ML23096A179

NRR E-mail Capture - Request for Additional Information Diablo Canyon Exemption Request Regarding Senior Reactor Operator License Application

ML23096A179
Person / Time
Site:	Diablo Canyon
Issue date:	04/06/2023
From:	Samson Lee NRC/NRR/DORL/LPL4
To:	Richardson M Pacific Gas & Electric Co
References
L-2023-LLE-0006
Download: ML23096A179 (5)

Text

From: Samson Lee Sent: Thursday, April 6, 2023 12:03 PM To: 'Richardson, Michael'

Subject:

Request for additional information: Diablo Canyon exemption request regarding Senior Reactor Operator license application (EPID: L-2023-LLE-0006)

Background:

By letter dated February 22, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23073A032), Pacific Gas and Electric Company (PG&E) submitted an exemption request for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP), regarding Senior Reactor Operator (SRO) license application. The NRC staff has reviewed the exemption request and determined that additional information is required to complete the review. The NRC staffs requests for additional information (RAIs) are listed below. The staff may have additional RAIs. The PG&E staff determined that a draft RAI clarification call was unnecessary. The PG&E staff requested, and NRC staff agreed, to an RAI response by April 24, 2023.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if PG&E does not respond to this request by the agreed upon date or provide an acceptable alternate date, the NRC staff may deny PG&Es application for exemption under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If circumstances result in the need to revise the agreed upon response date, please contact me at (301) 415-3168 or via e-mail Samson.Lee@nrc.gov.

RAI #1 Regulatory Requirements 10 CFR 55.11, Specific Exemptions, states, in part:

The Commission may grant such exemptions from the requirements of the regulations in this part as it determines will not endanger life or property.

10 CFR 55.47(a)(1) and (3) state:

(1) Has had extensive actual operating experience at a comparable facility, as determined by the Commission, within two years before the date of application; (3) Has learned the operating procedures for and is qualified to operate competently and safely the facility designated in the application.

Potential Issue Regarding the application of the 10 CFR 55.47 criteria to the specifically named individual (whose name is redacted and replaced with (( ))), the exemption request states the following:

Upon return to DCPP, Mr. (( )) successfully completed "Additional Training" under 10 CFR 55.59(b), and took and successfully passed both a facility-prepared written examination and operating test-both comparable to the NRC-administered exams he would be required to take without approval of this exemption request. Combined, these ensure that he is up-to-date in the licensed operator requalification training program, including generic fundamentals examination topics. A gap analysis, which included a review of the knowledge and abilities [K/As] catalog and a comparison of operator task lists, was also conducted for the duration of the individual's absence. Training has been provided to ensure there were no discontinuities in Mr. (( )) knowledge.

There is a lack of detail regarding the scope of additional training, the description of the facility-prepared written examination and operating test, the scope of activities conducted to ensure the individual is up-to-date in the licensed operator requalification training program, the gap analysis conducted, and what training was provided to ensure there were no discontinuities in the individuals knowledge.

Potential Significance While the regulation allows up to two years to occur between licensing actions, the individual has had four years and three months between being licensed at DCPP and the requested exemption. The scope of the requested exemption is well beyond the applicable criteria as stated in NUREG-1021, Revision 12, Operator Licensing Examination Standards for Power Reactors, September 2021 (ML21256A276), Examination Standard ES-2.2; therefore, additional information is required to satisfy the exemption.

Based on the scope of time between licensing actions at DCPP, the material provided does not provide enough detail to adequately assess the scope of training conducted for the individual to make a determination on whether the individual has learned the operating procedures for and is qualified to operate competently and safely the facility designated in the application.

Information Request In order to validate the requirements of 10 CFR 55.47(a)(1) and (3), the NRC staff must review the extent of Additional Training that the individual received since returning to DCPP.

Please provide the following information:

1. The scope of Additional Training as referenced in the exemption request.

2. The facility-prepared written examination and operating test or the details regarding the facility-prepared written examination and operating test, including the following:

a. Origin of the exam

b. Number of questions

c. Open or closed reference

d. Scope of content (random selection of K/As from the K/A Catalog, or otherwise selected, and basis)

e. Time allowed

f. Exam security measures used

g. Number of operating test job performance measures (JPM) given

h. JPM sampling methodology

i. Number of simulator scenarios given

j. Grading criteria used

k. Summary of performance deficiencies or weaknesses identified during the examinations, both written and operating, and subsequent actions to close those gaps

3. The scope of generic fundamentals examination topics.

4. The scope of the gap analysis.

5. Any other training or activity that the individual received upon returning to DCPP whose intent was to refamiliarize the individual with the operation of DCPP.

RAI #2 Regulatory Requirements 10 CFR 55.11, Specific Exemptions, states, in part:

The Commission may grant such exemptions from the requirements of the regulations in this part as it determines are in the public interest.

Potential Issue The exemption request states the following:

• it would increase the number of licensed SROs, and thereby improve operational and staffing flexibility at the station;

• it would reduce the burden on the existing DCPP SRO staff; and There is no additional information in the exemption request detailing what the current status is of the number of licensed SROs, the operational and staffing flexibility of the SROs, and the burden on the existing DCPP SRO staff.

Potential Significance Lack of detail in the exemption request detailing how approval of an exemption, pursuant to 10 CFR 55.11, in the waiving of 10 CFR 55.47 requirements for issuance of a license, is in the public interest challenges the NRCs ability to adequately review the requested exemption.

Information Request Please provide the following information:

1. What are the current operational challenges related to SRO staffing at DCPP.

2. The documented overtime/fatigue rule limitation/minimum operational staffing conditions currently existing at DCPP for SROs.

3. Specific details regarding the burden on current DCPP staff that this exemption would alleviate.

Docket Nos. 50-275 and 50-323

Hearing Identifier: NRR_DRMA Email Number: 2033 Mail Envelope Properties (SA1PR09MB8653B9247314F30BB6E7F8EB9A919)

Subject:

Request for additional information Diablo Canyon exemption request regarding Senior Reactor Operator license application (EPID L-2023-LLE-0006)

Sent Date: 4/6/2023 12:03:19 PM Received Date: 4/6/2023 12:03:00 PM From: Samson Lee Created By: Samson.Lee@nrc.gov Recipients:

"'Richardson, Michael'" <MJRm@pge.com>

Tracking Status: None Post Office: SA1PR09MB8653.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 7018 4/6/2023 12:03:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: