ML18332A494
| ML18332A494 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/29/2018 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Frederick Brown Office of New Reactors |
| hoellman j/415-5481 | |
| Shared Package | |
| ML18332A493 | List: |
| References | |
| ND-18-1126 | |
| Download: ML18332A494 (17) | |
Text
Michael J. Yox Southern Nuclear Regulatory Affairs Director Operating Company, Inc.
Voglte 3&4 7825 River Road Waynesboro, GA 30830 Tel 706.848.6459 December XX, 2018 Docket Nos.: 52-025 ND-18-1126 52-026 10 CFR 55.11 10 CFR 55.33(a)(2)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Mr. Frederick D. Brown Director, Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for Exemption from Operator Written Examination and Operating Test Ladies and Gentlemen:
Pursuant to 10 CFR 55.11, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests, on behalf of the former Virgil C. Summer Nuclear Station, (VCSNS) Unit 2 licensed operator candidates listed 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.
Following the closure of VCSNS 2&3, twelve licensed operator candidates trained at VCSNS 2&3 were hired by Vogtle Electric Generating Plant, Units 3 and 4 (VEGP 3&4). The twelve licensed operator candidates successfully completed a written examination and an operating test while employed at VCSNS 2&3.
Accordingly, in lieu of the requirement of 10 CFR 55.33(a)(2), these former VCSNS Unit 2 licensed operator candidates wish to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2, to VEGP 3 (License Number NPF-91).
The exemption will ensure SNC has a requisite number of licensed operators prior to fuel load for VEGP Unit 3. to this letter presents SNCs detailed basis for the exemption. Enclosure 2 provides the list of operator candidates requesting transfer of their pass letters.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
SNC requests NRC staff approval of the requested exemption by April 1, 2019.
U.S. Nuclear Regulatory Commission ND-18-1126 Page 2 of 4 Should you have any questions, please contact Ms. Kelli Roberts at (706) 848-6991.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the XXth of December 2018.
Respectfully submitted, Michael J. Yox Regulatory Affairs Director Southern Nuclear Operating Company
- Request for Exemption from Operator Written Examination and Operating Test : Operator Candidates Requesting Transfer of Their Pass Letters (Personally Identifiable Information-Withhold Under 10 CFR 2.390)
U.S. Nuclear Regulatory Commission ND-18-1126 Page 3 of 4 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)
Mr. D. G. Bost (w/o enclosures)
Mr. M. D. Meier (w/o enclosures)
Mr. D. H. Jones (w/o enclosures)
Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)
Mr. T. W. Yelverton (w/o enclosures)
Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. B. H. Whitley Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Ms. P. Reister Ms. K. Roberts Ms. P. Ridgway Mr. M. L. McCue Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)
Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn (w/o enclosure 2)
Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 2)
Ms. A. Whaley (w/o enclosure 2)
U.S. Nuclear Regulatory Commission ND-18-1126 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 2)
Mr. S. M. Jackson (w/o enclosure 2)
Dalton Utilities Mr. T. Bundros (w/o enclosure 2)
Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)
Mr. C. Churchman (w/o enclosures)
Mr. M. Corletti (w/o enclosure 2)
Mr. M. L. Clyde (w/o enclosure 2)
Ms. L. Iller (w/o enclosure 2)
Mr. D. Hawkins (w/o enclosure 2)
Mr. J. Coward (w/o enclosure 2)
Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure 2)
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 2)
Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 2)
Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 2)
Mr. K. C. Greene, Troutman Sanders (w/o enclosure 2)
Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 2)
Mr. S. Franzone, Florida Power & Light (w/o enclosure 2)
Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test (This Enclosure consists of 10 pages, including this cover page)
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 2 of 11 1.0 Summary Description Pursuant to 10 CFR 55.11, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests, on behalf of the former Virgil C. Summer Nuclear Station (VCSNS) Unit 2 licensed operator candidates listed in Enclosure 2, an exemption from the requirement of 10 CFR 55.33(a)(2), Written examination and operating test. In lieu of this requirement for approval of an initial application, former VCSNS 2 licensed operator candidates wish to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2, to Vogtle Electric Generating Plant (VEGP) Unit
- 3.
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, The 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 operators and senior operators contain a representative selection of knowledge, skills, and abilities needed to perform the operators respective duties. Representative samples of items to be tested on a written exam, for operators and senior operators, are provided in 10 CFR 55.41 or 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 during the operating tests is provided in 10 CFR 55.45.
SNC and South Carolina Electric & Gas Company (SCE&G) worked together to develop training material, for licensed operator candidates, that met the guidance in Nuclear Energy Institute (NEI)06-13A, Template for an Industry Training Program Description.
