ML21294A338

Proposed Amendment to Relocate Unit Staff Qualification Requirements from Technical Specifications to Nuclear Facility Quality .

ML21294A338
Person / Time
Site:	Millstone, Surry, North Anna
Issue date:	10/21/2021
From:	Mark D. Sartain Dominion Energy Nuclear Connecticut, Dominion Energy Services, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
21-268
Download: ML21294A338 (60)

Text

Dominion En ergy Se rvices, Inc.

5000 Dominion Boulevard, Glen All en, VA 23060 DominionEnergy.com October 21, 2021 Attn: Document Control Desk Serial No.: 21-268 U.S. Nuclear Regulatory Commission NRA/MLW: R4 Washington, DC 20555-0001 Docket Nos.: 50-245/336/423 50-338/339 50-280/281 License Nos.: DPR-21/65 NPF-49 NPF-4/7 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY MILLSTONE POWER STATION UNITS 1, 2, AND 3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 PROPOSED AMENDMENT TO RELOCATE UNIT STAFF QUALIFICATION REQUIREMENTS FROM TECHNICAL SPECIFICATIONS TO NUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION {QAPD)

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.90, "Application for Amendment of License, Construction Permit, or Early Site Permit,"

Dominion Energy Nuclear Connecticut, Inc. (DENC) and Virginia Electric and Power Company (Dominion Energy Virginia) hereby submit requests for amendments to the Technical Specifications (TS) for Millstone Power Station (MPS) Units 1, 2, and 3, North Anna Power Station (NAPS) Units 1 and 2, and Surry Power Station (SPS) Units 1 and 2.

The proposed amendment would modify MPS Unit 1 Technical Specification (TS) 5.3.1, MPS Unit 2 and 3 TS 6.3.1, NAPS TS 5.3.1, and SPS TS 6.1.3 by relocating requirements related to "Facility Staff Qualifications"/"Unit Staff Qualifications" respectively, to the Dominion Energy Nuclear Facility Quality Assurance Program description (QAPD) consistent with guidance contained in NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls to Quality Assurance."

Enclosures 1 through 3 provide attachments with a description and assessment of the proposed changes for each site, existing TS pages marked-up to show the proposed changes, the revised (clean) TS pages, the No Significant Hazards Consideration, and a list of references relative to each TS.

DENC and Dominion Energy Virginia request approval of the proposed license amendments by December 1, 2022, with a 60-day implementation period.

In accordance with 10 CFR 50 .91, "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated Connecticut and Virginia State Officials.

Serial No.21-268 Page 2 of 5 Should you have any questions, please contact Mr. Michael Whitlock at (804)-273-3123.

Respectfully, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Dominion Energy Nuclear Connecticut, Inc.

Virginia Electric and Power Company COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support of Dominion Energy Nuclear Connecticut, Inc. and Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of those Companies, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me thisJ I S-r' day of Oe,,f?J>.e, , 2021.

My Commission Expires: rt/'5>1 /vf Notary Public Commitments made in this letter: None.

Enclosures:

Enclosure 1. Request for Amendments to the Technical Specifications for Millstone Power Station Units 1, 2, and 3 Attachment A. Description and Assessment Attachment 8. Existing TS Pages Mark-up Unit 1 Attachment C. Revised (Clean) TS Pages Unit 1 Attachment D. Existing TS Pages Mark-up Unit 2 Attachment E. Revised (Clean) TS Pages Unit 2 Attachment F. Existing TS Pages Mark-up Unit 3 Attachment G. Revised (Clean) TS Pages Unit 3

Serial No.21-268 Page 3 of 5 Attachment H. No Significant Hazards Consideration Attachment I. References . Request for Amendments to the Technical Specifications for North Anna Power Station Units 1 and 2 Attachment A. Description and Assessment Attachment B. Existing TS Pages Mark-up Attachment C. Revised (Clean) TS Pages Attachment D. No Significant Hazards Consideration Attachment E. References . Requests for Amendments to the Technical Specifications for Surry Power Station Units 1 and 2 Attachment A. Description and Assessment Attachment B. Existing TS Pages Mark-up Attachment C. Revised (Clean) TS Pages Attachment D. No Significant Hazards Consideration Attachment E. References

Serial No.21-268 Page 4 of 5 cc: U.S. Nuclear Regulatory Commission, Region I 2100 Renaissance Blvd Suite 100 King of Prussia, Pennsylvania 19406-2713 U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Richard Guzman NRC Senior Project Manager (Units 2 and 3)

U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 C-2 11555 Rockville Pike Rockville, MD 20852-2738 Amy Snyder Decommissioning Project Manager (Unit 1)

U.S. Nuclear Regulatory Commission Mailstop T-5A10 Washington, D. C. 20555-0001 Mr. L. John Klos NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 9 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRC Project Manager, USNRC One White Flint North Mail Stop 9 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.21-268 Page 5 of 5 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street Suite 730 Richmond, VA 23219 Old Dominion Electric Cooperative R-North-Anna-Correspondence@odec.com NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station

