ML082950140

Final Safety Evaluation for Topical Report NEI 06-13A, Template for an Industry Training Program Description, Revision 1

ML082950140
Person / Time
Site:	Nuclear Energy Institute
Issue date:	12/05/2008
From:	William Reckley NRC/NRO/DNRL
To:	Bell R Nuclear Energy Institute
Burrows, S A, NRO/DNRL/NRGA, 415-6086
References
NEI 06-13A, Rev 1
Download: ML082950140 (10)

Text

December 5, 2008 Mr. Russell J. Bell, Director New Plant Licensing Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

FINAL SAFETY EVALUATION FOR TOPICAL REPORT NEI 06-13A, TEMPLATE FOR AN INDUSTRY TRAINING PROGRAM DESCRIPTION, REVISION 1

Dear Mr. Bell:

On September 5, 2007, the U.S. Nuclear Regulatory Commission (NRC) accepted the Nuclear Energy Institute (NEI) 06-13, ATemplate for an Industry Training Program Description,@

Revision 0 as an acceptable template for describing reactor operator (RO) and non-licensed plant staff training programs for combined license applications (COLAs). By letter dated March 28, 2008, the NEI submitted NEI 06-13A, ATemplate for an Industry Training Program Description,@ Revision 1, for NRC review and approval. The change to NEI 06-13A is the addition of Appendix A, Cold License Training Plan. The change to NEI 06-13A, Revision 1 is exclusive to the addition of the Appendix A and the remainder of the template has not been changed. NEI 06-13A, Revision 1 provides a generic training program description for use with COLAs. In addition, Appendix A to NEI 06-13A, Revision 1 provides licensed operator cold license eligibility guidance. NEI 06-13A, Revision 1 was developed by the NEI New Plant Training Task Force, which includes representatives from the four design-centered working groups, to assist in expediting NRC review of the combined license (COL) and issuance of the COL.

Enclosed is the staffs safety evaluation (SE) which defines the basis for acceptance of NEI 06-13A, Revision 1. The NRC staff finds that for COLAs, NEI 06-13A, Revision 1, provides an acceptable template for describing the licensed operator training program, the licensed operator cold license eligibility requirements, and the non-licensed plant staff training program.

Our acceptance applies only to material provided in NEI 06-13A, Revision 1. We do not intend to repeat our review of the acceptable material described in the NEI 06-13A, Revision 0. When NEI 06-13A, Revision 1 appears as a reference in COLAs, our review will ensure that the material presented applies to the specific application involved. Licensing requests that deviate from NEI 06-13A, Revision 1, will be subject to a plant-specific or site-specific review in accordance with applicable review standards.

In accordance with the guidance provided on the NRC website, we request that NEI publish the accepted version of NEI 06-13A, Revision 1 within 3 months of receipt of this letter. The accepted version should incorporate this letter and the enclosed SE. The accepted version should also contain historical review information, including NRC requests for additional information and your responses. The accepted versions shall include a "-A" (designating accepted) following the report identification symbol.

If future changes to the NRC's regulatory requirements affect the acceptability of NEI 06-13A, NEI will be expected to revise NEI 06-13A appropriately, or justify its continued applicability for subsequent referencing.

If you have any questions, please contact Sheryl A. Burrows at (301) 415-6086 or via email at Sheryl.Burrows@nrc.gov.

Sincerely,

/RA/

William D. Reckley, Chief Rulemaking, Guidance, and Advanced Reactors Branch Division of New Reactor Licensing Office of New Reactors Project No. 689

Enclosure:

Safety Evaluation cc w/encl: See next page

ML082950140 NRO-002 OFFICE DNRL/NRCA:PM DNRL/NRCA:LA DCIP/COLP:BC OGC DNRL/NRCA:BC NAME SBurrows RRobinson MJunge* MCarpentier WReckley DATE 10/23/2008 10/21/2008 9/30/2008 12/04/2008 12/05/2008 SAFETY EVALUATION REGARDING THE NUCLEAR ENERGY INSTITUTE ATEMPLATE FOR AN INDUSTRY TRAINING PROGRAM DESCRIPTION@

NEI 06-13A (REVISION 1)

1.0 BACKGROUND

On September 5, 2007, the U.S. Nuclear Regulatory Commission (NRC) accepted the Nuclear Energy Institute (NEI) 06-13, ATemplate for an Industry Training Program Description,@ Revision 0 (Agencywide Documents Access and Management System (ADAMS) accession no.

