NL-24-0117, Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 and License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from Technical Specifications to the Quality Assura

Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 and License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from Technical Specifications to the Quality Assuranc

ML25023A218
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	01/23/2025
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-24-0117
Download: ML25023A218 (1)

Text

3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 tel Regulatory Affairs January 23, 2025 Docket Nos.: 50-321 50-348 50-424 52-025 NL-24-0117 50-366 50-364 50-425 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 and License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Ladies and Gentlemen:

In accordance with 10 CFR 50.54(a)(4), Southern Nuclear Operating Company (SNC) requests approval of a proposed change to the SNC Quality Assurance Topical Report (QATR) and Nuclear Development Quality Assurance Manual (NDQAM). The proposed change would adopt Regulatory Guide 1.8 Revision 4 and extend an NRC-endorsed provision for crediting experience towards a baccalaureate, allowing individuals without a baccalaureate to serve in certain management positions.

Additionally, pursuant to 10 CFR 50.90, SNC hereby requests a license amendment to the Edwin I. Hatch Nuclear Plant (HNP) Unit 1 Renewed Facility Operating License (RFOL) DPR-57 and Unit 2 RFOL NPF-5; the Joseph M. Farley Nuclear Plant (FNP) Unit 1 RFOL NPF-2 and Unit 2 RFOL NPF-8; and the Vogtle Electric Generating Plant (VEGP) Unit 1 RFOL NPF-68, Unit 2 RFOL NPF-81, Unit 3 Combined License (COL) NPF-91, and Unit 4 COL NPF-92. The proposed amendment removes the Unit/Facility/Plant staff qualification requirements from the respective plant Technical Specifications (TS) and relocates control of the Unit/Facility/Plant staff qualification requirements to the QATR and NDQAM consistent with the guidance in NRC Administrative Letter 95-06.

to this letter provides the description and assessment of the proposed QATR and NDQAM changes. Enclosure 1 Attachments 1 and 2 provide the existing QATR and NDQAM, respectively, marked up to show proposed changes. Enclosure 1 Attachments 3 and 4 provide clean-typed QATR pages and NDQAM pages, respectively.

U. S. Nuclear Regulatory Commission NL-24-0117 Page 2 of 3 to this letter provides the description and assessment of the proposed TS changes and the no significant hazards consideration determination. Enclosure 2 Attachments 1 through 5 provide the existing TS pages marked up to show the proposed changes. Enclosure 2 Attachments 6 through 10 provide the clean-typed TS pages showing the proposed changes.

Approval of the changes to the QATR and NDQAM and proposed amendment is requested within one year of completion of the NRCs acceptance review.

Once approved, the HNP, FNP, and VEGP Units 1 and 2 amendments and quality assurance program changes shall be implemented within 180 days. The VEGP Units 3 and 4 amendments and quality assurance plan changes shall be implemented within 180 days following the first Unit 4 refueling outage or within 180 days following issuance of the amendments, whichever is later.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated Alabama and Georgia Officials.

This letter contains no regulatory commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of January 2025.

Respectfully submitted, Jamie Coleman Director, Regulatory Affairs Southern Nuclear Operating Company JMC/agq/cbg

Description and Justification of Quality Assurance Program Changes Attachments: 1.

Proposed Quality Assurance Topical Report (QATR) Changes (Marked-up Pages)

2.

Proposed Nuclear Development Quality Assurance Manual (NDQAM) Changes (Marked-up Pages)

3.

Proposed Quality Assurance Topical Report (QATR) Changes (Clean Pages)

4.

Proposed Nuclear Development Quality Assurance Manual (NDQAM) Changes (Clean Pages)

Description and Assessment of the Proposed Technical Specifications Changes

U. S. Nuclear Regulatory Commission NL-24-0117 Page 3 of 3 Attachments: 1.

Proposed HNP Unit 1 Technical Specifications Changes (Marked-up Pages)

2.

Proposed HNP Unit 2 Technical Specifications Changes (Marked-up Pages)

3.

Proposed FNP Units 1 and 2 Technical Specifications Changes (Marked-up Pages)

4.

Proposed VEGP Units 1 and 2 Technical Specifications Changes (Marked-up Pages)

5.

Proposed VEGP Units 3 and 4 Technical Specifications Changes (Marked-up Pages)

6.

Proposed HNP Unit 1 Technical Specifications Changes (Clean Pages)

7.

Proposed HNP Unit 2 Technical Specifications Changes (Clean Pages)

8.

Proposed FNP Units 1 and 2 Technical Specifications Changes (Clean Pages)

9.

Proposed VEGP Units 1 and 2 Technical Specifications Changes (Clean Pages)

10. Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages) cc:

Regional Administrator, Region ll NRR Project Manager - Hatch 1&2, Farley 1&2, Vogtle 1&2, and Vogtle 3&4 Senior Resident Inspector - Hatch 1&2, Farley 1&2, Vogtle 1&2, and Vogtle 3&4 Director, Alabama Office of Radiation Control State of Georgia Environmental Protection Division R-Type: CGA02.001

to NL-24-0117 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 Description and Justification of Quality Assurance Program Changes to NL-24-0117 Description and Justification of Quality Assurance Program Changes Page 1 of 4

1. Introduction In accordance with 10 CFR 50.54(a)(4), SNC requests approval of a proposed change to the Quality Assurance Topical Report (QATR) and Nuclear Development Quality Assurance Manual (NDQAM). The proposed change would commit to Regulatory Guide 1.8 Revision 4 and extend an NRC-endorsed provision for crediting experience towards a baccalaureate, allowing individuals without a baccalaureate to serve in certain management positions. This proposed change includes a reduction in commitment requiring NRC approval prior to implementation.

