RA-19-0006, License Amendment Application to Relocate Technical Specification Unit/Facility Staff Qualification ANSI N18.1-1971, ANSI/ANS-3.1-1978 and ANSI/ANS-3.1-1981 Requirements to the Duke Energy Corporation Quality Assurance Program Description

License Amendment Application to Relocate Technical Specification Unit/Facility Staff Qualification ANSI N18.1-1971, ANSI/ANS-3.1-1978 and ANSI/ANS-3.1-1981 Requirements to the Duke Energy Corporation Quality Assurance Program Description

ML19189A033
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	07/08/2019
From:	Snider S Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0006
Download: ML19189A033 (28)

Text

STEVE SNIDER Vice President Nuclear Engineering 526 South Church Street, EC-07H Charlotte, NC 28202 980-373-6195 Steve.Snider@duke-energy.com 10 CFR 50.90 Serial: RA-19-0006 July 8, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CATAWBA NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-413 AND 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-369 AND 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17 OCONEE NUCLEAR STATION, UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-269, 50-270 AND 50-287 / RENEWED LICENSE NOS. DPR-38, DPR-47 AND DPR-55 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

LICENSE AMENDMENT APPLICATION TO RELOCATE TECHNICAL SPECIFICATION UNIT/FACILITY STAFF QUALIFICATION ANSI N18.1-1971, ANSI/ANS-3.1-1978 AND ANSI/ANS-3.1-1981 REQUIREMENTS TO THE DUKE ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION (DUKE-QAPD-001-A)

Reference:

1. NRC Administrative Letter 95-06: Relocation of Technical Specification Administrative Controls Related to Quality Assurance Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as Duke Energy, hereby requests an amendment to the Technical Specifications (TS) for Brunswick Steam Electric Plant (BSEP), Units 1 and 2; Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS), Units 1 and 2; Oconee Nuclear Station (ONS), Units 1, 2, and 3; Shearon Harris Nuclear Power Plant (HNP),

Unit 1; and H. B. Robinson Steam Electric Plant (RNP), Unit 2.

( ~ DUKE ENERGY

U.S. Nuclear Regulatory Commission RA-19-0006 Page 2 The proposed changes will amend the TS Unit/Facility staff qualification requirements in either ANSI N18.1-1971, "American National Standard for Selection and Training of Nuclear Power Plant Personnel," ANSI/ANS-3.1-1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel," the September 1979 draft of ANS 3.1, or ANSI-ANS-3.1-1981, "Selection, Qualification and Training of Personnel for Nuclear Power Plants," and relocate them to the Duke Energy Corporation Quality Assurance Program Description (QAPD) consistent with the NRC Administrative Letter 95-06 (Reference 1) guidance. to this letter provides a detailed evaluation of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides the existing QAPD marked up to show the proposed changes. The retyped TS pages will be provided to the NRC immediately prior to issuance of the approved amendments.

There are no regulatory commitments contained in this letter.

Duke Energy requests review and approval of this license amendment request within one year of acceptance. The amendment shall be implemented within 120 days following approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina and South Carolina state officials.

If you should have any questions regarding this submittal, or require additional information, please contact Art Zaremba, Director - Nuclear Fleet Licensing, at 980-373-2062.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

.J"u.,,\\~

t:g., ao\\C\\

Sincerely, Steve Snider Vice President - Nuclear Engineering NDE Attachments: 1. Evaluation of the Proposed Change

2. Proposed Technical Specification Page Markups

3. Duke Energy Corporation Quality Assurance Program Description Marked-Up

U.S. Nuclear Regulatory Commission RA-19-0006 Page 3 cc (with Attachments):

