L-2018-090, Comment (7) of Larry Nicholson, on Behalf of Florida Power & Light Co., on Qualification and Training of Personnel for Nuclear Power Plants

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Comment (7) of Larry Nicholson, on Behalf of Florida Power & Light Co., on Qualification and Training of Personnel for Nuclear Power Plants
ML18120A113
Person / Time
Site: Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold  NextEra Energy icon.png
Issue date: 04/10/2018
From: Larry Nicholson
Florida Power & Light Co
To: May Ma
Rules, Announcements, and Directives Branch
References
83FR6053 00007, DG-1329, L-2018-090, NRC-2018-0023
Download: ML18120A113 (6)
v • d • e


Text

April 10, 2018 L-2018-090 ATIN:MayMa Office of Administration Mail Stop: OWFN-2A13 U.S. Nuclear Regulatory*Commission Washington, :pc 20555-0001

Subject:

Request for Comment on the NRC Draft Regulatory Guide, DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants" (Docket ID NRC-2018-0023)

Florida Power & Light Company, the licensee for the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, and on behalf of NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) the licensee for Seabrook Station; NextEra Energy Duane Arnold, LLC (NextEra Energy Duane Arnold), the licensee for Duane Arnold Energy Center; and NextEra Energy Point Beach, LLC (NextEra Energy Point Beach), the licensee for Point Beach Nuclear Plant, Units 1 and 2 (collectively referred to as Next:Era Energy), appreciates the opportunity to comment and offers the attached comments for consideration on the draft Regulatory Guide (R.G), DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants," published in the Federal Register on February 12, 2018 (83 FR 6053, [NRC-2018-0023]).

N extEra endorses the comments provided by the Nuclear Energy Institute (NEI) on behalf of the industry related to this draft RG.

s;;Y;;;t_ 93 F~ 1,053 Larry Nicholson Director, Nuclear Licensing and Regulatory Compliance

~1~1211(

Ci),,,.

Attachment (1)

SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM-03

.. ~dd_= !t!~~~:..~

Florida Power & Light C?mpany 700 Universe Boulevard, Juno Beach, FL 33408

.Attachment L-2018-090 Page 1 of 5 Comments Concerning Draft.Regulatory Guide DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants" Draft Regulatory Guide (RG) DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants," RG describes methods acceptable to the NRG for complying with those portions of its regulations associated with the selection, qualifications, and training for nuclear power plant personnel. This draft RG is proposed Revision 4 to RG 1.8 (same title).

NextEra Energy appreciates the opportunity to comment on DG-1329 and offers the following comments for consideration by the U.S. Nuclear Regulatory Commission (NRG).

General Comments Section 1, "Qualification," of the draft RG discusses qualification criteria that are described in Section 4 of ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," which the NRG considers acceptable with some exceptions. Following are NextEra Energy comments on the NRG exceptions.

1. DG-1329 Section*1.1 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.3, "Middle Manager Level" criteria:

An individual assigned to a specific position should meet the requirements for that position; therefore, the allowance for a specific position to be filled by a person that does not meet the requirements for that position if that person is provided a staff whose qualifications meet the selected middle manager qualification is not endorsed.

NextEra Energy recommends revising the exception to endorse Section 1.1 except for the Radiation Protection Manager. NextEra Energy does not agree with the exception as currently written. NextEra Energy believes that the proposed exception will result in undue and significant hardship for licensees and recommends that the NRG reconsider the

  • proposed exception based on the following.reasons:
  • The ANSI/ANS-3.1-2014 standard intentionally added the flexibility that would allow utilities to place leaders with strong leadership skills into roles where they might not have all the technical expertise, but would have the demonstrated managerial skill that is needed for a role. Significant upgrades in procedure requirements, risk management processes, work man~gement processes, and multitude of site challenge boards th~t have been implemented since the standard was last updated would remove the potential for unintended consequences due to the technical decision making of a single manager. Leaders and managers are able to gain proficiency more effectively today than in the past due to the candidate assessment and selection processes for new managers, mentoring programs, industry supervisor and leadership training programs and the implementation of INPO 15-005, "Leadership and Team Effectiveness Attributes"that set the standards of effective leadership and teams: Information sharing in our industry has advanced such that consultation with other site and fleet experts along with peers in the industry is common and accepted practice that allows managers to quickly and easily gain alignment on best practices and operating experience.

