STANDARD REVIEW PLAN · 2020-05-16 · 1. Design Certification1 The DC review is focused on the...

Revision 3 - March 2007 Draft Revision 4 – August 2014

USNRC STANDARD REVIEW PLAN

This Standard Review Plan (SRP), NUREG-0800, has been prepared to establish criteria that the U.S. Nuclear Regulatory Commission (NRC) staff responsible for the review of applications to construct and operate nuclear power plants intends to use in evaluating whether an applicant/licensee meets the NRC regulations. The SRP is not a substitute for the NRC regulations, and compliance with it is not required. However, an applicant is required to identify differences between the design features, analytical techniques, and procedural measures proposed for its facility and the SRP acceptance criteria and evaluate how the proposed alternatives to the SRP acceptance criteria provide an acceptable method of complying with the NRC regulations. The SRP sections are numbered in accordance with corresponding sections in Regulatory Guide (RG) 1.70, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition)." Not all sections of RG 1.70 have a corresponding review plan section. The SRP sections applicable to a combined license application for a new light-water reactor (LWR) are based on RG 1.206, "Combined License Applications for Nuclear Power Plants (LWR Edition)." These documents are made available to the public as part of the NRC policy to inform the nuclear industry and the general public of regulatory procedures and policies. Individual sections of NUREG-0800 will be revised periodically, as appropriate, to accommodate comments and to reflect new information and experience. Comments may be submitted electronically by e-mail to [email protected] Requests for single copies of SRP sections (which may be reproduced) should be made to the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Reproduction and Distribution Services Section by fax to (301) 415-2289; or by email to [email protected]. Electronic copies of this section are available through the NRC public Web site at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/, or in the NRC Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession No. ML070100636 ML.13311B565.

NUREG-0800

U.S. NUCLEAR REGULATORY COMMISSION

STANDARD REVIEW PLAN

13.2.1 REACTOR OPERATOR REQUALIFICATION PROGRAM; REACTOR OPERATOR TRAINING

REVIEW RESPONSIBILITIES Primary - Organization responsible for the review of operator licensing Secondary - Organization responsible for the review of human performance Secondary - None I. AREAS OF REVIEW The applicant's licensed operatororganization responsible for the review of operator licensing reviews the operator training program, of applicants (e.g., for a construction permit (CP), an operating license (OL), a standard design certification (DC), or a combined license (COL)) as described in the safety analysis report (SAR), is reviewed.its technical submittal. This section of the SARtechnical submittal should contain the description and scheduling of the licensed operator training program for reactor operators and senior reactor operators. The licensed operator training program also includes the licensed operator requalification program as required in 10 CFR 50.54(i)(i-1) and 55.59. .

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The specificobjective of this review is to ensure that the proposed licensed operator training program description contains an adequate format, attributes, and level of detail, that the training program shall be able to provide qualified personnel to operate and to maintain the facility in a safe and efficient manner, as well as to keep the facility in compliance with its license, technical specifications, and applicable regulations. In addition, the review is to ensure that sufficient technical resources have been, are being, and will continue to be provided to adequately accomplish these objectives. The areas of review, based on the type of application, are as follows: 1. Design Certification1

The DC review is focused on the evaluation of combined-license action items pertaining to licensed operator training and requalification.

2. Construction Permit (CP) andor Combined License (

The CP/COL). The training program descriptions review is focused on the applicant’s licensed operator training program description. The licensed operator training program is to be established, implemented, and maintained 18 months prior to fuel load. The application includes the following:

a. A commitment to meet the guidelines of Regulatory Guide (RG) 1.8,

“Qualification and Training of Personnel for Nuclear Power Plants.” b. A commitment to meet the guidelines of RG 1.149, “Nuclear Power Plant

Simulation Facilities for Use in Operator Training and License Examinations," for its simulation facilities.

c. A commitment to conduct formal licensed operator classroom, on-the-job

training, and simulator training before and after initial fuel load. d. For COL applicants, a commitment to meet the guidelines of Nuclear Energy

Institute (NEI) 06-13A, “Template for an Industry Training Program Description.” e. The licensed operator training program description should contain the following

elements:

(i) A. A description of the proposed training program, including the The subject matter of each initial licensed operator training course, the.

(ii) The duration of the course (approximate number of weeks personnel are

in full-time attendance), the) of each licensed operator training course. (iii) The organization teaching the course or supervising instruction, and the

of each licensed operator training course, and the qualifications of the instructors and supervisors.

(iv) The titles of the positions for which theeach licensed operator training

course is given. The program descriptions should include aintended.

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Draft Revision 4 – August 2014

(i)(v) A chart showing the proposed schedule for licensing personnel prior to criticality. The schedule should be relative to the expected fuel loadingload date and should also display the preoperational test period. The submittal should contain a commitment to conduct formal licensed operator, on-the-job training, and simulator training before initial fuel load.

(vi) B. The To the extent applicable to the facility, the subjects covered in

the reactor operator training programs shouldprogram will include, as a minimum, the following:

(a) Fundamentals of reactor theory, including fission process, neutron

multiplication, source effects, control rod effects, criticality indications, reactivity coefficients, and poison effects.

