June 18, 2007

MEMORANDUM TO: Darrell Roberts, Chief

Operator Licensing and Human Performance Branch

Division of Construction and Operational Programs

Office of New Reactors

FROM: Richard Pelton /RA/

Operator Licensing and Human Performance Branch

Division of Construction and Operational Programs

Office of New Reactors

SUBJECT: SUMMARY OF MAY 24, 2007, CATEGORY 2 PUBLIC MEETING WITH

THE NUCLEAR ENERGY INSTITUTE (NEI) TO DISCUSS NEW

REACTOR OPERATOR LICENSING INITIATIVES

On May 24, 2007, Nuclear Regulatory Commission (NRC) staff met with representatives of NEI,

industry representatives, and vendors in a public meeting at NRC headquarters in Rockville,

Maryland. Enclosure 1 provides a list of those in attendance and individuals who participated

via teleconference. Enclosure 2 is the meeting agenda. Information presented by NEI and

industry at the meeting is available in the NRC Agencywide Documents Access and

Management System (ADAMS) under Accession No. ML071450061.

The purpose of this meeting was to discuss issues related to NRC’s operator licensing program

for combined license applicants. Introductions of the persons attending the meeting were

conducted. The Director, Division of Construction and Operational Programs, Office of New

Reactors; the Deputy Director, Division of Inspection and Regional Support, Office of Nuclear

Reactor Regulation; and the Director, Operations Support, Nuclear Generation Division, NEI

followed with opening remarks.

An industry representative presented the industry proposal to use limited-scope simulators for

operator training because of the aggressive timelines leading to fuel loading. Plant-referenced

simulators are not projected to be available for reactivity manipulations and reactor start ups

until eighteen months prior to a fuel load. The industry still intends, however, to conduct actual

licensing exams on a plant-referenced simulator. Appendix D, “Guidance on Part-Task and

Limited-Scope Simulator Features and Fidelity,” of ANSI/ANS-3.5-1998, “Nuclear Power Plant

Simulators for Use in Operator Training and Examination” will be used to demonstrate the

limited-scope simulator possess a sufficient degree of completeness and accuracy when such

devices are used to satisfy operator training learning objectives. This will apply where use of a

systems approach to training methodology has determined that the use of a limited-scope

simulator is appropriate.

CONTACT: Richard Pelton, NRO/DCIP

 (301) 415-1028
D. Roberts -2-

Existing licensed operator eligibility requirements were discussed. During the discussion,

industry representatives highlighted the potential difficulty of meeting the current licensed

operator eligibility requirements for the licensed operator applicants expected for the first wave

of examinations. NEI proposed to have the industry develop alternative requirements that

leverage technology such as virtual reality. NEI also suggested that Regulatory Guide 1.8,

"Qualification and Training of Personnel for Nuclear Power Plants," be updated to address the

new construction conditions. It was noted that the National Academy for Nuclear Training

guidance for the initial training and qualification of licensed operators is in the process of being

modified and will include alternative eligibility guidance.

Anticipated problems with 'cold licensing' of operators were discussed. Cold license 

examinations are administered before completion of pre-operational and initial startup testing. 

The industry believes that instructors and training programs will need to be creative in providing

trainees with on-the-job training prior to a fuel load. Difficulties include conducting systems

training prior to construction of the systems, reactivity manipulations without a plant or plantreferenced simulator, and meeting operator experience guidance found in ANSI/ANS-3.1-1993,

"Selection, Qualification, and Training of Personnel for Nuclear Power Plants." The industry

expressed a strong desire to present a uniform industry approach and NEI stated a technical

paper will be developed and forwarded to the NRC through NEI.

Changes to NUREG 1122, “Knowledge and Abilities Catalog for Nuclear Power Plant

Operators: Pressurized Water Reactors” and NUREG 1123, “Knowledge and Abilities Catalog

for Nuclear Power Plant Operators: Boiling Water Reactors” (KA catalogs) may be necessary

after completion of the new reactor job analyses. Sections that may require changes at that

time include plant systems, emergency plant evolutions and abnormal plant evolutions. The

industry representative indicated that generic KAs would probably not need to be changed. An

NRC representative stated that the generic fundamentals portion of the KA catalog is 97%

applicable to the new reactors, needing primarily adjustment in the components area for digital

controls. Industry representatives stated those training materials will be developed as designs

advance and that benchmarking trips have been conducted to Japan, France, and to nonnuclear industries in the US.

NEI proposed, at the conceptual level, the topic of industry administered initial exams and

asked whether NRC would be receptive to further discussion on the topic. NEI proposed that

roles and responsibilities be changed in the Generic Fundamentals Examination (GFE) for all

reactor types and in the initial license examination process for new reactors. NEI specifically

proposed that (1) INPO be given “management” responsibility of the GFE and that (2) utilities

be allowed to develop, administer, and grade license examinations without any prior NRC

review or approval, and submit to NRC a package of results with the pass/fail

recommendations. At that time, the NRC would either agree with the recommendations to

issue an operator’s license or return the package to the facility for applicant reexamination. The

NRC raised questions regarding the reduced government role in the exam development

process, the qualifications and objectivity of the utility’s examination teams, the ability of the

licensee to independently author high quality examinations, the potential for examination

development biases, public confidence in the process, and the potential for significant resource

allocations necessary to effect such a change. The NRC discussed the problems encountered

in migrating to the 'industry prepared/NRC administered' examination model which is in use

today. The NRC mentioned, as an alternative, that further efficiencies in the NUREG 1021

licensing processes were possible and could be pursued. NEI further stated that it would
D. Roberts -3-

research how other agencies license operators, e.g., Canadian Nuclear Safety Commission,

Federal Aviation Administration, and Électricité de France.