Serial No.21-268 Enclosure 1 Request for Amendments to the Technical Specifications for Millstone Power Station Units 1, 2, and 3 MILLSTONE POWER STATION {MPS} UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. {DENC)

Serial No.21-268 Enclosure 1, Attachment A Description and Assessment MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment A: Page 1 of 5 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

Dominion Energy Nuclear Connecticut (DENG) requests an amendment to the Millstone Power Station (MPS) Unit 1, 2, and 3 Facility Operating Licenses. Specifically, this license amendment request (LAR) proposes to relocate specific administrative controls in the Millstone Unit 1 Technical Specifications (TS) 5.3.1, Millstone Unit 2 TS 6.3.1, and Millstone Unit 3 TS 6.3.1, "Facility Staff Qualifications," to the Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD). Since the commitments for "Facility Staff Qualifications" already exist in the QAPD, the revised TS administrative controls will reference the QAPD versus the specific ANS/ANSI standard endorsed by Regulatory Guide 1.8.

2.0 DETAILED DESCRIPTION 2.1 Current Requirements and Proposed Change MPS Unit 1 TS 5.3.1 currently states:

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. Exceptions to this requirement are specified in the Quality Assurance Program.

Proposed MPS Unit 1 TS 5.3.1 be revised to state:

5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description.

MPS Unit 2 TS 6.3.1 currently states:

6.3 Facility Staff Qualifications 6.3. 1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971* for comparable positions. Exceptions to this requirement are specified in the QualityAssurance Program.

• As of November 1. 2001, applicants for reactor operator and senior reactor operator qualification shall meet or exceed the education and experience guidelines of Regulatory Guide 1. 8, Revision 3. May 2000.

Serial No.21-268 Enclosure 1, Attachment A: Page 2 of 5 Proposed MPS Unit 2 TS 6.3.1 be revised to state:

6.3 Facility Staff Qualifications 6.3. 1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description.

MPS Unit 3 TS 6.3.1 currently states:

6.3 Facility Staff Qualifications 6.3. 1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971* for comparable positions. Exceptions to this requirement are specified in the Quality Assurance Program

• As of November 1, 2001. applicants for reactor operator and senior reactor operator qualification shall meet or exceed the education and experience guidelines of Regulatory Guide 1.8, Revision 3, May 2000.

Proposed MPS Unit 3 TS 6.3.1 be revised to state:

6.3 Facility Staff Qualifications 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description.

2.2 Reason for the Proposed Change These changes are proposed for MPS 1, 2, and 3 and will provide flexibility in adopting updated NRG endorsed standards for facility staff qualifications without the need to submit license amendment requests (LARs). The change process in 10 CFR 50.54(a) is utilized for QAPD changes. This change is consistent with guidance contained in NRG Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."

3.0 ASSESSMENT 3.1 Condition Assessment 10 CFR 50.36(c)(5) requires TS to include administrative controls. These are provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. AL 95-06 states that many license amendments were being processed that involved relocating

Serial No.21-268 Enclosure 1, Attachment A: Page 3 of 5 requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation and relocating requirements that are controlled directly by regulations and related licensee programs. The AL states:

"Increasingly, licensees are 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. 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 is consistent with the guidance in AL 95-06. The unit staff qualifications do not satisfy the criteria of 10 CFR 50.36 for inclusion in the TS as an Administrative Control. Changes to the QAPD are adequately controlled by other regulations and the QAPD is therefore an acceptable location for the unit staff qualification requirements. Specifically, consistent with the guidance in AL 95-06, future changes to the QAPD staff qualification requirements will be evaluated under the 10 CFR 50.54(a) evaluation process.

3.2 Assessment Summary DENG is requesting approval to move the referenced ANSI standard in the facility staff qualification requirements of the TS to the QAPD. The referenced ANSI standard and Regulatory Guide 1.8 alternative in the QAPD currently aligns with the existing TS requirement. Future changes to the QAPD will be controlled via the 10 CFR 50.54(a) evaluation process.

No Significant Hazards Consideration DENG has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of MPS 1, 2, and 3 in accordance with the proposed amendment presents no significant hazards. The DENG evaluation against each of the criteria in 10 CFR 50.92 is provided as Attachment H to this Enclosure.

Serial No.21-268 Enclosure 1, Attachment A: Page 4 of 5

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Acceptance Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. The following current applicable regulations and regulatory requirements were reviewed:

10 CFR 50.36 10 CFR 50.36, "Technical Specifications," Paragraph (c)(5), "Administrative Controls,"

requires the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting that are necessary to assure operation of the facility in a safe manner be included in the TS.

10 CFR 50.120 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel," requires that each nuclear power plant licensee or applicant for an operator license 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.

10 CFR Part 55 10 CFR Part 55, "Operators' Licenses," Subpart D, "Applications," requires that operator license applications include information concerning an individual's education, experience, and other related matters to provide evidence and certification that the applicant has successfully completed the facility licensee's training program that is based on a systems approach to training.

NUREG-1021, Revision 12 NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"

Revision 12, establishes 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."

Regulatory Guide 1.8 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 NRC's regulations regarding training and qualification of nuclear power plant personnel.

