ML21166A117

COL Docs - FW: VEGP Unit 4 Operator Licensing Exemption Draft

ML21166A117
Person / Time
Site:	Vogtle
Issue date:	06/15/2021
From:	NRC
To:
References
Download: ML21166A117 (14)

Text

From: Santos, Cayetano Sent: Tuesday, June 15, 2021 9:01 AM To: Vogtle PEmails

Subject:

FW: VEGP Unit 4 Operator Licensing Exemption DRAFT Attachments: VEGP Unit 4 Operator Licensing Exemption DRAFT.pdf From: Leighty, Steven <sleighty@southernco.COM>

Sent: Monday, June 14, 2021 4:34 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] VEGP Unit 4 Operator Licensing Exemption DRAFT

Tanny, As discussed earlier today, please find attached the draft exemption for the Vogtle Unit 4 Operator Licenses. This is in support of our presubmittal discussion. Please let me know which date would be best for scheduling the presubmittal meeting.

Thanks, Steve Leighty l Southern Nuclear Licensing Manager l Vogtle 3&4 706.848.6790 l sleighty@southernco.com

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 612 Mail Envelope Properties (MN2PR09MB5244797F857159C675ED00DCE5309)

Subject:

FW: VEGP Unit 4 Operator Licensing Exemption DRAFT Sent Date: 6/15/2021 9:00:56 AM Received Date: 6/15/2021 9:00:57 AM From: Santos, Cayetano Created By: Cayetano.Santos@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@usnrc.onmicrosoft.com>

Tracking Status: None Post Office: MN2PR09MB5244.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 663 6/15/2021 9:00:57 AM VEGP Unit 4 Operator Licensing Exemption DRAFT.pdf 873226 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Southern Nuclear Operating Company ND-21-0427 T

Enclosure 1 AF Request for Exemption from Operator tor Written ritten Examination Licenses Examinati censes and Operating Test for Unit 4 DR (This Enclosure consists of 10 pages, not including this cover page)

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses 1.0 Summary Description Pursuant to 10 CFR 55.11, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests, on behalf of the current Vogtle Electric Generating Plant (VEGP) Unit 4 licensed operator candidates listed in Enclosure 2, an exemption from the requirement of 10 CFR 55.33(a)(2), Written examination and operating test, and 10 CFR 55.31(a)(3) which requires submitting a written request that the written examination and operating test be administered. In lieu of the requirement for submitting a written request that the written examination and operating test be administered and passing the requisite written examination and operating test, current VEGP Unit 3 licensed operators (VEGP Unit 4 license operator candidates) request the previous written examinations and operating tests taken for VEGP Unit 3 licensure be applied for the initial application for a license for the essentially identical VEGP Unit 4.

2.0 Detailed Description D

Passing the requisite written examination and operating ting test is a requirem requirement for approval of an requireme initial application for a license as specified in 10 CFRFR 55.33, Disposition of an initial application.

10 CFR 55.33(a)(2) states, in part, These examinations minations and tests determine whether the R

applicant for an operator's license has learned ed to operate a facility competently and safely, and additionally, in the case of a senior operator, tor, whether the aapplicant has learned to direct the licensed activities of licensed operators competently mpetently and safely.

safe Written tests for operators and AF senior operators contain a representative tive selection of knowledge, know skills, and abilities needed to perform the operators respective duties. Representative Represe samples of items to be tested on a written examination, for operators rs and senior opera operators, are provided in 10 CFR 55.41 or 10 CFR 55.43, respectively. Operating tests require the ap 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 sted during g the operating tests is provided in 10 CFR 55.45.

T The candidates in Enclosure 2 were instructed Nuclear Energy Institute ute (NEI)

(N The criteria in NUREG-1021,06-13A, 1021, Oper Final Report, was used to instr using training material that met the guidance in 13 Template for an Industry Training Program Description.06-13A, Operator Licensing Examination Standards for Power Reactors; Opera o prepare prepar written examinations and operating tests as required by 10 CFR 55.40, Implementation. In conjunction with NUREG-1021, NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators, was utilized to ensure content-valid examinations and tests. The Commission approved the content of all administered written examinations and operating tests.

Vogtle Units 3&4 are AP1000 standard plants and as such both Units are nearly identical.

