ML23342A026

December 14, 2023, Presentation on NEI 23-01 Operator Cold Licensing Training Plan for Advanced Nuclear Reactors

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

NEI 23-01 Operator Cold License Training Plan for Advanced Nuclear Reactors December 14, 2023

©2023 Nuclear Energy Institute

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

• Allows06-13A to remain in place for any COL that chooses to use it

• 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 Retain the same minimum education requirement

• High school diploma or equivalent Update the experience requirement

• Existing Fleet Guidance

• Proposed ANR Guidance

• At least 18 months nuclear experience

• At least 6 months design specific nuclear

- or - experience

• 27 months of power plant experience - or -

• 12 months of power plant experience Additional specific requirements based on type (includes experience at other nuclear of nuclear facility and type of duties: 6 - 18 designs) months

Senior Reactor Operator Cold Licensing program entry requirements Existing Fleet Guidance Proposed ANR Guidance for

• Education

• Education

• BS degree

• HS diploma or equivalent

- AND -

• Internal Hiring Criteria Testing

- or - - or -

• Experience

• Experience

• HS diploma or equivalent - AND

• HS diploma or equivalent - AND

- one of the following: - one of the following:

• Previous RO or SRO license

• Previous RO or SRO license

• 24 months Military RO

• 24 months Military RO Equivalent Equivalent

• SRO Instructor time - evaluated

• SRO Instructor time by NRC on a case-by-case basis (NEI White Paper discussing education change)

Additional Cold Licensing training, & watchstanding requirements Existing NEI 06-13A Guidance Proposed ANR Guidance Cold License Training program: Cold License Training program:

• Site Layout Course

• Site Layout Course

• 6 months Practical Work Experience

• 3 months Practical Work Experience

• Alternate Cold License method qual. guide (using

• Alternate Cold License method qual. guide Exemption)

Experience Equivalency (one of the following): Experience Equivalency (one of the following):

• 6 months of previous Hot Plant experience

• 6 months of previous Hot Plant experience

• 6 week Plant Operational Excellence Course

• 6 week Plant Operational Excellence Course (greenfield sites) (greenfield sites)

• 6 weeks of Preoperational testing experience

• 6 weeks of Preoperational testing experience

• 6 weeks of Hot Plant Observation (at similar design)

• 6 weeks of Hot Plant Observation (at similar design)

Crew Cumulative Nuclear Power Plant Experience: Crew Cumulative Nuclear Power Plant Experience:

• 13 years cumulative power plant experience, including

• 24 months cumulative nuclear plant experience (w/

6 years of cumulative nuclear plant experience (w/ at at least 1 crew member w/ Hot Plant experience 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