ML25093A321
| ML25093A321 | |
| Person / Time | |
|---|---|
| Site: | 99902071 |
| Issue date: | 05/16/2025 |
| From: | NRC/NRR/DANU/UAL2 |
| To: | X-Energy |
| Shared Package | |
| ML25093A326 | List: |
| References | |
| EPID L-2024-TOP-0008 | |
| Download: ML25093A321 (1) | |
Text
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT REPORT XE-100 TRAINING PROGRAMS METHODOLOGY TOPICAL REPORT X ENERGY, LLC.
DOCKET NO. 99902071
1.0 BACKGROUND
By letter dated March 27, 2024, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24089A244), X Energy, LLC., (X-energy) submitted Revision 3 of the topical report (TR) titled, Xe-100 Training Programs Methodology, for the U.S. Nuclear Regulatory Commission (NRC) staffs review and approval. The TR provides the methodology for establishing, implementing, and maintaining Xe-100 training programs in support of future licensing applications regarding the Xe-100 technology.
The NRC staff issued its audit plan to X-energy on August 14, 2024 (ML24212A030), to support an audit using X-energys electronic reading room (eRR). During the audit, the NRC staff identified several areas in the TR that required further clarification. These observations were discussed with X-energy during audit meetings beginning August 22, 2024, and ending October 15, 2024. The NRC staff recommended that X-energy consider addressing the observations when revising the TR currently under the NRC staffs review.
2.0 AUDIT REGULATORY BASES The basis for the audit is the regulations in Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.120, Training and qualification of nuclear power plant personnel. The regulation under 10 CFR 50.120(b)(2) requires, in part, that the training program must be derived from a systems approach to training as defined in 10 CFR 55.4, Definitions. Regulation 10 CFR 55, Operator Licenses, Section 55.4, states, in part, that systems approach to training means a training program that includes the following five elements:
Systematic analysis of the jobs to be performed.
Learning objectives derived from the analysis which describe the desired performance after training.
Training design and implementation based on the learning objectives.
Evaluation of trainee mastery of the objectives during training.
Evaluation and revision of the training based on the performance of trained personnel in the job setting.
Enclosure 3.0 AUDIT PURPOSE AND OBJECTIVES The purpose of the audit was to enable the NRC staff to: (1) efficiently gain a more detailed understanding of X-energys training program methodology and, and (2) identify any information that will require docketing to support the development of the NRC staffs safety evaluation of the subject TR.
4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES During the audit, X-energy made the following documents available in the eRR:
TMX-1.0, Xe-100 Plant Training Manual TMX-1.1, Xe-100 SAT Methodology: Analysis Procedure TMX-1.2, Xe-100 SAT Methodology: Design Procedure TMX-1.3, Xe-100 SAT Methodology: Development Procedure TMX-1.4, Xe-100 SAT Methodology: Implementation Procedure TMX-1.5, Xe-100 SAT Methodology: Evaluation Procedure TMX-1.6, Xe-100 Exam Standard TMX-1.9, Xe-100 OJT, TPE, and Lab Standard Supporting procedure attachments and guides The audit followed the guidance in the Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274).
Members of the audit team are listed below.
Name Role Jeff Correll Reactor Engineer, Audit Technical Lead Adrian Muniz Senior Project Manager Ondra Dukes Project Manager 5.0
SUMMARY
OF OBSERVATIONS During the audit, the NRC staff reviewed the documents in the eRR identified above and provided questions to X-energy via Box for discussions during the audit meetings. X-energy posted the NRC staffs questions and the associated written responses into the eRR to support the audit meetings between the NRC and X-energy staff. During these meetings, NRC and X-energy staff discussed the questions and responses. A summary of the NRC staffs main observations is provided below.
Enclosure A. The NRC staff requested X-energy to provide clarification regarding the scope of the requested review in the TR.
