ML17090A201

License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators

ML17090A201
Person / Time
Site:	Monticello, Prairie Island
Issue date:	03/31/2017
From:	Murphy M Northern States Power Company, Minnesota, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-XE-17-001
Download: ML17090A201 (30)

Text

414 Nicollet Mall Minneapolis, MN 55401 800.895.4999 xcelenergy.com March 31, 2017 L-XE-17-001 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Monticello Nuclear Generating Plant Units 1 and 2 Docket 50-263 Docket 50-282 and 50-306 Renewed Facility Operating License Renewed Facility Operating License Nos. No. DPR-22 DPR-42 and DPR-60 License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota Corporation, doing business as Xcel Energy (hereafter NSPM), hereby submits an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) and Monticello Nuclear Generating Plant (MNGP). The proposed change would primarily revise the PINGP TS 5.3, Plant Staff Qualifications and MNGP TS 5.3, Unit Staff Qualifications, sub-sections 5.3.1 to add an exception for licensed operators from the education and experience eligibility requirements of American National Standards Institute (ANSI) N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, by requiring that licensed operators comply only with the requirements of 10 CFR 55, Part 55Operators Licenses.

Additionally, the proposed change would revise the PINGP and MNGP TS 5.0, Administrative Controls, sub-sections 5.1-5.3 by making changes to standardize and align formatting to the extent possible between the TSs. These changes focus on improving layout and readability and ensuring consistent terminology without modification of meaning.

The enclosure provides NSPMs evaluation of the proposed change. Attachment 1 to the enclosure provides the marked-up PINGP pages. Attachment 2 to the enclosure provides the marked-up MNGP pages. Attachment 3 to the enclosure provides a re-typed copy of the PINGP pages. Attachment 4 to the enclosure provides a re-typed copy of the MNGP pages.

NSPM requests approval of the proposed amendment by March 31, 2018, with an implementation period of 90 days.

In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this request by transmitting a copy of this letter and enclosure to the designated State Official.

Document Control Desk Page 2 If there are any questions or if additional information is needed, please contact Mr. Peter Gohdes at (612) 330-6503 or Peter.Gohdes@xenuclear.com.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on March ~I , 2017.

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Director, Nuclear Licensing and Regulatory Services Northern States Power Company- Minnesota Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Monticello, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota

ENCLOSURE PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 MONTICELLO NUCLEAR GENERATING PLANT Evaluation of Proposed Change

Subject:

License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change 2.5 Facility Description

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. PINGP Technical Specification Page Markups

2. MNGP Technical Specification Page Markups

3. PINGP Retyped Technical Specification Pages

4. MNGP Retyped Technical Specification Pages Page 1 of 14

L-XE-17-001 NSPM Enclosure 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota Corporation, doing business as Xcel Energy (hereafter NSPM), hereby submits an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) and Monticello Nuclear Generating Plant (MNGP). The proposed change would primarily revise the PINGP TS 5.3, Plant Staff Qualifications and MNGP TS 5.3, Unit Staff Qualifications, sub-sections 5.3.1 to add an exception for licensed operators from the education and experience eligibility requirements of American National Standards Institute (ANSI) N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, by requiring that licensed operators comply only with the requirements of 10 CFR 55, Part 55Operators Licenses.

Additionally, the proposed change would revise the PINGP and MNGP TS 5.0, Administrative Controls, sub-sections 5.1-5.3 by making changes to standardize and align formatting to the extent possible between the TSs. These changes focus on improving layout and readability and ensuring consistent terminology without modification of meaning.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The proposed change affects the minimum education and experience qualifications requirements for licensed operators and resolves inconsistencies between the PINGP and MNGP TSs. As such, the proposed change does not have a direct effect on any systems, structures or components within PINGP or MNGP.

2.2 Current Technical Specifications Requirements The PINGP and MNGP TS 5.0, Administrative Controls, specifications affected by the proposed change are as follows.

