DCL-19-017, Request for Exemption from Operator Written Examination and Operating Test

Request for Exemption from Operator Written Examination and Operating Test

ML19084A285
Person / Time
Site:	Diablo Canyon
Issue date:	03/07/2019
From:	Welsch J Pacific Gas & Electric Co
To:	Ho Nieh Office of Nuclear Reactor Regulation
References
PG&E Letter DCL-19-017
Download: ML19084A285 (14)

Text

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• II Pacific Gas and Electric Company"'

James M. Welsch Vice President Nuclear Generation and Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 Chief Nuclear Officer 805.545.3242 E.*Mail: James.Welsch@p~e.com March 7, 2019 PG&E Letter DCL-19-017 Ho Nieh, Director 10 CFR 55.11 Office of Nuclear Reactor Regulation 10 CFR 55.31(a)(3)

U.S. Nuclear Regulatory Commission 10 CFR 55.33(a)(2)

Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Request for Exemption from Operator Written Examination and Operating Test

Dear Mr. Nieh:

Pursuant to 10 CFR 55.11, "Specific Exemptions," Pacific Gas and Electric Company (PG&E) requests, on behalf of the former senior reactor operator (SRO) license candidate identified in Enclosure 2, an exemption from the requirement of 10 CFR 55.33(a)(2), "Written examination and operating test." Passing the requisite written examination and operating test is a requirement for approval of an initial application for a license as specified in 10 CFR 55.33, "Disposition of an initial application." An exemption from 10 CFR 55.31 (a)(3) is also requested on behalf of the candidate. The requirement involves submitting "a written request from an authorized representative of the facility licensee by which the applicant will be employed that the written examination and operating test be administered to the applicant.,;

In early 2018, while previously employed by PG&E, the SRO license candt~te successfully passed the written examination (administered on February 9, 2018) and operating test (administered January 22-26, 2018) for Diablo Canyon Power Plant (DCPP), Units 1 and 2. The individual subsequently resigned from PG&E, on February 16, 2018. He was then rehired by PG&E at DCPP on August 6, 2018.

Upon return to DCPP, the individual successfully completed "Additional Training" under 10 CFR 55.59(b) and a facility-prepared written examination and operating test, which ensure that he is up to date in the licensed operator requalification training program; including generic fundamentals examination topics.

A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

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Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Mr. Ho Nieh PG&E Letter DCL-19-017 March 7, 2019 Page2 In addition, upon his return the individual was enrolled and remains in the DCPP licensed operator continuing training program, which is based on the requirements defined in 10 CFR Part 55 and is accredited through the National Academy for Nuclear Training. He has made up for the training he missed during the approximately six months that he was not with PG&E; therefore, his knowledge and training level is commensurate with that of the individuals in his license class to date.

The continuing training program uses a systematic approach to training to maintain operator proficiency for the major subject areas and topics that define the reactor operator and SRO qualification programs. Enrollment in and passing of the continuing training program ensures operator license candidate knowledge retention is consistent with standards established in NRC regulations and NUREG-1021, "Operator Licensing Examination Standards for Power Reactors."

The individual's health was additionally recertified by a physician on October 24, 2018 (see NRC Form 396, dated October 29, 2018, and submitted under PG&E Letter DCL-18-099, dated November 15, 2018).

Therefore, in lieu of the requirements of 10 CFR 55.33(a)(2) and 10 CFR 55.31 (a)(3), the individual wishes to have his existing written examination and operating test pass results (Enclosure 2) recognized for purposes of the issuance of an SRO license for DCPP Units 1 and 21 in accordance with 10 CFR 55.33, "Disposition of an initial application."

The exemption would facilitate the licensing of this trained and qualified SRO license candidate without the duplicative effort, time, and expense that would be incurred by both the NRC and PG&E to re-administer the SRO written examination and operating test for this individual.

This exemption request is analogous to one submitted by Southern Nuclear Operating Company (SNC) on December 20, 2018 (ADAMS Accession No. ML19030A226). The SNC submittal requested exemption from the same two provisions of 10 CFR Part 55 to allow recognition of test pass letters for 12 licensed operator candidates from Virgil C. Summer Nuclear Station Unit 2 for purposes of licensing at Vogtle Electric Generating Plant Unit 3.

1 Note that the NRC did issue an SRO license for the individual with an effective date of March 8, 2018. This was after the individual had left PG&E and the license was therefore expired at issuance in accordance with 10 CFR 55.55, "Expiration."

