ML25015A090
| ML25015A090 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/2025 |
| From: | Correll J NRC/NRR/DRO/IOLB |
| To: | James Anderson NRC/NRR/DRO/IOLB |
| References | |
| Download: ML25015A090 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO: James Anderson, Chief Operator Licensing and Human Factors Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Jeff Correll, Reactor Engineer (Examiner Qualified)
Operator Licensing and Human Factors Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF NOVEMBER 22, 2024, PUBLIC MEETING WITH REPRESENTATIVES OF INDUSTRY On November 22, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with representatives of the Nuclear Energy Institutes Licensed Operator Focus Group and other industry representatives.
The purpose of the meeting is for the NRC staff and industry representatives to discuss the administration of the NRCs Operator Licensing (OL) Program. Specifically, the NRC staff and industry representatives will discuss examination scheduling, the written examination outline generator, OL program feedback, ongoing regulatory activities, an effectiveness review of NUREG-1021 Revision 12, and the Office of Inspector General OL audit results.
Enclosures:
1.
List of Attendees 2.
Agenda 3.
Discussion Summary 4.
NEI Presentation CONTACT: Jeff Correll, NRR/DRO (301) 415-2414 January 23, 2025 Signed by Correll, Jeffrey on 01/23/25
ML25015A090 NRC-001 OFFICE NRR/DRO/IOLB NRR/DRO/IOLB NAME JCorrell JAnderson DATE 1/23/2025 1/23/2025 LIST OF ATTENDEES - NOVEMBER 22, 2024, PUBLIC MEETING WITH REPRESENTATIVES OF INDUSTRY Name Organization Russell Felts NRC*
James Anderson NRC*
Jeff Correll NRC*
Joey McPherson NRC*
Jesse Seymour NRC Matthew Fannon NRC Matt Emrich NRC Maurin Scheetz NRC Lauren Nist NRC Rebecca Riggs NRC Louis Betancourt NRC Thomas Farina NRC Travis Iskierka-Boggs NRC Brett Jebbia NRC Larry Criscione NRC Maryia Bahdanovich-Kniazkova NRC Mary H Miller NRC Joyce Tomlinson Institute of Nuclear Power Operations*
Tim Riti Nuclear Energy Institute*
Kostas Dovas Constellation Energy*
Tom Dean Constellation Energy*
Megan Parlett Constellation Energy*
Michael Peterson Xcel Energy*
Mike Schulte Tennessee Valley Authority*
Russell Joplin Tennessee Valley Authority*
Jesse Brown Constellation Energy David Gerads Unknown
2 Note: An asterisk (*) indicates attendance was in person. All other attendees participated via video teleconference.
LIST OF ATTENDEES - NOVEMBER 22, 2024, PUBLIC MEETING WITH REPRESENTATIVES OF INDUSTRY Name Organization Joshua Reuer Unknown Haydee Valazquez Unknown Enrique Melendez Unknown AGENDA FOR THE U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING WITH INDUSTRY OPERATOR LICENSING REPRESENTATIVES Friday, November 22, 2024 09:00 a.m. to 11:00 a.m. Eastern Standard Time Hybrid meeting TOPIC PRESENTER Opening Remarks NRC/Industry Examination Scheduling NRC Written Examination Outline Generator NRC Operator Licensing Program Feedback NRC Ongoing Regulatory Activities NRC NUREG-1021 Revision 12 Effectiveness Review NRC Office of the Inspector General OL Audit Results NRC Industry Topics Industry Public Comments Public Closing Remarks NRC/Industry DISCUSSION
SUMMARY
Introduction This public meeting between NRC staff (staff) and representatives of the industry was to discuss the operator licensing (OL) program administered by the NRC staff. Specifically, the NRC staff and industry representatives discussed examination scheduling, the written examination outline generator, OL program feedback, ongoing regulatory activities, an effectiveness review of NUREG-1021 Revision 12, the Office of Inspector General OL audit results, and industry topics of interest.
No regulatory decisions were made during the meeting.
