ML18340A087

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
Issue date:	12/06/2018
From:	NRC
To:	NRC/NRO/DLSE/LB4
References
Download: ML18340A087 (25)

Text

Vogtle PEmails From: Hoellman, Jordan Sent: Thursday, December 6, 2018 10:41 AM To: Vogtle PEmails

Subject:

SNC Responses to Staff Comments RE: Draft B Exemption Request for Transferring Operator Pass Letters from VCS to VEGP Docket Attachments: 2018-12-06 Staff Comments on Draft B Response.docx; 2018-12-06 ND-18-1126

_Operator Exam_Exemption_Draft C.docx Forwarding to ADAMS to support the December 6, 2018, public meeting discussion.

Thanks, Jordan From: Roberts, Kelli Anne [1]

Sent: Wednesday, December 05, 2018 5:07 PM To: Nist, Lauren <lauren.nist@nrc.gov>; Guthrie, Eugene <Eugene.Guthrie@nrc.gov>; Hoellman, Jordan

<Jordan.Hoellman2@nrc.gov>

Subject:

[External_Sender] RE: Staff Comments RE: Draft B Exemption Request for Transferring Operator Pass Letters from VCS to VEGP Docket During tomorrows 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!

Kelli Roberts l Southern Nuclear Operating Company Vogtle 3&4 Licensing Supervisor From: Hoellman, Jordan <Jordan.Hoellman2@nrc.gov>

Sent: Monday, December 3, 2018 12:00 PM To: Roberts, Kelli Anne <KROBERTS@southernco.com>; Patel, Chandu <Chandu.Patel@nrc.gov>

Cc: Nist, Lauren <lauren.nist@nrc.gov>; Guthrie, Eugene <Eugene.Guthrie@nrc.gov>; Fergen, Pamela S.

<X2PSFERG@SOUTHERNCO.COM>; Pugh, Amanda Louise <ALPUGH@southernco.com>; Agee, Stephanie Y.

<SYAGEE@southernco.com>; Vogtle PEmails <Vogtle.PEmails@nrc.gov>

Subject:

Staff Comments RE: Draft B Exemption Request for Transferring Operator Pass Letters from VCS to VEGP Docket Hi Kelli, Please see the attached staff comments regarding SNCs draft B exemption request and block 25 comments for transferring operator pass letters from VC Summer to Vogtle (ADAMS Accession No. ML18332A493). These comments will be used to support the discussions at the December 6, 2018, public meeting.

1

Please note that although we are providing feedback on these drafts, when the request is officially submitted, there may be other questions that need to be addressed in additional public meeting discussions or through the request for additional information (RAI) process.

Thank you, Jordan Jordan Hoellman Project Manager NRO / DLSE / LB4 U.S. Nuclear Regulatory Commission office: OWFN 08-C18 phone: (301) 415-5481 email: Jordan.Hoellman2@nrc.gov From: Roberts, Kelli Anne [2]

Sent: Friday, November 09, 2018 11:34 AM To: Hoellman, Jordan <Jordan.Hoellman2@nrc.gov>; Patel, Chandu <Chandu.Patel@nrc.gov>

Cc: Nist, Lauren <lauren.nist@nrc.gov>; Guthrie, Eugene <Eugene.Guthrie@nrc.gov>; Fergen, Pamela S.

<X2PSFERG@SOUTHERNCO.COM>; Pugh, Amanda Louise <ALPUGH@southernco.com>; Agee, Stephanie Y.

<SYAGEE@southernco.com>

Subject:

[External_Sender] Draft B Exemption Request for Transferring Operator Pass Letters from VCS to VEGP Docket

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, Kelli Roberts l Southern Nuclear Operating Company Vogtle 3&4 Licensing Supervisor 2

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 395 Mail Envelope Properties (SN6PR0901MB2366D4F8F0C75D5E7F44D6E5D5A90)

Subject:

SNC Responses to Staff Comments RE: Draft B Exemption Request for Transferring Operator Pass Letters from VCS to VEGP Docket Sent Date: 12/6/2018 10:40:38 AM Received Date: 12/6/2018 10:40:43 AM From: Hoellman, Jordan Created By: Jordan.Hoellman2@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None Post Office: SN6PR0901MB2366.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4552 12/6/2018 10:40:43 AM 2018-12-06 Staff Comments on Draft B Response.docx 38775 2018-12-06 ND-18-1126_Operator Exam_Exemption_Draft C.docx 224944 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

1. The scope of the exemption request should also include 55.31(a)(3), which requires each applicant for an operators license to 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.