L. Dudes, USNRC Region II - Regional Administrator V. Cusumano, USNRC - Chief, TS Branch G. Smith, USNRC Senior Resident Inspector - BSEP J. D. Austin, USNRC Senior Resident Inspector - CNS G. A. Hutto, USNRC Senior Resident Inspector - MNS E. Crowe, USNRC Senior Resident Inspector - ONS G. Retterer, USNRC Senior Resident Inspector - HNP M. Fannon, USNRC Senior Resident Inspector - RNP D. Galvin, NRR Project Manager - BSEP M. Mahoney, NRR Project Manager - CNS & MNS A. L. Klett, NRR Project Manager - ONS M. C. Barillas, NRR Project Manager - HNP N. Jordan, NRR Project Manager - RNP A. Gantt, Chief, Bureau of Radiological Health (SC)

A. Wilson, Attorney General (SC)

W. L. Cox, III, Section Chief, North Carolina Department of Health and Human Services, RP Section (NC)

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management (SC)

Chairman, North Carolina Utilities Commission

Evaluation of the Proposed Change

Subject:

LICENSE AMENDMENT APPLICATION TO RELOCATE TECHNICAL SPECIFICATION UNIT/FACILITY STAFF QUALIFICATION ANSI N18.1-1971, ANSI/ANS-3.1-1978 AND ANSI/ANS-3.1-1981 REQUIREMENTS TO THE DUKE ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION (DUKE-QAPD-001-A)

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1 Proposed Changes

2.2 Background

3.

TECHNICAL EVALUATION

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions

5.

ENVIRONMENTAL CONSIDERATION

6.

REFERENCES

U.S. Nuclear Regulatory Commission RA-19-0006 Page 2

1.

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, Application for amendment of license or construction permit, Duke Energy is requesting that the Technical Specifications (TS), Appendix A of the facility operating licenses for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP); Catawba Nuclear Station, Units 1 and 2 (CNS); McGuire Nuclear Station, Units 1 and 2 (MNS); Oconee Nuclear Station, Units 1, 2 and 3 (ONS); Shearon Harris Nuclear Power Plant, Unit 1 (HNP);

and H. B. Robinson Steam Electric Plant, Unit 2 (RNP) under Facility Operating License Nos.

DPR-71 and DPR-62; NPF-35 and NPF-52; NPF-9 and NPF-17; DPR-38, DPR-47, and DPR-55; NPF-63; and DPR-23, respectively, be amended as proposed to permit relocation of the Unit/Facility Staff Qualification ANSI N18.1-1971, ANSI/ANS-3.1-1978, September 1979 draft of ANS 3.1, and ANSI-ANS-3.1-1981 (References 1-4) to the Duke Energy Corporation Quality Assurance Program Description (QAPD) (Reference 5).

2.

DETAILED DESCRIPTION 2.1 Proposed Changes The specific TS changes for each station are also shown in Attachment 2. For the purpose of general discussion, the proposed changes are as follows:

Brunswick Steam Electric Plant, Units 1 and 2 (BSEP)

BSEP TS 5.3.1 currently states:

Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for:

a. The manager of the radiation control function, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

b. The shift technical advisor, who shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant during transients and accidents; and

c. The operations manager, who shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding holding an SRO license.

The proposed change will revise BSEP TS 5.3.1 to read as follows:

Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Catawba Nuclear Station, Units 1 and 2 (CNS)

CNS TS 5.3 currently states:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except:

U.S. Nuclear Regulatory Commission RA-19-0006 Page 3

1. The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

2. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

The proposed change will revise CNS TS 5.3 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

McGuire Nuclear Station, Units 1 and 2 (MNS)

MNS TS 5.3 currently states:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except:

1. The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

2. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

The proposed change will revise MNS TS 5.3 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Oconee Nuclear Station, Units 1, 2, and 3 (ONS)

ONS TS 5.3 currently states:

U.S. Nuclear Regulatory Commission RA-19-0006 Page 4 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications described in Section 4 of ANSI/ANS-3.1-1978, Selection and Training of Nuclear Power Plant Personnel except:

1. The Operations Manager shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis.

2. The Assistant Operations Manager - Shift shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training on a one-for-one time basis.

3. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

The proposed change will revise ONS TS 5.3 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Shearon Harris Nuclear Power Plant, Unit 1 (HNP)

HNP TS 6.4 currently states:

A retraining and replacement training program for the unit staff shall be maintained and shall meet or exceed the requirements and recommendations of the September 1979 draft of ANS 3.1, with the exceptions and alternatives noted in Section 1.8 (Personnel Selection and Training) of the FSAR. The initial and requalification training for licensed personnel is through an accredited program based on the systematic approach to training, as allowed by 10 CFR 55.31, 10 CFR 55.59, and Generic Letter 87-07.

The proposed change will revise HNP TS 6.4 to read as follows:

A retraining and replacement training program for the unit staff shall be maintained and shall meet or exceed the requirements referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A.

U.S. Nuclear Regulatory Commission RA-19-0006 Page 5 H. B. Robinson Steam Electric Plant, Unit 2 (RNP)

RNP TS 5.3.1 currently states:

Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the manager of the radiation control function, who shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981, and the STA, who shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

The proposed change will revise RNP TS 5.3.1 to read as follows:

Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

2.2 Background

The existing TS requirements for unit/facility staff qualifications are based on NRC endorsed industry standards to ensure that a licensees staff is appropriately qualified and trained for their respective positions. Currently, Regulatory Guide (RG) 1.8 Revision 3, May 2000, Qualification and Training of Personnel for Nuclear Power Plants, endorses ANSI/ANS-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plant, with certain clarifications, additions, and exceptions. Duke Energy desires to relocate to the QAPD the TS ANSI/ANS-3.1-1978, ANSI/ANS-3.1-1981, September 1979 draft of ANSI 3.1, and ANSI N18.1-1971 requirements (References 1-4) in order to eliminate future license amendment requests due only to upgrades to future revisions to the ANSI/ANS 3.1 standard and RG 1.8.

3.

TECHNICAL EVALUATION The proposed change will relocate the TS Unit/Facility Staff Qualification ANSI N18.1-1971, ANSI/ANS-3.1-1978, September 1979 ANS 3.1, and ANSI-ANS-3.1-1981 requirements (References 1-4) for nuclear plant personnel from the TS to the Duke Energy QAPD. The requirements will be relocated verbatim to the QAPD.

This LAR does not change any current staff ANSI qualification requirements for any of the stations included in this submittal and is only an administrative TS change.

10 CFR 50.36(c)(5), requires TS to include items in the administrative controls category. Items include provisions relating to organization and management, procedures, recordkeeping, review and audit and reporting to assure operation of the facility in a safe manner. In 1995, the NRC acknowledged that many license amendments were being processed (e.g., organizational changes, position title changes, organization description changes, procedure review process, etc.) to relocate TS items to the licensee's quality assurance plan. The items being relocated from TS did not satisfy the criteria of 10 CFR 50.36 for inclusion as a limiting condition for operation and were adequately controlled by other regulations and related licensee programs.

The NRC issued Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," to address this issue and to provide additional guidance for relocating TS administrative controls to the licensee's quality assurance

U.S. Nuclear Regulatory Commission RA-19-0006 Page 6 plan. The proposed changes are consistent with the guidance in AL 95-06 for relocating a licensee's TS requirements to its quality assurance plan.

The unit/facility staff qualifications do not satisfy the criteria of 10 CFR 50.36 for inclusion in TS as a limiting condition for operation and are adequately controlled by other regulations and Duke Energy training programs. Duke Energy meets the training requirements specified in 10 CFR 55, "Operators' Licenses," 10 CFR 50.120, Training and qualification of nuclear power plant personnel," and NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." In addition, on March 20, 1985, the NRC issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, which endorsed the training accreditation program developed by INPO, in association with National Academy for Nuclear Training (NANT}. The NRC has documented discussion, approval, and acceptance of NANT guidelines in RIS 01-001, "Eligibility of Operator License Applicants," and NUREG 1021, "Operator Licensing Examinations Standards for Power Reactors." Duke Energy training programs employ the systematic approach to training (SAT) required by 10 CFR 50.120 as embodied in the INPO NANT standards for plant staff personnel and their qualifications.

