ML26048A712
| ML26048A712 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 02/15/2026 |
| From: | NRC |
| To: | NRC/NRR/DANU |
| References | |
| Download: ML26048A712 (0) | |
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Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Layout: DLT-007 Rev 9 Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Document ID Number Configuration Classification :
Revision Security Classification Status Date Created Project 006012-A XE00-GL-GL-GL-GL-GL-L 4
Unrestricted Approved 28-OCT-2024 XE-100 This document is the property of X Energy, LLC. The content may not be reproduced, disclosed, or used without the Companys prior written approval.
Mr. James Fogarty Licensing Manager, Xe-100 X Energy, LLC.
530 Gaither Road, Suite 700 Rockville, MD 20850
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSIONS FINAL SAFETY EVALUATION FOR X ENERGY, LLCS TRAINING PROGRAMS METHODOLOGY TOPICAL REPORT, REVISION 4 (EPID NO: L-2024-TOP-0008)
Dear Mr. Fogarty:
By letter dated December 9, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24344A156), X Energy, LLC., (X-energy) submitted Revision 4 of its Training Programs Methodology topical report (TR) to the U.S. Nuclear Regulatory Commission (NRC) for review. The TR would be used by a reactor applicant or licensee to establish, implement, and maintain Xe-100 training programs that are based on a systems approach to training (SAT) in order to meet training program requirements in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.120, Training and qualification of nuclear power plant personnel, and 10 CFR Part 55, Operators Licenses.
The NRC staffs final safety evaluation (SE) for X-energys Training Programs Methodology TR is enclosed. The NRC staff concluded that the TR is acceptable, subject to the limitations documented in the SE. The NRC staff requests that X-energy submit an accepted version of the Training Programs Methodology TR within 3 months of the receipt of this letter. The accepted version shall incorporate this letter and the enclosed SE.
September 5, 2025
J. Fogarty If you have any questions, please contact Adrian Muniz via email at Adrian.Muniz@nrc.gov.
Sincerely, Stephen Philpott, Acting Chief Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No.: 99902071
Enclosure:
As stated cc: X-Energy Xe-100 via GovDelivery jmaddocks@x-energy.com Signed by Philpott, Stephen on 09/05/25
ML25080A206 NRR-043 OFFICE NRR/DANU/UAL2:PM NRR/DANU/UAL2:LA NRR/DRO/IOLB:BC NAME AMuniz CSmith JAnderson DATE 3/25/2025 4/02/2025 4/09/2025 OFFICE OGC-NLO NRR/DANU/UAL2:BC NAME JEzell SPhilpott DATE 6/18/2025 9/5/2025
Enclosure X ENERGY, LLC., - FINAL SAFETY EVALUATION OF TOPICAL REPORT XE-100 TRAINING PROGRAMS METHODOLOGY, REVISION 4 (EPID L-2024-TOP-0008)
SPONSOR AND SUBMITTAL INFORMATION Sponsor:
X Energy, LLC.
Sponsor Address:
530 Gaither Road Rockville, MD 20850 Docket/Project No.:
99902071 Submittal Dates: March 27, 2024, and December 9, 2024 Submittal Agencywide Documents Access and Management System (ADAMS) Accession Nos.: ML24089A243 and ML24344A156.
Brief Description of the Topical Report:
By letter dated March 27, 2024 (ADAMS Accession No. ML24089A243), X Energy, LLC (X-energy), submitted licensing Topical Report (TR)-006012, Revision 3, Xe-100 Training Programs Methodology. Following the U.S. Nuclear Regulatory Commission (NRC or Commission) staffs regulatory audit of Revision 3 of TR-006012 (ML25093A326), X-energy submitted Revision 4 (hereafter referred to as the TR) by letter dated December 9, 2024, (ML24344A156).
The TR provides a methodology to be used by an applicant or licensee to establish, implement, and maintain Xe-100 training programs that are based on a systems approach to training (SAT) in order to meet training program requirements in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.120, Training and qualification of nuclear power plant personnel, and 10 CFR Part 55, Operators Licenses. An applicant or licensee that uses this methodology to develop Xe-100 training programs for licensed operators will need to seek Commission approval or National Nuclear Accrediting Board (NNAB) accreditation of training programs used for the licensing of operators, including requalification programs. The NRC staff reviews training programs for nuclear power plant personnel as part of its review of the operational programs submitted at the operating license/combined license (OL/COL) application stage.
For additional details on the submittal, please refer to the documents located at the ADAMS Accession Numbers identified above.
REGULATORY EVALUATION Regulatory Basis:
As discussed in the synopsis and conclusion sections of the TR, X-energy requested the NRC staffs review and approval of its methodology for developing training programs that are based on the SAT.
The regulatory requirements and guidance that the NRC staff considered in its review of the TR are as follows:
Regulation 10 CFR 55.31, How to apply, which includes the requirements for applicants applying for an operator license. Specifically, 10 CFR 55.31(a)(4) applies to individual applicants when applying for an operator license at a facility licensee site. To apply for a reactor operator or senior reactor operator license at a specific facility, an applicant must provide, among other things, evidence that they have successfully completed their facility licensees requirements to be licensed as an operator or senior operator, including details of the applicants qualifications, details regarding courses of instruction administered by the facility licensee, a description of the nature of the training received at the facility, and the startup and shutdown experience received. As an alternative to providing these details in the application, the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based on a systems approach to training and that uses a simulation facility acceptable to the Commission.1 Regulation 10 CFR 50.120, Training and qualification of nuclear power plant personnel, which includes the requirements for establishing training and qualification programs.
o Regulation 10 CFR 50.120(b)(1) states in part, each nuclear power plant operating license applicant, by 18 months prior to fuel load, and each holder of an operating license must establish, implement, and maintain a training program that meets the requirements of paragraphs (b)(2) of this section. Additionally, holders of a combined license must establish, implement, and maintain the training program that meets the requirements of paragraphs (b)(2).
o Under 10 CFR 50.120(b)(2) the training program must be derived from a systems approach to training as defined in 10 CFR 55.4, Definitions.
Regulation 10 CFR 55.4 states, in part, that the systems approach to training means a training program that includes the following five elements:
1.
Systematic analysis of the jobs to be performed.
2.
Learning objectives derived from the analysis which describe desired performance after training.
1 The NRC staff did not evaluate the TR methodology for compliance with 10 CFR 55.31(a)(4) but considered the potential impacts of implementation of the TR methodology on a future operator license applicants application.
3.
Training design and implementation based on the learning objectives.
4.
Evaluation of trainee mastery of the objectives during training.
5.
Evaluation and revision of the training based on the performance of trained personnel in the job setting.
NUREG-1220, Training Review Criteria and Procedures, Revision 1, provides criteria for evaluating the implementation of a systems approach to training and is used by the NRC staff to review training programs for compliance with the requirements of 10 CFR 50.120 and 10 CFR 55, as applicable. Applicants or licensees can also comply with the requirements of 10 CFR 50.120 without being accredited by the NNAB (58 FR 21904, 21908; April 4, 1993). NUREG-1220 has been revised to be consistent with this regulation, and the guidance will be used by the NRC staff for program evaluations.
Therefore, the NRC staff determined that NUREG-1220 is the most applicable guidance to use to determine compliance with 10 CFR 50.120(b)(2) and 10 CFR 55.4 in review of the TR.
TECHNICAL EVALUATION The NRC staff reviewed the TR using NUREG-1220, Revision 1 which provides guidance to the NRC staff for evaluating whether a licensees training program is based on a systems approach to training. The TR does not contain a training program. Instead, the TR contains a methodology to develop Xe-100 training programs. Therefore, the NRC staff considered whether the TR methodology, if followed by an applicant referencing this TR, could result in a training program that meets the criteria in NUREG-1220. The NRC staffs review of this TR does not constitute the Commissions approval of a training program as required, in part, by 10 CFR 55.31(a)(4). As the TR notes in the synopsis, the review and approval of training programs developed with the TR methodology is outside the scope of the TR.
The TR contains multiple sections; however, as stated in the synopsis and conclusion of the TR, X-Energy requested the NRC staffs approval of a methodology for developing training programs that are derived from a systems approach to training as required by 10 CFR 50.120(b)(2) and defined in 10 CFR 55.4. Therefore, the NRC staff limited its review to TR section 3, X-energy Systems Approach to Training for the Xe-100, and how the training program methodology described in that section, if implemented, could result in a training program that meets the requirements of 10 CFR 50.120(b)(2) and 10 CFR 55.4. Thus, the NRC staff does not make any determinations or conclusions on any information in other sections of the TR, though it provided context for the NRC staffs review of TR section 3.
The NRC staff reviewed TR section 3 using NUREG-1220, Training Review Criteria and Procedures, Revision 1 and the definition of the systems approach to training in 10 CFR 55.4.
The NRC staffs technical evaluation is organized as follows:
Section 1.0 contains the NRC staffs evaluation of how the TR methodology, if implemented, could result in a training program that satisfies the first element of the SAT for a systematic analysis of the job(s) to be performed.
Section 2.0 contains the NRC staffs evaluation of how the TR methodology, if implemented, could result in a training program that satisfies the second element of the SAT for learning objectives which are derived from the analysis and describe the desired performance after training.
Section 3.0 contains the NRC staffs evaluation of how the TR methodology, if implemented, could result in a training program that satisfies the third element of the SAT for the design and implementation of training which is based on the learning objectives.
Section 4.0 contains the NRC staffs evaluation of how the TR methodology, if implemented, could result in a training program that satisfies the fourth element of the SAT which involves the evaluation of trainee mastery of objectives during training.
Section 5.0 contains the NRC staffs evaluation of the fifth element of the SAT process which involves the evaluation and revision of training based on the performance of trained personnel in the job setting.
In addition, as part of the technical review, the NRC staff conducted a regulatory audit that concluded on October 15, 2024 (ML25093A326).
1.0 SAT element 1: Systematic analysis of the job to be performed According to NUREG-1220, Revision 1, the analysis element of the SAT means that plant and training staff use a systematic analysis process to identify the job tasks and associated knowledge and skills needed to meet job performance requirements. The analysis element of a training program is systematic if it includes the following characteristics:
1.1.
A systematic method is used to identify job tasks.
1.2.
Tasks are objectively selected for training.
1.3.
Tasks are differentiated for initial and continuing training.
1.4.
The results of analysis are adequate for the subsequent development of learning objectives.
1.5.
New or changed tasks are analyzed to determine training needs.
The NRC staff reviewed TR section 3.1, Analysis Phase, which contains X-energys methodology for conducting the analysis phase of an SAT based training program, to confirm that it contains a systematic process to identity job tasks and associated knowledge and skills for use in training, including the characteristics above.
First, for Characteristic 1.1 above, the NRC staff reviewed how the TR directs use of a systematic method to identify job tasks. According to the TR, the Analysis Phase consists of four activities: Needs Analysis, Job Analysis, Task Analysis, and Cognitive Analysis. The Job Analysis is specifically used to identify tasks for a specific job or position and includes inputs from the Xe-100 human factors engineering program, plant design, and safety analysis. TR section 3.1.2, Job Analysis, states that a Job Analysis is conducted to produce a list of duty areas and tasks for specific job or position. A Job Analysis evaluates what the individual does on the job (performance-based tasks) rather than what the individual must know to perform the job. TR section 3.1.2 also describes who participates in a Job Analysis, which states Job incumbents and subject matter experts participate in Job Analysis by providing input and reviewing job requirements. Training and Line supervision review and approve Job Analysis results.Personnel familiar with the Job Analysis process (e.g., job incumbents, subject matter experts, training staff) generate a task list derived from a Job Analysis. TR section 3.1.2 includes a list of specific criteria for task statements that meets NUREG-1220 Revision 1 guidance for being systematic. For example, consistent with NUREG-1220, the TR states that task statements must consist of a logically ordered set of steps able to be executed with consistent results on different occasions by different people and requires a record of review and approval. Based on the above, the NRC staff concludes that the TR methodology for the analysis phase contains a systematic method to identify job tasks.
For Characteristics 1.2 and 1.3, the NRC staff reviewed the TR for the determination of whether tasks are objectively selected for training and if tasks are differentiated for initial and continuing training.
TR section 3.1.2.1 states that Difficulty, Importance, and Frequency (DIF) Analysis [is used to]
determine whether a task should be trained and how often the task should be retrained.The DIF results are averaged to determine one of the following outcomes for each task: no training, initial training only, or initial and continuing training. The TR identifies the participants for required reviews of the DIF analysis, as the job analysis participants. The details of who participates in job analysis is identified in section 3.1.2 of the TR, which states, Job incumbents and subject matter experts participate in Job Analysis by providing input and reviewing job requirements. Based on the NRC staffs review of TR section 3.1.2.1, the staff concludes that the DIF analysis is a systematic method for determining whether tasks are objectively selected for training and, when selected for training, how tasks are differentiated for initial and continuing training, consistent with NUREG-1220.