Response: The letter was updated to include 10 CFR 55.31(a)(3). No changes were made to Form 398, Comment 25, because of this comment.

2. A. Please explain whether common means same (e.g., in Enclosure 1 of Draft B of letter ND-18-1126, Page 7/12 where it states, A review of testable knowledge and abilities for site-specific systems was conducted; the subject of all catalog items was traced back to lesson plans which were developed from a consistent set of AP1000 materials. Therefore, it was determined that all testable knowledge and abilities were included in common AP1000 systems training and/or procedure training.). If it does not mean same, please describe the differences between the training materials and procedures.

Response: As discussed on page 7 of ND-18-1126, training material (e.g., lesson plans, simulator scenarios, operating procedures), for operators at VCSNS Unit 2 and VEGP Unit 3, was created using procedures and references which were provided to the utilities by Westinghouse Electric Company (WEC). Following receipt of those documents, the training material was jointly developed by SNC and SCE&G.

VEGP acknowledges that minor differences between the training material of each site are expected as each training departments instructors enhance lessons to meet the background and experience of the utility. However, the training material had a common foundation (i.e., training material was developed from documents provided to both sites and was developed collaborative by the sites), was taught using common learning objectives, and used NUREG 2013 as guidance for common evaluation; a direct comparison of each training material document was not performed.

B. Also, Encl 1, Page 7/12 says, A review of testable knowledge and abilities for site-specific systems was conducted; the subject of all catalog items was traced back to lesson plans which were developed from a consistent set of AP1000 materials.

Therefore, it was determined that all testable knowledge and abilities were included in common AP1000 systems training and/or procedure training. Please explain whether SNC addressed any gaps in knowledge of the VEGP 3 site-specific systems.

Response: Although WLS and CWS have been evaluated to having no testable differences, since these systems are included in both WNAPC00032WAPP, Appendix B, and NUREG 2103, training has been conducted by SNC on these systems to the operators who received initial license training at VCSNS. This was completed to ensure any sitespecific material, with operational relevance, was taught based on the SNC plant design.

3. Please clarify whether the procedure exam discussed in Encl 1, Page 8/12 also tested knowledge of the emergency plan implementing procedures.

Response: All candidates passed an examination covering the EPIP.

The letter was updated to reflect this fact.

4. Encl 1, Page 8/12, says procedure gap training was conducted by self-study of VEGP 3 conduct of operations procedures. Please describe the nature of the subjects that were included in the conduct of operations procedures and training.

Response: In summary, the subjects included in Operations Procedure training were those which provided operators with Southern Nuclear Companys (SNCs) expectations for operators in conduct of operations for plant control, configuration management, and administration of duties.

Below is a complete list of the SNC procedures that were part of the Self-Study training and evaluation:

• B-ADM-OPS-001 (Operations Configuration Control)

• B-ADM-OPS-002 (Alarm Response and Status Control)

• B-ADM-OPS-003 (Recording Limiting Conditions for Operation)

• B-ADM-OPS-004 (Transient Response Procedure Users Guide)

• B-ADM-PLMO-002 (Minimum Shift Manning Requirements)

• B-ADM-PLMO-004 (Shift Relief)

• B-GEN-PLMP-020 (Emergency Classification Determination and Initial Action)

• B-GEN-PLMP-038 (Emergency Notifications)

• NMP-AD-003 (Equipment Clearance and Tagging)

• NMP-AD-006 (Infrequently Performed Tests and Evolutions)

• NMP-AD-008 (Applicability Determinations)

• NMP-AD-010 (10 CFR 50.59 Screenings and Evaluations)

• NMP-AD-012 (Operability Determinations and Functionality Assessments)

• NMP-AD-016 (Fatigue Management Program)

• NMP-AD-021 (Control Room Access and Decorum)

• NMP-AD-031 (SNC Reportability Roles, Responsibilities, and Fleet Requirements)

• NMP-AD-031-003 (Reportability Requirements - Plant Specific - Vogtle Electric Generating Plant)

• NMP-AP-001-003 (Review and Approval of Site Procedures)

• NMP-DP-001 (Operational Risk Awareness)

• NMP-ES-054 (Temporary Modifications)

• NMP-ES-084 (Design Control/Configuration Management Processes)

• NMP-GM-005-002 (Human Performance Tools Instruction)

• NMP-GM-006 (Work Management)

• NMP-GM-031 (On-Line Configuration Risk Management Program)

• NMP-OM-002 (Shutdown Risk Management)

• NMP-OS-007 (Conduct of Operations)

• NMP-OS-007-001 (Conduct of Operations Standards and Expectations)

• NMP-OS-007-005 (Site Specific Operations Expectations and Fleet Operations Policies)

• NMP-OS-007-007 (Rounds and Log keeping)

• NMP-OS-010 (Protected Train/Division and Protected Equipment Program)

• NMP-OS-016 (Use of eSOMS CRMP Interfaces)

• NMP-OS-017 (Severe Weather)

• NMP-TR-406 (License Administration)

• NMP-TR-417 (Initial License Training Program)

5. Encl 1, page 7/12 says that SNC looked for testable differences between the task lists.

Please explain whether the task list gap analysis was sufficient to also identify any significant differences in the technical specifications and operational characteristics between the two sites.

Response: Operator tasks identify that operators need to be able to follow TS; details of the TS are not covered in tasks. TS were covered as part of the common AP1000 systems training.

VCSNSs License Amendment 20, VCS 2&3 Technical Specification Upgrade, was issued on November 12, 2014. VEGPs License Amendment 13, Technical Specifications Upgrade, was issued on September 9, 2013. The upgraded Vogtle TS were used in the development of the common training material for both utilities. In addition, the upgraded TS were used in operator examinations.

6. Encl 1, Page 7/12, says SNC did a line by line comparison of tasks, all tasks were the same, but procedures varied. Please clarify if the procedures were those procedures cited in the task statements.

Response: Yes, the procedures noted were those procedures listed in the task statements.

The letter was updated to reflect this fact.

7. Encl 1, Page 10/12, please explain in the request how granting the exemption would avoid duplication of efforts and ensure trained personnel are available to support activities at VEGP Unit 3 and conserve NRC and licensee resources.

Response: Duplication of efforts consist of retraining the candidates; this includes approximately 18 months of classroom and simulator training involving operator candidates and training personnel. Licensee resources will be conserved as personnel will not have to build and validate an additional exam for these candidates; NRC resources are conserved as they will not be required to approve and administer an

additional exam. This exemption will ensure operators are available for startup activities such as fuel load.

The letter was updated with additional detail.

8. Encl 1, Page 10/12, says, Successful completion of the licensed examination and test indicated licensed operator candidates have learned to operate an AP1000 facility safely and competently. Successful completion of a licensed operator exam indicates candidates have learned to safely operate a particular facility; in this case, the facility is VC Summer Unit 2. The request should address how completion of that exam, plus any corrective actions SNC has taken to address knowledge gaps, demonstrate the candidates have learned to operate VEGP 3 safely and competently.

Response: The gap analysis conducted at SNC showed that testable knowledge and abilities (K&As), found in NUREG-2103, were primarily related to core AP1000 systems; only two site-specific systems in the catalog had K&As that were rated high enough to be testable. A review of testable knowledge and abilities for site-specific systems was conducted; the subject of all catalog items was traced back to lesson plans which were developed from a consistent set of AP1000 materials. Therefore, it was determined that all testable knowledge and abilities were included in common AP1000 systems training and/or procedure training.

Successful completion of the licensed examination and test, along with the actions SNC has taken in response to the gap analysis, indicate licensed operator candidates have learned to operate VEGP Unit 3 competently and safely; this ensures operation of the facility such that the public health and safety would not be adversely impacted.

The letter was updated to include the underlined addition above.