In summary, the proposed changes do not change current staff qualification requirements. The unit/facility staff qualification requirements are identical between the current plant's TS and the proposed marked-up Duke Energy QAPD (Attachment 3). Future changes to the Duke Energy QAPD are controlled by compliance changes to 10 CFR 50.54(a).

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the proposed change.

10 CFR 50.36 10 CFR 50, Domestic Licensing of Production and Utilization Facilities, Section 36, Technical specifications, Paragraph (c)(5), Administrative controls, requires provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting to be included in the technical specification that are necessary to assure operation of the facility in a safe manner. The proposed change conforms to 10 CFR 50.36(c)(5) 10 CFR 50.120 10 CFR 50, Domestic Licensing of Production and Utilization Facilities, Section 120, Training and qualification of nuclear power plant personnel, requires that each nuclear power plant applicant for and holder of an operator license shall establish, implement, and maintain the training and qualification programs that are derived from a systems approach to training as defined in 10 CFR 55.4. The proposed change conforms to 10 CFR 50.120 requirements.

10 CFR 55 10 CFR 55, Operators Licenses, Subpart D, Applications, requires that operator license applications include information concerning an individuals education, experience, and other related matters to provide evidence and certification that the applicant has successfully

U.S. Nuclear Regulatory Commission RA-19-0006 Page 7 completed the facility licensees training program that is based on a systems approach to training. The proposed change conforms to 10 CFR 55 requirements.

NUREG-1021, Revision 11 NUREG-1021, Operator Licensing Examination Standards For Power Reactors, established the policies, procedures, and practices for examining licensees and applicants for reactor operator and senior reactor operator licenses at nuclear power reactor facilities under 10 CFR Part 55, Operators Licenses. The Duke Energy operator training program meets the current requirements of NANT Academy Document, ACAD 10-001. The proposed change conforms to NUREG-1021 requirements.

Regulatory Guide 1.8, Revision 3 Regulatory Guide (RG) 1.8, Qualification and Training of Personnel for Nuclear Power Plants, describes a method that the NRC staff finds acceptable for complying with the NRCs regulations regarding training and qualification of nuclear power plant personnel. The proposed change conforms to RG 1.8 (Revisions 1-3), as identified in current TS staff qualifications requirements, and are being relocated verbatim to the QAPD.

Administrative Letter (AL) 95-06, Relocation of Technical Specification Administrative Controls Related to Quality Assurance Licensees have been requesting amendments to technical specifications that are located in the "administrative controls" section and are related to quality assurance programs. Licensees have frequently requested amendments to these specifications because they contain detailed information that is affected by organizational and process changes. Many licensees have revised their technical specifications to remove excessive detail, thereby gaining flexibility in making organizational changes without the need for a license amendment.

In addition, recent amendment requests related to quality assurance have also followed the trend for other technical specifications and have included moving requirements to licensee controlled documents and programs. The quality assurance program is a logical candidate for such relocations due to the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the existence of U.S. Nuclear Regulatory Commission-approved quality assurance plans and commitments to industry quality assurance standards, and the established quality assurance program change control process in 10 CFR 50.54(a). The relocation of technical specification requirements in cases where adequate controls are provided by such other methods can reduce the resources spent by licensees and the U.S. Nuclear Regulatory Commission staff in preparing and reviewing license amendment requests.

The proposed change to relocate TS staff ANSI qualification requirements conform to AL 95-06 in that the ANSI standards being relocated are considered quality assurance standards that do not satisfy the criteria of 10 CFR 36 for inclusion as a limiting condition for operation and are adequately controlled by other regulations (e.g., 10 CFR 50.120 and 10 CFR 55) and license programs (Duke Training Programs that comply with INPO NANT standards).

U.S. Nuclear Regulatory Commission RA-19-0006 Page 8 4.2 Precedent The proposed change is consistent with NRC-approved license amendments issued to Exelon Generation Company, LLC on August 2, 2018 (NRC ADAMS Accession No. ML18206A282).

The amendments revise the technical specifications for each facility to relocate the licensee's staff qualification requirements to the Exelon Quality Assurance Topical Report (References 6 and 7).