(b) General design features of the core, including core structure, fuel

elements, control rods, core instrumentation, and coolant flow. (c) Mechanical components and design features of the reactor

primary system. (d) Secondary coolant and auxiliary systems that affect the facility. (e) Facility operating characteristics during steady-state and transient

conditions, including coolant chemistry, causes and effects of temperature, pressure and reactivity changes, effects of load changes, and operating limitations, and the reasons for these operating characteristics.

(f) Design, components, and functions of reactivity control

mechanisms and instrumentation. (g) Design, components, and functions of control and safety systems,

including instrumentation, signals, interlocks, failure modes, and automatic and manual features.

(h) Components, capacity, and functions of emergency systems. (i) Shielding, isolation, and containment design features, including

access limitations. (j) Administrative, normal, abnormal, and emergency operating

procedures for the facility. (k) Purpose and operation of radiation-monitoring systems, including

alarms and survey equipment. (l) Radiological safety principles and procedures. (m) Procedures and equipment available for handling and disposal of

radioactive materials and effluents.

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(n) Principles of heat transfer thermodynamics and fluid mechanics.

(vii) To the extent applicable to the facility, in addition to those subjects in 10 CFR 55.31, 55.41, 55.43, 55.45, and Regulatory Guide 1.8identified for reactor operators and (Section I.2.e.(vi)), the subjects in the senior reactor operators as appropriate. The operator training program should alsowill include provisionsthe following:

(a) Conditions and limitations in the facility license.

(b) Facility operating limitations in the technical specifications and

their bases. (c) Facility procedures required to obtain authority for

upgradingdesign and operating changes in the facility. (d) Radiation hazards that may arise during normal and abnormal

situations, including maintenance activities and various contamination conditions.

(e) Assessment of facility conditions and selection of appropriate

procedures during normal, abnormal, and emergency situations. (f) Procedures and limitations involved in initial core loading,

alterations in core configuration, control rod programming, and determination of various internal and external effects on core reactivity.

(g) Fuel-handling facilities and procedures.

(ii)(viii) To the extent applicable to the facility, reactor operator licenses and for licensingoperators and senior reactor operators who have not been licensed as reactor operators per Regulatory Guide 1.8. The training should be based on use of the systems approach to training (SAT) as defined in 10 CFR 55.4are required to demonstrate an understanding of and the ability to perform the following:

C. The licensed operator requalification program should include the content

described in 10 CFR 55.59 or should be based on the use of a systems approach to training as defined in 10 CFR 55.4.

D. Applicants should describe their program for providing simulator capability for

their plants as described in 10 CFR 55.31, 55.45, 55.46, 50.34(f)(2)(i), and Regulatory Guide 1.149. In addition, the applicant should describe how it will ensure that its proposed simulator will correctly model its control room. Applicants should submit, prior to issuance of construction permits or other submittals, a general discussion of how the requirements will be met. Sufficient details should be presented to provide reasonable assurance that the requirements will be implemented prior to the issuance of a license.

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E. The means for evaluating training program effectiveness for all licensed operators, in accordance with a systems approach to training.

F. For COL, applicants provide implementation milestones for the reactor operator

training program. 2. Operating License (OL) or COL holder - verification through the Construction Inspection

Program. The training program descriptions should include the following elements:

A. The licensed operator training program descriptions should delineate clearly the extent to which the training program was accomplished at the approximate time of submittal of the SAR. Contingency plans for additional training for individuals to be licensed prior to criticality should be described in the event fuel loading is subsequently delayed until after the date indicated in the SAR.

B. Reactor operations training using nuclear power plant simulation facilities shall

comply with Regulatory Guide 1.149. The applicant should provide the details of the program for simulator training, including length of time (weeks) and a description of the simulation facility as required by 10 CFR 55.45(b) and 55.46. The applicant should also provide details of the program to meet experience requirements for applicants for operator and senior operator licenses as required by 10 CFR 55.31 and 55.46.

C. The SAR should describe the applicant's plans for requalification training for

licensed operators and senior operators.

i. The subject matter of each course, including a syllabus or equivalent course description, the duration of the course (approximate number of weeks personnel are in full-time attendance), the organization teaching the course or supervising instruction, and the titles of the positions for which the course is given. The program should distinguish between classroom, on-the-job, and simulator training, before and after the initial fuel loading. It should include provisions for training on modifications to plant systems or functions. The organization teaching the course or supervising the instruction and the qualifications of the instructors in the training program should be provided.

(a) The subjects covered should include, as a minimum, those

contained in 10 CFR 55.41, 55.43, 55.45, and Regulatory Guide 1.8 for reactor operators and senior reactor operators as appropriate. The training program should also include provisionsPerformance of pre-startup procedures, including operating those controls associated with plant equipment that could affect reactivity.

(b) Manipulation of console controls as required to operate the facility

between shutdown and designated power levels. (c) Identification of annunciators and condition-indicating signals and,

where appropriate, performance of necessary remedial actions.

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(d) Identification of the instrumentation systems and a description the significance of the instrument reading.

