ML20127A384
| ML20127A384 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/1991 |
| From: | Remick F NRC COMMISSION (OCM) |
| To: | Rogers, Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| COMFR-91-007, COMFR-91-7, NUDOCS 9301110269 | |
| Download: ML20127A384 (3) | |
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NUCLEAR REGULATORY COMMISSION J. v............... n'n?W c =
RELEASED TO THE PDR e
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eseee=5+eesesenesseeeoco September 26, 1991 MEMORANDUM FOR:
The Chairman Commissioner Rogers Commissioner C rtiss Fp$/ !
r Remick FROM:
SUBJECT:
RE-CENTRALIZATION OF OPERATOR LICENSING ACTIVITIES As you know, the Regional offices currently are responsible for administering and reviewing the initial operator licensing examinations and requalification examinations for nuclear power plant personnel, with Headquarters being responsible for maintaining the examiner standard and managing. generic issues that arise in connection with operator licensing and human factors. In the interest of obtaining better consistency and fairness in the administration of initial operator licensing examinations and requalification examinations, and with the intent of perhaps enhancing the career opportunities of our best examiners, I recommend that the Commission direct the staff to perform a study of the pros and cons of recentralizing the operator licensing function.
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As a result of the decentralization of the operator licensing responsibilities in the 1982-1983 timeframe, some adverse consequences have been recognized.
The most significant probably relate to the claims of inconsistencies in the administration of the licensing exams.. Claims of inconsistency seem to fall into three categories.
The first being the quality of the exam.
Although all of the Regions utilize NUREG 1021, the examiner standard, there is a lot of room for interpretation of the-standard, and, as a consequence, some feel-the Regions employ unwritten rules for giving the exam.
I-know it has been a problem historically to assure that all the examiners-within one office are following.the establishc1 procedure and practices.and it becomes even more dif ficult' to assure from Region to Region.
Claims that the quality of the exams vary from Region to Region result. The second is the number of examiners.
Regionalization has clearly resulted in unevenness in the number of examiners, and appears to have resulted in unevenness in the quality of examiners in each Region.
The third is program philosophy.
Some claim that regionalization of the operator licensing responsibilities has resulted in competition between the Regions to see who.can be the toughest. Different emphasis,_ they say, is 9301110569 910926
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PDR 'COMMS NRCC-CORRESPONDENCE PDR l' D i
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put on the exam in each Region. With recentralization of operator licensing, the variations in toughness and practicality from Region to Region would disappear and the complaint of inconsistency would be less likely to be applicable.
Another adverse consequence of operator licensing regionalization that I am aware of is that with smaller staffs in each Region, responsibility for oversight of the exam process must be shared with other responsibilities.
Often with smaller staffs, the people who administer and grade the exams are the same people who perform the supervisory review of the exams.
It has become even more difficult to ensure consistency in the way the exams are reviewed than in the format and content of the. exams themselves, or the way they are administered from Region to Region.
It has been argued that one big advantage of regionalizing this responsibility is that the examiners in the Regions are more likely to know the plants better, and can tailor the exams in order to identify each plant's weaknesses and strengthen the operators' knowledge of these weaknesses. However, I think this can be accomplished equally as well with recentralization.
With a central organization, it would also be easier to have several examiners who are very expert in a particular reactor type which, in turn, would result in better examinations and evaluation of.
applicants for operator and senior licenses assigned to those particular facilities.
This was an acknowledged strength when the function was centralized.
Another problem with the current arrangement appears to be that the career paths for examiners in the Regions have not been well developed, and as a result of this and the limited number of examiner positions in each Region, many of the best examiners look for career opportunities outside of the operator Licensing Branch, thus complicating-the ability to retain experienced L
examiners.
There should be better incentive for the good examiners to stay. Career development opportunities for' examiners should be explored. It would seem that opportunities would be greater in a larger centralized organization.
Although considerable progress has been made in improving the qualifications, education and training of operator licensing personnel, agency emphasis on the function seems to be slowly moving to the back burner.
Recentralizing the function would reverse this drift by enhancing the opportunity for higher management involvement and control of the process.
By recentralization I do not mean necessarily transferring all responsibility for administering operator licensing examinations to Headquarters.
This responsibility could be centralized at the TTC in Chattanooga or one of the Regional offices.
This would avoid the difficulties involved with attracting examiners.to the Washington D.C.
area with its high cost of living.
Relocating personnel could be phased in over time following recentralizing of the function.
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The importance of striving for more consistency is stressed by the EDO in the recently published Summary Of Performance Expectations For Examiners in.the Principles of Good Regulation, where-it is stated that program, crew, and individual evaluations are to be based on the egency-wide examination standards and not on individual examiner desires.
It states further'that this will.
result in an examination process that is reliable and valid from individual to individual and from plant to plant.
I am not convinced that this will be achieved under a decentralized process.
For these reasons, I recommend that the Commission direct the staff to perform a study of the pros and cons of recentralizing the operator licensing function.
SECY please track.
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SECY E00 OGC 1
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