A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek Enclosure 2 Contains Personally Identifiable Information - Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is deco,atrolled.

Mr. Ho Nieh PG&E Letter DCL-19-017 March 7, 2019 Page3 presents the detailed basis for the exemption request. Enclosure 2 is a copy of the candidate's written examination and operating test pass documentation.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

PG&E requests NRC staff approval of the requested exemption by early June 2019.

If the NRC requires additional information regarding this matter, please contact Mr. Adam Peck, Director, Operations Services, at 805-545-6675.

Sincerely,

~MM~

James M. Welsch Vice President Nuclear Generation and Chief Nuclear Officer jmsp/4927 Enclosures cc: Scott A. Morris, NRC Region IV Administrator-Christopher W. Newport, NRC Senior Resident Inspector Balwant K. Singal, NRC Senior Project Manager Diablo Distribution A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this enclosure is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 Enclosure 1 Request for Exemption from Operator Written Examination and Operating Test

('

Page 1 of 11 Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this enclosure is decontrolled.

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Enclosure 1 PG&E Letter DCL-19-017 1.0 Summ.ary Description Pursuant to 10 CFR 55.11, "Specific Exemptions," Pacific Gas and Electric Company (PG&E) requests, on behalf of the former Diablo Canyon Power Plant (DCPP) senior reactor operator (SRO) license candidate identified in Enclosure 2, an exemption from the requirements of:

(1) 10 CFR 55.33(a)(2), "Written examination and operating test"; and (2) 10 CFR 55.31 (a)(3), which requires submitting "a written request from an.

authorized representative of the facility licensee by which the applicant will be employed that the written examination and operating test be administered to the applicant."

In lieu of these requirements, the individual wishes to have his existing written examination and operating test pass results recognized for purposes of the issuance of an SRO license now,! for DCPP Units 1 and 2, in accordance with 10 CFR 55.33, "Disposition of an initial application."

2.0 Detailed Description Passing the requisite written examination and operating test is a requirement for approval of an initial application for a license as specified .in 10 CFR 55.33, "Disposition of an initial application." 10 CFR 55.33(a)(2) states, in part,

"[t]hese examinations and tests determine whether the applicant for an operator's license has learned to operate a facility competently and safely, and additionally, in the case of a senior operator, whether the applicant has learned to direct the licensed activities of licensed operators competently and safely." Written tests for reactor operators and SROs contain a representative selection of knowledge, skills, and abilities needed to perform the operator's respective duties. Representative samples of items to be tested on a written exam, for reactor operators and SROs, are provided in 10 CFR 55.41 and 10 CFR 55.43, respectively. Operating tests require the applicants to demonstrate an understanding of and the ability to perform the actions necessary to accomplish their duties. A representative sample of items to be tested d~.iring the operating tests is provided in 10 CFR 55.45._

1 Note that the NRC did issue an SRO license for the individual with an effective date of March 8, 2018. This was after the individual had left PG&E and the license was therefore expired at issuance in accordance with 10 CFR 55.55, "Expir~tion."

Page 2 of 11

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Enclosure 2 Contains Personally Identifiable Information - Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 In early 2018, while previously employed by PG&E, the SRO license candidate identified in Enclosure 2 successfully completed the written examination (administered on February 9, 2018) and operating test (administered January 22-26, 2018) for DCPP Units 1 and 2. The individual subsequently resigned from PG&E, on February 16, 2018. He was then rehired by PG&E at DGPP on August 6, 2018.

Upon his return to DGPP, the individual was enrolled in the station's Systematic Approach to Training (SAT) based continuing training program and has made up for the training he missed while outside of PG&E's employment. The individual's health was additionally recertified by a physician on October 24, 2018 (see NRG Form 396, dated October 29, 2018, and submitted under PG&E Letter DGL-18-099 dated November 15, 2018).

See Section 4.0 below for a fuller discussion.

• Based on the above-Le., the existing written examination and operating test pass results, the subsequent training activities, and the health recertification-in lieu of the requirements of 10 GFR 55.33(a)(2) and 10 GFR 55.31 (a)(3), the individual wishes to have his existing written examination and operating test pass documentation (Enclosure 2) recognized for purposes of SRO license issuance now, for DCPP Units 1 and 2, in accordance with 10 GFR 55.33, "Disposition of an initial application."