Michael J. Yox Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

Voglte 3&4 7825 River Road Waynesboro, GA 30830 Tel 706.848.6459 SeptemberDecember XX, 2018 Docket Nos.: 52-025 ND-18-1126 52-026 10 CFR 55.11 10 CFR 55.31(a)(3) 10 CFR 55.33(a)(2)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Mr. Frederick D. Brown Director, Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for Exemption from Operator Written Examination and Operating Test Ladies and Gentlemen:

Pursuant to 10 CFR 55.11, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests, on behalf of the former Virgil C. Summer Nuclear Station, Units 2 and 3 (VCSNS) Unit Commented [KAR1]: Draft A, Comment #1: Make it 2&3) licensed operator candidates listed in Enclosure 2, an exemption from the requirement of 10 clear that the pass letters were received for VCSNS CFR 55.33(a)(2), Written examination and operating test. Passing the requisite written Unit 2 and will be transferred to VEGP Unit 3.

examination and operating test is a requirement for approval of an initial application for a license Response: This change is made throughout the as specified in 10 CFR 55.33, Disposition of an initial application. An exemption from 10 CFR exemption request.

55.31(a)(3), is also requested on behalf of those candidates listed in Enclosure 2: the requirement Commented [FPS2]: Draft B, Comment #1: The scope involves submitting a written request, from an authorized representative of the facility licensee by of the exemption request should also include which the applicant will be employed, that the written exam and operating test be administered. 55.31(a)(3).

Following the closure of VCSNS 2&3, twelve licensed operator candidates trained at VCSNS 2&3 Commented [FPS3R2]: This change is made throughout the exemption request.

were hired by Vogtle Electric Generating Plant, Units 3 and 4 (VEGP 3&4). The twelve licensed operator candidates successfully completed a written examination and an operating test while employed at VCSNS 2&3.

Accordingly, in lieu of the requirements of 10 CFR 55.33(a)(2) and 10 CFR55.31(a)(3), these former VCSNS Unit 2&3 licensed operator candidates wish to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2&3, to VEGP 3&4 (License NumbersNumber NPF-91 and NPF-92, respectively).

The exemption will ensure SNC has a requisite number of licensed operators prior to fuel load for VEGP Unit 3.

U.S. Nuclear Regulatory Commission ND-18-1126 Page 2 of 4 to this letter presents SNCs detailed basis for the exemption. Enclosure 2 provides the list of operator candidates requesting transfer of their pass letters.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.

SNC requests NRC staff approval of the requested exemption by FebruaryApril 1, 2019.

Should you have any questions, please contact Ms. Kelli Roberts at (706) 848-6991.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the XXth of SeptemberDecember 2018.

Respectfully submitted, Michael J. Yox Regulatory Affairs Director Southern Nuclear Operating Company : Request for Exemption from Operator Written Examination and Operating Test : Operator Candidates Requesting Transfer of Their Pass Letters (Personally Identifiable Information- Withhold Under 10 CFR 2.390)

U.S. Nuclear Regulatory Commission ND-18-1126 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company 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)

Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. B. H. Whitley Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Ms. P. Reister Ms. K. Roberts Ms. P. Ridgway Mr. M. L. McCue Document Services RTYPE: VND.LI.L00 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 Georgia Mr. R. Dunn (w/o enclosure 2)

Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 2)

Ms. A. Whaley (w/o enclosure 2)

U.S. Nuclear Regulatory Commission ND-18-1126 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 2)

Mr. S. M. Jackson (w/o enclosure 2)

Dalton Utilities Mr. T. Bundros (w/o enclosure 2)

Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. C. Churchman (w/o enclosures)

Mr. M. Corletti (w/o enclosure 2)

Mr. M. L. Clyde (w/o enclosure 2)

Ms. L. Iller (w/o enclosure 2)

Mr. D. Hawkins (w/o enclosure 2)

Mr. J. Coward (w/o enclosure 2)

Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure 2)

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 2)

Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 2)

Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 2)

Mr. K. C. Greene, Troutman Sanders (w/o enclosure 2)

Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 2)

Mr. S. Franzone, Florida Power & Light (w/o enclosure 2)

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 ND-18-1126 Enclosure 1 Request for Exemption from Operator Written Examination and Operating Test (This Enclosure consists of 10 pages, including this cover page)

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test 1.0 Summary Description Pursuant to 10 CFR 55.11, Specific Exemptions, Southern Nuclear Operating Company (SNC) requests, on behalf of the former Virgil C. Summer Nuclear Station, Units 2 and 3 (VCSNS) Unit 2&3) licensed operator candidates listed in Enclosure 2, an exemption from the requirements 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 exam and operating test be administered. In lieu of theis requirement for approval of an initial application, former VCSNS 2&3 licensed operator candidates wish to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2&3, to Vogtle Electric Generating Plant, Units 3 and 4 (VEGP) Unit 3&4)..