Next, for Characteristic 1.4, the NRC staff reviewed the TR to determine if the methodology requires results from analysis activities to be used in the development of learning objectives.
Because actual results from analysis activities are not available, the NRC staff cannot make a determination on the adequacy of results; this will be done at the time of training program review or inspection. TR section 3.1.3, Task Analysis, states that Task Analysis produces a defined list of job attributes required for satisfactory task performance. Task analysis reviews task statements within the context to their plant application to identify characteristics of the task.
These characteristics are used to design and develop training content for incumbent qualification. The TR includes a list of characteristics of task analysis including: initial conditions, standards, elements (steps), tools, equipment, safety concerns, associated performance or cognitive statements required, and branch steps and alternate paths of the task.
Additionally, the TR states that Task Analysis includes all aspects of job performance, including but not limited to tasks important to safe plant operation and tasks related to the foundational theory of plant operations.
TR section 3.1.4, Cognitive Analysis, states that Cognitive Analysis is an iterative process that is conducted to systematically group and organize cognitive elements into common or prerequisite training cognitions. These cognitions are then analyzed to determine a training recommendation, i.e., no training, initial training, or initial and continuing training. If initial and continuing training are recommended, the Cognitive Analysis also recommends a retrain frequency. Subject matter experts and/or job incumbents participate in a Cognitive Analysis by providing input and reviewing job and task requirements. Accordingly, the NRC staff concludes that the TR methodology requires results from analysis activities to be used in the development of learning objectives, which is consistent with NUREG-1220.
Lastly, for Characteristic 1.5, the NRC staff reviewed the TR for determination of whether the methodology requires new or changed tasks to be analyzed to determine training needs. TR section 3.1.1 states that a Needs Analysis is performed to identify potential training needs, to suggest and approve training solutions, and where possible recommend non-training solutions to improve personnel performance. The TR specifies items that can result in the generation of a needs analysis, including training requestsfeedback, observation of task performance, audit or assessment finding, plant or human performance event, or engineering change with training program impact. Based on the NRC staffs review of TR section 3.1.1, the staff concludes that the TR method for conducting a Needs Analysis requires a training program to include a determination of whether training is needed for new or changed tasks, consistent with NUREG-1220.
Based on the evaluation of the characteristics discussed above, the NRC staff concludes that the TR contains an acceptable methodology for the analysis element of the SAT because the TR describes a method for a systematic process for identifying job tasks, differentiating and selecting tasks for initial and continuing training, and analyzing new or changed tasks to determine if training is needed. The TR methodology requires the results of the analysis activities to then be used to develop training learning objectives. As discussed above, this methodology is consistent with the guidance of NUREG-1220 for the Analysis element, and therefore, is acceptable.
2.0 SAT element 2: Learning objectives are derived from the analysis which describes the desired performance after training According to NUREG-1220, Revision 1, learning objectives should support successful job performance by reflecting analysis results and by providing conditions and standards for job performance behaviors and actions expected of trainees upon the completion of training. A method of objective design is considered systematic if it includes the following characteristics:
2.1 Learning objectives exist for tasks selected for training.
2.2 Learning objectives conditions, actions and standards reflect job performance requirements.
2.3 Learning Objectives are revised as needed to reflect job changes.
The NRC staff reviewed TR section 3.2, Design Phase, which contains X-energys methodology for developing learning objectives to confirm that it contains a systematic process to design learning objectives for tasks selected for training, learning objectives reflect job performance requirements, and learning objectives are revised as needed to reflect job changes. The guidance in NUREG-1220 pertains to the review of learning objectives and not the process to develop them; therefore, the NRC staff focused on how the TR methodology could be used to develop learning objectives that satisfy the characteristics above.
First, for Characteristic 2.1, the NRC staff verified that the TR contains a methodology to consistently create learning objectives for the tasks selected for training. TR section 3.2.2, Develop Learning Objectives, states that learning objectives are created, validated, or revised from results of the Analysis Phase. The TR also specifies the use of terminal and enabling objectives. Terminal objectives are derived from the task statement and focus on the overall results of the training while enabling objectives are written for each task element that a trainee must master to successfully complete the associated terminal objective. Based on this, the NRC staff concludes that the TR contains a methodology that will consistently create learning objectives for tasks that are selected for training, consistent with NUREG-1220.
Next, for Characteristic 2.2, the NRC staff reviewed the TR for how the methodology for developing learning objectives includes a process to consistently create conditions, actions and standards that reflect job performance requirements. TR section 3.2.2, Develop Learning Objectives, states that learning objectives consist of three components: a condition, an action, and a standard.The condition statement clearly states the condition(s) that will exist at the time of trainee performance. Regarding action statements, TR section 3.2.2 states that the action verb should identify trainee behavior that is observable, measurable, and applicable to trainee performance. Regarding the standard component of learning objectives, the TR states that the standard statement identifies the standard for evaluating student performance[and]
are derived from job standards identified during analysis. Based on this, the NRC staff concludes that the TR contains a methodology for consistent development of learning objectives with job performance conditions, actions and standards that reflect job performance requirements, consistent with NUREG-1220.
Finally, for Characteristic 2.3, the NRC staff reviewed how the TR methodology ensures that learning objectives are revised, when needed, to reflect job changes. TR section 3.1.1, Needs Analysis, states that a Needs Analysis is performed to identify potential training needs, to suggest and approve training solutions, and where possible recommend non-training solutions to improve personnel performance. The TR specifies activities that trigger a needs analysis, including training requestsfeedback, observation of task performance, audit or assessment finding, plant or human performance event, or engineering change with training program impact. Additionally, TR section 3.5, Evaluation Phase, documents the expectation that Xe-100 training programs are maintained through a process of evaluation, assessment and correction; this includes changes to training material as a result of new and modified procedures and plant changes, as well asapplicable operating experience. TR section 3.5.2, Facility Issues and Events, states that facility events should be evaluated for potential training program impact. Furthermore, TR section 3.2.2, Develop Learning Objectives, states that learning objectives arerevised from results of the Analysis Phase. Based on the above, the NRC staff concludes that the TR contains a methodology for consistent revision of learning objectives to reflect job changes, consistent with NUREG-1220.
The NRC staff concludes that the TR contains an acceptable method for producing learning objectives, derived from the analysis process, that support successful job performance and provide conditions, actions and standards that reflect job performance requirements. This process includes revising learning objectives as needed to reflect job changes. As discussed above, this process is consistent with the guidance in NUREG-1220 for SAT element 2, and therefore, is acceptable.
3.0 SAT element 3: Training design and implementation is based on the learning objectives According to NUREG-1220, Revision 1, the content of training programs should be derived from learning objectives and sequenced and presented for effective learning. A method of training material design and implementation is considered systematic if it includes the following characteristics:
3.1 Lesson plans are structured to provide for consistent presentation.
3.2 Depth of content is adequate to support mastery of learning objectives.
3.3 Information is presented in a sequence (within a lesson as well as among several lessons) that supports effective learning.
3.4 Training is adequately presented.
3.5 Personnel providing classroom, on-the-job, laboratory and simulator training are proficient in the methods and techniques for successful presentation in the particular setting.
The NRC staff reviewed TR section 3.3, Development Phase, which contains X-energys methodology for creating training material to confirm that it contains a systematic process for the design and implementation of training based on the learning objectives. The guidance in NUREG-1220 pertains to the review training plans and training presentation and not the process to develop these products; therefore, the NRC staff focused on how the TR methodology could be used to design and implement training that satisfies the characteristics above.
For Characteristic 3.1, the NRC staff reviewed the TR methodology to determine if lesson plans will be structured to provide for consistent presentation of training. TR section 3.3.1 states that training materials contain the following elements to ensure consistent presentation: Learning objectives, Adequate amount and detail of content to ensure consistency, [and] support materials (e.g., equipment, tools, audiovisual, other equipment). Based on the NRC staffs review of TR section 3.3.1, the staff concludes that the TR contains a systematic methodology for lesson plans to be structured to provide consistent presentation, consistent with NUREG-1220.
For Characteristic 3.2, the NRC staff reviewed the TR methodology for the determination of whether the depth of content is adequate to support the mastery of learning objectives. TR section 3.3.1 states that an appropriate delivery method aligns with the cognitive level of the learning objective. For example, if a learning objective requires analysis of a system fault, the supporting material cannot solely focus on the purpose and general function of the system; instead, the content must incorporate learning at the higher cognitive learning objective. Based on this, the NRC staff concludes that the TR contains a systematic methodology for ensuring that the depth of content is adequate to support the mastery of the learning objectives, consistent with NUREG-1220.
For Characteristic 3.3, the NRC staff reviewed the TR for the determination of whether the methodology requires information to be presented in a sequence (within a lesson as well as among several lessons) that supports effective learning. TR section 3.2.4 states that [t]emporal order is primarily based on progressing the content from low cognitive learning objectives to high cognitive learning objectives and providing trainees with introduction, background, fundamental, simple concepts before presenting detailed, advanced, complex concepts within a given curriculum topic. Based on this, the NRC staff concludes that the TR contains a systematic methodology for presenting information in a sequence that supports effective learning, consistent with NUREG-1220.
For Characteristics 3.4 and 3.5, the NRC staff also reviewed the TR for the determination of whether the methodology requires training to be adequately presented, and personnel providing classroom, on-the-job, laboratory, and simulator training to be proficient in the methods and techniques for successful presentation in the particular setting. TR section 3.4.2 states that instructors are proficient in the methods and techniques for successful presentation in the training setting and asset they are using. Instructors should be prepared, as evident by their performance in the classroom using questioning skills, coaching skills, and learning techniques for optimal trainee mastery of the learning objectives. Effective delivery of training includes consistent adherence to the approved training material. The NRC staff concludes that the TR contains a systematic methodology for ensuring the adequate presentation of training, and that the personnel providing classroom, on-the-job, laboratory and simulator training will be proficient in the methods and techniques for successful presentation in the particular setting, consistent with NUREG-1220.
The NRC staff concludes that the TR contains an acceptable method for the training design and implementation based on the learning objectives, including methods for structured lesson plans for consistent presentation, adequate depth of content, and sequencing of information to support effective learning, a methodology for training presentation and proficiency of the personnel providing training for successful presentation that is consistent with the guidance of NUREG-1220, and is therefore, acceptable.
4.0 SAT element 4: The evaluation of trainee mastery of objectives during training According to NUREG-1220, Revision 1, trainees should be evaluated during all aspects of training to determine their progress toward the mastery of job performance requirements. A method of evaluating trainee mastery of objectives is considered systematic if it includes the following characteristics:
4.1 A relationship exists between job performance requirements or learning objectives and test items.
4.2 Trainee performance is evaluated regularly.
4.3 Trainee remediation is provided when appropriate.
4.4 Continuing training contains performance requirements for difficult, important, or infrequent tasks.
4.5 Training and task performance exemptions are objectively based.
4.6 Evaluations of task performance test the trainees mastery of job performance requirements.
The NRC staff reviewed TR section 3.3, Development Phase, and section 3.4, Implementation Phase, which contains X-energys methodology for the evaluation of trainee mastery of objectives during training. The guidance in NUREG-1220 pertains to the review of training program material including procedures, lesson plans, test items, qualification records, and corrective actions. The TR describes a process to develop a training program that encompasses the evaluation of the trainee mastery of learning objectives and does not contain training program material. Therefore, the NRC staff focused on how the TR methodology could be used to create this aspect of a training program that satisfies the characteristics above.
For Characteristic 4.1, the NRC staff reviewed the TR to determine if, within the context of a training program, the methodology establishes a relationship between job performance requirements or learning objectives and test items. TR section 3.3.6, Development of Cognitive and Performance Evaluations, states cognitive examinations adequately sample the course objectives to ensure trainee mastery of the course content requisite knowledge.Sufficient evaluation items from each lesson plans learning objectives are included on the exam to adequately assess student comprehension and mastery of the content.Performance objectives derived from tasks or skills selected for training are evaluated with performance evaluations as identified in the design phase. Thus, the NRC staff concludes that the TR contains a systematic methodology for ensuring that a relationship exists between job performance requirements and test items, which is consistent with NUREG-1220.
For Characteristic 4.2, the NRC staff also reviewed the TR to determine whether it establishes a methodology for regularly evaluating trainee performance. TR section 3.4.3, Evaluation and Remediation, states that the examination process is used to verify trainee comprehension of the topics of the learning objectives. Cognitive learning objectives are examined using cognitive examination methods. Performance learning objectives are examined using performance evaluation methods. All training requires trainee evaluation. Proper implementation of evaluation requires specific guidelines for planning, exam security, delivery, scoring, post-evaluation review, and feedback. TR section 3.4.3 also states that the examination process is used to verify trainee competence of the learning objectives. Cognitive learning objectives are examined using cognitive evaluation methods. Performance learning objectives are evaluating using performance evaluation methods. Based on this, the NRC staff concludes that the TR contains a systematic methodology for evaluating trainee performance regularly, which is consistent with NUREG-1220.
For Characteristic 4.3, the NRC staff reviewed the TR to determine whether it establishes a methodology for providing trainee remediation when appropriate. TR section 3.4.3 states that remediation includes review of the evaluation results, review of satisfactory response(s),
training material review to close knowledge gaps, studying, and attempting a new evaluation. At a minimum, the remediation evaluation must retest on the concepts missed by the trainee on the original evaluation through items evaluating those learning objectives. Based on this, the NRC staff concludes that the TR contains a systematic methodology for remediating trainees when appropriate, which is consistent with NUREG-1220.
For Characteristic 4.4, the NRC staff reviewed the TR to determine whether it establishes a methodology for continuing training to contain performance requirements for difficult, important, or infrequent tasks. TR section 3.1.2.1 states that Difficulty, Importance, and Frequency (DIF)
Analysis [is used to] determine whether a task should be trained and how often the task should be retrained.The DIF results are averaged to determine one of the following outcomes for each task: no training, initial training only, or initial and continuing training. The NRC staff concludes that the TR contains a systematic methodology for continuing training containing performance requirements for difficult, important, or infrequent tasks, which is consistent with NUREG-1220.
For Characteristic 4.5, the NRC staff reviewed the TR to determine whether it establishes a methodology for training and task performance exemptions to be objectively based. TR section 3.4.1.1, Exemption and Equivalence, documents X-energys methodology of providing exemptions to training and task qualification requirements. Section 3.4.1.1 states that Training personnel review recorded evidence of prior training and performance history to specify training and/or performance evaluation activities that meet established acceptance criteria. Training personnel document justification of requested outcomes, attach objective evidence, and route the request to the Line for approval. Based on this, the NRC staff concludes that the TR contains a systematic methodology for objectively determining training and task performance exemptions, which is consistent with NUREG-1220.
For Characteristic 4.6, the NRC staff reviewed the TR to determine whether it establishes a methodology for evaluations of task performance to test the trainees mastery of job performance requirements. TR section 3.2.3.1, Performance Level, documents X-energys methodology of providing consistent performance of training and evaluation. Section 3.2.3.1 states Performance levelof OJT and performance evaluation is selected as follows. Criteria are provided for perform, simulate, and discuss levels of performance. For example, section 3.2.3.1 states that the perform mode is preferentially selected when possible, simulate mode is selected when the Perform (P) mode is unfeasible due to the potential impact of trainee error, the impact of repositioning equipment, operating mode, equipment availability, or other limitations and considerations that make task performance undesirable. Discuss mode is the least-preferred mode [and] should be used infrequently. Based on this, the NRC staff concludes that the TR contains a systematic methodology for evaluating task performance that tests the trainees mastery of job performance requirements, which is consistent with NUREG-1220.
The NRC staff concludes that the TR contains an acceptable method for the evaluation of trainee mastery of objectives during training, including a relationship between job performance requirements, or learning objectives, and test items, regulator trainee evaluation and remediation processes that is consistent with the guidance of NUREG-1220. The NRC staff also concludes that the TR contains an acceptable method for ensuring that continuing training will be based on DIF analysis, training and task performance exemptions will be objectively based, and trainee mastery of job performance will be ensured through task performance tests that is consistent with the guidance of NUREG-1220, and therefore, is acceptable.
5.0 SAT element 5: The evaluation and revision of training based on the performance of trained personnel in the job setting According to NUREG-1220, Revision 1, plant and training staff should use a systematic process to evaluate the effectiveness of the training and qualification programs and to determine and direct the needed revisions. A method to evaluate and revise training based on the performance of trained personnel in the job setting is considered systematic if it includes the following characteristics:
5.1 Trainee critiques are reviewed to identify potential improvements to the programs.
5.2 On-the-job work experiences are solicited from trainees and job incumbents to identify jobs/tasks for which they felt inadequately prepared to perform.
5.3 Information is solicited from supervisors on performance by new job incumbents to identify tasks for which they were inadequately prepared to perform.
5.4 Information on degraded task performance is solicited from job incumbents and supervisors.
5.5 External factors (change actions) are evaluated to identify their impacts on job performance requirements.
5.6 Changes in job performance requirements result in changes to training and training materials.
The NRC staff reviewed TR section 3.5, Evaluation Phase, which contains X-energys methodology for evaluating training programs. The guidance in NUREG-1220 pertains to the review of course critiques, feedback from trainees, job incumbents and supervisors, and other information associated with the evaluation and revision of training and not the process to develop these products; therefore, the NRC staff focused on how the TR methodology incorporates processes to evaluate and revise training that satisfy the characteristics above.
For Characteristic 5.1, the NRC staff reviewed the TR methodology for how trainee critiques will be used to identify potential improvements to training programs. TR section 3.5.1, Collect and Analyze Feedback, states that Training personnel collect trainee feedback during the Implementation Phase. Effective evaluation of the training program includes reviewing the trainee feedback and initiating actions, when necessary, to improve the training program curriculum for future offerings. Training feedback is solicited to gather the following data:
Adequacy of training in providing background knowledge, Adequacy of training in developing associated skills, Degree to which training is related to job requirements, and Degree to which training prepared trainees to fulfill job requirements.
Based on the above, the NRC staff concludes that the TR contains a systematic method to review trainee critiques to identify potential improvements to the training programs, consistent with NUREG-1220.
For Characteristics 5.2 and 5.3, the NRC staff reviewed the TR methodology to determine if on-the-job work experiences will be solicited from trainees and job incumbents to identify jobs/tasks for which they felt inadequately prepared to perform, and whether information will be solicited from supervisors on performance by new job incumbents to identify tasks for which they were inadequately prepared to perform. TR section 3.5.1 states that When a trainee completes the initial training program, a Post Training Effectiveness Evaluation is conducted to assess the effectiveness of the training program to prepare the trainee for the job. Feedback from the trainee, job incumbents, and Line management is included in the evaluation to assess how well the training program prepared the trainee for independent job performance. This information is typically collected six months to a year following course graduation.
TR section 3.5.1 also states that feedback is collected from supervisors for Tasks for which new job incumbents were inadequately prepared, kinds of errors being committed by job incumbents, suggestions for improvements in initial and continuing training, and potential changes in training program job requirements. The TR includes a list of the type of feedback collected that is in alignment with the guidance in NUREG-1220. The NRC staff concludes that the TR contains a systematic method for soliciting on-the-job work experiences from trainees and job incumbents to identify jobs/tasks for which they feel that they are inadequately prepared to perform. Furthermore, the NRC staff concludes that the TR contains a systematic method for soliciting information from supervisors on performance by new job incumbents to identify tasks for which they were inadequately prepared to perform, which is consistent with NUREG-1220.
For Characteristic 5.4, the NRC staff reviewed the TR methodology for how information about degraded task performance will be solicited from job incumbents and supervisors. TR section 3.5.6, Assessing the Approved Training Program Effectiveness, documents X-energys methodology for assessing the training program with the feedback solicited from job incumbents and supervisors. Section 3.5.6 states that information should be reviewed for any potential objective or factual data related to training program performance by evaluating the analyzed elements associated with the tasks selected for training as identified in the Analysis phase. Data can be identified through any method, such as trainee feedback, line performance, or assessments and analyzed into a Post Training Effectiveness Evaluation. The NRC staff concludes that the TR contains a systematic method to solicit information about degraded task performance from job incumbents and supervisors, which is consistent with NUREG-1220.
For Characteristic 5.5, the NRC staff reviewed the TR methodology to determine if external factors (change actions) will be evaluated to identify their impact on job performance requirements. TR section 3.5.4, Facility Modifications and Procedure Changes, documents X-energys methodology for assessing facility changes and their impact on the training program.
Section 3.5.4 states that [f]acility design changes, modifications, or procedure changes that impact equipment operation, maintenance, or user interface could alter the original information assessed in the training program job and task analysis and associated elements to which the training curriculum was designed. Consequently, any design changes to the facility must be reviewed for potential impact to the training program.
TR section 3.5.5, Industry Regulatory Changes and Operating Experience, documents X-energys methodology for assessing external factors and their impact on the training program.
Section 3.5.5 states that [r]egulatory changes and industry operating experience shall be reviewed for applicability and incorporated into the associated training programs accordingly.
The NRC staff concludes that the TR contains a systematic method to evaluate external factors to identify their impact on job performance requirements, which is consistent with NUREG-1220.
For Characteristic 5.6, the NRC staff reviewed the TR methodology to determine if changes in job performance requirements will result in changes to training and training materials. TR section 3.5, states that the evaluation phase is used to assess the effectiveness and efficiency of the training programs. The outcome of the Evaluation Phase is the initiation of necessary actions to improve gaps identified in the training programs. TR section 3.1.1, Needs Analysis, states that a Needs Analysis is entered as the result of Evaluation Phase activities. The NRC staff concludes that the TR contains a systematic method for evaluating changes in job performance requirements that will result in changes to training and training materials, which is consistent with NUREG-1220.
The NRC staff concludes that the TR contains an acceptable method for the evaluation and revision of training based on the performance of trained personnel in the job setting, including methods for the review of trainee critiques for potential improvements to the programs, solicitation of work experiences from trainees and job incumbents to identify jobs/tasks which they felt inadequately prepared to perform, information from supervisors on performance by new incumbents to identify tasks for which they were inadequately prepared to perform, and information on degraded task performance is solicited from job incumbents and supervisors that is consistent with the guidance of NUREG-1220. The NRC staff also concludes that the TR contains an acceptable method for analyzing external factors evaluations for the impact on job performance requirements, and a process for ensuring changes in job performance requirements result in changes to training and training materials that is consistent with the guidance of NUREG-1220.
LIMITATIONS 1.
As stated in both the synopsis and conclusion of the TR, X-energy requests the NRC staffs approval of a methodology for developing training programs that are derived from a systems approach to training as required by 10 CFR 50.120(b)(2) and 10 CFR Part 55, and defined in 10 CFR 55.4. The NRC staffs review and conclusions in this SE are limited to section 3 of the TR. The NRC staff did not review or make any determinations on sections in the TR that contain additional information not related to the SAT methodology in TR section 3.
2.
The NRC staffs approval of this TR is limited to a methodology to develop a training program. An applicant that uses the methodology in this TR to develop its Xe-100 training program must provide its training program to the NRC staff for review to verify compliance with applicable regulations (i.e., 10 CFR 50.120, 10 CFR 55.4, and 10 CFR Part 55).
CONCLUSION The NRC staff compared X-energys TR-006012, Revision 4, Xe-100 Training Programs Methodology, for developing training programs using a systems approach to training process to the guidance listed in NUREG-1220, section D, SAT Element Evaluation. The NRC staff determined that the methodology discussed in the TR is consistent with the review criteria outlined in NUREG-1220 for the development of an SAT methodology. Therefore, the NRC staff determined that the TR provides an acceptable methodology for developing SAT-based training programs as defined in 10 CFR 55.4 and required by 10 CFR 50.120(b)(2) and 10 CFR Part 55, subject to the limitations discussed above.
REFERENCES 1.
ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants.
2.
U.S. Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter 1, Title 10, Energy.
3.
U.S. Code of Federal Regulations, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter 1, Title 10, Energy.
4.
U.S. Code of Federal Regulations, Operators Licenses, Part 55, Chapter 1, Title 10, Energy.
5.
U.S. Nuclear Regulatory Commission, Qualification and Training of Personnel for Nuclear Power Plants. Regulatory Guide 1.8, Revision 4.
6.
U.S. Nuclear Regulatory Commission, Training Review Criteria and Procedures, NUREG-1220, Revision 1.
Principal Contributors: Jeff Correll, Reactor Engineer, Examiner Maurin Scheetz, Reactor Engineer, Examiner Date: September 5, 2025
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page ii Layout: DLT-007 Rev 9 E-SIGNATURES
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page iii Layout: DLT-007 Rev 9 Document Approval Signees Action Designation Name Signature Date Preparer Manager, Plant Training G. Crannick Maintained in Teamcenter December 5, 2024 Reviewer Manager, Licensing J. Fogarty Maintained in Teamcenter December 5, 2024 Approver Director, Licensing S. Vaughn Maintained in Teamcenter December 5, 2024
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page iv Layout: DLT-007 Rev 9 Copyright Notice This document is the property of X Energy, LLC (X-energy) and was prepared for review by the U.S. Nuclear Regulatory Commission (NRC) and use by X-energy, its contractors, its customers, and other stakeholders as part of regulatory engagements for the Xe-100 reactor plant design. Other than by the NRC and its contractors as part of such regulatory reviews, the content herein may not be reproduced, disclosed, or used without prior written approval of X-energy. This report has been reviewed by X-energy and determined to be available for unrestricted release.