The proposed change is also consistent with NRC-approved license amendments issued to Tennessee Valley Authority (TVA) on March 27, 2017 (Amendment Numbers 298, 322, and 282) for the Browns Ferry Nuclear Plant and (Amendment Numbers 338 and 331) for the Sequoyah Nuclear Plant (NRC ADAMS Accession No. ML17034A360). Both plants revised their TS 5.3, Unit Staff Qualifications, to delete the references to RG 1.8 Revision 2, and replace them with references to the TVA Nuclear Quality Assurance Plan (References 8 and 9).

4.3 No Significant Hazards Consideration Analysis Duke Energy requests approval of a proposed change to the Brunswick Steam Electric Plant, Units 1 and 2 (BSEP); Catawba Nuclear Station, Units 1 and 2 (CNS); McGuire Nuclear Station, Units 1 and 2 (MNS); Oconee Nuclear Station, Units 1, 2 and 3 (ONS); and H. B. Robinson Steam Electric Plant, Unit 2 (RNP) Technical Specifications (TS) 5.3, [Unit/Facility] Staff Qualifications, as well as, the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) TS 6.4, Training. The proposed change will relocate the TS Unit/Facility staff qualification requirements from either ANSI N18.1-1971, American National Standard Selection and Training of Nuclear Power Plant Personnel, ANSI/ANS-3.1-1978, Selection and Training of Nuclear Power Plant Personnel, Draft Standard ANS 3.1, dated December 6, 1979, or ANSI-ANS-3.1-1981, Selection, Qualification and Training of Personnel for Nuclear Power Plants, to the Duke Energy Corporation Quality Assurance Program Description (QAPD).

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as described below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change is administrative in nature, does not make any physical changes to the plants, and does not alter accident analysis assumptions, add any initiators or affect the function of plant systems, or the manner in which systems are operated, maintained, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems and components relied upon to mitigate the consequences of postulated accidents. The unit/facility staff qualification requirements remain the same and are being relocated from the Technical Specifications (TS) to the Duke Energy Quality Assurance Program Description (QAPD).

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

U.S. Nuclear Regulatory Commission RA-19-0006 Page 9

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve changes to unit/facility staff selection, qualification and training programs. The proposed change is administrative in nature and does not impact physical plant systems. The qualification standards are being relocated from the TS to the Duke Energy QAPD. As a result, the ability of the plant to respond to and mitigate accidents is unchanged by the proposed change. The proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change is administrative in nature. The proposed change does not affect plant design, hardware, system operation, or procedures for accident mitigation system.

The proposed change does not impact any plant safety margins that are established in existing limiting conditions for operation, limiting safety systems settings and specified safety limits. There is no change in the established safety margins of these systems. The proposed change does not impact the performance or proficiency requirements for licensed operators or unit/facility staff, since the qualification standards are not changing and are only being relocated from the TS to the Duke Energy QAPD. As a result, the ability of the plant to respond to and mitigate accidents is unchanged by the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.

ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendments do not change a requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20 and do not change surveillance requirements. The proposed

U.S. Nuclear Regulatory Commission RA-19-0006 Page 10 amendments relocate TS requirements for Unit/Facility Staff Qualifications to the Duke Energy QAPD. The proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.

REFERENCES

1.

ANSI N18.1-1971, American National Standard for Selection and Training of Nuclear Power Plant Personnel, approved by ANSI in 1971.

2.

ANSI/ANS-3.1-1978, American National Standard for Selection and Training of Nuclear Power Plant Personnel, approved by ANSI on January 17, 1978.

3.

ANSI/ANS-3.1 Draft of September 1979.

4.

ANSI-ANS-3.1-1981, Selection, Qualification and Training of Personnel for Nuclear Power Plants, approved by ANSI on February 17, 1981.

5.

Duke Energy Corporation Quality Assurance Program Description (QAPD).

6.

Exelon Fleet Issuance of Amendments to Relocate the Staff Qualification Requirements (EPID L-2018-LLA-0053), dated August 2, 2018 (ADAMS Accession No. ML18206A282).

