Text

Request for Review and Endorsement of NEI 23-01 (Rev 2), Operator Cold License Training Plan for Advanced Nuclear Reactors
	ML25198A381
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/17/2025
From:	Yuen S; Nuclear Energy Institute
To:	Michael Wentzel; Office of Nuclear Reactor Regulation
References
	NEI 23-01, Rev. 2
	Download: ML25198A381 (1)
	v • d • e

Stewart Yuen Senior Project Manager Phone: 920.396.0521 Email: sjy@nei.org July 17, 2025 Mr. Michael Wentzel Chief, Advanced Reactor Policy Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for Review and Endorsement of NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors Project Number: 689

Dear Mr. Wentzel:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 is submitting NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, revision 2 for NRC review and endorsement. The technical report was developed to assist advanced reactor applicants with the preparation of license applications and the NRC staff with their ongoing efforts to create a generic regulatory framework for the review and approval of such applications. The report will be available to all applicants, free of charge. NEI 23-01 provides applicants for Advanced Nuclear Reactors with a standard plan to train and license operators before construction of the plant is complete. NRC review and endorsement of NEI 23-01 will allow applicants to reference this plan within their Advanced Reactor CP/COL application and reduce the time the staff needs to review the application. Revision 2 addresses NRC staff questions submitted to NEI (ML25142A299). We are not requesting any additional public meetings.

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry

Mr. Michael Wentzel July 17, 2025 Page 2 Nuclear Energy Institute If there are any questions on this matter, please contact either me or Marcus Nichol at mrn@nei.org.

Sincerely, Stewart Yuen Senior Project Manager Attachments cc:

Angelica Gheen, NRR, NRC Maurin Scheetz, NRR, NRC NRC Document Control Desk

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

Crew cumulative nuclear power plant experience (definition on page 2 and in Table 1 page 15)

The staff would need information about why 24 months of crew cumulative nuclear power plant experience is an adequate amount or audit the methodology used to determine this number.

Following further discussion, NEI has amended the methodology to determine the time requirement of this component to be determined using a mathematical formula. The revised requirement would now be determined multiplying the number of crew members needed to satisfy the minimum crew size for the design by 1.2 years.

As an example, for a NuScale VOYGR 12 design, this would be 3 crew members x 1.2 years, equaling 3.6 years.

This mathematical formula is based on the ratio of minimum crew size compared to required crew cumulative nuclear power plant experience that is provided in the current NEI 06-13A requirements, where a 5-person crew required 6 years of crew cumulative nuclear power plant experience.

This approach has been chosen so that a consistent ratio can be applied to various plant designs, while also taking into consideration differing minimum crew size requirements between designs.

The change is reflected in the revised crew cumulative nuclear power plant experience definition in section 2, in the explanation of eligibility requirements in sections 4 and 5, and on Figures 1, 2 and 3 of NEI 23-01.

2.

NEI 23-01 states, In addition, at least one crew member must have hot plant experience.

NEI 06-13A has a similar requirement, Each operating crew shall be staffed with a SRO with hot-plant experience. NEI 06-13A also has a flexibility here: if any hot participation experience requirement was not satisfied by either the SS or Senior Operator, a shift advisor or a qualified advisor must be on shift.

Follow-up questions on excluding this flexibility and before it was for SRO, seems like this is okay for any license level.

The staff would need to audit the basis for the change from NEI 06-13A, meaning, why is hot plant experience sufficient for RO position only and not SRO position and did NEI consider the flexibility for a qualified advisor when hot plant experience was not present?

Following further discussion, NEI has revised the guidance to clarify that hot plant experience applies to both the RO and SRO position. The guidance has also been revised to include the flexibility of using a shift advisor.

The change to apply the hot plant experience requirement to either an RO or SRO is found in the definition of hot plant experience in section 2, in the explanation of eligibility requirements in sections 4 and 5, and on Figures 1, 2 and 3 of NEI 23-01.

The change to include a shift advisor is reflected in the revised crew cumulative nuclear power plant experience definition in section 2, in sections 4 and 5, and Figures 1, 2 and

Refined Clarifying Questions for NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, Revision 1 Page 2 3 of NEI 23-01. The requirements necessary to fulfill the role of shift advisor are directly taken from NEI 06-13A.

3.

The NRC staff may consider adding an exception to SRO eligibility in NEI 23-01 to include power plant experience for SRO candidates that do not have nuclear experience or a degree.

Following further discussion, NEI has revised the guidance to include an eligibility path for cold license SRO candidates based on power plant experience. The definition of power plant experience is taken from ACAD 10-001, Guidelines for Initial Training and Qualification of Licensed Operators, revision 2, so that this will be aligned with the current NRC endorsed hot license guidance. A time requirement of 18 months was chosen for this requirement based on the time requirements for similar paths using operator experience at nuclear plants of varying design, military experience or instructor experience.

The change is reflected in the added power plant experience definition in section 2, in the explanation of SRO eligibility requirements in section and 5, and on Figures 2 and 3 of NEI 23-01. of NEI 23-01.

4.

Degree in Science or Applied Science (definition on page 2)

Degrees from natural sciences are not credited. What are considered the natural sciences?

The staff would like more information about what natural science degrees are acceptable.

Following further discussion, NEI has revised the guidance to remove the discussion concerning natural sciences, and aligned the definition of degree(s) in Science or Applied Science in section 2 of this document to be consistent with the definition of Related Sciences found in ACAD 10-001, Guidelines for Initial Training and Qualification of Licensed Operators, revision 2.

5.

Practical Work Experience (definition on page 4)

What is the basis for 3 months of practical work experience (as compared to 6 months on site for operating reactors and NEI 06-13A which requires 6 months of practical work assignments)?

Without having much operations/human factors information about microreactors, that staff is challenged to understand that basis for 1 month of practical work experience for microreactors.

The staff would like to understand the basis or audit the methodology used to determine these amounts of practical work experience.

Following further discussion, NEI has revised the guidance for required practical work experience to be flexible, and determined using a SAT based approach.

This approach has been chosen to be more consistent with that used to determine prerequisite on-site requirement currently used in ACAD 10-001, Guidelines for Initial

Refined Clarifying Questions for NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, Revision 1 Page 3 Training and Qualification of Licensed Operators, revision 2. Using this methodology allows for factors such as differences in plant design and complexity to be included. It also depends on individual needs such as candidate aptitude, experience, maturity and drive, and license level being sought. The requirement will specify that this is pre-determined during the candidate selection process and done using a systematic analysis of candidate needs.

The change is reflected in the revised practical work experience definition in section 2, in the explanation of eligibility requirements in sections 4 and 5, and on Figures 1, 2 and 3 of NEI 23-01.

nei.org NEI 23-01 (Rev 2)

Operator Cold License Training Plan for Advanced Nuclear Reactors Prepared by the Nuclear Energy Institute July 2025

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nei.org Revision Table Revision Description of Changes Date Modified Responsible Person Draft Rev. A Initial revision 9/2023 Rick Stadtlander and Stew Yuen Rev. 0 Incorporation of Stakeholder Comments 9/2024 Rick Stadtlander and Stew Yuen Draft Rev 1

Incorporation of Stakeholder Comments 12/2024 Rick Stadtlander and Stew Yuen Rev 2 Incorporation of Stakeholder Comments 07/2025 Rick Stadtlander and Stew Yuen

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nei.org Acknowledgements This document was developed by the Operational Aspects of Advanced Reactors Team, led by the Nuclear Energy Institute. NEI acknowledges and appreciates the contributions of NEI members and other organizations in the preparation of this document.

NEI Project Lead: Rick Stadtlander, and Stew Yuen Notice Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

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nei.org Executive Summary NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, provides 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. The main objective of this report is to assist members in ensuring the proper qualifications are met in licensing operators.

This report does not address cold operator license training plans for operations staffing models presented in NEIs Proposal Paper, Regulations of Rapid High-Volume Deployable Reactors in Remote Applications (RHDRA) and Other Advanced Reactors, dated July 31, 2024, as this report predates the proposal paper.