• The exemption would facilitate the licensing of this trained and qualified SRO license candidate without the duplic~tive effort, time, and expense that would be incurred by both the NRG and PG&E to re-administer the SRO written examination and operating test to the individual.

3.0 Applicable Regulatory Requirements I

• This section provides a summary of regulations applicable to this exemption request.

3.1 Atomic Energy Act of 1954, as amended (42 U.S.G. 2137)

Section 107, "Operators' Licenses," states, in part, that:

The Commission shall-

a. prescribe uniform conditions for licensing individuals as operators of any of the various classes of production and utilization facilities licensed in this Act; Page 3 of 11 Enclosu11re 2 Co1111tains Personally Identifiable Information - Withhold Under 10 CFR 2.390 When sepall'ated fll'om Enclosure 2, this cover letter is decontroUed.

Enc!osuiire 2 Coll'lltains lfl>ersona!iy identifiable il!llformaition -Withhoid lJlinider 10 CIFIR 2.390.

Wlh!en separated fmm E111c!os1u11re 2, this cover iette1r is decontiroiled.

Enclosure 1 PG&E Letter DCL-19-017

b. determine the qualifications of such individuals 3.2 10 CFR Part 55, "Operators' Licenses" Section 55.31, "How to apply," states, in part, that:

(a) The applicant shall:

(3) Submit a written request from an authorized representative of the facility licensee by which the applicant will be employed that the*

• written examination and operating test be administered to the applicant; Section 55.33, "Disposition of an initial application," states, in part, that:

(a) Requirements for the approval of an initial application. The Commission will approve an initial application for a license pursuant to the regulations in this part, if it finds that -

(2) Written examination and operating test. The applicant has passed the requisite written examination and operating test in accordance with§§ 55.41 and 55.45 or 55.43 ahd 55.45. These examinations and tests determine whether the applicant for an operator's license has learned to operate a facility competently and safely, and additionally, in the case of a senior operator, whether the applicant has learned to direct the licensed activities of licensed operators competently and safely.

Section 55.40, "Implementation," states, in part, that:

(a) ... The Commission shall also use the criteria in NUREG-1021 to evaluate the written examinations and operating tests prepared by power reactor facility licensees pursuant to paragraph (b) of this section.

(b) Power reactor facility licensees may prepare, proctor, and grade the written examinations required by§§ 55.41 and 55.43 and may prepare the operating tests required by§ 55.45, subject to the following conditions:

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,Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 (1) Power reactor facility licensees shall prepare the required examinations and tests in accordance with the criteria in NUREG-1021 as described in paragraph (a) of this section; (4) Power reactor facility licensees must receive Commission approval of their proposed written examinations and operating tests.

3.3 NUREG-1021, Revision 11, "Operator Licensing Examination Standards for Power Reactors. Final Report" ES-201, "Initial Operator Licensing Examination Process," Section B, "Background," states, in part, that:

Title 10 of the Code of Federal Regulations (10 CFR) Part 55, "Operators' Licenses," requires that applicants for reactor operator (RO) and senior reactor operator (SRO) licenses must pass both a written examination and an operating test. The regulation at 10 CFR 55.40(b) allows power reactor facility licensees to prepare the site-specific written examinations and operating tests provided that (1) the facility licensee shall prepare the examinations and tests in accordance with the criteria contained in this NUREG, (2) the facility licensee shall establish, implement, and maintain procedures to control examination security and integrity, (3) an authorized representative of the facility licensee shall approve the examinations and tests before they are submitted to the NRG for review and approval, and (4) the facility licensee shall obtain NRG approval of its proposed written examinations and operating tests. The regulation requires that the license examinations must be developed and administered in accordance with 10 CFR 55.41, "Written Examination: Operators," and 10 CFR 55.45, "Operating Tests," for ROs, or 10 CFR 55.43, "Written Examination:

Senior Operators," and 10 CFR 55.45 for SROs.

ES-202, "Preparing and Reviewing Operator Licensing Applications,"

Section B, "Background," states, in part, that:

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 55.31(a)(4), an applicant shall do the following:

Provide evidence that the applicant has successfully completed the facility licensee's requirements to be licensed as an operator or senior operator and of the facility licensee's need for an operator or a senior operator to perform assigned Page 5 of 11 Contains Personally Identifiable Information-Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

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Enclosure 1 PG&E Letter DCL-19-017 duties. An authorized representative of the facility licensee shall certify this evidence on Form NRC-398 .. This certification must include details of the applicant's qualifications, and details on courses of instruction administered by the facility licensee, and describe the nature of the training received at the facility, and the startup and shutdown experience received.

