Information Notice 1998-37, Eligibility of Operator License Applicants
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
October 1, 1998
NRC INFORMATION NOTICE 98-37: ELIGIBILITY OF OPERATOR LICENSE APPLICANTS
Addresses
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
Purp ose
The U. S. Nuclear Regulatory Commission (NRC) Is issuing this information notice to remind
addressees that the eligibility requirements for applying for an operator license have not
changed since 10 CFR Part 55 was amended in 1987. Recently, the NRC staff denied some
applications for senior reactor operator licenses because the applicants did not have the
necessary responsible nuclear power plant experience at the plant for which the applicant was
seeking a license. It is expected that recipients will review the Information In this notice to avoid
similar problems. However, suggestions made in this Information notice are not NRC
requirements; therefore, no specific action or written response is required.
Backaround
10 CFR 55.31 (a)(4), requires that (1) operator license applicants submit evidence that they
have successfully completed a facility licensee's requirements to be licensed as an operator
and (2) an authorized representative of the facility licensee certify successful completion of the
requirements on NRC Form 398, uPersonal Qualification Statement - Licensee." In lieu of this
evidence, 10 CFR 55.31 (a)(4) provides that the Commission may accept certification that the
applicant has successfully completed a Commission-approved training program that is based
on a systems approach to training (SAT) and that uses a simulation facility acceptable to the
Commission.
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IN 98-37 Ocbober 1, 1998 The NRC discussed revised applicant eligibility criteria in a March 28, 1980 letter from
Harold Denton to all nuclear power plant licensees. In that letter, licensees were informed of
the revised criteria that the NRC staff would use In evaluating reactor operator training and
licensing. These criteria Included classroom training and simulator training and that a candidate
spend a specified amount of time on shift under instruction and to have, in the case of a senior
operator, previous responsible power plant experience, a portion of which must be at the plant
for which the license is sought, and a four-year college degree or one year as a reactor
operator. On October 31, 1980, the March 28, 1980 letter was reproduced in NUREG-0737
"Clarification of TMI Action Plan Requirements," as Section l.A.2.1, Immediate Upgrading of
Reactor Operator and Senior Reactor Operator Training and Qualifications."Section I.A.2.1 restated the criteria that a senior reactor operator applicant must have been licensed as a
reactor operator for a minimum of one year before obtaining a senior operator license. Section
l.A.2.1 further stated that applicants for a senior license were expected to have a minimum of
four years of "responsible power plant experience" and defined responsible power plant
experience as "that obtained as a control room operator (fossil or nuclear) or as a power plant
staff engineer involved in the day-to-day activities of the facility, commencing with the final year
of construction.
On February 7, 1985, the Commission published a policy statement on training and
qualification, which endorsed the industry-wide accreditation process while affirming the NRC's
responsibility for evaluating licensees' training efforts. The accreditation process was endorsed
by the Commission based on the strength of the SAT process in maintaining the training
program content and because the accreditation guidance for licensed operator training
programs established recommended qualifications, including experience, for licensed control
room operators, senior control room operators, and shift supervisors that were consistent with
the experience requirements contained In the 1980 Denton letter.
In 1987, 10 CFR Part 55, was amended to codify the Commission's policy related to operator
training. Concurrent with publication of the Part 55 rule change, the staff published Revision 2 to Regulatory Guide 1.8, Personnel Selection and Training," and endorsed ANSI/ANS-3.1-
1981Property "ANSI code" (as page type) with input value "ANSI/ANS-3.1-</br></br>1981" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., with exceptions. Regulatory Guide 1.8 defined a method acceptable to the NRC for
compliance with regulations regarding training and qualification of nuclear power plant
personnel. The endorsement and exceptions reiterated the NRC's position on the experience
needed by operator and senior reactor operator applicants, previously stated In the 1980
Denton letter and In NUREG-0737.
Description of Circumstances
Recently the NRC staff denied some applications for senior reactor operator licenses because
the applicants did not have the necessary responsible power plant experience. These
applicants had completed the licensee's training program but did not have six months of
responsible nuclear power plant experience at the plants for which the applicants were seeking
a license.