Attachment L-2018-090 Page 2 of 5

  • As currently written in the ANSI/ANS-3.1-2014 standard, there are sufficient provisions provided for the staff to support the manager. The standard as written .

also requires a staff that would meet all applicable requirements, which would further limit any potential vulnerability.

  • Additionally, the concept of a middle manager's staff holding certain qualifications in lieu of a fully qualified middle manager is not new to industry. As an example, current Improved Standard Technical Specifications (NUREG 1430-1434) ITS 5.2.2.d states that "The operations manager or assistant operations manager shall hold an SRO license." Implied in this NRG issued standard technical specification is* that if the operations manager does not possess an SRO license it is acceptable for him to be
  • the operations manager, as long as his assistant (staff) maintains an SRO license.
  • Further assurance that this would be a minimal potential impact, is the strict requirement in the ANSI/ANS-3.1-2014 standard related to collective experience for the middle manager level which would limit use of the allowance to very few middle manager positions simultaneously.
2. DG-1329 Section 1.3 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.3.3, "Radiation Protection" (Manager) criteria:

The RPM is the onsite member of the power plant staff that is responsible for implementation of the radiological protection program and that meets the education, experience, and special requirements listed in section 4.3.3. In addition to the experience requirements listed in section 4.3.3, individuals with no prior RPM experience should have six months of time onsite before being assigned RPM duties. Licensees should evaluate required onsite time for experienced RPMs who are new to a site or a reactor technology (i.e. Pressurized Water Reactor (PWR) or Boiling Water Reactor (BWR). The purpose of the onsite time is to provide a newly assigned RPM sufficient opportunity to learn the location and performance characteristics of key equipment and other plant-specific information that is necessary to make informed decisions concerning radiological safety. As a .

modification to item (3) in the Special Requirements section of 4.3.3, the majority of the station RPM's experience should be relevant to supervising in-field radiation protection program activities (e.g., As Low As Reasonably Achievable (ALARA),

radiation protection operations, and radioactive waste shipping). Personnel who are temporarily assigned to fill the RPM position as described in section 4. 1 and who do not meet the requirements to serve as an RPM should have first line supervisor experience of in-field radiation protection program activities. Personnel who do not meet the requirements for this position should not be assigned to temporarily fill the position for periods exceeding three months.

NextEra Energy partially agrees with this exception as noted in the comment below.

  • NextEra Energy agrees with the modification to Item (3) in the Special Requirements of Section of 4.3.3 of the ANSI/ANS-3.1-2014 standard, that the majority of the station Radiation Protection Manager's (RPM's) experience should be relevant to supervising in-field Radiation Protection (RP) program activities (e.g., As Low As Reasonably Achievable (ALARA), RP operations, and radioactive waste shipping)).

Attachment L-2018-090 Page 3 of 5 However, NextEra Energy does not support this exception based on the following:

  • NextEra Energy does not agree with the addition to the experience requirements listed in Section 4.3.3 of the ANSI/ANS-3.1-2014 standard, that individuals with no prior RPM experience should have six (6) months of time onsite before being assigned RPM duties. NextEra Energy does not agree that licensees should evaluate required onsite time for experienced RPMs who are new to a site or a reactor technology. There is no previous requirement in Revisions 1, 2 or 3 of RG 1.8, nor is there any requirement in the previous ANSI 3.1-1978 or ANSI 18.1-1971 standards. NextEra Energy believes that this exception presents a new NRC staff position with no justification for the increased burden. The experience requirements in ANSI/ANS-3.1-2014 of one-month time during a refuel outage and two months experience at a reactor operating greater than 20% provide adequate experience for the position. Additionally, the ability to review and research records electronically to easily determine the location and performance characteristics of key equipment and other plant-specific information, strong technical training program for Radiation Protection, along with the various requirements in procedures, risk management processes, work management processes, and ALARA site challenge boards provide more than adequate barriers to preclude any issues that could be attributable to a lack of site-specific experience.
  • NextEra Energy does not agree with the addition of the wording in the exception that personnel who are temporarily assigned to fill the RPM position as described in Section 4.1 of the ANSI/ANS-3.1-2014 standard, and who do not meet the requirements to serve as an RPM should have first line supervisor experience of in-field RP program activities. NextEra Energy believes that this is already adequately covered in Section 4.1 of the standard based on the statement: "Individuals temporarily filling a position due to the absence of its principal individual shall
  • possess, as a minimum, the qualifications required for the corresponding position in the next lower functional level." The next lower functional level already meets or exceeds this requirement.
  • NextEra Energy does not agree with the addition of the wording in the exception that personnel who do not meet the requirements for this position should not be assigned to temporarily fill the *position for periods exceeding three (3) months as there is guidance covered in Section 4.1 of the ANSI/ANS-3.1-2014 standard that includes the following statement:

