ML070950479

Final Safety Evaluation for Technical Report NEI 06-13, Technical Report on Template for an Industry Training Program (Project No. 689; TAC No. MD3406)

ML070950479
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/05/2007
From:	Coffin S M NRC/NRO/DNRL/AP1000B1
To:	Heymer A P Nuclear Energy Institute
Starefos, Joelle, NRO/DNRL/NWE1 415-1175
References
NEI 06-13, TAC MD3406
Download: ML070950479 (18)

Text

September 5, 2007Adrian P. Heymer, Senior DirectorNew Plant DeploymentNuclear Generation DivisionNuclear Energy Institute1776 I Street, NW, Suite 400Washington, DC 20006-3708

SUBJECT:

FINAL SAFETY EVALUATION FOR TOPICAL REPORT NEI 06-13, "TEMPLATE FOR AN INDUSTRY TRAINING PROGRAM" (PROJECT NO. 689; TAC NO. MD3406)

Dear Mr. Heymer:

By letter dated October 30, 2006, the Nuclear Energy Institute (NEI) submitted for U.S. NuclearRegulatory Commission (NRC) staff review its proposed Template for an Industry TrainingProgram, Revision 0. Enclosed is the staff's safety evaluation (SE) which defines the basis for acceptance ofNEI 06-13. On the basis of its review, the NRC staff finds that for combined licenseapplications, NEI 06-13 provides an acceptable template for describing reactor operator andnonlicensed plant staff training programs.Our acceptance applies only to material provided in NEI 06-13. We do not intend to repeat ourreview of the acceptable material described in the NEI 06-13. When the NEI 06-13 appears asa reference in regulatory applications, our review will ensure that t he material presented appliesto the specific application involved. Licensing requests that deviate from NEI 06-13 will besubject to a plant- or site-specific review in accordance with applicable review standards.In accordance with the guidance provided on the NRC website, we request that NEI publish theaccepted version of NEI 06-13 within three months of receipt of this letter. The acceptedversion should incorporate this letter and the enclosed SE after the title page. Typically, theaccepted version would also contain historical review information, including NRC requests foradditional information (RAIs) and your responses; however, that is not necessary for NEI 06-13because RAIs were not issued. The accepted versions shall include a "-A" (designatingaccepted) following the report identification symbol.If future changes to the NRC's regulatory requirements affect the acceptability of NEI 06-13, NEIwill be expected to revise NEI 06-13 appropriately, or justify its continued applicability forsubsequent referencing.

A. Heymer- 2 -If you have any questions, please contact Michael Canova at (301) 415-0737, ormac6@nrc.gov

.Sincerely,

/RA/Stephanie M. Coffin, ChiefAP1000 Projects BranchDivision of New Reactor LicensingOffice of New ReactorsProject No. 689

Enclosure:

Safety Evaluationcc w/encl: See next page

ML070950479NRC-043OFFICEDNRL/NWE:LADNRL/NARP:PMDCIP/COLP:BCOGC:NLODNRL/NWE:BC NAMEKGoldsteinMCanovaMJungeAHodgdonSCoffinDATE8/20/078/20/078/21/0709/04/079/5/07 ENCLOSUREENCLOSURESAFETY EVALUATIONREGARDING THE NUCLEAR ENERGY INSTITUTETOPICAL REPORT 06-13"TEMPLATE FOR AN INDUSTRY TRAINING PROGRAM "REVISION

01.0BACKGROUND

By letter dated October 30, 2006, the Nuclear Energy Institute (NEI) submitted Template for an Industry Training Program," Revision 0 (NEI 06-13) for Nuclear Regulatory Commission (NRC)review and approval. The topical report provides a complete generic training programdescription for use with combined license applications. NEI 06-13 was developed by the NEINew Plant Training Task Force, which includes representatives from the four design-centeredworking groups, to assist in expediting NRC review of the combined license and issuance of thecombined license. NEI 06-13 is not applicable to the review and issuance of constructionpermits or operating licenses.

