View source for LR-N16-0226, Response to Request for Additional Information, Regarding Removing Certain Training Requirements (CAC Nos. MF8477, MF8478, and MF8479)

{{Adams
| number = ML16354A866
| issue date = 12/19/2016
| title = Response to Request for Additional Information, Regarding Removing Certain Training Requirements (CAC Nos. MF8477, MF8478, and MF8479)
| author name = Mannai D
| author affiliation = PSEG Nuclear, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000272, 05000311, 05000354
| license number = DPR-070, DPR-075, NPF-057
| contact person = 
| case reference number = CAC MF8477, CAC MF8478, CAC MF8479, LR-N16-0226
| document type = Letter type:LR, Response to Request for Additional Information (RAI)
| page count = 5
| project = CAC:MF8477, CAC:MF8478, CAC:MF8479
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jorsey 08038-0236 PSEG DEC 1*9 2016                                                                                    NuclearLLC 10 CFR 50.90 LR-N16-0226 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

==Subject:==
Response to Request for Additional Information, Regarding Removing Certain Training Requirements (CAC Nos. MF8477, MF8478, and MF8479)

==Reference:==
NRC letter to PSEG, "Hope Creek Nuclear Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2- Request for Additional Information Regarding License Amendment Request to Remove Certain Training Requirements (CAC Nos. MF8477, MF8478, and MF8479)," dated November 21, 2016 (ADAMS Accession No. ML16321A464)
In the referenced letter, the Nuclear Regulatory Commission (NRC) requested PSEG Nuclear LLC (PSEG) to provide additional information in order to complete the review for removing technical specification requirements that are redundant to, or superseded by, the requirements contained in 10 CFR Part 55, "Operators' Licenses," and 10 CFR Section 50.120, "Training and qualification of nuclear power plant personnel." Attachment 1 provides a detailed response to the request for additional information.
There are no regulatory commitments contained in this letter.
~hould   yqu_have any questiQns regarding thi~ sub_mittal, please_cpntact Ms. Tanya Timbermao at 856-339-1426.

Page 2 LR-N 16-0226 I declare under penalty of perjury that the foregoing is true and correct.
Executed on     /2/t_
1  I 1&6 (Date)
David J. Mannai Senior Director Regulatory Operations Attachments:
: 1. Response to Request for Additional Information cc:     Mr. D. Dorman, Administrator, Region I, NRC Ms. C. Parker, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Hope Creek Commitment Tracking Coordinator Salem Commitment Tracking Coordinator Corporate Commitment Tracking Coordinator

Attachment 1 Response to Request for Additional Information

LR~N16~0226,.
Response to Request for Additional Information License Amendment Request Regarding Removal of Certain Training Requirements PSEG Nuclear LLC Hope Creek Generating Station Docket Nos. 50-354 By letter dated October 17, 2016 (Agencywide Documents Access and Management System Accession No. ML16291A318), PSEG Nuclear LLC (PSEG or the licensee) submitted a license amendment request (LAR) to revise the Hope Creek Generating Station (Hope Creek) and Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, Technical Specifications (TSs) by removing certain training program requirements. Specifically, the amendments would remove TS requirements that are redundant to, or superseded by, the requirements contained in Title 10 of the Code of Federal Regulations ( 10 CFR) Part 55, "Operators' Licenses," and 10 CFR Section 50.120,- "Training and qualification of nuclear power plant personnel."
For Hope Creek, this request would remove the requirements for conducting retraining for individuals identified in Section 5.5 of ANSI/ANS-3.1-1981, "Selection, Qualification and Training of Personnel for Nuclear Power Plants." 1 Section 5.5 of ANSI/ANS-3.1-1981 states, in part, that, "Mechanisms shall be established to ensure that individuals in the operating organization performing safety related functions remain cognizant of changes to the facility, procedures, governmental regulations, and quality assurance requirements .... " Quality Assurance personnel are listed in Section 4.4.5 of ANSI/ANS-3.1-1981 as requiring training consistent with other professional technical personnel which are listed in 10 CFR Section 50.120. By deleting TS Section 6.4.1, it would appear that the requirement to maintain a retraining and replacement training program for quality assurance personnel would also be deleted.
The U.S. Nuclear Regulatory Commission staff has reviewed the application and, based upon this review, determined that the following additional information is needed to complete our review:
: 1. The LAR technical analysis states that the TS requirements are redundant to, or superseded by, 10 CFR Part 55 and 10 CFR Section 50.120. Discuss the method
* and guidance documents that would be used regarding training of quality assurance personnel at Hope Creek.
PSEG Response to RAI-1 The PSEG Quality Assurance Program (QAP) contained in the Salem and Hope Creek
                                                                                                    -- - I QUality Assurance-Topical Report,NO-AA~10,corhprises all those planned ana--
systematic actions necessary to provide adequate confidence that structures, systems, and components will perform satisfactorily in service. The QAP includes requirements to establish and maintain indoctrination and training programs for personnel performing or verifying activities within the scope of the Quality Assurance Program. The current QAP requirements for indoctrination and training programs apply to Quality Assurance 1
Salem's TSs reference ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel."
1

LRgN16*0226 personnel and are similar to and, for Quality Assurance personnel, more comprehensive than the requirements in TS 6.4.1. The QAP complies with numerous industry standards, including ASME NQA-1-1994, which requires implementation of the following qualification and training criteria:
* Basic Requirement 2, Quality Assurance Program. This requirement states in part "The program [QAP] shall provide for indoctrination and training, as necessary, of personnel performing activities affecting quality to assure that suitable proficiency is achieved and maintained."
* Supplement 2S-1, Supplementary Requirements for the Qualification of Inspection and Test Personnel
* Supplement 2S-2, Supplementary Requirements for the Qualification of           i Nondestructive Examination Personnel                                           r
* Supplement 2S-3, Supplementary Requirements for the Qualification of Quality Assurance Program Audit Personnel
* Supplement 2S-4, Supplementary Requirements for Personnel Indoctrination and Training The proposed TS changes will not remove the above requirements for indoctrination and training from the QAP. Changes to the QAP are controlled in accordance with the requirements of 10 CFR 50.54(a).
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