"Individuals shall meet the requirements for a given position. Individuals needing exceptions to this may be temporarily assigned to fill that position. Such assignments shall be justified and a time period for the temporary assignment

  • shall be specified and documented. Temporary assignments shall not reduce the collective experience requirements specified for that level."

Attachment L-2018-090 Page4of5 There is no justification for mandating a 3-month limit and in fact having this specified limit could cause additional personnel having to be assigned temporarily to the same role to meet an arbitrary time requirement. NextEra Energy's position is that the requirement in the ANSI/ANS-3.1-2014 standard to specify and document the time period for temporary positions is reasonable and appropriate.

3. DG-1329 Section 1.4 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.4.1, "Senior Operator" criteria:

A non-licensed applicant (an instant candidate) for a senior operator (SO) license should have three years of responsible nuclear power plant experience. A professional engineering license or Bachelor of Science degree in engineering, engineering technology, or related sciences should only be allowed to account for a maximum of eighteen months of responsible nuclear power plant experience. A

  • Bachelor of Science degree in an area other than engineering, engineering technology, or related sciences should only be credited for a maximum of eighteen months if at least 80 semester hours (college credits) are in engineering, mathematics, chemistry, or physics. Applicants for an SO position who do not hold a bachelor's degree in engineering or the equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least one year at a commercial power reactor facility of the same vendor, or have 1. 5 years at a comparable or non-comparable commercial power reactor facility, or have at least two years of military experience in a position equivalent to a licensed reactor operator.

NextEra Energy does not support this exception as noted below.

  • NextEra Energy strongly disagrees with the proposed 3-year requirement for all non-licensed personnel. This exception imposes a 3-year experience requirement for all non-licensed personnel which would be in direct conflict with the NRG-endorsed ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators, " Figure 2-2, "Senior Reactor Operator Eligibility - RO Upgrade or Direct SRO Licensed at Another Facility or Direct SRO Military RO Equivalent, "and Figure 2..:3, "Senior Reactor Operator Eligibility- Direct SRO for Degreed Personnel."

Specifically, this new requirement would introduce conflicting requirements for the following candidate situations:

o A military candidate that does not have a degree (Figure 2-2).

  • o A non-licensed candidate but with a degree and 18 months at a comparable facility (Figure 2-3).

o A non-licensed candidate but with a degree and 27 months at a noncomparable facility (Figure 2-3).

  • NextEra Energy strongly disagrees with degree requirements specified, as it removes the flexibility of the non-traditional degree option in ACAD 10-001 that the NRC has already endorsed.

Attachment L-2018-090 Page 5of 5 NextEra Energy partially agrees with this exception as noted below. *

  • NextEra Energy agrees with the position pertaining to SO applicants "who do not hold a bachelor's degree in engineering or the equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least one year at a commercial power reactor facility of the, same vendor, or have 1. 5 years at a comparable or non-comparable commercial power reactor facility,. or have at least two years of military experience in a position equivalent to a licensed reactor operator." Although more restrictive than the guidance stipulated in the ANSI/ANS 3.1-2014 standard, it is aligned with ACAD 10-001 guidance which the NRC has already endorsed.

It is NextEra Energy's position that some of the exceptions noted in this draft RG related to Senior Operators appear to be in direct conflict to the NRC endorsement of ACAD 10-001, Revision 1. NextEra Energy would not necessarily be opposed to an exception that was aligned with ACAD 10-001 guidance. NextEra Energy suggests a possible resolution for this item that includes either of the following for an exception:

An applicant for a Senior Reactor Operator (SRO) license should meet the minimum qualifications, education, experience and training as specified in the facility licensee's "systematic approach to training" program.