The criteria in NUREG-1021, Operator Licensing Examination Standards for Power Reactors; Final Report, was used to prepare written examinations and operating tests as required by 10 CFR 55. In conjunction with NUREG-1021, NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators, was utilized to ensure content-valid exams and tests. The Commission approved the content of all administered written examinations and operating tests.
Following the closure of VCSNS Units 2 and 3, twelve licensed operator candidates trained at VCSNS were hired by VEGP. The twelve licensed operator candidates had successfully completed the written examination and operating test while employed at VCSNS. Following completion of the examination, the candidates were enrolled into a Systematic Approach to Training (SAT)-based continuing training program at VCSNS.
The candidates are currently enrolled in a SAT-based continuing training program at VEGP. The continuing training program curriculum includes training on design and procedure changes.
The AP1000 is designed to be a standard plant. VCSNS Unit 2 and VEGP Unit 3 are of similar age and power level, and share the same vendor and similar design. Training
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 3 of 11 material (e.g., lesson plans, simulator scenarios, operating procedures), for operators at VCSNS Unit 2 and VEGP Unit 3 was created jointly by SNC and SCE&G using common procedures and references provided to the utilities by Westinghouse Electric Company.
A gap analysis, which included a review of the knowledge and abilities catalog and a comparison of operator task lists, was conducted. The only training needs identified during the analysis were related to procedures. Training on VEGPs conduct of operations procedures and emergency plan procedures was conducted for former VCSNS operator candidates to ensure there were no discontinuities in operator knowledge. The examinations administered at VCSNS Unit 2 and VEGP Unit 3 tested common AP1000 systems and two site-specific systems; the examinations did not test aspects of site-specific systems which are unique to one facility. Due to design standardization, as well as collaboration between VCSNS and VEGP during examination development, no gaps in the material tested have been identified.
Accordingly, in lieu of the requirement of 10 CFR 55.33(a)(2), former VCSNS Unit 2 licensed operator candidates wish to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2, to VEGP Unit 3.
The exemption, from the requirement of 10 CFR 55.33(a)(2), is being requested on behalf of the VEGP Unit 3 licensed operator candidates identified in Enclosure 2 of this letter.
3.0 Applicable Regulatory Requirements This section provides a summary of regulations applicable to this exemption request.
3.1 Atomic Energy Act of 1954, as amended (42 USC. 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...
3.2 10 CFR Part 55, Operators Licenses 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 and 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:
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 4 of 11 (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:
(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 NRC for review and approval, and (4) the facility licensee shall obtain NRC 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 licensees requirements to be licensed as an operator or senior operator and of the facility licensees need for an operator or a senior operator to perform assigned duties. An authorized representative of the facility licensee shall certify this evidence on Form NRC-398. This certification must include details of the applicants qualifications, and details on courses of instruction
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 5 of 11 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 learning objectives contained in the facility licensees 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.
ES-401N, Preparing Initial Site-Specific Written Examinations Section B, Background, states, in part, that:
The ES-401N applies to new reactors licensed under 10 CFR Part 52. The content of the written licensing examinations for ROs and SROs is dictated by 10 CFR 55.41, Written Examinations: Operators, and 10 CFR 55.43, Written Examinations: Senior Operators, respectively. Each examination shall contain a representative selection of questions concerning the knowledge and abilities (K/As) and skills needed to perform duties at the desired license level. Both the RO and SRO examinations will sample the 14 items specified in 10 CFR 55.41(b), and the SRO examination will also sample the 7 additional items specified in 10 CFR 55.43(b).
Except as noted in Section D.1.b of this examination standard, NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators:
Westinghouse AP1000 Pressurized-Water Reactors, provide the basis for developing content-valid operator licensing examinations. Each K/A stem statement has been linked to an applicable item number in 10 CFR 55.41 and/or 10 CFR 55.43. Preparing the license examination using the appropriate K/A catalog, in conjunction with the instructions in this NUREG-series report, will ensure that the examination includes a representative sample of the items specified in the regulations.
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 6 of 11 3.4 NEI 06-13A, Revision 2, Template for an Industry Training Program Description NEI 06-13A was incorporated into the VEGP 3&4 UFSAR, Section 13.2A, by License Document Change Request, LCDR 2013-047.
Section 1.1, Licensed Operator Training, states, in part, that:
The Reactor Operator (RO) and Senior Reactor Operator (SRO) training programs, including initial and requalification training, provide the means to train individuals in the knowledge, skills, and abilities needed to perform licensed operator duties Before initial fuel loading, the number of persons trained in preparation for RO and SRO licensing examinations will be sufficient to meet regulatory requirements, with allowances for examination contingencies and without the need for planned overtime.