TS 5.3.1 Licensed Operator Exception The minimum education and eligibly qualifications requirements for licensed operators at PINGP are contained within TS 5.3, Plant Staff Qualifications, sub-section TS 5.3.1 which states:

Each member of the plant staff shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September 1975 except for the operations manager who shall meet the requirements of ANSI N18.1-1971, except that NRC license requirements are as specified in TS 5.2.2.e.

Similarly, the minimum education and eligibly qualifications requirements for licensed operators at MNGP are contained within TS 5.3, Unit Staff Qualifications, sub-section TS 5.3.1 which states:

Page 2 of 14

L-XE-17-001 NSPM Enclosure Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the radiation protection manager.

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. In addition, the operations manager shall be qualified as required by Specification 5.2.2.e.

Other Affected Specifications in TS 5.1-5.3 Additionally, this license amendment request will resolve position title and abbreviation usage inconsistencies between the PINGP and MNGP TSs.

PINGP TS 5.1.2 defines abbreviations for the positions senior reactor operator (SRO) and reactor operator (RO). Following this, TS 5.2.2.e makes use of the defined abbreviation SRO while later in TS 5.3.2 the full position titles are given again and the corresponding abbreviations are again defined senior reactor operator (SRO) and reactor operator (RO).

PINGP TS 5.1.2 also defines the abbreviation SS for the position shift supervisor. The abbreviation SS is only used in TS 5.1.2 even though later in TS 5.7.2.a.1 the position title shift supervisor is used.

MNGP TS 5.1.2, 5.2.2.e and TS 5.3.2 uses the positions Senior Operator and Operator without abbreviation.

MNGP TS 5.1.2 does not define an abbreviation for the position shift supervisor.

2.3 Reason for Proposed Changes The primary reason for the proposed change is to create an exception within TS 5.3.1 for licensed operators to only require compliance with 10 CFR 55. The reason for this is to allow for use of the minimum education and experience eligibility requirements contained within the latest NRC-endorsed National Academy for Nuclear Training (NANT) guideline for initial training and qualification of licensed operators in lieu of those in ANSI N18.1-1971.

Additionally, the PINGP and MNGP TSs are standardized without modification of meaning.

2.4 Description of the Proposed Change Brief descriptions of the associated proposed TS changes are provided in this section. The specific wording of the changes to the TS are provided in Attachments 1, 2, 3 and 4 to this enclosure.

TS 5.3.1 Licensed Operator Exception The proposed change would revise PINGP TS 5.3.1 as follows:

Page 3 of 14

L-XE-17-001 NSPM Enclosure 5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

In addition, the operations manager shall be qualified as required by TS 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55.

except for the operations manager who shall meet the requirements of ANSI N18.1-1971, except that NRC license requirements are as specified in TS 5.2.2.e.

Similarly, the proposed change would revise MNGP TS 5.3.1 as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

the radiation protection manager. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

In addition, the operations manager shall be qualified as required by Specification 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55.

Other Affected Specifications in TS 5.1-5.3 In addition to this, the following proposed administrative changes would be made:

In PINGP TS 5.1.2, the definition of the abbreviation SS is deleted and shift supervisor is substituted in the subsequent instances of the abbreviation.

In PINGP TS 5.3.2, senior reactor operator and reactor operator are removed leaving only the abbreviations.

In MNGP TS 5.1.2, Senior Operator is changed to senior reactor operator (SRO) in the first instance and subsequently Senior Operator is changed to SRO. Also, Operator is changed to reactor operator (RO).

Page 4 of 14

L-XE-17-001 NSPM Enclosure In MNGP TS 5.2.2.e and TS 5.3.2, Senior Operator is changed to SRO and in TS 5.3.2 Operator is changed to RO.