7.

Exelon Fleet License Amendment Request to Relocate Technical Specification Unit/Facility/Plant Staff Qualification ANSI N18.1-1971 and ANSl/ANS-3.1-1978 Requirements to the Exelon Quality Assurance Topical Report (QATR}, dated March 1, 2018 (ADAMS Accession No. ML18060A266).

8.

Browns Ferry Nuclear Plant, Units 1, 2 and 3, and Sequoyah Nuclear Plant, Units 1 and 2 - Issuance of Amendments Re: Changes to Technical Specification 5.3, Unit Staff Qualifications (CAC NOS. MF7607, MF7608, MF7609, MF7610, and MF7611), dated March 27, 2017 (ADAMS Accession No. ML17034A360).

9.

Application to Revise the Technical Specifications for the Browns Ferry Nuclear Plant (TS-504) and Sequoyah Nuclear Plant (TS 16-02) on Unit Staff Qualifications to Achieve Consistency between the Tennessee Valley Authority Nuclear Plants, dated April 14, 2016 (ADAMS Accession No. ML16105A287).

PROPOSED TECHNICAL SPECIFICATION PAGE MARKUPS

Facility Staff Qualifications 5.3 Brunswick Unit 1 5.0-4 Amendment No. 259 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for:

a.

The manager of the radiation control function, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

b.

The shift technical advisor, who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant during transients and accidents; and

c.

The operations manager, who shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding holding an SRO license.

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Facility Staff Qualifications 5.3 Brunswick Unit 2 5.0-4 Amendment No. 287 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for:

a.

The manager of the radiation control function, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

b.

The shift technical advisor, who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant during transients and accidents; and

c.

The operations manager, who shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding holding an SRO license.

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Unit Staff Qualifications 5.3 Catawba Units 1 and 2 5.3-1 Amendment Nos. 273/269 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, except:

1.

The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

2.

The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purposes of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Unit Staff Qualifications 5.3 McGuire Units 1 and 2 5.3-1 Amendment Nos. 276/256 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, except:

1.

The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

2.

The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

OCONEE UNITS 1, 2, & 3 5.0-5 Amendment Nos. 389, 391, & 390 Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications described in Section 4 of ANSI/ANS-3.1-1978, "Selection and Training of Nuclear Power Plant Personnel" except:

1. The Operations Manager shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis.

2. The Assistant Operations Manager - Shift shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training on a one-for-one time basis.

3. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained and shall meet or exceed the requirements and recommendations of the September 1979 draft of ANS 3.1. with the exceptions and alternatives noted in Section 1.8 (Personnel Selection and Training) of the FSAR.

The initial and requalification training for licensed personnel is through an accrecited program based on the systematic approach to trai11ing. as allowed by 10 CFR 55.31. 10 CFR 55.59. and Generic Letter 87-07.

6.5 DELETED SHEARON HARRIS - UNIT 1 (PAGES 6-8 THROUGH 6-15 DELETED)

(NEXT PAGE IS 6-16) 6-7 Amendment No. 92 referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications HBRSEP Unit No. 2 5.0-5 Amendment No. 176 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the manager of the radiation control function, who shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981, and the STA, who shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

referenced for comparable positions, as specified in the Duke Energy Corporation Quality Assurance Program Description (DUKE-QAPD-001-A).

DUKE ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION MARKED-UP Section Page Number Brunswick Specific QAPD, Attachment A Page A-15 Harris Specific QAPD, Attachment B Page B-25 Robinson Specific QAPD, Attachment C Page C-14 Catawba, McGuire, and Oconee Specific QAPD, Page D-9 Attachment D

1 l P a g e A m e n d m e n t 4 4 DUKE ENERGY CORPORATION TOPICAL REPORT Quality Assurance Program Description Operating Fleet DUKE-QAPD-001 -A-

Attachment A, Brunswick Specific QAPD A-15 l P a g e A m e n d m e n t 4 4 Table A17-2. Site Specific Response to Regulatory Guides and Industry Standards Table A17-2 identifies additional Regulatory Guides addressing subjects related to implementation of the QAP but the implementation is site specific and controlled with the UFSAR in accordance with 10 CFR 50.59.

Regulatory Guide 1.8, Personnel Selection and Training Personnel selection and training is site specific.

Brunswick addresses conformance with Regulatory Guide 1.8 (SAFETY GUIDE 8, MARCH 1971) in UFSAR Chapter 1 Table 1-6.

Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,

and Radioactive-Waste-Containing Components of Nuclear Power Plants Quality group classifications and standards trace to the original design and construction of the nuclear power plant and therefore are site specific.

Brunswick does not address Regulatory Guide 1.26 in UFSAR Chapter 1 Table 1-6.

Quality group classifications are addressed in UFSAR Chapter 3.

Regulatory Guide 1.29, Seismic Design Classification Seismic design classification trace to the original design and construction of the nuclear power plant and therefore is site specific.

Brunswick addresses conformance with Regulatory Guide 1.29 in UFSAR Chapter 1 Table 1-6.

Regulatory Guide 1.36, Nonmetallic Thermal Insulation for Austenitic Stainless Steel Nonmetallic thermal insulation for austenitic stainless steel trace to the original design and construction of the nuclear power plant and therefore is site specific.

Brunswick does not address conformance with Regulatory Guide 1.36 in UFSAR Chapter 1 Table 1-6. Thermal insulation for austenitic stainless steel is addressed in UFSAR Section 5.2.

Regulatory Guide 1.54, Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants Quality assurance requirements for protective coatings applied to water-cooled nuclear power plants trace to the original design and construction of the nuclear power plant and therefore is site specific.

Brunswick addresses conformance with Regulatory Guide 1.54 in UFSAR Chapter 1 Table 1-6.

Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for:

a. The manager of the radiation control function, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975;

b. The shift technical advisor, who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant during transients and accidents; and

c. The operations manager, who shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding holding an SRO license.

Attachment B, Harris Specific QAPD B-25 l P a g e A m e n d m e n t 4 4 Table B17-2. Site Specific Response to Regulatory Guides and Industry Standards Table B17-2 identifies additional Regulatory Guides addressing subjects related to implementation of the QAP but the implementation is site specific and controlled with the UFSAR in accordance with 10 CFR 50.59.

Regulatory Guide 1.8, Personnel Selection and Training Personnel selection and training is site specific.

Harris addresses conformance with Regulatory Guide 1.8 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,

and Radioactive-Waste-Containing Components of Nuclear Power Plants Quality group classifications and standards trace to the original design and construction of the nuclear power plant and therefore are site specific.

Harris addresses conformance with Regulatory Guide 1.26 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.29, Seismic Design Classification Seismic design classification trace to the original design and construction of the nuclear power plant and therefore is site specific.

Harris addresses conformance with Regulatory Guide 1.29 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.36, Nonmetallic Thermal Insulation for Austenitic Stainless Steel Nonmetallic thermal insulation for austenitic stainless steel trace to the original design and construction of the nuclear power plant and therefore is site specific.

Harris addresses conformance with Regulatory Guide 1.36 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.54, Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants Quality assurance requirements for protective coatings applied to water-cooled nuclear power plants trace to the original design and construction of the nuclear power plant and therefore is site specific.

Harris addresses conformance with Regulatory Guide 1.54 in UFSAR Chapter 1 Section 8.

A retraining and replacement training program for the unit staff shall be maintained and shall meet or exceed the requirements and recommendations of the September 1979 draft of ANS 3.1, with the exceptions and alternatives noted in Section 1.8 (Personnel Selection and Training) of the FSAR. The initial and requalification training for licensed personnel is through an accredited program based on the systematic approach to training, as allowed by 10 CFR 55.31, 10 CFR 55.59, and Generic Letter 87-07.