3.5 NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators Section 1.1, Introduction, states:
The Knowledge and Abilities Catalog for Nuclear Power Plant Operators:
Westinghouse AP1000 NUREG-2103 provides the basis for development of content-valid written and operating licensing examinations for reactor operators (ROs) and senior reactor operators (SROs). The Catalog is designed to ensure equitable and consistent examinations.
Section 1.2, Part 55 of Title 10 of the Code of Federal Regulations, states:
The catalog is used in conjunction with NUREG-1021 "Operator Licensing Examination Standards for Power Reactors." NUREG-1021 provides policy and guidance and establishes the procedures and practices for examining licensees and applicants for RO and SRO licenses pursuant to Part 55 of Title 10 of the Code of Federal Regulations (10 CFR 55). All knowledge and abilities (K/As) in this catalog are directly linked by item number to 10 CFR 55.
4.0 Technical Justification of Acceptability The licensed operator candidates identified in Enclosure 2 have been trained using common AP1000 training material and have passed all portions of a written examination and an operating test given at VCSNS Unit 2. The content and substance of the licensing examinations and tests given to licensed operator candidates at VCSNS Unit 2 and VEGP Unit 3 are developed from a consistent set of AP1000 materials and provide a common basis for evaluating candidates qualifications with respect to these substantially-similar facilities.
Training material (e.g., lesson plans, simulator scenarios, operating procedures),
for operators at VCSNS Unit 2 and VEGP Unit 3, was created using common procedures and references provided to the utilities by Westinghouse Electric Company (WEC). Training material was jointly developed by SNC and SCE&G.
Training programs were established consist with NEI 06-13A, Template for an
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 7 of 11 Industry Training Program Description, and ACAD 10-001, Guidelines for Initial Training and Evaluation of Licensed Operators at both VEGP and VCSNS.
The content of the examinations and the tests developed by SNC and SCE&G complied with the requirements of 10 CFR 55 and NUREG-1021 and drew from a common set of AP1000 materials (e.g., NUREG-2103).
Examinations and tests were developed to assess the knowledge, skills, and abilities needed by operators to perform assigned tasks common to both VCSNS Unit 2 and VEGP Unit 3.
A gap analysis was conducted by VEGP senior reactor operator (SRO) certified training instructors and former VCSNS Unit 2 SRO candidates to identify areas where testable differences may exist to inform whether gap training may be required for former VCSNS Unit 2 licensed operator candidates. The gap analysis included a review and comparison of the VEGP and VCSNS tasks lists. It also included a review of testable knowledge and abilities, those with a catalog rating of 2.5 or greater, for site-specific systems (i.e.,
Circulating Water System and Liquid Radwaste System).
A training task list was created by the AP1000 owners group and adopted by both SNC and SCE&G. The gap analysis included comparing the sites task lists.
A line by line comparison of the task lists for VEGP and VCSNS revealed all VEGP operator tasks were included on the VCSNSs operator task list; however, multiple procedures varied by site. Testable differences were limited to site-specific emergency planning and conduct of operations procedures.
The knowledge and abilities defined in NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors Westinghouse AP1000, were used in training and evaluating operators at both VCSNS and VEGP. A review of testable knowledge and abilities for site-specific systems was conducted; the subject of all catalog items was traced back to lesson plans which were developed from a consistent set of AP1000 materials.
Therefore, it was determined that all testable knowledge and abilities were included in common AP1000 systems training and/or procedure training.
Since the VCSNS Unit 2 candidates were hired by SNC, the following steps have been taken to address site-specific gaps in these candidates training and evaluation:
Training on the VEGP site Emergency Plan Implementing Procedure (EPIP) was delivered to the candidates identified in Enclosure 2 using the same material provided to VEGP Unit 3 initial licensed operator candidates in their post-NRC exam transition training.
Procedure gap training was conducted by self-study of VEGP conduct of operations procedures with instructors available to assist and answer questions.
All candidates identified in Enclosure 2 completed procedure gap training and passed written examinations covering topics within the procedures.
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 8 of 11 All operator license candidates that successfully completed the written examination and operating test, including operators listed in Enclosure 2, have been enrolled in a SAT-based continuing training program to maintain proficiency of acquired knowledge and abilities to perform assigned tasks. The SAT-based continuing programs at VEGP Unit 3 and VCSNS Unit 2 are functionally equivalent. The continuing training is based on a continuous two-year cycle.
The continuing training program is based on the requirements defined in 10 CFR Part 55 and is accredited through the National Academy for Nuclear Training.
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 senior reactor operator qualification programs.
Enrollment in and passage of the continuing training program ensures operator license candidate knowledge retention is consistent with standards recognized in NRC regulations and NUREG-1021.