2.0 Detailed Description Passing the requisite written examination and operating test is a requirement for approval of an initial application for a license as specified in 10 CFR 55.33, Disposition of an initial application. 10 CFR 55.33(a)(2) states, in part, The 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. Written tests for operators and senior operators contain a representative selection of knowledge, skills, and abilities needed to perform the operators respective duties. Representative samples of items to be tested on a written exam, for operators and senior operators, are provided in 10 CFR 55.41 or 10 CFR 55.43, respectively. Operating tests require the 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 during the operating tests is provided in 10 CFR 55.45.

SNC and South Carolina Electric & Gas Company (SCE&G) worked together to develop training material, for licensed operator candidates, that met the guidance in Nuclear Energy Institute (NEI)06-13A, Template for an Industry Training Program Description.

The criteria in NUREG-1021, Operator Licensing Examination Standards for Power Reactors; Final Report, was used to prepare written examinations and operating tests as required by 10 CFR 55. In conjunction with NUREG-1021, NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators, was utilized to ensure content-valid exams and tests. The Commission approved the content of all administered written examinations and operating tests.

Following the closure of VCSNS Units 2& and 3, twelve licensed operator candidates trained at VCSNS 2&3 were hired by VEGP 3&4. The twelve licensed operator candidates had successfully completed the written examination and operating test while employed at VCSNS 2&3. Following completion of the examination, the candidates were enrolled into a Systematic Approach to Training (SAT)-based continuing training program at VCSNS 2&3. The candidates are currently enrolled in a SAT-based continuing training program at Commented [KAR4]: Draft A, Comment #2:

VEGP 3&4. The continuing training program curriculum includes training on design and Clarify whether VCS applicants have been brought up procedure changes. to speed with VEGP applicants.

Response: Yes, added information in the next The AP1000 is designed to be a standard plant. VCSNS Unit 2&3 and VEGP Unit 3&4 are paragraph of similar age and power level, and share the same vendor and similar design. Training Page 2 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test material (e.g., lesson plans, simulator scenarios, operating procedures), for operators at VCSNS Unit 2 and VEGP Unit 3 was created jointly by SNC and SCE&G using common procedures and references provided to the utilities by Westinghouse Electric Company. A gap analysis, which included a review of the knowledge and abilities catalog and a comparison of operator task lists, was conducted. The only training needs identified during the analysis were related to procedures. Training on VEGPs conduct of operations procedures and emergency plan procedures was conducted for former VCSNS operator candidates to ensure there were no discontinuities in operator knowledge. The examinations administered at VCSNS Unit 2&3 and VEGP Unit 3&4 tested common AP1000 systems and two site-specific systems; the examinations did not test aspects of site-specific systems which are unique to one facility. Due to design standardization, as well as collaboration between VCSNS 2&3 and VEGP 3&4 during examination development, no gaps in the material tested have been identified. Commented [KAR5]: Draft A, Comment #3:

What did SNC do to come to the conclusion that there Accordingly, in lieu of the requirements of 10 CFR 55.33(a)(2) and 10 CFR 55.31(a)(3), are no gaps in material tested?

former VCSNS Unit 2&3 licensed operator candidates wish to transfer their test pass Response: Summary added here letters, for written examinations and operating tests taken at VCSNS Unit 2&3, to VEGP Unit 3 &4.

The exemption, from the requirement of 10 CFR 55.33(a)(2) and 10 CFR 55.31(a)(3), is being requested on behalf of the VEGP Unit 3&4 licensed operator candidates identified in Enclosure 2 of this letter.

3.0 Applicable Regulatory Requirements This section provides a summary of regulations applicable to this exemption request.

3.1 Atomic Energy Act of 1954, as amended (42 USC. 2137)

Section 107, Operators Licenses, states, in part, that:

The Commission 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; 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 -

Page 3 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test (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.

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

(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.