10 CFR 810 Export-Controlled Information Disclaimer This document was reviewed by X-energy and determined to not contain information designated as export controlled per Title 10 of the Code of Federal Regulations (CFR) Part 810 or 10 CFR 110.
Department of Energy Acknowledgement and Disclaimer This material is based upon work supported by the Department of Energy under Award Number DENE0009040.
This report was prepared as an account of work sponsored by an agency of the United States Government.
Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page v Layout: DLT-007 Rev 9 SYNOPSIS This licensing topical report (LTR) provides the X Energy, LLC (X-energy) approach and methodology for developing, implementing, and maintaining the initial, continuing, and requalification training programs for Xe-100 plant staff. The approaches and methodologies in this LTR specifically include the X-energy methodology for conducting a systems approach to training to produce the suite of Xe-100 training programs necessary for safe Xe-100 plant operation and maintenance under all operating conditions. X-energy is requesting NRC review and approval of the methodologies to develop, implement, and maintain the Xe-100 training programs to demonstrate compliance with 10 CFR 50.120(b)(2) and 10 CFR 55.4.
Future approval of the Xe-100 training programs developed with these methodologies, which is outside the scope of this report, may be used by an applicant or facility licensee to satisfy the 10 CFR Part 55 requirements for Commission-approved training program that is based on a systems approach to training as referenced in a construction permit, operating license, or combined license application.
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page vi Layout: DLT-007 Rev 9 CONFIGURATION CONTROL/DOCUMENT CHANGE HISTORY Document Change History Rev.
Date Preparer Page/Section Revised Description 1
28-OCT-2022 D. Williamson All Initial issuance 2
12-DEC-2022 D. Williamson All Incorporated comments from NRC white paper 3
27-Mar-2024 D. Williamson /
G. Crannick All Combined training program methodology, control room operator licensing, and plant staff qualification requirements into one LTR.
Removed control room operator licensing and plant staff qualification requirements that were added in revision 3 in response to NRC feedback to revision 3.
Addressed NRC acceptance review comments.
4 28-OCT-2024 G. Crannick
- Synopsis, Executive
- Summary, section 1.4, and section 5 Revised scope statement in each section to be consistent.
Section 3.1.4 Renamed section 3.1.4 to Cognitive Analysis.
Rewrite to add more clarity and detail.
Section 3.1.5 And Section 3.1.5.1 Removed requirement for NRC approval prior to making task list changes.
Rewrite to add more clarity and detail.
Because of the deletion and rewrite above, renamed section 3.1.5 to Task List Reviews; deleted subsection 3.1.5.1; and consolidated all content for task list reviews to section 3.1.5.
Section 3.2.3.1 Added new subsection 3.2.3.1 Performance Level that provides detail for determining task performance level.
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page vii Layout: DLT-007 Rev 9 Rev.
Date Preparer Page/Section Revised Description Section 3.3.1 Added more detail to explain how training material is created to ensure consistent presentation.
Section 3.3.6 Renamed section 3.3.6 to Development of Cognitive and Performance Evaluations.
Section 3.4.1.1 Added new subsection 3.4.1.1 Exemption and Equivalence that provides detail for training exemption and equivalent qualification processes.
Section 3.4.3 Renamed section 3.4.3 to Evaluation and Remediation.
Added detail for remediation process and aligned with section 4.3.
Section 3.5.1 Added detail to subsection Trainee Feedback Analysis regarding trainee feedback.
Added detail to subsection Post Training Effectiveness Evaluation regarding PTEE feedback from trainees, job incumbents, and supervisors.
Section 4.3 Renamed section 4.3 to Evaluation and Remediation.
Added more detail for remediation process and aligned with section 3.4.3.
Throughout Updated terms and phrases for consistency.
Examples:
Replaced exam/examination/test with evaluation or evaluation item Replaced competency analysis with cognitive analysis Replaced student with trainee
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page viii Layout: DLT-007 Rev 9 EXECUTIVE
SUMMARY
This licensing topical report (LTR) presents the X Energy, LLC (X-energy) approach and methodology for developing, implementing, and maintaining the initial, continuing, and requalification training programs for Xe-100 plant staff required by the categories of personnel listed in Title 10 of the Code of Federal Regulations (10 CFR) 50.120, Training and qualification of nuclear power plant personnel, as well as control room operators. The approach described in this report focuses on the methodologies for X-energy to develop facility training programs derived from a systems approach to training as defined in 10 CFR 55.4.
X-energy is requesting NRC review and approval of the methodologies to develop, implement, and maintain the Xe-100 training programs to demonstrate compliance with 10 CFR 50.120(b)(2) and 10 CFR 55.4. Future approval of the Xe-100 training programs developed with these methodologies is outside the scope of this report. It should be noted that X-energy does not intend to seek accreditation by the National Nuclear Accrediting Board (NNAB); rather X-energy is seeking a Commission-approved Facility-developed Training Program Methodology by the Commission.
X-energy recognizes that Commission approval of completed training programs compliant with 10 CFR 50.120 and 10 CFR 55.4, as well as the necessary training for control room operations personnel and personnel qualification requirements, is ultimately the responsibility of an applicant and/or licensee. However, X-energys intent is to fully develop, implement, and maintain the Xe-100 training programs as Commission approved, vendor-supplied, facility training programs for initial and continuing/requalification training of Xe-100 plant staff to meet 10 CFR 50.120(b)(2) and 10 CFR Part 55 requirements for Commission-approved training program that is based on a systems approach to training, as referenced in a future construction permit application, operating license application, or combined license application.
The methodologies provided in this report are also applicable to initial training as well as continuing training in the following areas:
General Access Security Emergency Planning Radiological Worker Administrative Procedures Fire Protection Quality Assurance Fitness for Duty
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page ix Layout: DLT-007 Rev 9 Table of Contents Abbreviations/Acronyms.................................................................................................................. xi 1.
Introduction................................................................................................................................ 1 1.1 Purpose....................................................................................................................................... 1 1.2 Scope........................................................................................................................................... 1 1.3 Interfacing Documents................................................................................................................ 1 1.4 Outcome Objectives.................................................................................................................... 2 2.
Xe-100 Training Programs Approach and Methodology................................................................. 3 2.1 Regulatory Basis and Applicability.............................................................................................. 3 2.2 Xe-100 Training Programs Compliance with 10 CFR 50.120(b)(1).............................................. 3 2.3 Xe-100 Categories of Nuclear Power Plant Personnel................................................................ 4 2.4 General Approach to Training..................................................................................................... 5 2.5 X-energy Training Organization for Xe-100................................................................................ 7 3.
X-energy Systems Approach to Training for Xe-100....................................................................... 8 3.1 Analysis Phase............................................................................................................................. 8 3.1.1 Needs Analysis.............................................................................................................. 8 3.1.2 Job Analysis.................................................................................................................. 9 3.1.3 Task Analysis............................................................................................................... 10 3.1.4 Cognitive Analysis....................................................................................................... 11 3.1.5 Task List Reviews........................................................................................................ 11 3.2 Design Phase............................................................................................................................. 12 3.2.1 Define Target Student Population.............................................................................. 12 3.2.2 Develop Learning Objectives...................................................................................... 12 3.2.3 Training Setting.......................................................................................................... 13 3.2.4 Organize Learning Objectives..................................................................................... 14 3.2.5 Prepare Evaluation Items........................................................................................... 14 3.3 Development Phase.................................................................................................................. 15 3.3.1 Creating Training Material......................................................................................... 15 3.3.2 Revising Training Material.......................................................................................... 17 3.3.3 Reviewing Training Material....................................................................................... 18 3.3.4 Piloting Training Material........................................................................................... 18 3.3.5 Approving Training Material...................................................................................... 19 3.3.6 Development of Cognitive and Performance Evaluations......................................... 19 3.4 Implementation Phase.............................................................................................................. 19 3.4.1 Preparation and Scheduling....................................................................................... 20 3.4.2 Delivery of Training.................................................................................................... 20
Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page x Layout: DLT-007 Rev 9 3.4.3 Evaluation and Remediation...................................................................................... 21 3.4.4 Post-Training Activities............................................................................................... 21 3.5 Evaluation Phase....................................................................................................................... 22 3.5.1 Collect and Analyze Feedback.................................................................................... 22 3.5.2 Facility Issues and Events........................................................................................... 23 3.5.3 Inspection, Assessment, and Corrective Action Reports........................................... 23 3.5.4 Facility Modifications and Procedure Changes.......................................................... 24 3.5.5 Industry Regulatory Changes and Operating Experience........................................... 24 3.5.6 Assessing the Approved Training Program Effectiveness.......................................... 24 4.
Xe-100 Control Room Operator Training Program....................................................................... 25 4.1 Initial Training........................................................................................................................... 25 4.2 Requalification Training............................................................................................................ 26 4.3 Evaluation and Remediation..................................................................................................... 26 4.4 Records..................................................................................................................................... 27 5.
Conclusions............................................................................................................................... 28 6.
Cross References and References............................................................................................... 29 List of Tables Table 1: Xe-100 Equivalent Positions.................................................................................................. 5 Table 2: Major and Minor Revisions.................................................................................................. 18 Table 3: Review Requirements......................................................................................................... 18 List of Figures Figure 1: Learning Object Model....................................................................................................... 16 Figure 2: Lesson Plan Model............................................................................................................. 17
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page xi Layout: DLT-007 Rev 9 Abbreviations/Acronyms Abbreviations/Acronyms Short Form Phrase ANS American Nuclear Society ANSI American National Standards Institute CFR Code of Federal Regulations CHM/RPT Chemistry and Radiation Protection Technician CRO Control Room Operator DIF Difficulty, Importance, Frequency DOE Department of Energy HFE Human Factors Engineering HMI Human-Machine Interface HSI Human-System Interface I&C Instrumentation and Control IAEA International Atomic Energy Agency IAW In Accordance With LWR Light-Water Reactor NEI Nuclear Energy Institute NNAB National Nuclear Accrediting Borad NRC U.S. Nuclear Regulatory Commission OJT On-the-Job Training P&ID Piping and Instrumentation Diagram PFT Plant Field Technician QA Quality Assurance
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page xii Layout: DLT-007 Rev 9 Short Form Phrase RG Regulatory Guide RO Reactor Operator SAT Systems Approach to Training SOP System Operating Procedure SRO Senior Reactor Operator TMX Xe-100 Training Manual TPE Task Performance Evaluation V&V Verification and Validation X-energy X Energy, LLC
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 1 Layout: DLT-007 Rev 9
- 1. Introduction 1.1 Purpose The purpose of this licensing topical report (LTR) is to:
Describe the methodologies for developing the initial and continuing/requalification training programs of Xe-100 plant staff, derived from a systems approach to training as defined in 10 CFR 55.4, required by the categories of personnel listed in 10 CFR 50.120, as well as control room operators (CROs), for safe and reliable Xe-100 plant operations in a multi-unit plant configuration across various modes, states, and operating conditions.
Describe the methodologies for implementing the Xe-100 training programs as Commission approved, vendor-supplied, facility training programs for initial and continuing/requalification training of Xe-100 plant staff to meet 10 CFR 50.120(b)(2) and 10 CFR Part 55 requirements for Commission-approved training program that is based on a systems approach to training, as referenced in a future construction permit, operating license, or combined license application.
Describe the approach and methodology that an applicant commencing the inaugural initial training programs at least 18 months prior to initial fuel loading on the first Xe-100 complies with the 10 CFR 50.120(b)(1), Requirement, that Each nuclear power plant operating license applicant, by 18 months prior to fuel load, and each holder of an operating license shall establish, implement, and maintain a training program that meets the requirements of paragraphs (b)(2) and (b)(3) of this section.
1.2 Scope This LTR describes:
The approach and methodologies X-energy is using to develop the Xe-100 initial and continuing/requalification training programs.
The approach and methodologies X-energy is using to implement the Xe-100 training programs as Commission approved, vendor-supplied, facility training programs for initial and continuing/requalification training of Xe-100 plant staff.
The approach X-energy is using to satisfy the 10 CFR 50.120(b)(1), Requirement, that 18 months prior to fuel load an applicant and/or licensee shall establish, implement, and maintain a training program that meets the requirements of paragraphs (b)(2) and (b)(3) of this section.
1.3 Interfacing Documents This LTR interfaces with the following documents:
Xe-100 Licensing Topical Report Control Room Staffing Analysis Methodology and Associated HFE Implementation Plans [1]. This LTR provides additional details of interrelated training elements, which are consistent with the guidance of NUREG-0711, Human Factors Engineering Program Review Model [2].
