. 

So it's a four-year period, but as you accumulate the tests at 25 percent per 

year, you're going to be retaining these test results until the time comes at 

your next report to discard it. 

Q. 169. Regarding decertification of a plant-referenced simulator: What process will be used to decertify a simulator? Will an NRC examiner be able to decertify 

a simulator based on his observations of simulator performance during an NRC 

exam? 

NUREG-1262 45 
A. No. An examiner will not be able to decertify a simulati·..,n facility based 

upon his observations. He will report those observations to NRC, and the staff 

may use that information to perform an audit or an inspection. 11 Decertification11 

can occur only as a result of an inspection which finds that the simulation 

facility is incapable of being used for the conduct of an operating test. 

Q. 170. Section 55.45 requires that within one year after its effective date, 

each facility licensee proposing to use a simulation facility must submit a 

plan detailing how and when their simulation facility will be developed and 

submitted for approval. Must a utility that operates dual units at the same 

plant and that currently obtains a multi-unit operator license from the NRC 

submit this plan for the unit not being replicated? 

A. The key issue is the similarity of the two units. The availability of 

current multi-unit licenses would lead us to believe that you do not need to 

submit an application for approval for the simulation facility for those units. 

We in all likelihood will accept certifications on Form 474 with the exceptions 

noted for each unit. 

Q. 171. If a utility with multiple units believes that the units are too 

dissimilar to support Form 474 certification, what format requirements, if any, does the Commission wish to see in the application for approval? 

A. Here is an example of what we'd expect. Let's assume that you have a 

dual unit control room and that the control rooms are identical with the excep- tion that they're mirror images of each other. Your physical fidelity comparison in accordance with the standard would identify as an exception the mirrorimage layout. 

One Form 474 would indicate that the mirror-image issue was a difference, but 

you conclude that's acceptable for an operating test. And you'd reference the 

certification form for the other unit; that is, you'd identify all the other 

exceptions that you may have. So one is tied to the other. That way we get a 

form that says it's certified for each plant to which it's referenced. 

Where you have a simulator now which is on site and which replicates two units, 

we would expect you to use the certification process. 

Q. 172. Several utilities are not planning to obtain plant-referenced simulators. 

They prefer to use other simulation devices. Assume that a facility licensee 

has constructed and is operating a plant-referenced simulator that meets the 

provision of Regulatory Guide 1.149 and ANSI 3.5 and has been certified to the 

NRC for use for operators and senior operators who operate the reference plant 

or are candidates for a license at that plant. A second utility wishes to use 

the simulator as their simulation device rather than construct and operate a 

plant referenced simulator. What procedure must the second utility follow to 

obtain approval to use that simulator? 

A. The answer assumes that the utility who wants to use it is treating At as 

a noncertified, nonplant-referenced simulator. It does not matter who built 

the simulator, who owns it, where it's located. The facility licensee who 

NUREG-1262 46 
----------- ----------------

wants to use a particular simulation facility for conducting operating tests 

is the organization that is required to file a certification or to apply for 

approval to use it. So in this case, the procedure that the second utility 

must follow would be to submit a plan within a year, followed by the application for NRC approval to use that simulation facility, whether they are the 

owner of it or not. 

Q. 173. Has the staff developed guidance and/or criteria regarding the use of a 

certified plant-referenced simulator by individuals other than those from the refer~nced plant? 

A. It is possible for any particular simulation facility to be certified as 

referenced to more than one plant, to the extent that those plants are similar. 

But only the facility licensee who wishes to use a simulation facility for its 

reference plant should submit the certification for its use. So if one simulation facility is intended to be used by several different licensees for 

different plants, then we would expect to see several different certification 

forms coming in, one for each of those facility licensees. 

Q. 174. Does this guidance apply to facility licensees that wish to use another 

facility licensee's plant referenced simulator? 

A. Yes, but there are some very practical issues that utilities are going to 

have to address in the area of configuration control, plant design changes, 

and getting those plant design changes referenced back into the simulator. 

Some of those can be taken care of with software, by having a different data 

pack, tapes, etc. Others are going to be very difficult to take care of where 

they relate to control board location or systems that you have on the device 

that are different. Clearly, where two utilities want to use the same simulation facility, they are going to have to work out agreements with each other as 

to how they are going to maintain configuration control such that the same 

device can be used for the operating test at each utility. 

We have not precluded that a facility may certify a simulation facility owned 

by someone else to its reference plant; but the requirements for having an 

appropriate configuration control system still exist, and you must still follow 

the ANSI standard. So that if you get into that mode, you may find it difficult over the long term. 

Q. 175. Assume that an entity has constructed and is operating a plantreferenced simulator that meets the provisions of Regulatory Guide 1.149 and 

ANSI/ANS 3.5-1985, and has been certified by NRC for use by operators and 

senior operators at the reference plant, or who are candidates for license. 

A utility wishes to use the above simulator as their simulation device rather 

than construct and operate a plant-referenced simulator. What procedure must 

the utility follow to obtain approval to use the above simulator? 

A. Only facility licensees are to certify simulation facilities to NRC or 

request approval for simulation facilities. If an entity means a facility 

licensee under 10 CFR Part 50, then that's fine. If it means some other 

organizational body, then that would not be acceptable for certifying, or 

NUREG-1262 47 
applying for approval of a simulation facility. It does not matter whether 

that utility owns that simulation facility. It does not matter where that 

simulation facility is located, but it is the utility who must certify, or 

apply for approval to use it. 

If that simulation facility referred to is referenced to a facility licensee's 

plant, then the process to be followed is certification on Form 474. If it is 

not referenced to the facility licensee's plant, then the proper approach would 

be submittal of a plan within a year, followed by application for NRC approval. 

Q. 176. Title 10 CFR 55.45(b)(4)(i) states, 11 In accordance with the plan submitted pursuant to Paragraph (b)(2)(i) or (b)(3)(i) of this section, as appli- cable, submit an application for approval of the simulation facility to the 

Commission, in accordance with the schedule in Paragraph (b)(2)(ii) or (b)(3)(ii) 

of this section, as appropriate." What performance tests are required and what 

standard is used to evaluate whether the tests are satisfactory or not? 

A. To the extent applicable even to those simulation facilities that will not 

be certified, ANS 3.5, as endorsed by Reg Guide 1.149, is the standard to be 

used. The performance tests include the malfunctions identified in Section 3.1.2 of the standard to be done at a rate of approximately 25 percent 

per year over an ongoing four-year cycle; the performance tests that are speci- fied in Appendix A of the standard, also at the rate of 25 percent per year; and the operability tests identified in Appendix B to the standard that are to 

be done annually. 

The criterion for the performance of these tests is that the simulation facility must be capable of being used for the conduct of the operating tests which 

are identified in Section 55.45(a) of the regulation, and the staff will inspect simulation facilities against that requirement. 

Our definition of "plant-referenced simulator" differs from the ANSI standard 

definition in that we require that a simulation facility be capable of being used with the plant's control room procedures, and we would inspect against the 

ability to use those procedures as well. 

Q. 177. Sections 55.45(b)(2)(i) and (ii) state that within one year a plan shall 

be submitted for a simulation facility (other than a plant-referenced simulator), 

and within 42 months an application for use of the simulation facility must be 

submitted. When will the facility licensee know if the plan for the simulation 

facility is acceptable to the NRC? What criteria will NRC use to determine 

acceptability? Can the plan be modified after the first submittal? 

A. The minimum acceptance criteria for nonplant-referenced simulators as 

simulation facilities include the capability for conducting the operating tests 

identified in Section 55.45(a) and their ability to operate under the use of 

the control room procedures. 

The nonplant-referenced simulator alone or in combination with other devices 

must demonstrate acceptability for conducting these operating tests using control room procedures. 

NUREG-1262 48 
The staff will review the plans for such simulation facilities against the 

criteria specified in the regulation for the conduct of the operating tests; 

and to the extent applicable, we will also apply the requirements of ANS 3.5 

as endorsed by Regulatory Guide 1.149 even for nonplant-referenced simulators. 

The staff intends promptly to inform any facility licensee if the staff 1s review of the plan or the application submitted is not satisfactory for being 

able t9 conduct these exams. 

We plan to meet with the small group of facility licensees who have indicated 

an intention to request staff approval of simulation facilities during the 

year following the effective date of the regulation and prior to the deadline 

for their submittal of a plan for application for approval. 

Finally, although we expect that our initial meetings with these few facility 

licensees will result in sufficiently specific guidance that modifications to 

plans won 1t be needed after submittal, we don 1t want to preclude such modifications if the facility licensee judges them to be necessary or desirable. 

Q. 178. The preparation of a simulation facility plan will cost money and resources. If an submitted simulation facility plan is not acceptable, the NRC 

should let the utility know it is wasting its time as soon as possible. If a 

utility submits a plan for an 11 approved simulation facility11 before May 26, 

1988 will the utility receive an indication of whether or not the NRC will 

approve the simulation facility? Or,. will the NRC approve the simulation 

facility only after application within the 42-month period stated in the rule? 

A. The NRC will review the plan submitted by each facility licensee which 

proposes to use a simulation facility pursuant to Section 55.45(b)(l)(i). The 

facility licensee will be provided the results of such review. However, approval of a simulation facility (in accordance with Section (b)(4)(ii)) proposed pursuant to paragraph (b)(l)(i) will only be considered after receipt of 

an application submitted in accordance with Section 55.45(b)(4). 

Q. 179. When a simulation facility evaluation is conducted by the NRC, plant 

operators may be used to perform the operations using plant procedures. In 

this case, are the operators performing on a 11 no risk11 basis to their licenses? 

If not, will the operators receive credit for an operating test? Could certified instructors be used to demonstrate the simulation facility evaluation 

test instead of plant licensed operators? 

A. During a simulator evaluation, no evaluation will be made of plant operators. If clearly unacceptable performance is identified, the operators and 

specifics of their performance will be identified to the facility licensee for 

appropriate action. Qualified simulator instructors would be acceptable for 

demonstrating simulator performance. 

Q. 180. When a malfunction is used during training can we take credit for it as 

a performance test? 

NUREG-1262 49 
A. If all of the requirements of the Perfomance Test including planning, scheduling and documentation as required on Form 474 are met, credit may be 

taken for completion of the Performance Test. 

Q. 181. Paragraph 55.45(b)(4)(i)(B) states 11A description of the components of 

the simulation facility which are intended to be used for each part of the 

operating test 11 must be included as part of a facility's application for approval of simulation facilities. Please elaborate. Does 11 intended11 mean 11 can? 11

. 

A. The word "intended" means that the listed component is that which the 

facility licensee plans to use for the evaluation of a specific one of the 13 

items specified in 55.45(a). 

Q. 182. Assuming that a utility were to submit a plan to certify a nonreference plant simulator as a simulation facility, what minimum criteria would 

this facility be required to meet (since operator testing using reference plant 

procedures would be limited or not possible) and what aspects of the nonreference simulator would disqualify the device from certification as a simulation facility? 

A. The minimum criteria for approval of simulation facility are contained in 

55.45(b)(4)(ii), which requires that it be suitable for the conduct of operating tests for the facility licensee's reference plant. The operating test 

requires that the 13 items listed in 55.45(a) be able to be adequately evaluated, and that plant procedures be used. Further details of simulation facility characteristics necessary for NRC certification are contained in Regulatory 

Guide 1.149 and ANSI/ANS-3.5-1985. For clarification, a non-plant-referenced 

simulator would be developed following a plan and then an application for NRC 

approval. It would not be certified using NRC Form 474. 

Q. 183. For utilities which have not yet received simulation devices from their 

respective vendors, when will they be required to undergo simulator examinations as part of their operating examination? When ready for training? When 

certified by the utility? When utilized by the facility as an evaluation tool? 

Does the above answer change for any facility which currently possesses a 

simulation device, but asks that it not be used for NRC examinations until 

such time that it is certified? 

A. No simulation facilities will be required to be used in the conduct of 

operating examinations until May 26, 1991, unless they have been certified to 

the NRC or approved (after application) by the NRC earlier. However, if a 

simulation facility is used by the facility licensee as an evaluation tool, 

the NRC will use it for exams as well. This would hold true despite any 

request by the utility that it not be used until certified. 

Regulatory Guide 1.149 

Q. 184. In order for a utility to comply with ANSI/ANS 3.5-1985, it would have 

to use a full-scope nuclear power plant control room simulator. The standard 

states the following under Section l, Scope: 11 Also excluded are part-task or 

limited scope simulators intended for specialized training or familarization. 11 

NUREG-1262 50 
This means that non-full-scope simulators would clearly be excluded from the 

Standard, and, hence, a simulation facility that does not consist solely of a 

full-scope simulator has no guidance or standard which a utility may use to 

obtain NRC approval. The previous statement leads us to the following conclusions: If Reg. Guide 1.149 and ANSI/ANS 3.5-1985 become the only standard for 

determining the acceptability of a simulation facility, the simulation facility 

must be a full-scope simulator, is that correct? 

A. No. Regulatory Guide 1.149, in regulatory position (c)(2), takes exception 

to thO"se segments of the Standard that were just cited. The Reg Guide says that 

simulation facilities, as defined in Section 55.4 of the Regulation (and that 

includes the plant, and potentially other simulation devices) should meet 

applicable requirements of the Standard. Also remember that Regulatory 

Guide 1.149 is only one acceptable means of meeting the requirements of the 

Regulation, and that facility licensees may propose other approaches to meeting the Regulation. 

We intend to evaluate those simulation facilities which are other than certified 

plant-referenced simulators on a case-by-case basis, once we get to the point of 

dealing only with the applicable portions of the Standard. 

Q. 185. If Regulatory Guide 1.149 and ANSI/ANS 3.5-1985 do not represent the 

only standard for determining the acceptability of a simulation facility, will 

NRC identify the minimum standards and criteria that are acceptable to them for 

non-full-scope simulators? 

A. Those two documents do describe the only standards. But Regulatory Guide 

1.149 is a Guide, it ;s not a regulation. A facility licensee may propose 

alternative ways to comply with the regulations in Part 55, other than the 

submittal of the information in Regulatory Guide 1.149. 

Q. 186. Does NRC continue to endorse the requirement in ANSI/ANS 3.5-1985 to 

perform annual operability tests? If so, should this be part of the 25 percent 

testing, or should it be done annually? 

A. Yes. We endorse Appendix B on operability testing, and as the standard 

requires, this must be done annually. This is not a part of the 25 percent 

performance testing. 

Q. 187. Section C4 of Reg. Guide 1.149 specifi·es that reference plant modifications be reviewed annually against the simulator and that the simulator update 

design data be revised as appropriate, and that the first such annual review 

and update should take place within one year following the facility licensee's 

certification. Does this mean we have until a year after certification to 

match the simulator update design database to the reference plant or 18 months 

after simulator operational date, as specified in ANS 3.5, Section 5.2? 

A. No. According to Section 5.2 of ANS 3.5, you start with a database which 

may, for nonoperating plants, be based on predicted data. Eighteen months 

after the simulator is ready for training, your simulator update design data 

must include available plant data, unless the simulator is on line before the 

plant, in which case you have 18 months from the date that the plant becomes 

operational. In accordance with the standard, it's whichever is operational 

later, the plant or the simulator. 

NUREG-1262 51 
Sec~ion C4 of Regulatory Guide 1.149 refers not to the development of this update 

design database, but rather to the annual review of reference plant modifications 

that are called for in the same Section of the standard, the results of which 

must be added to the update design database. 

The standard says, 11 Reference plant modifications shall be reviewed at least 

once per year, and the simulator update design data shall be reviewed as 

appropriate. 11 Section 5.3 of the standard goes on to say that the simulator 

shall _be modified as required within 12 months. It is this cycle of the annual 

review of plant modifications, followed within 12 months by simulator modification as required, that we expect will begin with your certification on Form 474. 

The rest of Section 5.2 addresses when your database must include actual plant 

data. And the two time schedules are somewhat independent. 

You must still base the simulator update design data against the reference plant 

within 18 months after the simulator is operational. But you must begin your 

cycle of annual plant review of reference plant modifications when you submit 

the certification. 

Q. 188. Section D, 11 Implementation, 11 of Regulatory Guide 1.149, outlines a 

procedure to be followed for a facility licensee that wishes to utilize a simulation facility at more than one nuclear power plant. Does this guidance apply 

to facility licensees that wish to use another facility licensee's plant- referenced simulator? 

A. Yes. But the facility must certify that the simulator meets the requirements 

of ANSI/ANS 3.5-1985, as endorsed by Reg Guide 1.149, for his plant. In reviewing such certifications, we would be particularly concerned about how you handled 

configuration control. Because you would have the potential for multiple design changes at a facility, we would have to understand how you are going to 

ensure that the simulation facility tracks the different plants. 

Q. 189. What procedure must be followed to determine whether a two-unit site 

will require only one plant-referenced simulator? 

A. There is considerable guidance on this in the 11 Implementation11 section of 

Regulatory Guide 1.149. It says that if a facility licensee wishes to use a 

simulation facility at more than one nuclear power plant, it must demonstrate 

to NRC in its certification, or in it's application, that the differences between the plants are not so significant that they have an impact on the ability 

of the simulation facility to meet the regulations in 10 CFR Part 55.45(a), and 

the guidance of ANSI/ANS 3.5-1985. 

There is a list of indicators that can be used to demonstrate that there are 

not such significant differences. One of the key areas that we will look at 

is whether we issue multiple licenses for your operators of those f~cilities. 

ANSI/ANS 3.5, 1985 

Q. 190. ANSI/ANS 3.5-1985 requires that performance tests be conducted in the 

event a design change results in a significant simulator configuration or performance variation. What is the NRC's definition of significant? 

NUREG-1262 52 
A. Our operational definition is any change to the simulation facility, its 

models or software that might cause the results of performance tests to fall 

outside the acceptable performance criteria set within the standard. The 

standard does not define "significant," and for an official definition, or an 

official clarification, you need to seek guidance from ANS itself. It's possible that this definition will be clarified in the next revision to the 

standard, but unless and until it is, we will use our operational definition. 

Q. 191. This question concerns the list of required malfunctions in performance 

testin·g and ANS 3. 5-1985. Are those not more "events" versus 11malfunctions 11 ? 

Do you understand that this causes confusion on the part of the simulator vendors in that if 1 was to go to a vendor and tell him that I want a reactor trip 

malfunction, he's going to wonder what I'm talking about? Do I want power to 

the CRD breakers? Do I want to lose all reactor coolant system flow? How do I 

want to do this to create the abnormal event that ANSI 3.5 is asking me to perform? Isn't that really referring to a list of abnormal transients? 

A. Yes. 

Q. 192. ANSI/ANS 3.5 Section 3.1.1(7) requires that the simulator be capable of 

performing startup and power operations with less than full rated reactor coolant flow. If the facility licensee is not allowed by Technical Specifications 

to conduct such operations, is this capability still required? 

A. No. If a plant is constrained in any particular area by its Technical 

Specifications, then the simulation facility need not possess that capability 

as it applies to routine operations. 

Q. 193. The Technical Specifications clearly bind the conditions under which 

the plant is allowed to operate. Am I correct that the simulator only needs to 

be bound by the same parameters? 

A. No. For normal startup and shutdown practical-factor evolutions, in 

accordance with your procedures, you need not model those to be outside the 

bounds of the Technical Specifications. The question came up in the context of 11 N-minus-l loop operation"; for instance, continued operation with a recirculation pump out of service or continued operation with one reactor coolant pump 

out of service. You need not model the simulation facility for operation in 

that mode if you are not permitted normally to start up in that mode. It was 

with respect to the context for startup. 

Clearly, emergency procedures, for example, which go into function restoration 

guidelines and go beyond design basis accidents are not covered by Tech Specs, 

but we expect the simulation facility to be able to reasonably model those 

events. The same holds true when you insert malfunctions. If you turn off 

power to a panel, you're clearly outside the bounds of the Technical Specifications. You would not be operating with that panel de-energized. So in general, if you are conducting malfunctions, you may be in that mode. 

Q. 194. ANSI/ANS 3.5 Section 3.1.1(9) states that measurement of reactivity coefficients and control rod worth using permanently installed instruments be 

performed. What is meant by "permanently installed instrumentation?" 

NUREG-1262 53 
A. The question of the meaning of the term 11 permanently installed instrumentation11 is in ANS 3.5, and official definition or clarification really has to 

come from ANS and not from the Commission. 

Our operational definition essentially says that portable or temporary instrumentation that is brought into the control room for specific modes of operation, 

such as startup, would not be required as part of the simulation facility. 

We in~end that you use the normally installed instrumentation available in the 

control room and not instrumentation associated with special tests. 

So if it's part bf your normal plant operating procedures and it's instrumentation you rely on (and we expect that you have instrumentation that falls into 

that category for calculating rod worth for doing startups) that's what.we 

intend you to use. You need not simulate other instrumentation that is outside 

the scope of your normal procedures. 

Q. 195. ANSI 3.5 Section 3.1.1(10) states that the simulator be capable of performing operator-conducted surveillance testing. Are you only considering the 

remote shutdown panel? 

A. Any surveillance that cannot be performed from the control room need.not 

be modeled. For example, if you're doing a diesel startup from the local panel for 

the diesel and that's the way you conduct the surveillance, you need not model 

anything that's done on a routine basis from outside the control room. 

Q. 196. Would it be wise to evaluate, for example, the plant's surveillance procedures and identify which of those we think would be applicable to being done 

on the simulation facility? In other words, generally the operator from the 

control room would be doing that evolution. Naturally, all of those valves 

exist on the control board and so on, and you can legitimately perform that. 

Would that be acceptable in meeting the intent of Item 10 in the standard? 

A. That would be one way of doing it. But if you look at the performance testing, 

particularly when you're getting out of component testing and into system testing, and you're evaluating your capability to actually model the system, a way 

of doing that would be to see if you can model the surveillance procedures on 

that. 

What you describe is acceptable. You may choose some subset of the surveillances 

that you can perform on those particular systems to show that those systems are 

operating within the bounds expected by the plant. 

After all, that's where you have a source of data on the actual performance of 

the system: the records from the surveillance tests that you've conducted on 

those systems, particularly where they have specifications for flow or pressure 

or some other characteristic which is modeled in the control room. 

Q. 197. Plant data, simulator update design data, and simulator design data: I 

interpret their relationship this way. Plant data represents the current plant 

configuration including installed and functional modifications. Simulator 

update design data, call it Data A, is an accumulation of plant data f?r a 

fixed time period, such as one year. At the end of the data accumulation, the 

NUREG-1262 54 
----------------

simulator update design data is evaluated and appropriate data is incorporated into the simulator design data by the simulator modification process. We have 

one year to match the simulator design data to the simulator update design data, Data A. In the meantime, a new accumulation of data into the next simulator update design data, Data B, is begun. Is this a correct interpretation? 

A. That interpretation is reasonable. The key thing is that you have up to 

two years according to the standard to incorporate a plant modification into 

the simulator. You have one year in which to identify the need for a simulator update~ based upon the required annual review of plant modifications; and then 

you have one more year during which you have to get it incorporated into the 

simulator modification. So we have possibly two years from the time you recognize the need from a plant change to update the simulator until it must be in 

the simulator. 

Simulation Facility Certification (Including Performance Testing, NRC Form 474, 

NUREG-1258) 

Q. 198. When will the official simulation facility inspections start? Will 

they start before certification takes place? 

A. No. There are two minimum criteria. They will not start before the SFEP 

guidance has been out for six months, and they will not start until we have 

received your certification on Form 474, or your application for approval. 

Q. 199. What level of simulator capability must be reported and tested if a 

simulator has considerable simulation capability, much greater than 

ANSI/ANS 3.5-1985 requirements? 

A. We are requiring that the capability of the simulation facility be such 

that it meets the requirements of 10 CFR 55, and ANS 3.5, as endorsed by 

Reg Guide 1.149. To the extent that any simulation facility has capabilities 

that exceed those minimum requirements, you need not tell us what they are. 

You need not certify them to us, and we will not inspect against them. 

Q. 200. In the event we had capabilities beyond ANSI/ANS 3.5-1985 and Part 55 

that we did not test and certify, would those capabilities be utilized in 

examining the operators? 

A. Possibly. For example, let's say that ANSI/ANS 3.5-1985 for a transient 

requires a parameter to move in a certain direction so that you don't get 

spurious alarms, etc. The standard is rather loose with respect to modeling 

for transients. And if you have something which is closer to an engineering 

tool, such that you cannot only predict the direction of the parameters, but 

also have a rather good tolerance on its value as compared to what you would 

expect from simply meeting the standard, that does not mean that we're not 

going to examine that particular transient or say that it's outside the scope 

of our examinations. On the other hand, if you are able to go into the area of, 

say, severe accidents, which we don't currently cover in the requirements, we 

may not be examining in that area. The issue is whether that's appropriate for 

the control room crew, or the technical support center, the accident assessment 

function, and that's the difference. 

NUREG-1262 55 
Q. 201. That's the real question. When our vintage simulator was purchased, 

the limitation on the vendor was to build it to plant design. Sometimes some 

of the NRC scenarios go beyond design basis, and I can't say whether the simulator1 s performance is correct or incorrect, I have no basis to certify it. 

A. We will still be examining on.the design basis, because you must do that 

in order to get into symptom-based procedures and function-restoration guide1 ines. And we want to be able to see an operator's ability to use those emerg~ncy operating procedures, in particular. 

That already puts you beyond the Chapter 15 design-basis transients and evaluations. There is one requirement in ANSI/ANS 3.5-1985, which is endorsed in our 

Regulatory Guide, and is also contained in our Simulation Facility Evalution 

Procedure, for some means or mechanism within the simulation facility to notify 

the simulator operator when the simulation facility has exceeded the capability of its modeling. And that's one of the things that we would be looking at 

in our inspections. 

Q. 202. In order to get into the emergency operating procedures on most plants, 

you have to have a variety of different types of failures that are compounded, which go beyond the design scope of the plant as single-failure-proof and would 

be very difficult to run on a simulator. We have found that in using the emergency operating procedures (EOP), we can quickly get outside the bounds of 

simulation. How do you propose that we address that issue on EOPs? 

A. There are two ways: First, the standard indicates that when you go beyond 

the bounds of modeling, it should indicate that in some way during the simulation. Second, we conduct examinations that go outside the bounds of your Chapter 15 accidents and transients. That's necessary in order to get you into the 

function-restoration guidelines. 

We intend to see and the regulations require that we understand that an operator can effectively implement those procedures. The tolerances, however, for 

those procedures are quite large. When you get into casualties, ANS 3.5 

essentially requires that the parameter go in the same direction it would go 

during the actual transient in a plant; that you don't get spurious alarms and 

that the alarms that are supposed to come in are the ones that you get. It's 

not time dependent. It's really the ability to look at the parameter and decide, based upon that parameter, what procedure you're supposed to be using, 

and then implement that procedure. We are not looking for a high-fidelity 

severe-accident simulator in order to be able to exercise the emergency 

procedures. 

Q. 203. This question relates to the definition of "site-specific plantreferenced simulator. 11 What is meant by "it's been designed and uses plant 

procedures?" With this explanation, could you give me a feeling for whether I 

have to delete some steps as inapplicable because of non-modeled systems? 

Does that need to be highlighted in my performance testing exceptions? 

A. What we mean by "use of procedures" is simply that the procedures that your 

operators use in the control room should be capable of being run on the simulation facility without change. You must be able to use controlled copies of the 

control room procedures, not copies modified in some fashion or by pen-and-ink 

NUREG-1262 56 
·- -~-~--------

changes. They actually need to be controlled copies. You can indicate which 

steps cannot be performed, then you must certify to that. NRC must be able to 

use the facility emergency operating procedures during the conduct of operating 

tests. A suitable alternative must be provided in the event of non-modeled systems that are involved with the execution of such procedures in the control room. 

Depending on the extent and degree of such discrepancies, it is possible to 

certify with exceptions as opposed to applying for NRC approval. 

Q. 204. In other words, I can't take exception to any step in the procedure 

because· of non-modeled systems? 

A. Let's assume that it is a step in the procedure that's used in the control 

room, but it directs an activity outside the control room. Say the reactor 

operator tells the auxiliary operator to do something, and you have not modeled 

that capability in the simulation facility. That would be not applicable. 

If it is a step normally conducted from the control room, it is part of the 

operating procedures for the control room, and it falls into one of the categories appropriate for the operating test, then you need to model and describe 

it as a part of your certification of the simulation facility. 

If that step need not be used as a part of the operating test, if it's for an 

ancillary system outside of what we would test on -- you may have something associated with fire suppression or some other system, for example, that's not 

explicitly covered in the items for the operating test -- then that need not be 

included. 

So you have to look at the scope of the operating test in view of the required 

capabilities of the simulation facility as described in the ANSI standard. 

Q. 205. Let's assume that in the absence of a modeled system or a modeled 

cabinet within the control room area, I believe it would be permissible to use 

the plant to train on that particular component. In essence, I have an exception on my performance test plan, which would normally require the use of that 

cabinet. But through on-the-job training in the actual control room, I can 

give the equivalent of that training that I would have performed on the simulator. Have I gone beyond the plant-referenced simulator category and moved into 

the other category here? If so, how do I address that? 

A. Not necessarily. You need to look at whether that system is, for instance, a safety system. If it's not a safety system and it's not otherwise 

called out in the categories under the operating test, then you need not model 

that system as a part of the control room. The safe-shutdown panels in some 

facilities aren't modeled. They are outside the control room. We do not require that you model that in the simulator. 

There are radiation monitor panels in the control room and things like that 

that you may not have modeled in your simulation. We understand that. That 

should not preclude you from using certification with exception. 

You need not necessarily go through the application process. It's when there 

is some portion of the operating test which requires controls in the control 

room that are not replicated on the simulation facility that would require you 

to submit an application for NRC approval. 

NUREG-1262 57 
Q. 206. Will the operator/examiner feedback form that was discussed be used to 

determine the status of current simulators? 

A: The.guidan:e.t? the Examiners is that the form will be applicable only to 

simulation facilities that have been certified, or have applied for approval. 

Howev:r, :ven today, with the present vintage of simulators, you still are experienci~g feedb~ck reports, although informal, in the exam review process. 

And th~t will continue. _If the Examiners have a problem in conducting the 

operating test at your simulator, you can expect some feedback in that regard 

even though it won 1t be the formal process that will occur for certification ~r approval. 

Q. 207. So, is it true that if I wait for 46 months to certify, that is an 

advantage to me? 

A. No. It 1s not an advantage because you will to have provide substantial 

additional information for every application that you submit and we are going 

review that information and make determinations on individual applications and 

candidates. 

Q. 208. But, yet, you won 1 t inspect us? 

A. We won 1t inspect your simulator, but we 1 re certainly going to be keep 

close tabs on your applicants. And every time you receive an NRC operating 

test using your simulator, you can expect feedback through the exam report on 

the performance of your simulator. 

Q. 209. This refers to the accelerated update of the simulation facility that 

may be required as a result of performance testing. What systems, events, or 

procedures are we trying to exercise during the simulator exam? 

A. The intent was to identify any potential system, operation or scenario that 

we could not conduct on the simulator exam because of the simulation facility 

and which we could not readily implement another way during the examination, 

so that the exam could potentially be compromised or considered invalid. We 

would need to see that that system, or procedure or event had been corrected 

before we could develop an appropriate exam using it. For example, one simulator was unable to adequately represent flow coast down on a loss of coolant. 

The response was very unusual as compared to what was expected, and on how the 

procedures were to be used, because there was no coast down. It would not have 

been appropriate to conduct an examination which involved a loss of flow event 

in that case. We would not want that situation to exist for the next two 

years, because we may want to conduct a loss of flow scenario as a part of an 

exam within that time. So, we would require that that be corrected on a schedule that is faster than the normal two-year correction schedule provided in the 

standard. 

Q. 210. I think clearly, that 1 s the intent. But I see opening some areas of 

disagreement in the future. None of us know what the next round of the 11 topic 

of the day 11 is going to be. And we may find that our present machines were not 

designed to handle whatever that issue is. And, so, when you say any event, 

that can be troublesome. 

NUREG-1262 58 
A. We suggest that you look at NUREG-1258 that describes the Simulation Facility Evaluation Procedure (SFEP) and the pilot tests. That should allay some of 

the apprehension. 

Also remember that this system, operation or event is something that you have 

already certified that your machine is capable of doing. We 1 re referring to 

something we discovered during the course of our inspection that contradicts 

something you 1ve told us on your certification. 

Q. 211. This question addresses performance tests to be performed on the simulator in compliance with 10 CFR 55. What are those set of performance tests, 

the specific scenarios and malfunctions? Could you clarify that? 

A. We're talking about Appendices A and B of ANSI/ANS 3.5-1985, and the 

of 25 malfunctions that are contained in Section 3.1.2 of the Standard. 

is a defined list of malfunctions that the simulation facility needs to 

perform. 

Q. 212. Is it just that list that's in 3.5, only? 

A. Yes. 

list 

There 

Q. 213. Or is it that list, plus the diesel generator that's covered in Regulatory Guide 1.149? 

A. There was a specific list of malfunctions in an earlier draft of Regulatory Guide 1.149, but it is gone from the final version. The equivalent paragraph that's in the final version endorses the paragraph in the Standard that 

lists the 25 malfunctions. Recognize, however, that some of those malfunctions 

are quite broad. We talked about the loss of power. That could mean loss of 

power to a panel, to a system, to a component, or loss of all power. Small 

break LOCAs can be initiated from a reactor coolant pump seal, from a steam 

generator, a tube rupture, a lot of different ways. What we are interested in 

is a representative sample of those things. You need not do all possible 

permutations and combinations. 

But you are going to have to look at what you are certifying to, that's the 

reason that you are submitting test abstracts, and you describe what your testing program is. 

Q. 214. So we will determine which specific scenarios we will run, as long as 

we cover those areas? 

A. That is correct. And you describe that in your abstract, with your certification, and you describe the performance tests that you will conduct in the 

future to maintain the simulation facility. 

Q. 215. Would the Commission find a formal simulator facility review board/ 

committee (consisting of training management, operations management and senior 

reactor operators) a suitable forum for making judgments regarding the simulator scope requirements versus training value? For example, ANSI/ANS 3.5-1985 

states that all accidents analyzed in the facility's FSAR must be included in 

plant malfunctions in the simulator's scope. It then later states that this is 

required only when the simulator is determined appropriate for training. 

NUREG-1262 59 
However, in a few cases the accidents provide little, if any, training value to 

an operator. Can a board, such as that proposed, be considered a legitimate forum for making these decisions? 

A. We are concerned with the applicability of your simulation facility for 

.the conduct of operating tests, and not as it applies to your training programs. Generally speaking, when you look at the ANS 3.5 document, you can 

safely substitute the term "operating tests" wherever the term "training" 

appea_rs. 

Although we recognize that your simulation facility's scope, when applied as 

part of your training program, may exceed that which is necessary for its 

applicability to use in operating tests, it doesn't matter to us what process 

you use internally to identify those differences. 

We have tried to indicate clearly the minimum requirements for use of your simulation facility to conduct operating tests, and it must meet those minimums. 

These include the evolutions and malfunctions identified in Section 3.1.2, in 

the performance test appendix, and in the operability test appendix of the 

standard, using the required operating test requirements in Section 55.45(a) as 

the criterion. 

However you meet those requirements is your decision to make; and as to whether 

you need to certify or provide additional performance testing data for anything 

additional, that's also your decision to make~ 

You will be submitting performance test abstracts with the Form 474 that describe the testing that you're going to perform. 

When you look at the list of malfunctions and you see a malfunction that says 

"loss of power," that's very broad. Which ones do you choose in developing the 

test abstract for various losses of power? 

You should look at the testing that you propose and, if possible, combine some 

of those malfunctions so that you have a smaller number of performance tests 

than would otherwise be the case and describe how those tests in your abstracts 

meet the intent of the standard. 

In doing that, we would use those tests in making a judgment as to what the 

capabilities are. That does not mean that we would limit our examinations, 

however, to those particular tests or scenarios. 

Obviously, if you demonstrate that the simulation facility works well for an 

event at high power and for some tests at low power, we may be able to mix 

those just as we do now. You have a substantial amount of control in deciding 

what testing you want to propose for the performance tests and that list of 

malfunctions is quite general. 

In the case of using the panel, that could be an appropriate vehicle for deciding what tests are going to be proposed as performance tests. They could be a 

subset of all the malfunctions the simulator is capable of performing. You may 

literally have hundreds of malfunctions which you can implement. 

NUREG-1262 60 
We don't want to see a performance test for each malfunction. We do want to 

be sure that all of the malfunctions that are listed in the standard can be 

performed. 

Q. 216. Section 55.45(b)(5)(vi) says a certification report need only include a 

description of performance testing completed, performance testing planned, and 

the schedule for conducting 25 percent of performance tests per year for the 

next four years. Is this sufficient, or must the document conform to ANS 3.5-

1985 Appendix A? 11 

A. This question addresses two different issues. The first is the testing 

that is required, and the second is the reporting. The reporting itself need 

not be in the format of Appendix A, ANS 3.5, although that's not necessarily a 

bad idea. But it must cover those items that are called out in the Regulation 

in Section 55.45(a), specifically a description of the performance tests conducted, and the schedule for future performance tests, if that schedule differs 

from one that was previously submitted with the certification. 

The actual testing must include not only the Appendix A performance testing, as 

called out in the standard, but the specific list of malfunctions that are 

identified in Section 3.1.2 of the standard, both at the rate of 25 percent per 

year. Also, the operability testing that's shown in Appendix B of the standard 

is to be performed annually. So, testing and reporting are separate issues. 

Q. 217. When does the Commission project that their guidance for conducting 

simulation facility audits will be made public? 

A. That guidance is available now in draft NUREG-1258, and we will accept 

your comments on that NUREG until the 26th of May. 

Q. 218. Will simulator certification audits be performed by NRC headquarters 

staff, regional NRC staff, or some combination? 

A. In all probability, the simulation facility inspection program will combine headquarters and regional staff, starting largely as a headquarters function and over time becoming more region-based as we move into the inspection 

procedures. 

Q. 219. NRC released a final draft of "Handbook for Software Quality Assurance 

Techniques Applicable to the Nuclear lndustry, 11 dated February 1986. This 

handbook addresses the applicability of 10 CFR 50 Appendix B requirements 

associated with computer uses in the nuclear industry. 

It specifies that training simulators require stringent software quality assurance. This requirement seems to imply that the simulator's software should 

be treated as though it were safety related, with the appropriate programmatic 

and procedural controls applied. What are the Commission's plans in this area 

and what relationship, if any, will the draft handbook have to simulator 

certification? 

A. The draft handbook to which you refer imposes no requirements on the 

industry. It is under consideration by the staff, but there is no intent for 

us to review your software development or quality control procedures as they 

apply to Part 55 and to simulation facility certification. 

NUREG-1262 61 
You, of course, have to manage your own simulator software program in order to 

meet the regulations in Part 55 as required to certify that the simulation 

facility is suitable for conducting operating tests. And we will review the 

simulation facility's adequacy using the performance testing program, after you submit your Form 474. 

We will take a look at the handbook to determine its status, but we think it is 

safe to consider it not applicable to these regulations. 

The ·best way of determining whether the software is any good or not is to see 

whether it performs in accordance with the plant's design characteristics. We 

don't need a very prescriptive software control program protocol that is subject to NRC review and evaluation. 

We've described how we intend to inspect the simulation facilities and we have 

put that into the Simulation Facility Evaluation Procedure. The evaluations 

will be based upon running things like Licensee Event Report scenarios and 

seeing how the simulation facility compares with the plant. 

But if you start modifying the software in one area, you may affect other 

areas. So you need to understand what impacts such changes will have to the 

overall performance tests. If a modification causes a performance test to fall 

outside of its acceptance values -- that is, the 2 percent and the 10 percent -- you need to rerun that test to ensure that the simulation facility is still 

performing in accordance with the design specification. We're looking for a 

machine that will replicate what we expect to happen in the plant. We're not 

looking for developing a software control system which is appropriate to a 

reactor protection system where you cannot test by operation how effectively 

the performance of the reactor protection system works. Title 10 CFR 50 Ap- pendix B requirements would appear to be appropriate in such safety-related 

applications. That's the difference. 

Q. 220. This question concerns a simulation facility consisting of other than a 

plant-referenced simulator, and the performance testing related to such a facility. What performance tests are required and what standard is used to 

evaluate whether the tests are satisfactory or not? 

