ML26012A332
| ML26012A332 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold  |
| Issue date: | 01/12/2026 |
| From: | Reuer J Nextera Energy |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML26012A332 (0) | |
Text
Joshua Reuer Corporate Training Director January 12, 2026 Meeting on Piloting of Facility-Administered Operating Tests Florida Power and Light Company NextEra Energy Seabrook, LLC NextEra Energy Point Beach, LLC NextEra Energy Duane Arnold, LLC
- Introductions
- Meeting purpose / goal
- Background for proposal and rationale
- Overview of proposal
- Envisioned roles of facility and NRC staff
- Regulatory considerations for pilot
- Proposed deliverables
- Questions Agenda NRC Meeting - January 12, 2026
Meeting
Purpose:
Engage in a dialogue with the NRC staff on a proposal for NextEra Energy staff to pilot administering and grading initial operator licensing operating tests.
Meeting Goal:
Establish a clear understanding of the needed deliverables and timeline required for the NRC to review and approve this pilot, including the associated license amendment request (LAR), topical report (as appropriate), and regulatory exemption requests.
Meeting Purpose NRC Meeting - January 12, 2026
- Objective is to make the best use of resources
- NRC staffing limitations place constraints on exam schedules
- Concurrently, the NRC staff face an increasing workload due to advanced reactor deployment
- A limited NRC examiner pool needs to support exams and inspections at existing plants, while also conducting program reviews, inspecting simulators, and cold-licensing operators
- Scheduling and timeliness challenges are emerging
- Facilities would benefit from enhanced examination capacity (e.g., more exams, larger classes, retakes and scheduling)
The operator licensing pipeline for existing nuclear plants is vital; effective resource balance is needed Background for Proposal Facility-Administered Operating Tests The best approach and mutually positive change uses both NRC and facility resources
- An exemption from regulations would be needed
- 10 CFR 55.40 states, in part, the following (emphasis added):
(a) The Commission shall also use the criteria in NUREG-1021 ["Operator Licensing Examination Standards for Power Reactors"] to evaluate the written examinations and operating tests prepared by power reactor facility licensees pursuant to paragraph (b) of this section.
(b) Power reactor facility licensees may prepare, proctor, and grade the written examinations required by §§ 55.41 and 55.43 and may prepare the operating tests required by § 55.45, subject to the following conditions
- A 10 CFR 55.11 exemption would be requested from aspects of the requirements of 55.40 because 55.40 excludes (by omission) facility administration and grading of operating tests Background for Proposal (continued)
Facility-Administered Operating Tests The 10 CFR 55.11 process for specific exemptions would be used
- The underlying reasoning draws from several points:
- Piloting a modification of the exam process has past precedent; a comparable effort in 1996 led to a subsequent transition to facility-authored exams
- A recent proposal was made by the NRC to allow for facility-administered operating tests under the proposed 10 CFR Part 53
- The Canadian Nuclear Safety Commissions operator certification process uses facility-administered operating tests at all Canadian nuclear plants
- The NRC examiner staff already have extensive experience with inspecting operating test administration by facilities during requalification program inspections
- Facility staff have been evaluating audit/certification exams using processes that parallel the NRCs for decades Rationale Behind Proposal Facility-Administered Operating Tests The proposal draws from established process and precedents
Operating test development and approval would occur identically to the current process.
- Differences would be in administration and grading responsibility Operating tests (i.e., simulator scenarios and JPMs) would be administered by licensee staff evaluators using the exact same NUREG-1021 guidelines as NRC examiners currently use
- For example, 1-to-1 evaluator/examinee ratio during simulator sets and maintaining an evaluator of record Operating test grading documentation would be completed by facility staff and forwarded to the NRC chief examiner and cognizant branch chief with a pass/fail recommendation
- This would include Forms 3.6-1 (JPM grades), 3.6-2 & 3 (scenario grades), and 5.1-2 (individual report)
Post-exam comment and informal review resolution processes would remain in accordance with existing NRC practices Overview of Proposal Facility-Administered Operating Tests The proposed approach maintains key aspects of the existing process
Qualification process for evaluators would draw from NRC IMC-1245 Appendix C-10 examiner qualification Staff conducting evaluations would be independent of those associated with the training of applicants at the facility
- For example, corporate training staff, staff from other facilities, and peers from other utilities would be used as evaluators
- Measures would be implemented to avoid conflicts of interest Evaluator teams would include a lead evaluator role (e.g., a designated corporate supervisor) that would provide supervision NRC chief examiner would retain exam review and approval role, overall authority for exam, and post-exam comment/appeal role.
Operating test administration and grading would be inspectable by the NRC by whatever means that the NRC determines appropriate
- Transparency and inspectability are key goals of the proposal Envisioned Roles of Facility and NRC Staff Facility-Administered Operating Tests The proposed approach would maintain the NRCs regulatory role in the examination process
AEA of 1954 (as amended) requires uniform operator licensing conditions at the various classes of utilization facilities
- Per §55.31 these include 1) completing a training program, 2) five control manipulations, 3) medical condition certification, and
- 4) completing both a written examination and an operating test
- A §55.11 exemption is needed from portions of §55.40 which exclude operating test administration by facility licensee staff
- Topical Report (TR) could be submitted for review under LIC-500 If using the TR approach, NRC licensing authority would be maintained, uniform conditions for licensing operators would be preserved, and well-established processes would be used
- A LAR would be needed to establish conforming operating license (OL) conditions for facilities involved in the pilot
- Pilot success measures would include compliance and quality, with issues being placed into the Corrective Action Program Regulatory Considerations for Pilot Facility-Administered Operating Tests The proposed approach is consistent with NRC statutory mandates
Facility-Administered Operating Tests Formal submittal would likely be in early 2026
- §55.11 exemption request for relevant aspects of §55.40
- Potentially a TR detailing the program plan
- §50.90 LAR modifying operating licenses to authorize program plan usage (e.g., Point Beach, Seabrook, St. Lucie, Turkey Point, and Duane Arnold)
Dry-run with NextEra Energy and NRC staff to exercise process prior to the first operating test being conducted under the pilot The 2027 St. Lucie exam would tentatively be the first exam conducted under the pilot approach
- Open to feedback on the necessary duration of pilot Proposed Milestones NextEra would like feedback on the proposed approach, timeline, and need for a follow-on meeting
Atomic Energy Act of 1954, as amended, Section 107 10 CFR Part 55, Operator Licenses SECY-98-266, Final Rule -- Requirements for Initial Operator Licensing Examinations Generic Letter 95-06, Changes in the Operator Licensing Program NRC IMC 1245, Appendix C-10, Operator Licensing (OL) Examiner Technical Proficiency Training and Qualification Journal NRC IP 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance Proposed 10 CFR Part 53 rule, paragraph 53.780(b)(3)
Operator Licensing Program Feedback Question Gen.7 (inquiry regarding facility-administered operating tests)
Canadas regulatory guidance which addresses key aspects of the CNSC examination process is available via https://www.nuclearsafety.gc.ca/eng/acts-and-regulations/consultation/comment/regdoc2-2-3/
References
Questions Florida Power and Light Company NextEra Energy Seabrook, LLC NextEra Energy Point Beach, LLC NextEra Energy Duane Arnold, LLC