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 2 Layout: DLT-007 Rev 9 1.4 Outcome Objectives X-energy is requesting NRC review and approval of the methodologies to develop, implement, and maintain the Xe-100 training programs to demonstrate compliance with 10 CFR 50.120(b)(2) and 10 CFR 55.4. Future applicants for an Xe-100 construction permit, operating license, or combined license application will be able to seek Commission approval of the completed Xe-100 training programs using the approaches and methodologies discussed in this LTR. Commission approval of the completed Xe-100 training programs developed with these methodologies is outside the scope of this report. However, it should be noted that X-energy does not intend to seek accreditation of the Xe-100 training programs by the National Nuclear Accrediting Board (NNAB). X-energy is seeking a Commission-approved Facility-developed Training Program Methodology by the Commission.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 3 Layout: DLT-007 Rev 9
- 2. Xe-100 Training Programs Approach and Methodology 2.1 Regulatory Basis and Applicability This report describes the X-energy approach and methodology for developing, implementing, and maintaining facility training programs for Xe-100 plant staff using a systems approach to training (SAT) as required by 10 CFR 50.120 and defined in 10 CFR 55.4. An additional description of the SAT process is located in ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants [3] section 6.2.1, as endorsed by RG 1.8, Rev. 4, Qualification and Training of Personnel for Nuclear Power Plants, [4] as well as NUREG-0711, Human Factors Engineering Program Review Model,
[2] Section 10.
An applicant that utilizes the X-energy SAT methodology as described in Section 3, to develop Xe-100 training programs adheres to NRC endorsed guidance and will meet the applicable requirements for the Xe-100 plant staff positions required by 10 CFR 50.120 and for control room operators (CROs).
However, 10 CFR 50.120(a), Applicability, states (emphasis added in bold):
The requirements of this section apply to each applicant for and each holder of an operating license issued under this part and each holder of a combined license issued under part 52 of this chapter for a nuclear power plant of the type specified in § 50.21(b) or § 50.22.
Similar references to applicant and license are used in 10 CFR 50.120(b)(1)(i) and (ii).
X-energy recognizes that compliance with 10 CFR 50.120 is ultimately the responsibility of an applicant and/or licensee and approved by the NRC staff during review of the applicants operating license application.
X-energy also intends to fully develop, implement, and maintain the Xe-100 training programs as Commission-approved, vendor-supplied, facility-developed training programs for initial, continuing, and requalification training of Xe-100 plant staff to meet 10 CFR 50.120(b)(2) and 10 CFR Part 55 requirements for Commission-approved training program that is based on a systems approach to training, as referenced in a future construction permit, operating license, or combined license application. This includes conduct of training by qualified X-energy instructors. However, future approval of the Xe-100 training programs developed using the X-energy SAT methodology is outside the scope of this report.
2.2 Xe-100 Training Programs Compliance with 10 CFR 50.120(b)(1)
The Xe-100 training programs satisfy the 10 CFR 50.120(b)(1), Requirement, that 18 months prior to fuel load an applicant and/or licensee shall establish, implement, and maintain a training program that meets the requirements of paragraphs (b)(2) and (b)(3) of this section, by being prepared to commence the inaugural Xe-100 initial training classes, utilizing established Xe-100 training programs, at least 18 months prior to the initial fuel load for the first Xe-100 deployment and with each site-specific staff member completing an initial requalification module (gap training) prior to the issuance of an operating or combined license where those members are part of the qualified staff.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 4 Layout: DLT-007 Rev 9 Additionally, the Xe-100 training programs material is maintained as outlined in Section 3, and plant staff training is considered maintained in accordance with the Evaluation element of SAT, which commences during implementation of the inaugural initial training classes.
Continuing and requalification training program content and frequency (i.e., duration of each class and how often classes are conducted) is determined using the same SAT methodology as the initial training programs.
2.3 Xe-100 Categories of Nuclear Power Plant Personnel The Xe-100 training programs are structured and designed to provide reasonable assurance that personnel obtain and maintain the qualifications commensurate with the performance requirements of their jobs. Xe-100 training programs address:
The range of categories of plant personnel shown in Table 1, Xe-100 Equivalent Positions Control Room Operations personnel The spectrum of plant functions and systems The range of relevant Human System Interface (e.g., Control Room, remote shutdown area, and local control stations)
The extent of plant conditions (normal, upset, and emergency) including preoperational testing and low-power operation Table 1, Xe-100 Equivalent Positions, lists the various 10 CFR 50.120 categories of personnel, including control room operations personnel that are typical for a traditional commercial light-water reactor (LWR).
The table provides a cross reference to the equivalent position for the Xe-100 plant personnel. The Xe-100 plant uses cross-trained, multi-skilled personnel to safely operate and maintain the plant to meet the categories of nuclear power plant personnel required by 10 CFR 50.120.
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Shift Supervisor Senior Reactor Operator (SRO)
Control Room Operator (CRO)
Reactor Operator (RO)
Shift Technical Advisor N/A - to be addressed in a future report Non-licensed Operator Plant Field Technician (PFT)
Instrumentation and Control Technician Electrical Maintenance Personnel Mechanical Maintenance Personnel Radiological Protection Technician Chemistry & Radiation Protection Technician (CHM/RPT)
Chemistry Technician Engineering Support Personnel Engineering Support Personnel 2.4 General Approach to Training X-energy is developing the Xe-100 Training Manual (TMX) that contains all the procedures, forms, and guides used by X-energy to develop, implement, and maintain facility-specific training programs for the Xe-100 following a SAT methodology. The TMX procedure series is developed to detail the SAT methodology and implementation for the Xe-100 training programs.
The TMX procedure series is developed using the guidance in DRO-ISG-2023-04, Advanced Reactor Content of Application Facility Training Programs Draft Interim Staff Guidance [5]. Additional references were reviewed and incorporated into TMX development. To the extent these reference documents align with the Xe-100 design, Xe-100 staffing approaches (e.g., CRO versus SRO or RO), and DRO-ISG-2023-04,
[5], the X-energy TMX procedure series incorporates the following guidance to provide procedure level details to demonstrate acceptable SAT methodology:
DOE Handbook, Training Program Handbook: A Systematic Approach to Training [6]
IAEA Nuclear Energy Series No. NGT2.8, Systematic Approach to Training for Nuclear Facility Personnel: Processes, Methodology and Practices [7]
NUREG-0711, Chapter 10, Training Program Development [2]
NUREG-0700, Appendix B, Design Process Guidelines [8]
NEI 06-13A, Template for an Industry Training Program Description [9]
NUREG-0800, Section 13.2.1, Reactor Operator Requalification Program; Reactor Operator Training [10]
NUREG-0800, Section 13.2.2, Non-Licensed Plant Staff Training [10]
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 6 Layout: DLT-007 Rev 9 The regulatory acceptance criteria applicable to the Xe-100 training programs, to the extent that these documents align with the Xe-100 design and staffing approaches, are found in:
DRO-ISG-2023-04, Advanced Reactor Content of Application Facility Training Programs Draft Interim Staff Guidance [5]
NUREG-0711, Human Factors Engineering Program Review Model, Section 10, Training Program Development [2]
NUREG-0700, Human-System Interface Design Review Guidelines [8]. Specifically, the criteria applicable to Training Program Development (Appendix B)
NUREG-0800, Standard Review Plan, [10] Acceptance Criteria sections for:
Chapter 13.2.1, Reactor Operating Requalification Program; Reactor Operator Training
Chapter 13.2.2, Non-licensed Plant Staff Training
Chapter 18, Human Factors Engineering, Attachment B, Methodology to Assess the Workload of Challenging Operational Conditions in Support of Minimum Staffing Level Reviews NUREG-1021, Operator Licensing Examination Standards for Power Reactors [11] is based on LWR technology and the associated LWR Knowledge and Abilities Catalogs (NUREG-1122, -1123,
-2103, -2104 [12] [13] [14] [15]) and is therefore not effective for the development of Xe-100 training programs. Licensed operator examination policies, procedures, and practices for examining incumbents is contained in the Xe-100 Training Manual which will be submitted for approval with the Xe-100 training programs for the operating license application The X-energy maintenance strategy [16] includes a population of maintenance tasks. Each task requires qualified personnel, appropriate level of work instructions, time, and materials to be allocated in the schedule to execute each task in accordance with approved procedures/ instructions. The maintenance strategy and included tasks are inputs to the training development process to provide training on the elements necessary to qualify the personnel performing the tasks. In this way, the Xe-100 training programs support compliance with 10 CFR 50.65 and conformance to the guidance of RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants [17].
In addition to the technical training that is required for each plant staff position, the Xe-100 training programs also address initial training as well as continuing training in the following areas:
Administrative Procedures Emergency Planning Fire Protection Fitness for Duty General Access Quality Assurance Radiological Worker Security The Xe-100 training programs are also designed to address performance under degraded conditions by including:
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 7 Layout: DLT-007 Rev 9 Understanding how and why the instrumentation and control (I&C) subsystems might degrade or fail The implications of degradations in the human system interfaces (HSIs) for task performance Monitoring the I&C systems performance, so degradations are detected and recognized via the control rooms HSIs Performing recovery actions and compensatory actions in the event of a degraded condition Transitioning to backup systems when needed Teamwork as an operator fundamental. Additionally, CROs receive supervisor training since they direct the work and oversee the actions of others Decision-making skills in addressing each of the above challenges Training records are maintained and kept available for NRC inspection in accordance with the record retention requirements described in Section 4.4, Records, to verify adequacy of the Xe-100 training programs.
2.5 X-energy Training Organization for Xe-100 The X-energy training organization for the Xe-100 develops the training requirements, policies, procedures, training materials, examinations, and evaluations and implements and maintains the training programs. The development of these training programs and related elements is conducted by personnel with prior experience in training development and/or prior experience in the specific (or equivalent) role that is the subject of the training. TMX-6.0 specifies the education and experience requirements for X-energy instructors, which align with ANSI/ANS-3.1-2014 [3], Section 4.5.4 as follows:
Education: High school diploma Minimum experience for the position:
o Related experience which shall include: 2 years o
Nuclear power plant experience 0.25 year Special requirements:
1.
Shall have demonstrated knowledge of instructional techniques through training or experience and be certified as a qualified instructor for the material being presented 2.
Instructors of licensed personnel who provide instruction on the simulator shall hold, or shall have held, a senior operators license or have been certified for equivalent senior operator knowledge
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- 3. X-energy Systems Approach to Training for Xe-100 X-energy training programs for the Xe-100 utilize a SAT methodology as required by 10 CFR 50.120 and defined in 10 CFR 55.4. Specific details of X-energys approach and methodologies for SAT are contained in the Xe-100 TMX procedure series.
The SAT process consists of five interrelated elements: analysis, design, development, implementation, and evaluation. These five elements are interrelated with elements of the HFE Program Management Plan (and referenced HFE Implementation Plans) [1], which is consistent with the guidance of NUREG-0711 [2].
The HFE Programs support for the Control Room staffing approach provides proper correspondence between developing the Xe-100 training programs and the HFE Program by following the SAT process and using the HFE Task Analysis as input to the SAT analysis phase/element.
The Xe-100 training programs also address the periodic continuing training and requalification of plant personnel, including the CRO requalification requirements. Continuing training reinforces initial training by reiterating selected portions of the material. Continuing training also addresses new and modified procedures and plant design changes. Additionally, fundamentals defined during the Analysis Phase are integrated into the initial and continuing/requalification Xe-100 training programs such that they are taught and evaluated routinely throughout both programs. This approach reinforces fundamentals with plant-specific and design-specific topics over the entirety of the Xe-100 training programs.
The main activities carried out in each of the element phases as well as the key factors considered in each are discussed in the subsections to follow.
3.1 Analysis Phase TMX-1.1 governs the Analysis Phase of the X-energy SAT process for the Xe-100. The purpose of the Analysis Phase is to determine training needs and identify job specific training requirements. The main activities of the Analysis Phase are: Needs Analysis, Job Analysis, Task Analysis, and Cognitive Analysis.
3.1.1 Needs Analysis A Needs Analysis is performed to identify potential training needs, to suggest and approve training solutions, and where possible recommend non-training solutions to improve personnel performance.
A Needs Analysis is entered as the result of Evaluation Phase activities (e.g., training request, post-training trainee and Line feedback, observation of task performance, audit or assessment finding, plant or human performance event, or engineering change with training program impact). Training required by a regulatory agency does not require further documented analysis because the analysis was completed by the regulator. This required training is included and addressed in the Design and Development Phases of the SAT process.