OR An applicant for a Senior Reactor Operator (SRO) license should meet the Senior Reactor Operator Eligibility as *specified in ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators. "

4. NextEra Energy agrees with the exceptions as noted in DG-132.9 for the sections below and offers no additional comments for NRC consideration related to the draft RG.
  • DG-1329 Section 1.2 forANSI/ANS-3.1-2014, Section 4.3.1, "Training"
  • DG-1329 Section 1.5 for ANSI/ANS-3.1-2014, Section 4.4.2, "Senior Operator Limited to Fuel Handling"

April 10, 2018 L-2018-090 ATIN:MayMa Office of Administration Mail Stop: OWFN-2A13 U.S. Nuclear Regulatory*Commission Washington, :pc 20555-0001

Subject:

Request for Comment on the NRC Draft Regulatory Guide, DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants" (Docket ID NRC-2018-0023)

Florida Power & Light Company, the licensee for the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, and on behalf of NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) the licensee for Seabrook Station; NextEra Energy Duane Arnold, LLC (NextEra Energy Duane Arnold), the licensee for Duane Arnold Energy Center; and NextEra Energy Point Beach, LLC (NextEra Energy Point Beach), the licensee for Point Beach Nuclear Plant, Units 1 and 2 (collectively referred to as Next:Era Energy), appreciates the opportunity to comment and offers the attached comments for consideration on the draft Regulatory Guide (R.G), DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants," published in the Federal Register on February 12, 2018 (83 FR 6053, [NRC-2018-0023]).

N extEra endorses the comments provided by the Nuclear Energy Institute (NEI) on behalf of the industry related to this draft RG.

s;;Y;;;t_ 93 F~ 1,053 Larry Nicholson Director, Nuclear Licensing and Regulatory Compliance

~1~1211(

Ci),,,.

Attachment (1)

SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM-03

.. ~dd_= !t!~~~:..~

Florida Power & Light C?mpany 700 Universe Boulevard, Juno Beach, FL 33408

.Attachment L-2018-090 Page 1 of 5 Comments Concerning Draft.Regulatory Guide DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants" Draft Regulatory Guide (RG) DG-1329, "Qualification and Training of Personnel for Nuclear Power Plants," RG describes methods acceptable to the NRG for complying with those portions of its regulations associated with the selection, qualifications, and training for nuclear power plant personnel. This draft RG is proposed Revision 4 to RG 1.8 (same title).

NextEra Energy appreciates the opportunity to comment on DG-1329 and offers the following comments for consideration by the U.S. Nuclear Regulatory Commission (NRG).

General Comments Section 1, "Qualification," of the draft RG discusses qualification criteria that are described in Section 4 of ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," which the NRG considers acceptable with some exceptions. Following are NextEra Energy comments on the NRG exceptions.

1. DG-1329 Section*1.1 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.3, "Middle Manager Level" criteria:

An individual assigned to a specific position should meet the requirements for that position; therefore, the allowance for a specific position to be filled by a person that does not meet the requirements for that position if that person is provided a staff whose qualifications meet the selected middle manager qualification is not endorsed.

NextEra Energy recommends revising the exception to endorse Section 1.1 except for the Radiation Protection Manager. NextEra Energy does not agree with the exception as currently written. NextEra Energy believes that the proposed exception will result in undue and significant hardship for licensees and recommends that the NRG reconsider the

  • proposed exception based on the following.reasons:
  • The ANSI/ANS-3.1-2014 standard intentionally added the flexibility that would allow utilities to place leaders with strong leadership skills into roles where they might not have all the technical expertise, but would have the demonstrated managerial skill that is needed for a role. Significant upgrades in procedure requirements, risk management processes, work man~gement processes, and multitude of site challenge boards th~t have been implemented since the standard was last updated would remove the potential for unintended consequences due to the technical decision making of a single manager. Leaders and managers are able to gain proficiency more effectively today than in the past due to the candidate assessment and selection processes for new managers, mentoring programs, industry supervisor and leadership training programs and the implementation of INPO 15-005, "Leadership and Team Effectiveness Attributes"that set the standards of effective leadership and teams: Information sharing in our industry has advanced such that consultation with other site and fleet experts along with peers in the industry is common and accepted practice that allows managers to quickly and easily gain alignment on best practices and operating experience.

Attachment L-2018-090 Page 2 of 5

  • As currently written in the ANSI/ANS-3.1-2014 standard, there are sufficient provisions provided for the staff to support the manager. The standard as written .

also requires a staff that would meet all applicable requirements, which would further limit any potential vulnerability.

