ML25290A000
| ML25290A000 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/15/2025 |
| From: | Spina J Arizona Public Service Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 102-08988-JLS/MDD | |
| Download: ML25290A000 (1) | |
Text
10 CFR 50.90 A member of the STARS Alliance, LLC Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek JENNIFER L. SPINA Vice President Nuclear Regulatory and Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623.393.4621 102-08988-JLS/MDD October 15, 2025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Renewed Operating License Nos. NPF-41, NPF-51, and NPF-74 License Amendment Request to Relocate Select Unit Staff Qualifications from Technical Specification Section 5.3.1 to the Quality Assurance Program Document Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) is submitting a license amendment request (LAR) to the Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3. The proposed change relocates select unit staff qualifications from TS section 5.3.1 to the Quality Assurance Program Document (QAPD). A pre-submittal meeting was held with the NRC staff on September 25, 2025. Approval of the proposed amendment is requested by March 31, 2026. Once approved, the amendment shall be implemented within 90 days.
In accordance with the PVNGS Quality Assurance Program, the Plant Review Board has reviewed and approved this LAR. By copy of this letter, the LAR is being forwarded to the Arizona Department of Health Services - Bureau of Radiation Control for information.
No new commitments are being made to the NRC by this letter. Should you need further information regarding this license amendment request, please contact Michael D. Dilorenzo, Acting Nuclear Regulatory Affairs Director, at (623) 393-3495.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Executed on ______October 15, 2025______
(Date)
Sincerely, JLS/MDD/cmr Spina, Jennifer (Z08962)
Digitally signed by Spina, Jennifer (Z08962)
Date: 2025.10.15 09:58:03
-07'00'
102-08988-JLS/MDD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission License Amendment Request to Relocate Select Unit Staff Qualifications from Technical Specification Section 5.3.1 to the Quality Assurance Program Document Page 2
Enclosure:
Description and Assessment of Proposed License Amendment cc:
J. D. Monninger NRC Region IV Regional Administrator W. T. Orders NRC NRR Project Manager for PVNGS E. R. Lantz NRC Senior Resident Inspector for PVNGS B. D. Goretzki Arizona Department of Health Services - Bureau of Radiation Control
ENCLOSURE Description and Assessment of Proposed License Amendment
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 1
Subject:
License Amendment Request to Relocate Select Unit Staff Qualifications from Technical Specification (TS) Section 5.3.1 to the Quality Assurance Program Document (QAPD) 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 4.2 PRECEDENT 4.3 SIGNIFICANT HAZARDS CONSIDERATION
4.4 CONCLUSION
S 5.0 ENVIRONMENTAL CONSIDERATION 6.0 REFERENCES ATTACHMENTS: : PVNGS Technical Specifications Mark-up Page : Clean PVNGS Technical Specifications Page
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 2
1.0
SUMMARY
DESCRIPTION This evaluation supports a request to amend Renewed Operating Licenses NPF-41, NPF-51, and NPF-74 for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3.
The proposed change would revise the Renewed Operating Licenses to relocate language regarding unit staff qualification standards in the PVNGS Technical Specifications (TS) Section 5.3.1 to the PVNGS Quality Assurance Program Document (QAPD).
This License Amendment Request (LAR) provides a discussion and description of the proposed TS change, a technical evaluation of the proposed TS change and information supporting a finding of No Significant Hazards Consideration.
2.0 DETAILED DESCRIPTION The proposed change is administrative in nature and will remove the specified reference to Regulatory Guide 1.8 and American National Standards Institute/
American Nuclear Society (ANSI/ANS) 3.1-1978 for select unit staff qualifications with the exception of operator license applicants. In addition, the requirements for the Director, Site Radiation Protection and Shift Technical Advisors will also be removed. These requirements are to be relocated to the PVNGS QAPD. Attachment 1 is the proposed marked up TS page and Attachment 2 is the proposed clean TS page.
The existing TS requirements in Section 5.3.1 for unit staff qualifications, with the exception of operator license applicants, will be maintained in the PVNGS QAPD, which is controlled pursuant to 10 CFR 50.54(a). This relocation is deemed prudent to facilitate future adoption of more current NRC endorsed standards for unit staff qualifications without requiring a formal license amendment pursuant to 10 CFR 50.90.
3.0 TECHNICAL EVALUATION
Currently, PVNGS is committed to Regulatory Guide 1.8 Revision 1-R which endorses ANSI/ANS 3.1-1971, and APS TS also includes ANSI/ANS 3.1-1978 and Regulatory Guide 1.8, Revision 1-R-1975 (Radiation Protection Manager only) standards for training and qualification. This requirement will be maintained with the relocation from the PVNGS TS to the PVNGS QAPD.
This LAR does not change any current staff qualification requirements and is only an administrative TS change.
4.0 REGULATORY EVALUATION
4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. APS has determined that existing requirements continue to be met and that the proposed changes do not require any
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 3
exemptions or relief from regulatory requirements. The following current applicable regulations and regulatory requirements were reviewed in making this determination:
Administrative Controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The proposed change conforms to these requirements.
In 1995 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 TSs 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. NRC issued Administrative Letter (AL) 95-06, Relocation of Technical Specification Administrative Controls Related to Quality Assurance, dated December 12, 1995, to address this issue and to provide additional guidance for relocating TS administrative controls to the licensee's quality assurance 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.
10 CFR 50.120 Training and Qualification of Nuclear Power Plant Personnel requires that each nuclear plant licensee or applicant for an operating license implement training and qualification programs that are derived from a systems approach to training. The proposed change conforms to these requirements.
