ML25099A329
| ML25099A329 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 04/28/2025 |
| From: | John Lamb Plant Licensing Branch II |
| To: | |
| Lamb J | |
| References | |
| EPID L-2025-LLA-0010, EPID L-2025-LLQ-0000 | |
| Download: ML25099A329 (15) | |
Text
U.S. NRC Staff Presentation - SNC Fleet Plant Staff Qualifications Public Meeting April 28, 2025 John G. Lamb Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 1
Introduction
- Two licensing actions submitted by letter dated January 23, 2025.
- License Amendment Request (LAR)
- Request in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(4) 2
- LAR to remove the plant staff qualification requirements from the respective plant Technical Specifications (TS) and relocate the control of the plant staff qualification requirements to the Quality Assurance Topical Report (QATR) and Nuclear Development Quality Assurance Manual (NDQAM) consistent with the guidance in NRC Administrative Letter 95-06.
3
10 CFR 50.54 Request Request to approve o a proposed change to the SNC QATR and NDQAM to adopt Regulatory Guide (RG) 1.8, Revision 4 (ML19101A395), Qualification and Training of Personnel for Nuclear Power Plants, and o a request to take an exception to RG 1.8, Rev. 4 to extend an American National Standards Institute/American Nuclear Society (ANSI/ANS)-
3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants dated 2014 and reaffirmed in 2020, provision for crediting experience towards a baccalaureate, allowing individuals without a baccalaureate to serve in certain management positions.
4
IAEA Safety Standards Specific Safety Guide No. SSG-75, Recruitment, Qualification and Training of Personnel for Nuclear Power Plants Managers and technical specialists should have a university degree or equivalent certification in management, engineering or science, or some other educational background appropriate to the national education system and the specific job assigned. They might also have attained the necessary competence through appropriate experience and training, where this is permitted by the national regulations. Many positions, however, should be filled by individuals with formal educational qualifications. For example, the title of electrical engineer is established by the awarding of a formal degree and cannot be obtained through experience or training.
5
NRCs Policy on Consensus Standards
- Involve all interested stakeholders in the NRCs regulatory development processes
- Participate in the development of consensus standards that support the NRCs mission
- Use consensus standards developed by voluntary consensus standards bodies consistent with the provisions of Federal law 6
NTTAA, OMB Circular A-119, and NRC MD 6.5
- National Technology Transfer and Advancement Act (1995) (Pub. L. 104-113)
- Established policy for Government to participate in development and adoption of consensus standards
- Government must consider consensus standards in lieu of Government-unique standards
- OMB Circular A-119 provides guidance for implementing NTTAA
- Agencies report annually to the National Institute of Standards and Technology (NIST), to Congress
- NRC Management Directive (MD) 6.5
- Provides direction to the NRC staff for implementing the NTTAA and OMB Circular A-119.
7
The Consensus Standards Process
- Administered by ANSI
- Consensus: Due process + substantial agreement
- Not strictly = unanimity
- Due process (for ANSI accreditation) - any party with a direct and material interest has a right to participate by:
- expressing a position and its basis
- having that position considered
- having the right to appeal 8
How NRC uses Codes and Standards -
Guidance
- Methods of satisfying NRC regulations are explained in NRC Regulatory Guides (RGs)
- Standard Review Plans explain how NRC reviews applications for licenses and license amendments
- Both widely reference Codes and Standards 9
- On November 20, 2014 (Reaffirmed in 2020),
ANSI/ANS-3.1-2014, was issued. Revisions to the standard align the ANS, NRC, and INPO with industry selection, training, and qualification standards; provide for a common language across the industry; address supplemental personnel training and qualification; and update previous positions in light of new nuclear power plant construction, current position terminology, and evolving technology.
10
RG 1.8, Revision 4
- NRC endorses ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, with certain exceptions and clarifications that are listed in the NRC staff RG 1.8, Revision 4.
11
ANSI/ANS-3.1 - 2014 (Reaffirmed February 3, 2020)
- ANSI/ANS-3.1 - 2014 (Reaffirmed February 3, 2020) states:
Related experience may be substituted for education at the rate of 6 semester credit hours for each year of experience up to a maximum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of credit.
12
SNC Letter Dated January 23, 2025
- SNC letter dated January 23, 2025, states:
SNC is proposing an exception and wants to use:
Experience substitution for education is expanded to allow related experience to be substituted at a rate of 8 semester credit hours for each year of related experience up to a maximum of 80 credit hours.
13
Questions
- What is the basis and justification for the proposal to substitute experience for education at a rate of 8 semester credit hours for each year of related experience up to a maximum of 80 credit hours instead of a rate of 6 semester credit hours for each year of related experience up to a maximum of 60 credit hours?
- Has SNC discussed with ANSI/ANS the proposed deviation from the standard or discussed the rationale why the proposed change was not adopted in prior standards development efforts?
14
Conclusion
- The NRC staff is not making any regulatory decision at todays meeting.
- Once the NRC staff makes a regulatory decision, that regulatory decision will be provided to SNC in writing in a timely manner.
15