The NRC staff identified inconsistencies in the scope of the requested review, based on different sections of the TR. The Synopsis, and Executive Summary sections of the TR state: This report is provided to request NRC review and approval of the Xe-100 methodology for developing facility training programs derived from a systems approach to training as required by 10 CFR 50.120 and in 10 CFR 55.4. However, section 1.4, Outcome Objectives, and section 5, Conclusions, state: X-energy is requesting NRC review and approval of the methodologies to develop the Xe-100 training programs described in Sections 3 and 4 of this TR to demonstrate compliance with developing facility training programs derived from a systems approach to training as required by 10 CFR [50.]120 and defined in 10 CFR 55.4.
The NRC staff discussed this topic with X-energy during audit meetings on September 25, 2024, and October 15, 2024. During these discussions, X-energy stated that it would clarify the scope in a revision to the TR. Following the audit, by letter dated December 9, 2024 (ML24344A156), X-energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
B. The NRC staff requested X-energy to provide additional details regarding the Competency Analysis process described in section 3.1.4 of the TR.
The NRC staff identified a lack of sufficient detail regarding the Competency Analysis process described in the TR. Section 3.1.4 of the TR describes X-energys Competency Analysis process. The TR states that a Competency Analysis gathers information from the collective experience, knowledge, and judgement of a group of experts to identify all competencies needed for a particular job. A Competency Analysis can evaluate a particular job, task, or a set of related tasks. Section 3.1.4 also states that the responsibilities of the Competency Analysis group may include the recommendation of learning objectives, thus combining parts of the analysis and design phases of a systems approach to training (SAT). While this is a novel approach to the SAT process, the TR does not appear to provide a sufficient level of detail for the NRC staff to adequately assess that the process conforms to the SAT process. If X-energy plans to seek approval of the Competency Analysis, then additional documentation and justification would be required for the inclusion of the Competency Analysis process in the NRC staffs safety evaluation of this TR. If not, the NRC staff plans to include a limitation on the TR.
The NRC staff discussed this topic with X-energy during audit meetings on September 25, 2024, and October 15, 2024. During these discussions, X-energy stated that it intended on revising the information pertaining to the Competency Analysis process in a revision to the TR. By letter dated December 9, 2024 (ML24344A156),
X-energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
Enclosure C. The NRC staff requested X-energy to provide clarification regarding the scheduled task list review process described in section 3.1.5.1 of the TR.
The NRC staff identified a lack of sufficient detail regarding the scheduled task list review process described in the TR. Section 3.1.5.1 of the TR states that the objectivity of the deterministic DIF process eliminates the need for a scheduled task list review.
Section 3.1.5.1 additionally states that: this approach does not require formal documentation of a full program review, but it ensures that all tasks, both selected and deselected, are consistently evaluated as needed.
During the audit, the NRC staff assessed the TR and supporting information pertaining to the systematic analysis of the job to be performed using the guidance in NUREG-1220, Training Review Criteria and Procedures, Revision 1.
The NRC staff noted that the TR and audited documentations lack of a full task list review produces a risk that could lead to a failure to identify gaps in the approved task list that would be identified by thorough reviews of the job analysis process. This risk is heightened in first-of-a-kind plants that do not have an established training program with supportive evidence of sustained performance of plant personnel. Additional documentation and justification to address these concerns would be required to support relying on the difficulty, importance, and frequency (DIF) process for eliminating the need for a regularly scheduled task list review. As a result, the NRC staff plans to include a limitation on this TR pertaining to section 3.1.5.1.
The NRC staff discussed this topic with X-energy during audit meetings on September 25, 2024, and October 15, 2024. During these discussions, X-energy stated that it intended to revise the task list review process in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
D. The NRC staff requested X-energy to provide clarification regarding the training material requirements described in section 3.2.2 of the TR.
The NRC staff identified a lack of sufficient detail regarding the training material requirements described in the TR. Section 3.2.2 of the TR states that: training materials contain enough detail for trainees to successfully master the associated learning objectives and provide direction for consistent delivery of the information.
During the audit, the NRC staff assessed the TR and supporting information pertaining to training design and implementation based on the learning objectives using the guidance in NUREG-1220, Revision 1.