A. We intend to follow the guidelines in the ANSI standard as applicable to 

the simulation facility which you have proposed. 

Let's say that you want to use another plant's simulation facility for reactor 

startup and that you can effectively model the controls and indications that 

would be used for reactor startup. We would expect you to follow the ANSI 

standard as it related to startup modeling. You may not be able to model it 

for controls and indications because you don't have that capability on the 

simulation facility. You would not have to follow ANS 3.5 guidelines in that 

instance because they are not applicable. 

Q. 221. If the standard for performance tests is ANSI/ANS 3.5, as modified by 

Regulatory Guide 1.149, will it be possible to deviate from the standard in 

certain areas or must it be adhered to in its entirety? 

NUREG-1262 62 
A. We recognize that there will be a number of outstanding discrepancy reports on the simulation facility against its reference plant. We expect that, 

for certified simulation facilities, as well as for those that achieve approval 

after application, exceptions will have to be taken from the requirements of 

ANS 3.5. There is a block on Form 474 for certified simulation facilities to 

address the exceptions that you take at any given time. The same would apply 

to noncertified simulation facilities where you would address those exceptions in your application. 

Q. 222. Does a simulation facility certification form, NRC 474, have to be submitted prior to each operating examination? 

A. No. Assuming that you maintain the acceptability of the simulation facility, it is a one-time certification. 

Q. 223. Will the guidance document be limited to auditing the provisions of 

ANSI/ANS 3.5-1985? 

A. No. It will be limited to auditing certification against the requirements 

of Section 55.45(a) of the regulation, which delineates the 13 components of 

the operating test, and ANS 3.5-1985, as endorsed by Regulatory Guide 1.149. 

Q. 224. Will the performance testing documentation maintained for NRC review be 

limited to those items addressed in ANSI 3.5? 

A. No. The performance testing and its documentation will use Section 55.45(a) 

of the regulation as its criterion, and must employ the malfunction testing of 

Section 3.1.2 of ANS 3.5, as well as the standard's two appendices, and the 

endorsement by Regulatory Guide 1.149. 

To amplify, the operability test identified as Appendix B in the standard is 

done annually. We have not taken exception to that. Performance testing, 

which appears in Appendix A, plus the repeat of the malfunction testing, which 

is described in Section 3 of the standard (that set of testing at approximately 

a rate of 25 percent per year over four years), will constitute the additional 

annual testing to be done. 

So you have an annual operability test, and then 25 percent of the performance 

tests that are described in the first appendix, plus 25 percent of the malfunctions that are listed. To the extent the operability test itself duplicates a portion of the performance test, that's sufficient. You gon't need to 

do it twice, but that's the scope of the testing we are expecting to be done on 

an annual basis, and the term annual is used in its common meaning. We are 

interested in you doing the performance tests regularly over a period of four 

years, and not putting them off for the last year. 

Of course, before you submit your certification or your application for ap- proval, you should have completed 100 percent of the operating tests and the 

performance tests. After that, the 25 percent per year cycle will begin. 

Q. 225. It was indicated that when we submit the Form 474, we should have 

100 percent of the performance tests completed. Can we count performance tests, 

specifically malfunction tests, that were performed as part of an acceptable 

NUREG-1262 63 
test procedure, say, three years ago, towards havirg performed that part of the 

performance test one time, or do we have to redo it before we submit the form? 

A. There is not necessarily any need to redo those performance tests. The 

concern, if any, is the difference in time from when they were done, and any 

changes to the plant configuration that would be required by the ANSI standard 

to bring the simulation facility up to date. If there have been no changes 

that would require you to repeat some performance tests to make them in compliance with the standard, then those tests should be acceptable. 

Q. 226. So if we conducted an acceptable test program, and since then have had 

a program in place to test all the modifications to the software, including 

malfunctions, if appropriate, then we've got a basis for starting, anyway? 

A. Yes. We intentionally did not specify a time prior to certification by which you had to have them all completed. 

But the situation you have is that once you do certify, then you start performing those same performance tests over again on a 25-percent-per-year basis over 

the 4 years to ensure that configuration changes are, indeed, incorporated in 

the simulation facility. But the rule itself is silent on how long before 

certification these tests may have been performed. 

There were some changes in the standard between the 1981 version and the 

1985 version. You have to show that you have met the 1985 version, and that 

any design changes or software changes that you have made since then have not 

affected the validity of those earlier tests. It may be easier to repeat them 

than to repeat the entire process, but that's up to you. · 

Q. 227. Is there any intent to include remote shutdown panels in any of the 

simulation facility requirements? 

A. No. However, if these panels are provided as part of the simulation facility, they may be used in the NRC operating test. 

Q. 228. What does the Commission consider an adequate schedule to correct performance test failures identified in the four-year anniversary certification? 

A. Although the rule requires a report on every four-year anniversary of 

certification, or four-year anniversary of application, we intend to have a 

much closer working relationship with you so that we will know on an ongoing 

basis about any such performance test failures, and there are several mechanisms to do that. One is the 90-day letter prior to examinations, in which 

uncorrected performance test failures would be identified. Another would be 

simulation facility fidelity reports from our examiners, and the third would be 

the results of our periodic audit and inspections of simulation facilities. 

The schedule to correct performance test failures is really based upon the 

seriousness and the magnitude of.the failures that are discovered. It may 

range from purely an NRC recommendation that the failures be corrected, to a 

recommendation that a failure be corrected within the normal update cycle required by ANS 3.5. The next level would require a correction on an accelerated 

schedule. The most serious failures require that the simulation facility 

essentially shut down until the failures are corrected. 

NUREG-1262 64 
Q. 229. What detail of description is the Commission anticipating in the report? Should the report be revised if a schedule for conducting a performance 

test changes year-to-year during the four-year period? . A. If your schedule for performance testing changes between the time you . submit a certification and any subsequent four-year report, you should advise 

us of that change on the Form 474. 

There are three documents for certified simulation facilities that address the 

level of .detail. The rule, specifically the operating test in 55.45(a), lists 

13 items that make up the content of the exam; ANS 3.5, which sets out the 

requirements for the simulation facility 1 s capabilities, as well as the performance testing requirements; and Form 474, which indicates that we want 

performance test abstracts and performance test schedules. 

We don 1 t want reams of material on the details of all your performance tests 

and all the results. If we need additional information in the course of 

conducting an off-site or an on-site simulation facility evaluation we will 

request it from you; we are really looking for summaries and abstracts submitted with that certification form. 

Q. 230. Will an NRC certification team be sent to the facility to conduct a 

simulator performance audit using the new simulator certification criteria? 

A. Essentially yes. The NRC staff will conduct the review and the inspection. 

It will be a two-phase process, an offsite review, followed by an onsite inspection, if necessary. Only as a result of onsite inspection might certification be removed, as a last resort. For further clarification, a certification 

is not removed as a result of an inspection. It 1 s removed as a result of failing performance tests which are required by the regulation. During the inspection we conduct performance tests where we audit the ability of the simulation 

facility to perform as described in the performance tests that you submitted. 

So if the machine does not work during an inspection, the criterion is still 

the failure of a substantial number of performance tests, such that you cannot 

perform a meaningful operating test as described in the regulation. 

The conclusion is based upon the requirements for the operating test, not just 

on failing some fraction of the performance tests. You have to fail performance tests, but it 1

s got to be a substantial enough number of performance 

tests that it impacts on the simulation facility 1 s ability to conduct an NRC 

operating examination. So one performance test failure does not necessarily 

mean that the simulation facility would be decertified. It has to be a gross 

enough set of failures that we can 1 t conduct a test. 

Q. 231. We presently have two years before a plant modification must be incorpor- ated into our simulator. Can we certify the simulator to the NRC without 

having incorporated all plant modifications? 

A. We always anticipate that even when you certify a simulation facility, 

there will be exceptions if you haven 1t been able to bring it up to date with 

plant modifications. The ANSI standard allows a two-year period from the date 

you identified the need for making modifications until those are fully incorporated into the simulation facility. So the answer is yes, you can certify 

prior to the date you've incorporated the modifications. 

NUREG-1262 65 
Q. 232. Where specifically would that be on Form 474? 

A. There is a block near the top of the form that says 11 I hereby certify that the simulation facility meets 10 CFR 55 and ANSI 3.5. 11 

It then says: 11 If there are any exceptions to the certification of item two ~bove [that is, the ANSI standard], check here and describe on additional pages 

1 f necessary. 11 

Q. ~33. In earlier discussions mention was made about using controlled copies of procedures for simulators. What do you mean by the word control? 

A. Controlled copies means those procedures identical to the ones that you use 

in the control room of the plant. The copies should be up to date, including references and revisions. 

*Q. 234. When an examiner conducts an exam on the simulator, are we going to be 

able to take a look at some of the fidelity questions that they have on a simulator prior to them leaving or prior to their exit interview? 

A. Yes. The examiner will provide any comments that he or she has about the 

simulator's fidelity on a "Simulation Facility Fidelity Report, 11 which has been 

added to Examiner Standard ES-104. Those thoughts will be shared with the 

facility licensee along with the rest of the examiner's comments, before he or 

she leaves the site. 

Q. 235. Are licensees required to submit exemption requests per the ANSI Standard or the Regulatory Guide, and they are to be issued per the requirements of 

55.45? 

A. If any one of the requirements of the operating tests in Section 55.45(a) 

cannot be met with the simulation facility, you would require an exemption from 

the Regulation. A failure to meet all of the requirements of the ANSI standard 

does not require an exemption. It simply requires an identification of what it 

is that you cannot meet. And it must include a conclusion on your part that 

that difference would not preclude the conduct of an operating test as it's 

described in the Regulation. 

That's why the certification on Form 474 is a certification to the Regulation 

with an identification that you follow the ANSI standard with some exceptions. 

We recognize that there will be exceptions. There are exceptions on new 

licenses on the day they're issued and we issue a number of license conditions. 

We don't expect that the number of discrepancy reports on a simulation facility 

is ever going to get to zero. It's anticipated that there will always be some 

feedback, some necessary correction. The standard itself provides a schedule 

for incorporating those corrections and revisions. 

Q. 236. I'm unclear as to how much we have to put into our simulator with regard to back panels. 

The simulator we have is what's called a main horseshoe. We have 50 to 60 back 

panels in the simulator which are used during surveillance testing, and 

NUREG-1262 66 
recently there have been a lot of bypass switches that we use during our emergency plan training. Must we have all those back panels in our simulator or 

can we substitute the plant for that part of the training? It 1s a very big 

main control room, and we put all our back panels in there instead of outside 

the main control room. 

A. Our intent is not to have you model the entire plant, but if the evolutions you are citing are your operating and emergency procedures for the facility, and it's an evolution which is conducted from within the control room 

by the regulation, we would expect that to be modeled or you would have to show 

us how that could be done without modelling and identify that as an exception. 

But for facilities that have a large number of back panels or other equipment 

available in the control room, it's not the intent that you mock up all those 

panels. Generally, they are merged in the main control boards. For example, 

those that control the reactor, safety systems, electrical line-up, and balance 

of plant are the typical ones that we're looking for. 

Q. 237. Would it be safe to assume that you have in mind the area that the 

operating shift typically does not leave during normal operation of the 

facility? 

A. It's those portions of the facility where the individual is defined as 

being "at the controls," which is described in Regulatory Guide 1.114. Some 

facilities mark it off with a red line on the floor or with a fence or whatever. 

It's that area where the individual is at the controls as defined in the Regulatory Guide that we 1

re interested in simulating. 

NUREG-1262 67 
LICENSES 
Special Senior Operator Licenses (Including Instructor Certification) 

Q. 238. What is the impact of the new rule on instructor qualifications? Are 

the requirements of NUREG-0737 superseded? 

A. The new rule supersedes the requirements for instructor qualifications in 

NURtG-0?37. The resp~nsi~lity for ensuring that instructors are qualified now 

rests wit~ the.accreditation process. INPO has established the qualifications 

for technical instructors, which would be reviewed within accreditation. NRC's 

role is to monitor the accreditation program to ensure that it maintains the 

standards that have been endorsed by the Commission. 

Q. 239. Instructors who have been certified or who have held a license previously may instruct students in courses needed to prepare applicants for NRC 

licensing examinations. Are these instructors required to participate in a 

requalification program? 

A. If you have an accredited program or systems approach to training (SAT) 

program, then that program will define the continuing qualification and retraining requirements for instructors. If you do not have an accredited program, then the instructors will have to meet the commitments of the approved 

program as defined under Part 55 and commitments contained in the FSAR. NRC 

will no longer issue instructor certifications. If a licensee is using vendorcertified instructors in a requalification program that has not been completely 

converted to an SAT program (performance-based), it is conceivable that a 50.59 

change could be made to support such an approach in the interim until such time 

as the requalification program is converted to an SAT-based program. 

Q. 240. As I understand it, only people that hold a license for a facility may 

instruct license-type material to a hot license class. Would consultants who 

were previously licensed and certified by General Electric be able to teach 

such material? 

A. If your program is accredited, then you determine subject matter expertise 

and instructor skills in accordance with the accredited program. If your pro- ~ram is not yet accredited and you were previously under the commitment in the 

Denton letter to assure subject matter expertise for instructors -- which was 

that those instructing integrated plant operations have a level of knowledge 

comparable to that of a senior reactor operator -- then the process we've 

allowed in the interim permits you to certify your instructors based upon their 

successful completion of your senior operator training program. 

We have also allowed that those examined and certified by NRC in the past can 

continue, but they should receive additional training on plant or procedure 

changes, that portion of the requalification program which is applicable to what 

they're teaching. 

Now, the practical aspect is that those people who are instructing have to 

learn that material to a depth greater than that which they instruct, and your 

program also has mechanisms for evaluating instructor performance. 

NUREG-1262 68 
-- ~-- ~-~-- -------------~--·-

We are trying to move out of the area of specifying training program content or 

qualifications for instructors. So depending upon your commitment in the presently approved program, you may need to review that in accordance with 50.59. 

NRC will not need to certify it; you may do that under your own program. 

Q. 241. How would that apply to vendors such as Westinghouse? We cannot get 

accredited by INPO. Therefore, if we hold a staff of instructors, are they 

then going to have to go to the utility and the utility is going to have to 

either license or certify them? 

A. For contractors that are providing instruction for facilities, it is the 

responsibility of the facility to ensure that the contractors have the appropriate subject matter expertise and instructor skills to meet the requirements 

of their accredited program. The staff will not be certifying or approving 

instructors who are contractors, nor will we be certifying or approving instructors who are facility employees. 

Q. 242. Did I understand correctly that you said that if you 1 re not accredited, 

that you would have to license instructors? 

A. Some facilities in their existing training programs have committed in the 

FSAR to have either licensed senior reactor operators or individuals who were 

certified instructors. The old instructor certification, which was comparable 

to a license (the eligibilty requirements were relaxed), required that the 

instructor go through the same examination, although he was not authorized to 

manipulate the controls. We no longer issue such certificates, which would 

imply that you would be obligated to have licensed operators conduct your program. 

We also indicated that you could perform a 50.59 type of review that would meet 

the same intent. Having your instructors complete and be examined by the standards of a program comparable to your own senior reactor operator program, such 

as a vendor certification program, would be sufficient in the interim. When we 

get to the point where everyone has been accredited, that issue is superseded. 

The accreditation process covers instructor qualification and training. 

Q. 243. I do not have my programs accredited yet. I hope we will have them 

done by the end of the year. But I have people who are in a program right now, 

the same one we 1ve been using all along, and they are being examined by us next 

week. And the Region is not going to come in and give them an NRC exam. My 

intention is to certify them as I have done in the past and put them right into 

a classroom. They will also be in a requalification program. Do I understand 

that to be a correct procedure? 

A. Yes. If you are getting ready for accreditation, you probably have completed the self-evaluation report, and are getting ready for a team visit. As 

preparation for that, you look at how you train and certify instructors. We 

want that to be a part of the accreditation process, and not a part of the NRC 

review. 

Q. 244. Can trainees participating in a systems training program for instructor certification manipulate controls on the facility under the appropriate 

supervision of licensed personnel? 

NUREG-1262 69 
A. _If that trai~ing program can lead to a license if carried to completion 

trainers may manipulate controls under appropriate supervision if it occurs in 

the proper sequence within the training program. The trainee may also manipulate controls (under proper supervision) without being involved in a course 

that leads to ~ ~icense if the systems that are being manipulated do not affect p~wer or react1v1ty (e.g., feedwater). However if the systems that the trainee 

will _t7ach, and therefore the controls he would manuipulate, do affect power or 

ract1v1ty, then he must be enrolled in a course that leads to a license. 

Q. 245. As I understand it, in the accredited utilities, instructors will be 

consid7red to ~e.certified to teach licensed operators after they complete the 

accredited tra1n1ng program. In the case of a utility that doesn 1 t have their 

operations programs accredited yet, could you outline what the requirements will be? 

A. The requirements are basically those which were in existence before the 

effective date of the Rule, and that is to either have an individual who has 

completed a training program comparable to that of an SRO, and been examined 

on it (we used to call that instructor certification), or be a licensed senior 

operator, who is currently enrolled in a requalification training program. 

Because of the fact that we no longer are going to be giving instructor certifications, you then have only the option of using a licensed operator to teach 

those courses. We are not going to give any further instructor 1 s certifications, 

that's not permitted under the Rule. 

For NTOLs and facilities that are in the accreditation process, the Commission 1 s 

Policy Statement in Training and Qualification of Power Plant Personnel of 

March 20, 1985 allowed facilities to make the transition from FSAR commitments 

to accredited programs. Therefore NRC instructor certifications which, as a 

policy, were discontinued in Mid 1985, relied on facility certification of 

instructors. We believe this policy will continue and eventually be reflected 

in Revisions to Section 13.2 of NUREG-0800, the Standard Review Plan. 

Q. 246. So, training instructors must be licensed operators? 

A. Yes, until such time as you get accredited, or have some other way of getting subject matter expertise through your accredited program, including instructor training. We are not going to specify that for an accredited program. 

But you may have a program on record today, in which you have committed to the 

requirements to the Denton letter, which said you were going to do certain 

things to ensure subject matter expertise in instructors. And that was to 

either use a licensed senior reactor operator or an individual who has been 

examined by the NRC to the same level as a senior operator. 

We are not going to examine without issuing a license. 

Q. 247. Will people who are currently certified by virtue of the fact that 

they have previously passed a senior reactor operator examination somewhere, 

and thus demonstrated their competency, be considered as certified to teach? 

A. Yes. But when they come to us after the effective date of the Rule requesting to have their certification renewed, that's not going to happen, because 

there is no longer such certification. 

NUREG-1262 70 
.,.,. 

Q. 248. So, then, is someone who has passed an SRO exam given by the NRC at 

some point in the past, considered certified or not? 

A. For the purpose of meeting your training program commitment of having an 

individual who has a knowledge level comparable to that of a senior reactor . operator, the answer is yes, provided the individual is maintaining currency ~n 

the requalification program, with respect to any changes which would affect his 

knowledge base. That is consistent with what INPO is looking at in the ~n~·tru.~­

tor training and as identified in Technical Instructpr Training and Qual1f1cat1on 

GuideliRe, INPO 82-026 at 7.1. 

Q. 249. Can you tell us how you expect to treat people under the new rule who 

are currently SRO instructor certified? What kind of credit are they going to 

get because they are SRO instructor certified, if any? 

A. The answer is none. Obviously they have· completed the same training program 

and taken the same exam as an SRO, but because of el i gi b i1 i ty requirements or 

time on shift or some other requirement they did not meet the SRO requirements. 

In the past, there have been individuals who successfully converted an instructor's certification to an RO license. 

Additionally, there is the provision for waiver of certain portions of the NRC 

examination, based on operators having: (1) extensive actual operating experience at a comparable facility within two years, (2) discharged his or her 

responsibilities competently and safely and is capable of continuing to do so, 

and (3) learned the operating procedures and is qualified to competently 

operate the facility designated in the application. 

If you want these individuals to become licensed, you will need to submit a 

complete application, and if applicable, request a waiver under the Regulation. 

This application would then be reviewed by the Region as to what portion, if 

any, of the examination would be waivered. 

"Actively Performing the Functions of an Operator or Senior Operator 11 

Q. 250. What guidance will the Commission provide to the facility licensees and 

the staff that Section IIF(2) is Commission policy? 

A. Section IIF(2) is part of the Statement of Considerations that summarizes 

public comments and describes the staff's final actions in response to them. 

This Section discusses the definition of 11 actively performing the functions of 

an operator or senior operator, 11 which is part of the regulation, contained in 

Sections 55.53(e) and 55.53(f). 

*Q. 251. The regulation for active participation states that 11 an individual has 

a position on the shift crew that requires the individual to be licensed as defined in the facility's Technical Specifications, and that the individual carries out and is responsible for the duties covered in that position. 11 How 

does this rule accommodate plants with RO and SRO licenses on shift that exceed 

the Technical Specification minimum staffing requirements? 

··-'"" 

NUREG-1262 71 
A: .The rule ~oes not.preclude having additional people on shift beyond the 

minimum staf'.1ng requ1remen~s: That is a utility decision. However, in order 

to ta~e cred1t.f?r t~e pr?f~c1ency of such personnel standing watch above the 

Technical Spec1f1cat1on m1n1mums, as a condition for maintaining a license under 

10 CFR 55.53(e), the facility licensee must maintain administrative control over 

these designated watchstanders, and must be satisfied that these individuals are 

maintaining their proficiency by manipulating the controls of the facility in 

the case o'. ~n.operato:, or by manipulating the controls and directing the licensed act1v1t1es of licensed operators, in the case of a senior operator. 

So that i'. Y?u.operate a ~ingle unit with three reactor operators on shift, two 

of t~ose ind1v1duals are 1n positions required by the Technical Specifications. 

One 1s usually the reactor operator and the other is the balance of plant operator. The third person would need to rotate into one of those two positions over 

the course of a quarter to obtain the requisite number of shifts to maintain his 

license active, so he would need to sign the logs, on occasion, as the reactor 

operator or the balance of plant operator. So it's clear that you must be in 

the position on shift required by the Technical Specifications, and additional 

personnel on shift to perform other duties do not meet the requirement for 

directing the activities of licensed operators or for manipulating the controls. 

There are alternatives built into the regulation to provide ample flexibility in 

obtaining proficiency for licensed duties, e.g., 40 hours of parallel watch 

standing. 

Q. 252. Our Technical Specifications do not address the individual's responsibilities for each position in order to satisfy the active participation requirement--it says you have to have an RO and two SROs, one SRO as a shift 

supervisor and one that's another RO. Can you rotate that SRO position from a 

shift foreman position to another senior reactor operator position? It doesn't 

say who is required to fill those positions, so the complication is that if we 

have a senior control operator who has an SRO license and he's clearly directing the operator's activities, can we give him the responsibility for the day 

and say the shift foreman no longer has the responsibility, because both of 

them hold an SRO license? 

A. For the case that you've described, the individual who is on shift directing 

the activities is the one who's in the position required by the Technical Specifications. Whether he is the shift foreman for that shift because that's the 

title that you use to describe other responsibilities he may have, it is the 

senior operator in the control room who directs how the other two operators 

manipulate the controls and who is there fulfilling the requirements of the 

Technical Specifications to be supervising the activities of the licensed 

operators. That's the position that qualifies for the eight hours on that 

shift, independent of title. Your administrative procedures should be clear as 

to who has authority to direct licensed operators so that if the shift foreman 

is relieved there is another senior operator in the control room carrying out 

those duties. The Technical Specifications don't refer to shift foreman; they 

say senior operator directing the activities of other licensed operators. 

There is a related question that concerns the extra person on shift who may not 

be in the licensed role. It is possible for that individual to complete 40 

hours of parallel watch standing; that is, he's not in the position required by 

NUREG-1262 72 
the Technical Specifications, as long as he is being supervised and his activities are being closely monitored by the person responsible. He could acc~ue 

40 hours of parallel watch standing for that quarter and not be actual~y in a 

position required by the Technical Specifications to meet the seven shifts at 

eight hours each, or the five shifts of twelve hours each. 

It would require in that case, that the authorizing representative of the facility certify that he has completed that duty. From a practical standpoint, it's 

easier to rotate the people through the watch to maintain their proficiency. The active license status is intended as a way of maintaining the proficiency 

of the people who are performing the functions. If you're dual licensed, the 

active status requirement can be met by standing watch on only one plant, or 

on some combination of the plants. 

Conditions of Licenses (Subpart F, Section 55.53) 

Q. 253. With regards to fuel handlers, in the case where you may refuel once a 

year, it's probable that the requirement won't be maintained. Subparagraph 55.53(f)(2) suggests that one shift of supervised duty is required before the 

fuel handling foreman with the license can assume his full duties. Is the 

intent that that supervision be performed by another fully qualified SRO who 

may not be a fuel handling specialist? 

A. That is correct. An active SRO license includes the capability and responsibilities associated with monitoring fuel-handling activities. 

Q. 254. The Operations Manager and Operations Supervisor are required by Technical Specifications to be licensed as Senior Reactor Operators. These individuals do not have a position on the shift crew. They are involved in the 

day-to-day direction of Licensed Operator activities. Are these positions 

considered as actively performing Licensed Duties? 

A. No, unless they stand the seven 8-hour shifts per quarter, or five 12-hour 

shifts per quarter. That does not mean that the Ops Manager and the Ops 

Supervisor cannot keep a license. The requirements to maintain a license are 

that they continue in requalification. 

If the Operations Manager must hold a license, then he must participate in 

requal, but he need not stand watch on shift in a position where he is directing the activities of the Reactor Operators. A license, whether it's active or not, 

may meet some Technical Specification requirement. 

Q. 255. What if you have an SRO stand a shift assignment as an RO? Does the 

SRO get credit for standing watch in that position for renewal purposes? 

A. The SRO is not performing Senior Reactor Operator license duties. Unless 

he is also standing SRO's duties during that quarter, then his SRO license 

would not be active. Where an SRO is standing an RO watch, his license would 

continue to be active insofar as it deals with his operating or manipulating the controls as an RO. · 

In order for him to direct others, he would have to stand a 40-hour parallel 

shift in order to be proficient and go back into an SRO's duties. He could, 

NUREG-1262 73 
however, continue to maintain an SRO license if he 1 s current in requal. If he 

wants to.assume an SR0 1s capacity, he must go back to a 40-hour shift under 

1struct1on as an SRO. 

Q: 256. ~hen the operations manager is licensed, should technical advisors or 

licensed instructors have to become members of a shift crew to maintain an 

active license? 

A. Yes, to maintain an active license, they do. To maintain an inactive licens~, they don't. 

Q. 257. Do personnel seeking to maintain an active license have to replace a 

member of a shift crew to meet the watch requirements of 10 CFR 55.53? 

A. Yes, they do, with the understanding that there may be additional people on 

shift beyond the minimum technical specification requirements. 

Q. 258. Although there is only one Technical Specification SRO position on 

shift (Shift Supervisor), our Technical Specification reflects the 10 CFR 50.54 

requirement of a second SRO on shift. Would standing a watch as a designated second SRO meet the definition of actively performing the function of a Senior 

Operator? 

A. If he is filling an SRO position under the Tech Specs then he would be 

maintaining his active SRO license. A number of people have asked, can we have 

two or three people come in to get their on-shift time? Our position is that 

those meeting the minimum staffing Technical Specification requirements for 

whatever operational mode get credit, although there can be other people on 

shift who are also eligible for credit. 

For clarification, this question seems to imply that at this facility the Tech 

Specs do not conform to the Regulation for a single-unit site for having two 

Senior Operators on shift during operational modes. That 1 s understandable 

because the Rule itself supersedes the Technical Specification requirement, and 

is a higher order requirement. That is, you must conform to the Rule even if 

your Tech Specs permit something less. We would suggest that the next time 

you have an administrative change to that section of the Technical Specifications, 

amend it to conform to the Rule. 

Q. 259. If the Operations Manager does not hold an active license, what duties 

may he perform or not perform in that status? For instance, we all have Technical Specifications that require licensed Senior Reactor Operators to approve changes to procedures. Would an inactive license allow him to do those administrative functions? 

A. Yes. He can do everythin~ but direct a Reactor Operator in manipulation of 

controls, or himself manipulate the controls. 

Q. 260. All stations have engineering expertise on shift in the form of a shift 

engineer, who is the STA. STAs hold a current SRO license. They direct 

activities and integrate schedules. Are they not actively performing the functions of an SRO license by those duties, or are they going to have to come back 

and perform as a shift supervisor, on shift? 

NUREG-1262 74 
~------------~- -~-

A. If they are one of the two individuals required by Technical Specifications to staff the shift, then what you just described is acceptable. If one 

is there as an engineer on shift who happens also to hold an SRO license, and 

is only fulfilling the role of an STA, then he is not responsible for directing 

the activities of licensed operators. There are many cases of extra people on 

day shift, who do support functions, such as reviewing tags, procedures, lineups, records, etc., and do not require an active license to perform them. It 

is only when he is performing the functions and duties of an operator or a 

senior operator that an active license is required . . 

*Q. 261. Our Technical Specifications require two senior reactor operators and 

two reactor operators for mode one and two operation. Typically, though, we'll 

have others assigned to the shift. Is it NRC's intention that only the two 

people assigned as the balance of plant operator and the reactor operator are 

receiving credit for being on shift? Or are the others manipulating the controls getting credit for being on shift? 

A. If utility management has determined that they are necessary for safe oper- ~tion, the decision about the number of additional watchstanders is that of the 

facility licensee. However, in order to take credit for the proficiency of such 

personnel standing watch above the Technical Specification minimums, as a condition for maintaining a license under 10 CFR 55.53(e), the facility licensee must 

be satisfied that they maintain their proficiency by manipulating the controls, 

in the case of an operator, or by manipulating the controls and directing the 

licensed activities of licensed operators, in the case of a senior operator. 

Q. 262. Do candidates with an RO license in training to be upgraded to senior 

operator lose their active license status per 55.53(e) while standing watch as 

an extra operator for three months? 

A. Yes. If the operator does not maintain the requirements of an RO, he loses 

his active status. 

Q. 263. This question is related to actively maintaining a license. Could 

someone stand 40 hours in January and then again in June to meet the active 

license requirement by calendar quarter. 

A. No. The 40-hour requirement does not pertain to maintaining a license, 

but is part of the requirement for resuming active status. Maintaining an 

active license means standing the necessary shift watches. 

*Q. 264. This question concerns active license status at a dual-unit plant. 

The shift supervisor is the SRO who normally directs the activities of the 

operators. We also have an SRO on shift who is over both of the shift supervisors. He does not normally direct the activities of the operators, but he 

may. Would his supervisory time on shift count as active time? 

A. Yes. If you look in the Regulations on staffing for a dual-unit site, you 

have three SROs for the two units. If he is in one of those positions, that 

qualifies him. If he is not in one of those positions, you may still take credit 

for his proficiency if you are satisfied that he is maintaining that proficiency 

by manipulating the controls and directing the licensed activities of licensed 

operators. 

NUREG-1262 75 
Q: 265. If an o~erator gets sick in the middle of February, and has been ac- t~vely on watch in January and February and has this requirement met but is 

sick for three months before he goes back on the watch, does he have to stand a 

40-hour watch? You don 1

t have to demonstrate in the prior three months he has 

served 40 hours; isn't it by calendar quarter? 

A. Correct. But during the remainder of that quarter he 1 s going to have to 

complete the required number of shifts to be considered actively performing the functions. 

Q. 266. What records will the Commission require to ensure that a licensee has 

maintained active status per 10 CFR 55.53(e)? What will be the record retention period? 

A. It 1s up to the facility to determine how it wants to be able to document 

the active status. Shift turnover logs would be appropriate documentation. 

The key is that the documentation be retained and available for review. 

There are two answers to the question of record retention. If the record is 

the control room log, it has its own record retention requirement, which is 

essentially for the life of the plant. If you are using the control room log 

to determine whether the guy was signed in, that 1 s adequate. 

The certification for his returning to duties is based upon his standing 40 

hours of parallel watch. On parallel watch, however, he need not sign the 

control room log. Under those conditions, the responsible official onsite 

could create a form which would go into your records onsite and be available 

for audit. That form would have a record retention requirement equal to that 

person 1s license; that is, six years. 

Q. 267. The proposed rulemaking said nothing about the five 12-hour shifts or 

seven 8-hour shifts. What is the basis for this, and why weren 1 t we given an 

opportunity to comment? 

A. The previous practice has been for a minimum of one shift, essentially per 

month, three per quarter. That was deemed by the Commission to not be sufficient, as a part of their review and determination of the final Rule, and they 

increased it to the current requirements in the Rule. 

Q. 268. Would it be possible for an operations superintendent to direct activities from off his shift, and if so, then would that individual be required to 

maintain an active license by actual shift ·time for a calendar quarter? 

A. Let me give you what I think is the most practical example: in an 

emergency, typically, the operations superintendent is the individual who 

goes back and forth between the Tech Support Center or provides assistance in 

an emergency. He gives directions to whoever it is, the Shift Superintendent 

or the other SROs; so he is not directing the manipulation of the controls; 

he 1 s providing guidance on how he wants the event to be handled. 

Someone else in the decision process is actually deciding whether he agrees or 

doesn 1 t and directs the activities of the licensed operators in manipulating 

controls. 

NUREG-1262 76 
So in that case he is not on shift in the position; he is off shift, responding 

in accordance with the emergency plan, which is covered by a different portion 

of the regulations. 

So the operations superintendent need not hold an active license unless you 

intend him to go on shift as a shift superintendent. 

Q. 269. That same logic would apply to day-to-day operations, then, if I understand you correctly? 

A. There is no day-to-day operations issue. He's there fulfilling the position that's required by the Tech Specs as the operations superintendent; that 

is, independent of proficiency in manipulating controls. We would not expect 

the operations superintendent to go in, for instance, and line up systems or 

manipulate controls on the board. 

He needs to be proficient in order to be consistent with the requirements of 

the regulations, so he would either have to stand 40 hours of parallel duty or 

maintain proficiency or keep his hands off the controls. 

In the process of examining him for requalification, we would examine him both 

at the RO and the SRO level. Your continuing training program should ensure 

that he doesn't lose those manipulative skills because he is not required to 

maintain an active license. 

Q. 270. If our Technical Specification defined the STA position as an SRO on 

shift, would filling that capacity satisfy the requirements? 

A. Yes. 

*Q. 271. Consider a plant in cold shutdown with lowered minimum shift manning 

requirements. Are the licensed operators assigned to that crew who are in 

excess of the minimum cold shutdown staffing requirements actively performing 

licensed duties? 

A. Yes, if you have determined that they are necessary for safe operations, 

you maintain administrative control over these positions, and if you are satisfied that they are maintaining their proficiency in accordance with the 

regulation. 

Q. 272. How, and to whom, is certification made under 55.53(f)? 

A. This section has to do with returning the individual to an active status. 

A certification must be made and available on file for inspection purposes; it 

need not be made to the NRC. 

Q. 273. It would appear that once a quarter, an individual could spend 40 hours 

on shift under the direction of the licensed operators. And the facility could 

certify that he had done so, and that his status in the requal program was current. And by doing so, he could maintain an active license by spending essentially 40 hours a quarter on shift, instead of the 56 to 60 hours specified in 

other parts of the Regulations? ls that true? 

NUREG-1262 . 77 
A. That is true, although that is not what we intend. The issue is to make it 

easy fo~ people to maintain a license. And that 1 s a decision that the facility makes with.respect to the commitment of time to the requalification program. 

If th~ fa7ility wants to commit an additional 40 hours for parallel watch 

standing in a.control room i~ addition to the requalification program, so that 

he can be active, that 1s their choice. Our intent was to make the minimum seven 

watches at eight hours, or five watches at twelve hours, to maintain the 

proficiency of those who are actually directing the activities, or manipulating the controls. It 1

s a proficiency issue, it 1 s not a license renewal issue. 

Q. 274. Are any allowances made in 55.53(f) for off-shift licensed personnel who are involved in daily operation 1 s supervision? 

A. No. They are either in active status or they are not. If they are not, 

their just being a daily operations manager, or an operations superintendent, does not convert them to an active status. 

Q. 275. Suppose someone completes 40 hours on shift under supervision; then his 

clock starts again for his seven 8-hour periods. If an individual goes through this in the last month of a quarter, does he have to complete those seven 8-hour 

shifts before that month is up, or does he start during the next calendar 

quarter? 

A. If he's done 40 hours of parallel watch in a quarter, he's active in that 

quarter. For the next calendar quarter, he would need to stand either seven 

8-hour watches, or five 12-hour watches. Regaining proficiency allows him to 

go back into an active status to stand watch. He does not have to do both in 

the same quarter. That is, he does not have to serve 40 hours under instruction, 

plus stand seven 8-hour watches, or five 12-hour shifts in that quarter; it goes 

to the next one. 

Q. 276. Could you clarify what you mean by 11 parallel watch standing? 11 

A. It's very similar to "being directly under the supervision of," as we use 

that phrase for a trainee; that is, the individual that has the watch still has 

the responsibility. 

The person that's in the parallel situation, even though he's licensed, is not 

considered proficient. The regulation requires that he not manipulate the 

controls or direct activities except under the direct supervision of someone 

who has an active license. 

Q. 277. Do those 40 hours have to be consecutive; i.e., eight hours a day? 

A. No. It has to be 40 hours. You can have four tens or ten fours or any other combination that adds up to 40 hours; however, they must be in the same 

calendar quarter. 

The only explicit guidance in the regulation concerns the seven 8-hour or five 

12-hour shifts where a full shift means from watch relief to watch relief. 

NUREG-1262 78 
Q. 278. Can licensed Senior Operators who are not in active status perform 

refueling SRO duties? 

A. No. Only active SROs can supervise refueling activities. If they are n~t 

active, they must stand one 8-hour shift under instruction from licensed active 

SROs to perform active SRO duties limited to fuel handling. 

Q. 279. What leeway do you give to the facility to know that an operator has receiv~d a felony conviction? 

A. Convicted felons typically go to jail, so they 1 re not going to be at work. 

Al so, a 11 those granted clearance for unrestricted access have background 

investigations that relate to such things as convictions for felonies. You will 

have access to the information from that source, too. 

Q. 280. But the facility will not necessarily know within 30 days? 

A. It is the operator who is required to let us know in 30 days, as a condition 

of the license. 

Q. 281. So, we don't assume any liability for not notifying you within 30 days? 

A. If you don 1 t know, and you didn 1t have a reasonable basis to know, we're 

not going to hold you liable for that. However, if you get a criminal history 

check that shows that the person has been convicted of a felony, we expect you 

to tell us. 

Q. 28~. If we submit an applicant for a license who has had a felony 15 years 

ago, 1s that still reportable? If he had taken a licensing exam and was ready 

to receive a license, would he have to notify you within 30 days, assuming we 

did not know that? 

A. If the individual knew that he had been convicted of a felony in the 

past, and he did not report that on the initial application, his application 

would be considered incomplete. Such an omission could be the basis for 

revoking his license, since he would have withheld information. 

Q. 283. Why is the applicant no longer required to sign the Form 396 certifying 

that he or she has no felony convictions? 

A. Because it is a condition of a license, per Part 55.53(g) that individuals 

notify us within 30 days of a conviction for a felony. So, should someone get 

a license who had a prior felony, he would be required to notify us of the prior 

felony. 

Q. 284. If we were to let an individual's license go inactive, would it also be 

reasonable for us to let his medical requiremerts lapse? 

A. No, you cannot let his medical requirements lapse. He must be medically 

examined each two years. That is a condition of his license, whether he maintains proficiency or not. 

NUREG-1262 79 
Q. ~85. Is th7re is a purpose for that, if he is going to continue inactive? 

He is not permitted go on shift, so there seems to be little point to maintain 

the medical status up to date? 

A. The issue is.whether he is medically fit to carry out the duties of a licens:d.operator 1f you put him in a situation of watch standing to regain his 

prof1c1ency. At that point, he would be permitted to manipulate the controls 

of ~he faci~ity, and/or direct activities. The reason we extended the licensing 

period to.six years was to make it coincide with the medical requirement, which 

comes up in two-year cycles. 

9· 286. Ar7 ~ice~sees who maintain an inactive license required to participate in a requal1f1cat1on program to the same extent as licensees maintaining an 

active license? 