Discussion The NRC staff opened the meeting by recognizing the important role that licensed operators have in nuclear safety. The NRC staff presented the ongoing examination scheduling process, including the current success of the process, while emphasizing that the NRC staff has a better chance of accommodating emergent changes to facility schedule changes when communicated early and often. The industry representatives highlighted their need to recruit and retain the best talent in the control room and emphasized the importance of open dialogue on examination scheduling. The industry representatives also referenced scheduling concerns with relation to responding to the annual operator licensing examination RIS and questioned if there should be more dynamic methods to schedule examinations including any opportunities to establish an online website submittal method for regional examination scheduling. The NRC staff stated that the annual operator licensing examination RIS responses are important to the budgeting and scheduling process used by the staff for allocating resources for operator licensing examinations. The NRC staff also offered that open communication between the regional examiners and the facilities is the best avenue for adjusting examination schedules.
The NRC staff gave a presentation about the development of a new sample plan generator, with an overview of the features available to automatically generate a sample plan consistent with NUREG-1021 requirements. A live demonstration of the sample plan generator was conducted by the NRC staff to showcase the generators capabilities. The industry representatives provided strong positive feedback regarding the capabilities. A question was asked about how someone could provide feedback on the generator if necessary. The NRC staff stated that the generator website has a submit feedback option available if necessary. NRC staff stated they expect the generator to be available for public use in the first half of 2025.
The NRC staff presented the status of operator licensing public feedback program (https://www.nrc.gov/reactors/operator-licensing/prog-feedback.html). Since December of last year, the NRC staff have added one new question to the OLPF, which was related to medical certifications for operators and operators license applicants. Some industry representatives stated that responses provided by the NRC to questions they asked via the program were very thorough and prompt and that they appreciated the effort by the NRC staff to respond to each question.
The NRC staff presented ongoing regulatory activities related to operator licensing, including the ADVANCE Act and its impact on current and advanced reactors. Section 507 of the Act directs the staff to, among other things, identify and assess measures to improve oversight and inspections, including elimination of areas of duplicative or otherwise unnecessary activities.
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One of the items the staff is assessing is the requirement for each region to prepare at least one exam per year. The current requirement was established as direction from the Commission to the staff in 1996, when the NRC was preparing to change Part 55 to allow facilities the option of preparing their own exams. Prior to that point, the NRC prepared all exams. While the assessment is ongoing, the NRC staff welcomes any feedback from the industry or members of the public not only regarding this potential change, but on any other operator licensing topics as well. Feedback can be provided here: https://www.nrc.gov/about-nrc/governing-laws/advance-act/contactus.html. The Licensed Operator Focus Group representatives stated that exams written by the NRC are not the most efficient and would be a good focus for Advance Act opportunities, suggesting that there are other tools that can be used to maintain NRC examiner proficiency. Industry representatives asked if there have been any consideration or initiative by the NRC to analyze the C-10 initial qualification requirements for writing a facility examination.
The NRC staff stated that there has been consideration about initial qualification requirements and are using the systems approach to training (SAT) to effectively analyze the job requirements. There has not been any decision on the subject yet. Some industry representatives stated that potential efficiencies can be found in travel, exam preparation, or how exam inspections are conducted. One industry representative provided an example of a recent operator licensing examination where the NRC chief examiner worked with the facility to optimize the schedule, reducing the number of scenarios required. Another example was provided regarding the option to perform administrative job performance measure validation remotely the week prior to the exam prep week, which allows traveling NRC staff to shorten their trip. The industry representatives encouraged the NRC to continue to pursue efficiency efforts.
The NRC staff also presented on Advanced Reactors and 10 CFR Part 53, which includes a new framework for staffing, personnel qualifications, training programs, operator licensing, and human factors engineering. Some of the provisions include load following, online refueling, customized staffing, engineering expertise, facility administered exams, and tailoring of exams.
Part 53 also introduces a new type of operator that would be licensed under a general license at certain facilities.
The NRC staff discussed a future update to NUREG-1220, Training Review Criteria and Procedures. The guidance will include the content and detail previously included in DRO-ISG-2023-04, Facility Training Programs, which was released in draft form (reference ML23017A130), to support the NRC staff to effectively review training programs.
The NRC staff presented the status of the NUREG-1021, Rev.12 effectiveness review. A two-year report has been written and will be issued with results and recommendations by the end of calendar year 2024. The staff discussed some findings from the report, including that there has been no significant change to pass/fail rates for initial licensing examinations under Revision 12.