To fully implement the proposed quality assurance program changes, corresponding changes are needed to each plants Technical Specifications (TS). The proposed TS changes and the evaluation of the TS changes are provided in accordance with 10 CFR 50.90 in Enclosure 2.

2. Description of the Proposed Changes Section 2.3 of the QATR is updated to refer to Part III, Regulatory Commitments, rather than each sites Technical Specifications, and the Part III section regarding Regulatory Guide 1.8 is updated to specify Regulatory Guide 1.8 Revision 4. Additionally, an exception and clarification are added. The exception allows, for select plant management positions, experience to be substituted for education at a higher rate and for a higher total number of semester credit hours.

The clarification states, in effect, that personnel who remain in the position they hold during the adoption of Regulatory Guide 1.8 Revision 4 are not required to be requalified to Regulatory Guide 1.8 Revision 4. These changes are shown below:

Regulatory Guide 1.8 Revision 4 - Qualification and Training of Personnel for Nuclear Power Plants Southern Nuclear meets the requirement of the applicable Technical Specifications Regulatory Guide 1.8 Revision 4 for each plant for the selection and training of nuclear power plant personnel, with the following exceptions:

o For the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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:

Plant Manager Operations Director (Operations Senior Manager)

Maintenance Director (Maintenance Senior Manager)

Training Director (Training Senior Manager)

Chemistry Manager Radiation Protection Manager Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

Part II, Section 7.2 of the NDQAM is updated to refer to the Part IV of the NDQAM rather than the Technical Specifications, and Part IV, Regulatory Commitments Section 1.1 is updated as follows:

to NL-24-0117 Description and Justification of Quality Assurance Program Changes Page 2 of 4 1.1 Regulatory Guide 1.8, Rev. 34, May 2000June 2019, Qualification and Training of Personnel for Nuclear Power Plants 1.1.1 Regulatory Guide 1.8 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel.

1.1.2 SNC identifiedconformsance with this regulatory guide except for the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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:and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1, Appendix 1A.

o Plant Manager o Operations Director (Operations Senior Manager) o Maintenance Director (Maintenance Senior Manager) o Training Director (Training Senior Manager) o Chemistry Manager o Radiation Protection Manager 1.1.3 Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

3. Justification for the Proposed Changes 3.1 Adoption of Regulatory Guide 1.8 Revision 4 Regulatory Guide 1.8 Revision 4, Qualification and Training of Personnel for Nuclear Power Plants, describes methods acceptable to the staff of the NRC for complying with 10 CFR 50.120, 10 CFR 50.34(b)(6)(i), and 10 CFR 52.79(a)(26). Edwin I. Hatch Nuclear Plant (HNP), Joseph M. Farley Nuclear Plant (FNP), Vogtle Electric Generating Plant (VEGP)

Units 1 and 2, and VEGP Units 3 and 4 currently follow prior versions of Regulatory Guide 1.8 or their endorsed standards. Thus, the change to commit to Regulatory Guide 1.8 Revision 4 represents the use of a method that the NRC staff finds acceptable for complying with the applicable regulatory requirements. An exception to Regulatory Guide 1.8 Revision 4 is requested and evaluated in the subsequent paragraphs.

3.2 Exception to Regulatory Guide 1.8 Revision 4 - Experience Substitute for Education The exception would allow experience to be substituted at a rate of 8 semester credit hours (SCHs) per year of experience up to 80 SCHs. This proposed exception is an extension of ANSI/ANS-3.1-2014 section 4.1.1.2, Experience substitution for education which allows experience to be substituted for education at a rate of 6 SCHs per year of experience up to 60 SCHs. The proposed extension of this provision would allow the criteria of ANSI/ANS-3.1-2014 section 4.1.1.1, Alternatives to degree requirements example (3)(c) to be met by crediting experience only. This would provide another example case-by-case basis that could be objectively applied when evaluating an individual against degree requirements.

to NL-24-0117 Description and Justification of Quality Assurance Program Changes Page 3 of 4 The exception to expand the ANSI/ANS-3.1-2014 experience substitution for education provision is acceptable for the select positions because, for these positions, an individuals level of experience and their ability to manage performance and motivate are more indicative than education level in terms of their abilities to perform these roles. This exception would not apply to individual contributors (e.g., engineers, chemistry technicians, radiation protection technicians, etc.), as well as their first line supervisors, who will still be subject to specific qualification requirements (including education levels) necessary for their job functions, providing assurance that those functions will be performed with quality.

Lastly, a baccalaureate has generally become a proxy for a candidates range and depth of skills, including soft skills such as the ability to manage and motivate others and the ability to resolve critical issues. However, this is not always an accurate proxy, especially for soft skills, and requiring a baccalaureate can result in eliminating candidates who possess some of the more important competencies that are required (Reference 1). By not automatically disqualifying candidates who demonstrate exceptional management and leadership abilities but who do not have baccalaureates, the candidate pool diversity, quantity, and quality can be increased leading to better selection outcomes.

3.3 Clarification Regarding Personnel in Position at the Time of Transition This clarification is based on Reference 2 and removes any ambiguity regarding the qualification status of personnel in position at the time of transition to Regulatory Guide 1.8 Revision 4. Note that this clarification would not apply to previous positions an individual may have held; this clarification would apply only to the individuals position at the time of transitioning to Regulatory Guide 1.8 Revision 4. Such personnel would already be qualified under the existing requirements of SNCs NRC-approved Technical Specifications, as well as the QATR or NDQAM, as applicable. Re-evaluating personnel qualifications upon implementing conformance with RG 1.8 Revision 4 would be an overly burdensome effort with no benefit to the safe operation of the plants.