A Needs Analysis may result in the following training related outputs:
The need for a new training module or activity for a particular job or task The need to modify an existing training module or activity
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 9 Layout: DLT-007 Rev 9 A new or modified task to be addressed in the training program Particular cognitive and performance elements to be addressed in training, to improve performance These outputs are considered as inputs to the Job Analysis and subsequent Task Analysis. The Needs Analysis may also generate additional training program improvement opportunities, such as the following:
Changes to the organization or sequence of training Changes to the training methods, training facilities, or training tools Enhancement of instructor competence Estimation of resources required for training (human resources, time, and cost) from the Xe-100 plant staff and Operating Company The Needs Analysis may generate non-training recommendations, which are communicated through appropriate channels (e.g., corrective action program).
3.1.2 Job Analysis A Job Analysis is conducted to produce a list of duty areas and tasks for a specific job or position. A Job Analysis evaluates what the individual does on the job (performance-based tasks) rather than what the individual must know to perform the job.
Job incumbents and subject matter experts participate in Job Analysis by providing input and reviewing job requirements. Training and Line supervision review and approve Job Analysis results. To ensure the Job Analysis is congruent with the HFE program, the following HFE items are considered as inputs to the Job Analysis:
HFE Concept of Operations Report HFE Task Analysis HFE Plant Staffing Report HFE Staffing & Qualifications Report HFE Control Room Staffing Analysis and associated Licensing Topical Report HFE Operating Experience Report HFE Functional Requirements Analysis and Function Allocation Report HFE Treatment of Important Human Actions Report Additional inputs considered for Job Analysis include:
Xe-100 design (e.g., system design descriptions, system drawings, etc.)
Safety analysis Licensing Basis Human System Interface (HSI) / Human Machine Interface (HMI)
Plant Procedures Verification and Validation (V&V)
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 10 Layout: DLT-007 Rev 9 Personnel familiar with the Job Analysis process (e.g., job incumbents, subject matter experts, training staff) generate a task list derived from a Job Analysis. Task statements address the following systematic criteria:
Consist of a logically ordered set of steps Are observable and measurable or produce an observable and measurable result Have one action verb and one object Have a specific beginning and end Occur over a short period of time Can be executed with consistent results on different occasions by different people Requires a record of review and/or approval for historical record Results in a consistently formatted, quality product 3.1.2.1 Difficulty, Importance, and Frequency Analysis Difficulty, Importance, and Frequency (DIF) Analysis uses three factors - difficulty, importance, and frequency - to determine whether a task should be trained and how often the task should be retrained.
DIF analysis is performed using deterministic DIF worksheets where job analysis participants assign a difficulty score, an importance score, and a frequency score for each task. The DIF results are averaged to determine one of the following outcomes for each task: no training, initial training only, or initial and continuing training. Tasks that screen for initial and continuing training are assigned a retraining frequency based on their DIF scoring.
3.1.3 Task Analysis A Task Analysis evaluates tasks selected for training to determine the scope of the activity. Task Analysis produces a defined list of job attributes required for satisfactory task performance.
Task Analysis reviews task statements within the context to their plant application to identify the characteristics of the task. These characteristics are used to design and develop training content for incumbent qualification.
Task Analysis considers the following characteristics:
Initial conditions (prerequisites) required for task performance Standards (criteria) for acceptable task performance (i.e. limits, ranges, time requirements)
Critical elements (steps) that must be performed to accomplish the task properly Tools, equipment, and safety concerns related to task performance Associated performance or cognitive statements required to perform particular elements of the task or the overall task Branch steps/alternate paths that result in additional actions or performance or cognitive elements to accomplish satisfactory performance Task Analysis includes all aspects of job performance, including but not limited to tasks important to safe plant operation and tasks related to the foundational theory of plant operations.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 11 Layout: DLT-007 Rev 9 3.1.4 Cognitive Analysis Job Analysis and Task Analysis break down the duty areas of a position into tasks, elements, and training recommendations for the performance realm. Those tasks and elements, however, require prerequisite knowledge to bridge the gap between the expected education of the minimum candidate and the cognition required for successful task performance and understanding.
Cognitive Analysis is an iterative process that is conducted to systematically group and organize cognitive elements into common or prerequisite training cognitions. These cognitions are then analyzed to determine a training recommendation, i.e., no training, initial training, or initial and continuing training. If initial and continuing training are recommended, the Cognitive Analysis also recommends a retrain frequency.
Subject matter experts and/or job incumbents participate in a Cognitive Analysis by providing input and reviewing job and task requirements.
The Cognitive Analysis process ensures that cognitive elements are consistently and effectively consolidated into cognitions prior to developing learning objectives, establishing comprehensive prerequisites to task performance. Cognitive Analysis reviews cognitive elements defined from the Task Analysis within the context of their plant application to identify the characteristics of the cognition.
These characteristics are used as inputs to the next phases of SAT, to design and develop training content for incumbent qualification.
Cognitive Analysis considers the following characteristics to create cognitions and determine training recommendations:
Minimum candidate education and experience Regulatory requirements for a job positions or duty areas prerequisite knowledge Number of tasks associated with each cognition Importance of cognition in task performance Similarity of cognitive elements (for creating cognition combinations)
Subject matter (e.g. mathematics)
Risks associated with misunderstanding the cognitive element Cognitive complexity Cognitive Analysis must include all aspects of job performance, including but not limited to knowledge important to safe plant operation and cognitions related to the foundational theory of plant operations.
3.1.5 Task List Reviews Task list review is an event-driven process that optimizes program task lists for sustained performance of plant personnel. Event triggers include:
Needs Analysis Post-Training Effectiveness Evaluation (PTEE)
Training program completion milestones Long-Range Training Plan
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 12 Layout: DLT-007 Rev 9 Configuration control process Change management process Performance improvement process Evaluation Phase activity findings New training programs (i.e., those for new construction plants) do not have supportive evidence of sustained performance of plant personnel. Therefore, the first PTEE in each training program will trigger a full task list review.
Task list reviews are initiated by the Training Program Lead based on the event triggers above. An instructor compiles the task list review and issues it to the Line organization for input. The Line organization selects task(s) to be reanalyzed and sends the task list review back to the instructor. The DIF analysis for the selected task(s) is reperformed and the results are submitted to the Training Program Lead and Program Owner for review and approval.
Based on the event trigger, a full or partial task list review may occur. All relevant tasks, both selected and deselected, are evaluated as needed.
The Analysis Phase results serve as the basis for the next SAT element, the Design Phase.
3.2 Design Phase TMX-1.2 governs the Design Phase of the X-energy SAT process for the Xe-100. The purpose of the Design Phase is to develop clear training objectives organized in a logical, pedagogical sense for effective learning in modules, courses, and training programs to achieve desired results. The main activities of the Design Phase are: define target student population, develop learning objectives, determine training setting, organize learning objectives, and prepare evaluation items.
3.2.1 Define Target Student Population The first process of the Design Phase is to define the target student population. Training program design is focused on the results of the Analysis Phase and identified prerequisite education and experience.
Learning objectives and content align with minimum education and experience requirements to enable knowledge transfer with appropriate detail and rigor.
3.2.2 Develop Learning Objectives Learning objectives are created, validated, or revised from results of the Analysis Phase. Learning objectives are organized into terminal and enabling objectives. Learning objectives are built of three components: a condition, an action, and a standard that are clearly written to distinguish each component.
Terminal Objectives A terminal objective is written for each major topic/ task. The terminal objective is derived from the task statement and focuses on the overall results of the training.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 13 Layout: DLT-007 Rev 9 Enabling Objectives An enabling objective is written for each task element that a trainee must master to successfully complete the associated terminal objective.
Enabling objective creation is focused on the elements identified in the job and task analyses. Enabling objectives are further refined into cognitive and performance objectives to distinguish the associated learning domain and aid in selection of the appropriate setting for training and evaluation.
Cognitive enabling objectives are typically trained in a self-paced or classroom setting. Cognitive enabling objectives are usually evaluated in a written or electronic evaluation.
Performance enabling objectives are typically trained in an on-the-job setting. Performance enabling objectives are usually evaluated in a laboratory, simulator, or task performance evaluation.
Learning Objective Conditions The condition statement clearly states the condition(s) that will exist at the time of trainee performance.
Conditions of performance define the facility situation, environmental aspects, and resources available to aid trainee performance.
Learning objective conditions are derived from various job conditions identified during analysis. When developing learning objective conditions, adjustments may be necessary to reflect the degree of fidelity desired and achievable within the training setting. For example, job conditions may be simulated with high fidelity during on-the-job and simulator training, because they mirror the actual job conditions. When classroom or self-paced learning is used, the learning objective conditions are limited by the constraints of the classroom or self-paced environment.
Learning Objective Action Statements The action statement consists of an action verb and a direct object. The action verb should identify trainee behavior that is observable, measurable, and applicable to trainee performance.
Learning Objective Standards The standard statement identifies the standard for evaluating trainee performance. The trainees action should result in an output, and the required quantity or quality of that output is the standard of performance. Standards can include step-by-step processes that do not permit deviation. Others may prescribe the product of performance and the factors for judging that product.
Standards are derived from job standards identified during analysis. Like the selection process for conditions, learning objective standards should be adjusted to reflect fidelity to job standards. If an action is required to be performed within a specified period, the standard must include the time requirement.
3.2.3 Training Setting The training setting is the environment or location in which training takes place. A decision on an appropriate setting for a specific training session is made during the Design Phase. The type and cognitive level of training and learning objectives have a direct bearing on the method of instruction and the
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Xe-100 Control Room Simulation Facility In-plant Classroom Laboratory Augmented/Virtual Reality 3.2.3.1 Performance Level Performance level (P/S/D) of OJT and performance evaluation is selected as follows:
1.
The Perform (P) mode is preferentially selected when possible.
2.
The Simulate (S) mode is selected when the Perform (P) mode is unfeasible due to the potential impact of trainee error, the impact of repositioning equipment, operating mode, equipment availability, or other limitations and considerations that make task performance undesirable.
3.
The Discuss (D) mode is the least-preferred mode. It is selected when neither P nor S are feasible due to personnel, plant, or equipment concerns. It should be used infrequently, as cognitive evaluation typically precedes performance evaluation.
3.2.4 Organize Learning Objectives Learning objectives are organized in a lesson plan to facilitate trainee learning and mastery. Instructional design addresses temporal order of learning objectives and their related content as well as scheduling.
Temporal order is primarily based on progressing the content from low cognitive learning objectives to high cognitive learning objectives and providing trainees with introduction, background, fundamental, simple concepts before presenting detailed, advanced, complex concepts within a given curriculum topic.
Scheduling is primarily based on estimated duration for each learning activity and any resource constraints that may occur. The estimated duration for each learning activity is based on various considerations (e.g.,
number of slides, multimedia length, verification, and validation duration data). Training resources and assets (e.g., staff availability, simulator availability, lab availability, etc.) are examples of possible constraints that may influence scheduling.
3.2.5 Prepare Evaluation Items Evaluation items are prepared to objectively measure a trainees mastery of the learning objectives and gauge the effectiveness of the training program. Evaluation items are categorized as cognitive evaluations and performance evaluations. Cognitive evaluations (e.g., quizzes, written exams) are addressed in TMX-1.6. Performance evaluations (e.g., simulator evaluations, laboratory evaluations, and task performance evaluations) are addressed in TMX-1.9.
The Design Phase results serve as the basis for the next SAT element, the Development Phase.
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Materials include lesson plans, simulator guides, laboratory guides, self-led training materials, and associated evaluation items and exams. The main activities of the Development Phase are: creating material, revising material, reviewing material, and approving material.
3.3.1 Creating Training Material Training materials are developed based on the plant design, as specified by the job and task analysis and their corresponding elements, and as analyzed and selected for training. Training materials contain enough detail for trainees to successfully master the associated learning objectives and provide direction for consistent delivery of the information.
Training materials contain the following elements to ensure consistent presentation:
Learning objectives Adequate amount and detail of content to ensure consistency Support materials (e.g., equipment, tools, audiovisual, other equipment)
Effective knowledge transfer is addressed, in part, by selecting an appropriate delivery method of instructional content and developing training material with this decision in mind. For example, relying solely on self-study of written guidance for tasks that will be evaluated in a performance setting, with no guided performance practice, is not an appropriate delivery method. However, self-study using augmented, simulated, or virtual reality training that allows interactive demonstration of the skill may be acceptable depending on the difficulty and importance of the topic being trained.
An appropriate delivery method aligns with the cognitive level of the learning objective. For example, if a learning objective requires analysis of a system fault, the supporting material cannot solely focus on the purpose and general function of the system; instead, the content must incorporate learning at the higher cognitive learning objective.
Learning Objects Note - learning object and learning objective are different terms and are not interchangeable in this document.