The proposed change would eliminate the unit staff qualification requirements from the TS and maintain the current commitments to RG 1.8 along with any exceptions, alternatives, or clarifications as identified in the current QAPD.

Serial No.21-268 Enclosure 1, Attachment A: Page 5 of 5 4.2 Precedent On April 14, 2016 Tennessee Valley Authority (TVA) submitted an LAR to revise TS 5.3, "Unit Staff Qualifications," by deleting references to Regulatory Guide 1.8, Revision 2 (endorses ANSI 3.1-1981) and replace it with reference to the TVA Nuclear Quality Assurance Plan. The LAR was applicable to Browns Ferry and Sequoyah. On March 27, 2017 the NRG approved the LAR from TVA (ML17034A360). Duke Energy, Exelon, and Diablo Canyon have also received approval of similar amendments (ML20083F927, ML18206A282, and ML20083F927 respectively).

4.3 Conclusion DENG has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria and has determined that the applicable regulatory requirements continue to be met. 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 Commission's 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.21-268 Enclosure 1, Attachment B Existing TS Pages Mark-up Unit 1 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No. 21 -268 Enclosu re 1, Attachment B: Page 1 of 1 SeptembeI 8, 2016 Facility Staff Ouali:fications 5.3 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Eaeh member ef m.e faeility staff sl=tal! ni eet er e-xeeeel the niinim1:1m ct1:Jalifieatiens et ANSI ms.1: 1971 fer eomf)am~le 13osiliens. Exee13Uons. te this r:equireiment are :Sf}8Gified in the Quality .A.ssur:aRG8 Pi:og,ram. Each member of th e facility staff shall meet or exceed e minimum qualifica *ons reference<l for comparable positions as specified in the Nuclear Facility Quality Assurance rogram Descrip ion.

5.3.2 The operations manager or at least one operations middle manag,er shall Ile a CERTIFIED FUEL HANDLER.

MILLSTONE-UNIT 1: 5.0-5 Amendment No. 400, 444, 44§, 44 Serial No.21-268 Enclosure 1, Attachment C Revised (Clean) TS Pages Unit 1 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment C: Page 1 of 1 Facility Staff Qualifications 5.3 ADMINISTRATIVE CONTROLS Facility Staff Qualifications 5.3. 1 Each: member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positrons as specified in the Nuclear Facilit; Quality Assurance Program Description.

5.3.2 The operations manager or at least one operations middle manager shall be a: CERTIFIED FUEL HANDLER MILLSTONE-UNIT 1 Amendment No. 101, 111,115,117

Serial No.21-268 Enclosure 1, Attachment D Existing TS Pages Mark-up Unit 2 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosu re 1, Attachment D Page 1 of 1

};fa.5- 20, 1015 ADMINISTRATIVE CONTROLS FACILIIT STAFF (CONTINUED) d_ A radiation protection teclmic.ian shall be on site when fuel is in the reactor_ (Table 6.2-1)

e. All CORE AL1ERATIONS after the initial fuel loading shall be directly supervi~ed by either a licensed Senior Reactor Operator or Senior Reactor Operntor Limited to Fuel Handling who has no other concurrent responsibilities during this operntion.

f. Deleted 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 EReh maMEf ef tbe ftLeilit)* stftff'sbftll meet er elteeell! the Bffltifffllffi 4ttittifiee.aOBS ef ANSIN18.1 1971

• fareeftlfl£1ffi8leP.esi:tieM. EKe.eptieMte thts~ emetttMe ~et:.ified iH, the QH!1l:ttyi'.55tl:fftftee Pt-e~ Each member of the unit st shall meet or exceed the minim.um qualifications referenced for cOinpamble p"Ositiom a, specified in the Nuclear Facility Quality Amira.nee rogr:un Description.

6.3.2 The operations manager o.r at le.ast one operations middle manager shall hold a senior reactor ope,rator license for Millstone Unit No. 2.

• .'\s efNe*.<ember 1, 2001, e.ppl:tefillt-1 far reileter eperat6f 11:Dd settier ree:eter epert1ter q,ulifieatien shall meet or e-xeeed the echleation and eNl)eiienee gmdeli.Bes efRegalatery Gmde 1.8, ReNisien 3, Mey 2000*.

MILL.STON""E - UNIT 2 6-2 Amendment No. 136, 142, 163 , 118, 199, 191 25:S , 270, 288, 398, 320 MILLSTON E POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment E Revised (Clean) TS Pages Unit 2 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No. 21 -268 Enclosure 1, Attachment E Page 1 of 1 ADtilNISTRATIVE CONTROLS FA,CIIJJY STAFF (CONTINI, ED) d_ A radiation protection tecl:mician sh..1 be on site when fuel is in the reactor. (Table 6.2-1)

e. All CORE ALTERATIONS after the initial fuel loading shall be directly supervised by eithe.r a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fue] Handllling who has no other concurrent responsib,- "ties during this operation.

f. Deleted 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility st~shall meet.or e~c:ee,di the minim11:ll! qualific[!lions referenced for comparable pos1flom.as specified m the Nuclear Facility Quah ty As.nuance Program Description.