2.5 Facility Description NSPM owns and operates both the PINGP and MNGP.

Prairie Island Nuclear Generating Plant PINGP is a two unit plant located on the right bank of the Mississippi River within the city limits of Red Wing, Minnesota. Each unit at PINGP employs a two-loop pressurized water reactor designed and supplied by Westinghouse Electric Corporation. The initial PINGP application for a Construction Permit and Operating License was submitted to the Atomic Energy Commission (AEC) on April 5, 1967. The Final Safety Analysis Report was submitted for application of an Operating License on January 28, 1971. Unit 1 began commercial operation on December 16, 1973 and Unit 2 began commercial operation on December 21, 1974.

The PINGP was designed and constructed to comply with NSPMs understanding of the intent of the AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as published on July 11, 1967. PINGP was not licensed to NUREG-0800, Standard Review Plan.

Monticello Nuclear Generating Plant MNGP is a single unit plant located on the south bank of the Mississippi River within the city limits of Monticello, Minnesota. The facility is owned and operated by NSPM. The MNGP is a single cycle, forced circulation, low power density boiling water reactor, designed and supplied by the General Electric Corporation. The MNGP application for a Construction Permit and Operating License was submitted to the AEC on August 1966. Amendment No. 1 to Provisional Operating License No. DPR-22 was issued on January 13, 1971, granting full power operation. MNGP began commercial operation in June 1971.

The MNGP was designed and constructed to comply with NSPMs understanding of the intent of the AEC GDC for Nuclear Power Plant Construction Permits, as published on July 11, 1967.

MNGP was not licensed to NUREG-0800, Standard Review Plan.

3.0 TECHNICAL EVALUATION

TS 5.3.1 Licensed Operator Exception On March 20, 1985, the NRC issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, which endorsed the training accreditation program developed by the Institute of Nuclear Power Operations (INPO) in association with its NANT guidelines (Reference 1).

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L-XE-17-001 NSPM Enclosure On March 25, 1987, the NRC amended 10 CFR 55, "Part 55Operators' Licenses," which included as an alternative, certification that the licensee has instituted an NRC-approved training program based upon a systems approach to training (SAT) utilizing an acceptable simulation facility (Reference 2).

On March 19, 1987, the NRC issued Generic Letter (GL) 87-07, Information Transmittal of Final Rulemaking for Revisions to Operator Licensing 10 CFR 55 and Conforming Amendments, which announced a series of public meetings following the implementation of the revised 10 CFR 55. GL 87-07 provided instruction to licensees that written notification certifying that the substitute training program is accredited and based upon SAT was sufficient for implementation and that the substitute training program would not require staff review (Reference 3). Later in November 1987, NUREG-1262, Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators Licenses, was published which contained further clarification based upon the public meetings (Reference 4). NUREG-1262 noted that the NRC reached the conclusion that the INPO accreditation criteria are equivalent to the NRCs. The NRC also indicated that while providing written notification of accreditation following the new rule would supersede all existing requirements to date, some licensees may still have more restrictive requirements in their TS and Final Safety Analysis Report. In that instance, the NRC noted that an administrative change to the TS would be necessary or the more restrictive requirement would continue to apply.

On March 21, 1988, NSPM provided written notification in response to GL 87-07 to the NRC of institution of an INPO-accredited operator training program based upon a SAT at PINGP and MNGP in separate, site-specific letters (References 5 and 6). These letters confirmed that INPO accredited the training programs of both stations in 1987 and that NSPM is a member of the NANT.

On January 18, 2001, the NRC issued Regulatory Issue Summary (RIS) 2001-01, "Eligibility of Operator License Applicants," to familiarize licensees with the NRC's current guidelines for the qualification and training of licensed operator applicants (Reference 7). This was due to the NRCs observation that some licensees had not responded to GL 87-07 and/or had failed to eliminate the inconsistencies and contradictions contained within their licensing basis documents. The RIS reiterated the acceptability to the NRC of a training program when it is accredited by the National Nuclear Accrediting Board and encouraged licensees to review and update their documentation to enhance consistency and minimize confusion. It stated that NANT's updated guidelines which were issued in January 2000 (in addition to the continued acceptability of the 1987 guidelines) for education and experience outline acceptable methods for implementing the NRC's regulations.