A learning object contains one learning objective and all related learning resources. Learning resources are any content that supports the learning objective, such as text, diagrams, media, trainee reinforcement activities, and cognitive and performance evaluation items. Figure 1, Learning Object Model, below describes this learning object methodology used in the X-energy SAT process for the Xe-100.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 16 Layout: DLT-007 Rev 9 Figure 1: Learning Object Model A fully developed learning object may be used as standalone training material. Multiple learning objects may be sequenced into a lesson plan, as shown in the Figure 2, Lesson Plan Model, below.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 17 Layout: DLT-007 Rev 9 Figure 2: Lesson Plan Model TMX-1.9 addresses sequencing learning objects into performance training.
3.3.2 Revising Training Material Existing training materials may be used and/or revised in this process. If materials are revised, the revisions are deemed either major or minor as follows:
Major revisions are changes either to the technical content supporting a learning objective or to the learning objective itself.
Minor revisions are non-technical changes to learning resources or learning objects or editorial changes to learning objectives.
Table 2, Major and Minor Revisions, below provides examples of major and minor revisions.
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Minor Correcting typographical errors in training content.
Minor Correcting a typographical error in a learning objective statement.
Minor Updating a supporting P&ID to reflect plant design changes.
Major Altering a learning objective condition to allow references.
Major 3.3.3 Reviewing Training Material Material is reviewed prior to use to ensure it is complete, accurate, relevant, and supports the learning objectives. Whenever possible, the material is piloted in advance of implementation.
Reviews are performed by knowledgeable individuals who provide feedback to the instructor. Lesson plans and evaluation items are reviewed, and deficiencies are identified for correction.
To maximize review efficiency and depth of reviews, classroom and self-guided/self-paced training materials are reviewed by training and knowledgeable individuals per Table 3, Review Requirements, below.
Table 3: Review Requirements Type of Material Required Reviewer Required Approver Learning Resource None Instructor Learning Object (First or Major Revision)
Knowledgeable Individual Training Manager (or designee)
Learning Object (Minor Revision)
Instructor (not the author)
Training Program Lead Lesson Plan Instructor (not the author)
Training Manager 3.3.4 Piloting Training Material After training material review is complete, a pilot may be conducted with a small group, including trainees who possess the entry level requirements expected of future trainees.
During pilots, the training environment should be simulated as closely as practicable. Training materials are presented as intended for actual use. Data is collected for subsequent analysis to improve lesson plans and learning resources and to validate instructor (teaching) skills.
Trainees who participate in a pilot session may be granted credit for completion if all the following are true:
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 19 Layout: DLT-007 Rev 9 There are no major changes (as defined in Revising Training Material section) to any learning object The trainee passed the evaluation associated with the piloted learning objectives and training material If a major change to any learning object is warranted, gap training on the changes is an appropriate method to grant credit for the pilot session.
3.3.5 Approving Training Material Training materials are reviewed by training and Line management for accuracy and adequacy prior to instruction.
3.3.6 Development of Cognitive and Performance Evaluations TMX-1.6 governs developing cognitive evaluations. Cognitive evaluations adequately sample the course objectives to ensure trainee mastery of the course content requisite knowledge. Lesson plan sequencing and course curriculum, the number of objectives, and objective difficulty are considered when developing a cognitive evaluation. Sufficient evaluation items from each lesson plans learning objectives are included to adequately assess trainee comprehension and mastery of the content. For learning objectives that cover multiple tasks and elements, the cognitive evaluation sufficiently samples the tasks and elements tied to the learning objective. The number of tasks and elements tied to the learning objective and the associated importance to risk and safety are considered when choosing tasks and elements for exam development. For exams that cover multiple lessons, learning objectives that will adequately cover the content and confirm overall mastery of the material may be chosen. Exam development includes higher cognitive learning objectives that build on the understanding of lower cognitive learning objectives.
If different versions of the same exam are being given in a short period, the questions on each version of the exam must differ by at least 40%. Exam questions are reviewed to ensure they are not duplicated and cannot be used to aid in answering another question.
TMX-1.9 governs developing performance evaluations. Performance evaluations include laboratory, simulator, or task performance evaluations (TPE) requiring hands-on or simulated performance by the trainee to demonstrate mastery. Performance objectives derived from tasks or skills selected for training are evaluated with performance evaluations as identified in the Design Phase.
For both cognitive evaluations and performance evaluations, clear grading methods and success criteria are defined, understood by trainees and evaluators, and applied uniformly.
The Development Phase materials are used in the next SAT element, the Implementation Phase.
3.4 Implementation Phase TMX-1.4 governs the Implementation Phase of the X-energy SAT process for the Xe-100. The purpose of the Implementation Phase is to deliver the training and evaluation materials created in the Development Phase. Successful performance of the Implementation Phase requires the training instructors to promote
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 20 Layout: DLT-007 Rev 9 trainee mastery of the learning objectives and to ensure a transfer of trainee knowledge and skills from the instructional setting to the job.
Applicants and/or licensees committing to implementing X-energy facility training programs for the Xe-100 also commit to interfacing with X-energy to update and maintain the training materials with new and modified procedures and plant changes, as well as communicating applicable operating experience. In this way the implementation element supports maintaining the Xe-100 training programs as required by 10 CFR 50.120(b)(1).
The main activities of the Implementation Phase are: preparation and scheduling, delivery of training, evaluation and remediation, and collecting feedback post-training.
3.4.1 Preparation and Scheduling Train-the-trainer is conducted to train and qualify Xe-100 instructors. This includes pedagogical and methodological skills as well as the technical elements from the training program the instructor is being qualified to instruct.
Training instructors execute training and evaluation activities per training program schedules using approved materials from the Development Phase. Instructors ensure training assets and resources are available, suitable, and reserved for use. Instructors coordinate the training schedule to align with the target audience identified in the Design Phase.
3.4.1.1 Exemption and Equivalence Exemption is a release from participating in training where training requirements have already been met. All training, including on-the-job training (OJT), may be exempted when appropriate.
Equivalence - or Equivalent Qualification - is a process that evaluates a trainees past training and performance history and is determined by the Program Owner to meet the qualification standards for a particular task or duty area.
The exemption and equivalence processes are conducted on a case-by-case basis. Training personnel review recorded evidence of prior training and performance history to specify training and/or performance evaluation activities that meet established acceptance criteria. Training personnel document justification of requested outcomes, attach objective evidence, and route the request to the Line for approval.
3.4.2 Delivery of Training Instructors who deliver training are qualified and proficient in the methods and techniques for successful presentation in the training setting and asset they are using. Instructors should be prepared, as evident by their performance in the classroom using questioning skills, coaching skills, and learning techniques for optimal trainee mastery of the learning objectives. Effective delivery of training includes consistent adherence to the approved training material and reinforcing Line standards where appropriate.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 21 Layout: DLT-007 Rev 9 The inaugural initial training classes will be prepared to commence at least 18 months prior to the initial fuel loading for the first Xe-100 deployment.
3.4.3 Evaluation and Remediation The evaluation process is used to verify trainee competence of the learning objectives. Cognitive learning objectives are evaluated using cognitive evaluation methods. Performance learning objectives are evaluated using performance evaluation methods.
All training requires trainee evaluation. Proper implementation of evaluations requires specific guidelines for planning, exam security, delivery, scoring, post-evaluation review, and feedback respective to their purpose and setting.
Remediation includes, at a minimum, following a standard remediation plan. This plan includes review of the evaluation results, review of satisfactory response(s), training material review to close knowledge gaps, studying, and attempting a new evaluation. At a minimum, the remediation evaluation must retest on the concepts missed by the trainee on the original evaluation through items evaluating those learning objectives. If the evaluation is an examination, at least 30% of questions must differ between the original and remedial exams.
In the event of repeated or complex unsatisfactory evaluation performance, a personalized remediation plan is directed on a case-by-case basis.
3.4.4 Post-Training Activities Following examination and evaluation activities, instructors collect training feedback and document the training occurrence. Training feedback should be collected promptly to capture initial impressions of effectiveness. The feedback is used for course (program) evaluation in the Evaluation Phase of the SAT process.
Documentation of training should include, as applicable, the lesson plan, examination or evaluation, curriculum completed, instructor, training completion date, and names of trainees who completed the training. Qualification records should be updated, as applicable.
Gap training is considered based on any differences between the training provided to the trainee and any changes impacting learning objects, including:
Modifications to the training materials that were used to conduct the initial training New tasks that need to be trained Design modifications Changes in regulatory requirements Any changes that affect the workers knowledge and skills before the next task re-training date The Implementation Phase provides data (input) to the next SAT element, the Evaluation Phase.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 22 Layout: DLT-007 Rev 9 3.5 Evaluation Phase TMX-1.5 governs the Evaluation Phase of the X-energy SAT process for the Xe-100. The purpose of the Evaluation Phase is to assess the effectiveness and efficiency of the training programs. Evaluation is the feedback component of the performance-based training model. The outcome of the Evaluation Phase is the initiation of necessary actions to improve gaps identified in the training programs.
Applicants and/or licensees committing to implementing X-energy facility training programs for the Xe-100 also commit to interfacing with X-energy to provide job performance, self-assessments, observations, and feedback to maintain the training materials with new and modified procedures and plant changes, as well as communicating applicable operating experience. In this way the Evaluation Phase supports maintaining the Xe-100 training programs as required by 10 CFR 50.120(b)(1).
The main activities of the Evaluation Phase are: evaluation intake, information assessment, and initiate corrective actions.
3.5.1 Collect and Analyze Feedback Training and Line personnel should be aware of conditions and events that indicate training effectiveness.
The method of data collection and review should be continuous to ensure the currency and adequacy of the training program to sustain program effectiveness in Line performance.
Training evaluation consists of receiving and analyzing feedback on the effectiveness of the training program. There are multiple methods of receiving feedback, including from trainees in the program, management observations of the program, analyzing exam results, and assessing the effectiveness of the training program by evaluating on-the-job performance of personnel who completed the training program.
Trainee Feedback Analysis Training personnel collect trainee feedback during the Implementation Phase. Effective evaluation of the training program includes reviewing the trainee feedback and initiating actions, when necessary, to improve the training program curriculum for future offerings.
Trainee feedback is solicited to gather the following data:
Adequacy of training in providing background knowledge Adequacy of training in developing associated skills Degree to which training is related to job requirements Degree to which training prepared trainees to fulfill job requirements Management Observations of Training Line management should observe training delivery on a routine basis and provide feedback on the adequacy of the training. Effective evaluation of the training program includes reviewing and analyzing the feedback for potential improvements.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 23 Layout: DLT-007 Rev 9 Exam Item Analysis Following exam administration, an exam item analysis should be conducted to review the effectiveness of the exam and ensure exam item topics were adequately addressed during training.
Post Training Effectiveness Evaluation When a trainee completes the initial training program, a Post Training Effectiveness Evaluation is conducted to assess the effectiveness of the training program to prepare the trainee for the job. Feedback from the trainee, job incumbents, and Line management is included in the evaluation to assess how well the training program prepared the trainee for independent job performance. This information is typically collected six months to a year following course graduation.
Post Training Effectiveness Evaluations solicit the following data:
From trainees and job incumbents Unexpected difficulties in performing tasks on the job Tasks that were particularly easy or difficult to perform Additional training needed to do the job Kinds of errors committed on the job Difference between the way tasks are performed on the job and the way they are taught From supervisors Tasks for which new job incumbents were inadequately prepared Kinds of errors being committed by job incumbents Suggestions for improvements in initial and continuing training Assessing the Approved Training Program Scope Information can also be reviewed for any potential changes in training program job requirements (i.e.,
tasks) that are not currently selected for training but have been flagged as being affected by a change or potentially contributed to an event. Data can be identified through any intake method, such as trainee feedback, facility modifications and procedure changes, industry event reports, or inspection results.
3.5.2 Facility Issues and Events Facility events should be evaluated for potential training program impact. Human errors, equipment damage or unavailability, or rework could be an indicator that the associated training program inadequately or improperly trained a task or identify a task that needs to be trained. For significant events, training and Line supervision evaluate whether training was a causal factor.
3.5.3 Inspection, Assessment, and Corrective Action Reports Any inspection, assessment, or corrective action report that explicitly mentions a training weakness needs to be evaluated. Facility reports from causal evaluation, internal and external inspections and evaluations,
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 24 Layout: DLT-007 Rev 9 and routine program assessments should be reviewed for potential training related weaknesses or recommendations.
3.5.4 Facility Modifications and Procedure Changes Facility design changes, modifications, or procedure changes that impact equipment operation, maintenance, or user interface could alter the original information assessed in the training program job and task analysis and associated elements to which the training curriculum was designed. Consequently, any design changes to the facility must be reviewed for potential impact to the training program.
3.5.5 Industry Regulatory Changes and Operating Experience Regulatory changes and industry operating experience shall be reviewed for applicability and incorporated into the associated training programs accordingly.