A. Yes. A condition of their license under the new Part 55.53 (h), requires participation in the requalification program. 

Q. 287. The problem is that standing the shift foreman's license does not prepare this person to go out and handle fuel, and I don't understand how doing 

one watch under instruction does that, how that can guarantee that he's going 

to be a safe person in charge of fuel handling? 

A. We're talking about an SRO limited to fuel handling, not an SRO with an 

unlimited license here. So if a guy has an SRO license and he 1.s an active SRO, 

he can be used as an SRO with no other duties but to handle fuel, or be the 

supervisor in charge of fuel handling, with no other duties. If he's a senior 

with a limited license, he's in a different category, because he can't be used 

as an SRO. So any active SRO could be a fuel handler senior, but if he is an 

active fuel handler and then he doesn't handle any fuel for awhile, or for some 

reason he doesn't use his license, then he has to only stand one watch, or one 

eight-hour shift with an SRO who is an active SRO, or an SRO with a limited 

fuel handler, and then he has met that certification again. 

The only adjustments we've made in the rule for fuel handlers are that, in 

order to become active, they only have to stand one parallel shift, which would 

make it much quicker and easier than the 40 parallel shift, and that the requal 

program is limited only to those aspects of the plant operation to which their 

license is limited. 

Q. 288. With respect to the requirements for maintaining operating proficiency, 

can a licensed STA (SRO License) who is standing the "STA Watch11 get credit for 

SRO proficiency? 

A. No. 

Q. 289. We had a concern on restoration of an inactive license as a full-scope SRO license, and we wanted to use that individual for fuel handling during refueling. Would that individual as a full-scope license have to go through the 

40 hours of concurrent duties, or just eight hours of concurrent duties? 

A. It would only take eight hours under parallel watch with a person whose 

license is active, whether that's another licensee limited to fuel handling 

only, or it's a senior reactor operator. 

NUREG-1262 80 
Q. 290. When will the quarter for shift standing start when the new rule is 

implemented? 

A. For accountability purposes the first complete calendar quarter after the 

rule is implemented must meet the seven shift/quarter requirement. 

Q. 291. Does completion of 7 days on shift in one position such as shift engineer, allow the individual to perform duties in another position on shift for 

which he is also qualified? 

A. If shift engineer is a Tech Spec position required to hold a SRO license, 

then performing in the seven-8 hour shifts, per 55.53(e) would permit the 

licensee to perform duties as either an SRO or RO. 

Q. 292. Do technical advisors or licensed instructors require an active license, 

if they must maintain a license for technical specifications or FSAR? 

A. They may need a license per the Technical Specifications, FSAR etc., but it 

does not have to be 11 active 11 per the Regulation unless the individual is required to assume a position onshift that the Technical Specifications identify 

as a licensed shift manning requirement. 

Q. 293. If an operator gets his license during a calendar quarter, how is he to 

meet the seven shifts per quarter requirement? 

A. For the initial calendar quarter for which a license is i~sued, he is considered to have met the proficiency requirements by virtue of having passed the 

exam. Thus, the 11 actively performing11 requirement will commence in the first 

calendar quarter after he receives the license. 

NUREG-1262 81 
Regualification and Renewal (Statement of Considerations) 

Q. 294. The regulation says that sometime during that six-year period, a candidate will get a test. That may be the first year through the sixth year, but 

the next time he is renewed, it may be as much as 11 years apart. Is that 

correct? 

A. No. In the Statement of Considerations, II(H)(4), the last sentence says, "The NRC will administer these requalification written examinations and operating 

tests ·on a random basis, so that no operator or senior operator will go longer than six years without being examined by the NRC once a six-year license is 

issued. 11 That's a direction from the Commission to the staff. That's the same 

way we handle the clarification of the INPO status, in the Statement of Considerations that goes with the Rule, describing intent. Some operators will receive 

more than one NRC-administered exam during the term of their license in order 

to comply with the Commission's direction to the staff. 

Renewal of Licenses (Subpart H, Section 55.57) 

Q. 295. At what point will the six-year cycle start for present license holders? 

A. It will start with the first license issuance after May 26th. We do not 

intend to amend the present licenses. So on May 25th, someone will get a twoyear license. On May 26th, that individual would receive a six-year license. 

Q. 296. I have 107 licenses expiring over the next two years for which NRC 

requal exams are not taken. Where do they stand? 

A. The renewal of the two-year license is governed by the rules under which they 

were given their original license, so no NRC exam is required. 

Q. 297. We've gone from a situation where at the end of the examination conducted by NRC, the results were discussed with the utility, to a situation 

presently where the results are not discussed until the license certificate is 

signed off and the results have been reviewed at the Region. In combining requalification exams administered by NRC with initial license exams administered by NRC, will the examiners, upon an indication that a candidate for 

renewal was a potential failure as a result of the operating portion of the 

exam, discuss that information with the utility, or will you allow that person 

to go back on shift pending the complete review? And how do you expect this to 

affect the turn-around time when we're significantly increasing the number of 

exams to be evaluated? 

A. We can't predict how it will affect the turn-around time. Hopefully we 

will have the resources to do it within the existing time frame. From the 

point of view of a licensing decision, no decision has been made until the 

paper is signed. In other words, it is only a recommendation until the point that either the license or the failure has been approved by the branch chief, 

by the licensing authority. 

We're prohibited from discussing predecisional information. That's why we do 

not give preliminary results either on site or from the regional office. 

NUREG-1262 82 
REQUALIFICATION AND RENEWAL 
Obviously, if the examiner believes that it 1

s a safety issue if an individual 

returns to shift, it 1 s incumbent upon him to notify the licensee. We wou~d not 

leave the site with a safety issue pending. However, when we leave the site, 

we don't always know whether an individual has passed or failed all portions of 

the examination (written, oral, and simulator). 

Q. 298. What is written evidence of the applicant 1 s experience and how is this 

supplied? 

A. Written evidence will be the same as it is now; as it is reported on relevant portions of Form 398. 

Q. 299. What is the evidence that the applicant has discharged the license 

responsibilities competently and safely, and how is this information provided? 

A. The utility certifies that the individual has performed in accordance with 

the terms and conditions of his license, and that he has performed satisfactorily. It is for you to determine how that performance has been, through 

whatever mechanisms you want to use; whether it be performance evaluations, or 

other information that you have in your company files related to that individual. 

Q. 300. In reviewing past performance under Section 55.57, you said earlier 

that an NRC letter or a letter of reprimand might be part of what you'd evaluate. Does this mean a letter of reprimand specifically from NRC, or one from 

the site itself? 

A. An NRC review would be based upon two things: the certification from the 

company, and any official enforcement actions taken against the individual that 

are in his official docket file. It does not include information that has not 

been formally transmitted to the individual under his license, as it must be a 

completed action. The fact that an individual is under investigation by the 

NRC may not result in something going into his file. It only goes into his 

file when we complete an enforcement action and he receives a letter. It 1s a 

formal notification, and there is guidance as to what is permitted in the docket file and what is not. Essentially, anything in the NRC docket file has 

already been presented to that candidate, whether it be an examination grading 

report result, or an enforcement action. 

Q. 301. If someone never operates the controls, and he gets a license, that 

license is renewable. Why do we then report the number of hours one operates 

the facility on a renewal? 

A. Although we will renew a license of an individual who has not stood watch, 

that information may be helpful in making judgments on renewal applications in 

which the individuals did not fully meet all 55.57(b) requirements to the letter. For example, an individual may have been unable to attend every requal 

class because he was participating in a management course. The number of 

operational hours for this person may influence our decision regarding his 

renewal. 

Q. 302. When it's time to renew the license of our shift engineers, can their 

license be renewed in an inactive status, without another examination, if they 

have maintained all of their requal requirements? 

NUREG-1262 83 
A .. For anyone who holds a lic~nse, he must be kept current in the requalificat1on program; he must be medically fit, and he must have bee• examined at some 

time.by ~RC duri~g the course of ~hat si~-year license. The requalification . exam1nat1on requirements are applicable independent of active/inactive status. 

Q. 303. If a licensee is not maintaining an active license in accordance with 

55.53(f) at the time of license expiration, what are the requirements for 

renewal? 

A. If he is not maintaining an active license, he still must meet all of the 

requirements for renewal in 55.57(b). However, he does not have to be active 

to get his license renewed. He must be, most importantly, current in the requal ification program, but he does not have to be active to have his license 

renewed. 

Q. 304. In order to obtain license renewal you must be examined by the NRC at 

least once during the six-year life of the license. What is the extent of this 

examination: written, operating, both, either? 

A. With respect to format, the requalification exam will parallel the initial 

exam1 i.e. 1 it will include both a written and operating test. The content of 

requalification exams will be based on the facility's learning objectives provided that these objectives are satisfactory. · 

Q. 305. Section 55.57 states that license renewal is going to be based on having 

passed the comprehensive requal exam and operating test administered by the 

Commission during the term of a six-year license. I believe that you have 

interpreted that to mean that an exam will be given at least once every six 

years? 

A. Yes, that 1 s what the Commission has stated .. The Commission has directed 

the staff to examine operators at least once each six years, and that's why we 

know that some people may have an exam more than once in six years. 

Q. 306. What percentage of people will you examine at a time? 

A. At least 16 percent per year, because we've got to examine 100 percent in 

six years. In fact, it will be greater than 16 percent because of the randomness involved in ensuring that candidates don't have prior knowledge of when we 

are coming in to examine them. 

Q. 307. How far in advance will an individual licensee be notified by the 

Commission of his scheduled examination date? 

A. Ten days, minimum; 6 weeks, maximum. 

Q. 308. Do you need to take examination to renew a two-year license? 

A. No. The rule is very specific: You need an examination by the NRC only 

for the renewal of a six-year license. 

Q. 309. I have some renewal submittals that will have to be submitted before 

the May 26th date, but the renewaJ is not until .after. ~o I submit them under 

the existing rules for them to come back as a six-year license? 

NUREG-1262 84 
A. The Form 398 that you use until May 26, 1987 is the same one that's in 

effect today. Even,.though you submit that version of the form, if we issue a 

license after the 26th, it will be a six-year license. Any applications submitted after May 26th should be on the new Form 398 with the new Form 396. 

Q. 310. Will the people presently holding two-year licenses have to reapply at 

the expiration of the two years or will they be automatically extended to the six-year.~ycle? 

A. They need to reapply prior to the expiration date of their current license. 

Q. 311. Considering that every utility has or will have an accredited retraining 

program, what is the justification for the random selection, which would include the possibility of having more than one exam in a six-year period, versus 

the possibility of poing an orderly schedule to include only one exam in that 

same six-year period? 

A. It is NRC's mandate to ensure that all licensed operators maintain a 

satisfactory level of proficiency at all times. As such, the required exam is 

intended to serve as a "spot-check11 to verify that that level of proficiency is 

in fact being maintained. Further, we want to ensure that operators can demonstrate this level of competence without special preparatioh outside of the 

normal required training program. The Commissioners believe that this is best 

accomplished by randomly selecting the operators to sit for the required exam. 

To the extent possible, we will coordinate the exam schedule with your regular 

cycles. But if we have reason to believe that there is something wrong with 

the program, or we have other indications of problems, we will conduct examinations at times other than during your requalification cycle. 

Q. 312. How can the Commission administer a comprehensive written exam once 

during t~e six-year cycle if the utility is administering their written exam 

spread out over a segmented period? 

A. As stated above, the Commission's mandate is to ens~re a satisfactory level 

of operator proficiency at all times. It is the facility licenses's responsibility to ensure that their required program, although segmented, maintains this 

level of proficienc~ throughout the training cycle. t 

Q. 313. Who will schedule and track each licensed operator to ensure he has had 

an NRC exam prior to renewal? ~ 

A. That's NRC's responsibility. It will be tracked in the Regions by the 

docket files on each individual which will contain the last NRC-administered 

requal exam. 

Q. 314. How soon can someone be re-examined after failing an NRC exam? 

A. We have resources for two visits to a facility per year. If the individual 

fails and is getting close to the point for renewal, we would evaluate on a 

case-by-case basis whether cur resources permit us to go back and give another 

examination before the next regularly scheduled exam. 

NUREG-1262 85 
If he's within, say, six months of renewal, and that's when he's targeted to ~ome up for an exam, that's a pretty good indicator that he's going to be taking an exam at that next cycle before his license renewal. 

Q. 315. In the past, if an operator failed the requal exam, he would go into an.accelerate~ requal program normally administered by the utility. Is that goin~ to.remain the s~m7, and, once he completes the accelerated requal and the exam~nat1on by the ut1l1ty, would that be acceptable as far as meeting the 

requirement of passing the NRC-administered exam? 

A. No. There are two different questions there. The first deals with the 

acceptability of the facility's accelerated retraining program to return that i~div~dual to licensed duties, and this depends upon the status of your requali- f1cat1on program. If your requalification program is deemed satisfactory, then 

you have the capabilities under your program of dealing with the failure of a 

requalification examination. 

The second concerns satisfying the requirement for a six-year reexamination. 

The Commission has directed the staff to administer a requalification examination to each licensee during the six-year term of the license. If he fails and 

you have a program that has been deemed satisfactory, you can retrain him and 

return him to shift duties; however, he must successfully pass an NRCadministered requalification examination before renewal of his license. 

Q. 316. Is the appeal process for the requal examination the same as the initial exam? If so, there are two problems. One is the individual's own selfrespect if he fails that exam and he feels he should not have. The other problem is that our program is being judged against the results of that requal 

exam. If there's something that we feel was amiss during the exam, we should 

have a method of recourse in having that evaluated. 

A. The answer is that the appeal process does apply as it relates to the 

administrative process. You are provided the opportunity to comment on the 

written examination through the normal process for any written examination. 

However, the individual does not have the right to request a hearing because 

his license has not been taken away. He still has a license. He can request 

an administrative review by the Division Director in the Region and a review at 

NRC Headquarters if there is a potential for the exam results to preclude 

his license renewal. 

If we were to deny the renewal of his license and he was contesting the failure 

of that exam administratively, he would have the right to a hearing because we 

had not granted the license renewal. So in that context, he would be eligible 

to request a hearing on the denial of his application for a license renewal. 

Q. 317. Why weren't the utilities allowed to make public comments on 10 CFR 

55.57(b)(2)(iv), license renewal requirements? 

A. The Commission decided to add Section 55.57(b)(2)(iv) between the time of 

the proposed and final rules to allow it to examine licensees during a 6-year 

license period. This decision was an outgrowth of comments on the proposed 

rule and is consistent with the Commission's Policy Statement on Training and 

NUREG-1262 86 
-----··--·------·-·- ---

Qualifications, and with Section 306 of the Nuclear Waste Policy Act. Part of 

the reason for that decision is that we indicated in the policy statement on 

training and qualifications that we would use the requalification exam~n~tior. 

as a mechanism for judging the validity of the industry-a~credited tra1n1ng 

program process. The Commission is continuing to do that. 

We have moved out of the training review and are instead judging the ability cf 

the individual to perform after training. We make that judgment through an 

examining process. That 1 s the reason for it. The Commission has indicated 

their policy both through the policy statement, which was publicly noticed and 

available, and through a continuation of staff practice. 

The Commission tied it to renewal to ensure that there was a clear understanding on the part of all operators that this was required, and to eliminate the 

question of 11Why me, 11 because in the past, when the staff selected operators for examination, there was always a question of, 11 How did I get chosen, 

why not someone else? 11 In this case, it 1s clear that it applies to all licensed operators who hold a six-year license. 

Q. 318. Will future NRC requalification exams given in conjunction with replacement tests be modified replacement tests as in the past? 

A. NRC requalification examinations are developed to evaluate the adequacy of 

the facility licensee's requalification program. Where replacement training 

program and requalification training program objectives overlap, duplication of 

questions is acceptable. 

Q. 319. Since it is six years before any renewals will require the completion 

of an NRC exam, when will the process of 11 10-day notice exams 11 get started? 

A. As of the effective date of the rule. We can notify selectees up to six 

weeks in advance of the examination date, but in no case will less than 10 days notice be given. 

Q. 320. Does the six-year license apply to nonpower reactors? Do their licensed 

operators require an NRC exam prior to renewing a license? 

A. Operators of nonpower reactors will receive six-year licenses upon 

satisfactory license renewal after their current licenses expire. License 

renewal will be in accordance with 55.57. 

Q. 321. When will the requirement for an applicant to be examined by the NRC 

prior to renewal be implemented? 

A. That requirement will become effective for all six-year licenses granted 

after May 26, 1987. 

Q. 322. What will the basis be for 11 continued need11 under 55.57(b)(3)? 

A. It is the facility licensee 1 s decisfon as to whether there is a continued 

need for an operator. We will not question the judgment of facility management. 

Q. 323. Can the requirements of 55.57(a)(4),(5), and (6) be certified on the 

Form 398? 

NUREG-1262 87 
A. Part 5~.~7(a~(4), assurance that the applicant has satisfactorily completed the r:qual1f1cat1on program, and 55.57(a)(5), assurance that the applicant 

has ~1~cha:ged license responsibilities competently and safely, can both be 

cert1f1ed in Form 398. For 55.57(a)(6), certification of medical condition, 

a Form 396 is needed. 

Regualification (Subpart H, Section 55.59) 

Q.324. What is required for Commission approval of a requalification program? 

A. You simply certify to us that you have an accredited program that is based 

on a systems approach to training, and that's sufficient . 

. Q: 325. In Generic Letter 87-07, page 24, it states that "The specific cycle ,. · w111 be approved by the NRC as part of each facility 1 s training program. 11 What 

does this refer to? 

A. It covers programs which are not approved through the accreditation 

process. 

Q. 326. On the training program approval, if you have an accredited program and 

you certify that you're doing an SAT process, that's one method. You also 

listed implementation of INPO Guideline 86-025 as another approach. Can you explain this? 

A. The accreditation process has a hierarchy of requirements, the top level of 

which are called objectives. You must meet the intent of the objective in order 

to be accredited, and those are contained in INPO 85-002. The Commission has 

reviewed and endorsed the INPO accreditation objectives and criteria as meeting 

the SAT or systems approach to training. I believe there are 12 objectives. 

Each objective has a number of criteria; meet the criteria and you meet the 

objective, but the opposite is not always the case. That is, you may not meet 

one criterion, but you still may meet the intent of the objective through some 

other mechanism. You go through the criteria and objectives for your selfevaluation. 

Subordinate to those are the guidelines for licensed operator training, for 

maintenance training, and for other areas. One guideline is for continuing 

training for licensed operators (INPO 86-025); it gives information about the 

content appropriate for a continuing training program. It also describes how 

you evaluate and feed information from plant operations and performance evaluations back into the process. 

You clearly do not have to cross all the t's and dot all the i's of everything 

that's in that guideline. That guideline, however, constitutes an acceptable 

method of implementing a performance-based, SAT-based continuing training program that the staff would find acceptable. 

The next level below guidelines are good practices. Those are things which 

INPO has seen facilities do that worked particularly well for a facility, and 

they have provided guidance on those. 

NUREG-1262 88 
We have concluded that if you are accredited you understand what the objectives 

are, and how criteria are used, and what the process is for developing a systems 

approach to training. We think that understanding, along with recent INPO 

training guidelines provide an adequate basis for you to review your own pr?g~ams 

and certify to us that your program is based upon a systems approach to training. 

We believe that there are two final parts to that. You need to look at the tasks 

that are relevant to the job, decide which ones are appropriate for training on 

a continuing basis, based upon such criteria as importance of the task to the 

safety ·function· and frequency of performance. Clearly, emergency procedures 

would fall into that category. Shift relief and turnover would be outside of 

that category, such that your continuing training program would not address 

shift relief and turnover. 

If you've operated continuously between outages, you would not necessarily 

have performed plant startups and shutdowns. In that case, you may want to 

fold the startup and shutdown into the continuing training program, and do 

that on a simulator. 

It's that type of flexibility, and reviewing and determining the content of 

the program which we feel is the most important attribute of the change to the 

regulation. It gives you the flexibility to tailor your program to the needs 

of the job incumbents, and to bring them up to a comparable level with the 

initial training programs through the INPO accreditation. That's the process 

we think should be followed. It doesn't mean that everything has to be done 

in INPO 85-026 with respect to simulator training, or INPO 85-025 with respect 

to continuing training. Those are guidelines, and you really need to address 

the issues as to how much of that should be followed or done with INPO, not 

with the staff. We are not in the position of reviewing and determining what 

constitutes INPO requirements. We want to move out of that. We will provide 

our comments to INPO should we see problem areas for INPO to address generically 

with the industry. We do not want to get into the mode of providing guidance 

to individual utilities on how much of an INPO document needs to be followed 

before the staff would accept a certification. That's for you and INPO to work 

out. 

Q. 327. While someone is in an SRO upgrade for (say) ten months, he is not officially in the requalification program. How is that going to affect that 

inactive status? 

A. If your upgrade program meets the objectives of your requal program, you 

can take credit for that. However, if there is a differential there might be 

some areas that are not covered at all, but are covered in a requalification 

program. If that individual is no longer current in requalification, to resume 

active status, he would have to receive the remedial training necessary to make 

him current with the requalification program. Simply being in the upgrade 

program does not, necessarily, compensate for the requalification program. 

We hope that that's not an issue that we face very often, because we expect 

that most candidates who go into an upgrade program would receive a license as 

a senior operator and remain cognizant of changes, LERs, and significant events. 

And upon the date they receive a license, they can manipulate the controls and 

NUREG-1262 89 
direct the a~ti~it~e~ of others .. so, it's only when there's a period between t~e end of his ~raining and the time he gets a license when you may want to use 

him as a reactor operator. He may have to stand some parallel watch with the 

reactor oper~tor before resuming duties. And that's the point when you would 

have to certify that he had completed the necessary requirements of the reactor 

requalification program, if there are any aspects that were not covered in the 

SRO operating training. 

Q. ~2~. Since.S~cti?n 55.59(b) indicates that the Commission would accept add1t1onal training in lieu of a licensee's participation in the requalification 

program, is it acceptable for a utility to remove certain license holders from 

the requalification program, yet have them retain their licenses if this additional training was provided to them? 

A. No. Section 55.53(h) requires completion of a requalification program as 

a condition of a license. In general, a licensee who is permanently removed 

from the requalification program no longer satisfies this condition of their 

license, and thus has been determined to no longer need a license by the 

facility licensee under Section 55.55, Expiration. Only under extenuating 

circumstances (e.g., special temporary assignment, extended illness, removal 

from shift to enter a degree program, etc.) would the provisions of Section 

55.59(b) be invoked. This will be handled on a case-by-case basis. 

Q. 329. There is no requirement to modify the Requalification Program documentation. We just have to follow the new rule, ~orrect? 

A. That is correct. You must follow the new Rule, or your existing program, 

whichever is more restrictive. But you may perform a 50.59 review to bring 

your existing program in conformance, and simply submit that. Or, if you need 

an amendment to the license, you request the amendment, and you would have an 

administrative change approved to put your program in conformance with the Rule. 

Q. 330. Most facilities have an NRC-approved requalification program in the 

FSAR. For utilities that cannot certify their requalification programs, either 

because their requalification program has not been approved by INPO, or it has 

been approved and does not meet the INPO 86-25 requirements for SAT, how will 

we implement 10 CFR 55? 

A. You will continue to follow your approved program of record, as is documented 

in the FSAR, until you either modify it, bring it up to the INPO guidelines in 

86-25, or take some other action to modify it. That's one way of doing it. You 

may be able to discuss with INPO other alternatives. But you follow the program 

of record, as modified by the Rule. 

Q. 331. What is the difference between a requalification program 24 months long 

followed by successive requalification programs and a continuing training program administered throughout the term of the individual's license? Does the 

Commission mean to imply something by use of the word 11 requalification11 versus 

"continuing training? 11 If so, what is the distinction? 

A. There is little difference between the two. We expect you on some basis 

to step back and take a look at the performance of your licensed operators and 

NUREG-1262 90 
------------------------

modify your program appropriately to reflect those areas that need continuing 

training. From that aspect, we chose 24 months, consistent with the previous 

program, to be a point at which you would take that formal look at your program. 

There is no distinction except that the law used the te-rm 11 requalification, 11 

and that's why we continued with that term. 

Q. 332. The requalification program must be conducted for a continuous period 

not to exceed 24 months. What is the purpose of the 24-month limit? 

A. Because it 1 s consistent with defining a fixed-length program. Since the 

previous period was 24 months, we retained it. 

Q. 333. Is there an intent to look at a 24-month period as an isolated section 

and try to meet certain requirements within a 24-month period? 

A. The intent is that at the end of that period we want you to do a comprehensive evaluation of the program and decide how you need to modify it for the 

next cycle. If you want to do it in 12-month or 18-month cycles, that 1 s also 

acceptable. If you want to tie it to refueling schedules that 1 s also acceptable. The cycle cannot be longer than 24 months, however. 

Q. 334. What is considered a "continuous period" with respect to the conduct of 

the requalification program? 

A. It 1s 24 months, then you start over again for another 24 months, and then 

another 24 months, so that you 1

d have three 2-year requal cycles in the six-year license period. 

Q. 335. Will the program that breaks for, say, a two-month refueling outage be 

considered a continuous program? 

A. By 11 continuous 11 we mean that it 1 s the same program for operators on shift 

as well as off shift, and it 1s the program as you 1 ve described it. There may 

be cases where you want to stop it for a period of time, where you are using 

segmented training and you want to teach one segment, and in the next segment 

you, in fact, may have some particular training in the outage that you want to 

cover prior to the outage. 

That 1 s the flexibility you have under the systems approach in defining your 

needs are and sequencing accordingly. 

We want one program for all licensed operators. We don 1 t want one schedule or 

program for people on shift and a different schedule or program for people who 

are not normal watch-standers on shift. 

Q. 336. Does NRC want to see a comprehensive evaluation of the program on a 

biennial basis? 

A. Yes, at least on a biennial basis. That 1 s the intent of the biennial 

qualification examination being comprehensive. Part 55 requires that the 

evaluation be used in determination of subsequent continuing training 

requirements. 

NUREG-1262 91 
Q. 337: On Page 24.of the suppleme~tary information provided to Generic Letter 

87-07 1s the following statement: The frequency of the comprehensive requalification written examination has been changed to a maximum of every two 

years." Where is this statement to be found in the text of 10 CFR 55? 

A. The st?tement "maximum of two years" with regard to examination frequency 

can be derived from 10 CFR 55.59(a)(l) under "Requalification Requirements" 

where it says 11 Each licensee shall successfully complete the requalification 

prog:am.developed by the facility licensee that has been approved by the 

Commission and that the program shall be conducted for a continuous period not 

to exceed 24 months in duration." The next paragraph says "pass a comprehensive 

requalification examination and an annual ope.rating test. 11 So, by inference, 

the written examination only has to be administered on a two-year basis, where 

the operating test is required on an annual basis. 

Q. 338. Does this statement mean that written requalification exams can occur 

less often than every two years? 

A. No. It must be conducted concurrent with the two-year program. 

Q. 339. If a utility currently has an NRC requal examination scheduled for the 

first week of June 1987, what will be the impact of this rule on the examination? Will the examination content be covered by the old rule, or will the 

content be upgraded t~ the requirements of the new rule? If the examination 

will be covering the content by the old rule, when can we expect examinations 

utilizing the content covered in the new rule? 

A. There will be no change for the June exams because preparation of those 

exams has already begun. Only exams given after July 1st of this year will be 

able to conform to the new rule. 

For clarification, there are clearly some changes in the rule that will change 

the examination. We don 1 t expect that there will be changes in the content of 

the exam, based upon a requal program that's already been done under the current 

Examiner Standard, ES-601, where we are auditing individuals who have two-year 

licenses and auditing the company•s program. 

Clearly, however, the operating test portion will be documented on the new Form 

157, and we will be addressing areas that are required by the regulation in 

constructing the examination. We aren't going to be testing on areas outside 

of the requal program, or the current licensing program at the facilities, but 

there will be some change in forms and in the documentation process. The reason 

for that is that those examinations are already in preparation now, and you can't do 90 days worth of work in the transition period, so we will be continuing 

to use the materials that were submitted prior to the effective date of the rule 

to construct the first few exams after the effective date of the rule, but there 

will be some changes in forms and processing and how it's handled.· 

Q. 340. Can the written requalification examination be given in several sections 

over a period of time or is the intent to administer one complete examination 

at one time? 

A. If you currently have a requalification program in which you've committed to 

an annual comprehensive written exam, you have to continue giving that annual 

NUREG-1262 92 
comprehensive written exam until you have sent in the ~ppropriate d~cumentation 

that you have an SAT-based program and that you 1 re moving to a continuous program that is going to be conducted over a period of 24 months .. That 1

s one way 

of doing it, sending us a letter telling us when you are accredited and that you 

have a requalification program that 1s SAT-based. 

The other alternative is what we have done in the past, which is the 50.54 

change, where you would notify us that you 1 re changing your program. So if 

you 1 re committed to an annual written exam during this transition period, you have to continue to meet your commitments until you 1 ve notified us that you•re 

changing. 

Along those lines, with regard to the segmented exams, if you currently have in 

your program an annual comprehensive examination, then we will expect you to 

continue that. 

If you have an accredited program and the segmented approach to evaluation is 

an acceptable methodology under that program, we will allow you to implement 

your program. 

But realizing that the NRC examination will be a comprehensive examination, we 

expect that the program evaluations that you implement will be comprehensive in 

nature, also. For clarification, weekly quizzes that may be given following a 

week of instruction tallied together to form one exam probably would not meet 

the comprehensive intent of this evaluation process. 

Q. 341. Written examinations for requalification will be based on initial license material. Should the exam not be limited to the scope of the approved Requalification Program? 

A. The requalification exams are intended to be performance-based and operationally oriented. To the extent that they're made available to us in the 

submittal following the 90-day letter, we intend to use the facility licensee's 

learning objectives that pertain specifically to the continuing training 

program. 

We anticipate that when you have an SAT-based requal training program, it would 

be modified from time to time, depending on the needs of the job incumbents. 

As your needs change, you would modify your program. 

We anticipate that those learning objectives might be different from time to 

time. We would, of course, tailor our exams to those learning objectives. 

Q. 342. Would it be NRC's goal to document those differences between the initial 

exams and the requalification exams? 

A. We want you to certify that you've got a requalification program that's 

based upon a systems approach to training; and you should document those 

differences. 

That's why we say that when you do the initial task analysis, you should identify 

that subset of tasks which are appropriate for continuing training. 

NUREG-1262 93 
We believe that to the 7xtent you fol~ow the.INPO guidelines in 86-025, you will 

have ?one that. We believe that that s a fair representation of the type of materia~ that should be contained in continuing training and should be used for 

the basis of a requalification examination. 

Q. 343. Where do we find the standards and criteria for administering the comprehensive exams for the requals? 

A. The standards and criteria are identified in Section 55.59, and as far as 

our-implementation, they will be clarified in ES-601. 

Q. 344. You said previously, where there is an annual operating exam and then a 

comprehensive written exam every two years, that the NRC exam would count for 

the operating portion of the examination. Why would that not also be acceptable for the written portion, if individuals were scheduled to have their written exam during that year? 

A. We intend for it to be both. If NRC administers a written exam, that will 

substitute for the facility written; if NRC administers an operating test, that 

will substitute for the facility operating test for that year or for that 

program, whichever is appropriate. 

Q. 345. Will section 55.59(a)(2) change the policy of using a licensed SRO to 

write/review the written requal examination? If the written examination is 

given every two years, would he still fulfill the requirements of this section 

since technically he is not taking the exam? Similarly, will the SRO who 

writes the performance exam, and is thus exempt from taking the exam for that 

year, comply with this requirement? 

A. Section 55.59(a)(2) will not change the policy of using a licensed SRO to 

write or renew these examinations. However, it is the Commission 1 s intent that 

all licensed operators be enrolled in the requalification program and take the 

requalification exams; further, an individual must take an exam that he did not 

write or review. 

Q. 346. What will be the duration of the grace period for the implementation of 

the new 10 CFR 55? 

A. The rule goes into effect on May 26, 1987. There are grace periods identified within the rule for certain aspects of the rule, and those are stated in 

the rule. 

These include operating tests on an annual basis. If an individual is licensed 

on May 26, 1987, and holds a license, he must have had an operating test by 

May 26, 1988, within one year. For an application which you submit in the 

middle of that period -- after, say, six months has expired -- he may or may 

not have had an operating test, because you would not have been required to 

complete an operating test for everyone until after one year. So if it says 

you've got to examine annually, then one year after the effective date of the 

rule, everyone should have had an operating test. Another example is the 

comprehensive written examination to be done at least each 24 months. After 

the rule has been in effect for 24 months, everyone who was licensed on the 

NUREG-1262 94 
first day that the rule went into effect shall have had a comprehensive exa~ination, unless, of course, you are accredited, and then you may use a segmented 

exam. 

Q. 347. It appears that comprehensive requalification written exams are required 

only every two years and operating tests are required once per year. Is this 

true? 

A. It is true that the written examination will go to every two years unless 

your program commitments are more stringent. If your current program requires 

an annual exam and it is not an accredited program, then you will have to notify 

us if you intend to reduce that commitment. If it's an accredited program, then 

you can make the changes as appropriate. 

Q. 348. Our past requal programs, for those facilities which don't have plantreferenced simulators, have not included an operating test. They have included 

some operating evaluations, but not a pure test in the context of the new 

regulation. Some of the currently licensed operators will be up for renewal 

immediately, as soon as the new 10 CFR 55 goes into effect. Will there be a 

transition period during which it would be possible to get a waiver for those 

operators because they will not have had an operating test? We do not have a 

simulator certified by NRC to conduct an operating test. And, in fact, I'm not 

even sure if, under the new regulation, we could use our current off-site 

simulator to conduct an operating test. So, how do we address renewal of 

licenses for the period between now and when we get our plant-referenced 

simulator; or will there be some time after which we will have to do an 

operating test? 

A. During the period between the effective date of the Rule and one year 

following, an individual may not have yet had an annual operating test, and 

you may put him up for license renewal. After one year, everyone should have 

had an operating test. The issue of whether an operating test is on a simulation facility, or conducted as a plant walk through is a different issue. 

At least the plant walk-through portion will be required. The issue of doing 

it on a simulation facility, that would be required by May 26th, 1991. Prior 

to that time, if you have certified or approved simulation facility, you would 

also do it on the simulator. If you are currently using a simulator, and we 

are conducting examinations on it, we expect you to continue to do so, and 

within one year of the effective date of the rule, start examining candidates 

using your current simulator as a part of the operating test for the requalification program. Also, you have to make sure that the documentation that you 

provide for that annual operating test addresses all 13 items in the new 

Regulation. The Form 157 is the way that we are going to check that. You can 

use alternate ways, but you must make sure you document all 13 items. 

Q. 349. During this one-year period of transition, do we document, by exception, 

and ask for a waiver on our requests for renewal? Would that be the appropriate way to handle that? 

A. No, that would not be necessary. 

NUREG-1262 95 
Q. 350. Must.a.facility administer annual operating tests to licensed operators before a cert1f1ed plant referenced simulator is available? 

A. Yes. Even though it may not be part of your requal program now you have 

to start administering an operating exam, and if you don't have a simulator, 

then you would give an oral exam, a walk-through type like we do on the plant. 

This is one aspect of the transition into the new rule where we are not going 

to look for everyone to have completed an operating test on May 26, 1987; but 

by May 26, 1988, everybody who's been licensed for that last year shall have 

completed an operating test on the facility. 

We're using a more common sense approach, so if you submit an application for 

renewal for a candidate who has a two-year license now, and you submit it in 

!our months, that individual may not have had an operating test, as is described 

1n the rule, because he has not been under that rule for a year. We would still 

renew the license and issue him a six-year license. 

After everyone has been under the rule for one year, we would not find that he 

had met the terms and conditions of his license if he had not had an operating 

test, because the operating test is to be conducted each year. 

Q. 351. If an SRO directs the proper action, does that satisfy the ability to 

perform the actions necessary? 

A. Yes. 

Q. 352. 

utility. 

We've talked about an annual operating exam to be administered by the 

What constitutes an 11 operating exam? 11 

A. If you currently have a simulator on which you or we are conducting examinations, then you must include an oral and a simulator examination. It is 

not performance of practical factors in a training environment. We've had, 

for instance, the requirement of the Denton letter to perform certain practical 

factors on an annual basis. People take simulator training and perform the 

practical part until successful, whether it takes one, two, or three tries. 

We are interested in a structured examination. We are not interested in training on the simulator. The structured examination must meet the requirements of 

the regulation as it relates to sampling those areas that are specified under 

the regulation. It is a combination on the simulator, if you have one, and in 

the plant. If you don't have a simulator, it must be done in the plant. 

Q. 353. What constitutes by definition, an annual operating exam? In our NRCapproved requal programs we administer what is called an accident assessment 

exam. It's an operational type exam, documented by written examination, which 

tests operator knowledge and on how they can operate the plant, implement 

procedures, diagnose a situation, a transient, an accident, or whatever. Does 

this meet the annual operating exam criteria? 

A. Look at what is specified in the Regulation by way of observed behavior for 

the operating test, and assure yourself that the way you are implementing the 

exams covers those 12 items for an operating test for requal. The start up 

NUREG-1262 96 
·····-------------

shut down is the only portion that 1 s dropped out. But control board familiarity, 

those kinds of things are still being assessed. You need to look at your 

program, and judge whether you have met those 12 items for the operating test 

for requal. 

Q. 354. Must the annual operating exam for requalification be given in one 

time frame or can that also be broken up into various pieces throughout the 

year? It 1 s very difficult to get everybody done in one year by the training 

staff. 

A. For a candidate, it needs to be done at one time, but if what you are 

asking is that you have 30 people that need to have an operating test, and you 

want to spread out the 30 tests over the period of a year, the answer is yes. 

But you can 1t take an individual and give him a walk-through today and some 

simulator evaluation tomorrow and then some six months from now add those 

three pieces up. That would not meet the intent of an annual operating test. 

Q. 355. Not even if you broke up the in-plant and the simulator between the different weeks in requal, and catch them one cycle a week, get a crew in on the 

simulator and maybe the next time they come up, five weeks from then, get that 

same crew up on the plant? 

A. Although we have explicitly approved such an approach for the written 

examination where you are using segmented tests, provided you show that the 

sum of the parts equals the whole in the comprehensive exam, we have not concluded that such an approach is acceptable for an operating test. Our position is that an operating test, to be effective, must be administered at one 

time, ·and must cover the 12 items in the rule as a minimum. 

Q. 356. Section 55.59(a)(2) implies that the requalification program includes 

observations and evaluations of performance and competency by supervisors or 

staff members during actual abnormal and emergency procedures at the plant. Is 

this required? 

A. This goes to part 5, evaluation, of the definition of systematic approach 

to training. The intent is that when the casualties are practiced on the simulator, performance would be evaluated by staff members as part of that systematic 

approach to training. It's not intended to have those evaluations done on the 

actual plant. 

Q. 357. The criteria for the NRC comprehensive requalification examinations are 

similar to the standard criteria for an initial examination listed in 55.41 and 

55.43. What is the perceived difference between the two exams? 

A. The requalification exam requires a sampling of criteria. If your requalification program is based upon a systems approach to training, you will have 

reviewed the tasks from the initial program which are appropriate for continuing 

training. You will have chosen those on some criteria, such as frequency of 

performance, safety significance or other criteria. That 1

s one way of determining the content of your continuing training program. 

Another way is the feedback from performance in the plant: licensee event reports, and the like. Another area would include facility design changes and/or 

NUREG-1262 97 
changes in procedures. Those are the subject areas that we would tend to focus 

on for a requalification examination. 

When.Y?U move to learning objectives for your requalification program that have 

cond1t1ons and standards, we would use that as the basis for sampling the 

content of the examination. 

In the meantime, because that's not fully in place yet, we are using such things 

as the K/A catalogs, which identify the importance of job tasks and are based 

upon·the industry generic job task analysis. We are also using a sampling plan -- it was referred to as the "examiner handbook11 -- where we sample from that 

catalog to ensure that we get a representative sample of the knowledge, skills 

and abilities -- the skills being done on the simulator--that are appropriate for an NRC examination. 

We intend the initial examination to be different from the requalification 

examination. We will look at the two, even though we developed them in parallel; and questions which are not appropriate for a job incumbent -- questions, for instance, on watch relief and turnover or other things which he does on 

a repetitive basis -- would be excluded from the requalification examination. 