The NRC has noted that more recent industry guidance is acceptable for qualifying license candidates. On June 4, 2010, in response to a question on the NRCs "Operator Licensing Program Feedback" webpage (Reference 8), the NRC noted that the NANT guidelines issued in February 2010 (that is, ACAD 10-001) provide an acceptable method for meeting the regulations (not withstanding an exception that was also previously taken to ACAD 00-003).

The NRC response to the question concluded that, "The next update to NUREG-1021 will be Page 6 of 14

L-XE-17-001 NSPM Enclosure revised to clarify that the NANT's 'current version' of the guidelines for training and qualification of licensed operators is an acceptable method for meeting 10 CFR 55.31."

In December 2014, the update to NUREG-1021, Operator Examination Standards for Power Reactors, Revision 10, was published in which the NRC clarified that the current version of those guidelines is outlined in the NANT Guidelines for Initial Training and Qualification of Licensed Operators, which were issued in February 2010 (NANT 2010 guidelines)

(Reference 9).

TS 5.3.1 ANSI N18.1-1971 and Regulatory Guide 1.8, Revision 1 In September 1975, the NRC issued Regulatory Guide (RG) 1.8, Personnel Selection and Training, Revision 1 (Reference 11). The NRC issued this RG with the purpose of outlining an acceptable method implementing a portion of the Commissions regulations with regard to personnel qualifications. The RG notes that ANSI N18.1-1971 is generally acceptable and provides an adequate basis for the selection and training of nuclear power plant personnel, with the one noted exception being the radiation protection manager position whose qualifications are then detailed within the RG.

On December 7, 1998, the Commission issued NSPMs PINGP License Amendments 141/132 which revised then TS 6.3, Plant Staff Qualifications (Reference 12). As part of the amendment, the minimum qualifications requirement to meet ANSI N18.1-1971, with an exception that the radiation protection manager be qualified to RG 1.8, Revision 1 was changed to simply RG 1.8, Revision 1. In doing this, while the explicit ANSI N18.1-1971 reference was removed (except in reference to the operations manager), it was still required via the endorsement contained within RG 1.8, Revision 1. The staff noted in the safety evaluation for the amendment that this relocation results in identical restrictions. Therefore, the proposed change to revert to the previous form will result in identical restrictions continuing to be met.

Lastly, the PINGP TS 5.3.1 operations manager exception simplification does not alter the meaning as the current form and the proposed change are the same requirement. The operations manager will continue to meet the minimum education and experience qualifications requirements contained in ANSI N18.1-1971 with the additional requirements of TS 5.2.2.e.

Alignment of Position Titles in TS 5.1.2, 5.2.2.e & 5.3.2 In both the PINGP and MNGP TS 5.2.1.a, the TS states that plant specific titles shall be documented in the Updated Safety Analysis Report (USAR) or Quality Assurance Topical Report. Both the USARs for PINGP (Section 13.2.1) and MNGP (Section 13.2.1) state that plant specific titles are delineated in NSPM-1, Quality Assurance Topical Report. The QATR is an NSPM fleet-level document which contains the terms senior reactor operator and reactor operator. Therefore, the proposed change aligns the position titles used in the administrative controls section of the TS to align with the QATR. This also matches with the Page 7 of 14

L-XE-17-001 NSPM Enclosure definitions contained within the latest NRC-endorsed NANT guideline for initial training and qualification of licensed operators.

Lastly, in the PINGP TS 5.1.2, the position shift supervisor is abbreviated SS. This abbreviation is then used only in TS 5.1.2 even though the position title is used again later in TS 5.7.2.a.1. The abbreviation is deleted to align PINGP TS 5.1.2 with MNGP TS 5.1.2.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the proposed change.

