ND-19-0216, Response to Request for Additional Information Related to Request for Exemption from Operator Written Examination and Operating Test
| ML19063B575 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/04/2019 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ND-19-0216 | |
| Download: ML19063B575 (7) | |
Text
Southern Nuclear Michael J. Yox Regulatory Affairs Director Vogtfe 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6459 tet myox@southernco.com March 4, 2019 Docket Nos.: 52-025 52-026 ND-19-0216 10CFR 55.11 10 CFR 55.31(a)(3) 10CFR 55.33(a)(2)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Response to Request for Additional Information Related to Request for Exemption from Operator Written Examination and Operating Test Ladles and Gentlemen:
On December 20, 2018, Southern Nuclear Operating Company, Inc. (SNC) submitted letter ND-18-1126, Request for Exemption from Operator Written Examination and Operating Test, to the U.S. Nuclear Regulatory Commission (NRC) for Vogtle Electric Generating Plant Units 3 and 4
(Agencywide Documents Access and Management System (ADAMS) Accession No. ML19030A226). By email dated February 13, 2019, the NRC staff Issued a request for additional Information (RAI) (ADAMS Accession No. ML19044A780).
The responses to the RAI questions are provided In the enclosure to this letter. The Information provided In the enclosure does not alter the scope or conclusions of the original submlttal.
This letter. Including the enclosure, has been reviewed and confirmed to not contain security-related Information. This letter contains no regulatory commitments. Should you have any questions, please contact Mr. Steve Leighty at (706) 848-6790.
I declare under penalty of perjury that the foregoing Is true and correct. Executed on the 4^ of March 2019.
U.S. Nuclear Regulatory Commission ND-19-0216 Page 2 of 4 Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Michael J. Vox Regulatory Affairs Director Vogtle 3 & 4 MJY/PSF/sfr
Enclosure:
Vogtle Electric Generating Plant (VEGP) Units 3 and 4
- Response to Request for Additional Information Related to Request for Exemption from Operator Written Examination and Operating Test
U.S. Nuclear Regulatory Commission ND-19-0216 Page 3 of 4 go:
Southern Nuclear Qperatino Company / Georgia Power Comoanv 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)
Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Vox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. J. Andrews Document Services RTYPE: VND.LI.LOO 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 Georoia Mr. R. Dunn
U.S. Nuclear Regulatory Commission ND-19-0216 Page 4 of 4 Oolethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georoia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinohouse Electric Company. LLC Mr. L. Oriani (w/o enclosures)
T. Rubenstein (w/o enclosures)
Mr. M. Corletti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. 8. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NU8, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.
Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. 8. Franzone, Florida Power & Light
Southern Nuclear Operating Company ND-19-0216 Enclosure Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to Request for Additional Information Related to Request for Exemption from Operator Written Examination and Operating Test (This enclosure consists of 3 pages, Including this cover page)
ND-19-0216 Enclosure Response to Request for Acfdttionaf Information Related to Request for Exemption from Operator Written Examination and Operating Test The following are questions provided by the NRC Staff on February 13, 2019 (ADAMS Accession Number ML19044A780) regarding the review of Southern Nuclear Operating Company, Inc. (SNC) submitted letter ND-18-1126, Request for Exemption from Operator Written Examination and Operating Test, for Vogtle Electric Generating Plant Units 3 and 4 (ADAMS Accession No. ML19030A226). Responses are provided below for each RAI question.
RAI Question 1 The staff requests the following additional information to determine whether the exams that SNC administered to the 12 former VCSNS 2 operator license candidates adequately demonstrate that they have learned to implement the VEGP 3 emergency plan and conduct of operations procedures:
- a. The minimum score needed to pass the exam,
- b. Whether and how these exams tested knowledge and abilities necessary to implement the VEGP 3 emergency plan and conduct of operations procedures that otherwise would be tested on an NRC written exam and operating test,
- c. Whether and how exam security measures were established for these exams.