ML070950479) as an acceptable template for describing reactor operator (RO) and nonlicensed plant staff training programs for combined license applications (COLAs). By letter dated March 28, 2008, the NEI submitted NEI 06-13A, ATemplate for an Industry Training Program Description,@ Revision 1, for NRC review and approval. NEI 06-13, Revision 0, ATemplate for an Industry Training Program Description,@ was previously reviewed and approved on September 5, 2007 (ADAMS accession no. ML070950479). The change to NEI 06-13 is the addition of Appendix A, Cold License Training Plan. The change to NEI 06-13 is exclusive to the addition of the Appendix A. The remainder of the template has not been changed. In addition to providing a generic training program description for use with COLAs, NEI 06-13 provides licensed operator cold license eligibility guidance. The template and revision was developed by the NEI New Plant Training Task Force, which includes representatives from the four design-centered working groups, to assist in expediting NRC review of the combined license (COL) and issuance of the COL. Changes to NEI 06-13 were discussed at public meetings held on May 24, 2007, September 13, 2007, January 8, 2008, and March 5, 2008.

Prior to obtaining an operating license from the NRC and prior to entering a licensed operator training program, an applicant must satisfy certain nuclear power plant (NPP) experience requirements and perform specific operating plant evolutions as described in the Title 10 of the Code of Federal Regulations, Part 55 (10 CFR Part 55); Operators licenses, 10 CFR Section 50.120; Training and qualification of nuclear power plant personnel, Regulatory Guide (RG) 1.8, Revision 3; qualification and training of personnel for nuclear power plants, NUREG-1021, Revision 9; Operator Licensing Examination Standards for Power Reactors, and ANSI/ANS-3.1-1993; Selection, Qualification, and Training of Personnel for Nuclear Power Plants.

In 1984, an Industry Working Group met to define components of operating shift experience and establish acceptable methods of meeting this experience. On February 24, 1984, at a meeting before the Commission, the industry presented the industry position on the level and type of operating shift experience required for the safe startup and initial operation of a nuclear generating plant. This industry position has come to be known as cold license eligibility.

The industry position for the licensed shift positions (shift supervisor, senior operator, and licensed operator) required power plant experience, nuclear plant experience, and hot operational experience. The experience requirements were derived from ANSI/ANS-3.1-1981, Selection, Qualification and Training of Personnel for Nuclear Power Plants, and required additional hot plant shift time within each crew.

Enclosure

The power plant experience requirement provided assurance of a minimum of 13 years per shift crew. The nuclear plant experience requirement could be met using experience equivalencies derived from ten categories of experience, with specific weighting factors and maximum time credited to each category and required a minimum of six years equivalent experience per crew.

Each crew was required to have hot-participation experience within the crew. Hot participation was defined as direct involvement in reviews and discussions leading to decisions relative to the operation of a commercial nuclear plant, or, direct hands-on operation as a trainee at a commercial NPP. Hot participation included six weeks participation in senior reactor operator (SRO) and RO duties at an operating plant of the same type (commercial boiling-water reactor (BWR) or pressurized-water reactor (PWR)), Shift Supervisor participation in reactor startup and shutdown at the same type plant, or six weeks participation as an SRO-Licensed STA participation at an operating plant of the same type.

In addition, if any hot participation experience requirement was not satisfied by either the Shift Supervisor or Senior Operator, a Qualified Advisor must be on shift.

Generic Letter (GL) 84-10, Administration of Operating Tests Prior to Initial Criticality informed licensees of actions to take for all applicants for RO and SRO licenses at facilities prior to initial criticality who did not have extensive actual operating experience. The Commission authorized the staff to grant exemptions to those individuals who have completed a 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 the actual system design of the candidate's plant. An exemption request was not needed for individuals who completed a cold license training program that included the four elements. The necessary exemption was to be granted as part of the issuance of the operator's license, provided that the individuals records clearly indicated satisfactory completion of a program.

GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants discussed a June 14, 1984 letter sent to J. H. Miller, President, Georgia Power Company from the Chairman of the NRC, N. J. Palladino. The June 14, 1984 letter accepted, with some clarifications, the Industry Working Group proposal presented to the Commission on February 24, 1984. It was noted in GL 84-16 that acceptance of these experience requirements by the NRC does not alter the guidance for eligibility, included in RG 1.8 and NUREG-0737, for RO and SRO licensing examination candidates.

RG 1.8, Revision 2, Qualification and Training of Personnel for Nuclear Power Plants discusses cold license applicants. A cold license candidate is one that uses cold license eligibility guidance to sit for the operator licensing examination. Licensed operator candidates utilizing cold license eligibility guidance are examined using a cold license examination. Cold license examinations are defined as those examinations administered before the unit has completed preoperational testing and the initial startup test program. Hot examinations are those administered after this condition is attained.