6.3.2 The operations manager or at least one operations middle manager shall hold a senior reactor operator license for Millstone Unit No. 2.

MII.LSTOl\TE - UNIT 2 6-2 1-\metlfffl:lffit Ne. 136, 142, 163, 178, 198, 191 255, 210, 288, 398, 329 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment F Existing TS Pages Mark-up Unit 3 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No. 21 -268 Enclosure 1, Attachment F Page 1 of 1 t-.fay 20, 2015 AD:MINISTRATIVE CONTROLS 6 3 FACil,ITI' STAFF QUALIFICATIONS 6.3.1 Ee.eh metttee.r ef the feeility stilff' sh1tll meet er elteeed the n:tffli!fttlB:l: qtt:RltaeEtlie!i9 ef ANSI Nl !l. 1 197 Ii' fer eemp!l:fftble peoiaetts. ExeeptieHS to this re<lflil'n:teat Me speei:fiea ill. the Qtlft~' Allrdfilftee PfogH!ft:1. Each member o the unit ,t, ' shall m~t or exceed the minimum q ialificatiom re erenced for comparob e positiorn as spe<'ified in the Nuclear Facility Quality Assurance Program e&cription_

6.3.2 The operatioru manager or at le,ast one operations middle mantiger shall hold ti senior retictor operator license for :Milfotone Unit No. 3.

6.4 TRAJNING 6.4.1 A retmining and replacement training program fo1 the facility staff that meets or exceeds the requirement~.as specified in the Quality Assurance Program and 10 CFR Part 55.59 shall be maintained.

,6.4_2 Deleted.

6.5 DELETED.

• As eHfo..-ember 1, 1001, applie:Mtts.fer reeeter epe-rnler !lfta seaier reactor epernte,r

• 't:ulifwatien &ba.ll meet or emceed the echiealien anaspeHenee gYidelines ef&@gYlatm:y GHiEie 1.8, Re.'.-'isioB: 3, May 200Q.

MILLSTONE - UNIT 3 6-5 Amendment No. 36, 69, 84, 90, 94, 130, 132, 135, 171, 173, 199, 212 , 226, MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment G Revised (Clean) TS Pages Unit 3 MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment G Page 1 of 1 AD}.ilN1STRATIVE CONTROLS 6 3 FACILITY STAFF QUAHFICATIONS 6.3.1 Each member of the unit staff shall meet or eXCl:ed the :minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description.

6.3.2 The operations manager or at least one operations mid.die manager shall hold a senior reactor operator license for Millstone Unit No. 3.

6.4 T.RAIN11'lG 6.4.1 A retraining and replacement training program for the facility staff that meets or exceeds the reqnirements as specified ii1 the Quality Assurance Program and 10 CFR Part 55 .59 shall be maintained.

6.4.2 Deleted.

6.5 DELETED.

11ILLSTONE - UNTI 3 Ameruiment Ne. 36, 19, 84, 90, 94, 1:38, 132, ns, 111, 1n, 100, 212, 22e,

~

MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment H NO SIGNIFICANT HAZARDS CONSIDERATION MILLSTONE POWER STATION (MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC}

Serial No.21-268 Enclosure 1, Attachment H: Page 1 of 2 NO SIGNIFICANT HAZARDS CONSIDERATION Dominion Energy Nuclear Connecticut, Inc. (DENG) has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of Millstone Power Station (MPS) in accordance with the proposed amendment presents no significant hazards. The DENG evaluation against each of the criteria in 10 CFR 50.92 is discussed below:

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

Response: No.

The proposed change improves consistency in administrative controls and does not make any physical changes to the plant. The proposed change does not alter any 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.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change does not impact the accident analyses. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis.

The proposed change does not alter or prevent the ability of the operators to perform their intended actions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change does not impact operation of the plant or its response to transients or accidents. The proposed change does not involve a change in the method of plant operation, and no accident analyses will

Serial No.21-268 Enclosure 1, Attachment H: Page 2 of 2 be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change.

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

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

Serial No.21-268 Enclosure 1, Attachment I REFERENCES MILLSTONE POWER STATION {MPS) UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Serial No.21-268 Enclosure 1, Attachment E: Page 1 of 1

1. Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD)

Topical Report, DOM-QA-1, "Nuclear Facility Quality Assurance Program Description," Revision 30

2. ML031110271, NRG Administrative Letter 95-06: "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12, 1995

3. ML17034A360, 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" dated March 27, 2017.

Serial No.21-268 Enclosure 2 Request for Amendments to the Technical Specifications for North Anna Power Station Units 1 and 2 NORTH ANNA POWER STATION (NAPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 2, Attachment A Description and Assessment NORTH ANNA POWER STATION (NAPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 2, Attachment A: Page 1 of 5 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia) requests an amendment to the North Anna Power Station (NAPS) Units 1 & 2 Facility Operating License. Specifically, this license amendment request (LAR) proposes to relocate specific administrative controls in North Anna Units 1 & 2 Technical Specifications (TS) 5.3.1, "Unit Staff Qualifications," to the Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD). Since the commitments for "Unit Staff Qualifications" already exist in the QAPD, the revised TS administrative control 5.3.1 will reference the QAPD versus the specific ANS/ANSI standard endorsed by Regulatory Guide 1.8.