The NRC staff noted that the TR does not include details regarding what specific content is expected to be included in lesson plans for consistent presentation, including learning objectives, and support materials including equipment, tools, audiovisual and other equipment. The NRC staff noted that this level of detail is located in the supporting information assessed during the audit.
Enclosure The NRC staff recommended that the supporting details be augmented into the TR for docketed review.
The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to revise the training material requirements section in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
E. The NRC staff requested X-energy to provide clarification regarding the remediation standards described in the TR.
The NRC staff identified a lack of sufficient detail regarding the trainee remediation requirements described in the TR. Section 3.4.3 of the TR states that the successful execution of trainee examinations and evaluations includes appropriate exam security standards, examination administration, grading and remediation.
During the audit, the NRC staff assessed the TR and supporting information pertaining to evaluation of trainee mastery of objectives during training using the guidance in NUREG-1220, Revision 1.
The NRC staff noted that section 3 of the TR does not document a SAT methodology related to the details of remediation. Section 4.3 documents the standards for examination and remediation for control room operator training programs. Section 4.3 states that: [r]emediation includes, at a minimum, reviewing the missed content of the exam for knowledge gaps, studying, and reattempting a new examination. At a minimum, the remediation exam must retest on the concepts missed by the trainee on the original exam through new exam items covering those learning objectives.
The NRC staff noted that the training program methodology for remediation is present for the control room operator training program, but the TR does not document the same methodology for other SAT based training programs consistent with 10 CFR 50.120. The NRC staff also noted that the supporting information assessed during the audit included details of this methodology in the training program.
The NRC staff recommended that the TR be updated to include the SAT methodology that X-energy intends to utilize for remediation for training programs other than the control room operator program.
The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to revise the remediation requirements section in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
Enclosure F. The NRC staff requested X-energy to provide clarification regarding the training exemption methodology proposed in the TR.
The NRC staff identified a lack of sufficient detail regarding the trainee exemption requirements described in the TR. During the audit, the NRC staff assessed the TR and supporting information pertaining to evaluation of trainee mastery of objectives during training using the guidance in NUREG-1220, Revision 1. Specifically, the NRC staff assessed the supporting documentation regarding the objectivity of training and task performance exemptions.
The NRC staff noted that the TR does not include any details documenting a methodology for exempting trainees from training, including the consistent application of evaluating previous training and experience against a standard set of criteria as the basis for exempting trainees from completing training and task qualification program requirements. The NRC staff noted that the methodology for exempting trainees, including the documentation of this methodology in the training program, is currently located in the supporting information assessed during the audit.
The NRC staff recommended that the supporting details be augmented into the TR for docketed review.
The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to address the trainee exemption requirements in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
G. The NRC staff requested X-energy to provide clarification regarding the methodology for determining task performance.
The NRC staff identified a lack of sufficient detail regarding the methodology for determining task performance described in the TR. During the audit, the NRC staff assessed the TR and supporting information pertaining to evaluation of trainee mastery of objectives during training using the guidance in NUREG-1220, Revision 1.
Specifically, the NRC staff assessed the supporting documentation regarding the objectivity of training and task performance exemptions.
The NRC staff noted that the TR and supporting information do not include any details documenting a methodology for determining task performance requirements for tasks selected for training. A consistent method of determining task performance is foundational to the systematic process of evaluating trainee mastery of objectives during training. The lack of this information could lead to the inconsistent performance of objective evaluation of trainee mastery of objectives during training. Additional detail is necessary to address these concerns.
The NRC staff recommended that the supporting details be augmented into the TR for docketed review.
Enclosure The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to clarify the methodology for determining task performance in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
H. The NRC staff requested X-energy to provide clarification regarding the training feedback process described in section 3.5.1 of the TR.
The NRC staff identified a lack of sufficient detail regarding the methodology for evaluating training program effectiveness described in the TR. Section 3.5.1 of the TR states that: [t]raining personnel collect trainee feedback during the Implementation Phase. Effective evaluation of the training program includes reviewing the trainee feedback and initiating actions, when necessary, to improve the training program curriculum for future offerings.