10 CFR Part 55, Operators' licenses states The Commission shall use the criteria in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," in effect six months before the examination date to prepare the written examinationsand the operating

tests The Commission shall also use the criteria in NUREG-1021 to evaluate the written examinations and operating tests prepared by power reactor facility licensees ES-202, Preparing and Reviewing Operator Licensing Applications of NUREG 1021 states Regulatory Guide 1.8 (Revision 2 or 3) and the guidelines for education and experience promulgated by the National Academy for Nuclear Training (NANT) outline acceptable methods for implementing the Commissions regulations in this area. In addition, methods different from those set forth in Regulatory Guide 1.8 (Revision 2 or 3) or the NANT guidelines may be acceptable if a facility licensee provides an adequate basis for using such methods. Appendix A to NEI 06-13 is a different methodology for determining experience for new reactor licensed operators.

On May 24, 2007, NRC staff met with representatives of NEI, the nuclear industry, and new reactor vendors in a public meeting (ADAMS accession no. ML071220329). The purpose of this meeting was to discuss issues related to the NRC operator licensing program for COLAs. The industry proposed to use limited-scope simulators for operator training because of the aggressive timelines leading to fuel loading. In addition, plant-referenced simulators are not projected to be available for reactivity manipulations and reactor startup until eighteen months prior to fuel load, in time for the licensing examination. Existing licensed operator eligibility requirements and anticipated problems with 'cold licensing' of operators were discussed. NEI proposed to have the industry develop alternative requirements that leverage technology. Cold license examinations are administered before completion of pre-operational and initial startup testing. Anticipated difficulties include conducting systems training prior to construction of the systems, reactivity manipulations without a plant or plant-referenced simulator, and meeting operator experience guidance.

On September 13, 2007, NRC staff met with representatives of NEI, the nuclear industry, and new reactor vendors in a public meeting (ADAMS accession no. ML072770067) to discuss the operator licensing white papers (ADAMS accession no. ML072420450) submitted by NEI on August 21, 2007. The operator licensing white papers discuss cold licensing and training of the estimated 450 licensed operators which are projected to be necessary to operate the new NPPs.

Meeting participants agreed that existing regulatory guidance addresses the training and qualification needs of licensed operator candidates for operating reactors but does not address the situation in which the plant is not operational (i.e., under construction). In addition, guidance related to the cold licensing of operators needs to be developed so that clear, appropriate, and achievable training commitments can be documented in each facility's COLA. It was also agreed that any process should follow current operator licensing guidance for operating plants with additional guidance in the areas of experience requirements, training program implementation, job performance measures (JPMs) and on-shift on-the-job training (OJT) during construction, simulator training using a limited scope simulator, continuing training for license candidates, and licensing examinations.

Concerns expressed by the NRC during this meeting included documentation of individual experience, documentation of experience obtained while an individual is in a training status, consistent calculation of time spent obtaining experience prior to licensing, activities that count toward meeting the experience guidelines must be meaningful, and, operating crew overall experience levels.

On January 8, 2008, NRC staff met with representatives of NEI, the nuclear industry, and new reactor vendors in a public meeting (ADAMS accession no. ML080290034) to discuss the operator licensing white papers (ADAMS accession no. ML080150100) submitted by NEI on December 13, 2007. It was agreed that time spent obtaining experience prior to licensing must be meaningful and consistently calculated and the final determination of meeting the experience requirements rests with the NRC. Consensus was reached in the areas of training program accreditation and implementation, in-plant JPMs and on-shift OJT during construction, simulator training using a part task/limited scope simulator, continuing training prior to and following NRC licensing exams, and scheduling of licensing examinations. The NRC noted that additional guidance needs to be developed in the areas of documentation of individual experience and, operating crew overall experience levels.

On March 5, 2008, NRC staff met with representatives of NEI, the nuclear industry, and new reactor vendors in a public meeting (ADAMS accession no. ML080910315) to discuss the operator licensing white papers submitted by NEI on February 29, 2008. Consensus between the NRC and NEI was reached in the areas of training program accreditation and implementation, in-plant JPMs and on-shift OJT during construction, simulator training using a part task/limited scope simulator, continuing training prior to and following NRC licensing exams, scheduling of licensing examinations, documentation of individual experience, and, operating crew overall experience.

