ML25120A134
| ML25120A134 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 05/08/2025 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Southern Nuclear Operating Co |
| Lamb J | |
| References | |
| EPID L-2025-LLA-0010, EPID L-2025-LLQ-0000 | |
| Download: ML25120A134 (1) | |
Text
May 8, 2025 LICENSEE:
Southern Nuclear Operating Company, Inc.
FACILITY:
Edwin I. Hatch Nuclear Plant, Units 1 and 2 Joseph M. Farley Nuclear Plant, Units 1 and 2 Vogtle Electric Generating Plant, Units 1, 2, 3, and 4
SUBJECT:
SUMMARY
OF APRIL 28, 2025, OBSERVATION PRE-SUBMITTAL MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,
REGARDING THE CHANGE TO THE PLANT STAFF QUALIFICATIONS (EPID L-2025-LLA-0010 and EPID L-2025-LLQ-0000)
On April 28, 2025, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Southern Nuclear Operating Company, Inc. (SNC, the licensee). The purpose of the meeting was for SNC to discuss its proposed change to plant staff qualifications for Edwin I. Hatch Nuclear Plant, Units 1 and 2, Joseph M. Farley Nuclear Plant, Units 1 and 2, and Vogtle Electric Generating Plant, Units 1, 2, 3 and 4 (SNC Fleet).
By letter dated January 23, 2025 (Agencywide Documents Access and Management System (ADAMS) No. ML25023A218), SNC submitted two licensing actions.
The first licensing action is a proposed license amendment request (LAR) to remove the plant staff qualification requirements from the respective plant Technical Specifications and relocate the control of the plant staff qualification requirements to the Quality Assurance Topical Report (QATR) and Nuclear Development Quality Assurance Manual (NDQAM) consistent with the guidance in NRC Administrative Letter 95-06.
The second licensing action is a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(4), to approve (a) a proposed change to the SNC QATR and NDQAM to adopt Regulatory Guide (RG) 1.8, Revision 4 (ML19101A395),
Qualification and Training of Personnel for Nuclear Power Plants, and (b) a request to extend an American National Standards Institute/American Nuclear Society (ANSI/ANS) -3.1--2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, 2014 and reaffirmed in 2020, provision for crediting experience towards a baccalaureate, allowing individuals without a baccalaureate to serve in certain management positions.
A pre-submittal meeting was held on December 11, 2023, and the meeting summary is contained in ML23356A028.
A list of attendees is provided as an Enclosure.
On April 4, 2025 (ML25093A346), the meeting was noticed on the NRC public web page, and the NRC slides are located at ML25099A329.
The NRC staff opened the meeting with introductory remarks and a roll call of the attendees.
The NRC staff described the proposed changes in the two licensing actions.
The NRC staff described the International Atomic Energy Agency (IAEA) Specific Safety Guide No. SSG-75, Recruitment, Qualification and Training of Personnel for Nuclear Power Plants, which states:
Managers and technical specialists should have a university degree or equivalent certification in management, engineering or science, or some other educational background appropriate to the national education system and the specific job assigned. They might also have attained the necessary competence through appropriate experience and training, where this is permitted by the national regulations. Many positions, however, should be filled by individuals with formal educational qualifications. For example, the title of electrical engineer is established by the awarding of a formal degree and cannot be obtained through experience or training.
The NRCs Policy on Consensus Standards is to (1) involve all interested stakeholders in the NRCs regulatory development processes, (2) participate in the development of consensus standards that support the NRCs mission, and (3) use consensus standards developed by voluntary consensus standards bodies consistent with the provisions of Federal law.
Public Law 104-113, National Technology Transfer and Advancement Act [NTTAA] of 1995, established policy for Government to participate in development and adoption of consensus standards, and that the Government must consider consensus standards in lieu of Government -unique standards.
The Office of Management and Budget (OMB) Circular A-119, Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities, provides guidance for implementing NTTAA, and it requires Agencies to report annually to the National Institute of Standards and Technology (NIST), to Congress.