We believe that through the informal review process of appeals, and the facility review of the written examinations, there are sufficient safeguards in place 

during the transition period to ensure that there was a content-valid examination that was indeed related to job performance. 

From our review of examination reports from all the regions, the weaknesses 

concern knowledge of events that have occurred at their own plant, significant 

events at other similar plants, changes to design, changes to procedures, and 

selection of those tasks from the initial program which are relevant to training 

on a continuing basis. We do not help the operators if we simply repeat the 

initial program for continuing training. That's not the intent. 

Q. 358. How are the current guidelines, which allow requalification examination 

site visits to be extended to every three years based on good SALP ratings or 

accreditation, going to interface with 100-percent requalification every six 

years? 

A. Basically these are two different programs. One is a programmatic evaluation looking at the adequacy of the requalification program. The other deals 

with the Commission-directed re-examination of each licensed operator on a 

six-year basis. In the next couple of years, though, we don't expect it to 

change very much. It's going to take some time to build up a pool of six-year licenses so that we would be conducting the examinations in accordance with 

this regulation. So in the near term, those facilities which have better 

performance and have achieved INPO accreditation would have a longer period between NRC visits. 

Q. 359. On the question of randomness, if in year two a candidate passes the 

E:xam, and in year four he fails, the rule says he has to pass it once during 

the six years. Will that stop the renewal of his license? 

A. No. If he had passed one exam and failed a second one, but was re-examined 

by the facility after appropriate remedial training and returned to watch, he 

NUREG-1262 98 
would have passed an exam and that would be the basis for the license renewal. 

The rule does not say the last examination administered by the NRC. It says 

an examination during the six-year term of the license.· And we recognize that 

some people may have more than one. 

Q. 360. What process will be used to schedule the NRC-administered written 

examination and operating tests during the term of a six-year license? 

A.' It is our intent that this will be a random test, performed on a random 

basis. We would try not to have double jeopardy, where an individual takes 

more than one NRC exam during his six-year term. But he may. We will have to 

coordinate with the facility. We would, in our 90-day letter, ask for lists 

of people who would be eligible to take the NRC exam. This would include all 

licensed individuals at the site. If there were individuals who had a vacation 

scheduled during that time, or if there were some personal hardship, we would 

want to know abou~ it. We want to work with your people 1 s needs as much as 

we can. 

Q. 361. This question addresses the random requalification examination and the 

pending notification. A lot of emphasis is placed on team work and communications, even though the license is granted to an individual. Admittedly, 

periodically we may rotate a person within a shift due to illness or vacation, 

etc., but most of the people, normally three out of the four, usually remain 

the same. The potential exists for administering a simulator examination, 

potentially to four people that don 1t work together normally. Have we considered the potential jeopardy there, that we have created an environment contrary to the way we have been trying to teach the operators, in particular going to the plant-referenced simulators? 

A. The examiner standards indicate that when selecting people from shift, 

you select one crew. That is the mechanism we use. And one crew is approximately 20 percent of those people on shift, unless you have a six-shift 

rotation instead of five. And then we look at approximately 20 percent of the 

operators who are not on shift, the day-shift workers. 

To the extent we can, we would put them into the crews where they normally 

work. But when you consider all the other constraints, such as those who have 

six-year licenses, those who have two years, the time frame for renewal, etc., 

that will not always be possible. To the extent we can, we want to accommodate 

your personnel. We would try to coordinate the examination visits with the 

requalification cycles that you are already using. In fact, in the past we 

have allowed the facility to identify how they wanted to combine the crews. 

We just say these are the guys we are going to see on this schedule, and you 

tell us how you want to group them. 

But at the same time, there is not going to be a lot of advance notice to the 

individual as to when he is going to be examined. It will be on the order of 

ten days to six weeks. Although there may be some comfort in being examined in 

the team environment in which training takes place, transfer between teams is a 

practical reality with which each operator must be equipped to deal, both in 

the plant and in the NRC exam. 

Q. 362. Will a representative sample. group of license holders be tested or will 

the whole license complement be tested? 

NUREG-1262 99 
---------------

A: In keeping with the Commission directive, it should be a random sample of 

license holders. All would be subject to exams. We would coordinate that with 

you if there were severe hardships but that would have to be handled on a caseby-case basis. · 

Q. 363. This concerns the random examinations of licensed operators. How far 

in advance will I know who will be examined? When will I be supplied with the 

list of names, saying that on this day, these people will be examined? 

A. ·You will be notified of the examination 90 days in advance in accordance 

with ES-601. Typically, ten days to six weeks, prior to the examination, we 

wil 1 notify you of the i ndi vi dua 1 s who have been randomly selected for "the 

requalification program evaluation. 

Q. 364. Will NRC notify the facility in time to facilitate preparation of the 

license holders before taking the requalification exam? 

A. We will provide ten days to six.weeks notice. It was exi;rlicit direction 

from the Commission to ensure that examining is done on a random basis for 

reasons that are associated with evaluating the continuing training program, 

and evaluating and ensuring that the candidate maintains proficiency and an 

appropriate knowledge level over the duration of his license. 

We will ~oordinate the scheduling of examination visits with your regular requal 

program schedules and/or your replacement examination schedules to the extent 

we can. But our resources are limited. We are budgeted for two visits per 

year to a facility. And if you have a need for more than two to accommodate 

some activity, it 1 s likely not to occur without adequate adv~nced planning. 

And we will choose candidates from among those who have not been examined by 

the NRC before we select someone who already has been so examined. However, 

some people will be examined twice, so that those who got examined early in 

their cycle shouldn 1 t make the assumption that they're not going to see the 

NRC again for the duration of that period. 

Q. 365. In the past NRC tested requal every two years and the operators were 

drum-head tight until somebody was randomly selected. Then they relaxed for 

two or three years, depending upon whether everybody had gotten accredited. 

And then the cycle was repeated. 

I 1m under the impressioQ that neither NUMARC, nor the operators, nor anybody 

else, had an opportunity to critique these particular two paragraphs prior to 

having seem them here. It appears to me that as a minimum, NRC is going to 

have to give a requal test once a year, if I have requested a hot license test 

once a year. 

A. Your perception is quite accurate. The Statement of Considerations is the 

vehicle that the Commission used to provide directions to the staff on how to 

implement the Regulation, which has always permitted the staff to administer 

requalification examinations. The fact that the requalification examination 

has been made a condition of license renewal is new. 

NUREG-1262 100 
There was some concern in the past, of 11 why me? 11 11Why not this other guy? 11 

By putting it in the Regulation, and indicating what the intent is, it becomes 

clear that everyone will, at some time during that six-year license, be examined 

by NRC in order to have his license renewed. 

We are accepting a certification by the facility for two written tests and five 

operating tests per six years, but the staff will continue to examine in some 

cases. That is, we will simply choose not to accept the facility 1s certification at that time, and we will examine the individual. There may be some cases 

where an individual will be examined more frequently than once each six years. 

Q. 366. If an operator gets his license renewed, and is tested in the first year, 

my arithmetic says that he can 1t go but one year beyond his renewal. Then, 

clearly, the frequency is going to be greater, by definition, than once every six years. 

A. Correct. That's why we use the term at least once during a six year license. 

Q. 367. These questions are related to the NRC-administered requal. Would it 

be possible for an individual to be selected twice during the six year period 

before all other individual licensees were selected once? 

A. We intend to sele~t people who have not been selected before selecting 

someone a second time. But that does not preclude this from happening, if we 

got everybody else. If we've been through all of the people with six-year 

licenses, and we are still sampling, it is possible for an individual to be 

examined twice. 

Q. 368. So, it 1s random, but the pool from which the random selections are made 

gets smaller as people are selected? 

A. It could get larger, based upon more six-year licenses being issued. At 

some point it will reach equilibrium, where everybody has a six-year license. 

Q. 369. Is this a testing of the requalification program, or is it testing 

human beings every six years? I feel that it may have been a step backwards in 

raising the anxiety level of the population of operators who are going to be up 

tight every year. That's why I don't understand the Statement of Considerations, because I'm just concerned about those people. 

A. It says that we're going to test so that nobody goes more than six years 

without being tested, and means that some are going to get examined more than 

once in six years. It's our view that if a licensed operator is going through 

an effective, continuing training program, then there shouldn 1 t be any concern 

with that person getting an NRC exam because our exams are designed to confirm 

that the individual has maintained a minimum acceptable capability. If he is 

going through a continuing training program, our expectation is that he is way 

above the minimum that's acceptable. 

Q. 370. I feel perfectly comfortable that our operators, and our supervisors on 

shift can safely operate our units. The vehicle you are using to measure the 

requalification program is improperly aimed at obtaining those results. If we 

NUREG-1262 101 
focus the requalification program on problem areas design changes and events 

in the industry, it's fairly narrowly focused. But the exam looks'at a target ~r~a beyond.th~t, that has not been covered, for memory/recall type things, and 

1t s unreal1st1c to see the operator be able to pass that, or the senior 

operator, or anyone else. 

But if the.exam were focused on what the requal program had focused on, then 

the fo~us is on target. You ought to be able to pluck an operator off shift, 

have him evaluated, and expect that he'll do fine. But when it's not aimed at 

the same material, very little probability exists of him doing well on the exam. 

A. We understand your comment, and we recognize that both groups are trying 

to move to the point where we are using content-valid examinations to measure 

performance. We have a ways to go, and we are working on that. And we think 

you all have ways to go in describing adequately the content of the continuing 

training program. Eventually, we will get to the point where we have closure 

on the scope and content validity of a requalification examination. 

Until then, there is going to be anxiety. We believe that with the administrative review process for examinations, there are adequate safeguards to ensure 

that improper questions can be challenged, and that the questions are appropriate to the job. We have provided some tools to do that, and they need to be 

used. And until we get conservative feedback both ways, and recognize that the 

objective is to measure that individual's performance, the imperfect tools that 

we are using now aren't going to get much better. 

And that is a challenge to the industry, to really take a hard look at the INPO 

guidelines in continuing training programs, and to consider how your program is 

modified to meet those objectives. 

We've had problems with exams in the past, and we probably will in the future. 

We have found problems with requal programs in the past, and we'll probably 

find problems with those programs in the future. But we have not taken action 

against individuals by way of revoking licenses, or other activities. We do 

expect that until remediation is provided, those who fail are removed from 

shift-standing duties until they are brought back up to speed. 

And if they feel that the examination is unfair, they can request a review of 

the examination by the Regional Division Director, and they can subsequently 

request a review by the Director of DLPQE. We are serious about improving the 

quality of exams and getting them content validated. 

Q. 371. What would happen if, by chance, an individual wasn't selected during 

the six year period? 

A. The NRC intends to administer a comprehensive written exam and operating 

test to every licensed operator at least once during the six-year term of the 

license. In the unlikely event that an individual did not receive such an exam, 

we would take immediate steps to initiate one. However, we would have to consider that he had made a timely application for renewal, and as a result, his 

existing license would remain in effect. But we would not issue a new license 

until we had examined the individual. 

NUREG-1262 102 
Q. 372. What occurs when an individual fails the NRG-administered requalification exam? 

A. First, the individual is removed from licensed duties and placed in an accelerated training program. Once he has successfully completed all remedial 

training, he must pass a facility-administered examination to ensure that all 

weaknesses have been corrected. If that facility's training program received 

an NRC rating of marginal or unsatisfactory, this examination may be overseen 

by the NRC, in keeping with the alternate approach to requalification evaluations which was recently adopted by NRC. 

In addition, it should be noted that in accordance with Section 55.57, all 

operators must pass an NRG-administered requalification exam during the term of 

the six-year license. Therefore, if this individual failed the NRG-administered 

requalification examination and has not passed another NRG-administered exam 

during the term of his current six-year license, his license will not be renewed 

until he has passed such an examination. 

Q. 373. Is there any minimum period before a person gets into the requalification pool, after getting an initial license? 

A. The clock starts the day he gets his six-year license. But if we give a 

requalification program audit, and there are individuals on site with two year 

licenses in effect, they are also in the pool to be randomly selected for an 

evaluation of the requalification program, in accordance with Examiner's 

Standard 601. So, don't assume that only six-year people may be chosen. 

Q. 374. Part 55.59 states that in lieu of accepting certification by the facility licensee that the licensee has passed written examinations and operating 

tests administered by the facility licensee, the Commission may administer 

comprehensive requalification written examinations and an annual operating 

test. Will this testing take the same form and frequency as the previously 

established 20 percent testing at 50 percent of the utilities in the Region? 

A. Yes. It will have essentially the same form except it will now be about 

16 percent of the operators at all facilities in the region every year. For 

clarification, you can anticipate that the operating test will resemble the 

one that would be given for an initial candidate, but the written exam would 

be geared directly to job performance. The written exam is going to have to 

be operationally oriented. 

Q. 375 .. Will requalification exams be administered to non-approved requalification programs? 

A. As we see it, there are no such programs. You are operating under present NRC approval under old Appendix A, new 55.59(c), the requal program, or you 

have an INPO-accredited SAT-based requal program. There can't be anything outside of those. 

Q. 376. Prior to the issuance of this rule, people developed their requal program with two taskmasters: one, the INPO accreditation process, and the other, 

the relatively non-task based aspects of Appendix A. Now that the utilities 

NUREG-1262 103 
have got the flexibility to withdraw or to remove the non-task based part of 

the old programs, which may take some time, what is the approved program in the 

interim? Is it the old program? 

~· Yes, ~ou must follow the ~RC-appro~ed program, which was based previously in Appendix A to Part 55, until such time as you send to us a letter which 

certifies that you are accredited and that your program has been based upon an 

SAT approach. We don't believe, however, that that is such a big task. Some 

of the material we required in the past falls into the kinds of things that can 

be us~d in an SAT-based program. 

Whether that set constitutes 80 percent coverage or 70 percent coverage, we're 

not sure; but the real issue is the flexibility to design your program based 

upon program evaluation and feedback from on-the-job performance to factor in 

changes in procedure, changes in design, licensee events, industry events, and 

if you look at the programs that have been approved by the NRC, those have been 

required. 

In some cases, because of the need to cover so many hours in the classroom, 

you've had a competition for time available to conduct training, so important items have been covered in the discretionary time left. 

So we think that's a major advantage, and it's one that we would encourage you 

to look at carefully and to implement as quickly as you can. 

You have to follow your approved program, but by May 26, 1987, that approved ~rogram has to be brought up to at least meet the requirements under the new 

rule. If you have an Appendix A approved program in place currently, then on 

May 26th, you can submit a certification that you have SAT program which now 

meets the requirements of the new rule, but if you do that on May 26th, to 

upgrade to the SAT program, the program you have in place has to comply. No 

matter what it is, it has to comply with the new rule on May 26, 1987. 

If you do not intend to upgrade to an SAT program, you can continue to follow 

the format of your old program, but that old program has to meet the requirements of the new rule on May 26, 1987. 

Q. 377. What is the intent of the Commission to approve specific cycles as a 

part of each facility's training program? 

A. Once the programs are certified as SAT programs, it's not our intention to 

recertify these programs on any particular basis. Item No. 5 brings in the 

continuing process of change that should reflect the feedback from the performance evaluation of your program. The Commission will not be requesting periodic 

certification. You certify once and update to indicate when subsequent accreditation was achieved. 

In the first round of accreditation, you have a specific date that you were 

accredited. Through that process you have a requirement to submit a report at 

two years and to be re-accredited at four years. You would simply send in 

another letter that says, "My programs have been again accredited, 11 and that 

would be all that's required based upon the Commission's endorsement in the 

policy statement as it exists today. 

NUREG-1262 104 
--------····-··------···· .. , -·- ------·-·-

Q. 378. By what means is a utility to certify to the Commission that their 

requalification program is both accredited and based upon a systems appr~a7h to 

training? The interpretation for implementing a systems approach to tra1n1ng 

is somewhat different by the NRC and INPO. By what specific standards is our 

certification for using a systems approach to training based; i. e., the NRC's 

criteria utilized in conducting pre/post accreditation site evaluation, or 

using the INPO 85-002 criteria? 

A. The two are equivalent; that is, NUREG-1220 is essentially a series of 

questions related to each of the five elements of a systems approach to training 

as it's described in the policy statement. In that same policy statement, the 

Commission has endorsed the INPO accreditation objectives and criteria as being 

a systems approach to training. 

The difference comes about in that INPO has 12 objectives and about 60 subordinate criteria. The Commission in the policy statement identified five 

elements, and the Staff has a number of questions that we use for informationgathering in our reviews. However, we would prefer that you use the INPO 

accreditation objectives and criteria and supporting documents; in particular, 

for your requalification program. 

There is clearly a hierarchy of documents within the INPO program. Objectives 

need to be met. Criteria may or may not be met if you can still meet the objectives. Guidelines are just that--they are guidelines, an acceptable way of 

doing business as INPO would review it. 

That is very similar to the staff's approach in doing our postaccreditation 

audits. We have questions that relate to each of the five elements that the 

Commission has endorsed. Those questions do not imply criteria. They are 

simply areas where we gather information. So the simple answer to the question is follow INPO. 

We have seen several cases where the requalification program was not based upon 

a systems approach to training; rather, it was based upon a training program 

docketed with the NRC, that the NRC had approved. It was very prescriptive. 

It was, "Conduct X number of hours of classroom training, perform certain practical factors on the simulator in accordance with the Denton letter, 11 etc. 

Because of a re 1 uctance on the part o.f the utility to change commitments that 

are required by license condition or regulation, many of those programs were 

not changed to a systems approach. 

Effective May 26th, you can remedy that prior restriction by simply sending a 

letter to NRC which indicates that you are accredited and that you have 

developed your requalification program on a systems-approach-to-training basis. 

That's the most important aspect of this rule. It gives you the flexibility to 

control the content of continuing training based upon the needs of the individuals who have been trained, and the feedback mechanisms which are described. 

Most important is Element 5 of the systems approach to training: program revision based upon evaluation of performance on the job. That's where we see 

the major payoff, and we think that we are giving you the flexibility that 

you need to fully implement the industry commitments through training and 

accreditation. 

NUREG-1262 105 
Q. 379. What criteria is the Commission going to use to approve programs developed using a system approach to training? 

A. If you are asking the NRC to approve a requalification program that's based o~ a system~ approach to training, we don't look forward to trying to do those 

kind of rev~ews. We'd rather see a submittal indicating that you have an 

INPO-accredited program, which has both initial and requalification training based on an SAT. 

If you· were ~o ask NRC to review a training program that was not INPO-accredited, 

that you claimed was based on a systems approach to training, we would try to 

use the document that we now have to evaluate that, NUREG-1220. 

For clarification, if your program is accredited, and you're not a cold plant 

licensee, then prior to receiving an operating license we fully expect that you 

will use the INPO accreditation process and the guidelines that have recently 

been issued by INPO in their continuing training guidelines for licensed 

operators to develop your requalification continuing training program. 

We will accept a simple statement to the effect that this has been done. We 

accept as fact that you have been accredited, and therefore that you understand the process of developing performance-based training. We do not expect 

to review such programs. I don't think INPO would like us to review programs 

against their criteria and to put them into that context. We are trying to, in 

this rulemaking, clearly differentiate between training programs, which are 

being handled by the industry initiatives through NUMARC and INPO, and licensing requirements and the NRC examination. We don't want to mix those two, and 

would probably have discussions with facilities that propose to do otherwise. 

Q. 380. As far as the INPO document, 86-025, is concerned, you just say 11 as 

long as you are following the guidelines." Do you expect verbatim compliance 

with the guidelines, or just general compliance? 

A. There is a hierarchy of criteria within the INPO program, starting with 

objectives. Then you have criteria guidelines. You must meet the intent of 

the objective. That's a 11 shall. 11 When you get down to the criteria, you may 

not meet all of them verbatim. For some you may have alternate methods. 

Guidelines indicates what INPO believes would be acceptable to meet the intent 

of the criteria and the objectives. 

Your program has mechanisms for reviewing and deciding how you put that process 

in place. The fact that you are accredited is evidence to us that you understand how to use that process and those guidelines. We don't need to see the 

details, based upon the fact that you have been through accreditation. 

The principal goal for revising the requal programs is to allow feedback from 

operating problems, particularly licensee events, plant design changes, proce- dure changes, and other aspects of training for which there is a demonstrated 

need, and not to be constrained to X number of hours in a class, because that's 

what's been required in the past. 

Q. 381. What if I put in 80 hours of simulator time, although INPO says 120, 

but we're doing okay with 80? 

NUREG-1262 106 
A. That's between you and INPO and your needs under a program which uti~izes 

the SAT process. We have confidence in the process based on our evaluation of 

a number of facilities. We may get back into training programs if we see performance deficiencies on the job, through an event or through our inspection 

program. 

We have developed guidance, the series of questions in NUREG-1220, as to how 

we're going to go about evaluating programs. So that you know what you consider 

to be fair game for us to look at. But we are not in the mode of telling INPO 

what t0 do. That's for the Accrediting Board, INPO, and the facilities to 

determine. 

Q. 382. Will your evaluation of the training program be in accordance with the 

guidelines in NUREG-1220? 

A. Yes. We have had a number of discussions with INPO on it, and we have been 

using that for our post-accreditation review. 

Q. 383. Will a change to FSAR Chapter 13 (to satisfy new 10 CFR 55 requirements) 

be considered a decrease in the scope of an approved operator requalification 

program requiring prior NRC approval, in accordance with 10 CFR 50.54(i)? 

A. No. That issue is addressed in the Statement of Considerations, where it 

indicates that this Rule supersedes all other previous requirements. Even 

though the Rule may have caused a decrease in the scope of your requal program 

it has already been sanctioned by the Commission in its approval of this Rule, 

provided your program is INPO accredited. If it's not, then you must follow 

50.54(i); so you must determine if it has decreased in scope. 

Q. 384. Applicable portions of Title 10, Chapter 1, Code of 

are one of the lecture topics for a requalification program. 

specific as to which portions of Title 10 are applicable, or 

plants to determine? 

Federal Regulations 

Can you be more 

is that up to the 

A. You just cited the NRC Rules and Regulations, which includes such things as 

Tech Specs and amendments to licenses, and things like that. So, there are 

many Title 10 issues, including the radiation protection standards in Part 20. 

The subject matter of those lectures should be determined by the plants to 

satisfy the training needs of their operators. 

Q. 385. Paragraph (c)(3)(i) of Part 55.59 requires certain manipulations to be 

performed annually. This list of manipulations differs from the list in the 

Harold Denton letter of March 28, 1980. Our requalification program is based 

on the Denton letter. How long do we have to modify our requalification 

program to be in compliance with the new 55.59 requirements?" 

A. The rule supersedes and should include the requirements of the Harold 

Denton letter of March 28, 1980. If there are commitments in your program that 

go beyond those identified within the March 28, 1980, letter, then you will 

have to entertain an amendment to your Tech Specs to bring your program to that 

minimum level specified within the rule. Otherwise, we expect you to have a 

program that is modified and in compliance with rule by May 26, 1987. 

NUREG-1262 107 
Q. 3~6. Section 55.59(c)(3)(v) states: 11A simulator may be used in meeting the 

requirements of paragrap~s (c)(3)(i) and (3)(ii) of this section, if it reproduces the general operating characteristics of the facility involved and 

the arrangement of the instrumentation and the controls of the simulator is 

similar to that of the facility involved. 11 Fort Calhoun will continue to use 

the Combustion Engineering (CE) simulator in Windsor until the plant-referenced simulato~ is available for training. Is the CE simulator approved for meeting 

the applicable requirements until such time as a referenced simulator is available? The same question applies to the discussion in Section 55.59(c)(4)(iv). 

A. Yes, unt i 1 May 26, 1991. This is now a part of your re qua 1 if i cation pro- g~am and will continue to be a part of your requalification program until you either have a certified or an approved simulation facility. 

Q. 387. Does NRC agree with the utility interpretation that they may use the 

nonplant-referenced simulator as the preferred device when it comes to the 

requalification training program's on-the-job training control manipulations? 

A. The word "preferred," we would think of as "equa 1. 11 There is a nuance for 

the control manipulations -- the on-the-job training in item~ (a) through (f). 

In the Rule, under on-the job training, it says, "A simulator may be used in 

meeting the requirements of paragraps (c)(3)(i), and (c)(3)(ii) of this section, 

if it reproduces the general operating characteristics of the facility involved, 

and the arrangement of the instrumentation and controls of the simulator is 

similar to that of the facility involved." 

This difference permits the use of the nonplant-referenced simulator for start 

up, shut down, and other things which are not related to casualty control, even 

after you have certified or received approval of your simulation facility. It 

specifies that you must use the certified or approved simulation facility for 

the operating test, and for Subparagraphs (g) through (aa) of the Section, which 

are the casualties. 

So, you may use a simulator other than an acceptable simulation facility for 

control manipulations for requals. But you must use the acceptable simulation 

facility for casualties after May 26, 1991, or after you have been certified 

or received approval. It provides you some flexibility during periods when 

your simulation facility may not be available for routine control manipulations. 

Q. 388. May a utility use a certified simulation facility for requalification 

training programs, such as on-the-job training in control manipulations, or 

must some control manipulations be performed using the plant controls? 

A. If you look at the list, it just says you can't do casualties on plant 

controls. Items A through F in 55.59 are eligible to be performed either on 

the plant or with an approved or certified simulator. 

These relate to start-ups and shutdowns and changes of power of more than 10 

percent, manipulations which you can perform on the facility without putting 

it in danger. It is your option. You may either do those on the plant or on 

the simulator. 

For the remaining items that are required annually or for the operating test, 

those must be done on a simulation facility. They may not be done on the plant. 

NUREG-1262 108 
Q. 389. With respect to licensed operator/senior operator requalification training, is it appropriate that utilities assume they can take credit for the 

required annual and biennial plant control manipulations completed on a 

simulation facility (nonplant referenced) if their programs have been approved 

by the National Nuclear Accrediting Board? 

A. Yes. 

Q. 390. Can a utility whose training programs have not been accredited by the 

National Nuclear Accrediting Board and which does not have a plant referenced 

simulator take credit for plant control manipulations that are performed on a 

nonplant referenced simulator? 

A. If that 1 s what your approved program is now, then there will be no change 

to that approved program until you get your own simulator, or until May 26, 

1991 at which time the regulation requires that the training portion be done 

on a certified or approved simulation facility. There's an exception, in 

Section 3, 11 0n-the-Job Training, 11 that you may substitute your accredited program for those requirements. So if you are able to talk INPO into accepting a 

simulation facility other than a plant-referenced simulator, that's between you 

and INPO, but for the purposes of the staff's review, we would expect you to 

use the simulator after it has been certified if you do that before the May 26, 

1991, with one minor exception, which has to do with the first six on-the-job 

items listed under 55.59(c)(3). In that case, you need not have a certified 

simulation facility or an approved facility. The words permit you to use 

another simulation device. Section 55.59(c)(3)(v) permits the use of a simulator which reproduces the general operating characteristics of the facility 

involved, if the arrangement of instrumentation and controls of the simulator 

are similar to those of the facility involved. It only requires the fidelity 

of a plant referenced simulator for the casualties. 

Q. 391. Must all six manipulations listed in Paragraph (55.59)(c)(3)(i) be 

performed biennially, or just one of the six? 

A. Items A through L must be performed annually. All the rest are performed 

biennially. All of the first six items must be performed, either on the plant 

or the simulator. The rest are casualties, that must be performed on a 

simulator. 

Q. 392. Is it correct that Section 55.59 has now added fuel manipulations to 

the required items to be done annually? They are more than what's in the 

Harold Denton letter. We have renewals coming up during the summer of 1987, 

and the training program has been ongoing for the last year. There may be some 

manipulations that, in fact, have not been accomplished on the simulator on an 

annual basis by July of 1987 that 55.59 now says should have been done on an 

annual basis. 

A. There are two parts to this answer. First, the requirements in Section 55.59(c)(3), with the exeption of the sequence, are identical to those in 

the Denton letter; no fuel manipulations are required. Second, although the 

new requirement exists, the annual manipulations don't have to be completed for 

everybody until the regulation has been in effect for one year. 

NUREG-1262 109 
Q. ~93. ~n 55.59, 11 0N-THE-JOB-TRAINING, 11 loss of electrical power is one of the 

man1pulat1ons that needs to be performed. Is that loss of off-site power or 

degraded power sources, such as the loss of half of your emergency bus or is it 

a total blackout? 

A. It may be both. That is, it could be a total loss of electrical power, or 

it could be loss of power, particularly involving buses or consoles. 

Q. 394. If we want to run those scenarios, either one would meet that? 

A. That i~ correct. But remember that, according to that Section, you may not 

do casualties on the plant. The break-out in the Regulation specifies that 

everything below a loss of coolant event is an accident. The malfunctions 

and faults are done on a simulator. But the permissive part is for the other 

manipulations, the control manipulations, that may be done on the plant or on a 

simulator. 

Q. 395. Must plant control manipulations during the requalification period be 

documented on Form 398? 

A. The documentation hasn't changed for that particular item of the 398 Form. 

You still have to certify that the control manipulations were done. Only where 

there would be exceptions to the guidance in Regul.atory Guide 1.8 would there 

need to be some amplifying comments made. For example, if you did five similar 

manipulations, evaluated them and concluded they were acceptable, you might 

want to point that out in the comments section on the Form 398. 

Q. 396. If a license holder fails the written requalification exam or operating 

test administered by the Commission during the six-year license term and subsequently participates in the approved accelerated requalification program per Section 55.59(c)(4)(v); will certification of successful participation in this 

program be acceptable for renewal, or will a second NRC-administered exam 

during the six-year term be required? 

A. A second NRC examination will be required. That individual can go back 

on shift after failing the NRC requal exam, after participating in upgrade 

training and passing the facility's own evaluation. However, the terms of the 

Regulation are that for renewal he must pass an NRC-administered exam. 

Q. 397. Must licensed Operator training records be retained for the life of the 

plant? 

A. Those that deal with the six-year license, per se, only need to be kept for 

six years. However, some facilities have committed to record retention requirements in their Technical Specifications which are more restrictive than this 

regulation. In order to get the relief that the regulation permits, you must 

submit an administrative change request to amend your Technical Specifications 

to make the record retention requirements equal to six years or the term of the 

individual's license. 

This Rule supersedes all previous requirements for operator licensing and 

training, unless you currently have a more restrictive requirement. In that 

case, there are two vehicles you can use. One is an amendment to the license, 

NUREG-1262 110 
if a formal amendment is necessary. The other is a 50.59 review, which you 

can do administratively and then notify us that it has been completed when you 

indicate your other changes at the end of the year. In any event, you must 

conform to the requirements of the regulation, particularly those that are 

more restrictive than your current program. 

Two examples immediately come to mind. Most people today have an annual written 

examination. The Rule would permit you to go to a two-year examination. The 

change to go to a two-year exam can be processed under 50.59 and it does not 

constitute a reduction in scope if the change is for the purpose of conforming 

to the regulation. 

That is, the Commission, in the process of reviewing the regulation, concluded 

that there were compensatory measures for changing from a one-year written exam 

to a two-year written exam. In this case the compensatory measure is the annual 

operating test. So it does not fall into a reduction of scope and it does not 

require prior NRC approval unless it happens to be involved in an amendment to 

the license or the Tech Specs. 

Q. 398. This is a question about documentation of exams given at the plant. Under the requal program, it says that we must keep the student's answers for 

the period of the license. Does this mean that we must keep those exams as 

quality records and keep them for the lifetime of the plant, or are you saying that we keep it for the term of the license? 

A. It's for the term of the operator's license. And in this case, for example, 

his records would include six operating test examination forms, and three comprehensive written examinations in his individual file, until such time as his 

license is renewed, and then you start over again. Now, if you use a segmented 

examination in lieu of a comprehensive exam for each requal program, and you 

have more than three written exams, then that's a function of how you structure 

your program. You keep them only for the term of that individual license. 

Q. 399. So, are you saying for any operator exams that we administer, once we 

are past the renewal stage, we could destroy those as long as we have quality 

records to back up the fact that he had the exam -- in other words, the grades, and so forth? 

A. Given the fact that he was in a requalification program before, and you 

certified that, the answer is yes, you could put them in other quality records. 

Q. 400. On initial operator exams, are we required to keep the exam itself, or 

can we just keep a summary that goes in the operator's history file -- a summary of his grades, and things like this? We currently keep the master exams 

and a copy of the answer key, but are we required to keep the individual 

student exams and his answers? 

A. Our requirement is that the actual exam, or copies of the actual exam, be 

maintained for the duration of the current license. When you get that license 

renewed, you may eliminate that material from the files and start over. 

Q. 401. So are you saying once an operator gets a license, we could do that on 

the initial files, too? 

NUREG-1262 111 
A. That is correct. The requirement demonstrates that you've met the requirement of the Regulation to conduct operating tests and comprehensive written 

examinations during the term of that particular license. 

Q. 402. How are microfilm records authenticated to meet 55.59(c)(5)(ii)? 

A. They are authenticated by an authorized representative of the facility. 

Q. 403. Could you comment on the use of video tape as far as exam documentation. 

You mentioned keeping a deck log where you would recover strip charts. Would 

you give us some comment on the use of video tape? 

A. We do not intend to use video tape or the equivalent of instant replay during 

an examination. The records that we are looking for are the same records that 

would be used for a post-trip review, essentially the same documentation. To the 

extent that the simulator has the ability to retain the scenario, and you can 

down load that to a computer tape, you could retain and use that tape. 

Q. 404. I'd just like to make one comment on that. That's fine, I think, if 

the scenario includes a trip. If you're starting in mode four with a scenario, 

it's more difficult to recover those kind of parameters that you would need to 

recreate the scenario. 

A. The problem with a TV tape is that it is incomplete. You may not hear 

discussions between the candidate and the examiner because of how microphones 

are placed. We generally stand back, but at times we are at the operator's elbow. 

We have been asked on numerous occasions whether the facility would be allowed 

to video tape for either record purposes or training purposes. We consider it 

intrusive, both on the candidate and the examiner, and incomplete. 

Q. 405. Most of the manipulations that are listed in the Regulation are not 

applicable to test and research reactors. Are we still operating under the ten 

manipulations in a two-year period, as we have been in the past? 

A. If that was in your approved requalification program, it would remain 

approved. 

Q. 406. Is it possible for requalification examinations administered by the NRC 

to be 11 split 11 , such that the written and operational exams are given during 

different site visits? 

A. This is Regional prerogative, on a case-by-case basis, with advance notice 

to the licensee. 

Q. 407. A licensed RO is enrolled in the facility's SRO upgrade training program. NRC chooses this individual, randomly, to participate in their requal 

program evaluation examination. He fails the NRC administered exam, yet he is 

passing or has passed all portions of the upgrade program to this point. 

Does he have to be withdrawn from the upgrade program, go through accelerated 

requal for RO requal exam failure, and be reexamined, or can he just drop RO 

qualification and pursue an SRO license? 

NUREG-1262 112 
A. A licensed operator must meet the requirements of the facility's requalification program which generally requires accelerated training and/or reexamination. His status in other facility managed training programs is the prerogative of facility management. If the facility elects to 11 drop RO qualification11 

for the individual under 10 CFR 55.5(a) the individual could make application 

for an SRO license under 10 CFR 55.31. However, the individual would not be an 

SRO upgrade candidate as that status assumes a active RO license. 

Q. 408. Will written exams administered by NRC for requalification be totally 

object.ive, totally subjective, or some combination? 

A. They will be a combination of both. Some examination questions are written with the intent of meeting the definition of an objective question. An 

objective question is defined as one in which: (1) there is only one correct 

answer; and (2) all qualified graders would agree on the amount of credit allowed for any given candidate's answer. 

Q. 409. Will persons holding a two year license be included in NRC requal 

exams during the transition? 

A. Persons with valid licenses may be included in NRC exams. However, renewals will be under 55.57 which requires the facility licensee to indicate a 

need for renewal of the license. 

Q. 410. Please clarify paragraph 55.59(c)(4)(iii). What is being asked for? 

A. The regulation requires a formalized, documented system for evaluating the 

performance and competency of licensed operators and senior operators. The 

system must include observation of on-the-job performance and evaluation of 

the operator's performance and competency through the use of an operating test. 

The operating test must include evaluation of actions taken during actual or 

simulated events which require the use of abnormal and emergency procedures. 

Q. 411. Concerning paragraph 55.59(c)(3)(iv), what does 11 on a regularly scheduled basis 11 mean? 

A. The facility licensee must establish a review schedule that will provide 

reasonable assurance that each licensed operator and senior operator is knowledgeable of all abnormal and emergency procedures. At a minimum, the schedule 

must require the review of all abnormal and emergency procedures at least once 

every two years. 

Q. 412. Where preplanned lectures are part of the requal program, is it necessary that the licensees participate in all of these lectures, notwithstanding 

successful completion of the written examinations following these lectures, in 

order to be able to say that the licensee has met the requal program requirements on the NRC-398 application? 

A. Under revised 55.59 no provisions for exemption of lectures is provided. 

If currently approved programs contain exemption provisions for licensed instructors the programs should continue until the programs are accredited. 

NUREG-1262 113 
INPO guideline 82-026 contains exemption provisions for instructors who teach 

specific subjects; however, they must attend lectures in subjects they do not 

teach. 

Q. 413. Paragraph 55.59(b) implies that the NRC is notified when an individual 

fails a comprehensive written examination or operating test. Is this a 

requirement? 

A. The NRC does not expect to be notified if a licensed operator or senior 

operator fails an examination. Requalification programs have provisions for 

accelerated training. We expect facility management will provide the necessary 

retraining and reexaminations before returning to active license status an 

operator or senior operator who has failed a requalification examination. 

Q. 414. How will individuals who are in non-compliance with accreditated requalification training programs (i.e. extended illness, jury duty, etc.) be 

requalified? 

A. Operators will be required to make-up missed portions of the requalification program and to submit evidence to the Commission of successful completion of the training. 

Q. 415. We have a program where we have licensed maintenance people as senior 

reactor operators limited to fuel handling. ·To what extent will this new rule 

apply to us, since in the comments preceding the rule there's mention that this 

is not being covered, that it's going to be covered as it is currently being 

done. 

For the past 14 years, as long as we've had SROs limited to fuel handling, we 

have not been required to give operating exams. Our annual requalification 

exam is a written exam only. 

A. For a license which is conditioned to fuel handling only, the testing and 

requalification program should be appropriate to the license as it's conditioned. The licensee is not permitted to operate the facility. You would 

therefore not be required to give him an operating test, as described in the 

regulation. 

NUREG-1262 114 
CONFORMING AMENDMENTS TO 10 CFR PART 50 
Q. 416. The new 10 CFR 50.54(i-1) requires us to notify you of any change in 

the scope of our program. Since we are not defining for you what our program 

is now, what is it that you are looking for? 

A. Let's say that you are using an NRC-approved program today, and you make a 

modification to that program to conform to the Regulation. Say you go from an 

annual written examination to a comprehensive examination each two years. You 

may do that pursuant to 50.59, and simply amend your FSAR at the next update. 

Or, preferably, you would be accredited, have completed your review of your requalification program, and confirmed it as a systems approach to training. 

Both methods may be done pursuant to 50.59. They do not require amendments to 

licenses. It is only when you have committed to something that's a part of the 

licensing document. For instance, some facilities have the Denton letter incorporated in their Technical Specifications, associated with staffing on shift. 

You need to look at your commitments on a case-specific basis for your utility. 

Our intent is that you be able to do most of those under 50.59. They would 

not require review and approval by the staff in advance of your implementing the change. 

Q. 417. Previously Part 50.54(i) referred to a decrease in scope, frequency, 

or duration. Now all you are saying is scope. Is that correct? 

A. Yes. The reason for that is that the Rule specifies that you shall have 

a duration of no longer than two years, and it must be followed. The program 

that you use through INPO describes content. 

Q. 418. What about frequency of the parts? 

A. That's covered by the systems approach to training, where you look at the 

task that is performed, and you decide what it is. And that's why we excluded 

the classroom, OJT, and examination portion of requalification given that you 

certify that your program is done in accordance with the systems approach to 

training. For clarification, although you may be giving segmented exams in 

your requalification program, you should be aware that if NRC conducts a requalification exam at your facility, it will be a comprehensive written exam 

and will include an operating test. 