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nei.org Table of Contents Introduction..................................................................................................................................... 1 Definitions........................................................................................................................................ 1 General Advanced Nuclear Reactor Cold License Training and Experience Requirements............ 6 3.1 Minimum Educational Requirements................................................................................. 6 3.2 Conduct of On-the-Job Training and Task Performance Evaluation (OJT/TPE).................. 7 3.3 Use of Part-Task/Limited Scope Simulators........................................................................ 7 3.4 Licensed Operator Continuing Training.............................................................................. 7 3.5 Crew Cumulative Nuclear Power Plant Experience............................................................ 7 3.6 Cold Licensing Process Applicability and Termination........................................................ 7 3.7 Experience Equivalency...................................................................................................... 8 3.8 Maintaining Proficiency While Under Construction........................................................... 8 Reactor Operator (RO) Eligibility and Training Requirements......................................................... 8 4.1 Education............................................................................................................................ 9 4.2 Training Related Experience Requirements........................................................................ 9 4.3 Additional Cold License Training and Watch Standing Requirements................................ 9 Senior Reactor Operator (SRO) Eligibility and Training Requirements.......................................... 12 5.1 Education.......................................................................................................................... 12 5.2 Training Related Experience Requirements...................................................................... 12 5.3 Additional Cold License Training and Watch Standing Requirements.............................. 13 Appendix A. Change to Education Requirement for Cold License Training for Direct SRO Candidates... A-1 Table of Figures Figure 1: ANR RO Eligibility and Training Requirements During Construction Phase................................. 11 Figure 2: ANR SRO Eligibility and Training Requirements for Personnel with Educational Backgrounds During Construction Phase......................................................................................................................... 14 Figure 3: ANR SRO Eligibility and Training Requirements for Previous Operator License, Military Reactor Operator, or SRO Certified instructor During Construction Phase............................................................. 15 Table of Tables Table 1: Crew Cumulative Nuclear Power Plant Experience Equivalencies................................................ 16 Table 2: Comparison of Hot and Cold License Guidance............................................................................ 17 Table 3: Illustration of Cold Licensing Plan by Candidate Type.................................................................. 21

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nei.org 1 INTRODUCTION The guidance document establishes an approach to meeting the requirements in 10 CFR 55 for the training and licensing of operators. This guidance is based upon the NRC-endorsed guidance NEI 06-13A for cold licensed operator training and is tailored to advanced nuclear reactors, which include light-water small modular reactors (LWR SMRs), non-LWRs, and micro-reactors. Prior to operation, plant experience requirements specified in regulatory and industry guidance documents and other standard guidance for operator selection, training, and qualification cannot be met. This document proposes a method to address this issue.

Cold licensing of operators provides a method for operations personnel to acquire the knowledge and experience required for licensed operator duties during the unique conditions of new plant construction and initial operation. Table 2, "Comparison of Hot and Cold License Guidance, shows the current hot license guidance versus the associated cold license guidance. Table 3, "Illustration of Cold Licensing Plan by Candidate Type, shows education and experience for each licensed operator candidate type.

Licensed operator candidates need not satisfy the experience requirements prior to entering a licensed operator training program. Experience and plant evolution requirements that have not been met at the time the licensed operator examination is administered shall be met prior to issuing the individuals NRC operator license. In such a case, the licensee will notify the NRC when the candidate meets the experience and plant evolution requirements.

The methods described in this guidance, along with the other cold license training elements provided within, provide the licensed operator candidate with meaningful experience on the reactor for which the license is sought. These criteria provide reasonable assurance that, at the end of the training program, the personnel will be qualified to operate and maintain the facility in a safe manner in all modes of operation.

It is also important to note that each Construction Permit (CP) or Combined Operating License (COL) holder (herein plant operator) will employ their own internal hiring criteria to candidates for a licensed operator training program. Typically, in addition to rigorous interviews and background checks, plants also use aptitude tests as a screening requirement as part of their hiring process. These practices would continue to be implemented because, ultimately, the plant owner is also deeply invested in only having the highest quality operators staffing their control rooms.

DEFINITIONS The following definitions are used throughout the document; some definitions have requirements described in addition to requirements discussed in Section 3.

Advanced Nuclear Reactor (ANR)

This term is used throughout this plan. It describes a fission reactor with significant improvements, including additional inherent safety features, compared to reactors operating on December 27, 2020, in the United States. This includes Light Water Reactors (LWR), Small Modular Reactors (SMR), non-LWRs,

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nei.org 2 and micro-reactors. This is consistent with the definition of Advanced Nuclear Reactor in 42 United States Code (USC) 162711.

Alternate Cold License Methods for OJT/TPE2 The On-the-Job-Training (OJT) and Task-Performance-Evaluation (TPE) phase during Cold Licensing will be modified to allow completion of this training before the plant becomes available. Acceptable methods for the conduct of OJT and TPE include discussion, simulation, tabletop exercises, and use of mockup equipment and virtual reality technology. This training includes familiarity with plant locations by use of plant layout diagrams and equipment diagrams. During the tabletop exercises the diagrams are used to allow the candidate to gain knowledge of important plant equipment building, elevation, and room locations. Examples of mock-up equipment which may be used are control room simulators (plant referenced, NRC staff approved, or part task simulators), training breaker labs, maintenance flow loop trainers, and Radiological Controls Area mock-up trainers.

Crew Cumulative Nuclear Power Plant Experience Each on-shift crew must have a cumulative total of at least 1.2 years (14.4 months) of nuclear power plant experience times the minimum crew size. The crews cumulative nuclear power plant experience is gained by working at nuclear power plants and military nuclear propulsion plants, conducting licensed operator training, participating in new nuclear plant construction and testing, and completing academic degree requirements. The cumulative crew nuclear power plant experience is the sum of an individuals experience, in months, after applying weighting factors and maximum credit limits in Table 1, "Crew Cumulative Nuclear Power Plant Experience Equivalencies. When determining cumulative nuclear power plant experience, one crew member should not be contributing to all of the experience. In addition, at least one crew member must have hot plant experience. If a senior reactor operator with hot plant experience is not available, then a shift advisor may be substituted. The shift advisor will have at least one year of on-shift licensed senior reactor operator experience at a similar type (e.g.

PWR/BWR/Molten Salt) operating plant and will have completed a training program on the design for which they are advising. While observing crew performance, the shift advisor will make recommendations to the shift manager only, and will not interfere with the licensed responsibilities of the operating crew. The shift advisor will have direct access to plant senior management to resolve issues. Shift advisor duties include, but are not limited to the following:

Monitor procedure adherence Observe the conduct of pre-job briefs, shift turnover, plant evolutions, nonlicensed operator rounds, plant tours, and post job debriefs Monitor overall station risk Degree in Science or Applied Science This term is used in Figure 2. The degree in science or applied science used to establish eligibility for a Senior Reactor Operator (SRO) candidate shall be from an engineering, engineering technology, or related science program, or from a mathematics, or computer science program. Acceptable degrees are 1 42 USC 16271: Nuclear energy (b) Definitions (1) Advanced nuclear reactor 2 Alternate guidance to satisfy NUREG 1021, section 3.7 Alternatives for In Plant Job Performance Measures at Plants under Construction

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nei.org 3 Associates, Bachelors, Masters, and Doctorate degrees in any of those disciplines that may be credited to satisfy the requirements. The degree shall be from a nationally accredited college or university.

An evaluation of degrees in related technical fields, or equivalent, can be used to identify those degrees beyond engineering or engineering sciences having an appropriate amount of engineering, mathematics, chemistry, and/or physics study. A curriculum review, when performed, should determine an acceptable amount of mathematics and science coursework required for license class level of understanding as determined by the utilities use of a Systematic Approach to Training (SAT) based analysis. Credit may also be given for pre-license class work in mathematics and science topics necessary to be successful in obtaining a license. A selection board comprised of leaders from Training and Operations and chaired by the Site Vice President (or equivalent) should make these determinations.

Documentation of such reviews, pre-course work, and other actions to declare academic eligibility should be maintained as part of candidate records.

Hot Plant Experience This definition is used when determining experience equivalency requirements. It describes work experience as a Reactor Operator (RO) or SRO at a power reactor that includes the following: at least six weeks of that experience including at least one unit operating above 20 percent power, a startup from subcritical to 20 percent power, a shutdown from above 20 percent power to cold and subcritical, and startup preparations following a fueling or refueling. The startup, shutdown, and startup preparations may have been performed at an operating plant or a plant simulator. The hot plant experience can be gained at any power reactor of any design, vendor, or vintage.

Hot Plant Observation This definition is used when determining experience equivalency requirements and is defined as at least 6 weeks of structured observation of operating crews at an operating commercial nuclear power plant of like design. The purpose of these observations is to familiarize candidates with the licensed operating crew roles and responsibilities and applied techniques for maintaining the high levels of nuclear professionalism expected in an operating nuclear power plant environment. To facilitate learning, it is recommended that structured observation at a hot facility include the observation of work activities performed by control room crews, non-licensed operators in the plant areas, work control/work management personnel, clearance and tagging personnel, and the outage planning staff.

