Administration of Operating Tests Prior to Initial Criticality (10 CFR SS55.25) (Generic Letter No. 84-10)

                                UNITED STATES
                           WASHINGTON, D.C. 20555 

                               April 26, 1984 



Subject:  Administration of Operating Tests Prior to Initial Criticality (10
          CFR SS55.25) (Generic Letter No. 84-10) 

This letter is to inform you that all applicants for Reactor Operator (RO) 
and Senior Reactor Operator (SRO) licenses at facilities prior to initial 
criticality who have not had extensive actual operating experience at a 
comparable facility must obtain an exemption to 10 CFR SS55.25(b) if they 
meet the conditions discussed below pending completion of NRC rulemaking 
effort identified below. 

On April 13, 1984, the Commission met to consider the existing staff 
practice of allowing satisfactory completion of an approved cold license 
training program as meeting the 10 CFR SS55.25(b) requirement for extensive 
actual operating experience at a comparable facility. They determined that 
additional rule-making action was required to clarify the Commission 
position that satisfactory completion of NRC-approved training programs 
could be substituted for experience requirements. They directed the Office 
of the General Counsel to initiate a rulemaking to make 10 CFR SS55.25(b) 
fully consistent with current staff practice. They also affirmed that 
operator licenses in effect will remain valid. 

For future operator licensing actions pending Commission action on the 
revised rule, the Commission authorized the staff to grant exemptions to the
requirements of SS55.25(b) for those individuals who have completed an 
approved cold license training program for their facility. The program must 
have included: (a) nuclear fundamentals, including ten reactor startups at a 
nuclear reactor, (b) observation training on shift at a comparable operating 
reactor, (c) training on a simulator and (d) training on actual system 
design of the candidate's plant. 

No specific exemption request is needed for individuals who have completed a 
cold license training program that includes all elements. The necessary 
exemption will be granted as part of the issuance of the operator's license,
provided that our records clearly indicate satisfactory completion of a 
program containing the above elements. Accordingly, until 10 CFR SS55.25(b) 
is modified as discussed above, applicants should identify those cold 
license candidates who satisfy the foregoing criteria for candidates whose 
application is presently before the Commission, a list of those who satisfy 
the criteria should be furnished promptly to avoid unnecessary delays. For 
future candidates, this information should be provided along with the 
individual applications. 

Specific exemption requests for individuals who have completed cold license 
training programs that did not include all elements identified above are 
necessary and shall be evaluated on a case-by-case basis in accordance with 


the provision of 10 CFR SS55.7. If you have any questions concerning this 
matter, please contact Don Beckham, Chief, Operator Licensing Branch, (301) 

This request has been approved by OMB Clearance Number 3150-0018, which 
expires February 28, 1987. 

                              Darrell G. Eisenhut, Director  
                              Division of Licensing 
                              Office of Nuclear Reactor Regulation 

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