3.4 Operators Licenses This quality assurance program change does not alter SNCs operator license program.

Operators licenses are governed by 10 CFR Part 55, Operators Licenses, which was removed from the scope of Regulatory Guide 1.8 Revision 4 so that NRC guidance for operator license qualifications is now located in NUREG-1021, Operator Licensing Examination Standards for Power Reactors. SNC meets the requirements of 10 CFR Part 55 and NUREG-1021 through its site operations training programs accredited by the National Nuclear Accrediting Board (NNAB).

4. Basis for Concluding that the Revised Program Continues to Satisfy the Criteria of 10 CFR 50 Appendix B and the Previously Accepted Quality Assurance Program Commitments The proposed changes, though considered a reduction in commitment, continue to satisfy the Criteria of 10 CFR 50 Appendix B. Specifically:

Adoption of Regulatory Guide 1.8 Revision 4. The adoption of Regulatory Guide 1.8 Revision 4 represents the use of method that is acceptable to the NRC staff for complying with those portions of the NRCs regulations associated with the selection, qualifications, and training of nuclear power plant personnel. The adoption of Regulatory Guide 1.8 to NL-24-0117 Description and Justification of Quality Assurance Program Changes Page 4 of 4 Revision 4 does not alter the structure of the SNC standard plant organization nor does it alter any of the responsibilities of any members of the SNC standard plant organization.

Exception to Regulatory Guide 1.8 Revision 4 - Experience Substitute for Education. When utilized for an individual with no credit hours towards a baccalaureate, the individual would be required to have at least ten years of experience (i.e., at least four more than required for any of the applicable positions). The positions to which this exception applies are all leadership positions for which experience is of great value. In addition, beyond quality assurance, SNCs internal succession planning and leadership programs assess and develop candidates talent through meaningful experiences, providing further assurance that leaders are qualified.

5. Conclusion The proposed change is compliant with, and continues to satisfy, the criteria of 10 CFR 50 Appendix B, as incorporated into the SNC QATR and NDQAM.

6. References

1. Fuller, J., Raman, M., et al. (October 2017). Dismissed By Degrees. Published by Accenture, Grads of Life, Harvard Business School.

2. ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Issuance of Amendments, Revise QA Program Manual and Staff Qualification Technical Specifications (ML12347A140).

to NL-24-0117, Attachment 1 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 Proposed Quality Assurance Topical Report (QATR) Changes (Marked-up Pages)

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

QUALITY ASSURANCE TOPICAL REPORT II.2-2 Version 27.0 2.3 Personnel Qualifications Personnel assigned to implement elements of the QAP shall be capable of performing their assigned tasks. To this end SNC establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the QAP to assure that suitable proficiency is achieved and maintained. Plant and support staff minimum qualification requirements are in accordance with Regulatory Guide 1.8 as delineated in Part III Regulatory Commitments.each sites Technical Specifications. Other qualification requirements may be established but will not reduce those required bycommitted to in Technical Specifications Part III. Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable SNC procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAP elements to be employed.

Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained.

The minimum qualifications of the senior manager responsible for quality assurance are that the manager holds an engineering degree, or a degree in a related science, and has a minimum of five years experience in the areas of engineering, field construction, or plant operations. Two of these five years must involve working under a nuclear quality assurance program.

2.4 NQA-1-1994 Commitment In establishing qualification and training programs, SNC commits to compliance with NQA-1-1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications and exceptions:

NQA-1-1994, Supplement 2S-1

- SNC Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 the same as if it were part of the Supplement. The following two alternatives may be applied to the implementation of this Supplement and Appendix:

In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determine who will

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

QUALITY ASSURANCE TOPICAL REPORT III-1 Version 27.0 PART III REGULATORY COMMITMENTS NRC Regulatory Guides and Quality Assurance Standards.

This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the SNC QA Program.

Southern Nuclear commits to compliance with these standards to the extent described herein. Commitment to a particular Regulatory Guide or other QA standard does not constitute a commitment to the Regulatory Guides or QA standards that may be referenced therein.

Regulatory Guide 1.8 Revision 4 - Qualification and Training of Personnel for Nuclear Power Plants

- Southern Nuclear meets the requirement of the applicable Technical SpecificationsRegulatory Guide 1.8 Revision 4 for each plant for the selection and training of nuclear power plant personnel, with the following exceptions.:

o For the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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:

Plant Manager Operations Director (Operations Senior Manager)

Maintenance Director (Maintenance Senior Manager)

Training Director (Training Senior Manager)

Chemistry Manager Radiation Protection Manager

- Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

- The SNC nuclear plant qualification and training program is described in Sections 13.1 and 13.2 of the FSARs.

Regulatory Guide 1.28, Revision 3, August, 1985 - Quality Assurance Program Requirements (Design and Construction)

- Southern Nuclear meets the requirements of this regulatory guide for Construction Activities conducted by Southern Nuclear, except that ASME NQA-1-1994 edition (as modified by the exceptions to NQA-1-1994 as shown in this QATR) will be used in place of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda.

to NL-24-0117, Attachment 2 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 Proposed Nuclear Development Quality Assurance Manual (NDQAM) Changes (Marked-up Pages)

PART II Nuclear Development Quality Assurance Manual Page 28 of 68 Version 25.1 4.0 Site-Specific Safety-Related Design Basis Activities Site-specific safety-related design basis activities are defined as those activities, including sampling, testing, data collection, and supporting engineering calculations and reports, that will be used to determine the bounding physical parameters of the site. Appropriate quality assurance measures are applied.

5.0 Periodic Review of the Quality Assurance Program Management of those organizations implementing the QA program or portions thereof, assess the adequacy of that part of the program for which they are responsible to assure its effective implementation at least once each year or at least once during the life of the activity, whichever is shorter.