Micro-Reactor An Advanced Nuclear Reactor (ANR) that has an electric power production capacity that is typically less than 50 megawatts. This definition is consistent with 42 USC 187513.

Military Reactor Operator Equivalent This term, used in Figure 3, describes military nuclear experience where the candidate is qualified to manipulate control rods or supervise the manipulation of control rods. For United States Navy personnel, these positions are reactor operator, engineering officer of the watch, propulsion plant 3 42 USC CHAPTER 162, SUBCHAPTER III, Part A: Nuclear Energy Infrastructure §18751. Infrastructure planning for micro and small modular nuclear reactors (a) Definitions (3) Micro-reactor

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nei.org 4 watch officer, engineering watch supervisor, and propulsion plant watch supervisor. There may be other positions not included here which should be evaluated by the licensee for equivalency.

The start date for calculating total military nuclear experience is the date on which military nuclear-power-plant-related prototype training is completed. End dates are calculated using military discharge dates or dates on which the candidate no longer holds the applicable military nuclear qualifications.

Non-licensed Operator Selected Tasks The selected non-licensed operator tasks are those tasks that are important to plant operation and contribute to nuclear safety, defense-in-depth, or that are risk significant. Typically, these tasks are associated with the local operator tasks within the Emergency Operating Procedure network. The tasks are implemented using alternate Cold License methods for OJT/TPE.

Plant Operational Excellence Course This is intended for sites without ready access to an operating commercial nuclear power plant. The course duration is 6 weeks. The scope of this course should include training in a full-scope simulator, and cover the following topics:

Teamwork Human Performance Factors Diagnostic Skills Mitigating Core Damage Transient and Accident Operations Power Plant Experience This term describes applicable work performed in fossil-fueled or nuclear-fueled electric power production plants during preoperational, startup testing or operational activities. Experience in nuclear-fueled or petrochemical process production plants; similar process plants; or steam propulsion plant design, construction, technical support, operation, maintenance, or training instruction can be substituted for applicable power plant experience. Simply observing others performing work is not considered power plant experience. Time spent in classroom training cannot be counted toward power plant experience requirements. However, time spent in a structured, job-related development program may be considered power plant experience. Also, time spent performing job-based training and qualification activities in the plant such as under instruction watchstanding, on-the-job training, and task or watchstation qualification activities can be applied toward power plant experience requirements. Time spent performing in-plant job-based training and qualification activities should be specifically documented if such time is used to meet power plant experience requirements.

Preoperational Test Experience This definition is used when determining experience equivalency requirements. At least 6 weeks of participation in control room activity during the site preoperational testing phase. The preoperational

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nei.org 5 test experience does not have to be completed before applying for an SRO or RO license or taking the NRC SRO or RO Operator licensing examination but must be completed before the license is issued.

Practical Work Experience Cold License Candidates must complete practical work experience assignments. Practical work experience is pre-determined during the candidate selection process and done using a systematic analysis of candidate needs. It is dependent on several common components such as the plant design and the license level being sought. It also depends on individual needs such as candidate aptitude, experience, maturity and drive. While the existing reactor fleet uses a specific time requirement for practical work experience, differences in designs and complexity for advanced reactors calls for a different method using a SAT-based approach and should be described in the licensees submittal to the NRC. For these activities to be considered meaningful, they must be associated with safety significant or defense-in-depth activities, or other major plant components or systems. These practical and meaningful work assignments include documented participation in preoperational testing and in one or more of the following activities:

procedure development and validation human factors engineering activities task analysis verification preparation, review, approval or implementation of licensed operator classroom or simulator training These work assignments allow the operator candidate to gain experience on the reactor design for which the license is sought. Therefore, structured observation training at another operating nuclear power plant cannot be used to reduce the duration of these work assignments. The practical work experience does not have to be completed before applying for an RO or SRO license or taking the NRC RO or SRO licensing examination but must be completed before the license is issued.

Site Layout Course The site layout course is designed to gain familiarity with the site layout before the physical plant becomes available. The course should be consistent with the SAT process, with a focus on the areas of the plant equipment that will be operated by operations department staff. The course should also include navigation to the local plant equipment used in the RO or SRO qualification guide and the NLO selected task guide, as implemented using Alternate Cold License Methods for OJT/TPE.

SRO Certified Instructor For the purposes of determining eligibility per Figure 3, an SRO certified instructor is one who has completed initial written and operating examinations to certify SRO-level knowledge including generic fundamentals; systems; plant normal, abnormal, emergency, and administrative procedures; mitigating core damage; and plant technical specifications. An SRO certified instructor is also one who participates in the licensed operator continuing training program and who satisfactorily completes annual operating examination and biennial comprehensive written examination requirements to certify maintenance of SRO-level knowledge.

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nei.org 6 GENERAL ADVANCED NUCLEAR REACTOR COLD LICENSE TRAINING AND EXPERIENCE REQUIREMENTS Additional considerations are required for an initial license operator training course during the plant construction phase (Cold Licensing) of an ANR and are provided here:

3.1 Minimum Educational Requirements Both RO and SRO candidates require a minimum of a High School Diploma or equivalent. There are additional screening criteria for SRO candidates with a High School Diploma or equivalent to be eligible for the operations training program.

Requiring a minimum education of a High School Diploma, or equivalent (e.g., General Education Diploma, GED) for the SRO, rather than an associate degree or bachelors degree, requires additional considerations by the applicant. SRO candidates will generally fall into two categories, those with previous nuclear experience and those with an educational background. For those candidates who are eligible by an educational background, these can be further divided into those with a Degree in Science or Applied Science and those who have a High School Diploma and have undergone additional screening to ascertain their aptitude. In order to ensure the health and safety of the public, the applicant will need to validate that the SRO candidates that are eligible using the High School Diploma and additional screening can meet certain criteria to ensure that they can perform the function of an SRO following their training. These criteria are summarized below:

Establishing SRO candidate eligibility using the High School Diploma, or equivalent, and additional screening path does not mean that this individual is directly out of high school. This individual could be a fossil plant operator with years of experience, but one that only completed their high school education before coming into the workforce. Their experience and informal training would qualify them from a leadership capacity, but additional training may be required to ensure they are ready for an SRO position at a nuclear facility.

The screening methodology used for an SRO candidate who establishes eligibility using this path will be established by the applicant. The intent is that the screening will assess their aptitude in verbal communication, math, science, and technical and spatial ability. This could take the form of an entrance exam like the ASVAB (Armed Services Vocational Aptitude Battery) which is used to set the standard entry criteria for the Nuclear Navy candidates or the Plant Operator Selection System (POSS) test that is a battery of aptitude tests that are used by electric companies to identify candidates for power plant operator positions. A selection board comprised of leaders from the Training and Operations departments and chaired by a senior leader (site vice president or equivalent) should make these determinations. Documentation of such reviews, pre-course work, and other actions to declare eligibility shall be maintained as part of candidate records.

The licensed operator training program would then be based on the starting point for the individuals defined by the minimum standards from this screening process. This process would provide the minimum criterion for the training program to ensure that the right technical aptitude is obtained to operate ANRs. The training program is required to be designed within the Systematic Approach to Training.

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nei.org 7 In addition to the technical aptitude test, a screening for leadership capabilities would also be required.

This could take the form of an oral board, an interview process, an evaluation of past industrial process plant experience (e.g., fossil generation plant or chemical plant), or some other method that could be used to screen the candidates to ensure they are mature enough to not only operate the ANR but also lead reactor operators when required. The focus should be on the ability of the candidate to exhibit or learn the Command & Control function of the position.

Details for the screening criteria should be specified in the COL or Operating License (OL) application for the ANR. Based on the Human Factors Engineering (HFE) performed for the specific ANR design, a staffing study may also be required to ensure that the required base educational requirements would be fulfilled.

The use of a Degree in Science or Applied Science as the minimum educational requirement without additional screening is consistent with the current recommendation from industry groups. This is because the degreed candidates have demonstrated the ability to learn technical fundamentals and knowledge necessary to enter an SRO training program through attaining their degree.

Appendix A provides additional information on the basis for why a high school diploma with additional screening is an acceptable minimum educational requirement for an SRO candidate.