2.0REGULATORY EVALUATION

The NRC staff verified that NEI 06-13, Revision 0 complies with the following regulations,regulatory guidance, NUREGs, and industry standards:

!10 CFR Part 19, "Notices, Instructions and Reports to Workers: Inspections andInvestigations"

!10 CFR Part 26, "Fitness For Duty Programs"

!10 CFR Part 50, "Domestic Licensing of Production and Utilizat ion Facilities"

!10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Productionand Utilization Facilities"

!10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and CombinedLicenses for Nuclear Power Plants"

!10 CFR Part 55, "Operators' Licenses"

!Regulatory Guide 1.8, Rev. 3, "Qualification and Training of Personnel for NuclearPower Plants"

!Regulatory Guide 1.149, Rev. 3, "Nuclear Power Plant Simulation Facilities for Use inOperator Training and License Examinations"

!NUREG-0711, Rev. 2, "Human Factors Engineering Program Review Model"

!NUREG-0800, Rev. 2, Standard Review Plan, Section 13.2.1, "Reactor OperatorTraining"!NUREG-0800, Rev. 2, Standard Review Plan, Section 13.2.2, "Training for NonlicensedPlant Staff"

!NUREG-0800, Standard Review Plan, Section 18.0, "Human Factors Engineering"

!ANSI/ANS 3.1-1993, "Selection, Qualification, and Training of Personnel in NuclearPower Plants"  !NUREG-1021, Rev. 9, "Operator Licensing Examination Standards for Power Reactors"

!NUREG-1220, Rev. 1, "Training Review Criteria and Procedures"

!Generic Letter 86-04, "Policy Statement on Engineering Expertise on Shift,"February 198

63.0TECHNICAL EVALUATION

The staff's review concentrated on the proposed training program description format, attributesand level of detail. In evaluating the adequacy of the format, attributes and level of detail, thestaff followed the guidance of the Standard Review Plan (NUREG-0800), Section 13.2.1(SRP 13.2.1), "Reactor Operator Training" and Section 13.2.2 (SRP 13.2.2), "Training forNonlicensed Plant Staff." SRP 13.2.1 outlines the training and requalification programguidance for licensed reactor operators and senior reactor operators. SRP 13.2.2 outlines thetraining and retraining program guidance for nonlicensed plant staff. SRP 13.2.1 and 13.2.2apply to construction permit, operating license, and combined license applicants.NEI 06-13 is organized into five areas, licensed operator training, training for positions listed in10 CFR 50.120, general employee training, selected other training programs, and the trainingeffectiveness evaluation program. Other training programs selected for description include fireprotection, emergency plan, physical security, and station management training programs.3.1Licensed Operator TrainingThe "Licensed Operator Training" section of NEI 06-13 states that the Reactor Operator (RO) and Senior Reactor Oper ator (SRO) training programs will provide individuals with theknowledge, skills, and abilities needed to perform licensed operator duties. The reactoroperator training program description includes a description of the 10 CFR 55.59 requiredlicensed operator requalification program. The RO and SRO training and requalificationprograms will be devel oped, established, im plemented and maintained using a systemsapproach to training (SAT) as defined by 10 CFR 55.4 and as endorsed by Regulatory Guide1.8" Qualification and Training of Personnel for Nuclear Power Plants," ANSI/ANS-3.1-1993"Selection, Qualification, and Training of Personnel in Nuclear Power Plants." In accordancewith 10 CFR 55.46, a simulator will be used for training licensed personnel and for theadministration of operating tests.NEI 06-13 further states that prior to initial fuel load, the number of licensed ROs and SROs willbe sufficient to meet regulatory requirements, with allowances for licensing examinationcontingencies, and without the need for planned overtime.A summary of the RO and SRO training programs follows:

1.The Licensed Operator Initial Training Program will prepare RO and SRO candidates forthe NRC license exam. The program will be implemented in accordance with licenseedeveloped administrative procedures.2.Reactor Operator candidates will receive training in the topics lis ted in 10 CFR 55.41. RO candidates will receive plant simula tor training to dem onstrate under standing andthe ability to perform the actions listed in 10 CFR 55.45. 3.In addition to the RO topics listed in 10 CF R 55.41, SRO candidates will receive training in the topics listed in 10 CFR 55.43. SRO candidates will receive plant si mulator training to demonstrate understanding and the ability to perfo rm the actions listed in10 CFR 55.45.4.Licensed Operator Requalification training will consist of regularly scheduled formalinstruction, eval uation, and on-t he-job training. Training material will be developed usingthe SAT process in accordance with licensee developed administrative procedures. Alllicensed operators will participate in c ontinuing training.5.Licensed Operator Requalification Program content, course schedules and examinationschedules will comply with 10 CFR 55.59 and will include industry operating ex perience training. Lic ensed Operator Requalification training for licensed personnel will beconducted in accordance with licensee developed administrative procedures.Based on the staff's review of the "Licensed Operator Training" section of NEI 06-13 outlinedabove, the staff concludes that NEI 06-13 clearly and sufficiently describes, in terms of scopeand level of detail, the RO and SRO training programs to enable a reasonable assurancefinding of acceptability for issuance of a combined license with verification of the RO and SROtraining programs during the construction stage.3.2Training for Positions Listed in 10 CFR 50.120The "Training for Positions Listed in 10 CFR 50.120" section of NEI 06-13 states that the training programs for the positions listed in 10 CFR 50.120 will be designed, developed,implemented, and maintained using the SAT process. 10 CFR 50.120 requires training andqualification of the following categories of nuclear power plant personnel:

!Non-licensed Operator

!Shift Supervisor

!Shift Technical Advisor

!Instrument and Control Technician

!Electrical Maintenance Personnel

!Mechanical Maintenance Personnel

!Radiological Protection Technician

!Chemistry Technician

!Engineering Support Personnel Course content and duration for each 10 CFR 50.120 training program will be determined usingSAT methodology and will follow licensee dev eloped administrative procedures. The 10 CFR 50.120 training programs will be impl emented and maintained no later than eighteenmonths prior to fuel load. 3.2.1Non-licensed Operator (NLO)NLOs will receive instruction on operation of plant equipm ent and components undernormal and emergency conditions. The non-lic ensed operator training program will be acombination of formal instru ction and on-t he-job training. In-plant training will includesystem walk downs, which will emphasize the use of procedures, the proper operation ofequipment, and safe operati ng practices. Areas of training will include:

!Fundamentals of mechanical and electrical components

!Operation of equipment and systems

!Operating procedures

!Surveillance requirements

!Operation of systems important to plant safety3.2.2Shift Supervisor Prior to entering t he training program, the shift supervisor will have been licensed as anSRO. The Shift Supervisors will receive additional traini ng that addresses higher-levelmanagement skills and behaviors, and provi des a broader perspective of plantoperations. The Shift Supervisor training program will be a combination of formal instruction and on-t he-job training. Initial shift supervisor training w ill include topics suchas: !Application of Operating Experience

!Problem-solving skills

!Planning and managing evolutions

!Maintaining a broad view of plant operations

!Application of observation skills

!Operating philosophy

!Shift team management

!Application of design bases to plant operations

!Emergency Plan

!Transient and Accident Analysis

!Systems Approach to Training

!Work controls3.2.3Shift Technical Advisor (STA)STAs provide engineering expertise to the on-shift crew. Training provides the STA withthe skills and knowledge to monitor equipment and system operat ion to assess plantconditions during abnormal, off-normal, and emergency events. The STA trainingprogram will be a combination of formal inst ruction and on-the-job training. STA initialtraining will include instruction in the following areas:

!Responses to accidents and analyses of plant transients

!Application of engineering principles to protection of the core

!Mitigation of plant accidents !Basis of plant and systems design

!Reactor theory, thermodynamics, heat transfer, and fluid flow

!General Operating Procedures, Abnormal and Emergency OperatingProcedures, Technical Specifications, and Administrative Controls

!Operational transient and accident analysis

!Accident response training

!Simulator training, including exercises in at least the following situations:-Plant or reactor startups to include a range such that reactivity feedbackfrom nuclear heat addition is noticeable and heatup rate is established-Plant shutdown from greater than 50 percent power-Manual control of feedwater during startup or shutdown-Significant (10 percent or greater) power changes, in the power range,using controls as defined in 10 CFR 55.43.2.4Instrument and Control (I&C) Technician Initial training for I&C technicians will be a combination of formal instruction and on-the-job training. Training for I&C technicians will include instruction in the followingareas:!Fundamentals of instrumentation and control