The NRC approved the use of a Commission-Approved Simulation Facility (CAS) for administering operating tests at VEGP (ML16070A301). Likewise, the staff approved the use of a CAS for administering operating tests at VCSNS (ML16203A116). The staff concluded that the simulation facilities used by both sites replicated the AP1000 DCD predicted core model with sufficient scope and fidelity to support use in operator tests.
As part of their continuing training, the candidates identified in Enclosure 2 are trained and evaluated on the VEGP CAS.
In summary, variances between the training programs of the two utilities were reconciled by conducting gap training on site-specific emergency and conduct of operations procedures. Written examinations administered at VCSNS Unit 2 were prepared using the same knowledge and abilities catalog used at VEGP Unit 3 and provide a common basis for evaluating candidates qualifications with respect to these substantially-similar AP1000 facilities. Following successful completion of the licensed examination, the candidates identified in Enclosure 2 were enrolled in a SAT-based continuing training program. The results of the licensed examination and test indicate licensed operator candidates have learned to operate an AP1000 facility competently and safely.
Therefore, transferring the test pass letters, for written examinations and operating tests taken at VCSNS Unit 2, to VEGP Unit 3, is an acceptable alternative to having these candidates reperform the examinations and tests at VEGP Unit 3.
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
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 9 of 11 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.
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 operator candidates from VCSNS Unit 2 are essentially equivalent to those taken by the VEGP Unit 3 operator candidates. The requirement governing uniformity is unaffected by the exemption request.
The Commission will comply with subsection (b) through the licensing process for operator candidates at VEGP Unit 3. The requirement governing operator qualifications is unaffected by the exemption request.
Accordingly, this requested exemption is authorized by law.
5.2 This exemption will not endanger life or property The exemption does not pertain to the design, construction, or operating procedures of VEGP Unit 3. Furthermore, as explained in Section 3 above, the exemption is consistent with ensuring that the operators will be competent and fully trained to safely operate the plant; the content and substance of the examinations and tests given at VCSNS Unit 2 and VEGP Unit 3 are comparable. The exemption would allow the pass letters of former VCSNS Unit 2 operator candidates to be transferred from VCSNS Unit 2 to VEGP Unit 3.
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), would prevent former VSCNS operator candidates who successfully completed the written examination and operating test while employed by VCSNS from having to re-take them before receiving an operator license for VEGP Unit 3. Requiring those candidates who thoroughly prepared and successfully completed the examination and the test to re-take them would be inequitable. The gap analysis demonstrated that the VCSNS operator candidates received equivalent training
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 10 of 11 to those candidates at VEGP. Successful completion of the licensed examination and test indicate licensed operator candidates have learned to operate an AP1000 facility competently and safely; this ensures 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 and licensee resources, while ensuring that operator license candidates satisfy the applicable requirements to obtain operator licenses. The exemption would avoid duplication of efforts and ensure trained personnel are available to support activities at VEGP Unit 3.
Additionally, a delay in the licensing of these operators could make it more difficult to ensure that an adequate number of licensed operators are available when construction is completed, potentially resulting in a delay in operation of the plant. A delay in operation would result in additional costs and would deprive the region of an earlier carbon-free source of electrical generation. Accordingly, to avoid such adverse impacts, the exemption is in the public interest.
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 former VCSNS Unit 2 licensed operator candidates to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2, to VEGP Unit 3. 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.
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 the proposed exemption does not
ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Page 11 of 11 involve a significant change in the types or a significant increase in the amounts of any effluents that 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.
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 None 7.0 References
- 1. 10 CFR Part 55, Operators Licenses
- 2. NEI 06-13A, Revision 2, Template for an Industry Training Program Description
- 3. NUREG-1021, Revision 11, Operator Licensing Examination Standards for Power Reactors; Final Report
- 4. Atomic Energy Act of 1954, as amended, Section 107
- 5. NUREG-2103, Revision 0, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors Westinghouse AP1000
- 6. NRC Letter, Safety Evaluation by the Office of New Reactors Related to the Request for a Commission Approved Simulator for Vogtle Electric Generating Plant Units 3 and 4, dated March 29, 2016 [ML16070A301]
- 7. NRC Letter, Safety Evaluation by the Office of New Reactors Related to the Request for a Commission Approved Simulator for Virgil C. Summer Nuclear Station Units 2 and 3, dated August 3, 2016 [ML16203A116]
Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 ND-18-1126 Operator Candidates Requesting Transfer of Their Pass Letters (Personally Identifiable Information-Withhold Under 10 CFR 2.390)
(This Enclosure consists of 2 pages, including this cover page)
ND-18-1126 Operator Candidates (Personally Identifiable Information-Withhold Under 10 CFR 2.390)
Page 2 of 2 Operator Candidate Docket Number Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-