Partitioning the 6-month onsite requirement

[NucEng for Hire]

To meet a 6 month onsite requirement for external license candidates, can anyone offer insight as to whether it is permissible to start the class with GFE & systems after 4 months onsite, recess to work a refueling outage for 2 months, and then resume the class with startup training? Do any of the guides address this potentiality (or definitively rule it out?)

[M1Ark]

Tried by my plant in Region 2.  everyone arrived on site at different times over the course of 4 months and the class was started (GFE).  The original idea was to get the class and license over with (18 months) and satisfy the remainder of the 6 month requirement at the end.  The idea was that we would pass our final NRC exam and the NRC would hold our license at the region until each of us satisfied the 6 months. A waiver was submitted to the NRC while we were in GFE.  The NRC denied our waiver request and stopped our GFE class.  We were close enough to completion that they allowed us to take the GFE exam.  They then started our 6 month clock from scratch again and restarted the class beginning with systems training.

A different outcome occurred at another region 2 plant.  They did everything I described except they didn't file their waiver until their class had completed their training and the waiver was submitted as part of the license application.  Their waiver was granted but was chastised by the region.

In short... you cannot be formally enrolled in a license program until you entry requirements are met (6 months onsite and education and/or experience requirements).

2.8 Section 4.4.1, Operations Shift Supervisor, and Section 4.4.2, Senior Operator

A nonlicensed applicant (an instant candidate) for a senior operator (SO) license should have three years of responsible nuclear power plant experience. A maximum of one year of responsible nuclear power plant experience may be fulfilled by academic or related technical training on a one-for-one basis. At least six months of the responsible nuclear power plant experience should be at the plant for which the instant candidate seeks a license and should not include any of the time spent in the control room as an extra person on shift. The education equivalence and the six months on site may also count toward the three years of responsible nuclear power plant experience. Applicants for an SO position who do not hold a bachelor's degree in engineering or the equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least one year or have at least two years of military experience in a position equivalent to a licensed reactor operator. Eligibility for equipment operators and non-degreed licensed operator instructors to sit for SO examinations will be evaluated on a case-by-case basis.

Source: NRC.Gov - Reg. Guide 1.8

http://www.nrc.gov/reading-rm/doc-collections/reg-guides/power-reactors/active/01-008/

M1Ark

[NucEng for Hire]

Thanks M1Ark.

Entergy's River Bend Station will attempt to do just that, having received the green light to staff up the ranks in Ops as rapidly as possible as we try to move to 6 crews. I guess we'll soon find out what Region IV thinks about the waiver attempts. We have been authorized to start a 22-person nonlicensed operator class in February (huge for a single unit site), and HR is willing to talk to anyone that can pass a POSS and wants to relocate (paid) to Baton Rouge. Any ex-Navy nukes in that class will have a bevy of fast track opportunities as well. A good time to be in commercial nuclear power....

[Fermi2]

My plant did exactly as NucEng described. They overlooked the 6 Month requirement all the all the region told them was so long as I wasn't enrolled for any period totalling 6 months I was good. If I took the examination and my 6 months wasn't complete they'd merely hold my license until it was complete. They honestly could care less how you obtain it so long as you are not officially enrolled in class when you do it. My 6 months has included 2 refueling outages, vacations, times when my class has stopped. Whenever I've gone to my outage job I've been disenrolled from the course. I performed my NLO Cards while doing 2 months of staff work during a class break.

We've gotten a LOT better now at my plant. Now its more regimented with documenting exact hours worked and what was worked on during the 6 months.

The NRC doesn't really care how you get the 6 months so long as you have a mechanism to document it and you make sure you follow the mechanism. Reg Guides are not Regs, you can always present an alternative means to follow them.

Mike

[M1Ark]

What I said is true. 


Sounds like it depends on the plant and region and maybe examiner.