Specifically, for VEGP Unit 3 and Unit 4, an engineering evaluation for differences between the Units was completed. The digital/electrical differences review consisted of a review of ovation logic and point databases and ovation graphics to identify unit specific differences. Also, a review of instrumentation calculation notes and Plant Control System interface specifications to identify unit specific points was performed. Only minor differences were identified in the Waste Water and Offsite Power Systems, consisting of indication, naming, and the resulting impact to the ovation screens, and a physical difference in that Unit 3 is connected to the 230 kV switchyard and Unit 4 is connected to the 500 kV switchyard. The mechanical component differences review was accomplished by reviewing design changes that are applicable to just Unit 3 or 4, reviewing design changes identified as impacting Standard Operating Procedures, and reviewing the Master Page 1 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses Equipment List. The mechanical component evaluation determined there are no significant mechanical differences between the units. Therefore, Unit 3 and Unit 4 are deemed to be nearly functionally identical. The switchyard arrangement difference is included as part of initial license and continuing training. Additionally, the Training Needs Analysis (TNA) conducted for the unit differences determined that no additional training is required; therefore, no new or modified exam questions, operating scenarios, or job performance measures are needed. The TNA also determined that the differences between the units do not affect the operators ability to operate each unit safely and competently.

Since VEGP Units 3 and 4 are virtually identical and the Unit 3 licensed operators have already been tested on a written and operating test which also would be applicable to Unit 4, no additional training is required for Unit 3 licensed operators seeking licensure ure for Unit 4. In addition, upon successfully completing their Unit 3 written examination and operating oper test, the Unit 4 licensed operator candidates have been enrolled in a Systematic ApproachAppro to Training (SAT)-based continuing training program that is applicable to both Unitt 3 and Unit The continuing training Uni 4. Th program curriculum includes training on design and procedure ocedure changes.

Accordingly, in lieu of the requirements of 10 CFR VEGP Unit 3 licensed operators request the previous T

R 55.33(a)(2) and 10 CFR vious examination C 55.31(a)(3), current examinati and operating test taken s written e VEGP Unit 4.

AF for VEGP Unit 3 licensure be applied for the initial application The exemption, from the requirements requested on behalf of the licensed applicatio for a license for the nearly identical nts of 10 CFR 55.33(a)(2) 55.33(a) ed operator candidates candi and 10 CFR 55.31(a)(3), is being identified in Enclosure 2 of this letter.

3.0 3.1 D Applicable Regulatory RAtomic atory Requirements This section provides rovides a summary of c Energy Act of 195 Section 107, o regulations r applicable to this exemption request.

1954, as amended (42 USC. 2137) 07, Operators Operat The Commission Licenses, states, in part, that:

ion 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 55.31, 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; Page 2 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 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, he whether the applicant has learned to direct thee lilicensed activities of licensed operators competently and safely.

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

that (a) The Commission shall also use thehe criteria in NUREG-1021 NUREG NUR -1 to evaluate the written examinations and operating licensees pursuant to paragraph (b) Power reactor facility licensees T

ting tests prepared by power reactor facility h (b) of this section.

ph pre s

nsees may prepare, proctor, pr and grade the written AF examinations required byy §§ 55.41 and 55.43 tests required by § 55.45, 55 5.45, subject to the follo (1) Power reactorr facility licensees shall and tests in accordance with paragraph ph (a) of this section and may prepare the operating a

following conditions:

sha prepare the required examinations wit the criteria c in NUREG-1021 as described in 3.3 DR (4) Power reactor faci NUREG-1021, licensees must receive Commission approval of their facility lic examinations proposed written ex exa and operating tests.

Revision 11, Operator Licensing Examination Standards for Power G-1021, Revisio Reactors; Final Report ES-201, Initial Repo al O al 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 Page 3 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses 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 operatorope or senior operator and of the facility licensees need for an operator tor or a ssenior operator to perform assigned duties. An authorized representative entative of the facility licensee shall certify this evidence on Form NRC-398. 98. This certification certifi must include details T

of the applicants qualifications,, and details on courses administered by the facility licensee, nsee, and describe the ensee, received at the facility, and the startup and shutdo tartup an co of instruction th nature of the training shutdown experience received. In AF lieu of these details, the Commission may accept has successfully completed based on a systems facility acceptable ES-301, Preparing ted a Commission-approved pleted ms approach Commission Commission-a roach to training le to the Commission Commis accep certification that the applicant training program that is trainin [SAT] and that uses a simulation ring Initial Operating ttests aring under u [10 CFR 55.45(b)].

DR Section B, Background, To the demonstrate Background states, in part, that:

he extent applicable, the operating test will require the applicant to nstrate an understanding to accomplish understan under mplish a representative 55.45(a). (All repr repre All 13 items ite addition, the content on of, and the ability to perform, the actions necessary sampling of the 13 items identified in 10 CFR do not need to be sampled on every operating test). In 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 Page 4 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses (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 ion using the appropriate K/A catalog, in conjunction with the instructions in n this thi NUREG-series N report, will ensure that the examination includes a representative represen sample of the items specified in the regulations.