2.0 DETAILED DESCRIPTION 2.1 Current Requirements and Proposed Change TS 5.3 currently states:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI 3. 1 (12/79 Draft) for the comparable positions. Exceptions to this requirement are specified in the QA Program. The SM, Unit Supervisor, Control Room Operator, and the individual providing advisorv technical support to the unit operations shift crew, shall meet or exceed the minimum qualifications of 10 CFR 55.59(c) and 55.31(a)(4).

Dominion Energy Virginia proposes that TS 5.3 be revised to state:

5.3 Unit Staff Qualifications 5.3. 1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description. The SM. Unit Supervisor, Control Room Operator. and the individual providing advisorv technical support to the unit operations shift crew, shall meet or exceed the minimum qualifications of 10 CFR 55.59(c) and 55.31(a)(4).

2.2 Reason for the Proposed Change This proposed change will provide flexibility in adopting updated NRG endorsed standards for unit staff qualifications without the need to submit LARs. The 10 CFR 50.54(a) process is utilized for QAPD changes. This change is consistent with guidance contained in NRG Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."

Serial No.21-268 Enclosure 2, Attachment A: Page 2 of 5 3.0 ASSESSMENT 3.1 Condition Assessment 10 CFR 50.36(c)(5) requires TS to include administrative controls. These are provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. AL 95-06 states that many license amendments were being processed that involved relocating requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation, and relocating requirements that are controlled directly by regulations and related licensee programs. The AL states:

"Increasingly, licensees are 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. 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 is consistent with the guidance in AL 95-06. The unit staff qualifications do not satisfy the criteria of 10 CFR 50.36 for inclusion in the TS as an Administrative Control. Changes to the QAPD are adequately controlled by other regulations and the QAPD is therefore an acceptable location for the unit staff qualification requirements. Specifically, consistent with the guidance in AL 95-06, future changes to the QAPD staff qualification requirements will be controlled under the 10 CFR 50.54(a) evaluation process.

3.2 Assessment Summary Dominion Energy Virginia is requesting approval to move the referenced ANSI standard in the unit staff qualification requirements of the TS to the QAPD. The referenced ANSI

Serial No.21-268 Enclosure 2, Attachment A: Page 3 of 5 standard in the QAPD currently aligns with the existing TS requirement. Future changes to the QAPD will be controlled via the 10 CFR 50.54(a) evaluation process.

3.3 No Significant Hazards Consideration Dominion Energy Virginia has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of the NAPS in accordance with the proposed amendment presents no significant hazards. The Dominion Energy Virginia evaluation against each of the criteria in 10 CFR 50.92 is provided as Attachment D to this Enclosure.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Acceptance Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met The following current applicable regulations and regulatory requirements were reviewed:

10 CFR 50.36 10 CFR 50.36, "Technical Specifications," Paragraph (c)(5), "Administrative Controls,"

requires the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting that are necessary to assure operation of the facility in a safe manner be included in the TS.

10 CFR 50.120 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel," requires that each nuclear power plant licensee or applicant for an operator license 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.

10 CFR Part 55 10 CFR Part 55, "Operators' Licenses," Subpart D, "Applications," requires that operator license applications include information concerning an individual's education, experience, and other related matters to provide evidence and certification that the applicant has successfully completed the facility licensee's training program that is based on a systems approach to training.

NUREG-1021, Revision 12 NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"

Revision 12, establishes the policies, procedures, and practices for examining licensees

Serial No.21-268 Enclosure 2, Attachment A: Page 4 of 5 and applicants for reactor operator and senior reactor operator licenses at nuclear power reactor facilities under 10 CFR Part 55, "Operators' Licenses."

Regulatory Guide 1.8 Regulatory Guide (RG) 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," describes a method that the NRG staff finds acceptable for complying with the NRC's regulations regarding training and qualification of nuclear power plant personnel.

The proposed change would eliminate the unit staff qualification requirements from the TS and maintain the current commitments to RG 1.8 along with any exceptions, alternatives, or clarifications as identified in the current QAPD.

4.2 Precedent On April 14, 2016 Tennessee Valley Authority (TVA) submitted an LAR to revise TS 5.3, "Unit Staff Qualifications," by deleting references to Regulatory Guide 1.8, Revision 2 (endorses ANSI 3.1-1981) and replace it with reference to the TVA Nuclear Quality Assurance Plan. The LAR was applicable to Browns Ferry and Sequoyah. On March 27, 2017 the NRG approved the LAR from TVA (ML17034A360). Duke Energy, Exelon, and Diablo Canyon have also received approval of similar amendments (ML20083F927, ML18206A282, and ML20083F927 respectively).