Title 10 Code of Federal Regulations 50.36(c)(5)

The regulations at Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36, Technical Specifications, establish the requirements related to the content of the TS. Section 50.36(c)(5) states:

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.

This license amendment request affects the administrative controls section of the TS. The primary proposed change is to revise TS 5.3.1 by adding an exception for licensed operators to comply only with 10 CFR 55 which allows for utilization of the education and experience qualifications requirements contained within the latest NRC-endorsed NANT guideline for initial training and qualification of licensed operators instead of those in ANSI N18.1-1971, which is an NRC accepted approach for meeting the requirements of 10 CFR 55. All other changes are administrative.

Therefore, with these changes, the TS will continue to provide administrative controls relating to organization and management of the PINGP and MNGP to assure operation of the facilities in a safe manner and the requirements of 10 CFR 50.36 will continue to be met.

Title 10 Code of Federal Regulations 55.31(a)(4)

The regulations of 10 CFR 55, Part 55Operators Licenses, establish procedures and criteria for the issuance of licenses to operators and senior operators, terms and conditions for the NRCs issuance or modification of licenses, and terms and conditions for maintenance and renewal of licenses. Specifically, in section 55.31, How to Apply, (a)(4) states that:

In lieu of these details, the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based on a Page 8 of 14

L-XE-17-001 NSPM Enclosure systems approach to training and that uses a simulation facility acceptable to the Commission under § 55.45(b) of this part.

This license amendment request affects the administrative controls section of the TS. The primary proposed change is to revise TS 5.3.1 by adding an exception for licensed operators to comply only with 10 CFR 55 which allows for utilization of the education and experience qualifications requirements contained within the latest NRC-endorsed NANT guideline for initial training and qualification of licensed operators instead of those in ANSI N18.1-1971, which is an NRC accepted approach for meeting the requirements of 10 CFR 55. All other changes are administrative.

Thus with the changes proposed in this license amendment request, the requirements of 10 CFR 55.31 continue to be met.

Title 10 Code of Federal Regulations 50.120(b)(2)

The regulations of 10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel, establish training program requirements for nine categories of nuclear power plant personnel. Specifically, section 50.120(b)(2) states that:

The training program must be derived from a systems approach to training as defined in 10 CFR 55.4.

This license amendment request affects the administrative controls section of the TS. The primary proposed change is to revise TS 5.3.1 by adding an exception for licensed operators to comply only with 10 CFR 55 which allows for utilization of the education and experience qualifications requirements contained within latest NRC-endorsed NANT guideline for initial training and qualification of licensed operators instead of those in ANSI N18.1-1971, which is an NRC accepted approach for meeting the requirements of 10 CFR 55. This proposed change does not affect the positions listed in 10 CFR 50.120(b)(2). All other changes are administrative.

Thus with the changes proposed in this license amendment request, the requirements of 10 CFR 50.120 will continue to be met.

NUREG-1021 The NRC published NUREG-1021, Operator Licensing Examination Standards for Power Reactors, to establish the policies, procedures, and practices for examining licensees and applicants for reactor operator and senior operator licenses at power reactor facilities pursuant to 10 CFR 55. The latest revision to NUREG-1021, Revision 11, was published in February 2017 (Reference 10) which states:

Specifically, the NRC staff understands that the current version of those guidelines is outlined in the NANT Guidelines for Initial Training and Qualification of Licensed Operators, issued February 2010 (NANT 2010). Unless otherwise informed by a facility Page 9 of 14

L-XE-17-001 NSPM Enclosure licensee, the NRC staff believes that the education and experience guidelines described in NANT 2010 constitute the facility licensees education and experience requirements to be licensed as an RO or SRO.

This license amendment request affects the administrative controls section of the TSs. The primary proposed change is to revise TS 5.3.1 by adding an exception for licensed operators to comply only with 10 CFR 55 which allows for utilization of the education and experience qualifications requirements contained within latest NRC-endorsed NANT guideline for initial training and qualification of licensed operators instead of those in ANSI N18.1-1971, which is an NRC accepted approach for meeting the requirements of 10 CFR 55. Therefore, as detailed within NUREG-1021, Revision 11, this is an acceptable approach to the NRC.

