ML23342A026
| ML23342A026 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 12/14/2023 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NEI 23-01 | |
| Download: ML23342A026 (10) | |
Text
©2023 Nuclear Energy Institute NEI 23-01 Operator Cold License Training Plan for Advanced Nuclear Reactors December 14, 2023
Purpose Discuss NEI 23-01, Operator Cold Licensing Training Plan for Advanced Nuclear Reactors Focus on the differences between NEI 06-13A and NEI 23-01 Discuss how proposed changes to hot and cold licensing requirements for advanced reactor operator licensing and training programs will be reviewed
Cold Licensing Requirements - background Different requirements are needed for licensing operators during new construction and initial operation (cold licensing)
- Normal in-field SAT program elements cant be done until after the plant is built
- Additional non-traditional work experience and observation program method needed Vogtle 3&4 and VC Summer 2&3 cold license plan
- Developed in NEI 06-13A, Template for an Industry Training Program
- Entire document was completely incorporated by reference in associated COL
- Included all training programs required by 10 CFR 50.120 (All required SAT based programs), and 10 CFR 55.4 (Licensed Operators)
- For operator licensing the guidance also included both hot and cold licensing guidance
NEI 06-13A, Template for an Industry Training Program Description
- NEI 06-13A (continued)
- Endorsed by NRC SER, and incorporated by reference into their COL Created Hot Plant Observations, Practical Work Experience, Site Layout Course and Participation in Pre-Operational Test Program requirements Added a Crew Cumulative Work Experience requirement during plant startup
- Evolutions in plant design and operator staffing no longer align with last revision to NEI 06-13A Drawbacks Design specific control room staffing size Did not cover Alternate Cold License Methods for OJT/TPE
- NEI 23-01 is a stand-alone companion guide to NEI 06-13A
- Developed by an NEI joint working group, Operational Aspects of Advanced Reactors (OAAR)
- Improved alignment to Advance Nuclear Reactors (ANRs)
- Intended to cover cold licensing phase for ANRs
- Defer hot licensing requirements to NANT Guidance (ACAD 10-001)
Industry Guidance Document Changes NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors New document to provide specific guidance for ANR operator licensing during cold licensing phase
Eliminate hot license training program descriptions Differed to NANT guidance document ACAD 10-001 Add a specific definition for Advance Nuclear Reactors Revise the Crew Cumulative Nuclear Power Plant Experience requirements to meet smaller crew sizes Create a path for direct SRO eligibility crediting BS academic degree to HS diploma + POSS test Revise the standard to include flowcharts to establish eligibility, to better align with other guidance
Reactor Operator program entry requirements
- Existing Fleet Guidance
- At least 18 months nuclear experience
- or -
- 27 months of power plant experience Additional specific requirements based on type of nuclear facility and type of duties: 6 - 18 months
- Proposed ANR Guidance
- At least 6 months design specific nuclear experience
- or -
- 12 months of power plant experience (includes experience at other nuclear designs)
Retain the same minimum education requirement
- High school diploma or equivalent Update the experience requirement
Senior Reactor Operator Cold Licensing program entry requirements Existing Fleet Guidance Education BS degree
- or -
Experience HS diploma or equivalent - AND
- one of the following:
Previous RO or SRO license 24 months Military RO Equivalent SRO Instructor time - evaluated by NRC on a case-by-case basis Proposed ANR Guidance for Education HS diploma or equivalent
- AND -
Internal Hiring Criteria Testing
- or -
Experience HS diploma or equivalent - AND
- one of the following:
Previous RO or SRO license 24 months Military RO Equivalent SRO Instructor time (NEI White Paper discussing education change)
Additional Cold Licensing training, & watchstanding requirements Existing NEI 06-13A Guidance Cold License Training program:
Site Layout Course 6 months Practical Work Experience Alternate Cold License method qual. guide (using Exemption)
Experience Equivalency (one of the following):
6 months of previous Hot Plant experience 6 week Plant Operational Excellence Course (greenfield sites) 6 weeks of Preoperational testing experience 6 weeks of Hot Plant Observation (at similar design)
Crew Cumulative Nuclear Power Plant Experience:
13 years cumulative power plant experience, including 6 years of cumulative nuclear plant experience (w/ at least 1 crew member w/ Hot Plant experience)
Proposed ANR Guidance Cold License Training program:
Site Layout Course 3 months Practical Work Experience Alternate Cold License method qual. guide Experience Equivalency (one of the following):
6 months of previous Hot Plant experience 6 week Plant Operational Excellence Course (greenfield sites) 6 weeks of Preoperational testing experience 6 weeks of Hot Plant Observation (at similar design)
Crew Cumulative Nuclear Power Plant Experience:
24 months cumulative nuclear plant experience (w/
at least 1 crew member w/ Hot Plant experience
Path Forward/Questions
- Solicit stakeholder feedback
- Update NEI 23-01, approve document
- Provide to NRC for endorsement
- Publish for the industry to use
Acronyms ACAD National Academy for Nuclear Training Academy Document ANR Advanced Nuclear Reactors CFR Code of Federal Regulations COL Combined license COLA Combined License Application INPO Institute of Nuclear Power Operations NANT National Academy for Nuclear Training NEI Nuclear Energy Institute NRC The U.S. Nuclear Regulatory Commission POSS Plant Operator Selection System SER Safety Evaluation Report RO reactor operator SRO senior reactor operator