RA-24-0094, Request for Approval of Duke Energy Corporation Transition to ANSI/ANS3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Traini
| ML24108A128 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire, 07200006, 07200040, 07200003, 07200060, 07100266, 07100345 |
| Issue date: | 04/17/2024 |
| From: | Gibby S Duke Energy Progress |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RA-24-0094 | |
| Download: ML24108A128 (1) | |
Text
Shawn K. Gibby Vice President Nuclear Engineering Duke Energy 13225 Hagers Ferry Rd., MG011E Huntersville, NC 28078 704-519-5138 Shawn.Gibby@duke-energy.com Serial: RA-24-0094 10 CFR 50.54(a)(4) 10 CFR 50.71(e)
April 17, 2024 United States Nuclear Regulatory Commission (NRC)
ATTN: Document Control Desk Washington, DC 20555-0001 Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325, 50-324 / Renewed License Nos. DPR-71 and DPR-62 Independent Spent Fuel Storage Installation Docket No. 72-6 Catawba Nuclear Station, Unit Nos. 1 and 2 Docket Nos. 50-413, 50-414 / Renewed License Nos. NPF-35 and NPF-52 Independent Spent Fuel Storage Installation Docket No. 72-45 McGuire Nuclear Station, Unit Nos. 1 and 2 Docket Nos. 50-369, 50-370 / Renewed License Nos. NPF-9 and NPF-17 Independent Spent Fuel Storage Installation Docket No. 72-38 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 Independent Spent Fuel Storage Installation Docket Nos. 72-04 / License No. SNM-2503 and 72-40 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 Independent Spent Fuel Storage Installation Docket Nos. 72-3 / License No. SNM-2502 and 72-60 Duke Energy, Inc. Quality Assurance Program for Radioactive Packages Shipping under 10 CFR 71, Docket No.71-266 Duke Energy, Inc. Quality Assurance Program for Radioactive Packages Shipping under 10 CFR 71, Docket No.71-345
U.S. Nuclear Regulatory Commission Page 2 Serial: RA-24-0094
References:
- 1. Transmittal of the Duke Energy Corporation Topical Report (Duke QAPD-001-A),
Amendments 48, 49 and 50, dated November 15, 2023
- 2. Dominion Energy Revision 35 of the Quality Assurance Topical Report DOM-QA Review of Program Changes (EPID L-2023-LLQ-0003), dated October 2, 2023 (ML23230A050)
Subject:
Request for Approval of Duke Energy Corporation Transition to ANSI/ANS 3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Training of Personnel for Nuclear Power Plants per 10 CFR 50.54(a)(4)
On July 28, 2022, Duke Energy Carolinas, LLC and Duke Energy Carolinas Progress, LLC (henceforth referred to as "Duke Energy") transitioned the personnel qualification standards for each nuclear site in the Quality Assurance Program Description (QAPD) from the multiple legacy personnel qualification standards to a single more recent personnel qualification standard for all Duke Energy sites listed above - ANSI/ANS 3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel. Revision 4 of Regulatory Guide (RG) 1.8, Qualification and Training of Personnel for Nuclear Power Plants, endorsing this standard with the several exceptions and clarifications, was issued in June 2019.
The regulation used to justify this transition by Duke Energy at that time was 10 CFR 50.54(a)(3)(i). This regulation states that a licensee may make changes to its QAPD without NRC approval as a reduction in commitment provided it involves, The use of a [Quality Assurance] QA standard approved by the NRC which is more recent than the QA standard in the licensee's current QA program at the time of the change. At that time, it was judged by Duke Energy that ANSI/ANS 3.1-2014 and RG 1.8 Rev. 4 were QA standards to which this regulation is applicable.
A discussion with the NRC staff on February 21, 2024 revealed that the NRC does not consider 10 CFR 50.54(a)(3)(i) to be the correct regulation to be applied in this transition. This issue came up during NRC review of Reference 1. The NRC staff expressed that ANSI/ANS 3.1-2014 and RG 1.8 Rev. 4 are not considered to be QA standards and as such, have taken the position that Duke Energy should have submitted the transition for review and approval under 10 CFR 50.54(a)(4) as a reduction in commitment. Note that the NRC issued approval for a similar standard transition in Reference 2.
Since the Duke Energy transition to ANSI/ANS 3.1-2014 and RG 1.8 Rev. 4 occurred prior to the approval of Reference 2, Duke Energy hereby requests approval of this personnel qualification standard transition to ANSI/ANS 3.1-2014 and RG 1.8 Rev. 4 in accordance with 10 CFR 50.54(a)(4) as a reduction in commitment. Reference 2 provides a recent precedent.
Duke Energy requests approval of this request by August 30, 2024.
U.S. Nuclear Regulatory Commission Page 3 Serial: RA-24-0094 There are no commitments made in this letter.
Sincerely, Shawn K. Gibby Vice President - Nuclear Engineering cc:
L. Dudes, Regional Administrator USNRC Region II G. Smith, USNRC Senior Resident Inspector - BNP D. Rivard, USNRC Senior Resident Inspector-CNS P. Boguszewski, USNRC Senior Resident Inspector-HNP C. Safouri, USNRC Senior Resident Inspector - MNS N. Smalley, USNRC Senior Resident Inspector - ONS J. Zeiler, USNRC Senior Resident Inspector-RNP L. Haeg, NRR Project Manager - BNP S. A. Williams, NRR Project Manager - CNS and ONS M. Mahoney, NRR Project Manager - HNP J. Klos, NRR Project Manager-MNS L. Haeg, NRR Project Manager - RNP