!Pneumatic systems and equipment

!Electronics

!Fundamental systems training

!Instrument and Control and other job-related procedures

!Surveillance requirements

!Mitigating core damage training commensurate with t heir responsib ilities duringaccidents that involve severe core damage On-the-job training will permit I&C technicians to practice the skills and knowledgelearned in the classroom.3.2.5Electrical Maintenance Personnel (electricians)Initial training for electricians will be a combination of fo rmal instructi on and on-the-jobtraining. Training for electricians will include in struction in the following areas:

!Print reading

!Use of electrical tools and test equipment

!Fundamental systems training

!Electrical components and equipment !Electrical maintenance practices

!Maintenance procedures On-the-job training will permit electrici ans to practice the skills and knowledge learned inthe classroom. 3.2.6Mechanical Maintenance Personnel (mechanics)Initial training for mechanics will be a combination of form al instructi on and on-the-jobtraining. Training for mechanics will include instruction in the following areas:

!Print reading

!Use of hand tools, power tools, and measuring devices

!Fundamental systems training

!Mechanical components and equipment

!Mechanical maintenance practices

!Maintenance procedures On-the-job training will permit mechanics to practice the skills and knowledge learned inthe classroom.3.2.7Radiological Protection (RP) TechnicianInitial training for RP technicians will be a combination of formal instruction and on-the-job training. Training for RP technicians will include instruction in the followingareas:!Principles of radiation

!Radiation protection and safety

!Use of survey instruments

!Use of analytical equipment

!Radiation Protection procedures

!Emergency Plan procedures

!ALARA practices and procedures

!Fundamental systems training

!Mitigating core damage training On-the-job training will permit RP tec hnicians oppor tunities to oper ate radiation protection equi pment and practice the skills and knowledge l earned in the classroom.3.2.8Chemistry TechnicianInitial training for chemistry technicians will be a combination of formal instruction and on-the-job training. Training for chemistry technicians will in clude instruction in thefollowing areas:

!Chemistry procedures

!Laboratory practices !Conduct of analytical tests

!Operation of laboratory equipment

!Fundamental systems training

!On-the-job training to include actual operation of analytical equipment and theuse of procedures

!Mitigating core damage training commensurate with t heir responsib ilities duringaccidents that involve severe core damage

!Power plant chemistry On-the-job training will permit chemistry technicians oppor tunities to operate analytical equipment and practice t he skills and knowledge learned in the classroom.3.2.9Engineering Support PersonnelEngineering support personnel complete orientation training on the various aspects ofnuclear technology in an operating plant environment. Initial training for engineeringsupport personnel will be a combination of formal instruct ion and on-t he-job tr aining. Training for engineering support personnel will include instruction in the following areas:

!Records management and document control

!Applicable industrial and nuclear regulations, codes, and standards

!Procedures and drawings

!Applicable programs such as corrective action, configuration management, workcontrol, and the Quality Assurance program

!Technical Specifications

!Fundamentals such as reactor theory, heat transfer, fluid flow, properties ofmaterials, and chemistry

!Plant systems, instrumentation, and components

!Plant operations

!Introductory review of accidents

!Design processes On-the-job training will permit engineeri ng support personnel opportunities to practicethe skills and knowledge l earned in the classroom.3.2.10Continuing Training for Personnel Listed in 10 CFR 50.120

Personnel in positions listed in 10 CFR 50.120 will receive continuing training to maintainqualifications and enhance proficiency. Continuing training reinforces initial training byreiterating selected portions of the material. Continuing training also addresses new andmodified procedures and plant design changes. Operating Experience (OE) is included in continuing training for all programs. OE trainingprovides personnel with actual examples of good practices and lessons learned. OE topics willbe selected from Licensee Event Reports, corrective action databases, industry groups, andother sources.