2.0 REGULATORY EVALUATION

The NRC staff verified that changes to NEI 06-13 comply with the following regulations, regulatory guidance, NUREGs, and industry standards:

- 10 CFR Part 50, ADomestic licensing of production and utilization facilities@

- 10 CFR Part 52, ALicenses, certifications, and approvals for nuclear power plants@

- 10 CFR Part 55, AOperators' licenses@

- RG 1.8, AQualification and Training of Personnel for Nuclear Power Plants@

- RG 1.149, ANuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations@

- NUREG-0800, Standard Review Plan (SRP), Section 13.2.1, AReactor Operator Requalification Program; Reactor Operator Training@

- NUREG-1021, AOperator Licensing Examination Standards for Power Reactors@

- ANSI/ANS 3.1-1993, ASelection, Qualification, and Training of Personnel in Nuclear Power Plants@

- GL 84-10, Administration of Operating Tests Prior to Initial Criticality

- GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants

3.0 TECHNICAL EVALUATION

The staff=s review of Appendix A, Cold License Training Plan to NEI 06-13A, ATemplate for an Industry Training Program description,@ Revision 1 (NEI 06-13), focused on the cold licensing

process for the selection, training and licensing of operators for the new nuclear plants. Specific areas of review included:

A. Experience Requirements for License Candidates B. Crew Experience Requirements during the First Year of Operation C. Training Program Accreditation and Implementation D. In-Plant JPMs and On-Shift OJT during the Construction Phase E. Simulator Training Using a Part Task/Limited Scope Simulator F. Continuing Training for License Candidates Prior to NRC License Exams G. Scheduling of NRC License Examinations H. Initiation of Licensed Operator Continuing Training 3.1 Licensed Operator Training Program Prior to Completion of the First Refueling Outage The Licensed Operator Training Program Prior to Completion of the First Refueling Outage section of NEI 06-13 states that persons eligible for the cold licensing process will be required to meet the following requirements:

RO candidates shall have a High School Diploma or equivalent SRO candidates shall have at least one of the following:

Previously held an SRO license at an operating NPP Previously held an RO license at an operating NPP Have a Bachelors Degree in engineering or science as defined by RG 1.8, Revision 3.

Two years military experience in a position equivalent to a RO.

NEI 06-13 states that experience as a licensed operator training instructor with an SRO certification is acceptable as experience for SRO candidates. As is the current NRC practice, the eligibility of licensed operator instructors to sit for the licensing examination will be evaluated on a case-by-case basis.

The requirements of this section are applicable to each unit of a multiple unit site.

The guidance in this section is equivalent to the guidance of RG 1.8, Revision 3, Qualification and Training of Personnel for Nuclear Power Plants, ANSI/ANS 3.1-1993, Selection, Qualification, And Training of Personnel for Nuclear Power Plants, and GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants, and is acceptable.

The cold licensing process for the selection, training and licensing of operators for the new nuclear plants adheres to current industry guidance for operating plants with exemptions and alternatives in the following areas:

3.1.1 Experience Requirements for License Candidates Licensed operator candidates do not need to satisfy all of the experience requirements prior to entering a licensed operator training program or sitting for the operator licensing examination.

Experience and performance requirements that have not been met when the operator licensing examination is administered shall be met prior to issuance of the individuals license after notification from the licensee that all experience and performance requirements have been met.

The NRC will determine the acceptability of experience for those candidates utilizing the alternative experience guidance.

The methods listed below are an acceptable method of providing the licensed operator candidate with meaningful experience on the reactor and at the site for which the license is sought. Methods for gaining meaningful experience include completing systematically designed training courses, and performing work assignments such as preoperational and startup testing, procedure development and validation, human factors engineering activities, task analysis verification, or conducting licensed operator classroom or simulator training. Additionally, for these activities to be considered meaningful, they must be associated with safety significant, defense in depth (DID), or major plant components or systems.

All cold licensed operator candidates will:

Complete a systematically designed site familiarization course.

Complete a site-specific non-licensed operator OJT program on selected non-licensed operator tasks. The tasks selected will be those tasks that are important to plant operation with regard to nuclear safety, DID, or that are risk significant.

Participate in work assignments for a minimum of six months that includes preoperational testing, and one or more of the following:

Procedure development and validation Human factors engineering activities Task analysis verification Licensed operator classroom presentations or simulator training implementation SRO cold license candidates will complete a site-specific SRO training course. SRO cold license candidates that do not have hot plant experience will complete a six week plant Operational Excellence course that will be completed either in a full scope plant simulator or through observation of control room activities at a similar type operating nuclear plant. The course will familiarize the candidate with the operational interfaces encountered in a nuclear plant control room.

Hot plant experience is defined as performance as a SRO for at least six months which includes:

At least 6 weeks of operation above 20 percent power A startup from subcritical to 20 percent power A shutdown from above 20 percent power to cold (less than 212°F) and subcritical Startup preparations following a fueling or refueling outage The startup, shutdown, and startup preparations may be performed at an operating plant or on a full scope plant simulator.

