ML20203C350
| ML20203C350 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20203C348 | List: |
| References | |
| FRN-64FR19868 AF62-2-054, AF62-2-54, SECY-98-266-C, NUDOCS 9902110386 | |
| Download: ML20203C350 (2) | |
Text
..
-. ~.
AFFIRMATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
CHAIRMAN JACKSON
SUBJECT:
SECY-98-266 - FINAL RULE - REQUIREMENTS FOR INITIAL OPERATOR LICENSING EXAMINATIONS w/ comments Approved Disapproved X Abstain i
Not Participating i
1 COMMENTS:
See attached comments.
l L
Shitley A n Jackson SIGNATURE February 2,1999 DATE L
. Entered on "AS" Yes X
No 9902110386 990209 l
PDR COPMS MtCC L
CORRESPONDENCE PDR 990z//$32;4
o Chairman Jackson's Comments on SECY-98-266
" Final Rule - Requirements for initial Operator Licensing Examinations" j
i disapprove of the staff intention to modify 10 CFR Part 55 to allow power reactor licensees to prepare and administer operator license examinations. While I have not, to date, opposed the pilot program or previous rulemaking efforts in this area, the subject paper has not made a compellirg case for the rule change in question. It is not clear to me what advantage will be gained from the proposed action. While I agree with the staff that this approach will save NRC l
resources, the subject paper leads me to conclude that the costs that would have been incurred I
by NRC will, on balance, simply be redistributed over the power reactor community. I agree with the staff position that some licensees may realize less of a resource burden by this approach (i.e. those that are capable of preparing high quality examinations with limited NRC l
involvement); however, it is not clear to me why.all power reactor licensees could not experience l
similar reductions in burden through effective staff management of NRC contractor activities. In balancing the unpredictable nature of the benefits to be realized against the !ncreased potential for the compromise of examinations and the difficulty in planning NRC activities due to the voluntary nature of this approach, I conclude that it is preferable for NRC to reestablish sole responsibility for the preparation and administration of initial licensed operator examinations.
I am troubled by the fact that the subject paper describes a decision-making process which places budget ahead of the agency public health and safety mission. Specifically, the paper states that the stats proposal in this area was, in part, the result of anticipated resource reductions; thus, it would appear that a decision was made to require licensees to administer operator license examinations to support those anticipated (and, eventually, realized) resource reductions. The subsequent determination that requiring licensees to prepare and administer operator license examinations constituted a backfit has now placed the staff in the position of proposing to allow, rather than recuire, licensees to perform these functions. Remaining mindful of the fact that many of the approximately 75% of licensees participating in the pilot program in this area may have done so in preparation for what they anticipated to be a requirement and that they may now request NRC to prepare and administer examinations at their facilities, I am concerned that this action may result in no net benefit for licensees and an increased pisnning burden (due to demand uncertainties) for the NRC. Additionally, the planning and budgeting uncertainties incumbent in the proposed action may add additional difficulty to staff efforts to ensure that NRC is not an impediment to licensees staffing their facilities with the numbers of licensed operators that they feel is appropriate (in this vein, some licensees have already complained that NRC can be just such an impediment, or at least an obstacle, by only offering l
generic furidamentals examinations twice in a given year).
l l
l l