Thus proposed changes in this license amendment request are consistent with the latest revision to NUREG-1021.

4.2 Precedent This proposed change is consistent with NRC-approved license amendments issued to Exelon Generation Company on June 20, 2013, (Reference 13) and FirstEnergy Nuclear Operating Company on June 7, 2016, (Reference 14).

These approved changes are similar to the changes proposed in this request. There are no differences between the plant and design licensing bases for PINGP and MNGP and the units listed above that would affect the applicability of the change.

4.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota Corporation, doing business as Xcel Energy (hereafter NSPM), hereby submits an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) and Monticello Nuclear Generating Plant (MNGP). The proposed change would primarily revise the PINGP TS 5.3, Plant Staff Qualifications and MNGP TS 5.3, Unit Staff Qualifications, sub-sections 5.3.1 to add an exception for licensed operators from the education and experience eligibility requirements of American National Standards Institute (ANSI) N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, by requiring that licensed operators comply only with the requirements of 10 CFR 55, Part 55Operators Licenses.

Additionally, the proposed change would revise the PINGP and MNGP TS 5.0, Administrative Controls, sub-sections 5.1-5.3 by making changes to standardize and align formatting to the extent possible between the TSs. These changes focus on improving layout and readability and ensuring consistent terminology without modification of meaning.

NSPM has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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L-XE-17-001 NSPM Enclosure

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

Response: No The proposed change revises TS 5.3.1 to take exception to ANSI N18.1-1971 requirements for the education and experience qualifications requirements for licensed operators and requires compliance with 10 CFR 55 and standardizes language between the TS without modifying meaning. An allowance for utilization of a Commission-approved training program that is based upon a SAT is contained within 10 CFR 55.

The NRC has also stated that the NANT guidelines, as endorsed, for initial licensed operator training and qualification are an acceptable way to meet the requirements of 10 CFR 55.

The proposed changes are administrative and do not affect any system that is a contributor to initiating events for previously evaluated accidents. Nor do the changes affect any system that is used to mitigate any previously evaluated 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 amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change revises TS 5.3.1 to take exception to ANSI N18.1-1971 requirements for the education and experience qualifications requirements for licensed operators and requires compliance with 10 CFR 55 and standardizes language between the TS without modifying the meaning. An allowance for utilization of a Commission-approved training program that is based upon a SAT is contained within 10 CFR 55.

The NRC has also stated that the NANT guidelines, as endorsed, for initial licensed operator training and qualification are an acceptable way to meet the requirements of 10 CFR 55. The proposed change is administrative and does not alter the design, function, or operation of any plant component, nor do they involve installation of any new or different equipment.

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

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

Response: No The proposed change revises TS 5.3.1 to take exception to ANSI N18.1-1971 requirements for the education and experience qualifications requirements for licensed Page 11 of 14

L-XE-17-001 NSPM Enclosure operators and requires compliance with 10 CFR 55 and standardizes language between the TS without modifying the meaning. An allowance for utilization of a Commission-approved training program that is based upon a SAT is contained within 10 CFR 55.

The NRC has also stated that the NANT guidelines, as endorsed, for initial licensed operator training and qualification are an acceptable way to meet the requirements of 10 CFR 55. The proposed change is administrative and does not alter the design, function, or operation of any plant component, nor do they involve installation of any new or different equipment.

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

Based on the above, NSPM concludes that the proposed amendment does not involve 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 Conclusions In conclusion, 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 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

The proposed amendment does not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and does not change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in 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, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Nuclear Regulatory Commission (NRC) Commission Policy Statement, Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, 50 FR 11147, dated March 20, 1985.

