ML24032A091
| ML24032A091 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/2024 |
| From: | Ober R NRC/NRR/DANU/UARP |
| To: | Steven Lynch NEI Nuclear Systems Ltd, NRC/NRR/DANU/UARP |
| References | |
| Download: ML24032A091 (4) | |
Text
MEMORANDUM TO:
Steven T. Lynch, Chief Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Rebecca A. Ober, Project Manager Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE DECEMBER 14, 2023, OBSERVATION MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTE REGARDING DRAFT NEI 23-01, OPERATOR COLD LICENSE TRAINING PLAN FOR ADVANCED NUCLEAR REACTORS.
On December 14, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with the Nuclear Energy Institute (NEI) to discuss the draft technical report NEI 23-01, Operator Cold License Training Plan for Advanced Reactors. The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML23345A169, and the presentation slides are available at ADAMS Accession No. ML23342A026. The enclosure to this summary provides the attendees for the meeting as captured by Microsoft Teams.
The purpose of this meeting was for NEI to present their slides on draft NEI 23-01 and to facilitate a discussion with NRC staff. NEI 23-01 is being developed to provide guidance for licensees of advanced nuclear reactors to utilize when licensing operators on a plant that has not yet been constructed or is in the process of being constructed.
CONTACT: Rebecca A Ober, NRR/DANU 301-289-9299 February 16, 2024 Seymour, Jesse signing on behalf of Ober, Rebecca on 02/16/24
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Meeting Highlights NEI presented their slides on the draft NEI 23-01, highlighting the differences of NEI 06-13A, Template for an Industry Training Program Description, which initiated the following discussion points:
o Slide 5 - NRC staff asked for clarification on the minimum cumulative crew nuclear power plant experience (NEI 06-13A requires 6 years but 23-01 changes to 24 months) and the assumptions used for crew size. In addition, NRC staff noted that in NEI 06-13A, all 6 years of the minimum cumulative crew experience shall not be attributed to one crew member, but this caveat is not explicitly stated in NEI 23-01. NRC staff asked for the rationale behind this change and if there would be a maximum amount of time the control room could be without an experienced operator.
NEI explained that the difference in crew size and composition for advanced reactors impacted the minimum cumulative crew nuclear power plant experience. In addition, allowing one operator to hold the full minimum plant experience is because the sharper nuclear-specific requirements means that this operator would have completed a full operating cycle at another plant. NEI did state that some clarification of applicability could be helpful, and it would be discussed with the working group.
o Slide 5 - NRC staff noted that the change in education requirements for the non-experienced senior reactor operator (SRO) eligibility track means that the Plant Operator Selection System test is the only difference between SRO and reactor operator (RO) eligibility criteria.
NEI explained that while the entry criteria changed, each RO and SRO candidate would still have to successfully complete the rigorous, NRC-approved nuclear-specific training program before receiving their operating license. The intent of this change is to shift the judgement of competency to the end of the program instead of at the entry criteria.
o Slide 7 - NRC staff asked for clarification on the SRO instructor time that could be used for the SRO licensing entry requirement. Although NEI 06-13A states that the necessary amount of equivalent time would be determined on a case-by-case basis, 4 years has been the accepted standard. In NEI 23-01, the SRO instructor equivalent time drops to 18 months which is a significant departure.
NEI explained that the training program length for these new plants is significantly different (i.e., 9 months plan for NuScale) so in the 18-month period, the trainer would have conducted two full training cycles.
However, NEI recognized that this is a departure from currently accepted requirements and would be open to further discussion.
o Slide 7 - NRC staff had multiple questions regarding the change in education entry requirement for SROs.
NEI stated that their justification was detailed in the White Paper submitted to NRC and were not prepared to go into detail on this topic during the public meeting.
o Slide 8 - NRC staff asked for clarification on the current guidance in NEI 06-13A for alternate cold license qualification methods and how it will be utilized in NEI 23-01.
NEI explained that when in-plant walk-throughs are not feasible (i.e., the plant is still under construction), the licensee requests an exemption from this requirement and instead utilizes another method, like tabletops, to
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complete this training. NEI is hoping to streamline this approach in NEI 23-01.
o Once NEI had concluded their presentation, NRC staff reviewed the 1989 Commission Policy Statement on, Education for Senior Reactor Operators and Shift Supervisors at Nuclear Power Plants (54 FR 33639). Specifically, the staff noted that this policy statement recognizes that the safety of commercial power reactors is enhanced with a team on NRC-licensed professionals that combine technical and academic knowledge, training, and hands-on experience.
Considering this policy, NRC staff had additional questions including the following:
NRC staff noted that other guidelines clarify that the comparable military experience does not start until after the final phase of training, but that clarification was not included in NEI 23-01. NRC staff asked if this was intended and, if so, what was the justification.
NEI stated that a shift was not intended and plan to stay with accepted practices. NEI will work on clarifying the language.
NRC staff requested clarification on applicability. Specifically, could a new construction large light-water reactor (LLWR) utilize this guidance instead of NEI 06-13A?
NEI explained that the NEI 23-01 guidance could be used by LLWRs as well, but also that the intention was for NEI 23-01 to only cover the cold operator licensing phase (i.e., facilities would transition to guidance such as NEI 06-13A once operations had commenced).
o NRC staff noted that NEI 23-01 didnt address 10 CFR 55.53(e) for conditions of licenses (i.e., proficiency requirements). Specifically, the staff inquired as to what would happen if a license was issued to an operator, but then the plant did not commence operations for a significant length of time thereafter? The staff asked whether NEI 23-01 will discuss the acceptable activities that can be used as a means for operators to maintain this condition of their license.
NEI stated that they did not intend to invent something new but, instead, assume that each facility or fleet will develop their own guidance within this area.
To finish the meeting, all stakeholders were given the chance to ask a question.
o Gregg Crannick, from X-energy, asked the NRC about the purpose of the training program. Specifically, shouldnt the NRC-approved training program be sufficient without requiring a college degree for SRO candidates?
NRC staff discussed the current Commission policy which highlights that a range of experience and education is optimal in the control room. In addition, to be in the control room, the NRC requires both training and qualifications to be met. For certain positions, the qualifications may include higher levels of education and experience.
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SUBJECT:
SUMMARY
OF THE DECEMBER 14, 2023, OBSERVATION MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTE REGARDING DRAFT NEI 23-01, OPERATOR COLD LICENSE TRAINING PLAN FOR ADVANCED NUCLEAR REACTORS.
DISTRIBUTION:
Public ROber, NRR JSeymour, NRR SLynch, NRR LNist, NRR ADAMS Accession Number: ML24032A091 NRC-001 OFFICIAL RECORD COPY OFFICE NRR/DRO/IOLB/BC NRR/DANU/UARP/BC NRR/DANU/UARP/SS NAME LNist SLynch ROber DATE 2/14/2024 2/16/2024 2/16/2024