3.2 Conduct of On-the-Job Training and Task Performance Evaluation (OJT/TPE)

Until plant construction is completed, acceptable methods for the conduct of OJT include discussion, simulation, and use of mockup equipment and virtual reality technology. Further information is provided in the definition of Alternate Cold License Methods for OJT/TPE.

3.3 Use of Part-Task/Limited Scope Simulators Part-task or limited scope simulators may be used during licensed operator training.

3.4 Licensed Operator Continuing Training The licensed operator continuing training program begins within 90 days following the completion of the first operator license examination and continues until operator licenses are issued and licensed operator requalification training begins. Continuing training content is systematically determined to maintain operator knowledge of plant operation.

3.5 Crew Cumulative Nuclear Power Plant Experience Additional experience requirements are added to the on-shift crew watch standing routine for the first operating cycle or two years, whichever is less, following initial plant startup. For multi-unit sites where all the units are operated from a common control room, this applies to the first unit placed into operation.

3.6 Cold Licensing Process Applicability and Termination The Cold Licensing process described in this document may be applied to each unit of a multi-unit site where each site has a stand-alone control room, for any licensed operator training class started prior to initial fuel load. The Cold Licensing process for a multi-unit site where all units are operated from a

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nei.org 8 common control room, such as a Small Modular Reactor site, may be applied for any license operator training program started prior to the initial fuel load of the first unit. The overall intent is to transition to normal hot licensing processes when all training and experience requirements can be completed as prescribed.

Cold License guidance that waives the time on site requirement will no longer apply to any licensed operator training class started after 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. For multi-unit sites, this will terminate after completion of the first refueling outage of the first unit, or two years of commercial operation, whichever occurs first.

As plant systems, components, and structures are completed, and as integrated plant operations begin, the systematic approach to training process will be used to adjust cold license class training methods and settings. The purpose is to optimize student learning using actual in-plant training and experience opportunities as they become available.

3.7 Experience Equivalency An RO or SRO candidate must have 6 months of Hot Plant Experience or satisfy the experience equivalency requirements. In lieu of 6 months Hot Plant Experience, the candidate may meet experience equivalency requirement by meeting one of the following:

Attend a 6-week Plant Operational Excellence Course OR Perform 6 weeks of Preoperational Test Experience OR Perform 6 weeks of Hot Plant Observation 3.8 Maintaining Proficiency While Under Construction An RO or SRO candidate will maintain watch standing proficiency while the facility is under construction.

The methodology to maintain this proficiency during cold licensing is similar to that used during hot licensing and is performed in accordance with the guidance provided in NUREG 1021, Section 5.3, A. 2.

Proficiency Watches.

REACTOR OPERATOR (RO) ELIGIBILITY AND TRAINING REQUIREMENTS The education, experience, and training criteria for an initial licensed operator training course during the plant construction phase (Cold Licensing) of an ANR as an RO Candidate are provided here and shown in Figure 1.

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nei.org 9 4.1 Education The candidate possesses a high school diploma or equivalent certificate.

4.2 Training Related Experience Requirements No prior power plant experience is required for entry into RO license training. There are additional experience requirements during the Cold License Phase that must be met prior to the issuance of a license for the RO candidate. These are satisfied by either of the following methods:

The candidate has at least 6 months of Hot Plant Experience

- OR -

Candidates that do not meet the hot experience requirement must meet at least one of the following options:

o Attend a 6-week Plant Operational Excellence Course.

- OR -

o Participate in at least 6 weeks of Preoperational Test Experience in the control room.

- OR -

o Perform at least 6 weeks of structured Hot Plant Observation of operating crews at an operating nuclear power plant of like design.

4.3 Additional Cold License Training and Watch Standing Requirements Additional training program requirements are added to Cold License Phase training programs for RO candidates to allow the operator candidate to gain experience on the reactor design for which the license is sought. These requirements, along with the additional watch standing requirements during the initial start of plant operation, are described below:

1. Additional Training Program Requirements:

a. Site Layout Course

- AND -

b. Practical Work Experience

2. Cold License In-Plant Activities (using Alternate Cold License Methods for OJT/TPE)

a. RO Qualification Guide

- AND -

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nei.org 10

b. NLO selected task OJT guide

3. Control Manipulations

a. Five significant control manipulations on a Plant Reference Simulator (PRS)

4. Additional Watch Standing Experience

a. 1.2 years (14.4 months) times the number of crew members required to meet the crew minimum staff size of Crew Cumulative Nuclear Power Plant Experience across each crew

i.

At least one crew member should have Hot Plant Experience or a shift advisor

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nei.org 11 Figure 1: ANR RO Eligibility and Training Requirements During Construction Phase

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nei.org 12 SENIOR REACTOR OPERATOR (SRO) ELIGIBILITY AND TRAINING REQUIREMENTS The education, experience, and training criteria for an initial license operator training course during the plant construction phase (Cold Licensing) of an ANR as an SRO Candidate are provided here and shown in Figures 2 & 3. Candidates may be eligible for SRO license based on 1) post-high school education,

2) previous nuclear experience, or 3) high school diploma or equivalent with successful aptitude and leadership screening.

5.1 Education Each candidate possesses a high school diploma or equivalent certificate and without previous nuclear experience, passes the internal screening criteria as described in Section 3.1 - Minimum Educational Requirements. If the candidate has a Degree in Science or Applied Science, or has previous nuclear experience, then the internal screening criteria described in Section 3.1 is not required. (See Figure 2) 5.2 Training Related Experience Requirements Eligibility for SRO candidates based on previous nuclear experience requirements fall into these general categories:

individuals with at least 18 months of experience as licensed ROs or SROs at a commercial nuclear power plant. The experience must include Hot Plant Experience. (See Figure 3)

- OR -

individuals with at least 18 months of experience as Military Reactor Operator Equivalent at a military reactor. (See Figure 3)

- OR -

individuals with at least 18 months of experience as SRO Certified Instructors involved in the training and evaluation of licensed operators at commercial nuclear plants. These individuals maintain their technical skills current through continuing training, including licensed operator continuing training, in-plant activities, and appropriate time on the simulator. (See Figure 3)

- OR -

individuals with at least 18 months of Power Plant Experience at a fossil-fueled experience or nuclear-fueled electric power production plants during preoperational, startup testing or operational activities. Experience in nuclear-fueled or petrochemical process production plants; similar process plants; or steam propulsion plant design, construction, technical support, operation, maintenance, or training instruction can be substituted for applicable power plant experience. (See Figure 3)

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nei.org 13 5.3 Additional Cold License Training and Watch Standing Requirements Additional training program requirements are added to Cold License Phase training programs for SRO candidates to allow the operator candidate to gain experience on the reactor design for which the license is sought. These requirements, along with the additional watch standing requirements during the initial start of plant operation, are described below:

1. Additional Training Program Requirements:

a. Site Layout Course

- AND -

b. Practical Work Experience

2. Cold License In-Plant Activities (using Alternate Cold License Methods for OJT/TPE)

a. RO Qualification Guide

- AND -

b. SRO Qualification Guide

- AND -

c. NLO selected task OJT guide

3. Control Manipulations

a. 5 significant control manipulations on a Plant Reference Simulator (PRS)

4. Additional Watch Standing Experience

a. 1.2 years (14.4 months) times the number of crew members required to meet the crew minimum staff size of Crew Cumulative Nuclear Power Plant Experience across each crew

i.

At least one crew member should have Hot Plant Experience or a shift advisor

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nei.org 14 Figure 2: ANR SRO Eligibility and Training Requirements for Personnel with Educational Backgrounds During Construction Phase

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nei.org 15 Figure 3: ANR SRO Eligibility and Training Requirements for Previous Operator License, Military Reactor Operator, or SRO Certified instructor During Construction Phase

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nei.org 16 Table 1: Crew Cumulative Nuclear Power Plant Experience Equivalencies Type of Experience Weighting Factor Max Credit

1. Nuclear Power Plant RO/SRO on the same type of plant (PWR/BWR/ANR) 1.00 No Limit

2. Nuclear Power Plant RO/SRO from different type of plant (PWR/BWR/ANR) 0.75 No Limit

3. Military Nuclear Propulsion Plant Experience (Propulsion Plant Watch Officer, Engineering Watch Supervisor, Reactor Operator, Engineering Officer of the Watch, Propulsion Plant Watch Supervisor) 0.50 No Limit

4. Military Nuclear Propulsion Plant Experience (Other than watch qualifications in type 3, above) such as Machinist Mate, Electricians Mate, Engineering Laboratory Technician, or Electronics Technician) 0.25 No Limit

5. Commission-Approved Simulator or Plant Reference Simulator 5.00 12 months

6. Limited Scope Simulator 3.00 9 months

7. Actual nuclear power plant experience during construction 0.25 12 months

8. Actual nuclear power plant experience during pre-operational testing 0.75 12 months

9. Actual nuclear power plant experience during fuel load and startup testing 1.00 12 months

10. License classroom training 0.25 9 months

11. Participation in operator duties at another nuclear facility. This includes non-licensed operator duties 0.75 12 months

12. Other Nuclear Plant experience 0.25 12 months

13. Licensed operator instructor 0.50 12 months

14. Bachelors Degree in an engineering, science, or technical field 1.00 12 months

15. Associate degree in an engineering, science, or technical field 1.00 6 months Weighting factors and max credit values based on those in Industry Evaluation of Operating Shift Experience Requirements By J.H. Miller Jr. 2/24/1984, and endorsed by Generic Letter number 84-16, Adequacy of On-Shift Operating Experience for Near Term Operating License Applicants, except for #s 13, 14, & 15 which are added experience types based on new technology or additional analysis.

