The Nuclear Regulatory Commission’s (NRC) oversight of the reactor operator licensing examination process is effective, efficient, and reliable. However, the agency could benefit from providing additional guidance and clarity in the current version of NUREG-1021, “Operator Licensing Examination Standards for Power Reactors” (Rev. 12). Specifically, NUREG-1021 contains process gaps and lacks clarity in policy interpretation. This occurred because when the agency updated NUREG-1021, it did not identify certain process gaps. This lack of clarity in the guidance could lead to potential delays and errors in processing reactor operator licensing applications and in rendering requalification decisions. This report makes one recommendation to identify process gaps and update NUREG-1021 to ensure that guidance in future revisions remains current and addresses emerging issues.
Report File
Date Issued
Submitting OIG
Nuclear Regulatory Commission OIG
Other Participating OIGs
Nuclear Regulatory Commission OIG
Agencies Reviewed/Investigated
Nuclear Regulatory Commission
Report Number
OIG-24-A-10
Report Description
Report Type
Audit
Agency Wide
Yes
Number of Recommendations
1
Questioned Costs
$0
Funds for Better Use
$0
Open Recommendations
This report has 1 open recommendations.
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1.1 | Yes | $0 | $0 | April 28, 2025: The U.S. Nuclear Regulatory Commission (NRC) staff identified three actions to address the one recommendation in the Office of the Inspector General’s (OIG’s) audit of the reactor operator licensing examination process (OIG-24-A-10). The implementation status is provided below: NRC Staff Action 1: Issue a draft of NUREG-1021, “Operator Licensing Examination Standards for Power Reactors,” for public comment that includes, at a minimum, revisions to address identified process gaps. Target: 6/30/2028 (i.e., 6 months following issuance of the final effectiveness review report, which is anticipated no later than the end of calendar year 2027). Status: In progress. The update of NUREG-1021 is on track for completion by the target date. NRC Staff Action 2: Revise Operator Licensing Program Feedback (OLPF) information. Target: 3/31/2025. Status: Complete. The staff evaluated the reports on interactions listed in figure 3 of OIG’s audit report dated September 30, 2024 (Agencywide Documents Access and Management System Accession No. ML24274A141), to determine whether information in them should be made available to external stakeholders through the OLPF website. Information that the staff determined would be beneficial to external stakeholders was added to the OLPF information and made available on the NRC’s public website on March 17, 2025. NRC Staff Action 3: Submit a revision to NRC Form 398, “Personal Qualification Statement— Licensee,” to the Office of Management and Budget that, at a minimum, addresses the identified process gaps. Target: 1/31/2026. Status: Complete. The staff revised the NRC Form 398 on March 20, 2025. The revision consisted of one editorial change to the instructions for box 11A on NRC Form 398 to clarify the instructions for new applications. The staff identified the need to make the change following its review of OIG’s assessment of the reports on interactions completed in calendar year 2023. OIG had also observed during the audit that NRC Form 398 did not contain a checkbox or other instructions for indicating a supplement, revision, or update of previously submitted information on the form. The staff determined that a checkbox or other instruction on the form is not necessary at this time because the process for submitting, reviewing, and approving license applications, as established in NUREG-1021, provides for the staff to notify a submitter when a new submission is necessary and for the submitter to supersede a previously submitted form. There are also no known issues with the current process. Target date for completion: June 30, 2028. OIG Analysis: The proposed actions described in the agency’s response meet the intent of this recommendation. The OIG will close this recommendation after reviewing and confirming that an update to NUREG-1021 addresses the identified process gaps. Agency Response Dated October 29, 2024: The staff concurs with the recommendation. The U.S. Nuclear Regulatory Commission (NRC) staff agrees with the recommendation in the Office of the Inspector General’s report for Audit OIG-24-A-10, “Audit of the U.S. Nuclear Regulatory Commission’s Reactor Operator Licensing Examination Process,” dated September 30, 2024. The NRC staff will update NUREG-1021, “Operator Licensing Examination Standards for Power Reactors,” and NRC Form 398, “Personal Qualification Statement—Licensee,” as applicable, to provide additional clarity and close process gaps, including those identified in figure 3 of the audit report. As noted in the audit report, the NRC staff established an effectiveness review team to assess the