  • Additionally, the concept of a middle manager's staff holding certain qualifications in lieu of a fully qualified middle manager is not new to industry. As an example, current Improved Standard Technical Specifications (NUREG 1430-1434) ITS 5.2.2.d states that "The operations manager or assistant operations manager shall hold an SRO license." Implied in this NRG issued standard technical specification is* that if the operations manager does not possess an SRO license it is acceptable for him to be
  • the operations manager, as long as his assistant (staff) maintains an SRO license.
  • Further assurance that this would be a minimal potential impact, is the strict requirement in the ANSI/ANS-3.1-2014 standard related to collective experience for the middle manager level which would limit use of the allowance to very few middle manager positions simultaneously.
2. DG-1329 Section 1.3 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.3.3, "Radiation Protection" (Manager) criteria:

The RPM is the onsite member of the power plant staff that is responsible for implementation of the radiological protection program and that meets the education, experience, and special requirements listed in section 4.3.3. In addition to the experience requirements listed in section 4.3.3, individuals with no prior RPM experience should have six months of time onsite before being assigned RPM duties. Licensees should evaluate required onsite time for experienced RPMs who are new to a site or a reactor technology (i.e. Pressurized Water Reactor (PWR) or Boiling Water Reactor (BWR). The purpose of the onsite time is to provide a newly assigned RPM sufficient opportunity to learn the location and performance characteristics of key equipment and other plant-specific information that is necessary to make informed decisions concerning radiological safety. As a .

modification to item (3) in the Special Requirements section of 4.3.3, the majority of the station RPM's experience should be relevant to supervising in-field radiation protection program activities (e.g., As Low As Reasonably Achievable (ALARA),

radiation protection operations, and radioactive waste shipping). Personnel who are temporarily assigned to fill the RPM position as described in section 4. 1 and who do not meet the requirements to serve as an RPM should have first line supervisor experience of in-field radiation protection program activities. Personnel who do not meet the requirements for this position should not be assigned to temporarily fill the position for periods exceeding three months.

NextEra Energy partially agrees with this exception as noted in the comment below.

  • NextEra Energy agrees with the modification to Item (3) in the Special Requirements of Section of 4.3.3 of the ANSI/ANS-3.1-2014 standard, that the majority of the station Radiation Protection Manager's (RPM's) experience should be relevant to supervising in-field Radiation Protection (RP) program activities (e.g., As Low As Reasonably Achievable (ALARA), RP operations, and radioactive waste shipping)).

Attachment L-2018-090 Page 3 of 5 However, NextEra Energy does not support this exception based on the following:

  • NextEra Energy does not agree with the addition to the experience requirements listed in Section 4.3.3 of the ANSI/ANS-3.1-2014 standard, that individuals with no prior RPM experience should have six (6) months of time onsite before being assigned RPM duties. NextEra Energy does not agree that licensees should evaluate required onsite time for experienced RPMs who are new to a site or a reactor technology. There is no previous requirement in Revisions 1, 2 or 3 of RG 1.8, nor is there any requirement in the previous ANSI 3.1-1978 or ANSI 18.1-1971 standards. NextEra Energy believes that this exception presents a new NRC staff position with no justification for the increased burden. The experience requirements in ANSI/ANS-3.1-2014 of one-month time during a refuel outage and two months experience at a reactor operating greater than 20% provide adequate experience for the position. Additionally, the ability to review and research records electronically to easily determine the location and performance characteristics of key equipment and other plant-specific information, strong technical training program for Radiation Protection, along with the various requirements in procedures, risk management processes, work management processes, and ALARA site challenge boards provide more than adequate barriers to preclude any issues that could be attributable to a lack of site-specific experience.
  • NextEra Energy does not agree with the addition of the wording in the exception that personnel who are temporarily assigned to fill the RPM position as described in Section 4.1 of the ANSI/ANS-3.1-2014 standard, and who do not meet the requirements to serve as an RPM should have first line supervisor experience of in-field RP program activities. NextEra Energy believes that this is already adequately covered in Section 4.1 of the standard based on the statement: "Individuals temporarily filling a position due to the absence of its principal individual shall
  • possess, as a minimum, the qualifications required for the corresponding position in the next lower functional level." The next lower functional level already meets or exceeds this requirement.
  • NextEra Energy does not agree with the addition of the wording in the exception that personnel who do not meet the requirements for this position should not be assigned to temporarily fill the *position for periods exceeding three (3) months as there is guidance covered in Section 4.1 of the ANSI/ANS-3.1-2014 standard that includes the following statement:

"Individuals shall meet the requirements for a given position. Individuals needing exceptions to this may be temporarily assigned to fill that position. Such assignments shall be justified and a time period for the temporary assignment

  • shall be specified and documented. Temporary assignments shall not reduce the collective experience requirements specified for that level."