Table 1, Comparison of Hot and Cold License Guidance, lists the current experience requirement and the associated cold license experience method. Table 2, Illustration of Cold Licensing Plan by Candidate Type, lists the acceptable education and methods of obtaining equivalent experience for each type of licensed operator candidate.

The guidance in this section is equivalent to the guidance of RG 1.8, Revision 3, Qualification and Training of Personnel for Nuclear Power Plants, ANSI/ANS 3.1-1993, Selection, Qualification, And Training of Personnel for Nuclear Power Plants, and GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants and is acceptable.

3.1.2 Crew Experience Requirements during First Year of Operation The cumulative NPP experience for each operating crew shall be greater than six years. The cumulative power plant experience for each operating crew shall be greater than 13 years.

Operators obtain NPP experience by working at NPPs and military nuclear propulsion plants (performing activities equivalent to those performed by licensed operators), conducting licensed operator training, participating in new nuclear plant construction and testing, and completing academic degree requirements. Cumulative crew NPP experience is the sum of each individuals NPP experience after applying weighting factors and maximum credit limits in Table 3, Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies. When determining cumulative NPP experience, the entire six years experience shall not reside in one crew member.

The crews cumulative power plant experience is the sum of each individuals power plant experience. Operators obtain power plant experience by working at NPPs, conventional power plants and military propulsion plants (performing activities equivalent to those performed by non-licensed operators). Cumulative power plant experience does not utilize weighting factors or maximum credit limits.

In addition to the experience requirements described above, each operating crew shall be staffed with at least one SRO with hot plant experience. If a SRO with hot plant experience is not available, a shift advisor will be substituted. The shift advisor will have at least one year of on-shift licensed SRO experience at a similar type (PWR/BWR) operating plant and will have

completed a training program on the design/plant for which they will be advising. While observing crew performance, the shift advisor will make recommendations to the shift manager and will not interfere with the licensed responsibilities of the operating crew. The shift advisor will have direct access to plant senior management. Shift advisor duties include, but are not limited to:

Monitoring procedure adherence Observing the conduct of pre-job briefs, shift turnovers, plant evolutions, non-licensed operator rounds, plant tours, and post job debriefs Monitoring overall station risk.

The guidance in this section is equivalent to the guidance of GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants and is acceptable.

3.1.3 Conduct of OJT Until construction of the plant is complete, acceptable methods for the conduct of OJT include discussion, simulation, and use of mockup equipment and virtual reality technology.

Selection of the instructional setting is an integral part of the systems approach to the training process as defined in 10 CFR 55.4, Definitions. The guidance in this section meets the requirements of 10 CFR 50.120, Training and qualification of nuclear power plant personnel and is acceptable.

3.1.4 Use of Part-Task/Limited Scope Simulators With the exception of the Operational Excellence course, which will utilize a full scope plant simulator, part-task or limited scope simulators may be used during licensed operator training.

RG 1.149, Revision 3, Nuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations, allows the use of a simulation facility for RO and senior operator training. 10 CFR 55.4 defines a simulation facility as one or more of the following components, alone or in combination: used for either the partial conduct of operating tests for operators, senior operators, and license applicants, or to establish OJT and experience prerequisites for operator license eligibility:

(1) A plant-referenced simulator; (2) A Commission-approved simulator under 10 CFR 55.46(b); or (3) Another simulation device, including part-task and limited scope simulation devices, approved under 10 CFR 55.46(b).

This guidance in this section is acceptable for those part-task or limited scope simulators that meet the requirements of 10 CFR 55.46(b).

3.1.5 Licensed Operator Continuing Training Licensed operator continuing training will begin within 90 days following the issuance of the first operator license. Continuing training content will determined using a systems approach to training methodology to maintain operator skills, knowledge, and abilities.

10 CFR 50.54.I (i-1) requires that within three months after either the issuance of an operating license or the date that the Commission makes the finding under § 52.103(g) of this chapter for a COL, as applicable, the licensee shall have in effect an operator requalification program. The operator requalification program must, as a minimum, meet the requirements of 10 CFR 55.59(c). The guidance in this section meets the requirements of 10 CFR 50.54.I (i-1) and is acceptable.

3.1.6 Cold Licensing Process Applicability and Termination The cold licensing process may be applied to each unit of a multi-unit site.

Cold license guidance items 1 through 9 on Table 1 of NEI 06-13 will apply to any licensed operator training class started prior to initial fuel load. The cold licensing process will terminate after completion of the first refueling outage.