4.3 Conclusion Dominion Energy Virginia has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria and has determined that the applicable regulatory requirements continue to be met. 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 Commission's 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.21-268 Enclosure 2, Attachment B Existing TS Pages Mark-up Unit 1 and 2 NORTH ANNA POWER STATION (NAPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No. 21 -268 Enclosure 2, Attachment B: Page 1 of 1 Uni t Staff Qual i f icat i ons

5. 3

5. 0 ADM UIISTRATI VE COlfTRO S 5.3 Uni t Staf f Qua l i fi cations 5.3. 1 fasl!: memlle:r of t he 11Rit staff s hal 1 meet GJ' e*Geelt t he mjRi!llllil!li

{l llcal ifisatio11,s ef .!l!U&I J,l (12/ 79 fJ Faft ) fe,* t il e Si!llil<1 Fa91@

JlOSitiG1'15, fX,S@ JltiOR,5 t e this :reqt1i FeB1eRt. are SJlesifie!I iR t he Q,A Program, E~ch member of lhe unit staff all meet or e:c.ceed the minimum qualifications refer ncro fo r comparab e pos it ions as pecified in the I\ dear 0

Facility Quali y Assuranc,* Program Description. The SM, Uni t Supe vi sor ,

Control Room Ope rator , and t 'he i ndi vi dual provid i ng advisory t echni cal suppor t t o the uni t oper at i ons s hift cr e-tt' , s ha H meet or e xceed the mi ni mum qual ifi cat i ons of 10 CFR 55.59*(c} and 55. 3l (a )

(4) .

5.3.2 For t he pur pose of 10 CFR 55. 4, a l i censed SRO and a l i censed RO a r e t hose i nd i vi dua l s who. i n addi t i on t o meet i ng t he requi r ffille nts of TS 5 . 3. 1. perform t he f un cti ons de scru bed in 10 CIFR 50.54(m).

lor th Anna Units l a nd 2 5.3- 1 Ame ndment s :N3/ 2lill

Serial No.21-268 Enclosure 2, Attachment C Revised (Clean) TS Pages Unit 1 and 2 NORTH ANNA POWER STATION (NAPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 2, Attachment C: Page 1 of 1 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 min1mom qoalUkations referenced for comparable positions as specified in the Nuclear FaciUty Quality Assurance Program Description. The SM, Unit Supervisor, Control Room Operator, and the individual providing advisory technical support to the unit operations shift crew, shall meet or exceed the minimum qualifications of 10 CFR 55.59(c) and 55.31(a)(4).

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

North Anna Units 1 and 2 5.3-1 Am8ndmants 243/224

Serial No.21-268 Enclosure 2, Attachment D NO SIGNIFICANT HAZARDS CONSIDERATION NORTH ANNA POWER STATION (NAPS)-UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 2, Attachment D: Page 1 of 2 NO SIGNIFICANT HAZARDS CONSIDERATION Virginia Electric and Power Company (Dominion Energy Virginia) has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of North Anna Power Station (NAPS) in accordance with the proposed amendment presents no significant hazards. The Dominion Energy Virginia evaluation against each of the criteria in 10 CFR 50.92 is discussed below:

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

Response: No.

The proposed change improves consistency in administrative controls and does not make any physical changes to the plant. The proposed change does not alter any 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.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change does not impact the accident analyses. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis.

The proposed change does not alter or prevent the ability of the operators to perform their intended actions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change does not impact operation of the plant or its response to transients or accidents. The proposed change does not involve a change in the method of plant operation, and no accident analyses will

Serial No.21-268 Enclosure 2, Attachment D: Page 2 of 2 be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change.

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

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

Serial No.21-268 Enclosure 2, Attachment E REFERENCES NORTH ANNA POWER STATION (NAPS)-UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 2, Attachment E: Page 1 of 2

1. Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD)

Topical Report, DOM-QA-1, "Nuclear Facility Quality Assurance Program Description," Revision 30

2. ML031110271, NRG Administrative Letter 95-06: "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12, 1995

3. ML17034A360, 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" dated March 27, 2017.

Serial No.21-268 Enclosure 3 Request for Amendments to the Technical Specifications for Surry Power Station Units 1 and 2 SURRY POWER STATION (SPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 3, Attachment A Description and Assessment SURRY POWER STATION (SPS} - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 3, Attachment A: Page 1 of 5 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia) requests an amendment to the Surry Power Station (SPS) Units 1 & 2 Facility Operating License.

Specifically, this license amendment request (LAR) proposes to relocate specific administrative controls in the Surry Units 1 & 2 Technical Specifications {TS) 6.3.1, "Unit Staff Qualifications," to the Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD). Since the commitments for "Unit Staff Qualifications" already exist in the QAPD, the revised TS administrative control will reference the QAPD versus the specific ANS/ANSI standard endorsed by Regulatory Guide 1.8.

2.0 DETAILED DESCRIPTION 2.1 Current Requirements and Proposed Change TS 6.1.3 currently states:

6. 1.3 Unit Staff Qualifications

1. Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI 3.1 (12179 Draft) for comparable positions. Exceptions to this requirement are specified in the QA Program. Incumbents in the position of Shift Manager, Unit Supervisor (SRO), Control Room Operator (RO), and the individual providing advisory technical support to the unit operations shift crew, shall meet or exceed the requirements of 10 CFR 55.59(c) and 55.31(a)(4).