Attachment L-2018-090 Page4of5 There is no justification for mandating a 3-month limit and in fact having this specified limit could cause additional personnel having to be assigned temporarily to the same role to meet an arbitrary time requirement. NextEra Energy's position is that the requirement in the ANSI/ANS-3.1-2014 standard to specify and document the time period for temporary positions is reasonable and appropriate.

3. DG-1329 Section 1.4 describes the following exception to the ANSI/ANS-3.1-2014, Section 4.4.1, "Senior Operator" criteria:

A non-licensed applicant (an instant candidate) for a senior operator (SO) license should have three years of responsible nuclear power plant experience. A professional engineering license or Bachelor of Science degree in engineering, engineering technology, or related sciences should only be allowed to account for a maximum of eighteen months of responsible nuclear power plant experience. A

  • Bachelor of Science degree in an area other than engineering, engineering technology, or related sciences should only be credited for a maximum of eighteen months if at least 80 semester hours (college credits) are in engineering, mathematics, chemistry, or physics. Applicants for an SO position who do not hold a bachelor's degree in engineering or the equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least one year at a commercial power reactor facility of the same vendor, or have 1. 5 years at a comparable or non-comparable commercial power reactor facility, or have at least two years of military experience in a position equivalent to a licensed reactor operator.

NextEra Energy does not support this exception as noted below.

  • NextEra Energy strongly disagrees with the proposed 3-year requirement for all non-licensed personnel. This exception imposes a 3-year experience requirement for all non-licensed personnel which would be in direct conflict with the NRG-endorsed ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators, " Figure 2-2, "Senior Reactor Operator Eligibility - RO Upgrade or Direct SRO Licensed at Another Facility or Direct SRO Military RO Equivalent, "and Figure 2..:3, "Senior Reactor Operator Eligibility- Direct SRO for Degreed Personnel."

Specifically, this new requirement would introduce conflicting requirements for the following candidate situations:

o A military candidate that does not have a degree (Figure 2-2).

  • o A non-licensed candidate but with a degree and 18 months at a comparable facility (Figure 2-3).

o A non-licensed candidate but with a degree and 27 months at a noncomparable facility (Figure 2-3).

  • NextEra Energy strongly disagrees with degree requirements specified, as it removes the flexibility of the non-traditional degree option in ACAD 10-001 that the NRC has already endorsed.

Attachment L-2018-090 Page 5of 5 NextEra Energy partially agrees with this exception as noted below. *

  • NextEra Energy agrees with the position pertaining to SO applicants "who do not hold a bachelor's degree in engineering or the equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least one year at a commercial power reactor facility of the, same vendor, or have 1. 5 years at a comparable or non-comparable commercial power reactor facility,. or have at least two years of military experience in a position equivalent to a licensed reactor operator." Although more restrictive than the guidance stipulated in the ANSI/ANS 3.1-2014 standard, it is aligned with ACAD 10-001 guidance which the NRC has already endorsed.

It is NextEra Energy's position that some of the exceptions noted in this draft RG related to Senior Operators appear to be in direct conflict to the NRC endorsement of ACAD 10-001, Revision 1. NextEra Energy would not necessarily be opposed to an exception that was aligned with ACAD 10-001 guidance. NextEra Energy suggests a possible resolution for this item that includes either of the following for an exception:

An applicant for a Senior Reactor Operator (SRO) license should meet the minimum qualifications, education, experience and training as specified in the facility licensee's "systematic approach to training" program.

OR An applicant for a Senior Reactor Operator (SRO) license should meet the Senior Reactor Operator Eligibility as *specified in ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators. "

4. NextEra Energy agrees with the exceptions as noted in DG-132.9 for the sections below and offers no additional comments for NRC consideration related to the draft RG.
  • DG-1329 Section 1.2 forANSI/ANS-3.1-2014, Section 4.3.1, "Training"
  • DG-1329 Section 1.5 for ANSI/ANS-3.1-2014, Section 4.4.2, "Senior Operator Limited to Fuel Handling"
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