Cold license guidance items 3 through 9 on Table 1 of NEI 06-13 will apply to any licensed operator training class started after initial fuel load and before completion of the first refueling outage. Items 1 and 2 of the Table 1 cold license guidance will not be allowed after the initial fuel load.

As plant systems, components, and structures are completed and made operational, and as integrated plant operations start, systems approach to training methodology will be used to modify the cold license class training methods and settings. These modifications will optimize student learning using actual in-plant training and experience opportunities.

The guidance in this section is equivalent to the guidance of GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants and is acceptable.

3.1.7 Initial Licensed Operator Examination Schedule Administration of the initial licensed operator examination will be approximately 18 months prior to initial fuel load.

10 CFR 50.120 requires NPP operating license applicants, by 18 months prior to fuel load to establish, implement, and maintain training programs based on a systems approach to training.

The guidance in this section ensures licensed operator examinations are developed from training programs that meet the requirements of 10 CFR 50.120 and is acceptable.

4.0 CONCLUSION

Operator Licensing and Human Performance Branch (COLP) staff used the guidance and the acceptance criteria in the documents listed in Section 2.0 of this evaluation as the basis for evaluating the acceptability of NEI 06-13A, ATemplate for an Industry Training Program Description,@ Revision 1. The COLP staff has determined that NEI 06-13A, ATemplate for an Industry Training Program description,@ Revision 1 is consistent with the training and qualification requirements, guidance, and industry standards for licensed plant staff training and eligibility as outlined in Section 2.0 of this evaluation with verification of the implementation of the cold license training plan during the construction stage.

On the basis of its review, the staff concludes that NEI 06-13 A, ATemplate for an Industry Training Program description,@ Revision 1 adequately provides guidance for establishing the cold licensed operator eligibility guidance. Accordingly, the COLP staff concludes that NEI 06-13 A, ATemplate for an Industry Training Program description,@ Revision 1 complies with the applicable NRC regulations, guidance, and industry standards and can be utilized by applicants for COLAs.

5.0 REFERENCES

5.1 Roe, J. W., NEI, to the U.S. NRC, NEI 06-13A, ATemplate for an Industry Training Program Description, Revision 1," March 28, 2008.

5.2 NUREG-0800, SRP, Section 13.2.1, AReactor Operator Requalification Program; Reactor Operator Training.@

5.3 Miller, J. H., Jr., Industry Evaluation Of Operating Shift Experience Requirements, February 24, 1984.

5.4 Summary of May 24, 2007 Category 2 Public Meeting with NEI to Discuss New Reactor Operator Licensing Initiatives.

5.5 Summary of September 13, 2007 Category 2 Public Meeting with NEI to Discuss Issues Related to Implementation of New Reactor Operator Licensing.

5.6 Summary Of January 8, 2008 Category 2 Public Meeting with NEI to Discuss New Reactor Operator Licensing Initiatives.

5.7 Summary Of March 5, 2008 Category 2 Public Meeting with NEI to Discuss New Reactor Operator Licensing Initiatives.

5.8 GL 84-10, Administration of Operating Tests Prior to Initial Criticality.

5.9 GL 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants.

5.10 RG 1.8, Revision 3, Qualification and Training of Personnel for Nuclear Power Plants.

5.11 NUREG-1021, Revision 9, Operator Licensing Examination Standards for Power Reactors.

5.12 ANSI/ANS-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plants.

DCWG - Combined (All) (Revised 09/29/2008) cc:

Mr. Glenn H. Archinoff Director AECL Technologies Division of Compliance & Inspection 481 North Frederick Avenue Bureau of Radiation Control Suite 405 Texas Department of State Health Services Gaithersburg, MD 20877 1100 West 49th Street Austin, TX 78756-3189 Mr. Ray Aycock Field Supervisor Mr. Ray Ganthner U.S. Fish and Wildlife Service Senior Vice President Mississippi Ecological Services Office AREVA, NP, Inc. 3315 6578 Dogwood View Parkway Old Forest Road Jackson, MS 39213 P.O. Box 10935 Lynchburg, VA 24506-0935 Mr. Richard L. Baker Bechtel Power Corporation Mr. Eugene S. Grecheck 5275 Westview Drive Vice President Frederick, MD 21703-8306 Nuclear Support Services Dominion Energy, Inc.

Scott Bond 5000 Dominion Blvd.