Additionally, NRC examiners will be reviewing industry documentation related to reductions in requirements for extra person on shift time for license applicants, as the change should be made using the licensees SAT process. The staff stated that several examinations had generic fundamentals questions that lacked plausibility analysis, especially when these questions are pulled from the NRC GFE bank of questions that did not have plausibility analysis attached.
Future improvements to the guidance in NUREG-1021 for developing GFE questions will be included in the next revision. Additional guidance on developing critical tasks and documentation of the basis for time-based alternate boundary conditions will also be included in the next revision. The next revision of NUREG-1021 is planned to be released after the effectiveness review is complete. Industry representatives stated that the changes made in revision 12 have not impacted success rates to classes and have had a great benefit in flexibility
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related to scheduling. Regarding the extra person on shift time, industry representatives stated that stations use SAT when making changes to program requirements including the time needed on shift to complete under instruction watches and tasks, and that OLPF 2.2.15 describes what should be considered when making changes to the shift time depending on if a licensee has a commitment to an older ANSI/ANS standard or Reg. Guide 1.8 revision.
The staff discussed the results of the Office of Inspector General (OIG) audit of the operator licensing program. OIG concluded that the NRCs oversight of the operator licensing examination process is effective, efficient, and reliable. However, the agency could benefit from providing additional guidance and clarity in NUREG-1021, and OIG recommended a revision to NUREG-1021. The report is available through the following link:
https://www.oversight.gov/report/NRC/Audit-US-Nuclear-Regulatory-Commission%E2%80%99s-Reactor-Operator-Licensing-Examination-Process. On October 29, 2024, the NRC issued a response to the OIG audit report (in ADAMS at ML24282A993),
indicating the NRCs agreement with the OIGs recommendation and timeframes for actions.
The NRC staff plan to issue a draft of a revision to NUREG-1021 for public comment by NLT CY2028. The draft revision will include edits to address the identified process gaps.
An industry representative discussed the topic of glass top simulators. A presentation was included; reference enclosure 4 of this report. The discussion included opportunities to expand the use of glass top, part task, and limited scope simulators. The discussion included the current use of glass top for training, but not evaluations. An example of potential evaluation was provided in an evaluation at the remote shutdown panel, which is currently simulated in the plant, but could be performed on a glass top panel. The industry representatives stated they would like to get better use out of the simulators and are interested in engagement with the NRC related to the role simulators can be used in the future. The NRC staff commented that endorsement of ANS 3.5, 2018, is currently in progress. The staff are open to new ideas on how to utilize glass panel simulators. Regulatory history intended to allow flexibility on the topic due to known advancement in technology. While the NRC staff doesnt have any specific guidance related on how to approach a glass top panel approval, it should be noted that regulatory guide endorsement of ANS 3.5 is only one method to meet the regulations; industry is fully capable of providing an alternate method with sufficient justification. Additionally, the NRC staff stated that methods of psychomotor evaluations need to address the efficacy of the evaluation instrument, because two-dimensional glass top simulators do not directly/exactly match the current plant components. Any new options must be defensible in examination validity.
An industry representative discussed the topic of Senior Reactor Operator (SRO) and Limited Senior Reactor Operator (LSRO) licenses. The industry is interested in the use of experienced SROs as LSROs at other similar facilities during refueling outages. This would involve dual licensing of SROs as LSROs at more facility sites. The industry representatives referenced NUREG-1021 Sections 7.1 and 7.2, regarding the administration of initial examinations and NRC requalification examinations for LSROs and the guidance in NUREG-1021 to request an additional LSRO license. For this type of licensing, the Nuclear Energy Institute is interested in developing industry guidance for sample exemption and waiver requests, management of licenses and program requirements, requalification examination requirements, and just in time training. The NRC staff asked when such industry guidance would be available. The industry representative stated that they expect it to be completed in the first half of calendar year 2025.
The NRC staff encouraged the industry to engage in the NRC through pre-submittal activities to ensure alignment in any review of industry guidance.
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Finally, the industry mentioned that there is an ANS conference on nuclear training and education and look forward to sharing with the NRC staff and would encourage anyone interested in attending to register.
Public Comments There were no public comments.
NEI PRESENTATION
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