ML24354A101

E-mail to NEI with Attachment: NEI 23-01 Questions and Additional Public Meeting Proposal

ML24354A101
Person / Time
Issue date:	12/05/2024
From:	Theresa Buchanan NRC/NRR/DANU/UARP
To:	Nuclear Energy Institute
References
Download: ML24354A101 (1)

Text

From:

Theresa Buchanan To:

sjy@nei.org Cc:

Steven Lynch (They/Them/Theirs); Michael Wentzel; James Anderson (He/Him); Maurin Scheetz

Subject:

NEI 23-01 Questions and Additional Public Meeting Proposal Date:

Thursday, December 5, 2024 3:58:00 PM Attachments:

Clarifying Questions on NEI 23-01 Rev. 0.pdf

Stewart,

I have attached a copy of the NRC staffs proposed clarifying questions to assist in their review of NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, Rev. 0. Due to the number and scope of the questions, we would like to propose discussing those questions you and your staff are prepared to discuss at the Advanced Reactor Stakeholder meeting on December 12, and to provide an opportunity to discuss the remaining questions at a separate public meeting the following week. Therefore, I am reaching out to ask for NEIs availability for a public meeting the week of December 16th. We could support a public meeting the morning of December 19th if that would work for you.

Thanks,

Theresa Buchanan Project Manager 301-415-2789

1 Clarifying Questions for NEI-23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, Revision 0

1. The Introduction section on page 1 of the document states, The guidance document establishes an approach to meeting the requirements in 10 CFR 55 for the training of licensed operators. The NRC staff observes that the guidance in NEI 23-01 concerns portions of the Commissions regulations associated with the selection, qualifications, and training for nuclear power plant personnel. Commission regulations regarding qualifications are also found in 10 CFR 50.120, Training and Qualification of Nuclear Poer Plant Personnel, 10 CFR 50.34(b)(6(i), and 10 CFR 52.79(a)(26). Additionally, NUREG-1021 contains the guidance for operator license qualifications. NUREG-1021 define qualifications as :

Eligibility refers to the necessary qualifications and training for applicants seeking an operator license. Qualifications include education, experience, and other requirements to meet job performance criteria. Training refers to an instructional program designed to develop or improve job performance.

Does NEI intend that NEI-23-01 be used for Part 55 training only?

2. Regarding the term Alternate Cold License Methods for OJT/TPE defined on page 1: why is this considered an alternate cold license method? What cold license method is it provided as an alternate to?

3. Regarding the definition of Crew Cumulative Nuclear Power Plant Experience on page 2, what is the basis for the requirement for 24 months of nuclear power plant experience for each crew as compared to the 6 years of nuclear plant experience required by NEI-06-13A?

How was 24 months determined? Does NEI anticipate that this requirement applies regardless of the number of licensed operators on shift as determined by a staffing plan analysis for the design?

4. Regarding the definition of Hot Plant Experience on page 2, is this experience gained in any position at an operating reactor? NEI-06-13A specifies that hot plant experience is gained through the performance of SRO duties for at least six months which includes at least 6 weeks of operating above 20 percent power. In other words, what does work experience and that experience in the definition entail?

5. General comment: the definitions provided in the Definitions section sometimes contain requirements and sometimes do not. For example, Figures 1, 2 and 3 state that 6 months of hot plant experience is required but the definition for hot plant experience only states that hot plant experience must include 6 weeks of operation above 20% power. The 6-month requirement for hot plant experience is found in the definition for hot plant observation.

6. The definition for Hot Plant Observation on page 2 contains a requirement that Candidates who do not have 6 months of hot plant experience prior to entering their training program may perform at least 6 weeks of structured observation or operating crews or complete a plant operational excellence course. The term may implies that there are other options

2 and that this is a suggestion instead of a requirement. Is that the intent of the use of the term may?

7. The definition of Plant Operational Excellence Course on page 3 also uses the term may which suggests that the requirement for candidates that do not have 6 months of hot plant experience have the option to complete a plant operational excellence course in lieu of performing hot plant observations. Are both optional if the candidate does not have hot plant experience?

8. The definition of Preoperational Test Experience on page 3 states that Candidates who do not have 6 months of hot plant experiencemay participate in at least 6 weeks of control room activity during the site preoperational testing phase. Is this a requirement or an option?

9. From page 3, please clarify whether the date that military nuclear-power-plant-related initial training is completed implies the end of Navy Nuclear Power School or Prototype training?

