ML18332A495
| ML18332A495 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/29/2018 |
| From: | Office of New Reactors |
| To: | |
| hoellman j/415-5481 | |
| Shared Package | |
| ML18332A493 | List: |
| References | |
| ND-18-1126 | |
| Download: ML18332A495 (6) | |
Text
Continuation of NRC FORM 398, Personal Qualification Statement BLOCK 25, Comments BLOCK 12 - Deferrals/Excusals/Waivers Item a.1, ELIGIBILITY:
o DEFERRAL: A deferral is requested from the requirement of VEGP 3&4 UFSAR, Table 13.2A-201, Item 1, Cold License Guidance to complete six months practical work assignments.
o VEGP 3&4 UFSAR:
Section 13.2A.1, Licensed Operator Experience Requirements Prior To Commercial Operation, lists six months practical work assignments as experience.
Section 13.2A.1 further states, Experience and plant evolution requirements that have not been met at the time the licensed operator examination is administered shall be met prior to issuing the individual's NRC operator license. In such a case, the Licensee will notify the NRC when the applicant meets the experience and plant evolution requirements.
o 10 CFR Part 55, Operators Licenses, states in part that the Commission shall use the criteria in NUREG-1021, Operator Licensing Examination Standards for Power Reactors.
o NUREG-1021, Operator Licensing Examination Standards for Power Reactors:
ES-202.C.2.d, states In accordance with ES-204, the region may administer a license examination to an applicant who has not satisfied the applicable training or experience requirements at the time of the examination, but is expected to complete them shortly thereafter. Assuming that the applicant passes the examination, the regional office shall not issue the applicants license until the facility licensee certifies that all of the requirements have been completed. (Refer to ES-501 for additional guidance.)
ES-202.D.4, Cold License Eligibility, states Cold licensed operator applicants need not satisfy the RG 1.8 or NANT 2010 experience requirements before entering a licensed operator training program. The experience requirements that have not been met at the time the licensed operator examination is administered will be certified by the licensee as being complete prior to the individuals NRC operator license being issued.
ES-501.D.3.c, states If the NRC granted an applicant a deferral and allowed him or her to take the examination before completing all of the training and experience requirements, the regional office shall normally not issue a license to the applicant until the facility licensee has certified in writing that the applicant has completed all of the deferred items.
o SNC equates six months practical work assignments to 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br />.
This applicant has completed XXX of the 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br />.
Per the requirements of NUREG 1021, Section ES-202. C.2.d, the applicant anticipates completing the remaining XXX hours prior to the license being issued; work assignment hours include a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of preoperational testing from the main control room. Pre-operational testing will be on systems covered in NUREG-1021 ES-401N-2 Tier 2.
Per the requirements of NUREG 1021, Section ES-202.D.4, the applicant understands that SNC must certify to the NRC that the applicant has completed the six months practical work assignments prior to the license being issued Item c.1 - NRC Written exam, Item c.2 - NRC Operating test WAIVER: Pursuant to 10 CFR 55.11, Specific Exemptions, SNC requested, on behalf of the former V.C. Summer Nuclear Station (VCSNS) 2&3 licensed operator candidate, an exemption from the requirement of 10 CFR 55.33(a)(2), Written examination and operating test. The exemption has been approved. Hence, a waiver is requested for the written examination and operating test.
o Pursuant to 10 CFR 55.11, Specific Exemptions, SNC requested an exemption from the written examination and operating test requirement of 10 CFR 55.33, Disposition of an initial application for this applicant. 10 CFR Part 55.33(a)(2), Written examination and operating test, states, in part, examinations and tests determine whether the applicant for an operators license has learned to operate a facility completely and safely, and additionally, in the case of a senior operator, whether the applicant has learned to direct the licensed activities of licensed operators completely and safely.
o The applicant was part of a group of licensed operator candidates from VCSNS 2&3 who passed a written examination and operating test at that facility. The NRC issued the applicant a pass letter providing the results of the initial written examination and operating test. The applicant, now employed by VEGP 3&4, is requesting to have his/her pass letter transferred from VCSNS 2&3 to VEGP 3&4 without taking another written examination and operating test at VEGP 3&4, in accordance with the exemption from the requirement in 10 CFR 55.33(a)(2) that was granted.
o The AP1000 is designed to be a standard plant. VCSNS 2&3 and VEGP 3&4 are of similar age and power level, and share the same vendor and similar design. The exams administered at VCSNS 2&3 and VEGP 3&4 tested common AP1000 systems; the exams did not test systems which are unique to one facility. Due to design standardization, as well as collaboration between VCSNS 2&3 and VEGP 3&4 during exam development, no gaps in the material tested have been identified.
o The VEGP 3&4 operations training group has performed training for prior VCSNS 2&3 personnel on SNC administrative and emergency planning procedures, to address any gaps in these site-specific areas, although this material is outside the scope of the exam.
Item c.4Other, Item d, Date Passed GFE WAIVER: A waiver is requested from the requirement of NUREG 1021, ES-202.C.1.b, to complete the GFE 'within 24 months before the date of application.' Pursuant to ES-204.D.1.k(4), the regional office may waive this requirement if the applicant has been a full
participant in the licensed operator requalification program, including satisfactory performance on the operator or senior operator annual and biennial requalification examinations. The participation must be continuous from 24 months following the date of the successful completion of the GFE exam up to entrance into the associated initial license class.