Continuing training programs will be developed in accordance with SAT principles and will beconducted in accordance with licensee developed administrative procedures.Shift Technical Advisors (STAs) will maintain their qualifications by partici pating in licensedoperator requalification training.Based on the staff's review of the "Training for Positions Listed in 10 CFR 50.120" section ofNEI 06-13 outlined above, the staff concludes that NEI 06-13 clearly and sufficiently describes,in terms of scope and level of detail, the training programs for positions listed in 10 CFR 50.120 to enable a reasonable assurance finding of acceptability for issuance of a combined licensewith verification of the programs during the construction stage.3.3General Employee TrainingThe "General Employee Training" (GET) section of NEI 06-13 states that GET consists of threecomponents, Plant Access Training, Radiation Worker Training, and General EmployeeRequalification Training.3.3.1Plant Access Training Prior to being granted unescorted access to the plant, members of the station staff, contractorworkers, and unescorted visitors will complete Plant Access Traini ng. Plant Access Training willinclude the following topics:

!Station organization

!Station facilities and layout

!Station administration

!Nuclear plant overview

!Industrial safety

!Fire protection

!Quality assurance and quality control

!Plant security

!Emergency planning

!Radiological orientation

!Appropriate portions of 10 CFR 26

!Appropriate portions of 10 CFR 193.3.2Radiation Worker Training Personnel whose job duties require unescorted access to radiologically controlled areas of theplant will receive instruction in the applicable aspects of radiation pr otection. Radiation WorkerTraining will include the following topics: !Sources of radiation

!Types and measurement of radiation

!Biological effects of radiation

!Limits and guidelines, including Reg. Guide 8.13

!Concept of As Low As Is Reasonably Achievable (ALARA)

!Radiation dosimetry

!Contamination

!Internal exposure

!Radiation work permits

!Radiological postings

!Radiological alarms

!Radioactive waste

!Rights and responsibilities

!Protective clothing3.3.3General Employee Requalification Training Personnel with unescorted access to the plant participate in annual requalification training.Requalification training will include those topi cs in 3.3.1 and 3.

3.2, as applicabl e to continue to meet access requirements. Emphasis will be placed on changes to the plant, plant pr oceduresand procedure changes, government regulations, and quality assurance requirements. As applicable, training will be conducted on industry operating experiences, Licensee EventReports, and personnel errors.Based on the staff's review of the "General Employee Training" (GET) section of NEI 06-13outlined above, the staff concludes that NEI 06-13 clearly and sufficiently describes, in terms ofscope and level of detail, the training programs for general employee training to enable areasonable assurance finding of acceptability for issuance of a combined license withverification of the programs during the construction stage.3.4Selected Other Training ProgramsThe "Selected Other Training Programs" section of NEI 06-13 addresses training for positionsnot specified by either 10 CFR 55, "Operators' Licenses" or 10 CFR 50.120, "Training andQualification of Nuclear Power Plant Personnel."3.4.1Fire Protection Training

NEI 06-13 states t hat the training programs for fire protection personnel will be designed,developed, implemented, and maintained using the SAT process as defined by 10 CFR 55.4and as endorsed by Regulatory Guide-1.8. In addition, initial fire protection training will becompleted prior to receipt of fuel at the site. Personnel assigned as fire brigade members willreceive formal training prior to assuming brigade duties. Fire brigade members will also receiveregularly scheduled retr aining. Fire brigade training will comply with National Fire ProtectionAssociation Standard 600, "Standard on Industrial Fire Brigades."Training appropriate to the assigned work will be provided for the fire protection staff, fire watchpersonnel, and the general employee. Final Safety Analysis Report (FSAR) Section 9.5.1, "Fire Protection Program" will include additional informat ion regarding the fire protec tion trainingprograms.3.4.2Emergency Plan Training Program

NEI 06-13 states that Emergency Plan training will meet the requirements of 10 CFR 50Appendix E,Section IV. F, "Training" and 10 CFR 50.47(b)(15). Additional information aboutthe Emergency Plan training program will be found in the Emergency Plan, which is a separatedocument.3.4.3 Physical Security Training Program

NEI 06-13 states that training of security personnel will be discussed in FSAR Section 13.6,"Physical Security" and in the Physical Security Plan.3.4.4Station Management Training Program

NEI 06-13 states that station supervisors will receive Fitness for Duty training in accordancewith 10 CFR 26.22. The qualification requirements for managers and middle managers includetraining or experience in supervision or management. Training for supervisors develops theirskills in the following areas:

