ML22180A243
| ML22180A243 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2022 |
| From: | Theresa Buchanan NRC/NRR/DRO/IOLB |
| To: | |
| Theresa Buchanan 301-415-2789 | |
| References | |
| Download: ML22180A243 (36) | |
Text
Trilateral Meeting with Canadian and Romanian Regulators June 30, 2022
Agenda
- Welcome and Introductions
- Canadian Presentation
- Romanian Presentation
- U.S. Operator Licensing Practices for Power Reactors Presentation
- U.S. Simulator Practices for Power Reactors Presentation
- U.S. Licensed Operator Requalification Program Inspections Presentation
- Q&A
Welcome and Introductions
- Jesse Seymour, Reactor Operations Engineer (Human Factors)
- Theresa Buchanan, Senior Reactor Operations Engineer (Examiner Qualified)
Canadian Presentation
Romanian Presentation
U.S. Operator Licensing Practices for Power Reactors Theresa Buchanan June 30, 2022 Disclaimer: the contents of this presentation do not necessarily indicate the Nuclear Regulatory Commissions views.
Overview
- Background of operator licensing in the U.S.
- Current U.S. regulations for power reactors
- Examination process overview
- Considerations under NEIMA and Part 53
- Proposed approach under Part 53
- Additional information
History
- NRC has been licensing operators for nuclear power plants since the 1950s
- Atomic Energy Act of 1954, as amended
- NRC must prescribe uniform conditions for licensing operators
- Nuclear Waste Policy Act of 1982, as amended
- NRC must establish regulations for training and qualification of nuclear power plant operators, supervisors, technicians and other operating personnel
- NRC must establish simulator training requirements for applicants for nuclear power plant operator licenses
Current U.S. Operator Licensing
- Title 10 of the Code of Federal Regulations Part 55
- Licensed as reactor operator or senior reactor operator
- Exam process is the same for power reactors regardless of vendor design
- Written exam, walkthrough, simulator scenarios
- NUREG-1021 provides guidance for this process
Current U.S. Operator Licensing
- Initial license exams approved and administered by NRC
- Facility may prepare the exams
- Knowledge and Ability catalogs provide exam content
- Catalogs developed from industry-wide job task analysis
- Catalogs are vendor-specific (ex, BWR vs. PWR)
NUREG-1021 Exams - Written
- 4-answer multiple choice
- Must meet technical accuracy and psychometric requirements
- RO - 75 questions
- Overall score to pass = 80%
- 25 SRO-only question passing score = 70%
NUREG-1021 Exams - Operating
- Includes both walkthrough and simulator scenario
- Walkthrough 4 - 5 administrative tasks 10 - 11 system tasks Administered to 1 individual at a time
NUREG-1021 - Operating
- Simulator scenarios Administered to a crew of 3 individuals 1 - 3 scenarios Dynamic Requires crew to respond to normal, abnormal and emergency events in real-time Quantitative and qualitative target attributes
NEIMA and 10 CFR Part 53
- Nuclear Energy Innovation and Modernization Act o Establish risk-informed, technology-inclusive framework for nuclear plant applicants
- Staff have issued preliminary rule language for 10 CFR Part 53 for stakeholder feedback o Part 53 Subparts F and P cover areas associated with plant operations and, while similar, reflect two distinct frameworks in Part 53
Part 53
- Integrated approach to human-system interactions
- Direct link from human factors engineering, staffing, and operator licensing requirements to design-specific safety functions
- HFE required where needed
- Not limited to control room
Part 53
- Operator staffing required as necessary to support fulfillment of safety functions
- Not a prescribed number of ROs and SROs
- Operator licensing flexibilities
- Not a single prescribed process
Part 53 - Operator Licensing Two approaches:
- Specific operator licenses
- Similar to current framework
- 2 license levels - RO and SRO
- Requires individual to apply and NRC to issue license in name of individual
- General reactor operator licenses
- New approach
- 1 license level
- Does not require individual to apply and license is embedded in the regulation
Part 53 - Operator Licensing
- Facility must develop exam process instead of being required to use NUREG-1021
- NRC reviews and approves the program
- Facility may administer exams
- NRC inspects
- Other requirements still apply
- Exam security, simulators, requalification, proficiency, license conditions
Additional Information
- White paper on Risk-Informed and Performance-Based Human-System Considerations for Advanced Reactors -
ADAMS Accession No. ML21069A003
- Current preliminary Part 53 rule language for operations:
o Part 53, Subpart F - ADAMS Accession No. ML22165A265 o Part 53, Subpart P - ADAMS Accession No. ML22145A000
- Stakeholder meetings, other public meetings, and opportunities to comment are posted on the NRCs public website at https://www.nrc.gov/pmns/mtg
U.S. Simulator Regulation:
Past, Present, and Future Jesse Seymour June 30, 2022 Disclaimer: the contents of this presentation do not necessarily indicate the Nuclear Regulatory Commissions views.