6.0 Issuance and Revision to Quality Assurance Program Description 6.1 Administrative control of the NDQAM will be in accordance with 10 CFR 50.55(f) and 10 CFR 50.54(a), as appropriate. New revisions to the document will be reviewed, at a minimum, by the senior manager for quality assurance and approved by the EVP - Vogtle 3&4 and the senior manager for nuclear oversight.

6.2 Regulations require that the FSAR include, among other things, the managerial and administrative controls to be used to assure safe operation, including a discussion of how the applicable requirements of Appendix B will be satisfied. In order to comply with this requirement, the FSAR references this NDQAM and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the NDQAM.

7.0 Personnel Qualifications 7.1 Personnel assigned to implement elements of the NDQAP shall be capable of performing their assigned tasks. To this end, SNC establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the NDQAP to assure that suitable proficiency is achieved and maintained.

7.2 Plant and support staff meet the minimum qualification requirements of Regulatory Guide 1.8 Revision 4, as committed to in Part IVare as delineated in each sites Technical Specifications. Other qualification requirements may be established but will not reduce theose requirementsd by Technical Specifications. Sufficient managerial depth is provided to cover absences of incumbents.

7.3 When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable SNC procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the NDQAP elements to be employed.

7.4 Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training.

Records of personnel training and qualification are maintained.

PART IV Nuclear Development Quality Assurance Manual Page 66 of 68 Version 25.1 PART IV REGULATORY COMMITMENTS NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the SNC NDQAM. SNC complies with these standards to the extent described or referenced. Commitment to a particular Regulatory Guide or standard does not constitute a commitment to Regulatory Guides or standards that may be referenced therein.

1.0 Regulatory Guides 1.1 Regulatory Guide 1.8, Rev. 43, June 2019May 2000, Qualification and Training of Personnel for Nuclear Power Plants 1.1.1 Regulatory Guide 1.8 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel.

1.1.2 SNC identifies conformsance with this regulatory guide except for the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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: and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1, Appendix 1A.

Plant Manager Operations Director (Operations Senior Manager)

Maintenance Director (Maintenance Senior Manager)

Training Director (Training Senior Manager)

Chemistry Manager Radiation Protection Manager 1.1.3 Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

1.2 Regulatory Guide 1.26, Revision 4, March 2007 - Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 1.2.1 Regulatory Guide 1.26 defines classification of systems and components.

1.2.2 SNC identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1, Appendix 1A.

to NL-24-0117, Attachment 3 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 Proposed Quality Assurance Topical Report (QATR) Changes (Clean Pages)

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

QUALITY ASSURANCE TOPICAL REPORT II.2-2 Version 2.3 Personnel Qualifications Personnel assigned to implement elements of the QAP shall be capable of performing their assigned tasks. To this end SNC establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the QAP to assure that suitable proficiency is achieved and maintained. Plant and support staff minimum qualification requirements are in accordance with Regulatory Guide 1.8 as delineated in Part III Regulatory Commitments. Other qualification requirements may be established but will not reduce those committed to in Part III. Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable SNC procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAP elements to be employed.

Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained.

The minimum qualifications of the senior manager responsible for quality assurance are that the manager holds an engineering degree, or a degree in a related science, and has a minimum of five years experience in the areas of engineering, field construction, or plant operations. Two of these five years must involve working under a nuclear quality assurance program.

2.4 NQA-1-1994 Commitment In establishing qualification and training programs, SNC commits to compliance with NQA-1-1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications and exceptions:

NQA-1-1994, Supplement 2S-1

- SNC Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 the same as if it were part of the Supplement. The following two alternatives may be applied to the implementation of this Supplement and Appendix:

In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determine who will be responsible for performing the inspections), evaluating inspection

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

QUALITY ASSURANCE TOPICAL REPORT III-1 Version PART III REGULATORY COMMITMENTS NRC Regulatory Guides and Quality Assurance Standards.

This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the SNC QA Program.

Southern Nuclear commits to compliance with these standards to the extent described herein. Commitment to a particular Regulatory Guide or other QA standard does not constitute a commitment to the Regulatory Guides or QA standards that may be referenced therein.

Regulatory Guide 1.8 Revision 4 - Qualification and Training of Personnel for Nuclear Power Plants

- Southern Nuclear meets the requirement of Regulatory Guide 1.8 Revision 4 for each plant for the selection and training of nuclear power plant personnel, with the following exceptions:

o For the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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:

Plant Manager Operations Director (Operations Senior Manager)

Maintenance Director (Maintenance Senior Manager)

Training Director (Training Senior Manager)

Chemistry Manager Radiation Protection Manager

- Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

- The SNC nuclear plant qualification and training program is described in Sections 13.1 and 13.2 of the FSARs.

Regulatory Guide 1.28, Revision 3, August, 1985 - Quality Assurance Program Requirements (Design and Construction)

- Southern Nuclear meets the requirements of this regulatory guide for Construction Activities conducted by Southern Nuclear, except that ASME NQA-1-1994 edition (as modified by the exceptions to NQA-1-1994 as shown in this QATR) will be used in place of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda.

to NL-24-0117, Attachment 4 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 Change to Quality Assurance Program to Adopt Regulatory Guide 1.8 Revision 4 Proposed Nuclear Development Quality Assurance Manual (NDQAM) Changes (Clean Pages)

PART II Nuclear Development Quality Assurance Manual Page 28 of 68 Version 4.0 Site-Specific Safety-Related Design Basis Activities Site-specific safety-related design basis activities are defined as those activities, including sampling, testing, data collection, and supporting engineering calculations and reports, that will be used to determine the bounding physical parameters of the site. Appropriate quality assurance measures are applied.

5.0 Periodic Review of the Quality Assurance Program Management of those organizations implementing the QA program or portions thereof, assess the adequacy of that part of the program for which they are responsible to assure its effective implementation at least once each year or at least once during the life of the activity, whichever is shorter.