In lieu of these details, the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based on a systems approach to training [SAT] and that uses a simulation facility acceptable to the Commission under [10 CFR 55.45(b)].

ES-301, "Preparing Initial Operating Tests," Section B, "Background," .

states, in part, that:

To the extent applicable, the operating test will require the applicant to demonstrate an understanding of, and the ability to perform, the actions necessary to accomplish a representative sampling of the 13 items identified in 10 CFR 55.45(a). (All 13 items do not need to be sampled on every operating test). In addition, the content of the operating test will be identified, in part, from teaming objectives contained in the facility licensee's training program and information in the final safety analysis report, system description manuals and operating procedures, the facility license and amendments thereto, licensee event reports, and other materials that the Commission requests from the facility licensee.

4.0 Technical Justification of Acceptability The SRO license candidate identified in Enclosure 2 successfully completed the written examination administered on February 9, 2018, and operating test administered January 22-26, 2018. His overall grade on the written examination was high, 97.9 percent. In addition, he received all "satisfactory" grades for the individual walkthrough portion of his operating test and uniform "3" scores (the highest score) for the simulator test portion of the operating test. He met all requirements of the SRO training program at DCPP. He,did have a gap in employment with PG&E, from February 16, 2018, to August 6, 2018. However, upon being rehired by PG&E he successfully-completed "Additional Training" under 10 CFR 55.59(b) and a facility-prepared written examination and operating test, which ensure that he is up to date in the licensed operator requalification training program, including generic fundamentals examination topics.

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Enclosure 2,Contains Personally Identifiable Information-Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 He is enrolled in the DCPP licensed operator continuing training program, which is based on the requirements defined in 10 CFR Part 55 and is accredited through the National Academy for Nuclear Training. He'completed all training that was missed during his approximately six-month absence from PG&E; therefore, his knowledge and training level is commensurate with that of the individuals in his license class to date.

The continuing training program uses a SAT to maintain operator proficiency for the major subject areas and topics that define the reactor operator and senior reactor operator qualification programs. Enrollment in and passing of the continuing training ,program ensures operator license candidate knowledge retention is consistent with standards established in NRC regulations and NUREG-1021.

The written examination and operating test pass documentation (Enclosure 2) along with the above training activities assure that the individual has learned to operate the DCPP units competently and safely: Additionally, they assure that he has learned as an SRO to direct the licensed activities of licensed operators competently and safely. This is consistent with 10 CFR 55.33(a)(2).

The individual's health was additionally recertifi~d by a physician on October 24, 2018 (see NRC Form 396, dated October 29, 2018, and submitted under PG&E Letter DCL-18-099 dated November 15, 2018). This supports the NRC staff finding required by 10 CFR 55.33(a)(1), "Health," that

"[t]he applicants medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety."

5.0 Regulatory Evaluation Exemptions from the provisions in 10 CFR Part 55 are governed by 10 CFR 55.11, "Specific Exemptions." That regulation states:

The Commission may, upon application by an interested.person, or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property and are otherwise in the public interest.

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

Page 7 of 11 Enclosul!"e 2 Contains Personally Identifiable Information -Withhold iJll1lder 1o*CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

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Enclosure 1 PG&E Letter DCL-19-017 5.1 This exemption is authorized by law The Commission has the authority to issue the requested exemption. The exemption would not conflict with any provision of the Atomic Energy Act (AEA) or any other law.

Specifically, Section 107 of the AEA states, in part; that the Commission shall (a) "prescribe uniform conditions for licensing individuals as operators of ... utilization facilities licensed" by the NRC, and (b)

"determine the qualifications of such individuals."

• The Commission, has complied with subsection (a) through the promulgation of Part 55 and NUREG-1021. There is nothing in the AEA that prohibits .the Commission from granting exemptions from the provisions in Part 55. The licensing written examination and operating test taken by the SRO license candidate in January-February 2018-were for DCPP, which is the same facility for which the individual would be licensed under the requested exemption. The requirement governing uniformity is therefore unaffected by the exemption request.