2. NRC Statements of Consideration, Operators Licenses and Conforming Amendments, 52 FR 9453, dated March 25, 1987.

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3. NRC Generic Letter, Information Transmittal of Final Rulemaking for Revisions to Operator Licensing 10 CFR 55 and Conforming Amendments (Generic Letter No. 87-07, dated March 19, 1987.

4. NUREG-1262, Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators Licenses, dated November 1987 (ADAMS Accession Number ML15198A217).

5. Letter from Northern States Power Company (NSP) to the NRC, Prairie Island Nuclear Generating Plant, NRC License Operator Training Program and Licensed Operator Requalification Program, Response to Generic Letter 87-07, dated March 21, 1988.

6. Letter from NSP to the NRC, Monticello Nuclear Generating Plant, NRC License Operator Training Program and Licensed Operator Requalification Program, Response to Generic Letter 87-07, dated March 21, 1988.

7. NRC Regulatory Issue Summary, RIS 01-001, Eligibility of Operator License Applicants, dated January 18, 2001 (ADAMS Accession Number ML003733003).

8. NRC Website, Operator Licensing Program Feedback, Section ES-202.20, (ADAMS Accession Number ML16084A735).

9. NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, dated December 2014 (ADAMS Accession Number ML14352A297).

10. NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 11, dated February 2017 (ADAMS Accession Number ML17038A432).

11. NRC Regulatory Guide 1.8, Personnel Selection and Training, Revision 1, dated September 1975.

12. Letter from NRC to NSP, Prairie Island Nuclear Generating Plant, Unit Nos. 1 and 2 -

Issuance of Amendments Re: Revised Administrative Controls (TAC Nos. M95130 and M95131), dated December 7, 1998 (ADAMS Accession Number ML022260707).

13. Letter from NRC to Exelon Generation Company, Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No.1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments Re: Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators (TAC NOS. ME9047, ME9048, ME9049, ME9050, ME9051, ME9052, ME9053, ME9054, ME9055, ME9056, ME9057, ME9058, ME9059, ME9060, ME9061, ME9062 AND ME9063), dated June 20, 2013 (ADAMS Accession Number ML13079A372).

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L-XE-17-001 NSPM Enclosure

14. Letter from NRC to FirstEnergy Nuclear Operating Company, Beaver Valley Power Station, Unit Nos. 1 and 2; and Davis-Besse Nuclear Power Station, Unit No. 1 -

Issuance of Amendments Re: Revision to Technical Specification 5.3.1, Unit Staff Qualifications, (TAC NOS. MF7118, MF7119, AND MF7120), dated June 7, 2016 (ADAMS Accession Number ML16040A084).

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ENCLOSURE, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators TECHNICAL SPECIFICATION PAGES (Markup)

(2 Pages Follow)

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.1.2 The shift supervisor (SS) shall be responsible for the control room command function. During any absence of the shift supervisorSS from the control room while the unit is in MODE 1, 2, 3, or 4, an individual with an active senior reactor operator (SRO) license shall be designated to assume the control room command function. During any absence of the shift supervisorSS from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or reactor operator (RO) license shall be designated to assume the control room command function.

Prairie Island Unit 1 - Amendment No. 158 XXX Units 1 and 2 5.0-1 Unit 2 - Amendment No. 149 XXX

Plant Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Plant Staff Qualifications 5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

In addition, the operations manager shall be qualified as required by TS 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55.

except for the operations manager who shall meet the requirements of ANSI N18.1-1971, except that NRC license requirements are as specified in TS 5.2.2.e.

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

Prairie Island Unit 1 - Amendment No. 184 188 205 XXX Units 1 and 2 5.0-5Unit 2 - Amendment No. 174 177 192 XXX

ENCLOSURE, ATTACHMENT 2 MONTICELLO NUCLEAR GENERATING PLANT License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators TECHNICAL SPECIFICATION PAGES (Markup)

(3 Pages Follow)

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affects nuclear safety.