6.0 Issuance and Revision to Quality Assurance Program Description 6.1 Administrative control of the NDQAM will be in accordance with 10 CFR 50.55(f) and 10 CFR 50.54(a), as appropriate. New revisions to the document will be reviewed, at a minimum, by the senior manager for quality assurance and approved by the EVP - Vogtle 3&4 and the senior manager for nuclear oversight.

6.2 Regulations require that the FSAR include, among other things, the managerial and administrative controls to be used to assure safe operation, including a discussion of how the applicable requirements of Appendix B will be satisfied. In order to comply with this requirement, the FSAR references this NDQAM and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the NDQAM.

7.0 Personnel Qualifications 7.1 Personnel assigned to implement elements of the NDQAP shall be capable of performing their assigned tasks. To this end, SNC establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the NDQAP to assure that suitable proficiency is achieved and maintained.

7.2 Plant and support staff meet the minimum qualification requirements of Regulatory Guide 1.8 Revision 4, as committed to in Part IV. Other qualification requirements may be established but will not reduce these requirements. Sufficient managerial depth is provided to cover absences of incumbents.

7.3 When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable SNC procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the NDQAP elements to be employed.

7.4 Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training.

Records of personnel training and qualification are maintained.

PART IV Nuclear Development Quality Assurance Manual Page 66 of 68 Version PART IV REGULATORY COMMITMENTS NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the SNC NDQAM. SNC complies with these standards to the extent described or referenced. Commitment to a particular Regulatory Guide or standard does not constitute a commitment to Regulatory Guides or standards that may be referenced therein.

1.0 Regulatory Guides 1.1 Regulatory Guide 1.8, Rev. 4, June 2019, Qualification and Training of Personnel for Nuclear Power Plants 1.1.1 Regulatory Guide 1.8 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel.

1.1.2 SNC conforms with this regulatory guide except for the following positions, the ANSI/ANS-3.1-2014 Section 4.1.1.2, Experience substitution for education is expanded 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:

Plant Manager Operations Director (Operations Senior Manager)

Maintenance Director (Maintenance Senior Manager)

Training Director (Training Senior Manager)

Chemistry Manager Radiation Protection Manager 1.1.3 Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

1.2 Regulatory Guide 1.26, Revision 4, March 2007 - Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 1.2.1 Regulatory Guide 1.26 defines classification of systems and components.

1.2.2 SNC identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1, Appendix 1A.

to NL-24-0117 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Description and Assessment of the Proposed Technical Specifications Changes to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 1 of 9 1

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit Southern Nuclear Operating Company (SNC) requests an amendment to the Edwin I. Hatch Nuclear Plant (HNP) Unit 1 Renewed Facility Operating License (RFOL)

DPR-57 and Unit 2 RFOL NPF-5; Joseph M. Farley Nuclear Plant (FNP) Unit 1 RFOL NPF-2 and Unit 2 RFOL NPF-8; and the Vogtle Electric Generating Plant (VEGP) Unit 1 RFOL NPF-68, Unit 2 RFOL NPF-81, Unit 3 Combined License (COL) NPF-91, and Unit 4 COL NPF-92. Consistent with the guidance of NRC Administrative Letter 95-06, Relocation of Technical Specification Administrative Controls, the proposed license amendment will relocate control of the unit staff qualification requirements from the respective plants Technical Specifications (TS) to either the SNC Quality Assurance Topical Report (QATR) (Reference 1) or SNC Nuclear Development Quality Assurance Manual (NDQAM) (Reference 2) as applicable.

This evaluation addresses the requested TS changes. Proposed quality assurance program changes are described and evaluated in Enclosure 1 to this letter.

2 DETAILED DESCRIPTION 2.1 Current Technical Specifications Requirements Each plant units TS Section 5.3, Unit Staff Qualifications, contains the staff qualifications requirements for that unit.

Section 5.3 of the HNP Unit 1 TS and Unit 2 TS each require:

5.3.1 Each member of the unit staff, including plant manager, shall either meet or exceed the minimum qualifications of ANSI N18.1-1971, or shall meet or exceed the minimum qualifications of the accredited program requirements for those positions stipulated in Enclosure 1 to letter NL-07-1925. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license. The senior individual in charge of radiation protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

The positions stipulated in Enclosure 1 to letter NL-07-1925 (ML072910386) are: mechanic, electrician, instrument and control technician, first line maintenance supervisor, health physics technician, chemistry technician, reactor operator, senior reactor operator, and engineer.

Section 5.3 of the FNP Units 1 and 2 TS requires:

5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in 10 CFR 55, except for (1) the senior individual in charge of radiation protection who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 2 of 9 Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

Section 5.3 of the VEGP Units 1 and 2 TS requires:

5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 2, 1987, and, for licensed staff, 10 CFR 55.59. Prior to meeting the recommendations of Regulatory Guide 1.8, Revision 2, personnel may be trained to perform specific tasks and will be qualified to perform those tasks independently.

Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

Section 5.3 of the VEGP Units 3 and 4 TS requires:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 3, 2000, with the following exception:

a.

During cold license operator training through the first refueling outage, the Regulatory Position C.1.b of Regulatory Guide 1.8, Revision 2, 1987, applies: cold license operator candidates meet the training elements defined in ANSI/ANS 3.1-1993 but are exempt from the experience requirements defined in ANSI/ANS 3.1-1993.

5Property "ANSI code" (as page type) with input value "ANSI/ANS 3.1-1993.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed 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).