3.4 AF NEI 06-13A, Revision 2, Template for an Industry Training Program Description NEI 06-13A was incorporated into to the e VEGP 3&4 ator Training, states, Section 1.1, Licensed Operator 3 UFSAR, sta UFSA Section 13.2 in part, that:

T The Reactor Operator (RO) nitial O) and Senior Reactor individuals in the knowledge, skills operator duties or RO and SRO licens preparation for R

itial and requalification training, provide the means to train programs, including initial Operator (SRO) training skills, and abilities needed to perform licensed Before initial fue fuel lo loading, the number of persons trained in licensing examinations will be sufficient to meet 3.5 Dregulatory requirements, without the R

NUREG-2103, ements, with all EG--2103, Knowledg EG Operators ors allowances for examination contingencies and planned overtime.

he need for plann ov Knowledge and Abilities Catalog for Nuclear Power Plant Section 1.1,, Introdu 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 Page 5 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses 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 for licensing on nearly identical VEGP Unit 3. The content and substance of the licensing examinations and tests given to the currently licensed VEGP Unit 3 operators were developed from a consistent set of AP1000 materials and provide a common basis for evaluating candidates qualifications with respect to these virtually identical units.

• Training programs were established consistent ent with NEI 06-13A, 06-13 Template for an Industry Training Program Description, for the currently licensed lice operators in Enclosure 2.

Training material (e.g., lesson plans, T

s, simulator mulator sscenarios, operating procedures), for both units.

The Unit 4 operator Planning and Conduct AF operators at VEGP Unit 3 and Unit 4, was references provided to the utilities s crea lities by Westinghouse Westingh Westingho or candidates in Enclosure tor onduct Enc Encl using common procedures and created us Electric Company (WEC).

Specifically, the training material used for Unit 3 and Unit 4 licensure is common for 2 have been trained on Emergency procedures, which are common for both VEGP ct of Operations p D

Unit 3 and Unitit 4.

R The content ent of the examinations requirements AP1000 materials examination and the tests developed by SNC complied with the nts of 10 CFR 55 and NUREG-1021 and drew from a common set of erials (i.e.,

between VEGP Unit 3 a A Training Needs A e., N NUREG-2103). An engineering evaluation of the differences and Unit 4 determined the units are nearly functionally identical.

Analysis n was completed and determined that no additional training is required for the slight differences between VEGP Unit 3 and Unit 4, and no new or modified exam questions, job performance measures, or operating scenarios are needed for Unit 4 licensure; the multiunit K/As (2.2.3 and 2.2.4) of NUREG 2103 are not applicable to VEGP 3 & 4.

• Examinations and tests were developed to assess the knowledge, skills, and abilities needed by operators to perform assigned tasks common to both VEGP Unit 3 and Unit 4.

Subsequent to the successful operating test and written examination, the licensed operators in Enclosure 2 have been enrolled in a SAT-based continuing training program that is applicable to both VEGP Unit 3 and Unit 4. The continuing training program curriculum includes training on design and procedure changes, and is designed to ensure operators maintain proficiency of acquired knowledge and abilities to perform assigned tasks.

Page 6 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses

• 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.

In summary, VEGP Unit 3 and Unit 4 have been determined to b be virtually identical, and no additional training is required for Unit 3 licensed operators seeking king licensure lilicens for Unit 4. The written exam and operating test taken by the licensed operators in Enclosure Enclos 2 are a applicable to VEGP Unit 4. In addition, upon successfully completing their Unit nit 3 written examination and operating ritten examin test, the Unit 4 operator candidates have been enrolled olled in a SAT-based SAT-based SAT- b continuing training exam and operating test and the continuing training 2 have demonstrated the ability to operate the ng T program that is applicable to both Unit 3 and Unit 4. The results of the V g program in e virtually VEGP Unit 3 licensing indicate the candidates in Enclosure ually identical ide VEGP Unit 4 competently and VEG AF safely. Therefore, crediting the written examination 3 is an acceptable alternative to having operating test for VEGP Unit 4 licensure.

5.0 Regulatory Evaluation e.

mination and operating ope test performed on VEGP Unit ng these candidates reperform the examination and D

Exemptions from the provisions Specific Exemptions.

R ovisions in 10 CFR ptions. That regulation The Commission may, regul initiative,, grant such e part as it determines etermines and are otherwise C

states:

Part 55 are governed by 10 CFR 55.11, upon application by an interested person, or upon its own may up exemptions ex from the requirements of the regulations in this etermine are authorized by law and will not endanger life or property wis 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.

Page 7 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses x 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 previous written examination and operating test successfully passed by the Unit 3 licensed operators is equivalent to any exam and operating test that would be given for Unit 4 licensure. The requirement governing uniformity is unaffected by the exemption request.

x The Commission will comply with subsection (b) through the licensing process for operator candidates at VEGP Unit 4. The requirement governing operator qualifications is unaffected by the exemption request.