(e) Safe control of the facility. (f) Performance of control manipulations to obtain desired operating

results during normal, abnormal, and emergency situations. (g) Safe operation of the facility’s heat-removal systems and

identification of the relationship of the proper operation of these systems to the operation of the facility.

(h) Safe operation of the facility’s auxiliary and emergency systems,

including operation of those controls associated with plant equipment that could affect reactivity or the release of radioactive materials to the environment.

(i) Demonstration or description of the use and function of the

facility’s radiation-monitoring systems, including fixed radiation monitors and alarms, portable survey instruments, and personnel monitoring equipment.

(j) Demonstration of knowledge of significant radiation hazards,

including permissible exposure levels and performance of the procedures necessary to reduce radiation levels and to minimize personnel exposure.

(k) Demonstration of knowledge of the facility emergency plan,

including the operator's or senior operator's responsibility to decide whether the plan should be executed, and knowledge of his assigned duties.

(l) Demonstration of knowledge and ability, as appropriate to the

assigned position, to assume the responsibilities associated with the safe operation of the facility.

(m) Demonstration of the ability to function within the control room

team, as appropriate to the assigned position, in such a way that the facility procedures are adhered to and that license limitations and amendments are not violated.

(iii)(ix) A description of the procedure for upgrading reactor operator licenses and

for licensing senior reactor operators who have not been previously licensed as reactor operators per Regulatory Guide 1.8. The training should be based on the use of SAT as defined in 10 CFR 55.4.

(x) iiA description of the procedures to meet licensed operator experience requirements.

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f. The licensed operator requalification program should must be conducted for a continuous period not to exceed two years and followed immediately by successive requalification programs.

(i) The requalification program must include preplanned lectures in those

areas where operator and senior operator examinations and operating experience indicate that emphasis is needed in the following subjects:

(a) Theory and principles of operation. (b) General and specific plant operating characteristics. (c) Plant instrumentation and control systems. (d) Plant protection systems. (e) Engineered safety systems. (f) Normal, abnormal, and emergency operating procedures. (a)(g) Radiation control and safety. (h) Technical the contentspecifications. (i) Applicable portions of Title 10 of the Code of Federal Regulations

(10 CFR), Chapter 1.

(ii) The requalification program must include on-the-job training so that each licensed operator of the facility manipulates the plant controls and each licensed senior operator either manipulates the controls or directs the activities of individuals during plant control manipulations during the term of the licensed operator's or senior operator's license. The control manipulations and plant evolutions will consist of the following control manipulations and plant evolutions: activities described in 10 CFR 55.59 or be (a) through (l) below must be performed annually. The remaining control manipulations and plant evolutions ((m) through (aa)) must be performed on a two-year cycle. The requalification program must contain a commitment that each operator will perform or participate in a combination of reactivity-control manipulations based on the availability of plant equipment and systems. Those control manipulations and plant evolutions that are not performed on the actual plant may be performed on the plant-referenced simulator. The use of a systems approach to training the technical specifications should be maximized during the simulator control manipulations. Senior operator licensees are credited with these activities if they directly control manipulations as defined in 10 CFR 55.4they are performed.

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Control manipulations and plant evolutions to be performed:

(a) Plant or reactor startups to include a range that reactivity feedback

from nuclear heat addition is noticeable and heatup rate is established.

(b) Plant shutdown. (c) Manual control of steam generators or feedwater or both during

startup and shutdown. (d) Boration or dilution during power operation. (e) Significant (≥10 percent) power changes in manual rod control or

recirculation flow. (f) Reactor power change of 10 percent or greater where load

change is performed with load limit control or where flux, temperature, or speed control is on manual (for high-temperature gas-cooled reactors (HTGR)).

(g) Loss of coolant, including:

(1) Significant PWR steam generator leaks.

(2) Inside and outside primary containment.

(3) Large and small, including leak-rate determination.

(4) Saturated reactor coolant response (PWR).

(h) Loss of instrument air (if simulated, plant specific).

(i) Loss of electrical power (or degraded power sources). (j) Loss of core coolant flow/natural circulation. (k) Loss of feedwater (normal and emergency). (l) Loss of service water, if required for safety. (m) Loss of shutdown cooling. (n) Loss of component cooling system or cooling to an individual

component. (o) Loss of normal feedwater or normal feedwater system failure. (p) Loss of condenser vacuum.

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(q) Loss of protective system channel. (r) Mispositioned control rod or rods (or rod drops). (s) Inability to drive control rods. (t) Conditions requiring use of emergency boration or standby liquid

control system. (u) Fuel cladding failure or high activity in reactor coolant or offgas. (v) Turbine or generator trip. (w) Malfunction of an automatic control system that affects reactivity. (x) Malfunction of reactor coolant pressure/volume control system.

(y) Reactor trip.

(z) Main steam line break (inside or outside containment).

(aa) Nuclear instrumentation failure.

(iii. The means for evaluating ) On-the-job training must ensure that:

(1) Each licensed operator and senior operator demonstrates

satisfactory understanding of the operation of the apparatus, the procedures and mechanisms associated with the Items I.2.(f)(ii)(a) through (aa) from Section I.2.