implementation of Revision 12 of NUREG-1021, issued September 2021, which included relatively major changes to the NRC’s commercial nuclear power operator licensing program. Revision 12 became effective in March 2022, and it is currently used by the NRC staff and examination developers at all commercial nuclear power facilities. Data collection for some areas of the effectiveness review ended in July 2024, and the NRC staff will continue to collect data for other review areas through September 2027. The NRC staff is preparing a report, for issuance by the end of calendar year (CY) 2024, that will summarize the data collected by the effectiveness review team through July 2024. The NRC staff expects that this report will identify a few additional enhancements to the guidance in NUREG-1021. The staff also intends to issue a final effectiveness review report by the end of CY 2027, which may also identify potential revisions to NUREG-1021. The NRC’s Principles of Good Regulation include clarity, openness, and efficiency. Notably, the principle for efficiency states, in part, “Where several effective alternatives are available, the option which minimizes the use of resources should be adopted.” Revising NUREG-1021 requires the expenditure of a relatively large amount of NRC resources, and power reactor facility licensees must expend their resources to implement process changes resulting from any NUREG-1021 revision. Thus, a decision to issue a revision to NUREG-1021 also needs to ensure the resources expended will be justified. The NRC staff evaluated the process gaps that have been identified to date to assess, from a safety perspective, if any of the gaps impact the ability to make the findings required by 10 C.F.R. 55.33 (disposition of an initial application) or other relevant regulations. The NRC staff determined that the process gaps identified to date are not causing any problems that warrant an immediate update to NUREG-1021. The staff can adequately address fact-specific gaps via the reports on interactions (ROIs) process. However, the staff is evaluating making the information in these ROIs available to external stakeholders through its Operator Licensing Program Feedback website (i.e., accessible on the NRC’s public website), with redactions when appropriate. Accordingly, to maximize efficiency by minimizing the number of NUREG-1021 revisions that could occur in a relatively short amount of time (e.g., NUREG-1021 revisions before and after issuance of the final effectiveness review report), the staff intends to issue a draft of NUREG-1021 for public comment that includes, at a minimum, revisions to address the identified process gaps by no later than 6 months following issuance of the final effectiveness review report (anticipated no later than the end of CY 2027). Additionally, the staff plans to revise the Operator Licensing Program Feedback information by no later than March 31, 2025 (i.e., approximately 3 months following issuance of the effectiveness review team’s report that will be issued by end of CY 2024). These actions together will balance the need for clarity, openness, and efficiency. Target date for completion: March 31, 2025. Revising NRC Form 398 also requires the expenditure of NRC resources, and power reactor facility licensees will also need to expend resources to implement process changes resulting from such a revision. Thus, a decision to issue a revision to NRC Form 398 also needs to ensure the resources expended will be justified. As such, the NRC staff evaluated the process gaps that have been identified to date and determined that issuing a revision to NRC Form 398 to address these gaps is not urgent. Furthermore, addressing the few process gaps that have been identified on NRC Form 398 to date in a revision to the form is also not urgent, and the cases that revealed the process gaps are very infrequent. Between now and the next revision to the form, the previously approved ROIs provide sufficient guidance to process NRC Form 398 submittals for cases similar to those discussed in the ROIs. Therefore, the NRC staff will revise NRC Form 398 to, at a minimum, address the identified process gaps as part of the renewal of the Office of Management and Budget (OMB) clearance expiration date, which is January 31, 2026. Accordingly, the NRC staff will submit the revised form to the OMB no later than December 2, 2025, to ensure timely renewal. Target date for completion: January 31, 2026 OIG Analysis: The proposed actions described in the staff response meet the intent of this recommendation. The OIG will close this recommendation after reviewing and confirming that an update to NUREG-1021 addresses the identified process gaps and the revision to NRC Form 398 is implemented. |
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| Identify process gaps and update NUREG-1021 to ensure that guidance in future revisions remains current and addresses emerging issues. | |||||