October 1, 1998 Discussion
The 1987 amendment to 10 CFR Part 55 provided that applicants would no longer need to
provide details of their training and experience on the application If they certified that they had
completed a Commission-approved training program that used a simulation facility acceptable
to the NRC under 55.45(b). Additionally, the Statement of Considerations (SOC)
accompanying the rule change stated that a facility licensee's training program would be
approved by being accredited by the National Nuclear Accrediting Board. At the time of the
publication of the Part 55 rule change, the experience recommendations In the industry's
accredited licensed operator training program guidelines were considered to be equivalent to
the experience criteria of Regulatory Guide 1.8, Revision 2. Therefore, when 10 CFR
55.31 (a)(4) was promulgated, an accredited training program, based on an SAT process, together with the specific experience criteria contained in the training program accreditation
guidelines at that time, was an acceptable alternative method for complying with the
Commission's regulations on training and qualification of nuclear power plant workers. The
SOC accompanying the 1987 revision also informed licensees that their training programs and
experience criteria must conform to the Commission-approved baseline as these were reflected
in the industry's accreditation standards at the time of the revision.
While the Commission-approved experience baseline for licensed operators has not changed
since the 1980 Denton letter, the National Academy for Nuclear Training modified its accredited
licensed operator training program guidelines in 1991 by removing certain criteria Integral to the
NRC's endorsement of that accreditation as an acceptable means of meeting the requirements
in 10 CFR Part 55. Some facility licensees interpreted the removal of these criteria from the
Industry guidelines as NRC approval to reduce the training and experience requirements for
operator license applicants and modified their training programs and procedures accordingly.
To rectify the unintended Interpretation by many facility licensees as a result of the modified
industry guidelines, the National Academy for Nuclear Training developed interim guidance
which reinstates the industry guidance that was removed in 1991. This interim guidance was
sent to its membership on July 8, 1998.
Many licensees are in the process of upgrading (amending) their facility licensing basis
documents, including the technical specifications, prior to submitting them to the NRC staff for
approval. The NRC staff will review submittals which contain references to licensed operator
eligibility requirements against the Commission-approved experience baseline referenced in
this Information notice; however, licensees may propose means other than those specified in
the baseline criteria for meeting applicable regulations.
IN 98-37 October 1, 1998 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
W. Roe, Acting Director
ivision of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Jesse Arildsen, NRR
301-415-1026 E-mail: jaa@nrc.gov
Richard Pelton, NRR
301-415-1028 E-mail: rmpl@nrc.gov
Richard Conte, Region I
610-337-5183 E-mail: mc@nrc.gov
John Pellet, Region IV
817-860-8159 E-Mail: jlp@nrc.gov
Thomas Peebles, Region II
404-562-4638 E-mail: tap@nrc.gov
Melvyn Leach, Region IlIl
630-829-9705 E-mail: mnl@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
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Attachment 1
October 1, 1998 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
98-37 Inadequate or Poorly Controlled
9/18/98
All holders of operating Ilicenses
Non-Safety-Related Maintenance
Activities Unnecessarily Challenged
Safety Systems
for nuclear power reactors
98-35
98-34
98-33
98-32
Threat Assessments and
Consideration of Heightened
Physical Protection Measures
NRC Configuration Control
Errors
NRC Regulations Prohibit
Agreements that restrict or
Discourage an Employee from
Participating in Protected Activities
Problems Associated with Post- Fire Safe-Shutdown Circuit
Analyses
914/98
8/28/98
8/28/98
8/26/98
All U.S. NRC fuel cycle facilities
power and non-power reactor
licencees (Safeguard issues, not
for public disclosure.)
All holders of Operating licenses
for nuclear power reactors, except
for those who have ceased
operations and have certified that
fuel has been permanently
removed from the reactor vessel
All holders of a U.S. Nuclear
Regulatory Commission (NRC)
license.