Accordingly, this requested exemption is authorized by law.

ed b 5.2 This exemption will not endanger life or property erty The exemption does not pertain to the design, construction, constru co or operating AF procedures of VEGP Unit 4. Furthermore, safely operate the plant; the content more, as explained above, consistent with ensuring that the operators ntent and substance subs given for licensing the currentt Unit 3 operato compe a

ab perators will be competent the exemption is and fully trained to of the examinations and tests Enclosure 2 is equivalent to any operators in En 5.3 T

exam and operating test that hatt would be given for would allow credit for previously applied for Unit 4 licensure.

property.

This exemption fo U evioussly passing equivalent equiva on is consistent with the public interest Unit 4 licensure. The exemption exam and operating test to be ensure. Therefore, the exemption will not endanger life or DThe proposed R

posed exemption from the requirements of 10 CFR 55.33(a)(2) and 10 CFR 55.31(a)(3) would pre successfully

4. Requiring the examination re-take tion an evaluation of the

-take prev prevent currently licensed VEGP Unit 3 operators, who essfully completed the written examination and operating test on VEGP Unit 3, from having to re-re candidates who thoroughly prepared and successfully passed ng those ca ta them before receiving an operator license for VEGP Unit and the test to re-take them would be inequitable. The engineering h Unit 3 and Unit 4 differences demonstrated that the units are virtually identical, and the Training Needs Analysis of the differences showed no further training is required for the currently licensed Unit 3 operators to be capable of operating VEGP Unit 4 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, including preparation and approval of another exam, retesting the candidates, and having the regulator conduct an additional examination. The exemption would ensure training department resources were available to meet other site training needs.

Additionally, removing licensed operators from shift to perform duplicative examination and testing could impact the ongoing testing and future operation of Unit 3, while simultaneously challenging operations, training, and NRC resources.

Page 8 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses The additional resource expenditure would result in additional costs. Accordingly, to avoid such adverse impacts, the exemption is in the public interest.

Therefore, this exemption is consistent with 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).

The requested exemption would allow current VEGP EG Unit VEGP Un 3 licensed operators to receive credit for previously passed examinationation and operating operat test on VEGP Unit 3 to be applied for licensing for the nearlyly identical VEGP VE Unit 4. The exemption Un a) does not involve a significant hazardsT does not make any changes to the facility cility or operating procedures ds consideration zards consider under pro proce and :

und the standards set forth x

x AF in 10 CFR 50.92(c), in that it does alter the design, function, ction, granting this exemption oes not:

n, or operation of any plant equipment. Therefore, ption would ould not increase any previously evaluated accident.

create the e possibility acciden create any new accident initiators.

ossibility of a new or increas the probability or consequence of increa initiators Therefore, T granting this exemption does not o different kind of accident from any accident DR x

previously exceed usly evaluated.

exemption evaluated ceed or alter a design desig basis or safety limit. Therefore, granting this des xemption does not involve Therefore, re, a finding of b) does not involve olve any inv a significant reduction in a margin of safety.

o no significant hazards considerations is justified.

a 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 involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

c) does not 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) does not involve any facility changes or change any construction activities.

Therefore, there is no significant construction impact.

Page 9 of 10

ND-21-0427 Request for Exemption from Operator Written Examination and Operating Test for Unit 4 Licenses e) does not 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.

f) involves education, training, experience, qualification, requalification, or other employment suitability requirements.

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 VEGP Units 3 and 4 previously submitted Request st for Exemption Exem from Operator Written Examination and Operating Test (ML19030A226 26 dated December Decem 20, 20 2018), which was approved by the Commission on May 31, 2019 however, it is far less complex, since VEGP the same procedures, including those used T19 (ML19126A057).

(ML19126A057 (ML19126A05 P Units 3 and 7). This Th request is similar; an 4 are virtually sed for Emergency Emerg virt Planning.

Plan identical and have 7.0 References

3. NUREG-1021, Revision AF

1. 10 CFR Part 55, Operators s Licenses nse

2. NEI 06-13A, Revision 2, Template for a Industry Training Program Description an Ind vision 11, Operator Licensing Examination Standards for Power D

Reactors; Final

4. Atomic Energy R

all Report nergy Act of 1954, as amended,

5. NUREG-2103, Operators: Pressurized

6. ND-18-1126, Request qu W

a Section 107 0, Knowledge and Abilities Catalog for Nuclear Power Plant 03, Revision 0 essurized Water Reactors Westinghouse AP1000 for Exemption from Operator Written Examination and Operating Test, Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4 (ML19030A226)

Page 10 of 10

Southern Nuclear Operating Company ND-21-0427 Enclosure 2 Unit 4 Operator Candidates Requesting Credit for Unit 3 Written Wr Examination E and Operating Test st (This Enclosure ure consists con of 2 page, not including this cover page)