Callaway Plant Glen Allen, VA 23060 P.O. Box 620 Fulton, MO 65251 Mr. Jay M. Gutierrez Morgan, Lewis & Bockius, LLP Ms. Michele Boyd 111 Pennsylvania Avenue, NW Legislative Director Washington, DC 20004 Energy Program Public Citizens Critical Mass Energy Ms. Sophie Gutner and Environmental Program P.O. Box 4646 215 Pennsylvania Avenue, SE Glen Allen, VA 23058 Washington, DC 20003 Mr. Brian Hastings Ms. Cindy Brizes Public Utility Commission U.S. Department of Energy William B. Travis Building P.O. Box A P.O. Box 13326 Aiken, SC 29802 1701 Noth Congress Avenue Austin, TX 78701-3326 Mr. Barton Z. Cowan, Esquire Eckert Seamans Cherin & Mellott, LLC Mr. Tim E. Herrmann 600 Grant Street, 44th Floor Vice President, Nuclear Engineering Pittsburgh, PA 15219 AmerenUE P.O. Box 620 Fulton, MO 65251

DCWG - Combined (All)

Mr. Ronald Kinney Mr. Ernest Reed South Carolina DHEC Living Education Center 2600 Bull Street for Ecology and the Arts Columbia, SC 29201 P.O. Box 2612 Charlottesville, VA 22902 Dr. Regis A. Matzie Senior Vice President and Mr. David W. Sutherland Chief Technology Officer Chesapeake Bay Field Office Westinghouse Electric Company U.S. Fish and Wildlife Service 20 International Drive 177 Admiral Cochrane Drive Windsor, CT 06095 Annapolis, MD 21401 Mr. Norris McDonald Mr. Robert E. Sweeney President IBEX ESI AAEA 4641 Montgomery Avenue 9903 Caltor Lane Suite 350 Ft. Washington, MD 20744 Bethesda, MD 20814 Dr. Masanori Onozuka Mr. Ed Wallace Mitsubishi Nuclear Energy Systems, Inc. General Manager - Projects 2300 Wilson Blvd. PBMR Pty LTD Suite 300 P. O. Box 9396 Arlington, VA 22201-5426 Centurion 0046 Republic of South Africa Dr. C. Keith Paulson Mitsubishi Nuclear Energy Systems, Inc. Mr. Gary Wright, Director 300 Oxford Drive, Suite 301 Division of Nuclear Facility Safety Monroeville, PA 15146 Illinois Emergency Management Agency 1035 Outer Park Drive PBMR Pty. Limited Springfield, IL 62704 Lake Buena Vista Building 1267 Gordon Hood Avenue PO Box 9396 Centurion 0046 Republic of South Africa Charles Peterson Pillsbury, Winthrop, Shaw & Pittman, LLP 2300 "N" Street, NW Washington, DC 20037

DCWG - Combined (All)

Email alsterdis@tva.gov (Andrea Sterdis) amonroe@scana.com (Amy Monroe)

APAGLIA@Scana.com (Al Paglia)

APH@NEI.org (Adrian Heymer) awc@nei.org (Anne W. Cottingham) barbara.lee-murphy@constellation.com (Barbara Lee-Murphy) barbara.perdue@unistarnuclear.com (Barbara Perdue) bevans@enercon.com (Bob Evans)

Bill.Moore@luminant.com (Bill Moore) bob.brown@ge.com (Robert E. Brown)

BrinkmCB@westinghouse.com (Charles Brinkman) brock.degeyter@energyfutureholdings.com (Brock Degeyter)

Carellmd@westinghouse.com (Mario D. Carelli) carey.fleming@constellation.com (Carey Fleming) chris.maslak@ge.com (Chris Maslak) ck_paulson@mnes-us.com (Keith Paulson) ckpaulson@aol.com (C.K. Paulson)

CumminWE@Westinghouse.com (Edward W. Cummins) cwaltman@roe.com (C. Waltman) dan1.williamson@ge.com (Dan Williamson) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis)

DeLaBarreR@state.gov (R. DeLaBarre) dlochbaum@UCSUSA.org (David Lochbaum) don.lewis@ge.com (Don Lewis) dpoole@luminant.com (David Poole) dwoodla1@luminant.com (Donald Woodlan) ecullington@earthlink.net (E. Cullington) eddie.grant@excelservices.com (Eddie Grant) erg-xl@cox.net (Eddie R. Grant)

Eugene_Grecheck@dom.com (Eugene S. Grecheck) frank_quinn@comcast.net (Frank Quinn)

Fred.Madden@luminant.com (Fred Madden) garry.miller@pgnmail.com (Garry D. Miller) gcesare@enercon.com (Guy Cesare) gedgar@morganlewis.com (George Edgar) george.honma@ge.com (George Honma) george.wadkins@ge.com (George Wadkins)