2.2 Reason for the Proposed Changes The Technical Specifications for HNP, FNP, VEGP Units 1 and 2, and VEGP Units 3 and 4 each contain unit staff qualifications requirements as stated in Section 2.1 above. SNC desires to relocate control of this administrative information to its quality assurance program, consistent with NRC Administrative Letter (AL) 95-06, in order to eliminate the need for future license amendment requests due only to upgrades to newer qualification and training standards endorsed by future revisions of Regulatory Guide 1.8.

Additionally, the training and qualification requirements currently vary from site to site. SNC desires to relocate control of these requirements to a central location (i.e., the quality assurance program) and conduct its training and qualification programs to a common NRC-endorsed standard for its whole fleet.

2.3 Description of the Proposed Change It is proposed to relocate control of the unit staff qualifications from each plants TS to the quality assurance program. For HNP Units 1 and 2, FNP Units 1 and 2, and VEGP Units 1 and 2, the specific TS 5.3.1 requirements are each removed and replaced with a reference to the SNC QATR. For VEGP Units 3 and 4, the specific TS 5.3.1 requirements are removed and replaced to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 3 of 9 with a reference to the SNC NDQAM or the SNC QATR. The changes are shown below; deleted text is shown as strikethrough, and added text is shown as underline. The QATR and NDQAM are updated, as shown in Enclosure 1 to this letter, to include the new training and qualification requirements (i.e., Regulatory Guide 1.8 Revision 4 with exceptions) rather than referring to each plants Technical Specifications.

Section 5.3 of the HNP Unit 1 TS and Unit 2 TS are each proposed to be changed as follows:

5.3.1 Each member of the unit staff, including plant manager, shall either meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report. of ANSI N18.1-1971, or shall meet or exceed the minimum qualifications of the accredited program requirements for those positions stipulated in Enclosure 1 to letter NL-07-1925. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license. The senior individual in charge of radiation protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

Section 5.3 of the FNP Units 1 and 2 TS is proposed to be changed as follows:

5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report. of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in 10 CFR 55, except for (1) the senior individual in charge of radiation protection who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

Section 5.3 of the VEGP Units 1 and 2 TS is proposed to be changed as follows:

5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report. of Regulatory Guide 1.8, Revision 2, 1987, and, for licensed staff, 10 CFR 55.59. Prior to meeting the recommendations of Regulatory Guide 1.8, Revision 2, personnel may be trained to perform specific tasks and will be qualified to perform those tasks independently. Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 4 of 9 The VEGP Units 3&4 TS are proposed to refer to either the SNC NDQAM or the SNC QATR to allow for the potential for transitioning VEGP Units 3&4 to the SNC QATR. Section 5.3 of the VEGP Units 3 and 4 TS is proposed to be changed as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications specified in either the SNC Nuclear Development Quality Assurance Manual or the SNC Quality Assurance Topical Report.of Regulatory Guide 1.8, Revision 3, 2000, with the following exception:

a.

During cold license operator training through the first refueling outage, the Regulatory Position C.1.b of Regulatory Guide 1.8, Revision 2, 1987, applies: cold license operator candidates meet the training elements defined in ANSI/ANS 3.1-1993 but are exempt from the experience requirements defined in ANSI/ANS 3.1-1993.

5Property "ANSI code" (as page type) with input value "ANSI/ANS 3.1-1993.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed 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).

3 TECHNICAL EVALUATION 3.1 Relocation of TS Requirements to Quality Assurance NRC AL 95-06 informed licensees about recent experiences involving the relocation of technical specification administrative controls related to quality assurance. Consistent with AL 95-06, the proposed amendment relocates control of the unit staff qualification requirements from TS Section 5.3 for each plant as described above, to either the SNC QATR or the SNC NDQAM as applicable per plant. The proposed relocation is acceptable since training and qualification requirements will continue to be mandated by either the SNC QATR or the SNC NDQAM as applicable. In addition, future changes to these requirements from the SNC QATR or the SNC NDQAM would require prior NRC approval, in accordance with 10 CFR 50.54(a)(4),

unless the changes did not reduce the commitments in the program description as accepted by the NRC.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. SNC has determined that existing requirements continue to be met and that the proposed changes do not require any exemptions or relief from regulatory requirements. The following current applicable regulations and regulatory requirements were reviewed in making this determination:

10 CFR 50.36 10 CFR 50.36 Technical specifications, establishes the requirements related to the content of the Technical Specifications (TS). Section 50.36(c)(5) requires provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting to be included in the technical specifications that are necessary to assure operation of the facility in a safe manner. The proposed changes conform to 10 CFR 50.36(c)(5) requirements.

to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 5 of 9 10 CFR 50.120 10 CFR 50.120, Training and qualification of nuclear power plant personnel, requires that each nuclear power plant licensee or applicant for an operator license to establish, implement, and maintain the training and qualification programs that are derived from a systems approach to training as defined in 10 CFR 55.4. The proposed changes conform to 10 CFR 50.120 requirements.

10 CFR 55 10 CFR 55, Operators' Licenses, Subpart D, Applications, requires that operator license applications include information concerning an individual's education, experience, and other related matters to provide evidence and certification that the applicant has successfully completed the facility licensees training program that is based on a systems approach to training. The proposed changes conform to 10 CFR 55 requirements.

NUREG-1021 NUREG-1021, Operator Licensing Examination Standards for Power Reactors, establishes the policies, procedures, and practices for examining licensees and applicants for reactor operator and senior reactor operator licenses at nuclear power reactor facilities under 10 CFR Part 55, Operators' Licenses. The SNC operator training program meets the current requirements of National Academy for Nuclear Training (NANT) Document (ACAD), ACAD 10-001. The proposed changes conform to NUREG-1021 requirements.