(2) Each licensed operator and senior operator is cognizant of facility

design changes, procedure changes, and facility license changes. (3) Each licensed operator and senior operator reviews the contents

of all abnormal and emergency procedures on a regularly scheduled basis.

(iv) To determine areas where retraining is needed, the requalification program must include (10 CFR 55.59):

(1) Annual operating tests. (2) Written examinations that provide a basis for determining operator

knowledge of the subjects covered in the requalification program,. (3) Systematic observation and evaluation of operator performance

and competency by supervisors or training staff, including evaluation of operator actions during actual or simulated implementation of abnormal and emergency procedures.

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(4) Operating conditions may be simulated using facility control

panels or the plant-referenced simulator. When facility control panels are used for the simulation, actual manipulation of the plant-controls is not required, and actions may be discussed.

(v) The requalification program must contain provisions for licensed operators to participate in an accelerated requalification program where performance evaluations conducted pursuant to Items I.2.(f)(iv)(1) through (4) from Section I.2 clearly indicate the need (10 CFR 55.59).

(vi) Per 10 CFR 55.59, the Rrequalification program documentation must

include:

(1) Records documenting the participation of each licensed operator and senior operator in the requalification program shall be maintained by the facility licensee. The facility licensee shall retain these records until the operator's or senior operator's license is renewed. The records to be retained include:

(a) Copies of written examinations administered,. (b) Answers provided by the licensed operator,. (c) Results of evaluations and documentation of operating

tests., (d) Any additional training administered in areas in which an

operator or senior operator has exhibited deficiencies.

(2) Records must be legible throughout the retention period. The record may be the original, a reproduced copy, or a microform, provided that the copy or microform is authenticated by authorized personnel and that the microform is capable of producing a clear copy throughout the retention period.

3. Operating License (Construction Permit holder) or Combined License Holder

For the OL applicant, during the later stages of plant design, construction, and licensing, the applicant should provide evidence that the initial licensed operator training program conforms to the commitments made in the CP stage of licensing. For COL holders, implementation of commitments made by the applicant during the COL application process will be evaluated as part of the Inspection Program. The OL/COL holder review is focused on the applicant’s detailed licensed operator training program description, which is verified as part of the Inspection Program. The licensed operator training program development process relies on review and feedback as an integral activity throughout program development and the

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implementation process. A system should be in place for periodically monitoring the program by individuals other than those directly responsible for providing the training. This monitoring includes an assessment of program effectiveness for all licensed operators, in accordance with SAT as defined in 10 CFR 55.4.in developing the trainees’ abilities to meet the performance requirements of the job. The program should be periodically updated, as appropriate, to reflect the results of program evaluations, industry experience, and changes to the facility, procedures, regulations, and quality requirements. In addition:

3. Design Certification. The development of training programs will be designated as a COL

action item. 4. COL Action Items and Certification Requirements and Restrictions. For . At a DC

application, the review will also address COL action items and requirements and restrictions (e.g., interface requirements and site parameters). minimum, the licensed operator training For a COL application referencing a DC, a COL applicant must address COL action items (referred to as COL license information in certain DCs) included in the referenced DC. Additionally, a COL applicant must address requirements and restrictions (e.g., interface requirements and site parameters) included in the referenced DC.

5. Operational Program Description and Implementation. For a COL application, the staff

reviews the Reactor Operator Requalification Program and the Reactor Operator Training Program program description and the proposed implementation milestones. The staff also reviews the final safety analysis report (FSAR) Table 13.x to ensure that the Reactor Operator Requalification Program and the Reactor Operator Training Program and associated milestones are included.

Review Interfaces

Other SRP sections interface with this section as follows: 1. For COL reviews of operational programs, the review of the applicant=s

implementation plan is performed under SRP contains the elements listed for CP/COL review in Section 13.4, AOperational [email protected].

b. At a minimum, the licensed operator initial training program description contains

the elements listed for CP/COL review in Section I.2. c. At a minimum, the licensed operator requalification training program description

contains the elements listed for CP/COL review in Section I.2.

II. REVIEW PROCEDURES The specific acceptance criteria and The review procedures described below are for the areas of review identified in Section I. The review procedures are contained in based on the acceptance criteria. For deviations from the acceptance criteria, the staff should review the applicant’s explanation describing the proposed alternatives to the referencedacceptance criteria and how the alternatives provide an acceptable method of complying with the relevant NRC requirements.

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In preparing to review the application, the reviewer should become familiar with the references for this SRP section. The application submitted is to be reviewed against this SRP section. The reviewer's evaluation is based on an inspection of the material presented in the application, on whether items of special safety significance are involved, and on the magnitude and uniqueness of the project. Any exceptions or alternatives presented in the application should be carefully reviewed to ensure that they are clearly defined and that an adequate basis for acceptance is provided.

II. The applicant will identify the references, RGs, and codes and standards revision numbers used in the application. The reviewer should identify the version of the references, RGs, and codes and standards used in the review. 1. In reviewing and evaluating the information related to the licensed operator training

program, the following points should be considered:

a. The applicant's plans for initial and requalification licensed operator training may not be fully developed and staffed. It is acceptable if these plans are not fully developed, provided that the applicant either makes an FSAR commitment or includes a license condition to ensure that the responsibility will be met. The licensed operator training program can be verified during the Inspection Program.

b. If the applicant has experience in the operation of a previously licensed nuclear

power plant, the reviewer may seek independent information about licensed operator training through the appropriate NRC regional office.