Regulatory Guide 1.8, Revision 1-R Describes a method acceptable to the NRC staff of implementing Paragraph 50.34(b)(6)(i) of 10 CFR Part 50 with regard to personnel qualifications. Regulatory Guide 1.8 Revision 1-R endorses ANSI/ANS 3.1-1971, and APS TS also includes ANSI/ANS 3.1-1978 and Regulatory Guide 1.8, Revision 1-R-1975 (Radiation Protection Manager only) standards for training and qualification. The proposed change relocates this information to the PVNGS QAPD.
10 CFR 50.34(b)(6)(i) 10 CFR 50, Domestic Licensing of Production and Utilization Facilities, requires that applications for a license to operate a nuclear power plant include information concerning organizational structure, personnel qualifications, and related matters.
The proposed change conforms to these requirements.
4.2 PRECEDENT The NRC has approved similar changes by other utilities:
On March 27, 2017, the NRC issued TS amendments (ADAMS Accession Number ML17034A360 and Reference 6.1 for LAR submittal) to Browns Ferry and Sequoyah Nuclear Plants to revise Unit Staff Qualifications to delete the references to RG 1.8
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 4
Revision 2 and replaced them with references to the TVA Nuclear Quality Assurance Plan.
On August 2, 2018, the NRC issued TS amendments (ADAMS Accession Number ML18206A282 and Reference 6.2 for LAR submittal) to Exelon Generation Company, LLC for a Fleet License Amendment Request to relocate TS Unit/Facility/Plant Staff Qualification ANSI N18.1-1971 and ANSI/ANS-3.1-1978 Requirements to the Exelon Quality Assurance Topical Report.
4.3 SIGNIFICANT HAZARDS CONSIDERATION Arizona Public Service Company (APS) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequence of an accident previously evaluated?
Response: No The proposed change relocates the Technical Specification (TS) staff ANSI qualification requirements to the Palo Verde Nuclear Generating Station (PVNGS) Quality Assurance Program Document (QAPD). The proposed change does not make any physical changes to the plants, is administrative in nature, does not alter accident analysis assumptions, and does not 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 a plant modification which affects the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents. The unit staff qualification requirements remain the same and are being relocated from the TS to the PVNGS QAPD.
Therefore, the proposed change does not involve a significant increase in the probability or consequence of an accident previously evaluated.
- 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 relocates the TS staff ANSI qualification requirements to the PVNGS QAPD. The proposed change does not involve changes to unit staff selection, qualification and training programs, is administrative in nature, and does not impact physical plant systems. The qualification standards are being relocated from the TS to the PVNGS 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, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 5
- 3. Does the proposed amendment involve a significant reduction in the margin of safety?
Response: No The proposed change relocates the TS staff ANSI qualification requirements to the PVNGS QAPD. The proposed change is administrative in nature and does not affect plant design, hardware, system operation, or procedures for accident mitigation systems. 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 are no changes in the established safety margins of these systems. The proposed change does not impact the performance or proficiency requirements for licensed operators or unit staff, since the qualification standards are not changing and are only being relocated from the TS to the PVNGS 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 the margin of safety.
Based on the above, APS concludes that the proposed amendment does not present 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 CONCLUSION
S APS concludes (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.
5.0 ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment does 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 does not change surveillance requirements. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in the 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, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 REFERENCES 6.1 Tennessee Valley Authority, "Application to Revise the Technical Specifications for the Browns Ferry Nuclear Plant (TS-504) and
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT 6
Sequoyah Nuclear Plant (TS 16-02) on Unit Staff Qualifications to Achieve Consistency between the Tennessee Valley Authority Nuclear Plants [ML16105A287], April 14, 2016 6.2 Exelon Generation, Exelon Fleet License Amendment Request to Relocate Technical Specification Unit/Facility Plant Staff Qualification ANSI N18.1-1971 and ANSI/ANS-3.1-1978 Requirements to the Exelon Quality Assurance Topical Report [ML18060A266], March 1, 2018
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT ATTACHMENT 1 PVNGS TECHNICAL SPECIFICATIONS MARK-UP PAGE
5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications Unit Staff Qualifications 5.3 5.3.1 Each member of the unit staff with the exception of operator license applicants, shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Palo Verde Quality Assurance Pro~ram Document.of Regulatory Guide 1.8, September 1975 and
,A,N I/ANS 3.1 1978, e~ept the Direotor, Site Radiation F2rotestion shall meet or e~eed the qualifioation of Regulatory Guide 1.8, September 1975, and the Shift Technical Advisor shall ha-.<e a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and plant operating characteristics, including transients and aooidents.
5.3.2 The education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in letter 102-04930-GRO/TNW/RJR, dated April 25, 2003.
5.3.3 For the purpose of 10 CFR 55.4, a licensed senior reactor operation (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.2, perform the functions described in 10 CFR 50.54(m).
PALO VERDE UNITS 1,2,3 5.3-1 AMENDMENT NO. -148
ENCLOSURE DESCRIPTION AND ASSESSMENT OF PROPOSED LICENSE AMENDMENT ATTACHMENT 2 CLEAN PVNGS TECHNICAL SPECIFICATIONS PAGE
Unit Staff Qualifications 5.3 PALO VERDE UNITS 1,2,3 5.3-1 AMENDMENT NO. 148, 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff with the exception of operator license applicants, shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Palo Verde Quality Assurance Program Document.
5.3.2 The education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in letter 102-04930-GRO/TNW/RJR, dated April 25, 2003.
5.3.3 For the purpose of 10 CFR 55.4, a licensed senior reactor operation (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.2, perform the functions described in 10 CFR 50.54(m).