Overview
- Origins of existing simulator-related requirements
- General structure of existing requirements and associated guidance
- Considerations for future simulator requirements under preliminary, proposed 10 CFR Part 53 rulemaking
Statutory Basis Nuclear Waste Policy Act of 1982, as amended (NWPA), Section 306 states, in part, the following:
The Nuclear Regulatory Commission is authorized and directed to promulgate regulations, or other appropriate Commission regulatory guidance, for the training and qualifications of civilian nuclear power plant operators, supervisors, technicians and other appropriate operating personnel. Such regulations or guidance shall establish simulator training requirements for applicants for civilian nuclear powerplant operator licenses and for operator requalification programs [and] requirements for operating tests at civilian nuclear powerplant simulators
Regulatory Background
- The NRC first established simulator requirements in 1987; at that time, the NRC's considerations included the following:
o The NRC identified a need to clarify how simulators should be used, as well as to reflect upgraded training requirements following the accident at Three Mile Island o A requirement for having a simulation facility was established o Initially these simulation facility requirements were located with the operating test requirements of 10 CFR 55.45; they were later relocated to 55.46
Current Regulations and Guidance
- 10 CFR 50.34(f)(2)(i) - requires a simulator that models the control room and has small-break loss of coolant accident simulation capability for construction permit applicants
- 10 CFR 55.46 - addresses use of simulation facilities for administering operating tests and plant-referenced simulators for meeting operator license applicant experience requirements
- RG 1.149, Nuclear Power Plant Simulation Facilities for Use In Operator Training, License Examinations, and Applicant Experience Requirements; Rev. 4 of this Regulatory Guide provides endorsement of ANSI/ANS-3.5-2009
- ANSI/ANS-3.5, Nuclear Power Plant Simulators for Use in Operator Training and Examination
Other Considerations
- While the existing operator licensing examination process for power reactors requires a simulator to support both dynamic simulator scenarios and a subset of the job performance measures, the non-power (i.e.,
research and test) reactor operator licensing examination process does not require a simulator for the operating test.
- Beyond operator training and licensing, simulators are also relied upon for facility licensing actions, such as performance-based testing to support human factors engineering analyses, staffing validations, and overall adequacy of a new (or modified) design.
NEIMA and 10 CFR Part 53
- Consistent with Section 103 of Nuclear Energy Innovation and Modernization Act (NEIMA), the NRC staff have been engaged in efforts to establish a risk-informed, technology-inclusive regulatory framework for optional use by applicants for new commercial nuclear reactor licenses by December 31, 2027
- NRC staff are currently developing preliminary, proposed rule language under 10 CFR Part 53, along with associated key regulatory guidance documents
- Preliminary, proposed rule language has been released incrementally for stakeholder feedback; Part 53 has two frameworks with similar operations provisions under Subparts F & P
Human-System Integration
- Preliminary requirements in areas of human factors engineering (HFE), staffing, and operator licensing are directly linked to design-specific safety functions and their fulfillment
- HFE is required where needed to support safety functions, versus being limited to a control room
- Operator staffing is required to the extent necessary to support design-specific needs for safety function fulfilment, versus relying upon a prescribed number of reactor operators (RO) and senior reactor operators (SRO)
- The fundamental role of the licensed operator centers around the management and fulfilment of safety functions, in addition to the manipulation of facility controls
Preliminary Approach for Part 53
- Past NRC considerations regarding simulators had included:
o Flexibilities were historically provided to allow for potential use of the plant itself, and/or a plant-referenced simulator, and/or some other type of simulation device (such as a part-task or basic-principles simulator) o Intent was not to permit initiation of transients on the plant if used as a simulation facility; use of the plant was envisioned as an option in conjunction with another simulation device, in lieu of plant-referenced simulator o A present goal is for a regulation that is performance-based versus prescriptive to better account for future designs
Preliminary Simulator Requirements
- Preliminary, proposed Part 53 Subpart F and P language contains simulation facility requirements for facilities with licensed operators; key aspects are:
o Full-scope simulators are not mandated; partial scope simulators may be acceptable if adequate to meet needs o Simulation facilities must be approved by the Commission if relied upon for training purposes, meeting experience requirements, or for initial or requalification examinations o Prior to initial fuel load, simulator models are allowed to replicate the intended initial core loads
Additional Information
- A white paper on Risk-Informed and Performance-Based Human-System Considerations for Advanced Reactors is available via the NRCs Agencywide Document Access and Management System (ADAMS)
Accession No. ML21267A006
U.S. Licensed Operator Requalification Program Inspections Theresa Buchanan June 30, 2022 Disclaimer: the contents of this presentation do not necessarily indicate the Nuclear Regulatory Commissions views.
Current U.S. Regulations for Licensed Operator Requalification Title 10 CFR Part 55.59
- Every 2 years
- Biennial written
- Annual operating test
- SAT-based program
- If not SAT-based, additional regulatory requirements
- Facility administered
- Commission may administer
Requalification Inspections
- Biennial review
- Requalification exam licensed operator performance
- Quality of facility-developed exams
- Ability of facility to properly administer exams
- Maintenance of operator licenses
- Simulator performance
- Ability of facility to identify and resolve problems related to licensed operator performance
Requalification Inspections
- Performed during the annual op test administration
- Scheduled and announced
- If performance warrants, may
- Observe additional crews
- Perform IP 41500, Training and Qualification Effectiveness
- Perform NRC-conducted licensed operator requalification examination
Proposed Part 53 - Requalification
- Facility must develop requalification program requirements, including exams, based on SAT
- Requalification training & exam cycle duration is 2 years for reactor operators and senior reactor operators; flexible for generally licensed operators
- NRC must review and approve program
- NRC will issue guidance on this at a later date
- Facility will administer requalification program, including periodic exams
- NRC will periodically inspect
Q&A