2. The review procedures for this section consist of the following:

a. An examination of the information submitted to determine that all areas identified in Section I, "Areas of Review," have been addressed.

b. A comparison of the information submitted with the acceptance criteria of Section

III, "Acceptance Criteria." c. A review of the information provided by the NRC regional office position

statement on the applicant’s licensed operator training program and commitments made in the SAR, if applicable.

d. Verification, through the Inspection Program, of the licensed operator training

and requalification program. Based on the procedures described above, the reviewer will determine the overall acceptability of the applicant's initial and requalification licensed operator training programs.


III. ACCEPTANCE CRITERIA Requirements 1. Acceptance criteria are based on meeting the relevant requirements of the following

Commission regulations: 1. General Guidance. The SAR should demonstrate that the training provided, or to be

provided, for reactor operators and senior reactor operators will be adequate to provide assurance that all reactor operator qualification requirement items will be met at the time needed, i.e., prior to operator license examinations, prior to fuel loading, or prior to appointment or reappointment to the position.

Criteria for acceptability, as they relate to licensed operator training and retraining programs, are:

A. The training and qualification requirements and guidance set forth in the following

regulations and regulatory guides should be met or acceptable alternatives should be presented:

• i. 10 CFR 50.54, items i through m34(a)(6) and (9)

ii. 10 CFR 55.4, 55.31, 55.41, 55.43, 55.45, 55.46 and 55.59

• 50.34(b)(6)(i), (ii), (iii. ), and (iv) • 10 CFR 50.34(f)(2)(i) • 10 CFR 50.40(a) and (b) • 10 CFR 50.54(a)(i-1) • 10 CFR 50.120(b)(1), (b)(2) and (b)(3) • 10 CFR 52.47(a)(7) • 10 CFR 52.79(a)(14), (33), (34), (39), (40) and (44) • 10 CFR 55.31(a)(4) and (5) • 10 CFR 55.41, Written Examination: Operators • 10 CFR 55.43, Written Examination: Senior Operators • 10 CFR 55.45, Operating Tests • 10 CFR 55.46, Simulation Facilities • 10 CFR 55.59, Requalification

The acceptance criteria are designed to meet 10 CFR 50.40(a) and (b) for all CP, OL, and COL reviews. As necessary for COL reviews, implementation of methods designed to meet the acceptance criteria may be verified through the Inspection Program.

Specific iv. Regulatory Guidecriteria are as follows:

a. The applicant has committed to RG 1.8, A"Qualification and Training of Personnel

for Nuclear Power Plants@.” RG 1.8 endorses American National Standards Institute (ANSI)/American Nuclear Society (ANS)-3.1-1993, “Selection, Qualification, and Training of Personnel for Nuclear Power Plants.”

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b. v. Regulatory GuideThe COL applicant has committed to NEI 06-13A, “Template for an Industry Training Program Description.” NEI 06-13A describes a training program that the staff has found is an acceptable example of a licensed operator training program.

c. The applicant has committed to RG 1.149, A“Nuclear Power Plant Simulation

Facilities for Use in Operator Training and License Examinations@." RG 1.149 endorses ANSI/ANS-3.5-1998, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.”

vi. NUREG-0711, AHuman Factors Engineering Program Review Model@

vii. NUREG-1021, AOperator Licensing Examination Standards for Power

Reactors@

B. Training programs d. Initial and requalification licensed operator training shall be developed, established, implemented, and maintained using a systems approach to training, as defined byin 10 CFR 55.4. Training program development will be evaluated by the staff using the guidance in NUREG-0711 and training program content, and effectiveness will be evaluated using NUREG-1220., “Definitions.”

C. Formal segments of the initial. e. For nuclear power plant license applicants, the technical submittal shall

demonstrate that a licensed operator training program should be substantially completed when the preoperational test program begins.

D. The number of persons trained in preparation for licensed operator and senior

operator licensing examinations prior to criticality should be sufficient to ensure that applicable regulatory requirements for shift staffing can be met from the time of initial fuel loading, with allowances for examination contingencies and the need to avoid planned overtime.

E. The licensed operator requalification training program should adequately

implement the requirements of 10 CFR 55.59. SRP Acceptance Criteria

will be Specific SRP acceptance criteria acceptable to meet the relevant requirements of the NRC=s regulations are identified within the Requirements section. The SRP is not a substitute for the NRC=s regulations, and compliance with it is not required. However, an applicant is required to identify differences between the design features, analytical techniques, and procedural measures proposed for its facility and the SRP acceptance criteria and evaluate how the proposed alternatives to the SRP acceptance criteria provide acceptable methods of compliance with the NRC regulations.