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nei.org 17 Table 2: Comparison of Hot and Cold License Guidance Current Hot License Guidance Applicable Position Cold License Guidance

1. Six months on-site at reactor for which license is sought.

All Practical work experience1 AND Site Layout Course AND Complete the required OJT/TPE phase training which has been modified for cold license

2. One year on-site at the reactor for which the license is sought with six months as a non-licensed operator.

Reactor Operator Practical work experience1 AND Site Layout Course AND Non-licensed Operator Selected Tasks AND Complete the RO OJT/TPE phase training which has been modified for cold license

3. Pre-requisite experience requirements must be met to enter training program.

All Applicable experience requirements shall be met prior to NRC license issuance

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nei.org 18 Current Hot License Guidance Applicable Position Cold License Guidance

4. Three years power plant experience, at least one of which should have been at the plant for which the license is sought.

Reactor Operator Practical work experience1 AND Cumulative operating crew experience requirements apply AND Non-licensed Operator Selected Tasks AND Complete the RO OJT/TPE phase training which has been modified for cold license

5. Reactor operator license actively involved in the performance of licensed duties for at least one year.

Senior Reactor Operator (Experience path)

Site Layout Course AND Non-licensed Operator Selected Tasks AND Complete the RO & SRO OJT/TPE phase training which has been modified for cold license AND Complete a reactor operator and senior reactor operator training course

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nei.org 19 Current Hot License Guidance Applicable Position Cold License Guidance

6. At least three years of responsible nuclear power plant experience.

Senior Reactor Operator (Non-Experience path)

Site Layout Course AND Non-licensed Operator Selected Tasks AND Complete a reactor operator and senior reactor operator training course

7. At least six weeks of operation above 20%

power, and startup from subcritical to 20%

power, and shutdown from above 20% power to cold (less than 212°F) and subcritical, and startup preparations following a fueling or refueling outage. (20% power on at least one unit for identical multi-unit plant sites)

Shift Supervisor (Shift Manager)

Crew Cumulative Nuclear Power Plant Experience requirements AND Plant Operational Excellence Course OR Preoperational Testing Experience OR Hot Plant Observation

8. At least six weeks of operation above 20%

power. (20% power on at least one unit for identical multi-unit plant sites)

Senior Reactor Operator Crew Cumulative Nuclear Power Plant Experience requirements AND Plant Operational Excellence Course OR

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nei.org 20 Current Hot License Guidance Applicable Position Cold License Guidance Preoperational Testing Experience OR Hot Plant Observation

9. Three years power plant experience and three years nuclear power plant experience Senior Reactor Operator Practical Work Experience1 AND Crew Cumulative Nuclear Power Plant Experience requirements Reference NUREG 1021, Rev 12

1)

Practical work assignments include activities such as participating in procedure development and validation, human factors engineering activities, and task analysis verification, or conducting licensed operator classroom or simulator training.

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nei.org 21 Table 3: Illustration of Cold Licensing Plan by Candidate Type License Candidate Education Site Layout Course NLO Task Training RO Training SRO Training Plant Operational Excellence Course or Pre-op test activities or hot license Observation Activity Practical Work Experience1 Reactor Operator High school diploma Yes Yes Yes N/A N/A Yes Senior Reactor Operator

- no previous nuclear experience High school diploma Yes Yes Yes Yes Yes Yes Senior Reactor Operator

- previous license or military equivalent High school diploma Yes Yes Yes Yes Yes2 Yes Senior Reactor Operator

- certified instructor High school diploma Yes Yes Yes Yes Yes Yes

1)

Practical work assignments include activities such as participating in procedure development and validation, human factors engineering activities, and task analysis verification, or conducting licensed operator classroom or simulator training.

2)

Not required if candidate has at least 6 months of previous hot license experience.

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nei.org A-1 APPENDIX A. CHANGE TO EDUCATION REQUIREMENT FOR COLD LICENSE TRAINING FOR DIRECT SRO CANDIDATES Although NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, is based on the guidance found in NEI 06-13A, Appendix A, Cold License Training Plan, it provides an alternative educational option for eligibility of Direct Senior Reactor Operators (SROs) who are seeking eligibility based on educational background, with additional aptitude and leadership screening criteria.

This appendix lays the foundation for why a high school diploma is an acceptable minimum educational eligibility for a direct SRO. This is based on the safety design improvements of advanced reactors, changes to training programs since the 1989 Commission Policy Statement on SRO Education, and NUREG/BR-0303 on Guidance for Performance-Based Regulation.

Within the current fleet of nuclear power plants, eligibility for SRO candidates to enter a training program and hold an SRO license is established by any of these four ways:

RO upgrade candidates from within the organization RO or equivalent experience at other commercial or military reactors Certified SRO instructors 4-year Bachelor of Science Engineering Degree (or equivalent) plus sufficient responsible nuclear power plant experience During cold licensing (licensing of reactor operators during new plant construction and initial operation),

candidates are not able to use (or gain) experience from plant operations, because the facility is still under construction. Changes are made to the existing hot plant guidance to develop site specific experience using alternative methods. NEI 23-01, in a similar fashion to the methods found in NEI 06-13A, is proposing alternatives to the requirements to enter the training program. The overall goal is to ensure sufficient high-quality candidates are available to start the training program. An additional consideration is to ensure that a pipeline is developed to retain and re-train viable candidates from retiring coal power plants already residing where the next generation of nuclear power plants are likely to be built.

NEI 23-01 proposes an alternative educational option combined with additional screening assessments.

A high school diploma in combination with both a technical aptitude test and leadership assessment provides an additional eligibility option for SRO candidates, who have may have previous non-nuclear process plant experience but did not elect to further their academic study beyond high school. The high school diploma coupled with successful technical aptitude testing and leadership assessment provides an equivalent means for assuring high quality SRO candidates and there is no corresponding reduction in the final requirements needed to become licensed as an SRO. Each successful candidate must still pass an SAT-based Operator training program that has been certified by the NRC or INPO. They must also successfully pass an NRC Operator License Exam to become SRO license holders.

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nei.org A-2 The 1989 Commission Policy Statement on the Education for Senior Reactor Operators and Shift Supervisors at Nuclear Power Plants acknowledged the potential for situations to arise which are not covered through training or operating procedures. It also noted that there is a need for some individuals on each nuclear power plant operating shift who have an innate understanding of the systems-level performance of a nuclear power plant and knowledge of scientific and engineering fundamentals and the basic scientific principles that govern the behavior of electrical, mechanical, and other engineering systems. It goes on to state that this is the type of knowledge that academic institutions develop and convey well.

As part of the 1989 Commission Policy, it endorsed the INPO document, Principles for Enhancing Professionalism of Nuclear Personnel, dated March 1, 1989. In this INPO document it specifically notes that: While a college degree in a technical field is not a necessary requirement for operations positions, operators with bachelors degrees in technical subjects have a greater likelihood of promotion to and success in management positions. It goes on to say that: Management practices ensure that an appropriate number of personnel with such degrees, or the potential and desire for acquiring such degrees, are selected for operations positions.

While it is recognized that a bachelors degree in technical subjects is currently required for many of the management positions within the nuclear industry, this is a different requirement than that required to hold an operations position. Ensuring that there are enough individuals with the correct requirements to hold management positions is the duty of the management team, not something that is currently required by regulation. As noted in the 1989 Commission Policy Statement, rulemaking in this area was stopped due to input from the industry.