Attachment C, Robinson Specific QAPD C-14 l P a g e A m e n d m e n t 4 4 Table C17-2. Site Specific Response to Regulatory Guides and Industry Standards Table C17-2 identifies additional Regulatory Guides addressing subjects related to implementation of the QAP but the implementation is site specific and controlled with the UFSAR in accordance with 10 CFR 50.59.

Regulatory Guide 1.8, Personnel Selection and Training Personnel selection and training is site specific.

Robinson addresses conformance with Regulatory Guide 1.8 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,

and Radioactive-Waste-Containing Components of Nuclear Power Plants Quality group classifications and standards trace to the original design and construction of the nuclear power plant and therefore are site specific.

Robinson does not address Regulatory Guide 1.26 in UFSAR Chapter 1 Section 8.

Quality group classifications are addressed in UFSAR Chapter 3.

Regulatory Guide 1.29, Seismic Design Classification Seismic design classification trace to the original design and construction of the nuclear power plant and therefore is site specific.

Robinson addresses conformance with Regulatory Guide 1.29 in UFSAR Chapter 1 Section 8.

Regulatory Guide 1.36, Nonmetallic Thermal Insulation for Austenitic Stainless Steel Nonmetallic thermal insulation for austenitic stainless steel trace to the original design and construction of the nuclear power plant and therefore is site specific.

Robinson does not address conformance with Regulatory Guide 1.36 in UFSAR Chapter 1 Section 8. See UFSAR Chapters 5 and 6 for insulation of austenitic stainless steel.

Regulatory Guide 1.54, Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants Quality assurance requirements for protective coatings applied to water-cooled nuclear power plants trace to the original design and construction of the nuclear power plant and therefore is site specific.

Robinson addresses conformance with Regulatory Guide 1.54 in UFSAR Chapter 1 Section 8.

Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the manager of the radiation control function, who shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981, and the STA, who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

Attachment D, Catawba, McGuire, and Oconee Specific QAPD D-9 l P a g e A m e n d m e n t 4 4 Table D17-2. Site Specific Response to Regulatory Guides and Industry Standards Table D17-2 identifies additional Regulatory Guides addressing subjects related to implementation of the QAP but the implementation is site specific and controlled with each site's UFSAR in accordance with 10 CFR 50.59.

Regulatory Guide 1.8, Personnel Selection and Training Personnel selection and training is site specific.

Catawba addresses conformance with Regulatory Guide 1.8 in UFSAR Chapter 1 Section 7.

McGuire addresses conformance with Regulatory Guide 1.8 in UFSAR Chapter 1 Table 1-4.

Oconee does not address conformance with Regulatory Guide 1.8. Personnel selection and training is addressed in UFSAR Chapter 13.

Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants Quality group classifications and standards trace to the original design and construction of the nuclear power plant and therefore are site specific.

Catawba addresses conformance with Regulatory Guide 1.26 in UFSAR Chapter 1 Section 7.

McGuire addresses conformance with Regulatory Guide 1.26 in UFSAR Chapter 1 Table 1-4.

Oconee does not address conformance with Regulatory Guide 1.26. Quality group classifications and standards are addressed in UFSAR Section 3.2.2.

Regulatory Guide 1.29, Seismic Design Classification Seismic design classification trace to the original design and construction of the nuclear power plant and therefore is site specific.

Catawba addresses conformance with Regulatory Guide 1.29 in UFSAR Chapter 1 Section 7.

McGuire addresses conformance with Regulatory Guide 1.29 in UFSAR Chapter 1 Table 1-4.

Oconee does not address conformance with Regulatory Guide 1.29. Seismic design classifications are addressed in UFSAR Section 3.2.1.

Insert 1

Insert 1 At Catawba and McGuire, each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, except:

1. The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

2. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

For the purposes of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10CFR 50.54(m).

At Oconee, each member of the unit staff shall meet or exceed the minimum qualifications described in Section 4 of ANSI/ANS-3.1-1978, "Selection and Training of Nuclear Power Plant Personnel" except:

1. The Operations Manager shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis.

2. The Assistant Operations Manager - Shift shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training on a one-for-one time basis.

3. The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).