(b)(j) Operational Programs. For COL reviews, the description of the operational program and proposed implementation milestone for the Reactor Operator Requalification Program are reviewed in accordance with 10 CFR 50.34(b), 10 CFR 50.54(i), and 10 CFR 55.59. The implementation milestone is within 3 months after issuance of license or the date that the Commission makes the finding under 10 CFR 52.103(g) per 10 CFR 50.54(i-1). The

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description of the operational program for the Reactor Operator Training Program is reviewed in accordance with 10 CFR 55.13, 10 CFR 55.31, 10 CFR 55.41, 10 CFR 55.43, and 10 CFR 55.45. Its implementation is required by a license condition.

Technical Rationale The technical rationale for application of these acceptance criteria to the areas of review addressed by this SRP section is discussed in the following paragraphs: 1. Compliance with the relevant requirements of 10 CFR 50.54 items i through m requires

the licensee to have licensed operators or senior operators present at the controls and responsible for manipulation of the controls or directing the licensed activities of other licensed operators, as appropriate.

The reactor operator and senior reactor operator training programs, including initial and

requalification training, established by the applicant provide the , implemented, and maintained by 18 months prior to fuel load by means to train individuals in the knowledge, skills, and abilities needed to perform licensed operator duties. of the following:

(1) The applicant has described how the licensed operator training program

conforms to RG 1.8, “Qualification and Training of Personnel for Nuclear Power Plants.”

(2) The subjects covered in the licensed operator training program should

include, as a minimum, the subjects in 10 CFR 55.31, “How to Apply”; 10 CFR 55.41; 10 CFR 55.43; 10 CFR 55.45; and RG 1.8 for reactor operators and senior reactor operators, as appropriate.

(3) For COL reviews, the applicant has described how the licensed operator

training program conforms to NEI 06-13A, “Template for an Industry Training Program Description.”

For DC reviews, the development of licensed operator training program will be designated as a COL applicant action item.

f. The submittal shall demonstrate that a requalification program for operators and

senior operators that conforms to 10 CFR 55.59 will be in effect within 3 months of either the issuance of an OL or the date that the Commission makes the 10 CFR 52.103(g) finding.

g. A system is in place to periodically evaluate the licensed operator training

program by individuals other than those directly responsible for the training. This evaluation should include an assessment of program effectiveness in developing the trainees’ abilities to meet performance requirements of the job. The program should be periodically revised and updated, to reflect the results of program evaluations, industry experience, and changes to the facility, procedures, regulations, and quality requirements.

2. Review Interfaces

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Other SRP sections interface with this section as follows: a. Meeting these requirements provides assurance that only trainedThe structure,

functions, and qualified individuals will be licensedresponsibilities of the onsite organizations to operate and assigned to carry out or directmaintain the plant are reviewed in SRP Section 13.1.2, “Operating Organization.”

b. Addition guidance for identifying operational programs is provided in SRP,

Section 13.4, “Operational Programs.” c. Procedure adequacy is reviewed in SRP Section 13.5.1, “Administrative

Procedures” and SRP Section 13.5.2, “Operating and Emergency Operating Procedures.”

d. Human factors engineering practices and guidelines are evaluated in SRP

Section 18.0, “Human Factors Engineering.”

3. Technical Rationale Compliance with the relevant requirements of 10 CFR 50.34, “Contents of Applications;

Technical Information”; 10 CFR 50.40, “Common Standards”; 10 CFR 50.54, “Conditions of Licenses”; 10 CFR 50.120, “Training and Qualification of Nuclear Power Plant Personnel”; 10 CFR 55.31; 10 CFR 55.41; 10 CFR 55.43; 10 CFR 55.45; 10 CFR 55.46; and 10 CFR 55.59 requires the applicant to be technically qualified in order to engage in the personnel training activities, including manipulation of the controls and other activities affecting reactivity or associated with the design, construction, and operation of a nuclear power level.plant, in accordance with the regulations in 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”

2. Compliance with the relevant requirements of 10 CFR 52.47, “Contents of Applications;

Technical Information”; 10 CFR 52.79, “Contents of Applications; Technical Information in a Final Safety Analysis Report”; 10 CFR 55.4, 55.31,; 10 CFR 55.41,; 10 CFR 55.43, 10 CFR 55.45,; 10 CFR 55.46,; and 10 CFR 55.59 requires that the applicant to be technically qualified in order to engage in the personnel training activities associated with the design, construction, and operation of a nuclear power plant, in accordance with the regulations in 10 CFR Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants.”

Meeting the requirements of 10 CFR 50.34, 10 CFR 50.40, 10 CFR 50.54, 10 CFR

50.120, 10 CFR 52.47, 10 CFR 52.79, 10 CFR 55.31. 10 CFR 55.41, 10 CFR 55.43, 10 CFR 55.45, 10 CFR 55.46, and 10 CFR 55.59, as applicable, provides assurance that the applicant for an operator's license and for requalification successfully complete written and operating examinations which demonstrate that the applicant possesses the knowledge, skills, and abilities needed to performis technically qualified to engage in the proposed activities and has established the necessary licensed activitiesoperator training program to safely design, construct, operate, and maintain the facility.

13.2.1- 17 Revision 3 - March 2007


The reactor operator and senior reactor operator training programs, including initial and requalification training, established by the applicant provide the means to train individuals in the knowledge, skills, and abilities needed to perform licensed operator duties.