Scientific and Engineering fundamentals knowledge are a highly desirable trait for senior reactor operators to have. While these fundamentals can be gained in a college classroom, the fields of study and degree requirements differ between scholastic institutes. The basis of the path proposed within NEI 23-01 is that there are other, more germane, methods to teach these fundamentals that are most relevant to operating a commercial power plant.

Specifically, the upgrades to the industry training programs that came about, and are required as part of NUREG-0737, Clarification of TMI Actions Plan Requirements, provides relevant scientific and engineering fundamentals knowledge. While college degrees in the engineering and science areas can be assumed to teach these fundamentals, the only way to ensure that it has specific relevance to the operation of nuclear power plants is to teach it within the Operator training programs at the power plants. By including this, appropriate oversight of this important element now also falls within the scope of NRC monitoring and governance. In addition, this training would already be required training elements for any CP/COL holder. The applicants licensed Operator training programs for the plant include the following attributes and items:

They were developed using a systems approach to training, as described in 10 CFR Part 55 The math, physics, thermodynamics, and component design topics that are of specific relevance to the operation of a nuclear power plant o e.g., GFES training. The amount and style of mathematical training provided by various academic bodies varies widely from institute to institute. It has been concluded that the

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nei.org A-3 mathematics needed for achieving mastery of an initial operator training program is engineering mathematics needed to complete the standard industry generic fundamentals training as described in NUREG-0737.

The training for mitigating core damage The plant or design specific training, specifically:

o plant systems o plant or design specific reactor technology (including core physics data) o plant chemistry and corrosion control o reactor plant materials o reactor plant thermal cycle o transient/accident analysis o emergency procedures It is important to note that, from this list, only a site specific commercial nuclear power plant training program would be guaranteed to include all these elements. Mitigating core damage, plant systems, specific reactor technology (including core physics data), transient and accident analysis, and emergency operating procedure training could ONLY be acquired at a plant or design specific training program.

Additionally, these industry training programs also ensure that knowledge transfer occurs from Operating Experience (OE) at the site and from around the industry. This use of OE can only be found within the training programs at the nuclear facilities.

Since the 1989 Policy Statement, Operations training programs have continued to evolve. They now routinely include scientific and engineering fundamentals along with the basic scientific principles that govern the behavior of plant systems. This academic training, along with experience requirements, ensures that the operators that pass the initial license training programs have the proper background and training to operate the plants safely and reliably through all modes of operation. The impact of these changes is resulting in bringing safer and more reliable nuclear power generation to the market at a time when it is needed the most.

The approach used by the training programs of the U.S. Navy for nuclear plant operators provides good empirical data supporting why the industry feels that the change will be successful. With only a high school diploma required to join the Navy and participate in the Navys Nuclear Propulsion School, they have been turning out qualified nuclear plant Operators for decades.

Both the Navy and existing electric utilities utilize screening tests for potential operations candidates.

The Navy uses the Armed Services Vocational Aptitude Battery (ASVAB) test to measure aptitudes in verbal, math, science, and technical and spatial reasoning. The results are used to help determine the best job for the enlisted individual. Existing utilities often use the Plant Operator Selection System

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nei.org A-4 (POSS) test developed by the Edison Electric Institute (EEI) to help identify operations candidates for nuclear power plants. This test measures aptitudes in spatial reasoning, math, mechanical concepts, and written instructions. A licensee could use a similar test to establish a screening criterion for candidates who only have a high school diploma or equivalent to ensure they meet a minimum criterion for entry into the SRO training program. As noted elsewhere in this document, the systematic approach to training would ensure that the SRO training program starts at the appropriate educational level, i.e.,

candidates with HS diploma who meet initial test screening criteria. In fact, industry licensed operator training programs typically include both RO and SRO candidates and assume a minimum entry educational level vs a more advanced degree. The International Atomic Energy Agency has published its COMPETENCY ASSESSMENTS FOR NUCLEAR INDUSTRY PERSONNEL which also provides guidance on employee selection and placement through testing utilizing the SAT process.4 Similarly, the candidates with only a high school education would be screened for leadership aptitude.

Several utilities use leadership assessment tests to screen individuals who would pursue a supervisory position. These tests will typically present the candidate with oral and written scenarios requiring the candidate to demonstrate aptitude for becoming a first line supervisor, including problem solving personnel issues including both individual and teamwork issues, how to assign work, how to monitor performance and how to address performance issues including engagement of human resources. Some utilities will also employ a psychological assessment as well for supervisory candidates in addition to tests described. The International Atomic Energy Agencys report, Competency Assessments for Nuclear Industry Personnel, also provides guidance on leadership assessment tools used at Assessment Centers for evaluating leadership potential of supervisory and higher management candidates.5 Another factor that should be considered is previous power plant experience, especially in leadership roles. Similar work history in non-nuclear power plants, petrochemical; similar process plants; or steam propulsion plant design, construction, technical support, operation, maintenance, or training instruction can also offer valuable insights into a candidates leadership aptitude. Additionally, other related leadership experience in non-power plant technical industries could be considered based on the type of leadership attributes and an assessment of that experience against those relevant leadership attributes. The results of any of these methods would be used to screen the candidate for leadership aptitude.

With the move to performance-based alternatives, NUREG/BR-0303 provides guidance on a process for developing a performance-based alternative for consideration, in regulatory decision-making. This performance-based approach focuses primarily on results to, among other things, promote flexibility that can reduce licensee burden, and promote safety by focusing on safety-successful outcomes.

Although the subject of this paper is not specifically rule making, this NUREG is not specific to rule making either. It describes a process for any part of the regulatory framework that is being considered for modification. By using this approach within the educational requirements for direct SROs it allows the industry to meet the result (fully qualified SROs) rather than prescribing how the result is to be obtained.

Technological improvements from todays currently safe Nuclear Power Plants are being implemented in the modern designs. Advanced Nuclear Reactors have built into their designs operating experience from the large light water fleet, resulting in passive safety systems and lower operational complexity that 4 Competency Assessments for Nuclear Industry Personnel, Section 2.1, Employee Selection and Job Placement, International Atomic Energy Agency, Vienna, 2006. ISBN 92-0-110105-8 5 Competency Assessments for Nuclear Industry Personnel, Section 6.3 Other Types of Performance Assessment, International Atomic Energy Agency, Vienna, 2006. ISBN 92-0-110105-8

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nei.org A-5 should result in no or very few important human actions (IHAs) for design basis events (DBEs), improving the overall safety. These modern technologies also do not require operator intervention for the vast majority of abnormal conditions. The IHAs, if there are any, should have a very small probability of occurring and should be simple actions to be completed by a single operator at the controls given the integrated digital control systems typical of advanced reactor designs. The safety improvements in the design of ANRs along with the training improvements discussed allow the minimum educational requirement of a high school education for SRO candidates to be possible. This helps to reinforce that taking a performance-based approach to a qualified SRO still ensures that the safety of the public can be maintained.

In conclusion, this appendix has laid the foundation for why a high school diploma should be the minimum educational eligibility for a direct SRO. Ensuring that engineering and scientific foundations are laid by the training programs, viable candidates are screened through the employment process and focusing on a performance-based approach all ensure direct SROs are trained & qualified at the nuclear power plants. This approach broadens the pool of potential candidates and will continue to ensure that the control room individuals are well trained and ready to manage both the normal and off-normal operation of a nuclear power plant.

nei.org NEI 23-01 (Rev 2)

Operator Cold License Training Plan for Advanced Nuclear Reactors (Redline Version)

Prepared by the Nuclear Energy Institute July 2025

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nei.org Revision Table Revision Description of Changes Date Modified Responsible Person Draft Rev. A Initial revision 9/2023 Rick Stadtlander and Stew Yuen Rev. 0 Incorporation of Stakeholder Comments 9/2024 Rick Stadtlander and Stew Yuen Draft Rev 1

Incorporation of Stakeholder Comments 12/2024 Rick Stadtlander and Stew Yuen Rev 2 Incorporation of Stakeholder Comments 07/2025 Rick Stadtlander and Stew Yuen

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nei.org Acknowledgements This document was developed by the Operational Aspects of Advanced Reactors Team, led by the Nuclear Energy Institute. NEI acknowledges and appreciates the contributions of NEI members and other organizations in the preparation of this document.

NEI Project Lead: Rick Stadtlander, and Stew Yuen Notice Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

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nei.org Executive Summary NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, provides 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. The main objective of this report is to assist members in ensuring the proper qualifications are met in licensing operators.

This report does not address cold operator license training plans for operations staffing models presented in NEIs Proposal Paper, Regulations of Rapid High-Volume Deployable Reactors in Remote Applications (RHDRA) and Other Advanced Reactors, dated July 31, 2024, as this report predates the proposal paper.

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nei.org Table of Contents Introduction..................................................................................................................................... 1 Definitions........................................................................................................................................ 1 General Advanced Nuclear Reactor Cold License Training and Experience Requirements............ 6 3.1 Minimum Educational Requirements................................................................................. 6 3.2 Conduct of On-the-Job Training and Task Performance Evaluation (OJT/TPE).................. 7 3.3 Use of Part-Task/Limited Scope Simulators........................................................................ 7 3.4 Licensed Operator Continuing Training.............................................................................. 7 3.5 Crew Cumulative Nuclear Power Plant Experience............................................................ 7 3.6 Cold Licensing Process Applicability and Termination........................................................ 8 3.7 Experience Equivalency...................................................................................................... 8 3.8 Maintaining Proficiency While Under Construction........................................................... 8 Reactor Operator (RO) Eligibility and Training Requirements......................................................... 9 4.1 Education............................................................................................................................ 9 4.2 Training Related Experience Requirements........................................................................ 9 4.3 Additional Cold License Training and Watch Standing Requirements................................ 9 Senior Reactor Operator (SRO) Eligibility and Training Requirements.......................................... 12 5.1 Education.......................................................................................................................... 12 5.2 Training Related Experience Requirements...................................................................... 12 5.3 Additional Cold License Training and Watch Standing Requirements.............................. 13 Appendix A. Change to Education Requirement for Cold License Training for Direct SRO Candidates... A-1 Table of Figures Figure 1: ANR RO Eligibility and Training Requirements During Construction Phase................................. 11 Figure 2: ANR SRO Eligibility and Training Requirements for Personnel with Educational Backgrounds During Construction Phase......................................................................................................................... 14 Figure 3: ANR SRO Eligibility and Training Requirements for Previous Operator License, Military Reactor Operator, or SRO Certified instructor During Construction Phase............................................................. 16 Table of Tables Table 1: Crew Cumulative Nuclear Power Plant Experience Equivalencies................................................ 16 Table 2: Comparison of Hot and Cold License Guidance............................................................................ 18 Table 3: Illustration of Cold Licensing Plan by Candidate Type.................................................................. 22

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nei.org 1 INTRODUCTION The guidance document establishes an approach to meeting the requirements in 10 CFR 55 for the training and licensing of operators. This guidance is based upon the NRC-endorsed guidance NEI 06-13A for cold licensed operator training and is tailored to advanced nuclear reactors, which include light-water small modular reactors (LWR SMRs), non-LWRs, and micro-reactors. Prior to operation, plant experience requirements specified in regulatory and industry guidance documents and other standard guidance for operator selection, training, and qualification cannot be met. This document proposes a method to address this issue.

Cold licensing of operators provides a method for operations personnel to acquire the knowledge and experience required for licensed operator duties during the unique conditions of new plant construction and initial operation. Table 2, "Comparison of Hot and Cold License Guidance, shows the current hot license guidance versus the associated cold license guidance. Table 3, "Illustration of Cold Licensing Plan by Candidate Type, shows education and experience for each licensed operator candidate type.

Licensed operator candidates need not satisfy the experience requirements prior to entering a licensed operator training program. Experience and plant evolution requirements that have not been met at the time the licensed operator examination is administered shall be met prior to issuing the individuals NRC operator license. In such a case, the licensee will notify the NRC when the candidate meets the experience and plant evolution requirements.

The methods described in this guidance, along with the other cold license training elements provided within, provide the licensed operator candidate with meaningful experience on the reactor for which the license is sought. These criteria provide reasonable assurance that, at the end of the training program, the personnel will be qualified to operate and maintain the facility in a safe manner in all modes of operation.

It is also important to note that each Construction Permit (CP) or Combined Operating License (COL) holder (herein plant operator) will employ their own internal hiring criteria to candidates for a licensed operator training program. Typically, in addition to rigorous interviews and background checks, plants also use aptitude tests as a screening requirement as part of their hiring process. These practices would continue to be implemented because, ultimately, the plant owner is also deeply invested in only having the highest quality operators staffing their control rooms.

DEFINITIONS The following definitions are used throughout the document; some definitions have requirements described in addition to requirements discussed in Section 3.

Advanced Nuclear Reactor (ANR)

This term is used throughout this plan. It describes a fission reactor with significant improvements, including additional inherent safety features, compared to reactors operating on December 27, 2020, in the United States. This includes Light Water Reactors (LWR), Small Modular Reactors (SMR), non-LWRs,

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nei.org 2 and micro-reactors. This is consistent with the definition of Advanced Nuclear Reactor in 42 United States Code (USC) 162711.

Alternate Cold License Methods for OJT/TPE2 The On-the-Job-Training (OJT) and Task-Performance-Evaluation (TPE) phase during Cold Licensing will be modified to allow completion of this training before the plant becomes available. Acceptable methods for the conduct of OJT and TPE include discussion, simulation, tabletop exercises, and use of mockup equipment and virtual reality technology. This training includes familiarity with plant locations by use of plant layout diagrams and equipment diagrams. During the tabletop exercises the diagrams are used to allow the candidate to gain knowledge of important plant equipment building, elevation, and room locations. Examples of mock-up equipment which may be used are control room simulators (plant referenced, NRC staff approved, or part task simulators), training breaker labs, maintenance flow loop trainers, and Radiological Controls Area mock-up trainers.

Crew Cumulative Nuclear Power Plant Experience Each on-shift crew must have a cumulative total of at least 24 months1.2 years (14.4 months) of nuclear power plant experience times the minimum crew size. The crews cumulative nuclear power plant experience is gained by working at nuclear power plants and military nuclear propulsion plants, conducting licensed operator training, participating in new nuclear plant construction and testing, and completing academic degree requirements. The cumulative crew nuclear power plant experience is the sum of an individuals experience, in months, after applying weighting factors and maximum credit limits in Table 1, "Crew Cumulative Nuclear Power Plant Experience Equivalencies. When determining cumulative nuclear power plant experience, one crew member should not be contributing to all 24 months of the experience. In addition, at least one crew member must have hot plant experience. If a senior reactor operator with hot plant experience is not available, then a shift advisor may be substituted. The shift advisor will have at least one year of on-shift licensed senior reactor operator experience at a similar type (e.g. PWR/BWR/Molten Salt) operating plant and will have completed a training program on the design for which they are advising. While observing crew performance, the shift advisor will make recommendations to the shift manager only, and will not interfere with the licensed responsibilities of the operating crew. The shift advisor will have direct access to plant senior management to resolve issues. Shift advisor duties include, but are not limited to the following:

Monitor procedure adherence Observe the conduct of pre-job briefs, shift turnover, plant evolutions, nonlicensed operator rounds, plant tours, and post job debriefs Monitor overall station risk Degree in Science or Applied Science This term is used in Figure 2. The degree in science or applied science used to establish eligibility for a Senior Reactor Operator (SRO) candidate shall be from an engineering, engineering technology, or related science program, or from a mathematics, or computer science program. Acceptable degrees are 1 42 USC 16271: Nuclear energy (b) Definitions (1) Advanced nuclear reactor 2 Alternate guidance to satisfy NUREG 1021, section 3.7 Alternatives for In Plant Job Performance Measures at Plants under Construction

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nei.org 3 Associates, Bachelors, Masters, and Doctorate degrees in any of those disciplines that may be credited to satisfy the requirements. The degree shall be from a nationally accredited college or university.

Degrees from the areas of communication, natural sciences, humanities, or social science are not credited.

An evaluation of degrees in related technical fields, or equivalent, can be used to identify those degrees beyond engineering or engineering sciences having an appropriate amount of engineering, mathematics, chemistry, and/or physics study. A curriculum review, when performed, should determine an acceptable amount of mathematics and science coursework required for license class level of understanding as determined by the utilities use of a Systematic Approach to Training (SAT) based analysis. Credit may also be given for pre-license class work in mathematics and science topics necessary to be successful in obtaining a license. A selection board comprised of leaders from Training and Operations and chaired by the Site Vice President (or equivalent) should make these determinations.

Documentation of such reviews, pre-course work, and other actions to declare academic eligibility should be maintained as part of candidate records.