3.5.6 Assessing the Approved Training Program Effectiveness Information should be reviewed for any potential objective or factual data related to training program performance by evaluating the analyzed elements associated with the tasks selected for training as identified in the Analysis Phase. Data can be identified through any method, such as trainee feedback, Line performance, or assessments and analyzed into a Post Training Effectiveness Evaluation.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 25 Layout: DLT-007 Rev 9
- 4. Xe-100 Control Room Operator Training Program The Xe-100 Control Room Operator (CRO) Training Program includes an initial training program, a requalification training program, and evaluation and remediation standards.
The CRO Training Program incorporates the instructional requirements necessary for CROs to obtain and maintain the necessary knowledge, skills, and abilities to operate and maintain the facility in a safe manner in all modes of operation.
The CRO Training Program:
Complies with the facility license, including all technical specifications and applicable regulations Is periodically evaluated and revised as appropriate to reflect industry experience and relevant changes, including changes to the facility, procedures, regulations, and QA requirements Is periodically reviewed by training and Line personnel for effectiveness Includes the CRO manipulating the controls of either the facility or the Xe-100 control room simulation facility that demonstrates compliance with the requirements of § 55.46 The CRO Training Program includes training conducted using the control room simulator, which is designed by adhering to the guidance of ANSI/ANS-3.5-2009, Nuclear Power Plant Simulators for Use in Operator Training and Examination [18], as endorsed by the NRC in RG 1.149, Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements [19]. The simulator training provides operations personnel with sufficient knowledge and experience required for CRO qualifications. This enables operations personnel to perform their required duties during the unique conditions of new plant construction and initial operation. The control room simulator is of sufficient scope and fidelity for individuals to acquire and demonstrate the necessary knowledge, skills, and abilities to safely perform licensed duties.
Shift Supervisors are also trained as CROs and receive additional training that addresses higherlevel management skills and behaviors and provides a broader perspective of plant operations.
4.1 Initial Training The CRO Training Program includes tasks and cognitions for foundational theory of plant operations and systems important to safety as applicable to the Xe-100 design, including:
Reactor theory, thermodynamic principles, and chemical theory associated with the technologies, materials, and processes of the Xe-100 design Safety-significant plant systems and components Reactivity management and manipulations Radiation control and safety Emergency, abnormal, and normal operations Administrative requirements and conditions of the facility license Technical specifications
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 26 Layout: DLT-007 Rev 9 This training is designed to provide the requisite task training, as defined by the SAT process, to support the qualification requirements for CROs. These qualification requirements are outside the scope of this document.
Additionally, CROs are trained to safely and competently:
Perform administrative tasks, including compliance with technical specifications, and perform operability determinations Implement maintenance and configuration controls Comply with radioactive release limitations Understand plant operating data, including reactor parameters, and evaluate emergency conditions Initiate a reactor shutdown from necessary locations Dispatch and direct operations and maintenance personnel Implement any applicable responsibilities under the facility emergency plan Make required notifications to local, State, and participating Tribal and Federal authorities 4.2 Requalification Training The CRO requalification program provides for the continuing training and examination to ensure that CROs maintain the knowledge and abilities needed to support the safe and reliable performance of job duties following the completion of an initial training and examination program. The requalification program specifies an appropriate periodicity for administering a complete requalification examination.
4.3 Evaluation and Remediation Evaluations assess whether trainees have achieved a degree of knowledge and ability that will be sufficient to enable them to carry out assigned duties as CRO in a manner that is both safe and reliable.
Examinations can be cognitive or performance evaluations, based on the associated learning objective.
Examinations test a representative sample (determined by the SAT process) of the knowledge, skills, and abilities needed to safely perform CRO duties, and include the examination methods and criteria to be used to assess passing performance. Successful execution of training examinations includes exam security standards, examination administration and grading, and remediation.
Examination administration includes establishing and implementing a standard that ensures test integrity.
The examination standard includes sufficient provisions to ensure that exams are not inadvertently compromised during exam development, exam administration, or post exam activities. Each examination will provide the opportunity for a representative of the Commission to be present during examination administration.
Remediation includes, at a minimum, following a standard remediation plan. This plan includes review of the evaluation results, review of satisfactory response(s), training material review to close knowledge gaps, studying, and attempting a new evaluation. At a minimum, the remediation evaluation must retest on the concepts missed by the trainee on the original evaluation through items evaluating those learning
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 27 Layout: DLT-007 Rev 9 objectives. If the evaluation is an examination, greater than or equal to 30% of questions must differ between the original and remedial exams.
In the event of repeated or complex unsatisfactory evaluation performance, a personalized remediation plan is directed on a case-by-case basis.
For the requalification training program, a CRO will be removed from the performance of watchstanding duties during the exam remediation process until such time that any necessary remedial training has been completed and a reexamination has been passed.
CROs, the facility licensee, and X-energy will not engage in any activity that compromises the integrity of any examination conducted under the CRO Training Program. The integrity of an examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, could have affected the equitable and consistent administration of the examination. This includes all activities related to the preparation, administration, and grading of examinations.
4.4 Records The following is required regarding the CRO Training Program records:
1.
Sufficient records are maintained providing documentation of the integrity of the program and are available for NRC inspection to verify the adequacy of the program.
2.
Records are maintained documenting the participation of each CRO in the training program. The records contain copies of examinations administered, the answers given by the CRO, documentation of the grading of examinations, and documentation of any additional training administered in areas in which a CRO exhibited deficiencies.
3.
Each of these records will be legible throughout the retention period. The record may be the original, a reproduced copy, or an electronic copy provided that the copy is authenticated by authorized personnel.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 28 Layout: DLT-007 Rev 9
- 5. Conclusions X-energy has reviewed, identified, and analyzed relevant NRC regulations and guidance applicable to the Xe-100 Training Programs for X-energy and prospective applicants and licensees. This Xe-100 Training Programs Methodology LTR provides the approaches and methodologies applicable for developing, implementing, and maintaining the Xe-100 Training Programs for plant staff. The Xe-100 Training Programs methodologies are derived from SAT as required by 10 CFR 50.120 and defined in 10 CFR 55.4.
The SAT methodologies follow industry best practices and long-standing precedence in the nuclear training community and will result in the establishment, implementation, and maintenance of the necessary training programs.
X-energy is requesting NRC review and approval of the methodologies to develop, implement, and maintain the Xe-100 training programs to demonstrate compliance with 10 CFR 50.120(b)(2) and 10 CFR 55.4. Future applicants for an Xe-100 construction permit, operating license, or combined license application will be able to seek NRC approval of the completed Xe-100 training programs using the approaches and methodologies discussed in this LTR. NRC approval of the completed Xe-100 training programs developed with these methodologies is outside the scope of this report. X-energy does not intend to seek accreditation of the Xe-100 training programs by the National Nuclear Accrediting Board (NNAB). Rather, X-energy is seeking a Commission-approved Facility-developed Training Program Methodology by the Commission.
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 29 Layout: DLT-007 Rev 9
- 6. Cross References and References Document Title Cross
References:
X-energy documents that may impact the content of this document.
References:
X-energy or other documents that will not impact the content of this document Document No.
Rev./
Date of Issuance Cross Reference/
Reference
[1] Xe-100 Licensing Topical Report: Control Room Staffing Analysis Methodology and Associated HFE Implementation Plans (ML22004A333) 000714 Jan 2022 Reference
[2] Human Factors Engineering Program Review Model NUREG-0711 Revision 3 Reference
[3] Selection, Qualification, and Training of Personnel for Nuclear Power Plants ANSI/ANS-3.1 2014 Reference
[4] Qualification and Training of Personnel for Nuclear Power Plants RG 1.8 Revision 4 Reference
[5] Advanced Reactor Content of Application Facility Training Programs Draft Interim Staff Guidance DRO-ISG-2023-04 Apr 2023 Reference
[6] Department of Energy (DOE) Handbook, Training Program Handbook: A Systematic Approach to Training DOE-HDBK-1 078-94 Jun 2014 Reference
[7] Systematic Approach to Training for Nuclear Facility Personnel:
Processes, Methodology and Practices NG-T-2.8 Apr 2021 Reference
[8] Human-System Interface Design Review Guidelines NUREG-0700 Revision 3 Reference
[9] Template for an Industry Training Program Description NEI 06-13A Revision 2 Reference
[10] Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition NUREG-0800 Reference Chapter 13.2.1, Reactor Operating Requalification Program; Reactor Operator Training NUREG-0800 Revision 4 Reference Chapter 13.2.2, Non-licensed Plant Staff Training NUREG-0800 Revision 4 Reference Chapter 18, Human Factors Engineering, Attachment B, Methodology to Assess the Workload of Challenging Operational Conditions in Support of Minimum Staffing Level Reviews NUREG-0800 Revision 3 Reference
[11] Operator Licensing Examination Standards for Power Reactors NUREG-1021 Revision 12 Reference
[12] Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors NUREG-1122 Revision 3 Reference
[13] Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors NUREG-1123 Revision 3 Reference
[14] Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Westinghouse AP1000 Pressurized-Water Reactors NUREG-2103 Jan 2021 Reference
Xe-100 Licensing Topical Report Doc ID No: 006012-A Revision: 4 Date: 28-OCT-2024 Revised 5/02/2023 X Energy, LLC Security Classification: Unrestricted Page 30 Layout: DLT-007 Rev 9 Document Title Cross
References:
X-energy documents that may impact the content of this document.
References:
X-energy or other documents that will not impact the content of this document Document No.
Rev./
Date of Issuance Cross Reference/
Reference
[15] Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Advanced Boiling-Water Reactors NUREG-2104 Dec 2011 Reference
[16] Xe-100 Maintenance Strategy Analysis 002123 Revision 2 Reference
[17] Monitoring the Effectiveness of Maintenance at Nuclear Power Plants RG 1.160 Revision 3 Reference
[18] Nuclear Power Plant Simulators for Use in Operator Training and Examination ANSI/ANS-3.5 2009 Reference
[19] Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements RG 1.149 Revision 4 Reference
[20] Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors SECY-23-0021 Mar 2023 Reference
[21] Risk Informed and Performance based Human System considerations for Advanced Reactors (ML21069A003)
ML21069A003 Mar 2021 Reference
[22] Xe-100 Licensing Maintenance Staff Optimization White Paper (ML21362A751)
ML21362A751 Dec 2021 Reference
[23] Xe-100 SAT Methodology: Analysis Procedure TMX-1.1 Revision 3 Reference
[24] Xe-100 SAT Methodology: Design Procedure TMX-1.2 Revision 3 Reference
[25] Xe-100 SAT Methodology: Development Procedure TMX-1.3 Revision 3 Reference
[26] Xe-100 SAT Methodology: Implementation Procedure TMX-1.4 Revision 3 Reference
[27] Xe-100 SAT Methodology: Evaluation Procedure TMX-1.5 Revision 2 Reference
[28] Xe-100 Cognitive Evaluation Methods TMX-1.6 Revision 3 Reference
[29] Xe-100 OJT, TPE, and Lab Standard TMX-1.9 Revision 2 Reference
[30] Xe-100 Training Department Training Program Manual TMX-6.0 Revision 2 Reference
From:
ext_Jessica_Maddocks To:
Ondra Dukes
Subject:
[External_Sender] Training Programs Methodology Replacement RE: General Form Submission (50535) Received Date:
Friday, October 3, 2025 3:42:41 PM Attachments:
image001.png Encl 1 - Xe-100 Training Programs Methodology LTR R4 Accepted Version.pdf
- Ondra, As discussed, see attached for replacement file for the Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology, Revision 4. Based off the order of the Accession Numbers below I believe the topical report corresponds to ML25275A038, but please confirm for me.
Jessica Maddocks Licensing Project Manager jmaddocks@x-energy.com This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, notify us immediately and delete this message immediately. Thank you. X Energy, LLC From: Yvonne Mirowski Sent: Thursday, October 2, 2025 10:28 AM To: alissa.neuhausen@nrc.gov; Adrian Muniz ; Ondra Dukes ; Denise McGovern (She/Her) ;
Richard Rivera Cc: Jessica Maddocks
Subject:
FW: General Form Submission (50535) Received Good morning, The Xe-100 Licensing Topical Report Xe-100 Training Programs Methodology, Revision 4 has been submitted to the NRC. ML numbers have been highlighted below.
- Regards, Yvonne
Original Message-----
From: mshd.resource@nrc.gov <mshd.resource@nrc.gov>
Sent: Thursday, October 2, 2025 10:24 AM To: Yvonne Mirowski <ymirowski@x-energy.com>
Subject:
General Form Submission (50535) Received Notice: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
The NRC received your General Form submission on: 10/02/2025 at 10.24 AM. It is being tracked as submission ID# 50535.
If it is a 'Publicly Available' submission after 6 work days from today the submission's attached document(s) will be available for viewing and download from the Agency's Public Web Based ADAMS website (https://usg02.safelinks.protection.office365.us/?
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