• The Commission will comply with subsection (b) through the licensing process for the operator candidate. The requirement governing operator qualifications is unaffected by the exemption request.

Accordin,gly, this_ requested exemption is authorized by law.

5.2 This exemption will not endanger life or property The exemption does not change the design, construction, or operating procedures of DCPP. Furthermore, as explained in Section 4.0 above, the exemption is consistent with ensuring that the operator will be competent and fully trained to safely operate the plant; the exemption merely requests the Commission to recognize his existing written examination and operating test pass documentation (Enclosure 2) for purposes of SRO license issuance now, for DCPP Units 1 and 2, in accordance with 10 CFR 55.33, "Disposition of an initial application." Therefore, the exemption will not endanger life or property.

5.3 This exemption is consistent with the public interest.

The proposed exemption from the requirements of 10 CFR 55.33(a)(2) and 10 CFR55.31(a)(3) would avoid unnecessary financial burden.on Page 8 of 11

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Em:losure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 PG&E, a regulated public utility. Successful recent completion of the written examination and operating test, along with the actions PG&E has taken to address the approximately six-month gap in employment with PG&E, as described in Section 4.0 above, indicate the candidate is prepared to operate DCPP competently and safely. This ensures 1 operation of the facility such that the public health and safety would not be adversely impacted. The exemption further supports the public interest by conserving NRC resources associated with re-administering the written examination and operating test to the individual, while ensuring the individual satisfies the applicable requirements to obtain a license. Having an additional licensed SRO also supports the ability of DCPP to maintain proper staffing levels to support activities until the end of licensed operation for the DCPP units.

• 5.4 Significant Hazards Determination and Environmental Consideration The proposed exemption has been evaluated against the criteria of .

10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review." The requested exemption meets the eligibility criteria set forth in 10 CFR 51.22(c)(25)(vi)(E).

The requested exemption would allow an SRO license candidate to obtain credit for the successful completion of his previous initial license examination and operating test. The exemption does not make any changes to the facility or operating procedures .and does not:

a) involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), in that it does not:

• alter the design, function or operation of any plant equipment.

Therefore, granting this exemption would not increase the probability or consequence of any previously evaluated accident.

• create any new accident initiators. Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

• exceed or alter a design basis or safety limit. Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Page 9 of 11 Contains Personally ld~ntifiable information -Withhold Under 10 CFR 2.390 Wtnen separated from Enclosure 2, this cover letter is decontrolled.

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Enclosure 1

• PG&E Letter DCL-19-017 Therefore, a finding of "no significant hazards considerations" is justified.

b) involve any changes that would introduce any change to effluent types, affect any plant radiological or non-radiological effluent release quantities, or affect any effluent release paths, or the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.

Therefore, it is concluded that ttie proposed exemption does not involve a significant change in the types or a significant increase in the amounts of any effluents tnat may be released offsite.

c) affect any plant radiation zones, nor change any controls required under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure. Therefore, it is concluded that the proposed exemption does not involve a significant increase in

• individual or cumulative occupational radiation exposure.

d) involve any facility changes or change any construction activities.

Therefore, there is no significant construction impact.

e) alter the design, function, or operation of any plant equipment.

Therefore, there is no significant increase in the potential for or consequences from radiological accidents.

Finally,* the requiremel'.lts to which the exemption applies involve qualification requirements and therefore meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25)(vi)(E).

Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this exemption. .

6.0 Precedent Exemption This exemption request is analogous to one submitted by Southern Nuclear Operating Company (SNC) on December 20, 2018 (ADAMS Accession No. ML19030A226). That SNC submittal requested exemption from the same two provisions of 10 CFR Part 55 to allow recognition of test pass letters for 12 licensed operator candidates from Virgil C. Summer Nuclear Station Unit 2 for purposes of licensing at Vogtle Electric Generating Plant Unit 3.

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Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.

Enclosure 1 PG&E Letter DCL-19-017 7.0 References 7 .1 10 CFR Part 55, "Operators' Licenses" 7.2 NUREG-1021, Revision 11, "Operator Licensing Examination Standards for Power Reactors, Final Report" 7.3 Atomic Energy Act of 1954, as amended, Section 107, "Operators' Licenses" Page 11 of 11 Enclosure 2 Contains Personally Identifiable Information -Withhold Under 10 CFR 2.390 When separated from Enclosure 2, this cover letter is decontrolled.