Meeting these requirements provides assurance that only trained and qualified licensed individuals possessing the required knowledge, skills, and abilities will be assigned to, and will conduct, licensed activities.

III. REVIEW PROCEDURES The reviewer will select material from the procedures described below, as may be appropriate for a particular case. These review procedures are based on the identified SRP acceptance criteria. For deviations from these acceptance criteria, the staff should review the applicant=s evaluation of how the proposed alternatives provide an acceptable method of complying with the relevant NRC requirements identified in Subsection II. 1. Preparation for the review of Section 13.2.1 of the SAR should include

familiarization with 10 CFR 50.54 items i through m; 10 CFR 55.4, 55.31, 55.41, 55.43, 55.45, 55.46, and 55.59; 10 CFR 50.34(f)(2)(i); Regulatory Guides 1.8 and 1.149; and NUREGs-0711 and -1021.

2. The reviewer then determines, based upon the foregoing, the

overall acceptability of the applicant's licensed operator training plans.

3. Operational Programs. The reviewer verifies that the Reactor Operator Requalification

Program and Reactor Operator Training Program are fully described and that implementation milestones have been identified. The reviewer verifies that the program and implementation milestones are included in FSAR Table 13.x. The implementation of the Reactor Operator Training Program is included in the license condition on operational programs and implementation.

Implementation of this program will be inspected in accordance with NRC Inspection Manual Chapter IMC-2504, "Construction Inspection Program - Non-ITAAC Inspections."

4. For review of a DC application, the reviewer should follow the above procedures to verify

that the design, including requirements and restrictions (e.g., interface requirements and site parameters), set forth in the final safety analysis report (FSAR) meets the acceptance criteria. DCs have referred to the FSAR as the design control document (DCD). The reviewer should also consider the appropriateness of identified COL action items. The reviewer may identify additional COL action items; however, to ensure these COL action items are addressed during a COL application, they should be added to the DC FSAR.

For review of a COL application, the scope of the review is dependent on whether the COL applicant references a DC, an early site permit (ESP) or other NRC approvals (e.g., manufacturing license, site suitability report or topical report).

13.2.1- 18 Revision 3 - March 2007


IV. EVALUATION FINDINGS The reviewer verifies that the applicant has provided sufficient information and that the staff’s technical review and calculations (if applicable)analysis support conclusions of the following type to be included in the staff's safety evaluation reportSafety Evaluation Report. The reviewer also states the bases for those conclusions. The applicant described the Reactor Operator Requalification Program and its

implementation in conformance with 10 CFR 50.34(b), 10 CFR 50.54(i), and 10 CFR 55.59. The applicant also described the Reactor Operator Requalification Program and its implementation is addressed through a license condition.

The staff concludes that the licensed operator training and requalification program for licensed operators and senior operators is acceptable and meets the requirements of 10 CFR 50.54 items i through m and34(b), 10 CFR 50.34(f), 10 CFR 50.54(i-1), 10 CFR 50.120, 10 CFR Sections 55.4, 52.79(a), 10 CFR 55.31,(a), 10 CFR 55.41, 10 CFR 55.43, 10 CFR 55.45, 10 CFR 55.46, and 10 CFR 55.59. This conclusion is based on the following: 1. For CP or COL. The overall conduct and administration of the licensed operator training

programs is the responsibility of the Plant Manager. The Training Manager is responsible for development, implementation, evaluation, and documentation of the licensed operator training programs.

1. Construction Permit or Combined License

The applicant stateshas stated that a training program will be established [for COL add: , in accordance with the implementation milestones] to provide licensed operators with sufficient knowledge and operating experience to start up, operate, shut down, and maintain the plant in a safe manner. The licensed operator training program, is derived from a systems approach to training, is to be developed by the applicant and will meetconform to the regulatory requirements of 10 CFR Part 55 and, for COL applicants, the guidance of Regulatory Guide 1.8.NEI 06-13A. Licensed operators and senior operators will receive the technical and administrative training required to operate the facility during normal, abnormal, and emergency conditions, as well as training in security procedures, radiological emergency plans, administrative procedures, and radiation protection., fire protection, and fitness for duty. Simulation facilities used for the licensed operator training program should meet shall meet 10 CFR 55.46 and be consistent with the guidance of Regulatory GuideRG 1.149., which endorses ANSI/ANS-3.5, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.” The information submitted relative to these subjects is satisfactory for the preoperational test program, for operator licensing, and for fuel loading.

