ND-19-0684, Active Operator License Maintenance

Active Operator License Maintenance

ML19235A016
Person / Time
Site:	Vogtle
Issue date:	07/02/2019
From:	Mccue M Southern Nuclear Operating Co
To:	Eugene Guthrie NRC/RGN-II
References
ND-19-0684
Download: ML19235A016 (5)

Text

ML19235A016 A Southern Nuclear SCc'SSn,,,'.

Michael L McCue 30.30 Training Director 706 848 6984 Tei Plant Vogtle 3&4 mlmccue@southernco.com July 2, 2019 Docket Nos.: 52-025 ND-19-0684 52-026 10 CFR 55.53 Mr. Eugene Guthrie U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257

Subject:

Vogtle Electric Generating Plant Unit 3- Active Operator License Maintenance

Dear Mr. Guthrie,

The purpose of this letter is to document the strategy that Southern Nuclear Operating Company (SNC) will implement to ensure licensed operators at Vogtle Electric Generating Plant(VEGP) Unit 3 obtain credit for watch-standing proficiency during the period after the issuance of the operator licenses until initial fuel load.

Recommendations for the operator licensing process for cold plants were developed by the Nuclear Regulatory Commission(NRC)(Agencywide Documents Access and Management System (ADAMS)Accession No. ML18039A950). Part A of the report. Charter: Operator Licensing Process for Cold Plants, states in part:

For cold plant construction projects, operator licenses should be Issued to applicants who meet all statutory and regulatory requirements necessary for an operator or senior operator under 10 CFR Part 55, after the facility licensee has staffed the main control room. Refer to ES-202, Attachment 2, and "Operator Licensing Milestones for 10 CFR Part52 Plants under Construction."

To maintain active status, 10 CFR 55.53(e) requires operators to perform the minimum quarterly licensed operator functions. Therefore, once operator licenses are issued, but before initial fuel load, a methodology for license maintenance for cold plants is required. During this time, licensed operators at VEGP Unit 3 will be performing the functions of an operator including testing and operation of safety-significant systems during pre-operational testing.

SNC personnel in operations, licensing, and training have reviewed watch-standing hours (i.e.,

proficiency watches)for cold plants to determine if operators could be credited for meeting the regulatory requirements. 10 CFR 55.53(e) states in part:

If a licensee has not been actively performing the functions of an operator[RO]or senior operator[SRO], the licensee may not resume activities authorized by a license Issued under this part except as permitted by paragraph (f) of this section [I.e., qualifications are

U. S. Nuclear Regulatory Commission ND-19-0684 Page 2 of 5 current and valid; and that the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift function]. To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum ofseven 8-hour or five 12-hour shifts per calendar quarter.

As delineated in NUREG-1021, ES-605 C.2(b), and in accordance with 10 GFR 55.4,"actively performing the functions of an operator or senior operator" means that an individual has a position on a shift crew that requires an individual to be licensed as defined in the facility's Technical Specifications (TS). VEGP Unit 3 is required to implement TS when the Commission makes the finding under 10 CFR 52.103(g).

The SNC administrative procedure which governs maintenance of active licenses credits the following positions for actively performing the functions of a RO or SRO:

• On-shift as Operator at the Controls(CATC)

• On-shift as Unit Operator(UO)

• On-shift as Shift Supervisor(SS)

• On-shift as Shift Manager(SM)

The administrative procedure describes the details of how each position is meaningfully and fully engaged in functions and duties analogous to the minimum licensed positions required by TS. In general, the positions described in the procedure will be staffed during construction and pre-operational testing identical to how the positions are staffed at an operating plant. For example, the SM is the senior licensed person and will have the same degree of responsibility whether the plant is under construction, testing, or operating: the SM will routinely relieve the Control Room Supervisors. As well, the UO has the same degree of responsibility during construction, testing, and when operating, routinely relieving the CATC and performing RO duties.

Watch-standing proficiency credit may also be appropriate for certain licensed reactor operator (RO)or senior reactor operator(SRO)crew positions that are in excess of those required by a facility's TS. To credit watch-standing proficiency for such excess positions, SNC will utilize the following procedural administrative controls:

• A list of all the licensed shift crew positions, including title, description of duties, and indication of which positions are required by TS; and

• For shift crew positions in excess of those required by TS, a description of how the position is meaningfully and fully engaged in the functions and duties of the analogous minimum licensed position(s) required by TS.

During pre-operational testing, systems listed in NUREG-1021, Form ES-401N-2, as Tier 2 Plant Systems, will be tested and operated. The administrative procedure which governs maintenance of active licenses allows these shifts to be credited for proficiency. These shifts have "meaningfulness" because ROs and SROs have the same level of responsibility for plant operations during testing as when the plant is operational.

U. S. Nuclear Regulatory Commission ND-19-0684 Page 3of 5 Requalificatlon training will be ongoing throughout the duration of pre-operationai testing, preparing the licensed operators for initial criticaiity. Just-in-Time (JIT)training will be utilized for safety-significant evolutions such as initial criticaiity and low power physics testing. The combination of requalificatlon and JIT training will ensure that the operators are proficient before standing watch during the reactor startup and power ascension.

If you have any questions, please contact me at(706)848-6984.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Michael L. McCue Training Director Plant Vogtle 3 & 4 MLM/PSF/sfr

U. S. Nuclear Regulatory Commission ND-19-0684 Page 4 of 5 go:

Southern Nuclear Operating Company / Georgia Power Company Mr. 8. E. Kuczynski(w/o enclosures)

Mr. R. G. West(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 Ms. 8. Agee Ms. A. C. Chamberlain Mr. 8. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. BIythe Document Services RP/PE: VND.LI.LOO File AR.01.02.06 Nuclear Regulatory Commission Mr. W.Jones (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Mr. B. Kemker Mr. G. Khouri Ms. 8. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. 8. Walker Mr. N.D. Karlovich Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Ms. K. P. Carrington Mr. P.J. Heher State of Georgia Mr. R. Dunn

U. S. Nuclear Regulatory Commission ND-19-0684 Page 5 of 6 Oaiethorpe Power Corporation Mr. M.W.Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Daiton Utilities Mr. T. Bundros Westinohouse Electric Company. LLC Mr. L. Oriani(w/o enclosures)

Mr. T. Rubenstein (w/o enclosures)

Mr. M. Corietti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Baich Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light