Q. 419. The systems approach to training in itself is subjected to revisions 

to the training program. Some of these changes may be considered, at least by 

the utility, as a reduction in scope. The statement in 50~54 is still there, 

where it says that Commission approval is required for a reduction in scope in 

a training program. How do we meet 50.54 and still co·mply with 55.59? 

A. The key words are 11 except as specifically authorized by the Commission. 11 

The Commission itself, in the Policy Statement on Training and Qualification of 

Nuclear Power Plant Personnel, on March 20, 1985, particularly Element 5, indicates that it ~xpects the program to be evaluated and revised as necessary, 

based upon job performance needs. 

We recognize that if you only added and never subtracted, you would eventually 

get to the point where you're putting all the time into training and never 

NUREG-1262 115 
doing anything on the job. We expect the evaluation to be reasonable based 

upon what you're doing. If you want to substitute something that 1 s more important, the fact that you've dropped something does not constitute a reduction 

in scope for a systems approach to training. 

We believe that 1s a major improvement in the whole training process. You are' 

not locked into doing something for the next six, seven, or eight years because 

you committed to it in 1980. You now review it and, if it's meaningful, you perform it -- you control that evaluation process. 

Q. 420. With respect to that area of 50.54 changes, which basically states 

that we will have a requalification program and that we cannot lessen the scope, 

what documents would be looked at as base documents to see whether we did or 

did not reduce the scope? 

A. We will look at your approved requalification training program. 

Q. 421. In the 50.74 requirement, you have set up some direction as to sending 

all correspondence for Part 55 to the Region. However, because this is a Part 

50 requirement, should we be sending that to the document control desk in accordance with Part 50.4, which became effective in January of 1987? All correspondence required under Part 50 was supposed to go to the document control 

desk, with a copy to the Regional Administrator. Please clarify. 

A. Communications under each part of the regulation have to conform to the 

communications requirements of that part. 

Q. 422. Is the licensee definition under 50.74 the same as the licensee definition in 10 CFR 55? 

A. Yes. 

Q. 423. If a licensee is out of conformance with the INPO-accredited training 

program, is that reportable pursuant to 10 CFR 50.72 and 50.73? 

A. It's not reportable to NRC, but you may need to report it to INPO, along 

with what you're doing to get back into conformance. It may be reportable to 

NRC if you have certified that someone is a graduate of an accredited program 

and that he has completed the program, then you find that you have not implemented 

the program adequately. In that instance, you may have a reporting requirement 

to NRC. 

NUREG-1262 116 
OPERATOR LICENSING EXAMINER STANDARDS (NUREG-1021) 
Q. 424. What weight does NUREG-1021 carry? 

A. The purpose of the Examiner Standards, NUREG-1021, is' to ensure uniformity 

and consistency among the regions in the conduct of the examination process. 

It provides direction to the regions on how we expect them to conduct the 

operator licensing function. We audit the regions against that Standard. It 

does not impose new requirements. That is, the requirements that are addressed 

in the Examiner Standards flow from other documents, whether it be a 

Regulatory Guide, or Regulation, or other guideline. 

That's why many of the changes to Examiner Standards described r~SL!lt from 

the change to the Rule, the more authoritative document. The standard contains 

policy on how to carry out the Rule. 

Q. 425. It was mentioned that the license examiners would be filling out a 

simulation facility fidelity feedback report. Could we request that those reports be included in our copy of the examination packages when they are returned to us? 

A. They will be. That has been incorporated into Rev. 4 to the Examiner Standards. The simulation facility fidelity feedback report is contained in Examiner Standard ES-104 "Procedures for Postexamination Activities, 11 as section C(3), 

which requires that a Simulation Facility Fidelity report be prepared for each 

examination including simulator evaluations of candidates. The Standard also 

requires this report to be part of the Examination Report sent to the facility. 

Q. 426. Will the Simulation Facility Fidelity Feedback Report be used to determine the status of current simulators? 

A. The guidance to the examiners is that this information will be applicable 

only to simulation facilities that have been certified or have applied for 

approval. However, even today, with the present vintage of simulators, you 

still receive informal feedback reports in the exam review process. And that 

will continue. If the Examiners have a problem conducting the operating test 

at your simulator, you can expect some feedback, although it won't be as formal 

as would occur after certification or approval. 

Q. 427. It was stated earlier that once Form 474 is submitted, the simulation 

facility is certified in accordance with ANSI/ANS 3.5, and that there are three 

different mechanisms that may trigger the process of further evaluation: 

(1) questions regarding the Form 474 submittal, (2) random visits to the 

facility for evaluation, and (3) the post-examination activities associated with 

the examination at the facility. 

Would the procedures for the simulation facility evaluation feedback due by May -- specifically, ES-104 -- be specific as to the standards and criteria and 

mechanisms by which the examiners will make a post-examination evaluation of a 

facility that would then trigger the evaluation procedure? 

A. No. The mechanism is intended to be essentially a simple comment sheet 

that might contain a comment to the effect that 11 During Scenario X, the simulation facility failed to perform as expected. There was no flow coast down 

associated with reactor coolant pumps on a loss of power. 11 

NUREG-1262 117 
This type of comment would be collected and evaluated. Someone would then 

determine whether it raised a question in our mind that would be the basis for 

going back and looking at the simulation facility. 

It's not significantly different from comments on the simulator in the 

tion report -- the inspection report that's issued following an exam. 

are a number of random failures, that's the kind of information we're 

collecting. 

examinaIf there 

There is no acceptance criteria threshold. It's the examiner's judgment. If 

he felt there was a problem, we're giving him a vehicle to write it down and 

communicate it back so that knowledgeable people can look at it and decide 

whether that would trigger an inspection or evaluation. 

Q. 428. Typically after that type of evaluation, there's not going to be a significant amount of data by which someone away from the facility, someone who 

was not there at the time of the examination, could make a very objective or 

accurate determination as to whether there is a problem with the simulation 

facility or not; and I understand that there are a significant number of freezes. 

If, during an overpressure incident, pressure continues to rise to 3,500 pounds, 

then obviously there's a problem with the simulation facility, but other examples may not be so clear-cut. Therefore, there's a potential for NRC followup 

where, perhaps it was not warranted because of an evaluation made by someone who 

was not there when the event occurred. 

A. That's why we're getting the feedback from the examiner who was there at 

the time it occurred. The facility will also receive a copy of the writeup with 

the inspection report, and I'm sure it will be a subject in the exit briefing 

with the chief examiner at the end of the exam week. 

We think there are adequate mechanisms in place to alert the facility as to 

what the potential concern is, but most importantly, we want to get feedback 

on how well the simulation facility is working during an examination based 

upon an examiner's observation of that simulation facility. 

Further, we have been increasingly requesting that facilities record data during 

simulator exams to the greatest extent possible so that information is available 

for review on a more objective scale. 

Q. 429. We are required to complete training and experience blocks on Form 398 

because we don't yet have an acceptable simulation facility, even though we 

have an INPO-accredited program. Will we still be evaluated in accordance with 

current ES-109 requirements? 

A. Yes. 

Q. 430. Under eligibility, you previously cited Examiner Standard 109. In 

the future an accredited program with an acceptable simulation facility may be 

substituted for eligibility. Examiner Standard 109 says two years of power 

plant experience is required. Does that requirement remain? 

A. A facility with an INPO-accredited training program that utilizes a certified or approved simulation facility need not meet other experience requirements. 

NUREG-1262 118 
Revision 4 to the examiner standards revises ES 109 to conform with the 

Regulation. 

Q. 431. Examiner Standard 109 lists the eligibility requirements for licensed 

operators and senior licensed operator applicants. One of these requirements is that each individual spend three months on shift as an extra man under the 

supervision of a licensed or senior licensed operator. Is this requirement still in effect? Where does this requirement come from, given that it is not 

addressed in 10 CFR 55, and the new revision supersedes previous requirements? 

A. Although not a requirement, this is consistent with our past practice, and 

it's consistent with Reg Guide 1.8, which endorses ANSI 3.1-1981. It will be 

continued in ES-109. Facility licensees can ask for a waiver, and their requests will be considered. 

Q. 432. Examiner Standard 109 says that training conducted as part of a license 

program cannot count for experience. But ANSI/ANS 3.1-1981, which is what the 

Commissioners have told us to use, allows related technical training to count 

for experience. Is ES-109 in compliance with 3.1? 

A. The training time that doesn't count as experience refers to the training required by the approved license program in which the individual is partici- pating. Related technical training refers to training he may have received in 

another position, such as auxiliary operator. This time may be counted, up to 

a certain percentage. 

Q. 433. There was an article in Nuclear News, January 1987, page 42, that says the average pass rate for the industry on requalification exams administered by the NRC is 78 percent nationwide. Examiner Standard 601 says that in order for 

a requalification program to be evaluated as satisfactory, 80 percent or more 

have to pass. This indicates that the industry, nation-wide, has less than a 

satisfactory requal program. Do you agree? 

A. No, because the statistics that Nuclear News used are somewhat questionable. Last year we evaluated 17 fac1lit1es, and 5 of them fell in the marginal 

or unsatisfactory category because they had substantially higher failure rates. 

So, a few are causing the national statistics to be different. It was similar 

the year before, when we had five facilities that were in the marginal or unsatisfactory category. 

The program evaluation is based upon whether 80 percent or more pass. It's not 

based upon the average scores of the candidates taking the exam. In other 

words, if you examine 10 candidates, aQd 2 fail, you have 80 percent passing and we determine that program is satisfactory. The average score on that exam 

may be 78 per cent because the 2 people that failed scored in the 60s, while 

everybody else scored above 80. 

Q. 434. Assume that NRC comes in to give the utility requalification exams, 

and the scores are between 60 and 80 percent and are rated marginal. After the 

utility modifies their program, reexamines those failures, and comes out with a 

satisfactory grade, does NRC change that from a marginal to acceptable program? 

A. The marginal rating would be based on the examination given, in accordance 

with ES-601. We evaluated the program and identified individuals with weaknesses. They require remedial training, which is given. Their training will 

NUREG-1262 119 
not cause us to re~ise our evaluation. Two years hence, when we come back and 

do another evaluat1~n, hopefully 80 percent will pass at that time, and you will 

be evaluated as satisfactory. The original evaluation and conclusion stands 

until we come back and re-evaluate, either by inspection or re-examination. 

Q. 435. Is that true, even if our program was modified to cover those weaknesses that you discovered? . 

A. Yes. Your program may, indeed, no longer be marginal. But until we come 

back and independently evaluate, that remains our conclusion of record. 

Q. 436. So, the only way we can get that changed, is for you to come back to 

give another exam, is that true? 

A. Yes, we come back and inspect that area, and reach a conclusion based on 

our inspection at that time. 

Q. 437. Can we ask for such a re-evaluation? 

A. Sure. 

Q. 438. What limits on materials requested from the facility licensee exist, 

if any? 

A. We will be reasonable, but there are no specific limits. Typically, we go through the list with the facility, and indicate what items we need. We are 

not going to ask for the whole library or every print on the facility. However, 

we may need more material at times than you issue to the student to learn the 

plant, because we have to get familiar with different plants that have slight differences from one type vendor to another. So, we may need more in-depth material. 

Q. 439. We receive a copy of the written exam after it has been administered, 

and as part of the documentation, we are provided with the learning objectives of the source documents from which these questions were derived. For simulator 

examinations, could we be provided with that same documentation, since we go to 

the effort to develop scenarios that are based on industry events, LERs, and 

learning objectives that we've derived from our program so that when you design 

your simulator exams, they would also be based upon these same precepts? 

A. We currently fill out Attachments 3 and 5 to Examiner Standard 302, which 

delineates the objectives that the exam events are trying to accomplish. Those 

have been provided to all the individuals who have failed the examination. For 

individuals who passed, we have provided only Attachment 3, the delineation of 

the overall exercise itself, malfunction by malfunction, or over-ride by override. We have not been providing Attachment 5 to individuals who pass. If you 

request, we can provide you a copy of Attachment 5, which contains our objec- tives for that examination. • 

Q. 440. With regard to IE Information Notice (IEIN) No. 85-101 11Applicability of 10 CFR 21 to Consulting Firms Providing Training, 11 is training material that 

is found deficient reportable under 10 CFR 21? 

NUREG-1262 120 
A. The answer is yes under certain conditions. IEIN85-101 provides guidatn~e 

to licensees and consultants concerning applicability of 10 CFR 21 to cer a1n 

training activities provided by consultants. Further information regarding 

reporting requirements can be found 1n NUR~G-0302 Re~. 1, 11

Re~arks Presente~ 

(Questions/Answers Discussed at Public Regional Meetings to Discuss Regulations 

(10 CFR Part 21) for Reporting of Defects and Noncompliance." 

Q. 441. Would the review of the exam to make our comments within the five 

working days also apply to the simulator exam? 

A. The comment procedure has been limited to the written examination by the 

Examiner's Standards. You can comment, obviously, on our simulator exam, and 

we are more than willing to listen to what you have to say. But we have not 

been going through a formal comment procedure for the simulator exam. One of 

the reasons is that the simulator examination is on-going during the course of 

the week. And the written examination is given typically in the first day. And, usually, by the end of the week, you provide us with your written exam 

comments, and that expedites the grading process. 

Our present practice does not solicit written comments on the simulator exam 

for grading pu~p?ses. Norm~lly the dialogue established with the simulator 

operators (t:a1n1n~ staff) 1~ adequate to resolve any weaknesses in tne simulator scenar~os pr1or to their execution. Otherwise, written comments are 

accepted during an appeal process for an individual candidate. 

NUREG-1262 121 
Appendix A 

Generic Letter 87-07 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D. C. 20555 

MAR 19 198i 

TO ALL FACILITY LICENSEES 

SUBJECT: INFORMATION TRANSMITTAL OF FINAL RULEMAKING 

FOR REVISIONS TO OPERATOR LICENSING - 10 CFR 55 AND CONFORMING AMENDMENTS 

(Generic Letter No. 87- 07) 

To provide information about the final revisions to 10 CFR 55, "Operators' Licenses," and their implementation, the Commission is holding a series of 

public meetings. These meetings will be held as follows: 

A. April 9, 1987 for Region II 

Richard B. Russell Federal Building Strom Auditorium, Lower Level 

75 Spring Street, SW 

Atlanta, Georgia Point of Contact: Mr. Kenneth E. Brockman 

US Nuclear Regulatory Convnission, Region II 

101 Marietta Street, Suite 3100 

Atlanta, GA 30323 

(404) 331-5594 

B. April 14, 1987 for Regions IV and V 

Stouffer Concourse Hotel 

3801 Quebec Street 

Denver, Colorado (Across from Stapleton Airport) Points of Contact: Mr. Ralph Cooley US Nuclear Regulatory Convnission, Region IV 

Parkway Central Plaza Building 

611 Ryan Plaza Drive, Suite 1000 

Arlington, TX 76011 

(817) 860-8147 

Mr. Phillip Morrill 

US Nuclear Regulatory Convnission, Region V 

1450 Maria Lane, Suite 210 

Walnut Creek, CA 94596 

(415) 943-3740 

C. April 16, 1987 for Region III 

Ramada Hotel O'Hare 

6600 N. Mannheim Road (corner of Higgins) Rosemont, Illinois (One mile from O'Hare Airport) Phone: (312) 827-5131 

Point of Contact: Mr. Thomas Burdick 

8703190287 

US Nuclear Regulatory Commission, Region III 

799 Roosevelt Road 

Glen Ellyn, IL 60137 

(312) 7~0-5566 

A-1 
D. April 20, 1987 for Region I 

Hilton Hotel Valley Forge 

251 West DeKalb Pike 

King of Prussia, Pennsylvania 

Phone: (215) 337-1200 

- 2 -

Point of Contact: Mr. Noel F. Dudley 

US Nuclear Regulatory Commission, Region I 

631 Park Avenue 

King of Prussia, PA 19406 

(215) 337-5211 

Enclosed with this letter is a double-spaced copy of the regulations and 

supporting information for your review prior to the public meeting. You are 

encouraged to forward questions to the appropriate point-of-contact, one week 

prior to the date of the meeting which you plan to attend. The staff intends 

to answer these questions and others during the meetings and will consolidate 

all questions and answers into a NUREG report after the meeting. 

In preparation for these meetings, all licensees should pay special attention 

to the requirements of Sections 55.31(a) and 55.59(c) regarding both initial 

and requalification training and the option of substituting an accredited 

training program for initial and requalification training programs previously 

approved by NRC. This option may be implemented upon written notification to 

the NRC and does not require any staff review. Howevt:r, because of conflicts 

between previous 10CFR55 Appendix A requirements and a systems approach to 

requalification training, it is necessary to certify that the substitute 

training program is both accredited and based upon a systems approach to 

training. The superseded training program description contained in the FSAR 

need not be revised until the next update required by 50.7l(e). 

Sincerely, 

( £tnU~-JJ-_J,~rJ- )f 

arold R. Denton, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

As stated 

A-2 
Appendix B 

10 CFR Parts 50 and 55 

Operators' Licenses and Conforming Amendments 

Federal Register I Vol. 52, No. 57 I Wednesday. March 25, 1987 I Rules and Regulations 9453 

known brucellosis in cattle for the 

period of 12 months preceding 

classification as Class Free. The Class C 

classification is for States or areas with 

the highest rate of brucellosis, with 

Claaa A and Class B in between. 

Restrictions on the movement of cattle 

are more stringent for movements from 

Class A States or areas compared with 

movement& from Free States or areas. 

and are more stringent for movements 

from Class B States or areas compared 

with movementa from Class A States or 

areas, and so on. 

The basic standards for the different 

classiftcations of States or areas 

concern maintenance of: (1) A cattle 

herd infection rate, baaed on the number 

of herds found to have brucellosis 

reactors, not tc exceed a stated level 

during 12 consecutive months: (2) a rate 

of infection in the cattle population, 

based on the percentage of brucellosis 

reactors found in Market Cattle 

Identification (MCl)-testing at 

stoc!kyards and slaughtering 

establishment9-llot to exceed a stated 

level: {3) a surveillance system that 

; requirea testing of dairy herds, 

participation of all slaughtering 

establishments in ,the MCI program, 

identification and monitoring of herds at 

high risk of infection, including herds 

adjacent to infected herds and herds 

from which infected animals have been 

sold or received; and {4} minimum 

procedural standards for administering 

the program. 

Prior to the effective date of this 

document. Alabama was classified as a 

Class B State because of the herd 

infection rate and the MCI reactor 

prevalence rate. However, a review of 

the brucellosis program establishes that 

Alabama should be changed to Class A 

status. 

In order to attain and maintain Class 

A status. a State or area must (1) not 

exceed e cattle herd infection rate, due 

to field strain Bruce/la abortus of 0.25 

percent or 2.5 herds per 1,000 based on 

the number of reactors found within the 

State or area during any 12 consecutive 

months, except in States with 10,000 or 

fewer herds; (2) maintain a 12 

consecutive months MCI reactor 

prevalence rate not to exceed one 

reactor per 1,000 cattle tested (0.10 

percent}: and (3) have an approved 

individual herd plan in effect within 15 

days of locating the source herd or 

recipient herd. Alabama now meets the 

criteria for classification as Class A. 

Executive Order 12291 and Regulatory 

Flexibility Act 

We are iNuing this rule in 

conformance with Executive Order 

12291. and we have determined that it is 

not a "major rule" Based on information 

compiled by the Department, we have 

determined that this rule will have an 

effect on the economy of leaa than $100 

million; will not cause a major increase 

in costs or prices for consumers. 

individual industries, Federal. State, or 

local government agencies, or 

geographic regions; and will not cause a 

significant adverse effect on 

competition, employment, investment. 

productivity, innovation, or on the 

ability of United Stales-baaed 

enterprises to compete with foreignbased enterprises in domestic or export 

markets. 

For this action, the Office of 

Management and Budget has waived its 

review process required by Executive 

Order 12291. 

Cattle moved interstate are moved for 

slaughter, for use as breeding stock, or 

for feeding. Changing the status of 

Alabama reduces certain testing and 

other requirements on the interstate 

movement of these cattle. However, 

cattle from certified brucellosis-free 

herds moving interstate are not affected 

by these changes in status. We have 

determined that the changes in 

brucellosis status made by this 

document will not affect market patterns 

and will not have a significant economic 

Impact on those persons affected by this 

document. 

Under these circumstances. the 

Administrator of the Animal and Plant 

Health Inspection Service has 

determined that this action will not have 

a significant economic impact on a 

substantial number of small entities. 

Executive Order 12372 

Thia program/activity is listed in the 

Catalog of Federal Domestic Assistance 

under No. 10.025 and is subject to the 

provisions of Executive Order 12372. 

which requires intergovernmental 

consultation with State and local 

official&. (See 7 CFR Part 3015, Subpart 

V.} 

Emergency Action 

Dr. John K. Atwell, Deputy 

Administrator of the Animal and Plant 

Health Inspection Service for Veterinary 

Services, has determined that an 

emergency situation exists, which 

warrants publication of this interim rule 

without prior opportunity for public 

comment. Immediate action is 

warranted in order to delete 

unnecessary restrictions on the 

interstate movement of certain cattle 

from Alabama. 

Further, purauant to administrative 

procedure provisions in 5 U.S.C. 533. it is 

found upon good cause that prior notice 

and other public procedures with 

ri 1 u- .!. 

respect t~ this interim rule are 

impracticable and contrary to the public 

interest, and good cause is found for 

making this interim rule effective less 

than 30 days after the publication of this 

document in the Federal Register. 

Comments are being solicited for 60 

days after publication of this document, 

and a final document discussing 

comments received and any 

amendment& required will be published 

in the Federal R_.ter a8 soon a8 

possible. 

U.t of Subjectt In 9 CFR Part 78 

Animal diseases, Brucellosis. Cattle, 

Hogs. Quarantine, Transportation. 

PART 71-BRUCELLOSIS 

Accordingly, 9 CFR Part 78 is 

amended as follows: 

1. The authority citation for Part 78 

continues to read as follows: 

Authority: 21U.S.C.111-114a-1. 114g, 115, 

117, 120. 121. 123-128. 134b, 134f: 7 CFR 2.17, 

2.51, and 371.2(d). 

f 78.41 (Amended) 

2. Section 78.41, paragraph (b} is 

amended by adding "Alabama" 

immediately before "Arizona". 

3. Section 78.41, paragraph (c) is 

amended by removing "Alabama". 

Done in Washington. DC, this 20th day of 

March. 1987. 

B. G. Jobmon. 

Deputy Administrator. Veterinary Servicea, 

Animal and Plant Health Inspection Service. 

f PR Doc. 87-6421 Filed 3-24--87; 8:45 amJ 

lllUJllG COOi 141044-ll 

NUCLEAR REGULATORY 

COMMISSION 

10 CFR Parts SO and 55 

Operators' License• and Conforming 

Amend men ta 

AGENCY: Nuclear Regulatory 

Commisaion. 

ACTION: Final rule. 

SUMMARY: The Nuclear Regulatory 

Commiaalon is amending its regulations 

to (1) clarify the regulations for issuing 

licenses to operators and senior 

operators: (2) revise the requirements 

and scope of written examinations and 

operating tests for operators and senior 

operators, including a requirement for a 

simulation facility; (3) codify procedures 

for administering requahfication 

examinations; and (4) describe the form 

and content for operator license 

applications. The rule is necessary to 

meet NRC responsibilities under Section 
9454 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 I Rules and Regulations 

306 of the Nuclear Waste Policy Act of 

1982. 

DATES: Effective Date: May 26, 1987. 

Public meeting dates: April 9, 14, 16, and 

20, 1987. 

ADDRESSES: Public meeting locations: 

Public meetings will be held to discuss 

implementation of the requirements of 

this rule. The meetings will be held as 

follows: 

A. April 9, 1987 for Region II, Richard 

B. Russell Federal Building, Strom 

Auditorium, Lower Level, 75 Spring 

Street, SW., Atlanta, Georgia. 

Point of Contact: Mr. Kenneth E. 

Brockman, U.S. Nuclear Regulatory 

Commission, Region II, 101 Marietta 

Street. Suite 3100, Altanta, GA 30323, 

(404) 331-5594. 

B. April 14, 1987 for Regions IV and V, 

Stouffer Concourse Hotel. 3801 Quebec 

Street, Denver, Colorado (Across from 

Stapleton Airport). 

Points of Contact: Mr. Ralph Colley, 

U.S. Nuclear Regulatory Commission, 

Region IV, Parkway Central Plaza 

Building, 611 Ryan Plaza Drive, Suite 

1000, Arlington. TX 76011, (817) 860-

8147. 

Mr. Phillip Morrill, U.S. Nuclear 

Regulatory Commission, Region V, 1450 

Maria Lane, Suite 210, Walnut Creek, 

CA 94596, (415) 943-3740. 

C. April 16, 1987 for Region lll, 

Ramada Hotel O'Hare, 6600 N. 

Mannheim Road (comer of Higgins), 

Rosemont, Illinois (One mile from 

O'Hare Airport), Phone: (312) 827-5131. 

Point of Contact: Mr. Thomas Burdick, 

U.S. Nuclear Regulatory Commission, 

Region Ill. 799 Roosevelt Road, Glen 

Ellyn, IL 60137, (312) 700-5566. 

D. April 20, 1987 for Region I, Hilton 

Hotel Valley Forge. 251 West DeKalb 

Pike, King of Prussia. Pennsylvania. 

Phone: (215) 337-1200. 

Point of Contact: Mr. Noel F. Dudley, 

U.S. Nuclear Regulatory Commission, 

Region I. 631 Park Avenue, King of 

Prussia, PA 19406, (215) 337-5211. 

Background information for the rule 

includes a copy of the regulatory 

analysis, the supporting statement for 

the Office of Management and Budget 

clearance of the information collection 

requirements, Regulatory Guides, ANSI/ 

ANS standards, NUREG-series 

documents, other documents discussed 

in this notice, and reports that contain a 

detailed analysis of the public 

comments received during the public 

comment period and their resolution 

may be examined at the NRC Public 

Document Room, 1717 H Street NW., 

Washington. DC. 

A single copy of the reports 

concerning public comments may be 

obtained from Chief, Operator Licensing 

Branch, Office of Nuclear Reactor 

Regulation, U.S. Nuclear Regulatory 

Commission, Washington. DC 20555, 

Telephone: 301--492--4868. 

FOR FURTHER INFORMATION CONTACT: 

Chief, Operator Licensing Branch, Office 

of Nuclear Reactor Regulation, U.S. 

Nuclear Regulatory Commission, 

Washington, DC 20555, Telephone: (301) 

492-4868. 

SUPPLEMENTARY INFORMATION: 

I. Background 

Section 107 of the Atomic Energy Act 

of 1954, as amended (42 U.S.C. 2137), 

requires the Nuclear Regulatory 

Commission to prescribe uniform 

conditions for licensing individuals as 

operators of production and utilization 

facilities and to determine the 

qualifications of these individuals and to 

issue licenses to such individuals. The 

regulations implementing these 

requirements are set out in Part 55 of 

Title 10, Chapter 1, of the Code of 

Federal Regulations. To assist licensees 

and others. the Commission also has 

issued regulatory guides and generic 

letters that provide guidance on 

acceptable methods of meeting these 

regulatory requirements. 

The Commission has become 

increasingly aware of the need to update 

its operator licensing regulations and 

related regulatory guides. These 

revisions are needed to clarify the 

extent to which simulators should be 

used in licensing examinations and to 

reflect upgraded requirements for 

licensed operator selection. training, and 

requalification programs resulting from 

the accident at TMI-2. Although the 

Commission has been actively engaged 

in investigating these matters, the 

schedule for completing these activities 

was further accelerated by the 

enactment of January 7, 1983, of the 

Nuclear Waste Policy Act of 1982, Pub. 

L. 97-425. Section 306 of that act (42 

U.S.C. 10226, 96 Stat. 2201 at 2262-2283) 

directs the NRC to establish (1) 

simulator training requirements for 

applicants for operator licenses and for 

operator requalification programs, (2) 

requirements governing NRC 

administration of requalification 

examinations, and (3) requirements for 

operating tests at civilian nuclear power 

plant simulators. 

On November 26, 1964, the 

Commission published proposed 

amendments to 10 CFR Part 55, 

"Operators' Licenses" in the Federal 

Register (49 FR 46428). These 

amendments proposed granting, in part, 

a petition for rulemaking (PRM-55-1) 

that was filed by KMC, Inc. PRM-55-1 is 

discussed more fully under Section II.B, 

B-2 

"Medical Requirements." A 90-day 

comment period expired on February 25, 

1985. Comments were received from 88 

respondents. An additional 47 

respondents commented on the three 

associated regulatory guides, also issued 

for public comment. Reports that contain 

a detailed analysis of these comments 

and their resolution are available as 

indicated under "ADDRESSES:". 

These proposed revisions to 10 CFR 

Part 55 were to improve the operator 

licensing process and to achieve the 

following objectives: 

(1) Improve the safety of nuclear 

power plant operations by improving the 

operator licensing process and 

examination content, 

(2) Provide the NRC with an improved 

basis for administering operator 

licensing examinations and conducting 

operating tests, and 

(3) Respond to the specific direction 

given by Congress in Section 306, 

Nuclear Waste Policy Act of 1982, Pub. 

L. 97-425, to promulgate regulations and 

guidance in the area of examinations. 

On March 20, 1985, the Commission 

published a Final Policy Statement on 

Training and Qualification of Nuclear 

Power Plant Personnel (50 FR 11147) that 

describes the Commission's current 

policy regarding training of operators. In 

addition to this policy statement. the 

Commission is publishing the new rules 

described in this notice; these rules 

supercede all current regulations for 

operator licenses. Those facility 

licensees that have made a commitment 

that is less than that required by these 

new rules must conform to the new rules 

automatically. Those facility licensees 

that have made a commitment different 

from or more than that required by these 

new rules for license amendments and 

technical specification changes, may 

apply to the Commission so that they 

can conform to these new rules. Other 

changes should be made in accordance 

with 10 CFR 50.59. 

Production facilities previously 

included in Part 55 are not referenced in 

the revisions since there are no 

operators at production facilities 

currently licensed by the Commission. 

Although special consideration has been 

given to the smaller size and scope of 

test and research reactors the 

requirements in this notice apply to all 

utilization facilities licensed under 10 

CFR Part 50, including test and research 

reactors. Consequently, except where 

specific wording has been used to note 

different requirements, these rules apply 

to test and research reactors. 
Federal Register / Vol. 52, No. 57 I Wednesday, March ZS, 1987 I Rules and Regulations 9455 

R. Summary of Public Comments and 

F'mal Actions 

The proposed amendments ta improve 

the operator licensing process have been 

modified in reaponae to the comments 

received. A summary ot the public 

cQmmenta and, where appropriate, a 

description or the changes that resulted 

from them follows. 

(A) General Commenls-{t} General 

purpose of these amendments. Several 

commenten provided general supp0rt 

for the proposed rule. Other commenter& 

auueated changes to clarify the purpose 

and exemptiona eections. These section• 

were reworded aa a result of the 

evaluation of these comments. In 

particular, the purpose of the rule 

indicates that term• and conditions or 

operators' licenses and renewal are 

covered. Exemption for trainees at a 

facility is clarified to indicate that a 

trainee ia only exempted while 

participating in an NRC-approved 

training program to qualify for an 

operator license. In addition, employees 

involved in fuel handling are exempt if 

they are supervised by a licensed aenior 

operator. 

(Z) Definitiom. Many commentera 

were concerned with the specific 

definitions in the rule. A number of 

commenters addresaed the definitions or 

"simulation facility" and "Plantreferenced simulator," and requested 

clarification of the NRC's intent for the 

use of such devices i.n the partial 

conduct of operating tests. Several 

commenters believed that only plantreferenced simulators would be 

permitted. 

The definition of a "plant-referenced 

simulator" is intended to mean a · 

simulator that meets all of the 

requirements of ANSI/ ANS 3.5-1985, as 

endorsed by Regulatory Gulde 1.149, 

"Nuclear Power Plant Simulation 

Facilities for Use in Operator License 

Examinations," (see Section V, 

Regulatory Guides. of this 

Supplementary Infonnation}. 

The definition of a "simulation 

facility" is intended to provide for 

flexibility in the conduct of the simulator 

(non-plant-walkthrough) portion of the 

operating teat. The intent is to permit, 

under clrcum1tances specified in to CFR 

55.45{b). the use of the plant itself, and/ 

or a plant-referenced simulator, and/or 

some other type of simulation device 

such as a part-task or basic-principles 

simulator. for the conduct of the 

simulator portion of the operating test. 

A number of commenters expressed 

concern that a plant. when used as a 

simulator. could not safely perform the 

full range of functions that a simulator 

could perfonn, and some commenters 

requested clarification about the 

·limitation of the conditions under which 

the plant could be used. 

It is not the intent of NRC to permit or 

encourage the initiation of transients on 

the plant when and if the plant is used 

as a simulation facility. The use of the 

plant is envisioned as a possible 

approach that a facility licensee might 

propose to use in conjunction w1th 

another simulation device or devices, in 

lieu of a plant-referenced simulator. This 

approach might be suitable, for example, 

for older plants without access to plantreferenced simulators. where 

manipulations of the plant, to the extent 

consistent with plant conditions, might 

be used to demonstrate familiarity with 

the plant for which the candidate would 

be licensed. 

Several commenters suggested that 

the definition of "reference plant" 

should not be specific to a plant and its 

unit. The word "unit" has been deleted 

from this definition. although it remains 

the NRC's intent that a reference plant 

refer to a specific docket number. For 

those situations in which a multi-unit 

plant is composed of units from the 

same vendor and vintage, it is likely that 

only one simulation facility would be 

required. For others, Regulatory Guide 

1.149 provides specific guidance for 

those facility licensees that want to 

consider the use of one simulation 

facility for use at more than one nuclear 

power plant. This guidance is based 

upon existing NRC policy on the 

granting of multiunit operator's licenses. 

{B) Medical requirements-{1) 

Criteria for medical requirements. Most 

commenters agreed with the revisions to 

the medical certification process, which 

would require. for the usual case, a brief 

certification by the facility licensee on 

Form NRC-396, as revised. Some 

commenters questioned the relationship 

of these requirements to drug and 

alcohol problems and programs. Other 

commenters were confused about who 

would have responsibility for 

determining the medical condition of an 

operator or applicant for an operator's 

license. Some comments were made 

about the specific language in the 

medical requirements regarding 

disqualifying conditions and 

commenters requested changes or 

clarification. Many commenters noted 

the need to adjust the medical 

requirements to the renewal cycle. 

The medical requirements reflect the 

industry standard articulated in ANSI/ 

ANS 3.4-1983, "Medical Certification 

and Monitoring of Personnel Requiring 

Operating Licenses for Nuclear Power 

B-3 

Plants." 1 The intent is to prevent the 

manipulation of the controls by an 

operator whose medical condition and 

general health would cause operational 

errors endangering public health and 

sefety. 'I1le medical requirements rely 

on examination of the applicant or 

operator by a licensed physician who 

evaluates the medical conditon of the 

operator. based on the criteria of ANSI/ 

ANS 3.4-1983 that is endorsed by 

Regulatory Guide 1.134, "Medical 

Evaluation of Licensed Personnel for 

Nuclear Power Plants.'' and makes 

recommendations to the facility's 

management. The facility's management 

ia responsible for certifying the 

suitability of the applicant for a licenae. 

The NRC has the responsibility for 

making an assessment of the applicant 

for a license. including the applicant's 

medical fitness. Neither the facility nor 

the NRC staff will make medical 

judgments. When a conditional license 

is requested, the NRC will use a 

qualified medical expert to review the 

medical evidence submitted by the 

facility to make a determination. For 

minor conditions. such as the need to 

wear corrective lenses or a hearing aid. 

the Form NRC 396 ia modified to 

simplify the process for obtaining a 

medically conditioned license. 

Moreover. while the biennial medical 

examination required under § 55.Zl is 

intended to detect alcoholism or drug 

dependency or both, no reference is 

made in the rule to alcohol or drug 

problems. These issues are covered in a 

Policy Statement on Fitness for Duty of 

Nuclear Power Plant Personnel (51 FR 

27921). published on August 4, 1986, by 

the Commission. In addition. the license 

renewal period is changed to 6 years to 

be compatible with the biennial medical 

examination requirements. 

In July 1983, I<MC, Inc., petitioned the 

Commission (PRM-55-1) "to simplify the 

procedure for the review of the medical 

status of applicants for operator-

. .. licenses." I<MC stated that the 

current procedures require that a 

detailed medical history and results of 

the applicant's medical examination by 

a licensed physician be sent to the 

Commission. The petitioner requested 

that the Commission amend its 

regulations to pennit designated medical 

examiners. as defined in ANSI N546-

1976, "Medical Certification and 

Monitoring of Personnel Requiring 

Operator Licenses for Nuclear Power 

Plants," to certify that the applicant has 

1 Standards discusted in this rule are available 

for purchase from American Nuclear Society. 555 

North Kensington Avenue, La Grange Park, Illinois 

605:!&. 
9456 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 I Rules and Regulations 

been examined (using the guidance 

contained in ANSI N546-1976 as 

endorsed by Regulatory Guide 1.134) 

and that the applicant's general health 

and physical condition is not such as 

may cause operational errors. Under the 

petitioner's request the use of the 

current NRC Form 396 would be 

discontinued for utility operators and 

detailed medical records would be 

retained by the licensee's designated 

medical examiner. Subpart C to Part 55 

responds to the KMC, Inc. petition. NRC 

grants its request, in part, by eliminating 

the requirement to submit, in usual 

cases, medical information for an 

applicant for an operator's license 

directly to the NRC. Instead, as 

described above, a certification to NRC 

about compliance with the health 

requirements in § 55.33(a)(l) would be 

made by the facility licensee. 

(2) Notificotwn of incapacitation 

because of disability or illness. Some 

confusion was noted by several 

commenters regarding the process to 

notify the Commission when an operator 

was incapacitated because of disability 

or illness. The final rule is changed to 

reflect more clearly the Commission's 

intent. That is, if, during the term of the 

license, an operator's medical condition 

changes and does not meet the 

requirements set forth in ANSI/ ANS 

3.4-1983, notification of the Commission 

by the facility licensee is required. At 

the same time, if the examining 

physician indicates that the condition can be accommodated as noted in § 5.1 

of the ANSI/ ANS 3.4-1983, a conditional 

license may be requested by an authorized representative of the facility 

licensee. Form NRC 396 must be used 

and supporting medical evidence must 

be supplied. However, the facility 

licensee does not have to wait for 

permission from the Commission before 

returning an operator to licensed duties, 

if the operator has been examined by a 

physician, who, using ANSI/ ANS 3.4-

1983 as a basis, has recommended to the 

facility's management that the operator 

can return. 

(3) Test and research reactors. Many 

test and research reactor operators were 

concerned that the requirements in the 

rule changed the medical requirements 

for them. The rule changes only the 

requirements for test and research 

reactor facility licensees. It does not 

change the status quo for reactor 

operators. for whom ANSI/ ANS-15.4-

1977(N 380), "Selection and Training of 

Personnel for Research Reactors," 

requirements continue. 

(C) Applications. Applications for an operator license require the facility 

licensee to certify that there is a need 

for the applicant to perform assigned 

duties. Several commenters were 

concerned that the "need" was not 

clearly defined. The requirements are 

intended to simply have the facility 

licensee's management internally review 

the need for the license before the 

application is made. Another concern of 

many commenter& was the relationship 

between industry-accredited training 

programs and the details regarding 

training and experience needed to apply 

to the NRC on Form NRC-398. In 

addition, some commenters were 

concerned with the definition of the 

phrase "learned to operate." This phrase 

has been deleted from § 55.31 and 

replaced by wording which indicates 

that if a candidate successfully 

completes the training and experience 

requirements to be licensed as an 

operator, the NRC will conduct the 

appropriate examination and operating 

test. Section 55.31(a)(5) has been added 

to specify the minimum number of 

control manipulations to be conducted 

by an applicant. Details regarding other 

training and qualification will not be 

required to be supplied on Form NRC398, if these requirements are contained 

in an NRG-approved training program 

that i:ses a simulation facility 

acceptable to the NRC under § 55.45(b). 

Subject to continued Commission 

endorsement of the industry's 

accreditation process under the Final 

Policy Statement on Training and 

Qualification of Nuclear Power Plant 

Personnel (50 FR 11147; March 20, 1985), 

a facility licensee's training program 

would be approved by being accredited 

by the National Nuclear Accrediting 

Board. 