In closing, NEI agreed to submit additional information pertaining to new plant experience

requirements, simulator training for new plants, cold licensing of operators, and additional

details on industry administered initial exams. NRC agreed to review the industry submittals. 

No final positions were taken during the meeting. Additional public meetings may be held after

NRC has reviewed the submittals being prepared by NEI.

Enclosure:

1. List of Attendees

2. Meeting Agenda

cc: w/all enclosures:

Service List
D. Roberts -3-

research how other agencies license operators, e.g., Canadian Nuclear Safety Commission,

Federal Aviation Administration, and Électricité de France.

In closing, NEI agreed to submit additional information pertaining to new plant experience

requirements, simulator training for new plants, cold licensing of operators, and additional

details on industry administered initial exams. NRC agreed to review the industry submittals. 

No final positions were taken during the meeting. Additional public meetings may be held after

NRC has reviewed the submittals being prepared by NEI.

Enclosure:

1. List of Attendees

2. Meeting Agenda

cc: w/all enclosures:

Service List

DISTRIBUTION:

PUBLIC COLP Reading File RidsNroOd

RidsNroDcip RidsNroDcipColp RidsNroDcipCtsb

RidsEDOMailCenter RidsOgcMailCenter RidsAcrsAcnwMailCenter

RidsNrrAdro NSalgado SGuenther

MSykes, RI PPresby, RI RAiello, RII

FEhrhardt, RII HPeterson, RIII KO’Donohue

SLynch (lynchs@gao.gov)

ADAMS Package Accession Number: ML071650266

Meeting Notice: ML071220329

Meeting Handout: ML071450061

Meeting Summary: ML071650262

Office DCIP/COLP DCIP/COLP

Name RPelton * DRoberts *

Date 06/18/2007 06/18/2007

Official Record Copy

* See previous concurrence.
Public Meeting with the Nuclear Energy Institute (NEI)

Discussion of New Reactor Operator Licensing Initiatives

May 24, 2007

Meeting Attendees

Name Organization

Glenn Tracy NRC

Stu Richards NRC

Gene Imbro NRC

Barry Westreich NRC

Darrell Roberts NRC

Nancy Salgado NRC

Michael Marshall NRC

Rick Pelton NRC

Fred Guenther NRC

Terry Beltz NRC

George Usova NRC

Mark Lintz NRC

Jim Bongarra NRC

Susan Uttal NRC

Brett Klukan NRC

Ron Aiello (per telcom) NRC

Frank Ehrhardt (per telcom) NRC

Kathleen O’Donohue (per telcom) NRC

Peter Presby (per telcom) NRC

Hironori Peterson (per telcom) NRC

Pedro Salas AREVA

Mark Paul Dominion

Charles Sawyer Duke Energy

William Shelly Entergy

Corey Goff Exelon

Julia Longfellow General Electric
Name Organization

Clair Goddard INPO

Michael Marler INPO 

Tony Harris NEI

Danny Johnson NEI 

Jack Roe NEI 

Chris Earls NEI 

Hamer Carter Progress Energy

Frank Quinn South Texas Project

Jim Calvert South Texas Project 

Ted Amundson Southern Nuclear

Gregg Ellis UNISTAR

Paul Hippely Westinghouse

Deann Raleigh Scientech

Sarah Lynch (per telcom) GAO
ENCLOSURE

AGENDA

FOR MEETING WITH INDUSTRY FOCUS GROUP (FG) ON

OPERATOR LICENSING ISSUES

MARCH 22, 2007

TOPIC LEAD

Introductions and Opening Remarks NRC/NEI

Public Input Public

New Plant Experience Requirements NEI

Simulator Training for New Plants NEI

Cold License Process NEI

Knowledge & Ability Catalogs NEI

Industry Administered Initial Exams NEI

Public Questions and Answers Public

Closing Remarks NRC/NEI
ENCLOSURE

 Nuclear Energy Institute

cc:

Mr. Anthony Pietrangelo, Senior Director

Risk Regulation

Nuclear Energy Institute

1776 I Street, NW, Suite 400

Washington, DC 20006-3708

Mr. H. A. Sepp, Manager

Regulatory and Licensing Engineering

Westinghouse Electric Company

P. O. Box 355 

Pittsburgh, PA 15230-0355

Mr. Jack Roe

Nuclear Energy Institute

1776 I Street, NW, Suite 400

Washington, DC 20006-3708

Mr. Charles B. Brinkman 

Washington Operations 

ABB-Combustion Engineering, Inc. 

12300 Twinbrook Parkway, Suite 330

Rockville, MD 20852

Mr. Gary L. Vine, Executive Director

Federal and Industry Activities, Nuclear

Sector

EPRI

2000 L Street, NW, Suite 805

Washington, DC 20036

Mr. Pedro Salas 

Regulatory Assurance Manager - Dresden

Exelon Generation Company, LLC

6500 N. Dresden Road

Morris, IL 60450-9765

Ms. Barbara Lewis

Assistant Editor

Platts, Principal Editorial Office

1200 G St., N.W., Suite 1100

Washington, DC 20005

Mr. Gary Welsh

Institute of 

 Nuclear Power Operations

Suite 100

700 Galleria Parkway, SE

Atlanta, GA 30339-5957

Mr. James H. Riley, Director

Engineering

Nuclear Energy Institute

1776 I Street, NW, Suite 400

Washington, DC 20006-3708