NRC Administrative Letter 95-06 AL 95-06, Relocation of Technical Specifications Administrative Controls Related to Quality Assurance, states that many license amendments were being processed that involved relocating requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation and relocating requirements that are controlled directly by regulations and related licensee programs. The AL states:

Increasingly, licensees are requesting amendments to technical specifications that are located in the administrative controls section and are related to quality assurance programs. Licensees have frequently requested amendments to these specifications because they contain detailed information that is affected by organizational and process changes. Many licensees have revised their technical specifications to remove excessive detail, thereby gaining flexibility in making organizational changes without the need for a license amendment. Recent amendment requests related to quality assurance have also followed the trend for other technical specifications and have included moving requirements to licensee controlled documents and programs. The quality assurance program is a logical candidate for such relocations due to the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the existence of U.S.

Nuclear Regulatory Commission-approved quality assurance plans and commitments to industry quality assurance standards, and the established quality assurance program change control process in 10 CFR50.54(a). The relocation of technical specification requirements in cases where adequate controls are provided by such other methods can reduce the resources spent by licensees and the U.S. Nuclear Regulatory Commission staff in preparing and reviewing license amendment requests.

The proposed changes to relocate control of facility/unit staff qualification requirements from the TS to the quality assurance program is consistent with the guidance in AL 95-06, as discussed in Section 3.1 above.

to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 6 of 9 4.2 Precedent The proposed change is consistent with other NRC-approved license amendments for relocating control of unit staff qualification requirements from the technical specifications to the quality assurance program. Such amendments have been issued to several other utilities /

licensees, including the following:

PSEG Nuclear on March 9, 2023 (ML23037A971) for Hope Creek Generating Station and Salem Nuclear Generating Station Units 1 and 2 (Reference 3).

Talen Energy on November 17, 2022 (ML22294A150) for Susquehanna Steam Electric Station Units 1 and 2 (Reference 4).

Dominion Energy South Carolina on December 28, 2021 (ML21319A262) for Virgil C.

Summer Nuclear Station Unit 1 (Reference 5).

Duke Energy on August 12, 2020 (ML20083F927) for Brunswick Steam Electric Plant, Units 1 and 2; Catawba Nuclear Station, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; and H.B. Robinson Steam Electric Plant, Unit No. 2 (Reference 6).

Exelon Generation Company, LLC on August 2, 2018 (ML18206A282) for Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R.E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station Unit 1 (Reference 7).

Tennessee Valley Authority (TVA) on March 27, 2017 (ML17034A360) for Browns Ferry Nuclear Plant, Units 1, 2, and 3 and Sequoyah Nuclear Plant, Units 1 and 2 (Reference 8).

4.3 No Significant Hazard Consideration Determination Analysis Southern Nuclear Operating Company (SNC) requests approval of a change to relocate control of the unit staff qualification requirements from the Technical Specifications (TS) for Edwin I.

Hatch Nuclear Plant (HNP) Unit 1, HNP Unit 2, Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2, and Vogtle Electric Generating Plant (VEGP) Units 1 and 2 to the SNC Quality Assurance Topical Report (QATR), and from the VEGP Units 3 and 4 TS to the Nuclear Development Quality Assurance Manual (NDQAM).

SNC has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as described below:

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

Response: No The proposed change involves relocating control of the unit staff qualification requirements from each SNC plants TS to the SNC QATR, for HNP Units 1 and 2; to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 7 of 9 FNP Units 1 and 2; and VEGP Units 1 and 2; and to either the SNC NDQAM or the SNC QATR for VEGP Units 3 and 4. The proposed changes are administrative in nature and do not make any physical changes to the plants and do not alter accident analysis assumption, add any accident initiators, or affect the function of the plants.

Additionally, the proposed changes do not involve any changes to the operation, maintenance, testing, or inspection of any systems.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change involves relocating control of the unit staff qualification requirements from each SNC plants TS to the SNC QATR, for HNP Units 1 and 2; FNP Units 1 and 2; and VEGP Units 1 and 2; and to either the SNC NDQAM or the SNC QATR for VEGP Units 3 and 4. The proposed changes are administrative in nature and do not make any physical changes to any SSCs and therefore do not affect any SSCs operation or its ability to perform its design function.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change involves relocating control of the unit staff qualification requirements from each SNC plants TS to the SNC QATR, for HNP Units 1 and 2; FNP Units 1 and 2; and VEGP Units 1 and 2; and to either the SNC NDQAM or the SNC QATR for VEGP Units 3 and 4. The proposed changes are administrative in nature and do not make any physical changes to any SSCs and therefore do not affect any SSCs operation or its ability to perform its design function. The proposed changes do not impact any plant safety margins that are established in existing limiting conditions for operation, limiting safety systems settings, and specified safety limits.

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

Based on the above, SNC concludes that the proposed change presents no 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 In conclusion, based on the considerations discussed above, SNC concludes: (1) there is reasonable assurance that the health and safety of the public will not be endangered by to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 8 of 9 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 the health and safety of the public.

5 ENVIRONMENTAL CONSIDERATION The proposed amendment is confined to changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6 REFERENCES

1. Southern Nuclear Operating Company Quality Assurance Topical Report, Version 27.0, December 2024.

2. Southern Nuclear Operating Company Nuclear Development Quality Assurance Manual, Version 25.1, January 2025.

3. PSEG Nuclear - Hope Creek and Salem Nuclear Generating Station Units 1 and 2 -

Issuance of Amendments to Relocate the Technical Specification Staff Qualification Requirements to the PSEG Quality Assurance Topical Report, Dated March 9, 2023 (ADAMS Accession No. ML23037A971).

4. Talen Energy - Susquehanna Steam Electric Station Units 1 and 2 - Issuance of Amendments Relocating Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program, Dated November 17, 2022 (ADAMS Accession No. ML22294A150).

5. Dominion Energy South Carolina - Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendments to Relocate Unit Staff Qualifications from Technical Specification to Quality Assurance Program Description, dated December 28, 2021 (ADAMS Accession No. ML21319A262).

