ML23118A075
| ML23118A075 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 04/30/2023 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23118A071 | List: |
| References | |
| Download: ML23118A075 (1) | |
Text
© NEI 2023. All rights reserved.
Change to Education Requirement for Cold License Training for Direct SRO Candidates Although NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, is based on the guidance found in NEI 06-13A, Appendix A, Cold License Training Plan, it does deviate in one specific area: the educational requirements for eligibility of Direct Senior Reactor Operators (SROs) who are seeking eligibility based on educational background, instead of becoming eligible based on previous work experience.
Currently, eligibility for SRO candidates to enter a training program and hold an SRO license in the existing fleet is established by any of these four ways:
RO upgrade candidates from within the organization RO experience at other commercial or military reactors Certified SRO instructors 4-year Bachelor of Science Engineering Degree (or equivalent) plus sufficient responsible nuclear power plant experience During cold licensing, candidates are not able to use (or gain) experience from plant operations, because the facility is still under construction. Changes are made to the existing hot plant guidance to develop site specific experience using alternative methods. In a similar fashion to the methods found in NEI 06-13A, NEI 23-01 is proposing alternatives to the requirements to enter the training program. The overall goal is to ensure sufficient high-quality candidates are available to start the training. An additional consideration is to ensure that a pipeline is developed to retain and re-train viable candidates from retiring coal power plants already residing where the next generation of nuclear power plants are likely to be built.
NEI 23-01 proposes a high school diploma as opposed to a Bachelor of Science degree in engineering or science for the minimum educational requirements to qualify for entering the training program as a Direct SRO candidate, for those candidates that qualify solely on educational background. While this does constitute a reduction in the overall entry level criteria, there is no corresponding reduction in the final requirements needed to become licensed as an SRO. Each successful candidate must still pass a Systematic Approach to Training (SAT) based Operator training program that has been certified by the NRC or INPO. They must also successfully pass the final NRC Operator License Exam to become SRO license holders.
It is also important to note that each CP/COL holder (plant operator) will employ their own internal hiring criteria to candidates for a licensed operator training program. Typically, in addition to rigorous interviews and background checks, plants also use aptitude tests as a screening requirement as part of their hiring process. These practices would continue to be performed because, ultimately, the plant owner is also deeply invested in only having the highest quality operators staffing their control rooms.
Engineering expertise is obviously a highly desirable skill for control room operators to have. While engineering expertise can be gained from knowledge gained in a college classroom, the fields of study
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© NEI 2023. All rights reserved.
and degree requirements differ between scholastic institutes. The basis of the path proposed within NEI 23-01 is that there are other, more germane, methods to teach the engineering expertise that is most relevant to operating a commercial power plant.
Specifically, the upgrades to the industry training programs that came about, and are required as part of NUREG-0737, Clarification of TMI Actions Plan Requirements, provides relevant engineering expertise.
While college degrees in the engineering and science areas can be assumed to teach engineering expertise, the only way to assure that the expertise that has specific relevance to the operation of nuclear power plants is to teach it within the Operator training programs at the power plants. By including this, appropriate oversight of this important element now also falls within the scope of NRC monitoring and governance. In addition, this training would already be required training elements for any CP/COL holder. The applicants licensed Operator training programs for the plant include the following attributes and items:
Were developed using a systems approach to training, as described in 10 CFR Part 55 Include the math, physics, thermodynamics, and component design topics that are of specific relevance to the operation of a nuclear power plant i.e., GFES training. The amount and style of mathematical training provided by various academic bodies varies widely from institute to institute. It has been concluded that the mathematics needed for achieving mastery of an initial operator training program is that engineering mathematics needed to complete the standard industry generic fundamentals training as described in NUREG-0737.
Include training for mitigating core damage Include plant or design specific training, specifically:
plant systems plant or design specific reactor technology (including core physics data) plant chemistry and corrosion control reactor plant materials reactor plant thermal cycle transient/accident analysis emergency procedures It is important to note that, from this list, only a site specific commercial nuclear power plant training program would be guaranteed to include all these elements. The mitigating core damage, plant systems, specific reactor technology (including core physics data), transient and accident analysis, and emergency operating procedure training could ONLY be acquired at a plant or design specific training program.
Additionally, these industry training programs also ensure that knowledge transfer occurs from Operating Experience (OE) at the site and from around the industry. This use of OE can only be found within the training programs at the nuclear facilities.
The approach used by the training programs of the U.S. Navy for nuclear plant operators provides good empirical data supporting why NEI feels that the change will be successful. With only a high school
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© NEI 2023. All rights reserved.
diploma required to join the Navy and participate in the Navys Nuclear Propulsion School, they have been turning out qualified nuclear plant Operators for decades.
The 1989 Commission Policy Statement on the Conduct of Nuclear Power Plant Operations indicated that it is the Commissions expectation that control room individuals have a mix of education, training, and experience in plant operations. The approach described above, and in NEI 23-01, broadens the pool of potential candidates. This change would continue to ensure that the control room individuals are well trained and ready to handle both the normal and off-normal operation of a nuclear power plant.
Since the 1989 Policy Statement, Operations training programs have continued to evolve. They now routinely include scientific and engineering fundamentals along with the basic scientific principles that govern the behavior of the plant systems. This academic training, along with experience requirements, ensures that the operators that pass the initial license training programs have the proper background and training to operate the plants safely and reliably through all modes of operation. The impact of these changes is resulting in bringing safer and more reliable nuclear power generation to the market at a time when it is needed the most.