Hot Plant Experience This definition is used when determining experience equivalency requirements. It describes work experience as a Reactor Operator (RO) or SRO at a power reactor that includes the following: at least six weeks of that experience including at least one unit operating above 20 percent power, a startup from subcritical to 20 percent power, a shutdown from above 20 percent power to cold and subcritical, and startup preparations following a fueling or refueling. The startup, shutdown, and startup preparations may have been performed at an operating plant or a plant simulator. The hot plant experience can be gained at any power reactor of any design, vendor, or vintage.

Hot Plant Observation This definition is used when determining experience equivalency requirements and is defined as at least 6 weeks of structured observation of operating crews at an operating commercial nuclear power plant of like design. The purpose of these observations is to familiarize candidates with the licensed operating crew roles and responsibilities and applied techniques for maintaining the high levels of nuclear professionalism expected in an operating nuclear power plant environment. To facilitate learning, it is recommended that structured observation at a hot facility include the observation of work activities performed by control room crews, non-licensed operators in the plant areas, work control/work management personnel, clearance and tagging personnel, and the outage planning staff.

Micro-Reactor An Advanced Nuclear Reactor (ANR) that has an electric power production capacity that is typically less than 50 megawatts. This definition is consistent with 42 USC 187513.

Military Reactor Operator Equivalent This term, used in Figure 3, describes military nuclear experience where the candidate is qualified to manipulate control rods or supervise the manipulation of control rods. For United States Navy 3 42 USC CHAPTER 162, SUBCHAPTER III, Part A: Nuclear Energy Infrastructure §18751. Infrastructure planning for micro and small modular nuclear reactors (a) Definitions (3) Micro-reactor

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nei.org 4 personnel, these positions are reactor operator, engineering officer of the watch, propulsion plant watch officer, engineering watch supervisor, and propulsion plant watch supervisor. There may be other positions not included here which should be evaluated by the licensee for equivalency.

The start date for calculating total military nuclear experience is the date on which military nuclear-power-plant-related prototype training is completed. End dates are calculated using military discharge dates or dates on which the candidate no longer holds the applicable military nuclear qualifications.

Non-licensed Operator Selected Tasks The selected non-licensed operator tasks are those tasks that are important to plant operation and contribute to nuclear safety, defense-in-depth, or that are risk significant. Typically, these tasks are associated with the local operator tasks within the Emergency Operating Procedure network. The tasks are implemented using alternate Cold License methods for OJT/TPE.

Plant Operational Excellence Course This is intended for sites without ready access to an operating commercial nuclear power plant. The course duration is 6 weeks. The scope of this course should include training in a full-scope simulator, and cover the following topics:

Teamwork Human Performance Factors Diagnostic Skills Mitigating Core Damage Transient and Accident Operations Power Plant Experience This term describes applicable work performed in fossil-fueled or nuclear-fueled electric power production plants during preoperational, startup testing or operational activities. Experience in nuclear-fueled or petrochemical process production plants; similar process plants; or steam propulsion plant design, construction, technical support, operation, maintenance, or training instruction can be substituted for applicable power plant experience. Simply observing others performing work is not considered power plant experience. Time spent in classroom training cannot be counted toward power plant experience requirements. However, time spent in a structured, job-related development program may be considered power plant experience. Also, time spent performing job-based training and qualification activities in the plant such as under instruction watchstanding, on-the-job training, and task or watchstation qualification activities can be applied toward power plant experience requirements. Time spent performing in-plant job-based training and qualification activities should be specifically documented if such time is used to meet power plant experience requirements.

July2025

nei.org 5 Preoperational Test Experience This definition is used when determining experience equivalency requirements. At least 6 weeks of participation in control room activity during the site preoperational testing phase. The preoperational test experience does not have to be completed before applying for an SRO or RO license or taking the NRC SRO or RO Operator licensing examination but must be completed before the license is issued.

Practical Work Experience Cold License Candidates must complete at least 3 months of practical work experience assignments., OR 1 month of The amount of time necessary to complete the pPractical work experience is pre-determined during the candidate selection process and done using a systematic analysis of candidate needs. It is dependent on several common components such as the plant design and the license level being sought.

It also depends on individual needs such as candidate aptitude, experience, maturity and drive. As an example, the practical work experience assignments for a light water ANR plant design may take 3 While the existing reactor fleet uses a specific time requirement for practical work experience, months to complete, while the practical work experience for Micro-Reactors may be 1 month long due to the limited number of activities in this style of reactodifferences in designs and complexity for advanced reactors calls for a different method using a SAT-based approach and should be described in the licensees submittal to the NRC. For these activities to be considered meaningful, they must be associated with safety significant or defense-in-depth activities, or other major plant components or systems. These practical and meaningful work assignments include documented participation in preoperational testing and in one or more of the following activities:

procedure development and validation human factors engineering activities task analysis verification preparation, review, approval or implementation of licensed operator classroom or simulator training These work assignments allow the operator candidate to gain experience on the reactor design for which the license is sought. Therefore, structured observation training at another operating nuclear power plant cannot be used to reduce the duration of these work assignments. The practical work experience does not have to be completed before applying for an RO or SRO license or taking the NRC RO or SRO licensing examination but must be completed before the license is issued.

Site Layout Course The site layout course is designed to gain familiarity with the site layout before the physical plant becomes available. The course should be consistent with the SAT process, with a focus on the areas of the plant equipment that will be operated by operations department staff. The course should also include navigation to the local plant equipment used in the RO or SRO qualification guide and the NLO selected task guide, as implemented using Alternate Cold License Methods for OJT/TPE.

SRO Certified Instructor

July2025

nei.org 6 For the purposes of determining eligibility per Figure 3, an SRO certified instructor is one who has completed initial written and operating examinations to certify SRO-level knowledge including generic fundamentals; systems; plant normal, abnormal, emergency, and administrative procedures; mitigating core damage; and plant technical specifications. An SRO certified instructor is also one who participates in the licensed operator continuing training program and who satisfactorily completes annual operating examination and biennial comprehensive written examination requirements to certify maintenance of SRO-level knowledge.

GENERAL ADVANCED NUCLEAR REACTOR COLD LICENSE TRAINING AND EXPERIENCE REQUIREMENTS Additional considerations are required for an initial license operator training course during the plant construction phase (Cold Licensing) of an ANR and are provided here:

3.1 Minimum Educational Requirements Both RO and SRO candidates require a minimum of a High School Diploma or equivalent. There are additional screening criteria for SRO candidates with a High School Diploma or equivalent to be eligible for the operations training program.

Requiring a minimum education of a High School Diploma, or equivalent (e.g., General Education Diploma, GED) for the SRO, rather than an associate degree or bachelors degree, requires additional considerations by the applicant. SRO candidates will generally fall into two categories, those with previous nuclear experience and those with an educational background. For those candidates who are eligible by an educational background, these can be further divided into those with a Degree in Science or Applied Science and those who have a High School Diploma and have undergone additional screening to ascertain their aptitude. In order to ensure the health and safety of the public, the applicant will need to validate that the SRO candidates that are eligible using the High School Diploma and additional screening can meet certain criteria to ensure that they can perform the function of an SRO following their training. These criteria are summarized below:

Establishing SRO candidate eligibility using the High School Diploma, or equivalent, and additional screening path does not mean that this individual is directly out of high school. This individual could be a fossil plant operator with years of experience, but one that only completed their high school education before coming into the workforce. Their experience and informal training would qualify them from a leadership capacity, but additional training may be required to ensure they are ready for an SRO position at a nuclear facility.

The screening methodology used for an SRO candidate who establishes eligibility using this path will be established by the applicant. The intent is that the screening will assess their aptitude in verbal communication, math, science, and technical and spatial ability. This could take the form of an entrance exam like the ASVAB (Armed Services Vocational Aptitude Battery) which is used to set the standard entry criteria for the Nuclear Navy candidates or the Plant Operator Selection System (POSS) test that is a battery of aptitude tests that are used by electric companies to identify candidates for power plant operator positions. A selection board comprised of leaders from the Training and Operations departments and chaired by a senior leader (site vice president or equivalent) should make these determinations. Documentation of such reviews, pre-course work, and other actions to declare eligibility shall be maintained as part of candidate records.

July2025

nei.org 7 The licensed operator training program would then be based on the starting point for the individuals defined by the minimum standards from this screening process. This process would provide the minimum criterion for the training program to ensure that the right technical aptitude is obtained to operate ANRs. The training program is required to be designed within the Systematic Approach to Training.

In addition to the technical aptitude test, a screening for leadership capabilities would also be required.