All holders of operating licenses
for nuclear power reactors, except
those who have permanently
ceased operations and have
certified that fuel has been
permanently removed form the
reactor
OL = Operating License
CP = Construction Permit
'
IN 98-37 October 1, 1998 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Jesse Arildsen, NRR
301-415-1026 E-mail: jaa@nrc.gov
Richard Pelton, NRR
301-415-1028 E-mail: rmpl@nrc.gov
Richard Conte, Region I
610-337-5183 E-mail: mc@nrc.gov
John Pellet, Region IV
817-860-8159 E-Mail: jlp@nrc.gov
Thomas Peebles, Region II
404-562-4638 E-mail: tap@nrc.gov
Melvyn Leach, Region IlIl
630-829-9705 E-mail: mnl@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
- See previous concurrence
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62i Sft~rtMer.xk, 1998 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Jesse Arildsen, NRR
301-415-1026 E-mail: jaa@nrc.gov
Richard Pelton, NRR
301-415-1028 E-mail: rmpl@nrc.gov
Richard Conte, Region I
610-337-5183 E-mail: rnc@nrc.gov
John Pellet, Region IV
817-860-8159 E-Mail: jlp@nrc.gov
Thomas Peebles, Region II
404-562-4638 E-mail: tap@nrc.gov
Melvyn Leach, Region IlIl
630-829-9705 E-mail: mnl@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
- See previous concurrence
DOCUMENT NAME: G:\\CDP\\IN OPLIC.003
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attachment/enclosure E=Copy with attachment/enclosure N = No copy
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IN 98-xx
September xx, 1998 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Jesse Arildsen, NRR
301-415-1026 E-mail: jaa@nrc.gov
Richard Pelton, NRR
301-415-1028 E-mail: rmpl@nrc.gov
Richard Conte, Region I
610-337-5183 E-mail: rnc@nrc.gov
John Pellet, Region IV
817-860-8159 E-Mail: jlp@nrc.gov
Thomas Peebles, Region II
404-562-4638 E-mail: tap@nrc.gov
Melvyn Leach, Region III
630-829-9705 E-mail: mnl@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
- See previous concurrence
DOCUMENT NAME: G:\\CDP\\INOPLIC.003 - OFFICIAL RECORD COPY
To receive a copy of this document, indicate In the box C=Copy wlo attachmentlenclosure E=Copy with attachment/enclosure N = No copy
OFFICE
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OFFICIAL RECORD COPY
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IN 98-xx
" September xx, 1998 qualification of nuclear power plant workers. The SOC accompanying the 1987 revision also
D -eRic-ce
nsees that their training programs and experience criteria must conform to the
afet
Commission-approved baseline as these were reflected in the industry's accreditation
standards at the time of the revision.
While the Commission-approved experience baseline for licensed operators has not changed
since the 1980 Denton letter, it has come to the NRC staffs attention that the industry's
accredited licensed operator training program modified its guidelines in 1991 by removing
certain criteria integral to the NRC's endorsement of that accreditation as an acceptable means
of meeting the requirements in 10 CFR Part 55. To rectify the unintended interpretation by
many facility licensees as a result of the modified industry guidelines, the National Academy for
Nuclear Training has developed interim guidance which reinstates the industry guidance that
was removed in 1991. This interim guidance was sent to its membership on July 8, 1998.
Many licensees are in the process of upgrading their facility licensing basis documents, including the technical specifications, prior to submitting them to the NRC staff for approval.
The NRC staff expects that any such submittals which contain reference to licensed operator
eligibility requirements will conform to the Commission-approved experience baseline
referenced in this information notice. Licensees may propose means other than those specified
baseline criteria for meeting applicable regulations.
This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Richard Pelton, NRR
John Pellet, Region IV
301-415-1028
817-860-8159 E-mail: rmpl@nrc.gov
E-Mail: jlp@nrc.gov
Jesse Arildsen, NRR
Richard Conte, Region I
Thomas Peebles, Region II
301-415-1026
610-337-5183
404-562-4638 E-mail: jaa@nrc.gov
E-mail: rnc@nrc.gov
E-mail: tap@nrc.gov
Melvyn Leach, Region IlIl
Charles Petrone, NRR
630-829-9705
301-415-1027 E-mail: mnl@nrc.gov
i-E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\CDP\\INOPLIC.002 - OFFICIAL RECORD COPY
To receive a copy of this document, indicate In the box C=Copy wlo attachment/enclosure E=Copy with attachment/enclosure N = No copy
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