6. Duke Energy - Brunswick Steam Electric Plant, Units 1 and 2; Catawba Nuclear Station, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; and H.B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments to Relocate the Unit/Facility/Plant Staff Qualification Requirements to the Duke Energy Quality Assurance Program Description, Dated August 12, 2020 (ADAMS Accession No. ML20083F927).

7. Exelon Generation Company - Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R.E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station Unit 1 - Issuance of Amendments to Relocate the Staff Qualification Requirements, dated August 2, 2018 (ADAMS Accession No. ML18206A282).

to NL-24-0117 Description and Assessment of the Proposed Technical Specifications Changes Page 9 of 9

8. Tennessee Valley Authority - Browns Ferry Nuclear Plant, Units 1, 2 and 3, and Sequoyah Nuclear Plant, Units 1 and 2 - Issuance of Amendments Re: Changes to Technical Specification 5.3, Unit Staff Qualifications, dated March 27, 2017 (ADAMS Accession No. ML17034A360).

to NL-24-0117, Attachment 1 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed HNP Unit 1 Technical Specifications Changes (Marked-up Pages)

Unit Staff Qualifications 5.3 HATCH UNIT 1 5.0-5 Amendment No. 282 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff, including plant manager, shall either meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.of ANSI N18.1-1971, or shall meet or exceed the minimum qualifications of the accredited program requirements for those positions stipulated in Enclosure 1 to letter NL-07-1925. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

The senior individual in charge of radiation protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

to NL-24-0117, Attachment 2 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed HNP Unit 2 Technical Specifications Changes (Marked-up Pages)

Unit Staff Qualifications 5.3 HATCH UNIT 2 5.0-5 Amendment No. 227 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff, including plant manager, shall either meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.of ANSI N18.1-1971, or shall meet or exceed the minimum qualifications of the accredited program requirements for those positions stipulated in Enclosure 1 to letter NL-07-1925. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

The senior individual in charge of radiation protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

to NL-24-0117, Attachment 3 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed FNP Units 1 and 2 Technical Specifications Changes (Marked-up Pages)

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in 10 CFR 55, except for (1) the senior individual in charge of radiation protection who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

Farley Units 1 and 2 5.3-1 Amendment No. 207 (Unit 1)

Amendment No. 203 (Unit 2)

to NL-24-0117, Attachment 4 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed VEGP Units 1 and 2 Technical Specifications Changes (Marked-up Pages)

Vogtle Units 1 and 2 5.3-1 Amendment No. 183 (Unit 1)

Amendment No. 166 (Unit 2)

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff, including plant manager, shall meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.of Regulatory Guide 1.8, Revision 2, 1987, and, for licensed staff, 10 CFR 55.59.

Prior to meeting the recommendations of Regulatory Guide 1.8, Revision 2, personnel may be trained to perform specific tasks and will be qualified to perform those tasks independently. Personnel who complete an accredited program which has been endorsed by the NRC shall meet the requirements of the accredited program in lieu of the above. The operations manager shall meet or exceed the above requirements except that Technical Specification 5.2.2.f shall specify the requirements regarding the holding of an SRO license.

to NL-24-0117, Attachment 5 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed VEGP Units 3 and 4 Technical Specifications Changes (Marked-up Pages)

Technical Specifications Unit Staff Qualifications 5.3 VEGP Units 3 and 4 5.3 - 1 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 specified in either the SNC Nuclear Development Quality Assurance Manual or the SNC Quality Assurance Topical Report.of Regulatory Guide 1.8, Revision 3, 2000, with the following exception:

a.

During cold license operator training through the first refueling outage, the Regulatory Position C.1.b of Regulatory Guide 1.8, Revision 2, 1987, applies:

cold license operator candidates meet the training elements defined in ANSI/ANS 3.1-1993 but are exempt from the experience requirements defined in ANSI/ANS 3.1-1993.

5Property "ANSI code" (as page type) with input value "ANSI/ANS 3.1-1993.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed 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).

to NL-24-0117, Attachment 6 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed HNP Unit 1 Technical Specifications Changes (Clean Pages)

Unit Staff Qualifications 5.3 HATCH UNIT 1 5.0-5 Amendment No.

5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall either meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.

to NL-24-0117, Attachment 7 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed HNP Unit 2 Technical Specifications Changes (Clean Pages)

Unit Staff Qualifications 5.3 HATCH UNIT 2 5.0-5 Amendment No.

5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall either meet or exceed the minimum qualifications specified in the SNC Quality Assurance Topical Report.

to NL-24-0117, Attachment 8 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed FNP Units 1 and 2 Technical Specifications Changes (Clean Pages)

Unit Staff Qualifications 5.3 Farley Units 1 and 2 5.3-1 Amendment No. (Unit 1)

Amendment No. (Unit 2) 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 specified in the SNC Quality Assurance Topical Report.

to NL-24-0117, Attachment 9 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed VEGP Units 1 and 2 Technical Specifications Changes (Clean Pages)

Vogtle Units 1 and 2 5.3-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

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 specified in the SNC Quality Assurance Topical Report.

to NL-24-0117, Attachment 10 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Vogtle Electric Generating Plant Units 3&4 License Amendment Request to Relocate Control of the Unit/Facility/Plant Staff Qualification Requirements from the Technical Specifications to the Quality Assurance Program Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages)

Technical Specifications Unit Staff Qualifications 5.3 VEGP Units 3 and 4 5.3 - 1 Amendment No. (Unit 3)

Amendment No. (Unit 4) 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 specified in either the SNC Nuclear Development Quality Assurance Manual or the SNC Quality Assurance Topical Report.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed 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).