ML18340A087

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2018/12/06 Vogtle COL Docs - SNC Responses to Staff Comments Draft B Exemption Request for Transferring Operator Pass Letters from VCS to Vegp Docket
ML18340A087
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 12/06/2018
From:
NRC
To:
NRC/NRO/DLSE/LB4
References
Download: ML18340A087 (25)


Text

During tomorrow's call, we will discuss SNC responses to your comments, including changes to the draft exemption request. We intend to verbally discuss everything in the attached but are providing for your use to help follow along since we will be participating via phone.

Thanks!

Jordan, Following the 9/6 pre-submittal meeting, the attached draft B exemption request and draft B Block 25 Comments for NRC Form 398 have been prepared. No changes were made to the draft NRC Form 398 provided in support of the 9/6 pre-submittal meeting, but it is also attached for completeness. We would like to discuss draft B with staff during the public call on December 6, if possible. Please let me know if staff can support the requested 12/6 pre-submittal meeting for draft B. The documents have placeholders for personally identifiable information (PII), but all PII has been removed for the purposes of supporting the pre-submittal meeting. Thus, the entirety of the attached documents can be made available to the public; final submittal will have withheld PII.

I have also attached a word file of draft B with tracked changes as a courtesy to staff to make it easier to see what changes have been made.

Please let me know if you have questions.

Thanks,

            • VCS 2&3 Technical Specification UpgradeTechnical Specifications Upgrade

The Commission shall- a. prescribe uniform conditions for licensing individuals as operators of any of the various classes of production and utilization facilities(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;(a) Requirements for the approval of an initial application. -

(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. (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. 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.

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 licensee's requirements to be licensed as an operator or senior operator and of the facility licensee's 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 applicant's qualifications, and details on courses of instruction 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)]. 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 licensee's 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 licenseeThe 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. 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. 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. 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.