!Leadership

!Interpersonal communications

!Management responsibilities and limits

!Motivation of personnel

!Problem analysis and decision making

!Administrative policies and procedures

!Observation skills

!CoachingBased on the staff's review of the "Selected Other Training Programs" section of NEI 06-13outlined above (fire protection, emergency plan, physical security, and station managementtraining programs), the staff concludes that NEI 06-13 clearly and sufficiently describes, in terms of scope and level of detail, the training programs for fire protection, emergency plan,physical security, and station management training to enable a reasonable assurance finding of acceptability for issuance of a combined license with verification of the progr ams during theconstruction stage.3.5Training Effectiveness Evaluation ProgramNEI 06-13 states that the program to evaluate the effectiveness of training programs will bebased on three independent inputs: the supervisor of the trainee, the trainee, and aneducational content evaluation of the instructional techniques and materials.3.5.1Supervisory Review for Training Effectiveness The supervisory review will evaluate the content and effectiveness of training programs as related to the duties and job responsibilities of the trainees. Reviews may be performed by the supervisor of the trainee (former student) meeting with appropriate Training Department personnel, by designated oversight personnel (Quality Assurance or instructional technologists),or by observing employee performance in the job setting.Management observations of training will be discussed to deter mine topics that may requireadditional training or subjects that may be removed from the training program.3.5.2Trainee Review of Training Effectiveness Following selected courses or training cycles, trainees will have the opportunity to providecomments regarding the effectiveness of the instructional methods and content relevancy totheir jobs. These comments will used in the evaluation of both instruction and content of thetraining program.3.5.3Review for Effectiveness of Instructional Techniques and Materials The effectiveness of instructional techniques and materials review assesses the clarity andapplicability of training ma terial and instructional aids. Management observations of instructors in the teaching environment will be conducted by an educational specialist qualified to monitorand evaluate classroom performance. Full time instructors will receiv e basic indoc trination ininstructional techniques as soon as practicable after assuming instructional duties. Theeducational specialist w ill conduct periodic semi nars in instructional techniques, discussingareas where group performance could be improved and recommends innovative techniquesobserved at this or other power stations.Based on the staff's review of the "Training Effectiveness Evaluation Program" section ofNEI 06-13 outlined above, the staff concludes that NEI 06-13 clearly and sufficiently describes,in terms of scope and level of detail, the training effectiveness evaluation program to enable areasonable assurance finding of acceptability for issuance of a combined license withverification of the programs during the construction stage.

4.0CONCLUSION

Operator Licensing and Human Performance Branch (COLP) staff used the acceptance criteriaof SRP 13.2.1 and 13.2.2 as the basis for ev aluating the acceptability of NEI 06-13, "Templatefor an Industry Training Program Description," Revision 0. The COLP staff has determined thatNEI 06-13, "Template for an Industry Training Program," Revision 0 is consistent with thetraining and qualification requirements, guidance, and industry standards for licensed andnonlicensed plant staff as outlined in Section 2.0 of this evaluation with verification of theprograms during the construction stage.The training programs for licensed and nonlicensed plant staff described in NEI 06-13 will incorporate instru ctional requirements to qualify personnel to operate and maintain the facility,in a safe manner, in all modes of operation. The training programs will be developed andmaintained in compliance with the facility license and applicabl e regulations. The trainingprograms will be periodically evaluated and revised to reflect industry exper ience; to incorporatechanges to the facility, proc edures, regulations, and quality assuranc e requirem ents; and by management to determine overall program effectiveness. The training programs will be further described in site and/or corporate procedures. Sufficient records will be main tained and keptavailable for NRC inspection during construction to verify adequacy of the programs.The results of reviews of operating experience will be incorporat ed into the training andretraining programs in accordance with the provisions of TMI Action Item I.C.5, Appendix 1A. Training programs will encompass all phases of pl ant operation in cluding preoper ational testing and low-power operation in accordance with the provisions of TMI Action Item I.G. Sufficientplant staff will be trained prior to fuel load to provide for safe pl ant operations.The licensed operator tr aining program, to be derived using SAT principles, will be developedby the applicant and will meet the regulatory guidance of Regulatory Gui de 1.8 and 10 CFR Part 55. Licensed oper ators and senior operators will receive training in securityprocedures, radiological emergency plans, administrative procedures, and radiation protection. Simulation facilities used for the licensed operator training program will meet the guidance ofRegulatory Guide 1.149. The licensed operator requalification training program conforms to therequirements of 10 CFR Part 50 and 10 CFR 55.59 and follows the guidance inRegulatory Guide 1.8. Sufficient licensed operators will have comple ted the trai ning programprior to fuel load to ensure that the minimum shift staffing requirements of 10 CFR 50.54 will bemet. The licensed operator training program will be verified during the cons truction stage.In accordance with the requirements of 10 CFR 50.34(a) and (b), the applicant has providedinformation related to its training program for nonlicensed personnel. The training and retrainingof nonlicensed plant staff will meet the guidance of Regulatory Guide 1.8. The applicant has committed to establish, implement, and maintain training programs that will utilize a systemsapproach to training as required by 10 CFR 50.120 and as defined in 10 CFR 55.4. All initialtraining of the nonlicensed plant staff is scheduled to be completed prior to fuel loading. Training programs for personnel listed in 10 CFR 50.120 will be verifi ed during the constructionstage.The applicant will meet the requirements of 10 CFR 19 by developing and im plementing a training program that will inform and instruct personnel regarding radioactive materials andradiation, health protection problems associated with exposure to radiation, the means andresponsibilities for the protection of workers fr om radiation, and the availability upon request ofradiation exposure reports. The training program includes initial training and periodic retrainingfor categories of employees and nonemployees whose assistance may be needed in the eventof a radiological emergency. The GET program will be verified during the construction stage.The applicant will meet the requirements of 10 CFR Part 26 by having a trai ning program toensure that personnel are adequately informed regarding the fitness-for-duty policy. Supervisors and persons assigned to escort duties will be trained to ensur e that they understand their roles, re sponsibilities, and procedures for the fitness-for-duty program. Thefitness-for-duty training program will ensure supervisors and escorts will possess knowledgeand skills necessary to recognize behavioral changes, drugs, and/