During the audit, the NRC staff assessed the TR and supporting information pertaining to evaluation and revision of the training program based on trainee feedback using the guidance in NUREG-1220, Revision 1. The NRC staff noted that the TR and supporting information do not include any details regarding the type of information that should be collected as they complete major segments of training. Information requested should focus on at least the following:
i)
Adequacy of training in providing background knowledge, ii) Adequacy of training in developing associated skills, iii) Degree to which training is related to job requirements, and iv) Degree to which training prepared trainees to fulfill job requirements.
The lack of details for the type of information produces a risk that could lead to the failure to identify gaps in the approved training program. The NRC staff noted that this level of detail is not located in the supporting information assessed during the audit.
Additional documentation is necessary to address these concerns. The NRC staff recommended that the TR be updated to include the information that will be solicited from the trainees as they complete major segments of training for docketed review.
The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to clarify the trainee feedback process described in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
I.
The NRC staff requested X-energy to provide clarification regarding the methodology proposed for evaluating training program effectiveness described in section 3.5.1 of the TR.
Enclosure The NRC staff identified a lack of sufficient detail regarding the methodology for evaluating training program effectiveness described in the TR. Section 3.5.1 of the TR states that: When a trainee completes the initial training program, a Post Training Effectiveness Evaluation is conducted to assess the effectiveness of the training program to prepare the trainee for the job. Feedback from the trainee, job incumbents, and line management is included in the evaluation to assess how well the training program prepared the trainee for independent job performance. This information is typically collected six months to a year following course graduation.
During the audit, the NRC staff assessed the TR and supporting information pertaining to evaluation and revision of the training based on the performance of trained personnel in the job setting using the guidance in NUREG-1220, Revision 1. The NRC staff noted that the TR does not include any details regarding the type of information that should be collected when soliciting information for training program assessment. The type of information solicited from trainees and job incumbents should include, at a minimum, the following:
i)
Unexpected difficulties in performing tasks on the job, ii) Tasks that were particularly easy or difficult to perform, iii) Additional training needed to do the job, iv) Kinds of errors committed on the job, and v) Differences between the way tasks are performed on the job and the way they are taught.
The type of information solicited from supervisors should include, at a minimum, the following:
i)
Tasks for which new job incumbents were inadequately prepared, ii) Kinds of errors being committed by job incumbents, and iii) Suggestions for improvements in initial and continuing training.
The lack of details for the type of information produces a risk that could lead to the failure to identify gaps in the approved training program.
The NRC staff noted that the details regarding the information solicited during post training effectiveness evaluation are currently located in the supporting information assessed during this audit. It is requested that the supporting details be augmented into the TR for docketed review.
The NRC staff discussed this topic with X-energy during an audit meeting on September 25, 2024. During the discussion, X-energy stated that it intended to clarify the training effectiveness evaluation process in a revision to the TR. By letter dated December 9, 2024 (ML24344A156), X-energy submitted Revision 4 of the TR, which is currently under the NRC staffs review.
J. The NRC staff reviewed supporting procedures to better understand the content of the TR methodology.
Enclosure While not specifically in scope of the TR, the review provided insight to the NRC staff pertaining to the scope of the training program as described by the methodology in the TR. During the audit, feedback was provided to X-energy in the following general areas:
i)
General clarity of procedures for consistent performance, ii) Task list generation process and records, iii) Involvement of line personnel in training activities, and iv) The systematic methodology of the Competency Analysis process.
The NRC staff discussed these topics with X-energy during an audit meeting on August 22, 2024. During the discussion, X-energy stated that it planned to revisit the training procedures to clarify the processes described in the NRC staffs feedback.
6.0 REQUESTS FOR ADDITIONAL INFORMATION RESULTING FROM THE AUDIT At the conclusion of the audit, X-energy committed to submitting a revision to its TR to reflect some of the audit question responses as discussed above. The NRC staff is currently reviewing this revision submitted on December 9, 2024 (ML24344A156), and has determined that there is no need for requests for additional information.
7.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS There are no open items as a result of the audit.