3.3 NUREG-1021, Revision 11, Operator Licensing Examination Standards for Power Reactors; Final Report ES-201, Initial 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 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:

Page 4 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test 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 operator or senior operator and of the facility licensees 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 applicants 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)].

ES-301, Preparing Initial Operating tests Section B, Background, states, in part, that:

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 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 (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 Page 5 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test ensure that the examination includes a representative sample of the items specified in the regulations.

3.4 NEI 06-13A, Revision 2, Template for an Industry Training Program Description NEI 06-13A was incorporated into the VEGP 3&4 UFSAR, Section 13.2A, by License Document Change Request, LCDR 2013-047.

Section 1.1, Licensed Operator Training, states, in part, that:

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.

3.5 NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators Section 1.1, 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 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 given at VCSNS Unit 2&3. The content and substance of the licensing examinations and tests given to licensed operator candidates at VCSNS Unit 2&3 and VEGP Unit 3&4 are developed from a consistent set of AP1000 materials and provide a common basis for evaluating candidates qualifications with respect to these substantially-similar facilities.

A training task list was created by the AP1000 owners group and adopted by both SNC and SCE&G. The knowledge and abilities defined in NUREG-2103, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors Page 6 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Westinghouse AP1000, were used in training and evaluating operators at both VCSNS 2&3 and VEGP 3&4.

• Training material (e.g., lesson plans, simulator scenarios, operating procedures),

for operators at VCSNS Unit 2&3 and VEGP Unit 3&4, was created using common procedures and references provided to the utilities by Westinghouse Electric Company. (WEC). Training material was jointly developed by SNC and SCE&G.

Training programs were established consistent with NEI 06-13A, Template for an Industry Training Program Description. , and ACAD 10-001, Guidelines for Initial Training and Evaluation of Licensed Operators at both VEGP and VCSNS.

• The content of the examinations and the tests developed by SNC and SCE&G complied with the requirements of 10 CFR 55 and NUREG-1021 and drew from a common set of AP1000 materials. (e.g., NUREG-2103).

• Examinations and tests were developed to assess the knowledge, skills, and abilities needed by operators to perform assigned tasks common to both VCSNS 2&3 and VEGP 3&4. Site-specific tasks were not trained on or evaluated for license purposes.Unit 2 and VEGP Unit 3. Commented [KAR6]: Draft A, Comment #4: What was done to conclude that site-specific tasks were not A gap analysis was conducted by VEGP senior reactor operator (SRO) certified training trained on or evaluated?

instructors and former VCSNS Unit 2&3 SRO candidates to identify areas where testable Response: Information added to gap analysis section differences may exist to inform whether gap training may be required for former VCSNS Unit 2&3 licensed operator candidates. Differences noted were limited to fleet and site- Commented [KAR7]: Draft A, Comment #5:

specific conduct of operations procedures. The gap analysis included a review and Clarify what gap analysis included.

comparison of the VEGP and VCSNS tasks lists. It also included a review of testable Response: Changes were made to clarify what knowledge and abilities, those with a catalog rating of 2.5 or greater, for site-specific information gives us confidence that the training systems (i.e., Circulating Water System and Liquid Radwaste System). material has a common basis and what was done in support of gap analysis.

An evaluation of the simulators used for the tests revealed no testable variances. The Commented [KAR8]: Draft A, Comment #7:

commission-approved simulation facilities used at VEGP 3&4 and VCSNS 2&3 were What about the emergency planning procedures designed by WEC. Minor differences between the simulation facilities were identified mentioned below? Those are not included in conduct of operations procedures.

during a gap analysis. VCSNS used the original WEC design where VEGP made minor tuning and system response related changes. The gap analysis concluded that differences Response: Changes made to clarify.

between the simulation facilities would not have affected operator responses or decision making. Commented [KAR9]: Draft A, Comment #6:

What was analyzed for simulator gap analysis?

• A training task list was created by the AP1000 owners group and adopted by both SNC and SCE&G. The gap analysis included comparing the sites task lists. A line Response: This evaluation was a qualitative assessment based on knowledge gained during CAS.

by line comparison of the task lists for VEGP and VCSNS revealed all VEGP This paragraph has been deleted, and a new operator tasks were included on the VCSNSs operator task list; however, multiple paragraph added to the continuing training section to procedures cited in the task statements varied by site. Testable differences were reference the CAS SERs.

limited to site-specific emergency planning and conduct of operations procedures. Commented [FPS10]: Draft B, Comment 6: Please clarify if the procedures were those procedures cited in

• The knowledge and abilities defined in NUREG-2103, Knowledge and Abilities the task statements.

Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors Westinghouse AP1000, were used in training and evaluating operators at both VCSNS 2&3 and VEGP 3&4. A review of testable knowledge and abilities for site-specific systems was conducted; the subject of all catalog items was traced back to lesson plans which were developed from a consistent set of AP1000 materials.

Page 7 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test Therefore, it was determined that all testable knowledge and abilities were included in common AP1000 systems training and/or procedure training.

Since the VCSNS Unit 2&3 candidates were hired by SNC, the following steps have been taken to address site-specific gaps in these candidates training and evaluation:

• Training on the VEGP 3&4 site Emergency Plan Implementing Procedure (EPIP) was delivered to the candidates identified in Enclosure 2 using the same material provided to VEGP Unit 3&4 initial licensed operator candidates in their post-NRC exam transition training. All candidates passed an examination covering the EPIP. Commented [FPS11]: Draft B, Comment 3: Please clarify whether the procedure exam discussed in Encl

• Procedure gap training was conducted by self-study of VEGP 3&4 conduct of 1, Page 8/12 also tested knowledge of the emergency operations procedures with instructors available to assist and answer questions. plan implementing procedures.

All candidates identified in Enclosure 2 completed procedure gap training and passed written examinations covering topics within the procedures.

All operator license candidates that successfully completed the written examination and operating test, including operators listed in Enclosure 2, have been enrolled in a SAT-based continuing training program to maintain proficiency of acquired knowledge and abilities to perform assigned tasks. The SAT-based continuing programs at VEGP Unit 3&4 and VCSNS Unit 2&3 are functionally equivalent. The continuing training is based on a continuous two-year cycle.

• 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.

The NRC approved the use of a Commission-Approved Simulation Facility (CAS) for administering operating tests at VEGP (ML16070A301). Likewise, the staff approved the use of a CAS for administering operating tests at VCSNS (ML16203A116). The staff concluded that the simulation facilities used by both sites replicated the AP1000 DCD predicted core model with sufficient scope and fidelity to support use in operator tests. As part of their continuing training, the candidates identified in Enclosure 2 are trained and evaluated on the VEGP CAS.

In summary, variances between the training programs of the two utilities were reconciled by conducting gap training on site-specific emergency and administrativeconduct of operations procedures. Written examinations administered at VCSNS Unit 2&3 were prepared using the same knowledge and abilities catalog used at VEGP Unit 3&4 and provide a common basis for evaluating candidates qualifications with respect to these substantially-similar AP1000 facilities. Following successful completion of the licensed Page 8 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test examination, the candidates identified in Enclosure 2 were enrolled in a SAT-based continuing training program. The results of the licensed examination and test indicate licensed operator candidates have learned to operate an AP1000 facility competently and safely. Therefore, transferring the test pass letters, for written examinations and operating tests taken at VCSNS Unit 2&3, to VEGP Unit 3&4, is an acceptable alternative to having these candidates reperform the examinations and tests at VEGP Unit 3&4.

5.0 Regulatory Evaluation Exemptions from the provisions in 10 CFR Part 55 are governed by 10 CFR 55.11, Specific Exemptions. That regulation states:

The Commission may, upon application by an interested person, or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property and are otherwise 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.

• 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 licensing written examination and operating test taken by the operator candidates from VCSNS Unit 2&3 are essentially equivalent to those taken by the VEGP Unit 3&4 operator candidates. The requirement governing uniformity is unaffected by the exemption request.

• The Commission will comply with subsection (b) through the licensing process for operator candidates at VEGP Unit 3&4. The requirement governing operator qualifications is unaffected by the exemption request.

Accordingly, this requested exemption is authorized by law.