or indications of the use ofdrugs. The fitness-for-duty training program will be verified duri ng the constr uction stage.

NEI 06-13 states that training will be provided based on individual employee ex perience, theintended position, and previous training and education of the individual. Training Departmentpersonnel may be supplemented by other personnel such as subject matter experts, contract staff, and vendor representatives. Formal instruction will be present ed through a co mbination ofclassroom lectures, e-learning, assigned reading, simulator training and evaluations, and otherdelivery techniques.On the basis of its review, the staff concludes that NEI 06-13, "Template for an Industry TrainingProgram," Revision 0 adequately provides guidance for establishing the licensed operator andnonlicensed plant staff training programs. Accordingly, the COLP staff concludes thatNEI 06-13, "Template for an Industry Training Program," Revision 0 complies with the applicable NRC regulations, guidance, and industry standards and can be utilized by applicants forcombined license applications.5.REFERENCES5.1Heymer, A. P., Nuclear Energy Institute, to the U.S. NRC, NEI 06-13, "Template for anIndustry Training Program Description," October 30, 2006.5.2NUREG-0800, "Standard Review Plan," Section 13.2.1, "Reactor Operator Training,"and Section 13.2.2, "Training for Nonlicensed Plant Staff" NEI New Reactors Mailing ListList #35 cc:Ms. Michele BoydEdward G. WallaceLegislative DirectorSr. General ManagerEnergy ProgramU.S. ProgramsPublic Citizens Critical Mass EnergyPBMR Pty. Ltd. and Environmental ProgramPO Box 16789215 Pennsylvania Avenue, SEChattanooga, TN 37416Washington, DC 20003 Mr. Gary Wright, DirectorMr. Marvin FertelDivision of Nuclear Facility Safety Senior Vice PresidentIllinois Emergency Management Agency and Chief Nuclear Officer1035 Outer Park DriveNuclear Energy InstituteSpringfield, IL 627041776 I Street, NW Suite 400Washington, DC 20006-3708 Ms. Leslie Compton KassSenior Project ManagerNuclear Energy Institute1776 I Street, N.W.Suite 400Washington, DC 20006-3708 Mr. Brian SmithNuclear Energy Institute1776 I Street, NW, Suite 400Washington, DC 20006 Mr. Ed WallaceGeneral Manager - ProjectsPBMR Pty LTDP. O. Box 9396Centurion 0046Republic of South Africa

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