Dominion Energy Virginia proposes that TS 6.1.3 be revised to state:

6.1.3 Unit Staff Qualifications

1. Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Nuclear Facility Quality Assurance Program Description. Incumbents in the position of Shift Manager, Unit Supervisor (SRO), Control Room Operator (RO), and the individual providing advisory technical support to the unit operations shift crew, shall meet or exceed the requirements of 10 GFR 55.59(c) and 55.31(a)(4).

2.2 Reason for the Proposed Change This proposed change will provide flexibility in adopting updated NRG endorsed standards for unit staff qualifications without the need to submit LARs. The 10 CFR 50.54(a) process is utilized for QAPD changes. This change is consistent with guidance

Serial No.21-268 Enclosure 3, Attachment A: Page 2 of 5 contained in NRG Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."

3.0 ASSESSMENT 3.1 Condition Assessment 10 CFR 50.36(c)(5) requires TS to include administrative controls. These are provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. AL 95-06 states that many license amendments were being processed that involved relocating requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation, and relocating requirements that are controlled directly by regulations and related licensee programs. The AL states:

"Increasingly, licensees are 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. 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 is consistent with the guidance in AL 95-06. The unit staff qualifications do not satisfy the criteria of 10 CFR 50.36 for inclusion in the TS as an Administrative Control. Changes to the QAPD are adequately controlled by other regulations and the QAPD is therefore an acceptable location for the unit staff qualification requirements. Specifically, consistent with the guidance in AL 95-06, future changes to the QAPD staff qualification requirements will be controlled under the 10 CFR 50.54(a) evaluation process.

Serial No.21-268 Enclosure 3, Attachment A: Page 3 of 5 3.2 Assessment Summary Dominion Energy Virginia is requesting approval to move the referenced ANSI standard in the unit staff qualification requirements of the TS to the QAPD. The referenced ANSI standard in the QAPD currently aligns with the existing TS requirement. Future changes to the QAPD will be controlled via the 10 CFR 50.54(a) evaluation process.

3.3 No Significant Hazards Consideration Dominion Energy Virginia has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of the SPS in accordance with the proposed amendment presents no significant hazards. The Dominion Energy Virginia evaluation against each of the criteria in 10 CFR 50.92 is provided as Attachment D to this Enclosure.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Acceptance Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. The following current applicable regulations and regulatory requirements were reviewed:

10 CFR 50.36 10 CFR 50.36, "Technical Specifications," Paragraph (c)(5), "Administrative Controls,"

requires the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting that are necessary to assure operation of the facility in a safe manner be included in the TS.

10 CFR 50.120 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel," requires that each nuclear power plant licensee or applicant for an operator license 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.

10 CFR Part 55 10 CFR Part 55, "Operators' Licenses," Subpart D, "Applications," requires that operator license applications include information concerning an individual's education, experience, and other related matters to provide evidence and certification that the applicant has successfully completed the facility licensee's training program that is based on a systems approach to training.

Serial No.21-268 Enclosure 3, Attachment A: Page 4 of 5 NUREG-1021, Revision 12 NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"

Revision 12, establishes 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."

Regulatory Guide 1.8 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 NRC's regulations regarding training and qualification of nuclear power plant personnel.

The proposed change would eliminate the unit staff qualification requirements from the TS and maintain the current commitments to RG 1.8 along with any exceptions, alternatives, or clarifications as identified in the current QAPD.

4.2 Precedent On April 14, 2016 Tennessee Valley Authority (TVA) submitted an LAR to revise TS 5.3, "Unit Staff Qualifications," by deleting references to Regulatory Guide 1.8, Revision 2 (endorses ANSI 3.1-1981) and replace it with reference to the TVA Nuclear Quality Assurance Plan. The LAR was applicable to Browns Ferry and Sequoyah. On March 27, 2017 the NRC approved the LAR from TVA (ML17034A360). Duke Energy, Exelon, and Diablo Canyon have also received approval of similar amendments (ML20083F927, ML18206A282, and ML20083F927 respectively).

4.3 Conclusion Dominion Energy Virginia has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria and has determined that the applicable regulatory requirements continue to be met. 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 Commission's 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant

Serial No.21-268 Enclosure 3, Attachment A: Page 5 of 5 to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.21-268 Enclosure 3, Attachment B Existing TS Pages Mark-up Unit 1 and 2 SURRY POWER STATION (SPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 1, Attachment B: Page 1 of 1 TS 6.1 -2 09-1 5-05

2. Unit Staff The unit staff organiU1lion shnll include th ' folfowing:

a. Each on-duty sh ift .shal l be composed of al least th mi nimum shift crew composition for each unit as shown in Table: 6.1 - 1.

b. A radiation protection technician shall be on site when fuel is in the reactor. Th~ position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpec ted abseJK'lll, provided immediate action is taken to fill the po.~ i(ion.

c. All core alte.rutions shall be obs *n*cd and directly superv ised by either a licensed Senior Reactor Operator or Senior Re.actor Operator limi ted to fuel handJ iog who has no other concu rrent responsibilities during this operation.

d. The operations manager shall hold (or have previously held) a Senior Reactor Operator License for Surry Power Station or a .simila:r design Pressurized \!v'ater Re.actor plant The Superv isor Nucle.ar Sh ift Operations. shall hold an acti,*e Senior Re-llrtor Operator License for Surry Power Station.

c, Procedure will be cs!ablished IO insure that NRC polic,y .statement guidelines regarding working hours establi_~hed fo r employees are followed. In addition, procedure will provide for documentation of authorized deviatiom from those guideline,;; and that the documentation is available for RC review.