5.2 This exemption will not endanger life or property The exemption does not pertain to the design, construction, or operating procedures of VEGP Unit 3&4. Furthermore, as explained in Section 3 above, the Page 9 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test exemption is consistent with ensuring that the operators will be competent and fully trained to safely operate the plant; the content and substance of the examinations and tests given at VCSNS Unit 2&3 and VEGP Unit 3&4 are comparable. The exemption would allow the pass letters of former VCSNS Unit 2&3 operator candidates to be transferred from VCSNS Unit 2&3 to VEGP Unit 3&4. Therefore, the exemption will not endanger life or property.

5.3 This exemption is consistent with the public interest.

The proposed exemption from the requirements of 10 CFR 55.33(a)(2) and 10 CFR55.31(a)(3), would prevent former VSCNS operator candidates who successfully completed the written examination and operating test while employed by VCSNS from having to re-take them before receiving an operator license for VEGP Unit 3&4. Requiring those candidates who thoroughly prepared and successfully completed the examination and the test to re-take them would be inequitable. The gap analysis demonstrated that the VCSNS operator candidates received equivalent training to those candidates at VEGP. Successful completion of the licensed examination and test, along with the actions SNC has taken in response to the gap analysis, indicate licensed operator candidates have learned Commented [FPS12]: Draft B, Comment 8: The to operate an AP1000 facilityVEGP Unit 3 competently and safely; this ensures request should address how completion of that exam, operation of the facility such that the public health and safety would not be plus any corrective actions SNC has taken to address knowledge gaps, demonstrate the candidates have adversely impacted. The exemption further supports the public interest by learned to operate VEGP 3 safely and competently.

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 retraining the candidates and having the regulator prepare and validate an additional examination, and Commented [FPS13]: Draft B, Comment 7: explain ensure trained personnel are available to support activities at VEGP Unit 3&4 how granting the exemption would avoid duplication of including fuel load. efforts and ensure trained personnel are available to support activities at VEGP Unit 3 and conserve NRC and licensee resources.

Additionally, a delay in the licensing of these operators could make it more difficult to ensure that an adequate number of licensed operators are available when construction is completed, potentially resulting in a delay in operation of the plant.

A delay in operation would result in additional costs and would deprive the region of an earlier carbon-free source of electrical generation. Accordingly, to avoid such adverse impacts, the exemption is in 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)(vi)(E).

The requested exemption would allow former VCSNS Unit 2&3 licensed operator candidates to transfer their test pass letters, for written examinations and operating tests taken at VCSNS Unit 2&3, to VEGP Unit 3&4. The exemption does not make any changes to the facility or operating procedures and does not:

Page 10 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test a) involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), in that it does not:

• alter the design, function or operation of any plant equipment. Therefore, granting this exemption would not increase the probability or consequence of any previously evaluated accident.

• create any new accident initiators. Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

• exceed or alter a design basis or safety limit. Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Therefore, a finding of no significant hazards considerations is justified.

b) involve any 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) 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) involve any facility changes or change any construction activities. Therefore, there is no significant construction impact.

e) 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.

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 None 7.0 References

1. 10 CFR Part 55, Operators Licenses

2. NEI 06-13A, Revision 2, Template for an Industry Training Program Description Page 11 of 12

ND-18-1126 Request for Exemption from Operator Written Examination and Operating Test

3. NUREG-1021, Revision 11, Operator Licensing Examination Standards for Power Reactors; Final Report

4. Atomic Energy Act of 1954, as amended, Section 107

5. NUREG-2103, Revision 0, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors Westinghouse AP1000

6. NRC Letter, Safety Evaluation by the Office of New Reactors Related to the Request for a Commission Approved Simulator for Vogtle Electric Generating Plant Units 3 and 4, dated March 29, 2016 [ML16070A301]

7. NRC Letter, Safety Evaluation by the Office of New Reactors Related to the Request for a Commission Approved Simulator for Virgil C. Summer Nuclear Station Units 2 and 3, dated August 3, 2016 [ML16203A116]

Page 12 of 12

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 ND-18-1126 Enclosure 2 Operator Candidates Requesting Transfer of Their Pass Letters (Personally Identifiable Information- Withhold Under 10 CFR 2.390)

(This Enclosure consists of 2 pages, including this cover page)

ND-18-1126 Operator Candidates (Personally Identifiable Information- Withhold Under 10 CFR 2.390)

Operator Candidate Docket Number Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Candidate 55-Page 2 of 2