(D) Written examinations and 

operating tests-{1) Content. Most 

commenter& recommended that the 

principal means of determining the 

knowledge, skills, and abilities to be 

included in operator licensing written 

examinations and operating tests should 

be the learning objectives derived from 

a systematic analysis of the job 

performance requirements. These 

commentera recommended that these 

learning objectives form the basis and 

scope of examinations and tests and 

that other sources of information should 

only be used until the learning 

objectives are available for a facility. 

Conversely, some commenters 

questioned as premature the 

endorsement by NRC of a systematic 

analysis from which to draw the content 

for licensing examinations and tests. 

One commenter recommended that NRC 

8-4 

issue a document that specifically 

delineates what an operator is 

responsible for on NRC examinations 

and operating tests. 

Systematic analysis of job 

performance requirements is an 

accepted methodology for deriving 

licensing examination content. The jobtask analyses are being performed as 

part of the performance-based programs 

that are being implemented by facility 

licensees as part of the industry 

supported accreditation program. The 

learning objectives derived from these 

job-task analyses should form the basis 

for licensing written examinations and 

operating tests at a facility. Ultimately, 

the NRC testing objectives will reflect 

facility licensee-developed learning 

objectives. In the interim, while these 

programs are being developed and 

reviewed for accreditation, the NRC has 

activities underway to improve the 

content validity of NRC examinations 

and operating tests. 

(2) Specific wording of categories. 

Many commenters made specific 

wording recommendations for the 

categories listed under content of the 

written examinations and operating test. 

These suggestions were reviewed by 

subject-matter experts and changes 

were made to clarify or improve the 

content categories. No major changes 

resulted except to two categories under 

the operating test. Under § 55.45, 

categories (12) and (13) were reworded 

as follows: 

{12) Demonstrate the knowledge and ability 

as appropriate to the assigned position to 

assume that responsibilities associated with 

the safe operation of the facility. 

{13) Demonstrate the applicant's ability to 

function within the control room team as appropriate to the assigned position. in such a 

way that the facility licensee's procedures are 

adhered to and that the limitations in its 

license and amendments are not violated. 

(3) Waivers. Several commenters 

suggested that examinations and tests 

be automatically waived under specific 

circumstances. As the agency 

responsible for public health and safety 

with regard to nuclear facilities, the 

Commission cannot waive its 

independent assessment of operators. 

Waivers are based on operators 

previously passing all or part of a 

licensing examination. Details regarding 

the processing of waivers are addressed 

in NUREG-1021, "Operator Licensing 

Examiner Standards."• 

1 NUREG-aeriee documents are available for 

public inspection and copying for a fee in the 

Commi11ion'1 Public Document Room at 1717 H 

Continued 
Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 9457 

(4) Integrity and examinations and 

tests. Although many commenters 

supported the addition of § 55.49, 

"Integrity of Examinations and Tests," 

they felt that the penalties in § 55.71 

were excessive. Other commenters were 

afraid that any action might be 

interpreted as cheating and that the role 

of facility licensees in enforcement was 

unclear. The NRC always has 

prosecutorial discretion not to take 

enforcement action in unclear cases. 

The language in § 55.71 on criminal 

violations only covers persons who 

"willfully violate" the Atomic Energy 

Act or the NRC's regulations and does 

not apply to situations such as 

discussions after an examination is 

administered or when a previously 

administered examination is used as a 

practice examination. 

(E) Simulation facilities-(1) 

Application process. Many commenters 

were concerned with what they termed 

the burdensome procedure requiring 

initial and subsequent application for 

approval to use a simulation facility. 

Most of these commenters felt that 

certification by the facility licensee to 

the NRC that the simulation facility met 

industry standards should suffice, when 

combined with the NRC's ability to 

audit the simulation facility and review 

the supporting documentation. 

The Commission has amended the 

final rule to reflect the position taken in 

these comments. Any facility licensee 

that proposes to use a simulation facility 

that meets the definition of a plantreferenced simulator (essentially a 

simulator that meets the requirements of 

ANS-3.5, 1985, "Nuclear Power Plant 

Simulators for Use In Operator 

Training,'' as modified by Regulatory 

Guide 1.149) will be required only to 

certify this to the Commission, and to 

maintain records pertaining to 

performance testing results for 

Commission review or audit. Any 

facility licensee that proposes to use a 

simulation facility that is other than a 

plan-referenced simulator will be 

required to submit a plan detailing how 

the requirements of § 55.45 will be met 

on the alternative device or devices. 

followed by an application for NRC 

approval for use of the simulation 

facility. However, in response to the 

numerous comments received, this 

application process has been greatly 

simplified, and the requirement for a 

S1reet NW. Washington. DC These documents may 

be purchased from the US Govemmenl Prinling 

Office (GPO) by calling 202-275-2060 or by wroting 

the GPO. P 0 Box 37062. Washington DC 20013-

7062 They may also be purchased from Ch• !\;aCional 

T•chnical lnformation Service.US Department of 

Commerce. 5Z85 Port Royal Road Springfield. VA 

22161 

periodic "subsequent" application has 

peen eliminated. In support of its 

certification or its application, as 

appropriate, each facility licensee will 

be required to conduct periodic 

performance tests on its simulation 

facility, and maintain records pertaining 

to the conduct of these tests and the 

results obtained. 

It is the Commission's intent that 

those facility licensees that submit a 

certification for a simulation facility 

may immediately begin use of the 

certified simulation facility for the 

conduct of operating tests at the 

reference plant. 

(2) Performance testing. Many 

comments addressed the requirement 

for the conduct of a series of 

perfonnance tests, in which an 

extensive range of tests would be 

conducted over a 4-year cycle, 25 

percent per year. The industry standard 

which was in effect at the time of the 

proposed rulemaking. ANSI/ ANS 3.~ 

1981, required complete simulator 

perfonnance testing every four years, 

and R.G. 1.149 endorsed that 

requirement. In addition, the R.G. 

specified that all malfunctions which a 

simulation facility was capable of 

performing should be tested to the 

extent that such malfunctions could be 

used in the conduct of operating tests. 

The majority of commenters felt that the 

burden of conducting these tests would 

demand an excessive amount of time on 

the part of the simulation facility as well 

as the facility licensee's staff. Numerous 

suggestions were made proposing lists 

of performance tests thought to be 

appropriate, suggesting alternative 

formulas for the cycle of performance 

testing, or offering suggestions that the 

rule merely endorse a new version of the 

industry standard which was in 

preparation at the time. 

A new version of the standard, 

identified as ANSI/ ANS 3.~1985. was 

published after the expiration of the 

public comment period. In response to 

the comments received and to the newly 

issued industry standard. R.G. 1.149 has 

been changed to endorse the new 

standard, with exceptions, and lo 

include in its endorsement the specific, 

limited list of malfunction performance 

tests contained in the standard. 

However, although the new standard 

continues to require the conduct of 

simulator performance tests. it has 

deleted the requirement that these tests 

be conducted on a four-year cycle for 

the life of the simulator. Instead it has 

substituted an annual operability test, 

and now required that performance tests 

be conducted only upon completion of 

initial simulator construction and in the 

B-5 

event that simulator design changes 

result in significant simulator 

configuration or performance variations. 

In addition, the standard is silent on 

the subject of periodic testing of 

malfunctions. The NRC endorsement of 

the standard in the R.G. takes exception 

to the deletion of periodic performance 

testing. The regulations will require 

performance testing to be conducted 

throughout the life of a simulation 

facility, on a four-year cycle, at the rate 

of approximately 25 percent per year. 

The protection of public health and 

safety requires that licensed operators 

not only be proficient in general 

operations but be able to safely cope 

with plant transients and malfunctions. 

Thus a reactor operator license 

candidate's response to malfunctions 

during an operating test is an important 

factor in the examiner's assessment of 

that candidate's performance. It is also 

necessary to avoid misleading or 

negative training, which could result 

from the use of a simulation facility 

which does not correctly portray plant 

response to malfunctions. Therefore the 

ability of a simulation facility to 

faithfully portray plant malfunctions as 

well as general operability is to be 

verified by periodic performance testing. 

Such testing provides assurance that the 

simulation facility remains acceptable 

over time and continues to meet the 

Commission's regulations. A definition 

of performance testing has been added 

to § 55.4, and the requirements for 

performance testing have been clarified 

in the applicable paragraphs of 

§ 55.45(b), as they apply to all 

simulation facilities, whether certified or 

approved. 

(3) Schedule. A number of comments 

included criticism of the time schedules 

specified as being unreasonably short 

for submitting a simulation facility plan 

and for having a simulation facility in 

full compliance with the regulation. 

The regulation has been changed to 

allow 1 year (versus 120 days) for a 

facility licensee to submit a plan 

detailing its approach to the simulation 

facility requirement; and to allow 4 

years (versus 3) for its simulation 

facility to be in full compliance with the 

regulation. Those facility licensees that 

certify the use of a plant-referenced 

simulator will not have to submit a plan. 

(4) Penalty for unavailability of 

simulation facility. Several comments 

expressed concern that the penalty was 

too harsh for the unavailability of a 

simulation facility acceptable to the 

Commission. 

It is the Commission's intent that 

every facility licensee have available a 

simulation facility that meets the 
9458 Federal Register I Vol. 52, No. 57 / Wednesday, March 25, 1987 I Rules and Regulations 

Commission's requirements within a 

reasonable period of time after the 

effective date of the rule. and that, once 

available, the simulation facility be 

maintained and upgraded. as needed. to 

continue its acceptability for the 

conduct of operating tests. The 

Commission recognizes that unique 

circumstances may arise on a plantspecific basis that cause some deviation 

from the time requirements established 

in the rule and that, from time-to-time, a 

previously certified or approved 

simulation facility may become 

temporarily unacceptable for the 

conduct of operating tests. It is the 

Commission's intent to address any such 

situations on a case-by-case basis. 

(5) Lack of guidance for assessment. 

A number of comments expressed 

concern that the guidance to be used by 

the Commission in its assessment of 

simulation facility adequacy was not yet 

available. It is the Commission's intent 

that no simulation facility audits will be 

conducted until this guidance has been 

fully developed and made publicly 

available for a minimum of 6 months. 

(6) App/Jcability lo future facility 

licensees. Several commenters 

questioned whether the Commission's 

regulations regarding simulation 

facilities were intended to apply to 

future facility licensees. 

It is the Commission's intent that 

these regulations apply to future facility 

licensees as well as current facility 

licensees. 

{7} Test and research reactor 

operators. Several test and research 

reactor operators were concerned that 

the requirements in the rule changed the 

licensing process for them. As stated 

above, the rule does not change the 

status quo for this category of operator. 

The definition of "simulation facility" in 

§ 55.4 allows the plant to be used to 

meet the requirements of § 55.45{b). In 

addition, specific wording in § 55.45{b) 

permits test and research reactor facility 

licensees to be exempted from 

submitting a plan for the use of a 

simulation facility that is other than a 

plant-referenced simulator. 

{F) Licenses-(1) Special senior 

operator licenses. Many commenters 

questioned the issuance of special 

senior licenses. Several argued that 

current instructor certification 

requirements were sufficient, others 

indicated that industry-accredited 

programs include instructor evaluation, 

and others cited the Commission's 

Policy Statement on Training and 

Qualifications of Nuclear Power Plant 

Personnel as conflicting with these 

licenses. 

The Commission has deleted the 

provision for the issuance of special 

senior operator licenses from the final 

rule. Thie action is in recognition of the 

industry accreditation of training 

programs, which includes instructor 

training. qualification and evaluation, 

and is in keeping with the intent of the 

Commission Policy Statement on 

Training and Qualifications of Nuclear 

Power Plant Personnel. Industry efforts 

in implementing instructor training, 

qualification and evaluation programs 

will be monitored as described by the 

Policy Statement. Moreover, senior 

operator licenses limited to fuel 

handling will continue to be issued as 

they are currently. However. since 

industry accreditation includes 

instructor evaluation, current NRC 

instructor certification will not continue 

at facilities with industry accreditation. 

A great number of commenters had 

specific suggestions regarding the · 

requirements for special senior 

operators. These comments are no 

longer applicable since the Commission 

has deleted these licenses from the final 

rule. 

(2) "Actively performing the functions 

of an operator or senior operator." 

Although only one commenter 

specifically questioned the definition of 

"actively performing the [functions] of," 

a great many commenters questioned 

this phrase in regard to R.G. 1.8. 

"Personnel Qualifications and Training 

for Nuclear Power Plants," as it was 

published for public comment in 

conjunction with the proposed rule. 

From the comments made in response lo 

the regulatory guide and other 

comments made regarding the provision 

in the rule under "Requalification," 

which required that an operator or 

senior operator be "actively and 

extensively engaged" as an operator or 

senior operator, it is clear that many 

commenters were confused about the 

degree of participation in plant 

operations that ia required as a 

condition to maintain an operator's or 

senior operator's license. To prevent 

further confusion. the rule has been 

modified in I 55.4, "Definitions," to 

provide the following definition: 

Actively performing the functions of an operator or senior operator" means that an individual has a position on the shift crew that requires the individual to be licensed as defined in the facility's technical 

specification•. and that the individual carrie1 

out and is responsible for the dutiel covered 

by that position. 

In addition, several commenters were 

concerned that the requirements were 

unclear regarding the return to "active" 

status following a period during which a 

licensee has not been "actively 

performing the functions of an operator 

or senior operator" for a period of 4 

B-6 

months or longer. Therefore. the 

following requirements have been 

added: 

If an operator has not performed licensed 

duties on a minimum of seven 8-hour shifts or five 12-hour shifts per quarter, before 

resumption of activities authorized by a 

license issued under these regulations. an authorized representative of the facility 

licensee shall certify that the qualificatlona 

and statua of the licensee are current and 

valid, and that the licenaee has completed a minimum of 40 hour& of 1hift function• under 

the direction of the operator or senior 

operator, as appropriate, and In the position 

to which the individual licensee will be 

assigned. For licenses limited to fuel 

handling. one supervised shift Is sufficient. 

Certification shall be maintained al the 

facility. 

The revision in the wording of the rule 

was made so that it is no longer 

necessary to include the wording 

"actively and extensively engaged" 

under requalificalion. A licensee can 

now maintain licensed status by 

successfully completing the facility 

licensee's NRC-approved requalificalion 

program and passing the requalification 

examinations and operating tests. 

However, to return to active 

performance after a period of not 

participating on shift, the conditions of a 

license in § 55.53(£) must be meL In this 

manner, a licensee without current 

knowledge of the facility would not be 

able to perform shift duties. 

For test and research reactors, the 

requirements for "actively performing 

the functions of an operator or senior 

operator" would be met with a minimum 

of four hours per calendar quarter. 

Similarly, under I 55.53(£), a minimum of 

six hours parallel work would be 

required to return to active status. 

(3) Notification of the Commission. 

Some commenters noted that the 

Commission had no need to know about 

the criminal conviction of a licensee. 

However, I SS.53{g) is intended to cover 

criminal behavior. NRC i8 interested in 

felonious criminal convictions of a 

licensee. The NRC considers that there 

may be a relationship between 

conviction for a felony and job 

performance. 

(G) Expiration. Currently, licensee 

expire after two years. To lessen the 

paperwork burdens of facility licenseu 

and the NRC, a five year expiration waa 

proposed. Many commenters susgested 

that the proposed five year expiration 

and renewal of licenses be adjusted to 

meet the biennial medical examination 

requirements. The renewal cycle baa 

been changed and licen1es will now 

expire after 6 years. 

(H) Requalification and renewal·•-()) 

Requalification program and 
Federal Register I Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 9459 

examination content. A great many 

commenters were unclear about the 

relationship of the NRC requalification 

requirements and performance-based 

training programs. Moreover, many 

commenters urged more flexibility in the 

requalification cycle and more clarity in 

the program content requirements. 

Although the requirement for NRC 

approval of requalification programs 

will remain, the list of content areas 

under 1155.41, 55.43 and 55.45 will be 

referenced in I 55.59 to clarify the issue 

of examination and operating test 

content. In addition, I 55.!59(c) content 

requirements (formerly Appendix A to 

10 CFR Part 55) can be met with a performance-based program for a facility as approved by the NRC. In its 

Final Policy Statement on Training and 

Qualification of Nuclear Power Plant 

Personnel, the Commission endorsed 

industry-accredited programs as performance based. The frequency of 

the comprehensive requalification 

written examination has been changed 

to a maximum of every 2 years and of 

the requalification operating test to once a year. The requalification program must 

be conducted for a continuous period 

not to exceed 24 months. The specific 

cycle will be approved by the NRC as part of each facility's training program. 

(2) "Actively and extensively 

engaged." As explained above, many 

commenters were concerned with the 

implementation of the provision for 

"actively and extensively engaged as an operator or senior operator" as it related 

to renewal. This provision is deleted in 

the final rule. This action complements 

the additions I !55.53 (e) and CO to 

"Conditions of Licenses." 

(3) Test and research reactors. 

Several commenters were concerned 

that the requalification requirements for 

operators at this class of reactor were 

changed. The requirements in 

I 55.59(c)(7) continue the requirements 

of former Appendix A to 10 CFR Part 55 

for test and research reactors. No change 

in requirements is intended. 

(4) NRC administration of 

requalification examinations. Some 

commenters questioned the NRC 

administration of requalification 

examinations. The Commission believes 

that an NRC administered examination 

for license renewal provides assurance 

that an operator or senior operator can 

operate the controls in a safe and 

competent manner and that a senior 

operator can direct the activities of 

other licensed operators in a safe and 

competent manner. The Commission 

also believes that NRC administered 

examinations provide assurance that 

facility licensee administered 

requalification programs are 

successfully maintaining the proficiency 

and knowledge of licensed personnel. 

To this end, the rule requires in I 55.57 

that each applicant for renewal of a sixyear license pass an NRC administered 

comprehensive requalification written 

examination and operating test at least 

once during each six-year license. The 

NRC will administer these 

requalification written examinations 

and operating tests on a random basis 

so that no operator or senior operator 

will go longer than six years without 

being examined by the NRC once a sixyear license is issued. 

{I) Modification and revocation of 

licenses. Some comments were received 

about the Commission's authority to 

modify and revoke licenses. The 

Commission has the authority to modify, 

suspend or revoke a license under the 

Atomic Energy Act. Moreover, inherent 

in the Commission's authority to modify, 

suspend. or revoke a license is its ability 

to place a licensed operator or senior 

operator under probation, if warranted. 

(J) Editorial. Many commenters had 

non-substantive editorial changes to 

suggest. These comments were reviewed 

by an NRC technical editor and 

incorporated as appropriate. 

(I<) Conforming amendments. A 

conforming amendment, 10 CFR 50.74, 

requires the facility licensee to notify 

the Commission of a change in operator 

status. This amendment complements 

I 55.53(g). 

(L) Revision to 10 CFR 50.54 and 10 

CFR 50.34{b){B). Revisions have been 

made to 10 CFR 50.34(b}(8) and 50.54 to 

reflect the changes made to 10 CFR Part 

55. 

Separate Views of Commissioner 

Asselstine 

This rule is a good idea, but it does 

not go far enough. The Commission 

should have required all licensees to 

obtain plant referenced simulators. 

There are two reasons for this. First. I 

believe that section 306 of the Nuclear 

Waste Policy Act of 1982 (Pub. L. 97-

425) requires it. Second, plant referenced 

simulators are an excellent way for 

reactor operators to practice control 

manipulations for the plant and to 

actually see how the plant would 

respond. This is especially important in 

training the operators to deal with 

emergency or other situations when the 

plant is not in its normal state. It is a 

much more effective teaching tool for 

the operators to actually manipulate 

controls and watch the "plant" respond 

than to have them merely memorize 

emergency procedures. Further, a simulator which is referenced to the 

plant on which the operator will be 

B-7 

licensed will be a much more effective 

training tool than one which is not. 

The Commission decided, however, 

that because there might be special 

circumstances in some cases which 

would weigh against requiring that a 

particular utility purchase a simulator 

the Commission would not make it a 

requirement. This kind of case-specific 

special circumstances is precisely what 

our exemption procedures are intended 

to handle. If a licensee had appropriate 

justification, the Commission could 

always consider whether to grant an 

exemption to the regulation. Instead, the 

Commission chose to water down the 

regulation and require less. 

Separate Views of Commissioner 

Bemthal 

I fully support the Commission's 

broad objective that operators be 

reexamined on a regular basis. But I 

believe the final rule is too inflexible for 

good regulatory and administrative 

practice. NRC may indeed need to 

examine operators every six years; in 

some cases, perhaps more often. But if a 

licensee satisfactorily demonstrates its 

ability to conduct high quality, 

performance-based examinations in 

accordance with I 55 57(b)(2)(iii), such 

licensee performance may well justify 

extension or relaxation of this 

requirement. This approach would have 

been consistent with the Commission's 

policy of rewarding good licensee 

performance and focusing attention and 

resources on deficient performers. The 

Commission thus could have provided 

incentive to licensees and flexibility to 

the NRC examiner staff, and should 

have thereby focused NRC's limited 

regulatory resources where they are most urgently needed. 

I also continue to believe that the time 

has come (given the decreased cost and 

increased sophistication of the 

technology) for all but a few small 

powerplants to be required to have plant 

reference simulators for operator 

training While there may be some 

special cases that would qualify for 

exemption from such a requirement, on 

the basis of geography and/or plant 

similarity, licensees could in those 

circumstances apply for and receive an 

exemption. 

III. Regulatory Analysis 

The regulatory analysis describes the 

values (benefits) and impacts (costs] of 

implementing the proposed regulations 

and guidance for operator licensing. The 

accuracy of these estimates in the 

regulatory analysis is limited by the lack 

of extensive data on human 

performance improvement associated 
9460 Federal Register I Vol. 52. No. 57 I Wednesday, March 25, 1987 / Rules and Regulations 

with an improved licensing process. 

Where possible, quantitative measures 

were qualitatively compared to related 

information from other sources for 

verification. The full text of the 

regulatory analysis on these 

amendments is available for inspection 

in the NRC Public Document Room, 1717 

H Street NW., Washington, DC. Single 

copies of the analysis may be obtained 

from Chief, Operator Licensing Branch. 

telephone: {301) 492-4868. 

IV. Backfit Analysis 

The Commission has determined that 

these rules are in response to section 

306 of the Nuclear Waste Policy Act of 

1982 and, therefore. are exempt from the 

backfit rule 10 CFR 50 109 {50 FR 38097). 

V. Regulatory Guides 

Three regulatory guides were 

published in draft form for public 

comment in conjunction with the 

proposed rule. These guides were 

intended to provide guidance on 

acceptable methods of implementing the 

revisions to the regulations. As a result 

of public comment and additional staff 

review. these three guides are being 

issued in final form: 

(1) R G. 1.134, Revision 2, "Medical 

Evaluation of Licensed Personnel for 

Nuclear Power Plants." 

(2) R.G. 1.149, Revision 2. "Nuclear 

Power Plant Simulation Facilities for 

Use in Operator License Examinations." 

(3) R.G. 1.8, Revision 2. "Qualifieation 

and Training of Personnel for Nuclear 

Power Plants." 

Copies of these guides may be 

purchased from the Government Printing 

Office at the current GPO price. 

Information on current GPO prices may 

be obtained by contacting the 

Superintendent of Documents, U.S. 

Government Printing Office, Post Office 

Box 37082. Washington. DC 20013-7082. 

telephone (202) 275-2060 or (202} 275-

2171. 

VI. Environmental Impact: Categorical 

Exclusion 

The NRC has determined that this 

regulation is the type of action described 

in categorical exclusion 10 CFR 

51.22(c}(1}. Therefore, neither an 

environmental impact statement nor an 

environmental assessment has been 

prepared for this regulation. 

VII. Paperwork Reduction Act 

Statement 

This final rule amends information 

collection requirements that are subject 

to the Paperwork Reduction Act of 1980 

(44 U.S.C. 3501 et seq.). These 

paperwork requirements were approved 

by the Office of Management and 

Budget approval number 3150--0018. 

VIII. Regulatory Flexibility Certification 

As required by the Regulatory 

Flexibility Act of 1980, 5 U.S.C. 605{b), 

the Commission hereby certifies that 

this rule will not have a significant 

economic impact on a substantial 

number of small entities. The 

conforming amendment to 10 CFR Part 

50 and the revision of 10 CFR Part 55 

affect primarily the companies that own 

and operate light-water nuclear power 

reactors and the vendors of those 

reactors. They also affect individuals 

licensed as operators at these 

companies. Neither the companies that 

own and operate reactors nor these 

individuals fall within the scope of the 

definition of "small entity" set forth in 

section 501(b) of the Regulatory 

Flexibility Act, NRC's Size Standards 

adopted December 9, 1985 (50 FR 50241), 

or the Small Business Size Standards set 

out in regulations issued by the Small 

Business Administration in 13 CFR Part 

121. 

List of Subjects 

10 CFR Part 50 

Antitrust, Classified information, Fire 

prevention, Incorporation by reference, 

Intergovernmental relations, Nuclear 

power plants and reactors, Penalty, 

Radiation protection, Reactor siting 

criteria, Reporting and recordkeeping 

requirements. 

10 CFR Part 55 

Manpower training programs, Nuclear 

power plants and reactors, Penalty, 

Reporting and recordkeeping 

requirements. 

For the reasons set out in the 

preamble and under the authority of the 

Atomic Energy Act of 1954, as amended, 

the Energy Reorganization Act of 1974, 

as amended, the Nuclear Waste Policy 

Act of1982, and 5 U.S.C. 553, the NRC is 

adopting the following amendments to 

10 CFR Part 55 and 10 CFR Part 50. 

1. 10 CFR Part 55 is revised to read as 

follows: 

PART 55-0PERATORS' LICENSES 

Subpart A-General ProvlslOns 

Sec 

55.1 Purpose. 

55.2 Srope. 

55.3 License requirements. 

55.4 Definitions. 

55.5 Communications. 

55 6 Interpretations 

55 7 Additional requirements. 

55.B Information collection requirements: 

OMB approval. 

B-8 

Subpart 8-Exemptlona 

55 11 Specific exemptions. 

55. t3' General exemptions. 

Subpart C-Medlcat Requirement• 

55.21 Medical examination. 

55.23 Certification. 

55.25 lncapacitation because of disability or illneH. 

55.27 Documentation. 

Subpart D-AppllcaUona 

55.31 How to apply. 

55.33 Disposition of an initial application. 

55.35 Re-applications. 

Subpart E-Wrttten Examinations and 

Opernlng Teata 

55 41 Written examination: Operators. 

55.43 Written examination: Senior operators. 

55.45 Operating tests. 

55.47 Waiver of examination and test 

requirements. 

55.49 lntegrity of examinations and testa. 

Subpart F-l..lcenaM 

55.51 IS11uance of licenses. 

55.53 Conditions of licenses. 

55.55 Expiration. 

55.57 Renewal of licenses. 

55.59 Requalification. 

Subpart G-Modlflcatlon and Revocation of 

Ucenaea 

55.61 Modification and revocation of licenses. 

Subpart H-Enforcement 

55.71 Violation&. 

Authority: Secs. 107. 161, 182, 68 Stat. 939. 

948, 953 as amended, sec. Z34, 83 Stat. 444, as amended (42 U.S.C. 2137, 2201. 2232. 2282); 

aec1. 201, as amended, Z02. 88 Stal 1242, a1 

amended, 1244 (42 U.S.C. 5841, 5842). 

Sections 55.41, 65.43, 55.45 and 55.59 also 

issued under tee. 306. Pub. L. 97-425, 96 Stal 

2262 (42 U.S C. 10226). Section 65.61 alto 

issued under secs. 186, 187, 68 Stal 955 (42 

u.s c 2236, 2237). 

For the purposes of sec. 223, 68 Stat. 958, aa amended (42 U.S.C. 2273) H 55.3, 55.21, 55.49 

and 55 53 are !Hued under sec. 161i, 68 Stat. 

949. as amended (42 U.S.C. Z201(i]J: and 

U 55.23. 55.25 and 55.53(f) are Issued under sec. 1610, 88 Stat. 950, as amended {42 U.S.C. 

2201(0)). 

Subpart A-General Provisions 

§ 55.1 Purpose. 

The regulations in this part: 

(a) Establish procedures and criteria 

for the issuance of licenses to operators 

and senior operators of utilization 

facilities licensed pursuant to the 

Atomic Energy Act of 1954. as amended. 

or section 202 of the Energy 

Reorganization Act of 1974, as amended, 

and Part 50 of this chapter, 

(b) Provide for the terms and 

conditions upon which the Commission 

will issue or modify these licenses, and 

(c) Provide for the terms and 

conditions to maintain and renew these 

licenses. 
Federal Register I Vol. 52, No. 57 I Wednesday, March ZS, 1987 I Rules and Regulations 9461 

I 55.1 Scope. 

The regulations in this part apply to-

(a) Any Individual who manipulates the 

controls of any utilization facility 

licensed pursuant to Part SO of this 

chapter, and 

(b) Any individual designated by a facility licensee to be responsible for 

directing any licensed activity of a 

licensed operator. 

I 55.3 UcenM requlrementa. 

A person muat be authorized by a 

license isaued by the Commiuioo to 

perform the function of an operator or a 

senior operator u defined in till• part. 

I 55.4 Deflnltlona. 

Aa used In this part: 

"Act" means the Atomic Energy Act 

of 1954, Including any amendments to 

theAcl 

"Actively performing the functions of 

an operator or senior operator" means 

that an Individual has a position on the 

shift crew that requires the individual to 

be licensed as defined in the facility's 

technical specifications, and that the 

individual carries out and is responsible 

for the duties covered by that position. 

"Commission" means the Nucfear 

Regulatory Commission or its duly 

authorized representatives. 

"Controls" when used with respect to 

a nuclear reactor means apparatus and 

mechanisms the manipulation of which 

directly affects the reactivity or power 

level of the reactor. .. Facility" means any utilization 

facility as defined in Part 50 of this 

chapter. In cases for which a license is 

issued for operation or two or more 

facilities, "facility" means all facilities 

identified in the license. 

"Facility licensee" means an applicant 

for or holder of a license for a facility. 

"Licensee" means an individual 

licensed operator or senior operator. 

"Operator" means any individual 

licensed under this part to manipulate a 

control of a facility. 

"Performance testing" means testing 

conducted to verify a simulation 

facility's performance 88 compared to 

actual or predicted reference plant 

performance. 

"Physician" means an individual 

licensed by a State or territory of the 

United States, the District of Columbia 

or the Commonwealth of Puerto Rico to 

dispense drugs in the practice of 

medicine. 

"Plant-referenced simulator" means a 

simulator modeling the systems of the 

reference plant with which the operator 

interfaces in the control room. including 

operating consoles. and which permits 

use of the reference plant's procedures. 

A plant-referenced simulator 

demonstrates expected plant response 

to operator input, and to normal, 

transient, and accident conditions to 

which the simulator has been designed 

to respond. 

"Reference plant" means the specific 

nuclear power plant from which a 

simulation facility's control room configuration, system control 

arrangement, and design data are derived. 

"Senior operator" means ariy 

individual licensed under this part to 

manipulate the controls of a facility and 

to direct the licensed activities of 

licensed operators. 

"Simulation facility" 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 candidates: 

(1) The plant, 

(2) A plant-referenced simulator, 

(3) Another simulation device. 

"Systems approach to training" means 

a training program that includes the 

following five elements: 

(1) Systematic analysis of the jobs to 

be performed. 

(2) Leaming objectives derived from 

the analysis which describe desired 

performance after training. 

(3) Training design and 

implementation based on the learning 

objectives. 

(4) Evaluation of trainee mastery of 

the objectives during training. 

(5) Evaluation and revision of the 

training based on the performance of 

trained personnel in the job setting. 

"United States," when used in a 

geographical sense, includes Puerto Rico 

and all territories and possessions of the 

United States. 

f 55.5 Communications. 

(a) Except as provided under a 

regional licensing program identified In 

paragraph (b) of this section, an 

applicant or licensee or facility licensee 

shall submit any communication or 

report concerning the regulations in this 

part and shall submit any application 

filed under these regulations to the 

Commission 88 follows: 

(1) By mail addressed to-Director of 

Nuclear Reactor Regulation, U.S. 

Nuclear Regulatory Commission, 

Washington. DC 20555, or (2) By delivery in person to the 

Commission offices at-(i) 1717 H Street 

NW .. Washington, DC or (ii) 7920 

Norfolk Avenue. Bethesda. Maryland. 

(b}(l) The Director of Nuclear Reactor 

Regulation has delegated to the Regional 

Administrators of Regions I, II. Ill, IV, 

and V authority and responsibility 

pursuant to the regulations In this part 

for the issuance and renewal of licenses 

B-9 

for operators and senior operators of 

nuclear reactors licensed under 10 CFR 

Part 50 and located in these regions. 

(2) Any application for a license or 

license renewal filed under the 

regulations in this part involving a 

nuclear reactor licensed under 10 CFR 

Part 50 and any related inquiry. 

communication, lnfonnation, or report 

must be submitted l>y mail or in person 

to the Regional Administrator. The 

Regional Administrator or the 

Administrator's designee will transmit 

to the Director of Nuclear Reactor 

Regulation any matter that is not within 

the scope of the Regional 

Administrator's delegated authority. 

(i) If the nuclear reactor is located in 

Region I. submission must be made to 

the Regional Administrator, Region I, 

U.S. Nuclear Regulatory Commission. 

631 Park Avenue, King of Prussia, 

Pennsylvania 19406. 

(ii) If the nuclear reactor is located in 

Region II, submission must be made to 

the Regional Administrator, Region II, 

U.S. Nuclear Regulatory Commission, 

101 Marietta Street. Suite 2900. Atlanta, 

Georgia 30303. 

(iii) If the nuclear reactor is located in 

Region Ill, submission must be made to 

the Regional Administrator, Region III, 

U.S. Nuclear Regulatory Commission, 

799 Roosevelt Road, Glen Ellyn, Illinois 

60137. 

(iv) If the nuclear reactor is located in 

Region IV, submission must be made to 

the Regional Administrator, Region IV, 

U.S. Nuclear Regulatory Commission, 

611 Ryan Plaza Drive, Suite 1000, 

Arlington, Texas 76011. 

(v) If the nuclear reactor is located in 

Region V. submission must be made to 

the Regional Administrator. RPgion V, 

U.S. Nuclear Regulatory Commission. 

1450 Maria Lane, Suite 210, Walnut 

Creek, California 94596. 

§ 55.6 Interpretations. 

Except as specifically authorized by 

the Commission in writing. no 

interpretation of the meaning of the 

regulations in fhis part by any officer or 

employee of the Commission other than 

a written interpretation by the General 

Counsel will be recognized to be binding 

upon the Commission. 

§ 55.7 Additional requirements. 

The Commission may. by rule. 

regulation, or order. impose upon any 

licensee such requirements, in addition 

to those established in the regulations in 

this part, as it deems appropriate or 

necessary to protect health and to 

minimize danger to life or property. 
9462 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 

§ 55.8 Information collection 

requirements: OMB approval. 

(a) The Nuclear Regulatory 

Commission has submitted the 

Information collection requirements 

contained in this part to the Office of 

Management and Budget (OMB) for 

approval as required by the Paperwork 

Reduction Act of 1980 (44 U.S.C. 3501 et 

seq.). OMB has approved the 

information collection requirements 

contained in this part under control 

number 315(}.-0()18. 

(b) The approved information 

collection requirements contained in this 

part appear in § § 55.45, 55.53, and 

§ 55.59. 

(c) This part contains information 

collection requirements in addition to 

those approved under the control 

number specified in paragraph (a} of this 

section. These information collection 

requirements and the control numbers 

under which they are approved are as 

follows: 

(1) In§§ 55.23, 55.25, 55.27, 55.31, Form 

r.iRC-396 is approved under control 

number 315()...-0()24. 

(2) In § § 55.31, 55.35, 55.47, and 55.57, 

F.Jrm NRC-398 is approved under 

control number 3150--0090. 

(3) In § 55.45, Form NRC-474 is 

aoproved under control number 3150-

0138. 

Subpart B-Exemptlons 

§ 55.11 Specific exemptions. 

The Commission may, upon 

aμplication by an interested person, or 

upon its own initiative, grant such 

exemptions from the requirements of the 

regulations in this part as it determines 

are authorized by law and will not 

endanger life or property and are 

otherwise in the public interest. 

§ 55.13 General exemptions. 

The regulations in this part do not 

require a license for an individual 

who-

(a) Under the direction and in the 

presence of a licensed operator or senior 

operator, manipulates the controls of-

(1) A research or training reactor as 

part of the individual's training as a student, or 

(2) A facility as a part of the 

individual's training in a facility 

licensee's training program as approved 

by the Commission to qualify for an 

operator license under this part. 

(b) Under the direction and in the 

presence of a licensed senior operator, 

manipulates the controls of a facility to 

load or unload the fuel into, out of, or 

within the reactor vessel. 

Subpart C-Medlcal Requirements 

§ 55.21 Medical examination. 

An applicant for a license shall have a 

medical examination by a physician. A 

licensee shall have a medical 

examination by a physician every two 

years. The physician shall determine 

that the applicant or licensee meets the 

requirements of§ 55.33(a)(l). 

§ 55.23 Certification. 

To certify the medical fitness of the 

applicant, an authorized representative 

of the facility licensee shall complete 

and sign Form NRC-396, "Certification 

of Medical Examination by Facility 

Licensee," available from Publication 

Services Section, Document 

Management Branch, Division of 

Technical Information and Document 

Control, U.S. Nuclear Regulatory 

Commission, Washington, DC 20555. 

(a) Form NRC-396 must certify that a 

physician has conducted the medical 

examination of the applicant as required 

in§ 55.21. 

(b) When the certification requests a 

conditional license based on medical 

evidence, the medical evidence must be 

submitted on NRC Form 396 to the 

Commission and the Commission then 

makes a determination in accordance 

with § 55.33. 

§ 55.25 Incapacitation because of 

dlaabllity or Illness. 

If, during the term of the license, the 

licensee develops a physical or mental 

condition that causes the licensee to fail 

to meet the requirements of § 55.21 of 

this part, the facility licensee shall notify 

the Commission within 30 days of 

learning of the diagnosis. For conditions 

for which a conditional license (as 

describing in § 55.33(b) of this part) is 

requested, the facility licensee shall 

provide medical certification on Form 

NRC 396 to the Commission (as 

described in§ 55.23 of this part). 

I 55.27 Documentation. 

The facility licensee shall document 

and maintain the results of medical 

qualifications data, test results, and 

each operator's or senior operator's 

medical history for the current license 

period and provide the documentation 

to the Commission upon request. The 

facility licensee shall retain this 

documentation while an individual 

performs the functions of an operator or senior operator. 

Subpart D-Appllcatlons 

§ 55.31 How to apply. 

(a) The applicant shall: 

(1) Complete Form NRC-398, 

"Personal Qualification StatementB-10 

Licensee," available from Publication 

Services Section, Document 

Management Branch, Division of 

Technical Information and Document 

Control, U.S. Nuclear Regulatory 

Commission, Washington, DC 20555; 

(2) File an original and two copies of 

Form NRC-398, together with the 

information required in paragraphs 

(a)(3), (4), (5) and (6) of this section, with 

the appropriate Regional Administrator: 

(3) Submit a written request from an authorized representative of the facility 

licensee by which the applicant will be 

employed that the written examination 

and operating test be administered to 

the applicant: 

(4) Provide evidence that the applicant 

has successfully completed the facility 

licensee's requirements to be licensed as 

an operator or senior operator and of the 

facility licensee's need for an operator or a senior operator to perform assigned 

duties. An authorized representative of 

the facility licensee shall certify this 

evidence on Form NRC-398. This 

certification must include details of the 

applicant's qualifications, and details on 

courses of instruction administered by 

the facility licensee, and describe the 

nature of the training received at the 

facility, and the startup and shutdown 

experience received. In lieu of these 

details. the Commission may accept 

certification that the applicant has 

successfully completed a Commissionapproved training program that is based 

on a systems approach to training and 

that uses a simulation facility 

acceptable to the Commission under 

§ 55.45(b) of this part; 

(5) Provide evidence that the 

applicant, as a trainee, has successfully 

manipulated the controls of the facility 

for which a license is sought. At a minimum, five significant control 

manipulations must be performed which 

affect reactivity or power level. For a 

facility that has not completed 

preoperational testing and initial startup 

test program as described in its Final 

Safety Analysis Report, as amended and 

approved by the Commission, the 

Commission may accept evidence of 

satisfactory performance of simulated 

control manipulations as part of a 

Commission-approved training program 

by a trainee on a simulation facility 

acceptable to the Commission under 

§ 55.45(b) of this part. For a facility 

which h&d (i) completed preoperational 

testing as describe~ in its Final Safety 

Analysis Report, as amended and 

approved by the Commission, and Iii) is 

in an extended shutdown which 

precludes manipulation of the control of 

the facility in the control room, the 

Commission may process the 
Federal Register I Vol. 52. No. 57 / Wednesday, March 25, 1987 I Rules and Regulations 9463 

application and may administer the 

written examination and operating test 

required by 11 55.41 or 55.43 and 55.45 

of this part, but may not issue the 

license until the required evidence of 

control manipulations is supplied. For 

licensed operators applying for a senior 

operator license, certification that the 

operator has successfully operated the 

controls of the facility as a licensed 

operator ahall be accepted; and 

(6) Provide certification by the facility 

licensee of medical condition and 

general health on Form NRC-396, to 

comply with H 55.21, 55.23 and 

55.33(a)(1). 