6.1.3 nit Staff Qu aJ ifications l . E~eh fttt!mlm ofl:he u11it .~loff §h::t:ll meet or e:teeed lhe mi 1ti1num quoli fiettt:iotts of ANSI 3.1 (12119 Dtttft) fo r eefttp9:!ttele i,esitie11s.

Elfeepliet1s to lhis reqei reme1'1l sre. speeifte->fl i11 lite QA Progfll:ftt. Each member of the unit staff shall mee or exceed e minimum qmlific :itions referenced for comparable positions as specified in the l\ucle:i:r Facility Quality Assurance Program Description. Incumbent. in the pos itions of Shift Manager, njt Supervisor (SRO), Control Room Operator (RO), rrnd the ind ividual providjng advisory technical suppon to the unit opemlions shift cre.w, shall meet or exoeed the. req11iremen1s of 10 CFR 55.59{c) and

-5.3 l(a)(4).

2. For the purpost; of IOCFR 55.4, a Jicen. ed Senior Reaclor Operator and a licensed Reactor Operator are those indi vidu als who, in addition !o meeting the require.ments of TS 6.1.3. 1 perfonn the functions dc.scribe.d in IOCFR 50.54(m).

Amendment Nes. 244 s11d 243

Serial No.21-268 Enclosure 3, Attachment C Revised {Clean) TS Pages Unit 1 and 2 SURRY POWER STATION (SPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 3, Attachment C: Page 1 of 1 TS6.l-2

2. Unit Staff The unit staff organization shall include the following:

a. Each""--'"""' shift shall be composed of at least the minimum shift crew composition for each unit as shown in Table 6.1-1.

b. A radiation protection technician shall be on site when fuel is in the reactor. Too position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for un"°xpected absence, provid1."'1 immediate action is taken to fill the position.

c. All core alterations shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator limited lo fuel handling who bas no other concurrent responsibilities during this operation.

d. The operations manager shall hold (or have previously held) a Senior Reactor Operator Liecnsc for Surry Power Station or a similar design Pressurized Water Reactor plant. The Supervisor Nuclear Shift Operations shalt hold an activ*e Senior Reactor Operator Ucc,nse for Power Station.

c. Procedures will be established to insure that NRC policy slatement guidelines regarding working hours established for employees are followed. In addition, procedures will provide for documentation of authorized deviations from those guidelines and that the documentation is available for NRC review.

6.1.3 Unit Staff Qualifications:

1. Each member of the unit staff shall meet or exceed the miru:mum qualificati.on.s referenced for comparable positions as specified in the Nuclear Facility Quality A"'1mrance Program Description. Incumbents in the positions of Shift Manager, Unit Supervisor (SRO), Control Room Operator (RO), and the individual nrovidirur advisory technical support to the unit opemtions shift crew, shall meet or exceed the requirements of IO CFR 55.59{c) and 55.31(a)(4).

2. For the purpose of 10 CFR 55.4, a Hocnsed Senior Reactor Operator and a licensed Reactor Operator are those individuals who, in addition to meeting the requirements of TS 6.1.3.f perform the functions described in IO CFR 50.S~m).

Affleadmeat No:;, 244 Mtd 243

Serial No.21-268 Enclosure 3, Attachment D NO SIGNIFICANT HAZARDS CONSIDERATION SURRY POWER STATION (SPS) - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 3, Attachment D: Page 1 of 2 NO SIGNIFICANT HAZARDS CONSIDERATION Virginia Electric and Power Company (Dominion Energy Virginia) has evaluated the proposed amendment against the criteria in 10 CFR 50.92 and has determined that the operation of Surry Power Station (SPS) in accordance with the proposed amendment presents no significant hazards. The Dominion Energy Virginia evaluation against each of the criteria in 10 CFR 50.92 is discussed below:

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

Response: No.

The proposed change improves consistency in administrative controls and does not make any physical changes to the plant. The proposed change does not alter any 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.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change does not impact the accident analyses. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis.

The proposed change does not alter or prevent the ability of the operators to perform their intended actions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change does not impact operation of the plant or its response to transients or accidents. The proposed change does not involve a change in the method of plant operation, and no accident analyses will

Serial No.21-268 Enclosure 3, Attachment D: Page 2 of 2 be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change.

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

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

Serial No.21-268 Enclosure 3, Attachment E REFERENCES SURRY POWER STATION (SPS)- UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Serial No.21-268 Enclosure 3, Attachment E: Page 1 of 1

1. Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD)

Topical Report, DOM-QA-1, "Nuclear Facility Quality Assurance Program Description," Revision 30

2. ML031110271, NRC Administrative Letter 95-06: "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12, 1995

3. ML17034A360, 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" dated March 27, 2017.