5.1.2 The shift supervisor shall be responsible for the control room command function.

During any absence of the shift supervisor from the control room complex while the unit is in MODE 1, 2, or 3, an individual with an active senior reactor operator (SRO) Senior Operator license shall be designated to assume the control room command function. During any absence of the shift supervisor from the control room complex while the unit is in MODE 4 or 5, an individual with an active SROSenior Operator license or reactor operator (RO)Operator license shall be designated to assume the control room command function.

Monticello 5.1-1 Amendment No. 146, XXX

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

c. A radiation protection technician shall be on site when fuel is in the reactor.

The 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 unexpected absence, provided immediate action is taken to fill the required position.

d. Not Used.

e. The operations manager shall hold an SRO Senior Operator license or shall formerly have held an SRO Senior Operator license. If the operations manager does not hold an SRO Senior Operator license, another member of plant management shall hold an SRO enior Operator license and shall be assigned to the plant operations group on a long term basis (approximately 2 years). This individual shall not be assigned to a rotating shift.

f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Monticello 5.2-2 Amendment No. 146 , 163, XXX

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 minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

the radiation protection manager. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975..

In addition, the operations manager shall be qualified as required by Specification 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55..

5.3.2 For the purpose of 10 CFR 55.4, a licensed SROSenior Operator and a licensed ROOperator are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Monticello 5.3-1 Amendment No. 146, XXX

ENCLOSURE, ATTACHMENT 3 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators TECHNICAL SPECIFICATION PAGES (Re-typed)

(2 Pages Follow)

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.1.2 The shift supervisor shall be responsible for the control room command function. During any absence of the shift supervisor from the control room while the unit is in MODE 1, 2, 3, or 4, an individual with an active senior reactor operator (SRO) license shall be designated to assume the control room command function. During any absence of the shift supervisor from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or reactor operator (RO) license shall be designated to assume the control room command function.

Prairie Island Unit 1 - Amendment No. 158 XXX Units 1 and 2 5.0-1 Unit 2 - Amendment No. 149 XXX

Plant Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Plant Staff Qualifications 5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

In addition, the operations manager shall be qualified as required by TS 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55.

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 the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

Prairie Island Unit 1 - Amendment No. 188 205 XXX Units 1 and 2 5.0-5 Unit 2 - Amendment No. 177 192 XXX

ENCLOSURE, ATTACHMENT 4 MONTICELLO NUCLEAR GENERATING PLANT License Amendment Request to Revise Technical Specification for Plant/Unit Staff Qualifications Education and Experience Eligibility Requirements for Licensed Operators TECHNICAL SPECIFICATION PAGES (Re-typed)

(3 Pages Follow)

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affects nuclear safety.

5.1.2 The shift supervisor shall be responsible for the control room command function.

During any absence of the shift supervisor from the control room complex while the unit is in MODE 1, 2, or 3, an individual with an active senior reactor operator (SRO) license shall be designated to assume the control room command function. During any absence of the shift supervisor from the control room complex while the unit is in MODE 4 or 5, an individual with an active SRO license or reactor operator (RO) license shall be designated to assume the control room command function.

Monticello 5.1-1 Amendment No. 146, XXX

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

c. A radiation protection technician shall be on site when fuel is in the reactor.

The 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 unexpected absence, provided immediate action is taken to fill the required position.

d. Not Used.

e. The operations manager shall hold an SRO license or shall formerly have held an SRO license. If the operations manager does not hold an SRO license, another member of plant management shall hold an SRO license and shall be assigned to the plant operations group on a long term basis (approximately 2 years). This individual shall not be assigned to a rotating shift.

f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Monticello 5.2-2 Amendment No. 146, 163, XXX

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 minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

In addition, the operations manager shall be qualified as required by Specification 5.2.2.e.

The licensed operators shall comply only with the requirements of 10 CFR 55.

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 the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Monticello 5.3-1 Amendment No. 146, XXX