(b) The Commission may at any time 

after the application has been filed, and 

before the license has expired. require 

futher information under oath or 

affirmation in order to enable it to 

determine whether to grant or deny the 

application or whether to revoke, 

modify, or suspend the license. 

(c) An applicant whose application 

has been denied because of a medical 

condition or general health may submit 

a further medical report at any time as a 

supplement to the application. 

(d) Each application and statement 

must contain complete and accurate 

disclosure as to all matters required to 

be disclosed. The applicant shall sign 

statements required by paragraphs (a)(1) 

and (2) of this section. 

f 55.33 DlspoalUon of an Initial 

applicatlon. 

(a) Requirements for the approval of 

an initial application. The Commission 

will approve an initial application for a 

license pursuant to the regulations in 

this part, if it finds that-

(1) Health. The applicants medical 

condition and general health will not 

adversely affect the performance of 

assigned operator job duties or cause 

operational errors endangering public 

health and safety. The Commission will 

base its finding upon the certification by 

the facility licensee as detailed in 

§ 55.23. 

(2) Written examination and 

operating test. The applicant has passed 

the requisite written examination and 

operating test in accordance with 

11 55.41 and 55.45 or 55.43 and 55.45. 

These examinations and tests determine 

whether the applicant for an operator's 

license has learned to operate a facility 

competently and safely. and 

additionally. in the case of a senior 

operator, whether the applicant has 

learned to direct the licensed activities 

of licensed operators competently and 

safely. 

(b) Conditional license. If an 

applicant's general medical condition 

does not meet the minimum standards 

under§ 55.33(a}(l) of this part, the 

Commission may approve the 

application and include conditions In 

the license to accommodate the medical 

defect The Commission will consider 

the recommendations and supporting 

evidence of the facility licensee and of 

the examining physician (provided on 

Fonn NRC-396) in arriving at its 

decision. 

I 55.35 Re-appllcatlona. 

(a) An applicant whose application for 

a license has been denied because of 

failure to pasa the written examination 

or operating test, or both, may file a new 

application two months after the date of 

denial. The application must be 

submitted on Form NRC-398 and include 

a statement signed by an authorized 

representative of the facility licensee by 

whom the applicant will be employed 

that states in detail the extent of the 

applicant's additional training since the 

denial and certifies that the applicant is 

ready for re-examination. An applicant 

may filed a third application six months 

after the date of denial of the second 

application, and may file further 

successive applications two years after 

the date of denial of each prior 

application. The applicant shall submit 

each successive application on Form 

NRC-398 and include a statement of 

additional training. 

(b) An applicant who has passed 

either the written examination or 

operating test and failed the other may 

request in a new application on Form 

NRC-398 to be excused from reexamination on the portions of the 

examination or test which the applicant 

has passed. The Commission may in its 

discretion grant the request, if it 

determines that sufficient justification is 

presented. 

Subpart E-Wrltten Examinations and 

Operating Tests 

§ 55.41 Wrttten examination: Operatora. 

(a) Content. The written examination 

for an operator will contain a 

representative selection of questions on 

the knowledge, skills, and abilities 

needed to perform licensed operator 

duties. The knowledge, skills, and 

abilities will be identified, in part, from 

learning objectives derived from a 

systematic analysis of licensed operator 

duties performed by each facility 

licensee and contained in its training 

program and from information in the 

Final Safety Analysis Report, system 

description manuals and operating 

procedures, facility license and license 

amendments, Licensee Event Reports, 

and other materials requested from the 

facility licensee by the Commission. 

B-11 

(b) The written examinatioQ for an 

operator for a facility will include a 

representative sample from among the 

following 14 items, to the extent 

applicable to the facility. 

(1) Fundamentals of reactor theory, 

including fission process, neutron 

multiplication, source effects, control 

rod effects, criticality indications, 

reactivity coefficients, and poison 

effects. 

(2) General design features of the 

core, including core structure, fuel 

elements, control rods, core 

instrumentation. and coolant flow. 

(3) Mechanical components and 

design features of the reactor primary 

syatem. 

(4) Secondary coolant and auxiliary 

systems that affect the facility. 

(5) Facility operating characteristics 

during steady state and transient 

conditions, including coolant chemistry, 

causes and effects of temperature, 

pressure and reactivity changes. effects 

of load changes, and operating 

limitations and reasons for these 

operating characteristics. 

(6) Design. components, and functions 

of reactivity control mechanisms and 

instrumentation. 

(7) Design, components, and functions 

of control and safety systems, including 

instrumentation, signals, interlocks, 

failure modes, and automatic and 

manual features. 

(8) Components, capacity, and 

functions of emergency systems. 

(9) Shielding, isolation, and 

containment design features, including 

access limitations. 

(10) Administrative, normal. 

abnormal. and emergency operating 

procedures for the facility. 

(11) Purpose and operation of 

radiation monitoring systems, including 

alarms and survey equipment. 

(12) Radiological safety principles and 

procedures. 

(13) Procedures and equipment 

available for handling and disposal of 

radioactive materials and effluents. 

(14) Principles of heat transfer 

thermodynamics and fluid mechanics. 

§ 55.43 Wrmen examination: Senior 

operators. 

(a) Content. The written examination 

for a senior operator will contain a 

representative selection of questions on 

the knowledge, skills, and abilities 

needed to perform licensed senior 

operator duties. The knowledge, skills. 

and abilities will be identified. in part, 

from learning objectives derived from a 

systematic analysis of licensed senior 

operator duties performed by each 

facility licensee and contained in its 
9464 Federal Register I Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 

training program and from information 

in the Final Safety Analysis Report. 

sytem description manuals and 

operating procedures, facility license 

and license amendments, Licensee 

Event Reports, and other materials 

requested from the facility licensee by 

the Commission. 

(b) The written examination for a 

senior operator for a facility will include a representative sample from among the 

following seven items and the 14 items 

specified in § 55.41 of this part, to the 

extent applicable to the facility: 

(1) Conditions and limitations in the 

facility license. 

(2) Facility operating limitations in the 

technical specifications and their bases. 

(3) Facility licensee procedures 

required to obtain authority for design 

and operating changes in the facility. 

(4) Radiation hazards that may arise 

during normal and abnormal situations, 

including maintenance activities and 

various contamination conditions. 

(5) Assessment of facility conditions 

and selection of appropriate procedures 

during normal, abnormal, and 

emergency situations. 

(6) Procedures and limitations 

involved in initial core loading, 

alterations in core configuration, control 

rod programming, and determination of 

various internal and external effects on 

c0re reactivity. 

(7) Fuel handling facilities and 

procedures. 

§ 55.45 Operating tests. 

(a) Content. The operating tests 

administered to applicants for operator 

and senior operator licenses in 

accordance with paragraph (b)(l) of this 

section are generally similar in scope. 

The content will be identified, in part, 

fr om learning objectives derived from a 

systematic analysis of licensed operator 

or senior operator duties performed by 

each facility licensee and contained in 

its training program and from 

information in the Final Safety Analysis 

Report, system description manuals and 

operating procedures, facility license 

and license amendments, Licensee 

Event Reports, and other materials 

requested from the facility licensee by 

the Commission. The operating test, to 

the extent applicable, requires the 

applicant to demonstrate an 

understanding of and the ability to 

perform the actions necessary to 

accomplish a representative sample 

from among the following 13 items. 

(1) Perform pre-startup procedures for 

the facility, including operating of those 

controls associated with plant 

e4uipment that could affect reactivity. 

(2) Manipulate the console controls as 

required to operate the facility between 

shutdown and designated power levels. 

(J) Identify annunciators and 

condition-indicating signals and perform 

appropriate remedial actions where 

appropriate. 

(4) Identify the instrumentation 

systems and the significance of facility 

instrument readings. 

(5) Observe and safely control the 

operating behavior characteristics of the 

facility. 

(6) Perform control manipulations 

required to obtain desired operating 

results during normal, abnormal, and 

emergency situations. 

(7) Safely operate the facility's head 

removal systems, including primary 

coolant, emergency coolant, and decay 

heat removal systems, and identify the 

relations of the proper operation of 

these systems to the operation of the 

facility. 

(8) Safely operate the facility's 

auxiliary and emergency systems, 

including operation of those controls 

associated with plant equipment that 

could affect reactivity or the release of 

radioactive materials to the 

environment. 

(9) Demonstrate or describe the use 

and function of the facility's radiation 

monitoring systems, inlcuding fixed 

radiation monitors and alarms, portable 

survey instruments, and personnel 

monitoring equipment. 

(10) Demonstrate knowledge of 

significant radiation hazards, including 

permissible levels in excess of those 

authorized, and ability to perform other 

procedures to reduce excessive levels of 

radiation and to guard against personnel 

exposure. 

(11) Demonstrate knowledge of the 

emergency plan for the facility, 

including, as appropriate, the operator's 

or senior operator's responsibility to 

decide whether the plan should be 

executed and the duties under the plan 

assigned. 

(12) Demonstrate the knowledge and 

ability as appropriate to the assigned 

position to assume the responsibilities 

associated with the safe operation of the 

facility. 

(13) Demonstrate the applicant's 

ability to function within the control room team as appropriate to the 

assigned position, in such a way that the 

facility licensee's procedures are 

adhered to and that the limitations in its 

license and amendments are not 

violated. 

(b) lmplementation-{1) 

Administration. The operating test will 

be administered in a plant walkthrough 

and in eitherB-12 

(i) A simulation facility which the 

Commission has approved for use after 

application has been made by the 

facility licensee, or 

(ii) A simulation facility consisting 

solely of a plant-referenced simultator 

which has been certified to the 

Commission by the facility licensee. 

(2) Schedule for facility licensees. (i) 

Within one year after the effective date 

of this part, each facility licensee which 

proposes to use a simulation facility 

pursuant to paragraph (b)(l)(i) of this 

section, except test and research 

reactors, shall submit a plan by which 

its simulation facility will be developed 

and by which an application will be 

submitted for its use. 

(ii) Those facility licensees which 

propose to conform with paragraph 

(b)(l)(i) of this section, not later than 42 

months after the effective date of this 

rule, shall submit an application for use 

of this simulation facility to the 

Commission. in accordance with 

paragraph (b)(4)(i) of this section. 

(iii) Those facility licensees which 

propose to conform with paragraph 

(b)(t)(ii) of this section, not later than 46 

months after the effective date of this 

rule, shall submit a certification for use 

of this simulation facility to the 

Commission on Form NRC-474, 

"Simulation Facility Certification," 

available from Publication Services 

Section, Document Management Branch, 

Division of Technical Information and 

Document Control, U.S. Nuclear 

Regulatory Commission, Washington, 

DC 20555, in accordance with paragraph 

(b)(5)(i) of this section. 

(iv) The simulation facility portion of 

the operating test will not be 

administered on other than a certified or 

an approved simulation facility after 

May 26, 1991. 

(3) Schedule for facility applicants. (i) 

For facility licensee applications after 

the effective date of this rule, except test 

and research reactors. the applicant 

shall submit a plan which identifies 

whether its simulation facility will 

conform with paragraph (b)(l}(i) or 

(b)(t)(ii) of this section at the time of 

application. 

{ii) Those applicants which propose to 

conform with paragraph (b)(l)(i) of this 

section, not later than 180 days before 

the date when the applicant proposes 

that the Commission conduct operating 

tests, shall submit an application for use 

of its simulation facility to the NRC. in 

accordance with paragraph {b)(4){i) of 

this section. 

(iii) Those applicants which propose 

to conform with paragraph (b)(l)(ii) of 

this section, not later than 60 days 

before the date when the applicant 
Federal Register / Vol. 52, No. 57 I Wednesday, March 25, 1987 / Rules and Regulations 9465 

proposes that NRC conduct operating 

tests, shall submit a certification for use 

of its simulation facility to the 

Commission on Form NRC-474. in 

accordance with paragraph (b)(5)(i) of 

this section. 

(4) Application for and approval of 

simulation facilities. Those facility 

licensees which propose. in accordance 

with paragraph (b)(l)[i) of this section, 

to use a simulation facility that is other 

than solely a plant-referenced simulator 

as defined in I 55.4 shall-

(i) In accordance with the plan 

submitted pursuant to paragraph 

(b )(2)(i) or (b )(3)(i) of this section, as 

applicable submit an application for 

approval of the simulation facility to the 

Commission, in accordance with the 

schedule in paragraph (b}(2}(ii) or (b)(3)(ii) of this section, as appropriate. 

This application must include: 

(A) A statement that the simulation 

facility meets the plan submitted to the 

Commission pursuant to paragraph 

(b)(2)(i} or (b}(3)(i) of this section, as 

applicable; 

(B) A description of the components of 

the simulation facility which are 

intended to be used for each part of the 

operating test; and 

(C) A description of the performance 

tests as part of the application. and the 

results of such tests. 

(ii) The Commission will approve a 

simulation facility if it finds that the 

simulation facility and its proposed use 

are suitable for the conduct of operating 

tests for the facility licensee's reference 

plant, in accordance with paragraph (a) 

of this section. 

(iii) Submit, every four years on the 

anniversary of the application. a report 

to the Commission which identifies any 

uncorrected performance test failures. 

and submit a schedule for correction of 

these performance test failures. if any. 

(iv) Retain the results of the 

performance test conducted until four 

years after the submittal of the 

application under paragraph (b}(4}{i), 

each report pursuant to paragraph 

(b)(4)(iii), or any reapplication under 

paragraph (b)(4}(iv) of this section. as 

appropriate. 

(v) If the Commission determines, 

based upon the results of performance 

testing. that an approved simulation 

facility does not meet the requirements 

of this part, the simulation facility may 

not be used to conduct operating tests. 

(vi) If the Commission determines, 

pursuant to paragraph (b)(4)(v) of this 

section, that an approved simulation 

facility does not meet the requirements 

of this part. the facility licensee may 

again submit an application for 

approval. This application must include 

a description of corrective actions taken, 

including results of completed 

performance testing as required for 

approval. 

(vii) Any application or report 

submitted pursuant to paragraphs 

(b)(4)(i), (b)(4)(iii) and (b)(4}(vi) of this 

section must include a description of the 

performance testing completed for the 

simulation facility, and must include a description of performance tests, if 

different, to be conducted on the 

simulation facility during the subsequent 

four-year period, and a schedule for the 

conduct of approximately 25 percent of 

the performance tests per year for the 

subsequent four years. 

(5) Certification of simulation 

facilities-Those facility licensees 

which propose, in accordance with 

paragraph (b)(l}(ii) of this section, to use 

a simulation facility consisting solely of 

a plant-referenced simulator as defined 

in I 55.4. shall-

(i) Submit a certification to the 

Commission that the simulation facility 

meets the Commission's regulations. The 

facility licensee shall provide this 

certification on Form NRC-474 in 

accordance with the schedule in 

paragraph (b)(2)(iii) or (b)(3)(iii) of this 

section, as applicable. 

(ii) Submit, every four years on the 

anniversary of the certification. a report 

to the Commission which identifies any 

uncorrected performance test failures, 

and submit a schedule for correction of 

such performance test failures. if any. 

(iii} Retain the results of the 

performance test conducted until four 

years after the submittal of certification 

under paragraph (b)(5)(i), each report 

pursuant to paragraph (b)(5)(ii), or 

recertification under paragraph (b}(5)(v} 

of this section, as applicable. 

(iv) If the Commission determines, 

based upon the results of performance 

testing, that a certified simulation 

facility does not meet the requirements 

of this part, the simulation facility may 

not be used to conduct operating tests. 

(v} If the Commission determines, 

pursuant to paragraph (b)(5)(iv) of this 

section, that a certified simulation 

facility does not meet the requirements 

of this part, the facility licensee may 

submit a recertification to the 

Commission on Form NRC-474. This 

recertification must include a 

description of corrective actions taken, 

including results of completed 

performance testing as required for 

recertifica lion. 

(vi) Any certification report, or 

recertification submitted pursuant to 

paragraph (b)(S)(i), (b)(5)(ii) or (b)(5)(v) 

of this section must include a 

description of performance testing 

completed for the simulation facility, 

and must include a description of the 

B-13 

performance tests, if different, to be 

conducted on the simulation facility 

during the subsequent four-year period, 

and a schedule for the conduct of 

approximately 25 percent of the 

performance tests per year for the 

subsequent four years. 

§ 55.47 Waiver of examination and test 

requirements. 

(a) On application. the Commission 

may waive any or all of the 

requirements for a written examination 

and operating test, if it finds that the 

applicant-

(1) Has had extensive actual operating 

experience at a comparable facility, as 

determined by the Commission, within 

two years before the date of application; 

(2) Has discharged his or her 

responsibilities competently and safely 

and is capable of continuing to do so; 

and 

(3) Has learned the operating 

procedures for and is qualified to 

operate competently and safely the 

facility designated in the application. 

(b) The Commission may accept as 

proof of the applicant's past 

performance a certification of an 

authorized representative of the facility 

licensee or of a holder of an 

authorization by which the applicant 

was previously employed. The 

certification must contain a description 

of the applicant's operating experience, 

including an approximate number of 

hours the applicant operated the 

controls of the facility, the duties 

performed, and the extent of the 

applicant's responsibility. 

(c) The Commission may accept as 

proof of the applicant's current 

qualifications a certification of an 

authorized representative of the facility 

licensee or of a holder of an 

authorization where the applicant's 

services will be utilized. 

§ 55.49 Integrity of examinations and 

teats. 

Applicants, licensees, and facility 

licensees shall not engage in any 

activity that compromises the integrity 

of any application, test. or examination 

required by this part. 

Subpart F-Llcenses 

§ 55.51 Issuance of licenses. 

Operator and senior operator 

licenses. If the Commission determines 

that an applicant for an operator license 

or a senior operator license meets the 

requirements of the Act and its 

regulations, it will issue a license in the 

form and containing any conditions ar.d 

limitations it considers appropriate and 

necessary 
9466 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 

§ 55.53 CondlUona of lk:enaea. 

Each license contains and is subject to 

the following conditions whether stated 

in the license or not: 

(a) Neither the license nor any right 

under the license may be assigned or 

otherwise transferred. 

(b) The license is limited to the facility 

for which it is issued. 

(c) The license is limited to those 

controls of the facility specified in the 

license. 

(d) The license is subject to, and the 

licensee shall observe. all applicable 

rules. regulations, and orders or the 

Commission. 

(e) If a licensee has not been actively 

performing the functions of an operator 

or senior operator, the licensee may not 

resume activities authorized by a license 

issued under this part except as 

permitted by paragraph (f) of this 

section. To maintain active status. the 

licensee shall actively perform the 

functions of an operator or senior 

operator on a minimwn of seven 8-hour 

or five 12-hour shifts per calendar 

quarter. For test and research reactors, 

the licensee shall actively perform the 

functions of an operator or senior 

operator for a minimum of four hours 

per calendar quarter. 

(f) If paragraph (e) of this section is 

not met, before resumption of functions 

authorized by a license issued under this 

part, an authorized representative of the 

facility licensee shall certify the 

following: 

(1) That the qualifications and status 

of the licensee are current and valid; 

and 

(2) That the licensee has completed a 

minimum of 40 hours of shift functions 

under the direction of an operator or 

senior operator as appropriate and in 

the position to which the individual will 

be assigned. The 40 hours must have 

included a complete tour of the plant 

and all required shift turnover 

procedures. For senior operators limited 

to fuel handling under paragraph (c) of 

this section, one shift must have been 

completed. For test and research 

reactors, a minimum of six houra must 

have been completed. 

(g) The licensee shall notify the 

Commission within 30 days about a 

conviction for a felony. · 

(h) The licensee shall complete a 

requalification program as described by 

§ 55.59. 

(i) The licensee shall have a biennial 

medical examination. 

(j) The licensee shall comply with any 

other conditions that the Commission 

may impose to protect health or to 

minimize danger to life or property. 

§ 55.55 Explr•tlon. 

(a) Each operator license and senior 

operator license expires six years after 

the date of issuance, upon termination 

of employment with the facility licensee, 

or upon determination by the facility 

licensee that the licensed individual no 

longer needs to maintain a license. 

(b) If a licensee files an application for 

renewal or an upgrade of an existing 

license on Form NRC-398 at least 30 

days before the expiration of the 

existing license, it does not expire until 

disposition of the application for 

renewal or for en upgraded license has 

been finally determined by the 

Commission. Filing by mail or telegram 

will be deemed to be complete at the 

time the application is deposited in the 

mail or with a telegraph company. 

§ 55.57 Renewal of lk:enaea. 

(a) The applicant for renewal of a 

license shall-

(1) Complete and sign Form NRC-398 

and include the number of the license 

for which renewal is sought. 

(2) File an original and two copies of 

Form NRC-398 with the appropriate 

Regional Administrator specified in 

§ 55.S(b). 

(3) Provide written evidence of the 

applicant's experience under the 

existing license end the approximate 

number of hours that the licensee has 

operated the facility. 

(4) Provide a statement by an 

authorized representative of the facility 

licensee that during the effective tenn of 

the current license the applicant baa 

satisfactorily completed the 

requalification program for the facility 

for which operator or senior operator 

license renewal is sought. 

(5) Provide evidence that the applicant 

has discharged the license 

responsibilities competently and safely. 

The Commission may accept as 

evidence of the applicant's having met 

this requirement a certificate of an 

authorized representative of the facility 

licensee or holder of an authorization by 

which the licensee has been employed. 

(6) Provide certification by the facility 

licensee of medical condition and 

general health on Form NRC-396. to 

comply with § § 55.21, 55.23 end 55~. 

(b) The license will be renewed if the 

Commission finds that-

(1) The medical condition and the 

general health of the licensee continue 

to be such as not to cause operational 

errors that endanger public health and 

safety. The Commission will base this 

finding upon the certification by the 

facility licensee as described in l 55.23. 

(2) The licenseeB-14 

(i) Is capable of continuing to 

competently and safely assume licensed 

duties; 

(ii) Has successfully completed a 

requalification program that hes been 

approved by the Commission as 

required by § 55.59; and 

(iii) Hes passed the requeliflcation 

examinations and annual operating tests 

as required by § 55.59. 

(iv) Has passed a comprehensive 

requalification written examination and 

operating test administered by the 

Commission during the term of a sixyear license. 

(3) There Is a continued need for a 

licensee to operate or for a senior 

operator to direct operators at the 

facility designated in the application. 

(4) The past performance of the 

licensee has been satisfactory to the 

Commission. In making its finding, the 

Commission will include in its 

evaluation infonnation such es notices 

of violations or letters of reprimand in 

the licensee's docket. 

t 55..59 RequallflcaUon. 

(a) Requalification requirements. 

Each licensee shall-

(1) Successfully complete a 

requelification program developed by 

the facility licensee that has been 

approved by the Commission. This 

program shall be conducted for a 

continuous period not to exceed 24 

months in duration. 

(2) Paaa a comprehensive 

requalification written examination end 

an annual operating test. 

(i) the written examination will 

sample the itema specified in H 55.41 

and SS.43 of thia part, to the extent 

applicable to the facility, the licensee, 

and any limitation of the license under 

I SS.53(c) of this part. 

(ii) The operating teat will require the 

operator or senior operator to 

demonstrate an undentanding of and 

the ability to perform the actions 

necesaacy to accomplish a 

comprehensive sample of items 

specified in I 55.45(e) (Z) throuRh (13) 

inclusive to the extent applicable to the 

facility. 

(iii) In lieu of the Commiaalon 

accepting a certification by the facility 

licemee that the licensee hes pasa~ 

written examinations and operating 

teats administered by the facility 

licensee within its Commissionepproved program developed by using a 

systems approach to training under 

paragraph (c) of this section, the 

Commission may administer a 

comprehensive requalification written 

examination and an annual operating 

teat. 
Federal Register / Vol. 52, No. 57 / Wednesday, March 25. 1987 / Rules and Regulations 9467 

(b) Additional training. If the 

requirements of paragraphs (a) (1) and 

(2) of this section are not met, the 

Commission may require the licensee to 

complete additional training and to 

submit evidence to the Commission of 

successful completion of this training 

before returning to licensed duties. 

(c) Requa/ificotion program 

requirements. A facility licensee shall 

have a requalification program reviewed 

and approved by the Commission. The 

requalification program must meet the 

requirements of paragraphs (c) (1) 

through (7) of this section. In lieu of 

paragraphs (c) (2), (3), and (4) of this 

section. the Commission may approve a 

program developed by using a systems 

approach to training. 

(1) Schedule. The requalification 

program must be conducted for a 

continuous period not to exceed two 

years. and upon conclusion must be 

promptly followed. pursuant to a 

continuous schedule, by successive 

requalification programs. 

(2) Lectures. The requalification 

program must include preplanned 

lectures on a regular and continuing 

basis throughout the license period in 

those areas where operator and senior 

operator written examinations and 

facility operating experience indicate 

that emphasis in scope and depth of 

coverage is needed in the following 

subjects: 

(i) Theory and principles of operation. 

(ii) General and specific plant 

operating characteristics. 

(iii) Plant instrumentation and control 

systems. 

(iv) Plant protection systems. 

(v) Engineered safety systems. 

(vi) Normal, abnormal. and emergency 

operating procedures. 

(vii) Radiation control and safety. 

(viii) Technical specifications. 

(ix) Applicable portions of Title 10, 

Chapter I. Code of Federal 

Regulations. 

(3) On-the-job training. The 

requalification program must include onthe-job training so that-

(i) Each licensed operator of a 

utilization facility manipulates the plant 

controls and each licensed senior 

operator either manipulates the controls 

or directs the activities of individuals 

during plant control manipulations 

during the term of the licensed 

operator's or senior operator's license. 

For reactor operators and senior 

operators. these manipulations must 

consist of the following control 

manipulations and plant evolutions if 

they are applicable to the plant design. 

Items described in paragraphs (c)(3)(i) 

(A) through (L) of this section must be 

performed annually; all other items must 

be performed on a two-year cycle. 

However, the requalification programs 

must contain a commitment that each 

individual shall perform or participate in 

a combination of reactivity control 

manipulations based on the availability 

of plant equipment and systems. Those 

control manipulations which are not 

performed at the plant may be 

performed on a simulator. The use of the 

Technical Specifications should be 

maximized during the simulator control 

manipulations. Senior operator licensees 

are credited with these activities if they 

direct control manipulations as they are 

performed. 

(A) Plant or reactor startups to include 

a range that reactivity feedback from 

nuclear heat addition is noticeable and 

heatup rate is established. 

(B) Plant shutdown. 

(C) Manual control of steam 

generators or feedwater or both during 

startup and shutdown. 

(D) Boration or dilution during power 

operation. . (E) Significant (;;.10 percent) power 

changes in manual rod control or 

recirculation flow. 

(F) Reactor power change of 10 

percent or greater where load change is 

performed with load limit control or 

where flux, temperature, or speed 

control is on manual (for HTGR). 

(G) Loss of coolant. including-

(1} Significant PWR steam generator 

leaks 

(2) Inside and outside primary 

containment 

(3) Large and small, including lead-rate 

determination 

(4) Saturated reactor coolant response 

(PWR). 

(H) Loss of instrument air (if 

simulated plant specific). 

(I) Loss of electrical power (or 

degraded power sources). 

(J) Loss of core coolant flow/natural 

circulation. 

(K) Loss of feedwater (normal and 

emergency). 

(L) Loss of service water, if required 

for safety. 

(M) Loss of shutdown cooling. 

(N) Loss of component cooling system 

or cooling to an individual component. 

(0) Loss of normal feedwater or 

normal feedwater system failure. 

(P) Loss of condenser vacuum. (Q) Loss of protective system channel. 

(R) Mispositioned control rod or rods 

(or rod drops). 

(S) Inability to drive control rods. 

(T) Conditions requiring use of 

emergency boration or standby liquid 

control system. 

(U) Fuel cladding failure or high 

activity in reactor coolant or offgas. 

B-15 

(V) Turbine or generator trip. 

(W) Malfunction of an automatic 

control system that affects reactivity. 

(X) Malfunction of reactor coolant 

pressure/volume control system. 

(Y) Reactor trip. 

(Z) Main steam line break (inside or 

outside containment). 

(AA) A nuclear instrumentation 

failure. 

(ii) Each licensed operator and senior 

operator has demonstrated satisfactory 

understanding of the operation of the 

apparatus and mechanisms associated 

with the control manipulations in 

paragraph (c)(3)(i) of this section, and 

knows the operating procedures in each 

area for which the operator or senior 

operator is licensed. 

(iii) Each licensed operator and senior 

operator is cognizant of facility design 

changes, procedure changes, and facility 

license changes. 

(iv) Each licensed operator and senior 

operator reviews the contents of all 

abnormal and emergency procedures on 

a regularly scheduled basis. 

(v) A simulator may be used in 

meeting the requirements of paragraphs 

(c) (3)(i) and (3)(ii) of this section, if it 

reproduces the general operating 

characteristics of the facility involved 

and the arrangement of the 

instrumentation and controls of the 

simulator is similar to that of the facility 

involved. If the simulator or simulation 

device is used to administer operating 

tests for a facility, as provided in § 55.45 

(b)(1), the device approved to meet the 

requirements of§ 55 45(b)(1) must be 

used for credit to be given for meeting 

the requirements of paragraphs (c)(3)(i) 

(G through AA) of this section. 

(4) Evaluation. The requalification 

program must include-

(i) Comprehensive requalification 

written examinations and annual 

operating tests which determine areas in 

which retraining is needed to upgrade 

licensed operator and senior operator 

knowledge. 

(ii) Written examinations which 

determine licensed operators' and senior 

operators' knowledge of subjects 

covered in the requalification program 

and provide a basis for evaluating their 

knowledge of abnormal and emergency 

procedures. 

(iii) Systematic observation and 

evaluation of the performance and 

competency of licensed operators and 

senior operators by supervisors and/ or 

training staff members. including 

evaluation of actions taken or to be 

taken during actual or simulated 

abnormal and emergency procedures. 

(iv) Simulation of emergency or 

abnormal conditions that may bP 
9468 Federal Register I Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 

accomplished by using the control panel 

of the facility involved or by using a , 

simulator. Where the control panel of 

the facility is used for simulation, the 

actions taken or to be taken for the 

emergency or abnonnal condition shall 

be discussed; actual manipulation of the 

plant controls is not required. If a 

simulator is used in meeting the 

requirements of paragraph (c}(4)(iii} of 

this section, it shall accurately 

reproduce the operating characteristics 

of the facility involved and the 

arrangement of the instrumentation and 

controls of the simulator shall closely 

parallel that of the facility involved. 

After the provisions of§ 55.45(b) have 

been implemented at a facility, the 

certified or approved simulation facility 

must be used to comply with this 

paragraph. 

(v) Provisions for each licensed 

operator and senior operator to 

participate in an accelerated 

requalification program where 

performance evaluations conducted 

pursuant to paragraphs (c){4) (i) through 

(iv) of this section clearly indicated the 

need. 

(5) Records. The requalification 

program documentation must include 

the following: 

(i) The facility licensee shall maintain 

records documenting the participation of 

each licensed operator and senior 

operator in the requalification program. 

The records must contain copies of 

written examinations administered. the 

answers given by the licensee, and the 

results of evaluations and 

documentation of operating tests and of 

any additional training administered in 

areas in which an operator or senior 

operator has exhibited deficiencies. The 

facility licensee shall retain these 

records until the operator'• or senior 

operator's license is renewed. 

{ii) Each record required by this part 

must be legible throughout the retention 

period specified by each Commisaion 

regulation. The record may be the 

original or a reproduced copy or a 

microfonn provided that the copy or 

microform is authenticated by 

authorized personnel and that the 

microform is capable of producing a 

clear copy throughout the required 

retention period. 

(iii) If there is a confiict between the 

Commission's regulations in this part. 

and any license condition. or other 

written Commission approval or 

authorization pertaining to the retention 

period for the same type of record. the 

retention period specified for these 

records by the regulations in this part 

apply unless the Commission. pursuant 

to § 55.11, grants a specific exemption 

from this record retention requirement. 

(6) Alternative training programs. The 

requirements of this section may be met 

by requalification programs conducted 

by persons other than the facility 

licensee if the requalification programs 

are similar to the program described in 

paragraphs (c) (1) through (5) of this 

section and the alternative program has 

been approved by the CommiHion. 

(7) Applicability to research and test 

reactor facilities. To accommodate 

specialized modes of operation and 

differences In control. equipment, and 

operator skills and knowledge, the 

requalification program for each 

licensed operator and senior operator of 

a research reactor or teat reactor facility 

must conform generally but need not be 

identical to the requalification program 

outlined in paragraphs (c} (1) through (6) 

of this section. Significant deviations 

from the requirements of paragraphs (c) 

(1) through (6) of this section will be 

permitted only if supported by written 

justification and approved by the 

Commission. 

Subpart G-Modlflcatlon and 

Revocation of Ucenses 

§ 55.11 Modification and revocation of 

Ileen .... 

(a) The terms and conditions of all 

licenses are subject to amendment, 

revision. or modification by reason of 

rules, regulations, or orders issued in 

accordance with the Act or any 

amendments thereto. 

(b) Any license may be revoked, 

suspended, or modified, in whole or in 

part: 

(1) For any material false statement in 

the application or in any statement of 

fact required under section 182 of the 

Act, 

(2) Because of conditions revealed bJ 

the application or statement of fact or 

any report. record, inspection or other means that would warrant the 

Commission to refute to grant a licenae on an original application, 

(3) For willful violation of, or failure to 

observe any of the tenns and conditions 

of the Act. or the license, or of any rule, 

regulation. or order of the CommiBSton, 

or 

(4) For any conduct determined by the· 

Commission to be a hazard to safe 

operation of the facility. 

Subpart H-Enforcement 

§ 55.71 Vlolatlons. 

(a) An injunction or other court order 

may be obtained prohibiting any 

B-16 

violation of any provision of: 

(1) The Atomic Energy Act of 1954, as amlmded: 

(2) Title II of the Energy 

Reorganization Act of 1974, as amended: 

or 

(3) Any regulation or order issued 

under these Acts. 

(b) A court order may be obtained for 

the payment of a civil penalty imposed 

under .ection 234 of the Aomic Energy 

Act for violation of: 

(1) Sections 53. 57, 62, 63, 61, 82, 101, 

103, 104, 107, or 109 of the Atomic 

Energy Act: 

(2) Section 206 of the Energy 

Reorganization Act of 1974; 

(3) Any rule, regulation, or order 

issued under these Acts; 

(4) Any term, condition, or limitation 

of any license iBSued under these Acts: 

or 

(5) For any violation for which a 

license may be revoked under section 

186 of the Atomic Energy Act. 

(c) Any person who willfully violates 

any provision of the Atomic Energy Ac:t 

or any regulation issued under the Act, 

including the regulations in this part, 

may be guilty of a crime and. upon 

conviction, may be punished by fine or 

imprisonment. or both. as provided by 

law. 

PART SO-OOMESTIC LICENSING OF 

PRODUCTION AND UTILIZATION 

FACILITIES 

2. The authority citation for Part SO 

continues to read aa follows: 

Authority: Secs. 103, 104. 161, 182. 183, 18&, 

189. 68 Stat. 938. 937, 941. 953, 954, 955, 956, 11 

amended, aec. 234, 83 Stat. 1244. .. amended 

(42 u.s.c. 2133, 2134. 2201. 2232. 2233, 2236. 

2239, %282); secs. 201, 202. 206, 88 Stat. 1242. 

1244.1246. as amended (42 U.S.C. 5841, 5842. 

5846), unleaa otberwi8e noted. 

Section 50.1 also !11ued under Pub, L. 95-

601, sec. 10, 92 Stat. 2951 (42 U.S,C. 58151). 

Sectiona 50.58, 50.91, and 50.92 also Issued 

under Pub. L. 9?-415, 96 Stat. 1.071, 20'13 (42 

U.S.C. 2133, 2239). Section 50.78 a!IO inaed 

under MC. 122. 88 Stat. 1139 (42 U.S.C. 2152). 

Sectiona 50.80-50.81 alao iaaued under MC. 

184.118 Stal 854. as amended (42 U.S.C. ZZM). 

Sections 50.100-50.102 also iHued under sec. 188. ea Stat. 955 {42 u.s.c. Z236). 

For the purposes of 1ec. Z23, 118 Stat. 958. as amended (4Z U.8.C. 2213), It 5CUO (a). (b), 

and (c). IOM, 50.48, 50.48. 90.M, and !I0.80(a) 

are iaaued under 1ec. llllb. 118 Stal 948. u 

amended (42 U.S.C. Z201(b)); It llO.tO(b) and 

(c) and 60.M are l11ued under 1ee. t81i, 118 

Stat. 949. aa amended (4Z U.S.C. 2201(i)); and 

H 50.ss(eJ, so.59(b), 50.70. so.71, 50.72. 50.73, 

and 50.78 are isaued under aec. 1610, 68 Stat. 

950. aa amended (42 U.S.C. 2201(0)). 

3. In l 50.34, paragraph {b)(8) is 

revised as follows: 
Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 I Rules and Regulations N69 

§ 50.34 Contents of applications; technfcal 

Information. 

* 

(b) * •• 

{8} A description and plans for 

implementation of an operator 

requalification program. The operator 

requalification program muat as a 

minimum, meet the requirements for 

those program• contained In I 55.59 of 

Part 55 of this chapter. 

• • • 

4. In I 50.54. paragraphs (i) and (1-1) 

are revised to read as follows: 

1 50.54 eor..:t1on1 or 1cen11 .. 

* • • • • 

(i) Except as provided in I 55.13 of 

this chapter, the licensee may not permit 

the manipulation of the controls of any 

facility by anyone who is not a licensed 

operator or senior operator as provided 

in Part 55 of this chapter. 

(i-1) Within three montha after 

issuance of an operating license, the 

licensee shall have in effect an operator 

requalification program which must Bl a 

minimum, meet the requirements of 

I 55.59(c) of thia chapter. 

Notwithstanding the provisions of 

I 50.59, the licensee may not, except as 

specifically authorized by the 

Commission decrease the scope of an 

approved operator requalification 

program. 

5. Immediately following I 50.73, 

"Licensee Event Report System," a new 

I 50.74 is added as a conforming 

amendment to read as follows: 

§ 50.74 Notification of change In operator 

or senior operator status. 

Each licensee shall notify the 

Commission in accordance with I 50.4 

within 30 days of the foli'owing in regard 

to a licensed operator or senior 

operator: 

(a) Permanent reassignment from the 

position for which the licensee has 

certified the need for a licensed operator 

or senior operator under § 55.31(a)(3) of 

this chapter; 

(b) Tennination of any operator or 

senior operator; 

(c) Disability or illness as descrided in 

I 55.25 of this chapter. 

Dated at Washington. DC. this 20\h day of 

March 1987. 

For the Nuclear Regulatory Commission 

John C. Hoyle, 

Act ins Secretory for the Commission 

(FR Doc. 87-6476 Filed 3-24-87; 8:4S amJ 

BIU.IMG CODE 7591H11-ll 

DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

14 CFR Part 39 

(Docket No. 88-NM-215-AD; Amdt. 39-

55181 

Alrworthlnffs DlrecUvn; Boeing 

Model 747 and 757 Series Airplanes 

AGENCY: Federal Aviation 

Administration {FAA), DOT, 

ACTION: Final rule. 