NRC Management Directive 6.5, NRC Participation in the Development and Use of Consensus Standards, dated October 28, 2016 (ML18073A164), provides direction to the NRC staff for implementing the NTTAA and OMB Circular A-119.
The Consensus Standards Process is administered by American National Standards Institute (ANSI) and is implemented by Standards Development Organizations, such as ANS, American Society of Mechanical Engineers, etc. Consensus consists of due process and substantial agreement, and does not require unanimity. The due process for ANSI accreditation is any party with a direct and material interest has a right to participate by (1) expressing a position and its basis, (2) having that position considered, and (3) having the right to appeal.
Methods of satisfying NRC regulations are explained in NRC RGs and Standard Review Plans (SRPs) explain how NRC reviews applications for licenses and license amendments. Both RGs and SRPs widely reference Codes and Standards.
On November 20, 2014 (Reaffirmed in 2020), ANSI/ANS-3.1-2014, was issued. Revisions to the standard align the ANS, NRC, and Institute of Nuclear Power Operations with industry selection, training, and qualification standards; provide for a common language across the industry; address supplemental personnel training and qualification; and update previous positions in light of new nuclear power plant construction, current position terminology, and evolving technology.
NRC endorses ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, with certain exceptions and clarifications that are listed in the NRC staff RG 1.8, Revision 4.
ANSI/ANS 3.1 - 2014 (Reaffirmed February 3, 2020) states:
Related experience may be substituted for education at the rate of 6 semester credit hours for each year of experience up to a maximum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of credit.
SNC letter dated January 23, 2025, states:
SNC is proposing an exception and wants to expand the use of experience substitution for education to allow related experience to be substituted at a rate of 8 semester credit hours for each year of related experience up to a maximum of 80 credit hours.
The NRC staff asked the following questions:
What is the basis and justification for the proposal to substitute experience for education at a rate of 8 semester credit hours for each year of related experience up to a maximum of 80 credit hours instead of a rate of 6 semester credit hours for each year of related experience up to a maximum of 60 credit hours?
Has SNC discussed with ANSI/ANS the proposed deviation from the standard or discussed the rationale why the proposed change was not adopted in prior standards development efforts?
Discussion SNC stated that one of the examples in the case-by-case section of the ANSI/ANS -3.1-2014 standard uses a substitute experience for education at a rate of 8 semester credit hours for each year of related experience up to a maximum of 80 credit hours.
SNC stated that it did not contact ANSI/ANS regarding this change.
Closing Remarks There were no members of the public present at the meeting.
The NRC staff did not make any regulatory decisions during the meeting. The NRC staff is in the process of thoroughly reviewing the LAR and the 10 CFR 50.54(a)(4) request submitted by SNC on January 23, 2025. The NRC staff will make any regulatory decisions in writing in a timely manner on these two licensing actions. Public Meeting Feedback forms were available, but no comments were received.
The meeting adjourned at 1:30 pm Eastern time.
Please direct any inquiries to me at John.Lamb@nrc.gov or 301-415-3100.
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch, II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.
50-321, 50-366, 50-348, 50-354,50-424, 50-425,52-025, and 52-026
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES APRIL 28, 2025, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY REGARDING A PROPOSED CHANGE TO PLANT STAFF QUALIFICATIONS EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 ATTENDEE REPRESENTING John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Mike Markley NRC Zach Turner NRC Andrea Keim NRC Maurin Scheetz NRC Clint Ashley NRC David Garmon-Candelaria NRC Kerri Kavanagh NRC Shivani Metha NRC Kevin Hsueh NRC Jim Anderson NRC Jake Davis NRC Dawnmathews Kalathiveettil NRC Adam Quarles Southern Nuclear Operating Company (SNC)
Ryan Joyce SNC
PKG: ML25120A137 Meeting Notice: ML25093A346 Meeting Slides: ML25099A329 Meeting Summary: ML25120A134 OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DRO/IQVB/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KZeleznock KKavanagh MMarkley JLamb DATE 04/29/2025 05/01/2025 05/05/2025 05/05/2025 05/08/2025