SNC Response to RAI Question 1 1.a. The minimum passing score for examinations related to the emergency plan and the conduct of operations procedures was an 80% grade or better for both the written examination and job performance measure (JPM) examination. The minimum score needed to pass the exams was based on criteria used for the Initial License Training (ILT) Program. Procedure NMP-TR-417, "Initial License Training Program," outlines the passing criteria for senior reactor operator exams.
The 12 former VCSNS Unit 2 operator license applicants for VEGP Unit 3 are senior reactor operators.
I.b. The exams that SNC administered to the 12 former VCSNS Unit 2 operator license applicants on the VEGP Unit 3 emergency plan implementing procedures (EPIP) and the conduct of operations procedures following the gap training included both JPMs and written test questions.
The exams consisted of a 25-question written exam and a 5-part JPM exam. The test questions were developed by an instructor who is both trained and experienced in writing regulatory exam questions. The written exam questions met the standards in NUREG 1021, Appendix B, and the JPM questions met the standards in NUREG 1021, Appendix C.
The written exam tested the candidates on conduct of operations procedures. The nature of the gap for Conduct of Operations was knowledge based, not skill based, so the method selected to evaluate the gap closure was a written exam. The JPMs tested the candidates on the EPIP; the JPMs were administrative in nature based on the gap being addressed. There was no overlap between the written and JPM exams. This use of written exams for evaluating gap closure was proven to be an effective method as evidenced by successful completion of JPM exams during annual continuing training in 2018.
All written test questions and JPMs were based on and linked to knowledge and ability (K/A) items selected from NUREG 2103. The importance rating of each K/A item was equal to or greater than 2.5. The exams were based on closing the gaps which were identified during the Page 2 of 3
ND-19-0216 Enclosure Resporrse to Request for Additional Irrformation Related to Request for Exemption from Operator Written Examination and Operating Test Systematic Approach to Training based gap analysis. The K/A s selected for the exams that SNC administered sampled from all the K/As that SNC identified as testable differences. K/As from the following sections of NUREG 2103 were sampled:
2.1 Conduct of operations, 2.2 Equipment Control, 2.3 Radiation Control, and 2.4 Emergency Procedures and Emergency Plan As stated in the exemption request, subjects included in operations procedure training were those which provided operators with VEGP's expectations for operators in conduct of operations for plant control, configuration management, and administration of duties. In addition, the training on the emergency plan was delivered to the candidates using the same material presented to the VEGP Unit 3 initial licensed operator candidates in their post-NRC examination transition training.
1.0. The exams were developed and administered in accordance with SNC policies used for licensed operator exams; NMP-TR-417, "Initial License Training Program," was followed. Exam security was in place for the written and JPM exams. Exam security was established in accordance with NMP-TR-208, "Examination and Examination Security." The process used during gap training and examination of former VCSNS Unit 2 operator license applicants on the VEGP Unit 3 EPIP and the conduct of operations procedures, is the same process that would be used for conducting gap training and examination of operators following an NRC exam.
The procedures identified above include steps to ensure individuals taking the exams do not have knowledge of the exams prior to taking the exam. These measures include:
Printing copies of the exam on colored paper and controlling access to the exams; Counting exams and locking them in a secure location to control access to the exams before administering them; Informing the students and instructor(s), by means of a briefing, that they are not to discuss the content of the exam; and Requiring an exam integrity statement to be signed by each student taking the exam.
RAI Question 2 Additionally, Enclosure 1 states that SNC conducted the gap analysis by comparing "VEGP and VCSNS tasks lists." Please clarify whether task lists for both reactor operators and senior reactor operators were reviewed during the gap analysis.
SNC Response to RAI Question 2 The task list review, conducted as part of the gap analysis, included a comparison of both the Reactor Operator and Senior Reactor Operator task lists. The review was conducted in accordance with NISP-TR-01, "Systematic Approach to Training Process."
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