GovePA@BV.com (Patrick Gove) greshaja@westinghouse.com (James Gresham) gwcurtis2@tva.gov (G. W. Curtis) gzinke@entergy.com (George Alan Zinke) hickste@earthlink.net (Thomas Hicks) ian.c.rickard@us.westinghouse.com (Ian C. Richard)

DCWG - Combined (All) james.beard@gene.ge.com (James Beard)

JCaldwell@luminant.com (Jan Caldwell)

Jean.Amundson@luminant.com (Jean Amundson) jeff.simmons@energyfutureholdings.com (Jeff Simmons) jgutierrez@morganlewis.com (Jay M. Gutierrez) jim.riccio@wdc.greenpeace.org (James Riccio) jim@ncwarn.org (Jim Warren)

JJNesrsta@cpsenergy.com (James J. Nesrsta) joel.Friday@ge.com (Joel Friday)

John.Conly@luminant.com (John Conly)

John.O'Neill@pillsburylaw.com (John O'Neill) john.sorensen@ge.com (John Sorensen)

Joseph_Hegner@dom.com (Joseph Hegner) joseph_tapia@mnes-us.com (Joe Tapia) joseph_tapia@mnes-us.com (Joseph Tapia) junichi_uchiyama@mnes-us.com (Junichi Uchiyama) karen@seedcoalition.org (Karen Hadden) kcrogers@aol.com (K. C. Rogers)

KSutton@morganlewis.com (Kathryn M. Sutton) kurt.schaefer@ge.com (Kurt Schaefer) kwaugh@impact-net.org (Kenneth O. Waugh) lchandler@morganlewis.com (Lawrence J. Chandler) lois@ieer.org (Lois Chalmers) lou.lanese@ge.com (Lou Lanese)

Marc.Brooks@dhs.gov (Marc Brooks) maria.webb@pillsburylaw.com (Maria Webb) marilyn.kray@exeloncorp.com mark.beaumont@wsms.com (Mark Beaumont)

Marvin.Smith@dom.com (Marvin L. Smith) masanori_onozuka@mnes-us.com (Masanori Onozuka) masayuki_kambara@mhi.co.jp (Masayuki Kambara) matias.travieso-diaz@pillsburylaw.com (Matias Travieso-Diaz) maurerbf@westinghouse.com (Brad Mauer) mbowling@numarkassoc.com (Marty Bowling) media@nei.org (Scott Peterson) mgiles@entergy.com (M. Giles) mike.blevins@luminant.com (Mike Blevins) mike_moran@fpl.com (Mike Moran) mlucas3@luminant.com (Mitch Lucas)

MSF@nei.org (Marvin Fertel) mwetterhahn@winston.com (M. Wetterhahn) nirsnet@nirs.org (Michael Mariotte) pareez.golub@ge.com (Pareez Golub) patriciaL.campbell@ge.com (Patricia L. Campbell) paul.gaukler@pillsburylaw.com (Paul Gaukler)

DCWG - Combined (All)

Paul@beyondnuclear.org (Paul Gunter) peter.jordan@ge.com (Peter Jordan) phinnen@entergy.com (Paul Hinnenkamp) pshastings@duke-energy.com (Peter Hastings) rbird1@luminant.com (Bobby Bird) rclary@scana.com (Ronald Clary)

REB@NEI.org (Biff Bradley)

Rebecca.Smith-Kevern@nuclear.energy.gov (Rebecca Smith-Kevern)

RJB@NEI.org (Russell Bell)

RKTemple@cpsenergy.com (R.K. Temple) robert.kitchen@pgnmail.com (Robert H. Kitchen) roberta.swain@ge.com (Roberta Swain) sandra.sloan@areva.com (Sandra Sloan)

SauerB@BV.com (Robert C. Sauer) sfrantz@morganlewis.com (Stephen P. Frantz) shinji_kawanago@mnes-us.com (Shinji Kawanago) shinji_kawanago@mnes-us.com (Shinji Kawanago) sid.kere@dom.com (Sid Kere) steven.hucik@ge.com (Steven Hucik) steven.stark@ge.com (Steven Stark) tgilder1@luminant.com (Tim Gilder) tkkibler@scana.com (Tria Kibler) tom.miller@nuclear.energy.gov (Thomas P. Miller) tomccall@southernco.com (Tom McCallum) trsmith@winston.com (Tyson Smith)

Vanessa.quinn@dhs.gov (Vanessa Quinn)

VictorB@bv.com (Bill Victor) vijukrp@westinghouse.com (Ronald P. Vijuk)

Wanda.K.Marshall@dom.com (Wanda K. Marshall) wayne.marquino@ge.com (Wayne Marquino) whorin@winston.com (W. Horin)