ML20059M651

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Informs Commission Re Findings of Independent Mgt Study Conducted to Evaluate Consistency of NRC Operator Licensing Exams & Practicality of Recentralizing Operator Licensing Function to Mitigate Any Inconsistencies
ML20059M651
Person / Time
Issue date: 11/17/1993
From: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-93-309, NUDOCS 9311190214
Download: ML20059M651 (83)


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POLICY ISSUE (Information)

November 17, 1993 SECY-93-309 FOR:

The Comissioners FROM:

James M. Taylor Executive Director for Operations

SUBJECT:

FINDINGS OF THE OPERATOR LICENSING RECENTRALIZATION STUDY PURPOSE:

To inform the Comission of the findings of the independent management study conducted to evaluate the consistency of the Nuclear Regulatory Comission's (NRC's) operator licensing examinations and the practicality of recentralizing the operator licensing function to mitigate any inconsistencies.

BACKGROUND:

When the operator licensing function was decentralized in the early 1980s, it was recognized that regional inconsistency in the rievelopment and administration of operator licensing examinations could exist. To address this issue, the staff enhanced the Operator Licensing Examiner Standards and instituted a program for regional oversight.

In 1991, the Comission determined that it should have more information on the sources of operator licensing inconsistencies. This information would be used to determine whether the structure of the operator licensing program warranted change.

In a memorandum of November 25, 1991, the Secretary of the Commission forwarded the Comission's recommendation that the staff should hire a contractor to study inconsistencies in the NRC's operator licensing program and to review the advantages and disadvantages of recentralizing the operator licensing function.

The contractor, ICF, Incorporated, conducted its study e

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The Commissioners from June 1 to August 31, 1993, and submitted its final report to the Office of Nuclear Reactor Regulation (NRR) on September 30, 1993. A copy of the final report, entitled " Evaluation of the Operator Examination and Licensing Function," with Appendix is enclosed.

DISCUSJJ_0H:

0 The primary objective of the study was to assess the quality and consistency of NRC licensing examinations administered in accordance with Revision 6 of NUREG-1021, " Operator Licensing Examiner Standards," during the inclusive period 1990 to 1992. The study's intent was also to determine possible solutions to any quality and inconsistency problems that might be identified and evaluate the advantages and disadvantages of both a centralized and decentralized operator licensing structure.

The study methodology included written questionnaires, as well as in-depth interviews, of personnel involved with the operator licensing process at NRR, the NRC regional offices, selected plants, and industry groups (the Nuclear Management and Resources Council (NUMARC) and the Professional Reactor Operator Society (PROS)). Where entire populations could not be surveyed, personnel were selected at random so that the findings could be generalized to the entirety of the subgroups surveyed.

The study concluded that both the requalification and initial examinations are sufficiently consistent to assure that appropriate licensing decisions are being made. The requalification examinations were generally found to be less consistent than the initial licensing examinations. However, that concern may be rendered moot if and when the proposed amendment to 10 CFR Part 55 eliminating the requirement for each operator to pass an NRC-conducted i

requalification examination during every license term is approved.

The staff expects to submit the final rulemaking proposal in December 1993.

The study found that the individual differences among examiners are the most i

important determinant of variations in the development and administration of operator licensing examinations. Varying levels of education and professional experience, personal preferences, and differing interpretations of the Operator Licensing Examiner Standards have resulted in variations in the level of difficulty of individual examination components, especially in the dynamic simulator and walkthrough portions of the operating test. The study concluded that the current regional structure of the operator licensing program is not a key contributor to examination inconsistency.

Although a modest gain in examination consistency could occur if examiners were situated in one location, differences among examiners would not disappear under a centralized structure. Centralization would give examiners 1

opportunities to share ideas, discuss problems, and reduce conflicting guidance from regional managers. However, according to the study, these

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The Commissioners ;

benefits would come at the expense of reduced exam quality, loss of some experienced examiners, and large reorganizational costs.

In conclusion, the contractor recommended that the NRC retain the existing organizational structure of the operator licensing program because the current level of variation does not warrant a major overhaul of the program.

To correct the inconsistency problems and improve program quality, the contractor recommends strengthening four general program areas:

headquarters oversight activities

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examiner training examination guidance regional interaction and communication Based upon a review of the contractor's recommendations, the staff agrees that major changes to the operator licensing program are not warranted. However, the staff is evaluating the contractor's recommendations as discussed in Sections IV and V of the contractor's report to determine the most cost-effective way for maximizing examination consistency. The staff will give priority to those recommendations that can be implemented at minimal cost under existing staffing levels and will consider the remaining recommendations within the context of future staffing and budgetary resources.

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Enclosure:

Evaluation of the Operator Examination and Licensing Function:

Final Report (with Appendix)

(To Commission, SECY, OGC & EDO only)

DISTRIBUTION:

Comunissioners OGC OC1LA OIG OPA OCA OPP EDO SECY