ML20203C376
| ML20203C376 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1998 |
| From: | Merrifield J NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20203C348 | List: |
| References | |
| FRN-64FR19868 AF62-2-050, AF62-2-50, SECY-98-266-C, NUDOCS 9902110400 | |
| Download: ML20203C376 (2) | |
Text
..
~.
I A F F l R M A T I O N VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER MERRIFIELD
SUBJECT:
SECY-98-266 - FINAL RULE -- REQUIREMENTS FOR INITIAL OPERATOR LICENSING EXAMINATIONS Approved x in part Disapproved x in part Abstain Not Participating COMMENTS:
See attached comments.
SIGWA1GRt-e Y9P u
DATE Entered on "AS" Yes x
No I
l 9902110400 990209 PDR COMMS NRCC l
._ CORRESPONDENCE PDR u
l Commissioner Merrifield's Comments on SECY-98-266 l
l commend the staff on their efforts to make the examination process more effective and efficient. The NRC must continue to ensure that the quality of the operator licensing j
examinations and the effectiveness of the operator licensing program are maintained. I agree 1
with the staff's assessment that the dynamic simulator and walk-through portions of the operating test are the most performance-based aspects of the licensing process and permit the NRC to truly evaluate the applicants' competence under normai and abnormal plant conditions.
As such, continued NRC evaluation of applicant performance during these portions of the initial operator licensing examination is prudent.
I do not agree with the restrictions placed on facility personnel who can participate in developing the initial operator licensing examinations. I believe the restriction which precludes instructors from preparing questions related to those topics on which they provided instruction places an undue burden on facility licensees with minimal benefit. Operator training is usually a collaborative process in which several instructors and managers are involved in the preparation, review, approval, and presentation of training material. Those involved in this process would likely have a comparable understanding of the instruction content as that of the instructor.
Thus, placing the stated restriction on the instructor does not accomplish its intent of diminishing j
the potential for bias in examination content.
1 Further, I do not believe the staff has provided an adequate basis to demonstrate why these restrictions should be more limiting than the NRC's restrictions on requalification examination personnel. The staff's concern regarding the potential for instructors to bias examination content should be the same regardless of whether it is an initial or requalification examination, and thus, the restrictions should be similarly consistent. I believe the requalification examination personnel restrictions in conjunction with the NRC's enforcement authority provide an acceptable degree of deterrence against any bias in the content of an examination.
Therefore, I endorse adopting a parallel to the NRC's restrictions on requalification examination personnel to allow any instructor to prepare the initial operator licensing examination as long as he or she refrains from teaching the applicants after starting work on their licensing examination.
t a
G CEGQ 4[
D UNITED STATES o
58 " -
p).h,,
NUCLEAR REGULATORY COMMISSION p
WASMNTON D C MW0001 IN RESPONSE, PLEASE 4
/
February 9, 1999 REFER TO: M990209B OFFICE OF THE SECRETARY l
/
D MEMORANDUM FOR:
William D. Travers Executive Director for Operations FROM:
Annette Vietti-Cook, Secretary
/4g g@P
]
1
SUBJECT:
STAFF REQUIREMENTS - AFFIRMATION SESSION,12:05 P.M.,
TUESDAY, FEBRUARY 9,1999, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE)
L SECY-98-266 - Final Rule - Reauirements for Initial Operator Licensino Examinations The Commission approved a final rule amending 10 CFR Part 55 to allow power reactor facility licensees to prepare the initial operator licensing examinations. The Commission voted to approve publication and implementation of this final rule subject to removing the restriction which precludes instructors from preparing questions related to those topics on which they provided instruction. The restriction should be revised to be consistent with the restrictions on requalification examinations which allow any instructor to prepare the initial operating examination as long as they refrain from teaching the applicants after starting work to prepare i
the examination.
Following incorporation of this change, the Federal Reaister notice should be reviewed by the Rules Review and Directives Branch in the Office of Administration and forwarded to the Office of the Secretary for signature and publication.
(EDO)
(SECY Suspense:
3/12/99)
The staff should continue to monitor examination results with particular attention to the potential for the level of difficulty between licensee-developed and NRC-developed examinations to diverge. While the differences could be attributed to higher standards by some licensees or decline in NRC examiner proficiency, the differences should be assessed and corrective action initiated, where warranted.
The Commission disapproved the proposed changes to the enfc;rcement policy. Willful violations under this rule should be assessed in a manner similar to other willful violations, as provided for in the enforcement policy. In addition, the staff should reevaluate the proposed examples to determine if the examples cover the spectrum necessary to ensure consistent application of the enforcement policy and technical and regulatory significance have been l
appropriately considered. For example, the demarcation between escalated and non-escalated l
violations (non-willful) might be better placed at the point of license issuance rather than examination adininistration. The Commission should ce provided the revised changes to the enforcement policy, along with the associated bases. 'or review prior to implementation by the
^
J)q) ipjv iv
.u-
, w.s
e staff.
(EDO)
(SECY Suspense:
3/26/99) cc:
Chairman Jackson Commissioner Dicus Commissioner Diaz
' Commissioner McGaffigan Commissioner Merrifield OGC CIO -
- OlG OPA Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
i 1
L i
l 1
l