10. The definition of Site Layout Course on page 4 contains a statement:

The education, experience, and training requirements needed for an initial license operator training course during the plant construction phase (Cold Licensing) of an Advanced Nuclear Reactor (ANR) as a Reactor Operator Candidate are provided here and shown in Figure 1.

Is this statement for the definition misplaced or an error?

11. The definition of SRO Certified Instructor contains a requirement that the SRO certified instructor completes an annual performance examination and a biennial comprehensive written examination. What is the annual performance examination? Is that the same as an annual operating test?

12. Section 3.1 Minimum Educational Requirements on page 4 states that In order to ensure the health and safety of the public, the applicant will need to validate that the direct SRO can meet certain criteria to ensure that they can perform the function of an SRO following their training. The staff would like to know what criteria will be used to ensure that the SRO can do their job?

13. How is direct SRO defined? It would be helpful to understand what the starting point is for a direct SRO. Elsewhere in the guidance, it seems a direct SRO is one without nuclear experience, but the term direct SRO is not used on Figure 2.

14. According to the official ASVAB website reference by the US Navy, The ASVAB tests are designed to measure aptitudes in four domains: Verbal, Math, Science and Technical, and Spatial. How is the ASVAB being used to meet qualification requirements? Why is the ASVAB used for an SRO candidate and not a RO candidate? The staff is trying to understand the purpose of the ASVAB testing requirement.

3

15. What training program is Section 3.1 on page 5 referring to in this sentence:

The training program would then be based on the starting point for the individuals defined by the minimum standards from this test. Is this part of the Systems Approach to Training process? It seems to imply that training programs will be created on an individual basis. Is that correct?

16. Does NEI have an example of how a facility licensee can screen for leadership capability?

The staff finds the criteria of mature enough on page 5 too subjective and the staff wants to understand how this will be determined consistently. Why is the check for leadership capability performed for SROs without nuclear experience/degree and not SROs with nuclear experience? If an applicant has an associates degree, then the staff understands that this leadership capability check is not required; is that a correct interpretation of Section 3.1? If so, how does an associates degree satisfy the need for leadership capability or skills? Where is this check for leadership capability on the Figures 2 and, if applicable, Figure 3?

17. Section 3.1 on page 5 states that:

The use of an associate degree or bachelors degree as the minimum educational requirement complies with the current recommendation from industry groups and may not require the same entrance exam as someone coming in with only a High School diploma.

The staff would like to know more about the current recommendation from industry included if this is documented elsewhere?

The staff would like to better understand this statement: does this mean to say: An SRO candidate that has an associate degree or bachelors degree does not require an entrance exam? Does the entrance exam mean the ASVAB?

The staff is interested in understanding the basis for setting the level of competency for direct-SRO entry criteria at an associate degree including any benchmarking or operating experience that NEI may have collected to make this determination.

Regarding the associates degree: is this from an accredited institution? Are there other limits on types of associates degrees, for example, can an Applied Associates of Science be used?

A job analysis is usually performed to determine minimum education requirements for a specific job. Was any job analysis performed to determine these education requirements?

18. On page 6, the requirements for Crew Cumulative Nuclear Power Plant Experience states that additional experience requirements are added to the watch standing routine for the first operating cycle following initial plant startup. What does the terms watch standing routine mean? Is that different from the on-shift crew?

4

19. Please walk us through Section 3.6 Cold Licensing Process Applicability and Termination on page 6. These two statements appear to contract each other:

The Cold Licensing process described in this document may be applied to each unit of a multi-unit site, for any licensed operator training class started prior to initial fuel load.

The Cold Licensing process will terminate after completion of the first refueling outage, or after two years of commercial operation, whichever occurs first.

Does cold licensing end with initial fuel load or first refueling outage? Does initial fuel load mean for the first unit, or can the process be used before the initial fuel load of the second unit? How is this requirement applied to a facility that does online refueling (i.e., without a refueling outage)?

20. Given the different education requirements for direct SROs (different from those in existing guidance documents for eligibility requirements), does NEI envision that education requirements for direct-SROs will match existing requirements for 4-year technical degrees following the completion cold licensing?

21. On Figure 3 page 12, why is SAT Training Program listed above the training program requirements in Figure 3 and not Figure 1 and 2?

22. Based on experience, the staff wants to share another area where cold license guidance may be helpful is regarding the timeframe for licensing operators before the plant is operational. If licenses are issued and the unit(s) are still under construction, how can licensed operators satisfy requirements for actively performing the functions of an operator or senior operator and maintain active status (reference 10 CFR§55.53(e))?