The applicant meets the criteria for a waiver of ES-204.D.1.k(4). Following completion of the licensing examination, the candidate was enrolled in a licensed operator continuing training program at VCSNS 2&3. Once hired by VEGP 3&4, the candidate was enrolled in a licensed operator continuing training program at that facility. The SAT-based continuing training programs at VCSNS 2&3 and VEGP 3&4 are functionally equivalent.
The candidate completed the GFE on the date provided in Item 12.d.
BLOCK 20 - Power Reactor Operator Training Program Item b - Is A Plant-Referenced Simulator (As Defined In 10 Cfr 55.4) Used in the Operator Training Program EXPLANATION:
o In its Safety Evaluation (SE), the Commission approved the simulation facility at VEGP 3&4 for use in administrating operating tests (ML16068A043, March 25, 2016). In an exemption issued by the NRC, the NRC found the simulation facility to be acceptable for conducting control manipulations (ML16090A176, March 31, 2016). Similarly, the Commission approved the simulation facility at VCSNS 2&3 for use in administrating operating tests and conducting control manipulations (ML16146A772, July 29, 2016).
o All Commission-approved simulation facilities used at VEGP 3&4 and VCSNS 2&3 were designed by WEC. Minor differences between the simulation facilities were identified during a gap analysis conducted at VEGP. VCSNS used the original WEC design where VEGP made minor tuning and system response related changes. The gap analysis concluded that differences between the simulation facilities would not have affected operator responses or decision making. Therefore, gap training for prior VCSNS 2&3 operator candidates was not deemed necessary.
o Continuing training for operator candidates at VEGP 3&4 is conducted using the Commission-approved simulation facility, as needed.
BLOCK 21 - Training Item a.3 Plant Procedures o Training on the site Emergency Plan Implementing Procedure (EPIP) was delivered to former VCSNS candidates.
o The candidate self-studied conduct of operations procedures. The candidate completed procedure gap training and passed written examinations covering topics within the procedures.
Item d - Extra Person On Shift in Control Room
EXPLANATION: This item is not applicable to Cold License SRO applicants.
o NUREG-1021, Operator Licensing Examination Standards for Power Reactors:
ES-202.D.2.b(1) states that before being assigned SRO duties, the applicant should complete at least 3 months as an extra person on shift in training for the SRO position. However, ES-202.D.4 states Current regulatory guidance does not address the situation in which the plant is not operational (i.e., under construction). Cold licensing examinations are administered prior to fuel load and prior to completion of pre-operational testing and the initial startup test program as described in the FSAR.
Each cold license applicant must meet the education, experience, and training guidance described in NEI 06-13A, Template for an Industry Training Program Description, Revision 1. NEI 06-13A was accepted by the NRC on December 5, 2008 for use in combined operating license applications for proposed new plants.
The requirements of NEI 06-13A, Revision 2 were fully incorporated into the VEGP 3&4 UFSAR as Section 13.2A.
o VEGP 3&4 UFSAR, Section 13.2A, Cold License Training Plan, Table 13.2A-201, Item
- 8, provides alternative guidance that an SRO applicant meet cumulative operating crew experience requirements and complete a plant observation activity.
o The applicant meets the alternative requirements.
Item e - Time on Shift Above 20% Power EXPLANATION: This item is not applicable to Cold License applicants.
o NUREG-1021, Operator Licensing Examination Standards for Power Reactors:
ES-202.D.2.a (3) states in part that an SRO applicant should participate in reactor operator activities at power levels greater than 20 percent for at least 6 weeks.
However, ES-202.D.4 states Current regulatory guidance does not address the situation in which the plant is not operational (i.e., under construction). Cold licensing examinations are administered prior to fuel load and prior to completion of pre-operational testing and the initial startup test program as described in the FSAR.
Each cold license applicant must meet the education, experience, and training guidance described in NEI 06-13A, Template for an Industry Training Program Description, Revision 1. NEI 06-13A was accepted by the NRC on December 5, 2008 for use in combined operating license applications for proposed new plants.
The requirements of NEI 06-13A, Revision 2 were fully incorporated into the VEGP 3&4 UFSAR as Section 13.2A.
o VEGP 3&4 UFSAR, Section 13.2A, Cold License Training Plan, Table 13.2A-201, Item
- 8, provides alternative guidance that SRO applicants meet cumulative operating crew experience requirements and complete a plant observation activity.
o The applicant meets the alternative requirements.
Item g. Other / Continuing Training Program o The applicant has been enrolled in a Systematic Approach to Training (SAT) based continuing training program that evaluates skills and knowledge continuously since joining Vogtle 3&4.
o The facility licensee commits to enrolling each applicant who passes the NRC Exam into a Systematic Approach to Training (SAT) based continuing training program that evaluates skills and knowledge.
BLOCK 22 - SIGNIFICANT CONTROL MANIPULATIONS o As stated in the comment section for Block 20 above, the Comission issued an exemption which allowed applicants at VCSNS 2&3 to use the simulation facility for conducting control manipulations.
o Commission-approved simulation facilities used at VEGP 3&4 and VCSNS 2&3 were designed by WEC. Minor differences between the simulation facilities were identified during a gap analysis conducted at VEGP. VCSNS used the original WEC design where VEGP made minor tuning and system response related changes. The gap analysis concluded that differences between the simulation facilities would not have affected operator responses or decision making. Therefore, repeating significant control manipulations for prior VCSNS 2&3 operator candidates was not deemed necessary.
o The applicant performed five control manipulations while employed at VCSNS 2&3.
Information regarding the control manipulations can be found in the following table.