2. For OLOperating License or COL holder - verification through the Construction

Inspection Program. The overall conduct and administrationCombined License

Verification of the licensed operator training program is the responsibility of the Plant Manager. The Training Manager is responsible for administering the licensed operator training program and monitoring program effectiveness. The applicant states that the licensed operator training program will provide reasonable assurance that decisions and

13.2.1- 19 Revision 3 - March 2007


actions by licensed operators and senior operators during all plant conditions will be made consistent with plant safety procedures and operational limits established to protectaccomplished through the public health and safety.Inspection Program by reviewing the items included in Section I.1. The licensed operator training program has beenis designed to meet the individual needs of the participants, depending upon their backgrounds, previous training, and expected job assignmentassignments. The program will meet the guidelines of Regulatory Guide 1.8 and 10 CFR Part 55. Simulation facilities used in theis derived from a systems approach to training program shall meet theand will conform to the regulatory requirements of 10 CFR 55.31, 55.45(b), 55.46, and 50.34(f)(2)(1), and the guidelines of Regulatory Guide 1.149. Over [state specific number provided by the licensee] candidates will have completed the entire training program prior to the fuel loading so that a sufficient number of licensed operators should be available to meet the requirements of 10 CFR 50.54.Part 55 and, for COL applicants, the guidance of NEI 06-13A. Simulation facilities used for the licensed operator training program shall meet 10 CFR 55.46 and be consistent with the guidance of RG 1.149, which endorses ANSI/ANS-3.5, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.”

The licensed operator requalification training program conforms to the requirements of 10 CFR Part 50 and50.54(i-1), 10 CFR 52.79(a)(34), 10 CFR 55.59 and follows, for COL applicants, the guidance in Regulatory Guide 1.8of NEI 06-13A.

3. For Design Certification.

For DC reviews, the findings will also summarize the staff=sstaff’s evaluation of COL action items relevant to this SRP section.

V. IMPLEMENTATION The staff will use this SRP section in performing safety evaluations of DC applications and license applications submitted by applicants pursuant to 10 CFR Part 50 or 10 CFR Part 52. Except when the applicant proposes an acceptable alternative method for complying with specified portions of the Commission=sCommission’s regulations, the staff will use the method described herein to evaluate conformance with Commission regulations. The provisions of this SRP section apply to reviews of applications submitted 6 months or more after the date of issuance of this SRP section, unless superseded by a later revision. Implementation schedules for conformance to parts of the review plan discussed herein are contained in the referenced regulatory guides and NUREGSNUREGs. VI. REFERENCES 1. 1. 10 CFR Part 19, “Notices, Instructions, and Reports to Workers: Inspection and

Investigations.” 2. 10 CFR Part 26, “Fitness for Duty Programs.” 1.3. 10 CFR Part 50, A“Licensing of Production and Utilization Facilities.@.”

13.2.1- 20 Revision 3 - March 2007


4. 2. 10 CFR Part 50, Appendix E, “Emergency Planning and Preparedness for Production and Utilization Facilities.”

2.5. 10 CFR Part 52, AEarly Site Permits; Standard Design “Licenses, Certifications;, and

Combined LicensesApprovals for Nuclear Power Plants.@,.” 3.6. 3. 10 CFR Part 55, AOperators=“Operators’ Licenses.@.”

7. 4. Regulatory GuideANSI/ANS-3.5, “Nuclear Power Plant Simulators for Use in

Operator Training and Examination.” 8. ISG, DC/COL-ISG-011, “Finalizing Licensing-Basis Information.” 9. ISG, DC/COL-ISG-015, “Post-Combined License Commitments.” 10. NEI 06-13A, “Template for an Industry Training Program Description.” 11. NRC Inspection Manual Chapter IMC-2504, “Construction Inspection Program –

Inspection of Construction and Operational Programs,” October 15, 2009.

12. NUREG-0711, “Human Factors Engineering Program Review Model.”

13. NUREG-0718, "Licensing Requirements for Pending Applications for Construction Permits and Manufacturing License."

14. NUREG-1021, “Operator Licensing Examination Standards for Power Reactors.” 15. NUREG-1220, “Training Review Criteria and Procedures.” 16. NUREG-0737 and Supplement 1, “Clarification of TMI Action Plan requirements.” 11.17. RG 1.8, "Qualification and Training of Personnel for Nuclear Power Plants.@.” 12.18. 5. Regulatory GuideRG 1.149, A“Nuclear Power Plant Simulation Facilities for Use

in Operator Training and License Examinations."

6. NUREG-0711, AHuman Factors Engineering Program Review Model.@

13.19. 7. NUREG-1021, AOperator Licensing Examination StandardsRG 1.189, “Fire Protection for Nuclear Power Reactors.@Plants.”

20. RG 1.206, "Combined License Applications for Nuclear Power Plants (LWR Edition).”

Formatted: Indent: Hanging: 0.5", Numbered+ Level: 1 + Numbering Style: 1, 2, 3, … +Start at: 8 + Alignment: Left + Aligned at: 0.25" + Indent at: 0.5"











PAPERWORK REDUCTION ACT STATEMENT

The information collections contained in the draft Standard Review Plan are covered by the requirements of 10 CFR Part 50 and 10

CFR Part 52, and were approved by the Office of Management and Budget, approval number 3150-0011 and 3150-0151.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information

collection requirement unless the requesting document displays a currently valid OMB control number.


SRP Section 13.2.1

Description of Changes

Section 13.2.1 – Reactor Operator Requalification Program; Reactor Operator Training

This revision of SRP Section 13.2.1 has been restructured and reorganized to clarify staff guidance. To this end, while this guidance has been significantly revised, it does not contain new staff positions. A listing of detailed changes to this section from its previous revision has thus been omitted.

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