SUMMARY: This amendment adopts a 

new airworthiness directive (AD). 

applicable to Boeing Models 7'7 and 757 

series airplanes, which requires 

inspection of the passenger door 

emergency power reservoir for integrity 

of the pre1Sure relief rupture disk. 

repair, ii necessary, and replacement of 

defective diak retainers. This 

amendment is prompted by numeroua 

reports of emergency power reservoirs 

found to be prematurely discharged. 

This condition, if not corrected, would 

render the emergency power reservoir 

incapable of providing power to assist in 

opening the door quickly when required 

for emergency evacuation. 

DATES: Effective May 1, 1987. 

ADDRESSES: The applicable Boeing 

service information may be obtained 

from the Boeing Commercial Airplane 

Company, P.O. Box 3707, Seattle, 

Washington 98124; the applicable H.R. 

Textron service information may be 

obtained from H.R. Textron, Z5200 West 

Rye Canyon Road, Valencia, California 

91355. This information may be 

examined at the FAA. Northwest 

Mountain Region, 17900 Pacific Highway 

South. Seattle, Washington, or the 

Seattle Aircraft Certification Office, 

9010 East Marginal Way South. Seattle, 

Washingon 98168. 

FOR FURTHER INFORMATION CONTACT: 

Mr. Pliny Brestel, Airframe Branch. 

ANM-1208; telephone (206) 431-1931. 

Mailing address: FAA, Northwest 

Mountain Region, 17900 Pacific Highway 

South, C--eB966. Seattle, Washington 

98168. 

SUPPLEMENTARY INFORMATION: A 

propoaal to amend Part 39 of the Federal 

Aviation Regulations to include an 

airworthiness directive which requires 

inspection of the passenger door 

emergency power reservoir on Boeing 

Models 747 and 757 series airplanes for 

integrity of the pressure relief rupture 

disk, repair, if necessary. and 

replacement of defective disk retainers. 

was published in the Federal Register on 

December 24. 1986 (51 FR 46687). The 

comment period for the NPRM, which 

ended February 16, 1987, afforded 

B-17 

interested peraona an opportunity to 

participate in the making of this 

amendmeo.t. Due consideration has been 

given to the comments received. 

The Air Transport Association {ATA) 

of America. representing operators of 

Boeing Model ?•7 and 7S7 airplanea 

stated that the proposed rule requirill8 

inspection of all 747 and 757 airplanes is 

not justified for those operators whose 

records !wt the serial numbera and 

applicable ain:raft of the subject 

reservoin ln1talled.11te ATA. therefore, 

requested that paragraph A. of the 

proposed rule be deleted and that the 

effectivity be revised to read "Boeing: 

Applies to atl Model 747 and 757 series 

airplanes equipped with emergency 

power reservoirs listed in H.R. Textron 

Service Bulletin No. 8033()()-52-0S." The 

FAA agrees that it is unnecessary to 

inspect the airplanes if records are 

available to detennine the serial 

numbers of the reservoirs installed, and 

the AD has been revised accordingly; 

however. in absence of such records, 

operators must inspect for serial 

numbers in accordance with the 

applicable service bulletin. 

The ATA also commented that the 

"NOTE" in the proposed rule which 

advises readers that the affected 

reservoirs may be installed on other 

airplanes should be deleted because. if 

adopted, will create confusion in the 

field since the effectivity of the 

proposed rule is clearly only against 

Boeing aircraft. The FAA concurs that 

the effectivity is only Boeing aircraft and 

specifically Models 747 and 757; 

however, the "NOTE" should not be 

deleted because, while some Boeing 747 

and 757 aircraft may have been 

delivered without defective reservoirs. a 

defective reservoir could have been 

installed in the field since delivery. The 

note has been revised to reflect "Boeing 

Model 747 and 757 series airplanes." 

The ATA also requested that the 

initial compliance period in paragraph 

A. of the proposed rule be changed from 

60 to 90 days to afford those operators. 

who may not have records listing serial 

numbers of reservoirs, additional time lo 

complete the fleet inspection to 

determine if they are affected by the 

rule. The ATA stated that, in aome 

instances (likely 50%), the installed 

reservoirs would require removal to 

read the serial number. Further, some 

operators check the reservoirs every 

four days and, therefore. need time to 

change their maintenance program to 

comply with the daily check requirement 

of paragraph B. The FAA does not 

concur with an extension of the initial 

compliance period from 60 to 90 days in 

that air safety and public interest 

Appendix C 

Regulatory Guide.1.134 

Medical Evaluation of Licensed Personnel for Nuclear Power Plants 

C-1 

U.S. NUCLEAR REGULATORY COMMISSION 

Revision 2* 

April 1987 

REGULATORY GUIDE 

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 1.134 

(Task OL 401-5) 

IVIEDICAL EVALUATION OF LICEi\ISED PERSOl\INEL FOR NUCLEAR P0~11ER PLAi\lTS 

A. INTRODUCTION 

Sections 55 31, "How To Apply," and 55 57, "Renewal 

of Licenses," of 10 CFR Part 55, "Operators' Licenses," 

require that each initial or renewal application for an 

operator or senior operator license contain a medical 

examination certification following the form prescribed 

in Subpart C of Part 55, "Medical Requirements" Sections 5 5 3 3, "Disposition of Initial Application," and 

55 57 state that the initial or renewal applications for 

these licenses will be approved if, among other things, 

the applicant has no medical or general health condition 

that might cause operational errors endangering public 

health and safety Paragraph li) of § 55 S3, "Conditions 

of Licenses," requires that an examination be conducted 

every 2 years. 

Section 5 5 25, "Incapacitation Because of Disability 

or Illness," deals with an operator or senior operator 

who becomes incapacitated because of a mental or 

pnysical condition that might cause impaired judgment 

or"' motor coordination 

Section 55 27, "Documentation," requires that the 

facility licensee document and maintain the medical qualifications data, current test results, and each operator's 

medical history and provide these to the NRC upon its 

request 

This guide 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 operator or senior operator licenses 

for nuclear power plants and for providing notification to 

the NRC of an incapacitating disability or illness. 

*The substantial number of changes in this revision has made it 

impractical to indicate the changes with lines in the margin. 

USN RC REGULATORY GUIDES 

Regulatory Guides are issued to describe and make available to the public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech- niques used by the staff in evaluating specific problems or postu- lated accidents, or to provide guidance to applicants. Regulatory Guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the commission. 

This guide was issued after consideration of comments received from the public. Comments and suggestions for Improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new informa- tion or experience. 

Written comments may be submitted to the Rules and Procedures Branch, DR R, ADM, U.S. Nuclear Regulatory commission, 

Washington, DC 20555. 

The Advisory Committee on Reactor Safeguards has 

been consulted concerning this guide and has concurred in 

the regulatory position. 

Any information collection activities mentioned in this 

regulatory guide are contained as requirements in 1 O CFR 

Part S5, which provides the regulatory basis for this guide 

The information collection requirements in 10 CFR Part 5S 

have been cleared under OMB Clearance No 31S0-0018 

B. DISCUSSION 

Section 5S 23, "Certification," of Subpart C, "Medical 

Requirements," of 10 CFR Part S 5 requires that a physician 

examine the applicant in accordance with NRC's regulatory 

guidance and determine that the examinee's medical condition and general health meet the requirements for granting 

or renewing an operator license. The physician must send a 

full medical examination report to the facility licensee, 

which will then transmit a completed Form 396 to the 

N RC. The intent of these requirements is to have the facility 

licensee certify the health of its operators. However, the 

facility licensee is expected to maintain those records that 

may be reviewed by the NRC. Therefore, § SS.27 requires 

the facility licensee to document and maintain the full 

medical examination report, including the results of medical 

qualifications data, test results, and each operator's medical 

history In addition, § SS .27 requires the facility licensee 

to retain the most recent medical information as a result of 

the biennial physical examination and provide that information to the NRC on request The certification form would 

be sent by the facility licensee to the NRC 

There are two instances in which medical information 

must be sent to the NRC One is when a conditional license 

based on medical evidence is requested under the provisions 

of paragraph S5.33(b). The second instanc.e is when a licensed 

individual has become mentally or physically unable to 

The guides are issued in the following ten broad divisions: 

l. Power Reactors 6. Products 2. Research and Test Reactors 7. Transportation 3. Fuels and Materials Facilities 8. Occupational Health 4. Environmental and Siting 9. Antitrust and Financial Review 5. Materials and Plant Protection 10. General 

Copies of issued guides may be purchased from the Government 

Printing Office at the current GPO price. Information on current GPO Prices may be obtained by contacting the Superintendent of 

Documents, U.S. Government Printing Office, Post Office Box 37082, Washington, DC 20013-7082, telephone (202)275-2060 or (202)275-2171. 

Issued guides may also be purchased from the National Technical Information Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Rort Royal Road, 

Springfield, VA 22161. 
C-2 

perform job duties. In this case, the facility licensee 

must notify the NRC within 30 days after learning that 

the diagnosis has been made. The facility licensee must 

forward to the NRC Form 396 and medical records 

describing the disability. This related information is 

required by § SS 27 to be documented and maintained 

by the facility 

An American National Standard developed by the 

American Nuclear Society, ANSI/ANS-3.4-1983, "Medical 

Certification and Monitoring of Personnel Requiring 

Operator Licenses for Nuclear Power Plants,"1 prescribes 

minimum requirements necessary to determine that the 

medical condition and general health of nuclear reactor 

operators will not cause operational errors The criteria 

presented in this standard provide an examining physician 

a basis for determining whether a potentially disqualifying abnormal health condition exists. Establishing minimum health requirements should aid in more uniform 

medical evaluations. However, it is necessary to recognize 

that, although it is the physician's responsibility to 

identify and evaluate any potentially disqualifying 

medical conditions, NRC makes the final determination 

of the applicant's medical fitness. 

1 Copies may be obtained from the American N uc)e~ Society, 

SSS North Kensington Avenue, La Grange Park, lllinoJS 60525. 

Nothing in ANSI/ ANS-3 .4-1983 or this guide should 

be construed to mean that such matters as an individual's reading habits, political or religious beliefs, or 

attitudes on social, economic, or political issues should 

be investigated or judged. 

C. REGULATORY PQSITION 

The requirements contained in ANSI/ AN S-3 4-1983, 

"Medical Certification and Monitoring of Personnel 

Requiring Operator Licenses for Nuclear Power Plants,"' 

provide a method acceptable to the N RC staff for 

determining the medical qualifications of applicants for 

initial or renewal operator or senior operator licenses. 

D. IMPLEMENTATION 

The purpose of this section is to provide information 

to applicants and licensees about the staff's plans for 

using this regulatory guide. 

Except in those cases in which the licensee proposes 

an acceptable alternative method for complying with 

specified portions of the Commission's regulations, the 

methods described in the guide will be used in evaluating the part of an application for initial or renewal operator or senior operator licenses on NRC Form 396, "Certificate of Medical Examination by Facility Licensee." 

1.134-2 
C-3 

VALUE/IMPACT ANALYSIS 

A separate value/impact analysis has not been prepared for this regulatory guide. A value/impact analysis 

was included in the regulatory analysis for the amendments to 10 CFR Part S 5 published on March 25, 1987, 

a copy of which was placed in the Public Document 

Room at that time. This analysis is also appropriate 

to Revision 2 of Regulatory Guide 1.134. A copy of 

the regulatory analysis is available for inspection and 

copying for a fee at the NRC Public Document Room, 

171 7 H Street NW., Washington, DC. 

1 134-3 

Appendix D 

Regulatory Guide 1.149 

Nuclear Power Plant Simulation Facilities for Use in Operator 

License Examinations 

D-1 

U.S. NUCLEAR REGULATORY COMMISSION 

Revision 1* 

April 1987 

REGULATORY GUIDE 

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 1.149 

(Task OL 402·5) 

NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE 

IN OPERATOR LICENSE EXAMINATIONS 

A. INTRODUCTION 

Paragraph SS.4S(a) of 10 CFR Part SS, "Operators' 

Licenses," requires that an applicant for an operator or 

senior operator license demonstrate both an ~nderstanding of and ihe ability to perform certain essential job 

tasks. Paragraph SS 4S(b) specifies that these operating 

tests will be administered, in part, either in a simulation 

facility consisting solely of a plant-referenced simulator 

that has been certified to the Commission by the 

facility licensee or in a simulation facility approved by 

the Commission after application has been made by the 

facility licensee. 1 

This regulatory guide describes a method ~cceptable 

to the NRC' staff for complying with those portions of 

the Commission's regulations regarding (1) certification 

of a simulation facility consisting solely of a plant· 

referenced simulator and (2) application for prior approval of a simulation facility 

1he Advisory Committee on Reactor Safeguards has 

been consulted concerning this guide and has concurred 

in the regulatory position 

Any information collection activities mentioned in 

this regulatory guide are contained as requirements in 

those sections of 10 CFR Part SS that provide the 

regulatory basis for this guide. The information collection requirements in 10 CFR Part SS have been cleared 

under Clearance No. 3150-0018 and No 31SO-Ol38. 

• The substantial number of changes in this revision has made it 

impractical to indicate the changes with lines in the margin. 

1 A simulation facility is defined in § 5 5 .4 as one or more of the 

following components, alone or in combination, used for the partial 

conduct of operating tests for operators, senior operators1 and candidates: (i) the plant, (ii) a plant-referenced simulator, (Iii) another 

simulation device. 

USNRC REGULATORY GUIDES 

Regulatory Guides are issued to describe and make available to the 

public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate tech· 

niques used by the staff in evaluating specific problems or postu- lated accidents, or to provide guidance to applicants. Regulatory Guides are not substitutes for regulations, and compliance with 

them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the 

findings requisite to the issuance or continuance of a permit or license by the Commission. 

This guide was issued after consideration of comments received from 

the public. comments and suggestions for improvements In these 

guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new Informa- tion or experience. 

Written comments may be submitted to the Rules and Procedures 

Branch, DR R, ADM, U.S. Nuclear Regulatory Commission, 

Washington, DC 20555. 

B. DISCUSSION 

Although ensuring that individuals who receive operator or senior operator licenses possess the knowledge, 

skills, and abilities necessary to operate the facility in a 

safe manner is the responsibility of facility licensees, the 

Nuclear Regulatory Commission must perform an independent audit of this process through its operawr 

licensing examinations. Section S5.45, "Operating Tests," 

of l 0 CFR Part 5 5 requires the candidate for a license 

to demonstrate ( l) an understanding of and the ability 

to perform the actions necessary during normal, abnormal, and emergency situations, (2) the operation of 

systems that affect heat removal or reactivity changes, 

and (3) behaviors that show the individual's ability to 

function within the control room team in such a way 

that the facility licensee's procedures are adhered to and 

that the limitations in its license and amendments are 

not violated 

The use of a plant-referenced simulator for testing 

enables the examiner to evaluate a candidate's performance in an environment closely correlated with conditions in the specific plant for which that candidate has 

applied for a license With major facility differences 

minimized between the testing and operating environments, examiners have been able to make pass-fail 

judgments with confidence 

Although the increased use of plant-referenced simulators has provided to examiners the capability for 

better discrimination between success and failure in a 

candidate than could be achieved with non-plantreferenced simulators, the staff recognizes the existence 

of several factors that could suggest the use of alternative systems or devices for conducting the nonwalkthrough portions of operating tests These factors 

The guides are issued In the following ten broad divisions: 

l. Power Reactors 6. Products 

2. Research and Test Reactors 7. Transportation 3. Fuels and Materials Facilities 8. Occupational Health 

4. Environmental and Siting 9. Antitrust and Financial Review 

5. Materials and Plant Protection 10. General 

Copies of issued guides may be purchased from the Government 

Printing Office at the current GPO price. Information on current GPO prices may be obtained by contacting the Superintendent of 

Documents, U.S. Government Printing Office, Post Office Box 

37082, Washington, DC 20013-7082, telephone (202)275-2060 or (202)275-2171. 

Issued guides may also be purchased from the National Technical Information Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 P.ort Royal Road, 

Springfield, VA 22161. 
D-2 

,.nclude the cost and lead time associated with procurement or upgrading of a plant-referenced simulator. Moreover, rapidly changing technology in the simulation industry is resulting in previously unavailable options that 

could Ir.ad a facility licensee to seek alternative ways to 

meet the requirements of §55.45. ANSI/ANS-3.5-1985, 

"Nuclear Power Plant Simulators for Use in Operator 

Training"2 (the standard), in conjunction with this 

regulatory guide, provides guidance in these areas. 

C. REGULATORY POSITION 

Requirements are set forth in ANSI/ANS-3.5-1985 for 

specifying minimum performance and configuration criteria for a simulator, for comparing a simulator to its 

reference plant, and for upgrading simulators to 1eflect 

changes to reference plant response or control room 

configuration These requirements provide a method 

acceptable to the NRC staff for a facility licensee (1) to 

certify a simulation facility consisting solely of a plantreferenced simulator or (2) to obtain approval of a 

simulation facility for use in portions of reactor operator and senior operator license examinations subject to 

the following: 

1. The references to operator training in Section 1, 

"Scope," of the standard should be taken to apply to 

operating tests for operators, senior operators, and 

candidates 

2. Simulation facilities as defined in § 55.4 of 10 CFR 

Part 55, to the extent that the facility licensee applies 

for approval under the requirements of paragraph 55.45(b), 

should meet the applicable requirements of the standard. 

3. The standard identifies in Section 1.1, "Background," 

other documents to be included as part of the standard 

The applicability of one of these documents, ANSI/ 

ANS-3.1, 2 should be determined by referring to Revision 2 to Regulatory Guide 1 8, "Qualification and 

Training of Personnel for Nuclear Power Plants." 

4. Section 5.2, "Simulator Update Design Data," requires that reference plant modifications be reviewed 

annually against the simulator and that the simulator 

update design data be revised as appropriate. This 

should be taken to mean that the first such annual 

review and update should take place within one year 

following the facility licensee's certification as specified 

in paragraph 55.45(b)(5)(i) or within 18 months following the submittal of the application for approval as 

specified in paragraph 55 45(b)(4)(i). 

5. Section 5.4, "Simulator Testing," requires the conduct of specific tests to establish simulator performance 

and verify its operability. In addition to these procedures, applicable malfunctions, identified in Section 

3.1.2, "Plant Malfunctions," should be periodically tested 

2copies may be obtained from the American Nuclear Society, 

SSS North Kensington Avenue, La Grange Park, IL 6052S. 

to ensure the continued acceptability of the simulation 

facility. These malfunctions, if applicable to the facility, 

should be tested in their entirety not less than every 

four years, approximately 25% per year. When conducted in addition to the tests required by Section 5.4 

and when subjected to the performance criteria for 

transient operations specified in Section 4.2, "Transient 

Operation," these malfunction tests provide an acceptable means of demonstrating the performance and 

operability of the simulation facility. 

6 Appendix A to the standard, "Guide for Documenting Simulator Performance," and Appendix B to the 

standard, "Simulator Operability Tests," should be considered integral parts of the standard. 

D. IMPLEMENTATION 

The purpose of this section is to provide information 

to facility licensees about the NRC staff's plans for using 

this regulatory guide. 

In accordance with the requirements in §55.45 of 

10 CFR Part 55, the simulation facility portion of the 

operating test will not be administered on other than an 

approved or a certified simulation facility after: 

1. The facility licensee has submitted a certification 

in accordance with paragraph 55.45(b)(5)(i), or 

2. The staff has approved an application submitted 

by the facility licensee in accordance with paragraph 

55.45(b)(4), or 

3. May 28, 1991, whichever occurs sooner. 

Until that time, the NRC will continue to give examinations for a facility licensee's reference plant in accordance with Generic Letter 8 2-18, "Reactor Operator and 

Senior Reactor Operator Requalification Examinations," 3 

October 12, 1982. 

Licensees and applicants may propose means other 

than those specified in Section C of this guide for meeting 

applicable regulations. Except in those cases in which a 

facility licensee submits a certification for its simulation 

facility or proposes an acceptable alternative method for 

complying with specified portions of the Commission's 

regulations, the NRC will use the method described in 

this guide in the evaluation of the application for 

approval submitted by the facility licensee for its simulation facility. The guidance provided in Section C has 

been approved for use by the staff in the evaluation of 

all submittals as an acceptable means of complying with 

the Commission's regulations specified in Section A. 

If a facility licensee wishes to utilize a simulation 

facility for more than one nuclear power plant, it must 

3 Available for copying for a fee or inspection at the NRC 

Public Document Room, 1717 H Street NW., Washington, DC. 

l.149-2 
D-3 

demonstrate to the NRC in its certification or in its 

application that the differences between the plants are 

not so significant that they have an impact on the 

ability of the simulation facility to meet the requirements and guidance of ANSI/ ANS-3.5-1985 as qualified 

in this regulatory guide for each of the plants. This 

demonstration should include an analysis and summary 

of the differences between each plant and the simulation facility, including: 

Facility design and systems relevant to control 

room personnel; 

2. Technical specifications; 

3. Procedures, primarily abnormal and emergency 

operating procedures; 

4. Control room design and instrument/control location; and 

5. Operational characteristics. 

l 149-3 
0-4 

VALUE/IMPACT ANAL VSIS 

A separate value/impact analysis has not been prepared for this regulatory guide. A value/impact analysis 

was included in the regulatory analysis for the amendments to 10 CFR Part 55 published on March 25, 1987, 

a copy of which was placed in the Public Document 

Room at that time. This analysis is also appropriate to 

Revision 1 of Regulatory Guide 1.149. A copy of the 

regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room, 

1717 H Street NW., Washington, DC. 

1.149-4 
Appendix F 

Regulatory Guide 1.8 

Qualification and Training of Personnel for Nuclear Power Plants 

E-1 

U.S. NUCLEAR REGULATORY COMMISSION 

Revision 2* 

April 1987 

REGULATORY GUIDE 

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 1.8 

(Task OL 403-5) 

QUALIFICATIOl\I AMJ TRAINING OF PERSONl\IEL FOR l\IUCLEAR POWER PLANTS 

A. INTRODUCTION 

Paragraph S0.34(b)(6)(i) of 10 CFR Part SO, "Domestic 

Licensing of Production and Utilization Facilities," requires 

that an application for a license to operate a nuclear 

power plant include information concerning organizational 

structure, personnel qualifications, and related matters. 

Subpart D, "Applications," of 10 CFR Part SS, "Operators' 

Licenses," requires that operator license applications 

include information concerning an individual's education 

and experience and related matters. This regulatory guide 

describes a method acceptable to the NRC staff for 

complying with those portions of the Commission's 

regulations with regard to the training and qualifications 

of nuclear power plant personnel. Personnel of test, 

training, research, and mobile reactors are not covered 

by this regulatory guide. 

The Advisory Committee on Reactor Safeguards has 

been consulted concerning this guide and has concurred 

in the regulatory position. 

Any information collection activities mentioned in 

this regulatory guide are contained as requirements in 

10 CFR Parts 50 and 5S, which provide the regulatory 

basis for this guide. The information collection requirements in 10 CFR Part SO have been approved under 

OMB Clearance No. 3150-011, those in 10 CFR Part 

55, under OMB Clearance No. 3150-0018. 

B. DISCUSSION 

Subcommittee ANS-3, Reactor Operations, American 

Nuclear Society Standards Committee, developed a 

standard containing criteria for the qualification and 

• The substantial number of changes in this revision has made it 

impractical to indicate the changes with lines in the margin. 

USN RC REGULATORY GUIDES 

Regulatory Guides are issued to describe and make available to the 

public methods acceptable to the N RC staff of Implementing specific parts of the Commission's regulations, to delineate techniques used by the staff in evaluating specific problems or postu- lated accidents, or to provide guidance to applicants. Regulatory Guides are not substitutes for regulations, and compliance with 

them Is not required. Methods and solutions different from those set out In the guides will be acceptable If they provide a basis for the 

findings requisite to the Issuance or continuance of a permit or 

license by the Commission. 

This guide was Issued after conslderatl.on of comments received from 

the public. Comments and suggestions for Improvements In these 

guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new lnforma· 

tlon or experience. 

Written comments may be submitted to the Rules and Procedures 

Branch, ORR, ADM, u.s. Nuclear Regulatory Commission, 

Washington, DC 20555. 

training of nuclear power plant personnel. This standard 

was approved by the American National Standards 

Institute (ANSI) Committee N 18, Design Criteria for 

Nuclear Power Plants, and designated ANSI Nl8. l-1971, 

"Selection and Training of Nuclear Power Plant Personnel." Regulatory Guide 1.8, "Personnel Selection and 

Training," endorsing ANSI N 18.1-1971, was issued in 

March 1971, and Revision 1 was issued in September 

1975. A revision of ANSI Nl8.l-1971 was subsequently 

approved by the ANSI Board of Standards Review and 

designated ANSI/ANS-3.1-1978, "Selection and Training 

of Nuclear Power Plant Personnel." 

A first proposed Revision 2 to Regulatory Guide 1.8 

endorsing ANSl/ANS-3.1-1978 was issued for public 

comment in February 1979. As a result of experience 

gained from the accident at Three Mile Island Unit 2 

(TMI-2), additional public comments in the area of 

personnel qualifications were requested on proposed 

Revision 2 to Regulatory Guide 1.8 in May 1979. All 

of the comments from both requests were forwarded to 

the ANS-3 Subcommittee for its use during the development of a revision to ANSl/ANS-3.1-1978. Subsequently, Draft Standard ANS 3.1, dated December 6, 1979, 

incorporating the upgraded requirements was issued. In 

September 1980, public comments were requested on a 

second proposed Revision 2 to Regulatory Guide 1.8 

that endorsed Draft Standard ANS 3.1. The public 

comments received were held in abeyance pending 

Commission action on proposed rules on operator 

qualifications and licensing in SECY 81-84, "Qualification of Reactor Operators," 1 February 2, 1981, and 

SECY 8 l-84A, "Discussion of Revisions to Reactor 

Operator Qualifications," 1 June 15, 1981. The Commission did not approve either of these proposals and 

directed the staff to continue to study the issue . 

1 

Cop~es are available for inspection or copying for a fee in the 

NRC Public Document Room, 1 71 7 H Street NW., Washington, DC. 

The guides are Issued In the following ten broad divisions: 

1. Power Reactors 6. Products 2. Research and Test Reactors 

3. Fuels and Materials Facilities 4. Environmental and Siting 

7. Transportation 8. Occupational Health 

9. Antitrust and Financial Review 

5. Materials and Plant Protection 10. General 

Coples of Issued guides may be purchased from the Government 

Printing Office at the current GPO price. Information on current GPO prices may be obtained by contacting the Superintendent of 

Documents, U.S. Government Printing Office, Post Office Box 

r;g: ~~\h~~~ton, DC 20013·7082, telephone (202)275-2060 or 

Issued guides may also be purchased from the National Technical 

Information service on a standing order basis. Details on this 

service may be obtained by writing NTIS, 5285 Flort Royal Road 

Springfield, VA 22161. ' 
E-2 

During 1981, Draft Standard ANS 3.1 was updated to 

factor in additional lessons learned from the TMl-2 

accident and changing regulatory requirements. The 

standard was approved by the American Nuclear Society's 

Nuclear Power Plant Standards Committee (NUPPSCO) 

and the ANSI Board of Standards Review and was 

reissued as ANSI/ANS-3.1-1981, "Selection, Qualification 

and Training of Personnel for Nuclear Power Plants."2 A 

third proposed Revision 2 of Regulatory Guide 1.8 was 

developed to endorse ANSl/ANS-3.1-1981 with certain 

additions and exceptions and was issued for public comment in January 1985. As a result of the public comments and Commission actions concerning training and 

qualifications, this Revision 2 of Regulatory Guide 1.8 

now endorses Sections 4 3.1.1, "Shift Supervisor," 4.3.1.2, 

"Senior Operator," 4.5.1.2, "Licensed Operators," 4.4.8, 

"Shift Technical Advisor," and 4.4.4, "Radiation Protection," of ANSI/ANS-3.1-1981. Endorsement for all other 

positions will remain with ANSI N18.1-1971, "Selection 

and Training of Nuclear Power Plant Personnel." The 

bases for the additions and exceptions to ANSI/ANS-3.1-

1981 are contained in NUREG-0737, "Clarification of 

TMI Action Plan Requirements," 3 which includes the 

March 28, 1980 letter to all power reactor applicants 

and licensees regarding qualification of reactor operators, 

and NUREG-0094, "Guide for the Licensing of Facility 

Operators, Including Senior Operators,"3 and the Commission's "Policy Statement on Engineering Expertise on 

Shift" (50 FR 43621 ). The regulatory position related 

to the radiation protection manager is revised from what 

was included in Revision 1 of Regulatory Guide 1.8 (1975). 

The industry has adopted the requisite qualifications in 

ANSI/ ANS 3 1-1981, and the current change endorses 

that industry position. 

On March 20, 1985, the Commission issued a "Policy 

Statement on Training and Qualification of Nuclear 

Power Plant Personnel" (50 FR 11147) that recognizes industry commitment to accredit training programs. In the policy statement, the NRC endorsed the 

training accreditation program managed by the Institute 

of Nuclear Power Operations (INPO) because it encompasses the elements of performance-based training and 

will provide the basis to ensure that personnel have 

qualifications commensurate with the performance requirements of their jobs. The Commission has decided 

to withhold action on promulgating new training and 

qualifications regulations during an evaluation period. 

During that period, NRC will continue to evaluate the 

results of the accreditation program to determine if the 

voluntary industry efforts ensure qualifications that meet 

or exceed the minimum standards included in this guide. 

The Commission's "Policy Statement on Engineering 

Expertise on Shift" issued on October 28, 1985 (50 FR 

43621) provides two options for meeting nuclear power 

plant staffing requirements (paragraph 50.54(m)(2)(i) of 

2Copies may be obtained from the American Nuclear Society, 

555 North Kensington Avenue, LaGrange Park, IL 60525. 

3copies may be obtained from the Government Printing Office, 

Post Office Box 37082, Washington, DC 20013-7082. 

10 CFR Part 50) and the requirement to have a shift 

technical advisor (STA) available to the shift (NUREG073 7, I.A. I. I). One option in the Policy Statement, 

which is preferred by the Commission, allows combining 

the functions of the ST A with one of the required senior 

operators as long as specific training and education 

requirements are met. The other option allows for continuation of an approved independent STA program. 

Regulatory Position C. l .j reflects the guidance provided 

in this Policy Statement 

C. REGULATORY POSITION 

I. Positions in ANSI/ANS-3.1-1981 that Are Endorsed 

by this Regulatory Guide 

For the positions listed in ANSl/ANS-3.1-1981, 

"Selection, Qualification and Training of Personnel for 

Nuclear Power Plants," as shift supervisor, senior operator, licensed operator, and shift technical advisor, the 

requirements contained in the standard provide an 

approach acceptable to the NRC staff for complying with 

the qualifications and training requirements of 10 CFR 

Parts 50 and 55 subject to the guidance regarding the 

ST A function provided in the Commission's "Policy 

Statement on Engineering Expertise on Shift" and the 

clarifications, additions, and exceptions in paragraphs a 

through k below. For radiation protection supervisory 

personnel, Section 4.4.4 of the standard contains an 

approach acceptable for the position of radiation protection manager (RPM) subject to the following 

a. In lieu of the description in Section 5.1 of ANSI/ 

ANS-3 1-1981, cold license examinations should be defined 

as those that are administered before the unit has completed preoperational testing and initial operations as 

described in its Final Safety Analysis Report as amended 

and approved by the Commission. Hot examinations are 

those administered after this condition is attained. 

1.8-2 

b. Hot license applicants must meet the training 

elements in Sections 4.3.1.1.c, 4.3.1.2.c, and 4.5.1.2.c of 

the standard and the experience elements in Sections 

4.3.l.1.b, 4.3.1.2.b, and 4.5.1.2.b of the standard. Cold 

license applicants are subject to the training elements 

identified above, but they are exempt from the experience elements. 

c. Paragraph 2 of Section 4.3.1. l.a of ANSI/ANS-3.1-

1981 is not applicable. An individual who meets the 

Commission's "Policy Statement on Engineering Expertise 

on Shift" is required on all shifts to provide engineering 

expertise (see Regulatory Position C. l .j). 

d. The minimum educational requirement for shift 

supervisors, Section 4.3.1.1.a, and for senior operators, 

Section 4.3.1. 2.a, is a high school diploma or equivalent. 

e An applicant for a senior operator (SO) license 

should have 4 years of responsible power plant experience. Responsible power plant experience for an SO is 

defined as having actively performed as a designated 
E-3 

control room operator (fossil or nuclear) or as a power 

plant staff engineer involved in the day-to-day activities 

of the facility during or after the final year of construction. A maximum of 2 years of responsible power plant 

experience may be fulfilled by academic or related technical training on a one-for-one time basis. Two years should 

be nuclear power plant experience. At least 6 months of 

the nuclear power plant experience should be at the 

plant for which an applicant seeks a license In addition, 

applicants for an SO position not holding a bachelor's 

degree in engineering or equivalent should have held an 

operator's license and should have been actively involved 

in the performance of licensed duties for at least 1 year. 

f In addition to the requirements stated in Section 

5 2 121 of ANSI/ANS-3 1-1981, classroom instruction 

for all license applicants should include training in the 

use of installed plant systems for the control and mitigation of an accident in which the core is severely damaged. 

g ln addition to the requirements in Section 5.2 1.3.1 

of ANSI/ANS-3 1-1981, each applicant for an operator or 

senior operator license should serve 3 months as an extra 

person on shift in training for that position. These 3 

months as an extra person on shift in training should 

include all phases of day-to-day operations under the 

supervision of licensed personnel. 

h Control room operating experience for hot license 

applicants, described in Section 5 2.1.3 1 of ANSI/ ANS3 1-1981, should include manipulation of controls of the 

facility during a minimum of five reactivity changes. Every 

effort should be made to have a diversity of reactivity 

changes for each applicant Startups, shutdowns, large load 

changes, and changes in rod programming are some examples and could be accomplished by manually using such 

systems as rod control, chemical shim control, or recirculation flow 

i All cold license applicants should participate in 

practical work assignments as described in Section 5.2 1.4 

of ANSI/ANS-3 1-1981 for a minimum of 6 months. 

j In addition to the responsibilities described in Section 4.4 8 of ANSI/ANS-3.1-1981, the STA should assume 

an active role in shift activities. For example, the ST A 

should review plant logs, participate in shift turnover, 

and maintain awareness of plant configuration and status. 

The educational requirements for the ST A specified in 

Section 4 4 8.a of ANSl/ANS-3.1-1981 are not applicable An independent ST A should have a bachelor's 

degree or equivalent in a scientific or engineering discipline 

"Actively performing ST A functions" means performing at least three shifts per quarter as the ST A. If an 

1.8-3 

ST A has not actively performed, the ST A should receive 

training sufficient to. ensure that the ST A is cognizant of 

facility and procedure changes that occurred during the 

absence. 

Combining the functions of a senior operator and the 

ST A is acceptable if the provisions of the Commission's 

"Policy Statement on Engineering Expertise on Shift" 

are met. In addition to the requirements specified in 

Section 4.4.8.c of ANSI/ANS-3.1-1981, the STA should 

have specific training in the response to and analysis of 

plant transients and accidents and training in the relationship of accident conditions to offsite consequences 

and protective action strategies. 

k. The radiation protection manager should have the 

qualifications described in Section 4.4.4 of ANSI/ ANS3.1-1981 with the clarification that 3 of the 4 years of 

experience in applied radiation protection should be 

professional-level experience. 

2. Positions in ANSI/ANS Nl8.l-1971 that Are Endorsed 

by this Re!,'Ulatory Guide 

For positions listed in the standard other than those 

under Regulatory Position 1 above, the requirements contained in ANSI Nl8.l-1971, "Selection and Training of 

Nuclear Power Plant Personnel," provide an approach 

acceptable to the NRC staff for complying with the qualifications and training requirements of 10 CFR Parts 50 

and 55. 

O. IMPLEMENTATION 

The purpose of this section is to provide information 

to applicants and licensees regarding the NRC staff's 

plans for using this regulatory guide. 

Applicants and licensees may propose means other 

than those specified in Section C of this guide for meeting applicable regulations 

Except in those cases in which the applicant or licensee 

proposes an acceptable alternative means of complying 

with the Commission's regulations specified in Section A, 

the guidance provided in Section C has been approved 

for use by the staff after March 31, 1988, in the evaluation of the qualifications and training requirements for 

(1) nuclear power plant personnel as described in applications for an operating license, (2) applicants for operator and senior operator licenses, and (3) replacement 

personnel in those positions in operating nuclear power 

plants whose training programs have not yet been accredited by an accreditation program endorsed by the NRC. 
E-4 

VALUE/IMPACT ANALYSIS 

A separate value/impact analysis has not been prepared 

for this regulatory guide. A value/impact analysis was 

included in the regulatory analysis for the amendments to 

10 CFR Part 55 published on March 25, 1987, a copy 

of which was placed in the Public Document Room at 

1.8-4 

that time. This analysis is also appropriate to Revision 2 

of Regulatory Guide 1.8. A copy of the· regulatory analysis is available for inspection and copying for a fee at 

the NRC Public Document Room, 171 7 H Street NW., 

Washington, DC. 
NRC FORM 335 

12 841 

US NUCLEAR REGULATORY COMMISSION 1 REPORT NUMBER (Assigned b~ TIDC add Vol No, if any) 

NACM 1102, 

3201, 3202 BIBLIOGRAPHIC DATA SHEET 

SEE INSTRUCTIONS ON THE REVERSE NUREG-12 6 2 ~~~~~~~~~~~~~~~~~~~~~~-f.___;..:....:....~~~....::....::=--~~~~-- ~~~-~ 

2 TITLE AND SU8TITLE , , . • 3 LEAVE BLANK 

Answers to Questions at Public Meetings Regarding 

Implementation of Title 10, Code of Federal Regulations, 

Part 55 on Operators' Licenses 

S AUTHOAISI 

7 PEA FOAMING ORGANIZATION NAME AND MAILING ADDRESS (Include z,P Code} 

Division of Licensee Performance and Quality Evaluation 

Office of Nuclear Reactor Regulation 

U. S. Nuclear Regulatory Commission 

Washington, DC 20555 

10 SPONSORING ORGANIZATION NAME AND MAILING AD?RESS (Include Z,p Code) 

Division of Licensee Performance and Quality Evaluation 

Office of Nuclear Reactor Regulation 

U. S. Nuclear Regulatory Commission 

Washington, DC 20555 

12 SUPPLEMENTARY NOTES 

13 ABSTRACT (200 words or lt1Ss) 

4 DATE REPORT COMPLETED 

MONTH YEAR 

November 1987 t--~~~~~6-0-AT~E~R~EP~O-R~Tl~SS~U~EO~~~~~ 

MONTH YEAR 

November 1987 

8 PROJECT/TASK/WORK UNIT NUMBER 

11a TYPE OF REPOA~ 

Question and Answer 

b PERIOD COVER ED (Inclusive dates) 

This document presents questions and answers based on the transcripts of four publir 

meetings (and from written questions submitted after the meetings) conducted from 

April 9 to April 20, 1987 by the staff of the U. S. Nuclear Regulatory Co~mission. The 

meetings discussed implementation of the Commission's final rule governinq Ooerators' 

Licenses and Conforming Amendments (10 CFR Parts 55 and 50), The rule became effective 

May 26, 1987 and is intended to clarify the regulations for issuing licenses to operators 

and senior operators; revise the requirements and scope of written examinations and 

operating tests for operators and senior operators, including a requirement for a 

simulation facility; clarify procedures for administering requalification examinations: 

and describe the form and content for operator license applications. · 

14 DOCUMENT ANALYSIS - , KEYWORDS/DESCRIPTORS 

Nuclear Power 

b IDENTIFIERS/OPEN ENDED TEAMS 

Operator Licenses 

10 CFR Parts 50 and 55 

Simulation Facilities 

Requalification Examinations 

*U,S.GOVERNMENT PRINTING OFFICE:1987-202-292:60299 

15 .\VAILAS!i___!TY 

~ i ATE.tv1ENT 

Unlimited 

16 SECURIT'I CLASSIFICATION -- (This p•geJ 

(This =------- r~port) 

17 NUMBER OF PAGES 

~18=-="PR-IC~E~--~-·~