Mike GloverGeneral Manager, Nuclear= Duke Support

uEnergy Nuclear Generation

Duke Energy Corporation

526 South Church Street10 CFR 50.90 Charlotte, NC 28202

Mailing Address:

September 16, 2010 P. 0. Box 1006ECO7HCharlotte, NC 28201-1006

U. S. Nuclear Regulatory CommissionAttn: Document Control Desk 704-382-6108

Washington, DC 20555-000 1Mike. Glover@duke-energy.com

Subject: Duke Energy Carolinas, LLC (Duke Energy)Oconee Nuclear Station, Units 1, 2, and 3Docket Nos. 50-269, 50-270, 50-287McGuire Nuclear Station, Units 1 and 2Docket Nos. 50-369, 50-370Catawba Nuclear Station, Units 1 and 2Docket Nos. 50-413, 50-414License Amendment Request to Revise Technical Specification 5.3, "Unit StaffQualifications"

Reference: Letter, R. T. Repko, Duke Energy to NRC, "License Amendment Request toReflect Changes to Organization, Unit Staff Responsibility, and Unit StaffQualifications," dated April 26, 2010

Pursuant to 10 CFR 50.90, Duke Energy is submitting a request for an amendment to TechnicalSpecification (TS) 5.3, "Unit Staff Qualifications," for Oconee Nuclear Station (ONS), Units 1, 2,and 3; McGuire Nuclear Station (MNS), Units 1 and 2; and Catawba Nuclear Station (CNS),Units 1 and 2.

The enclosed License Amendment Request (LAR) proposes to update the qualificationrequirements for the Station Manager (SM) and Radiation Protection Manager (RPM) to meet orexceed the minimum qualifications in ANSI/ANS-3.1-1993, "Selection, Qualification, andTraining of Personnel for Nuclear Power Plants" endorsed by Regulatory Guide 1.8, Revision 3,dated May 2000.

Currently ONS TS 5.3.1 requires the SM and RPM to meet the minimum qualifications ofANSI/ANS-3.1-1978 while MNS and CNS TS 5.3.1 require the SM to meet the minimumqualifications of ANSI-N18.1-1971 and RPM to meet the minimum qualifications of RegulatoryGuide 1.8, dated September 1975. This proposed change represents an update to currentguidance. This update for SM and RPM qualifications will provide.ONS, MNS, and CNS theneeded flexibility to appoint SM and RPM from a larger candidate pool. The currentqualificationrequirements restrict the pool of personnel capable of performing the SM and RPM functions.The proposed change will also revise the current ONS, MNS, and CNS TS 5.3.1 qualification.requirements for SM and RPM to be consistent among all three stations.

The Enclosure provides an Evaluation of the Proposed Change. Markups of existing TS pagesare included as attachments to the Enclosure. The retyped TS pages will be provided to the

NRC prior to issuance of the approved amendments. The LAR referenced above, datedApril 26, 2010, has the same pages (TS 5.3.1) marked up. A note has been added to the

i_ www.duke-energy.com .

U. S. Nuclear Regulatory CommissionSeptember 16, 2010Page 2

marked up pages in this request to identify the need to coordinate the correct TS pages to beretyped prior to approval.

This LAR contains no commitments.

Duke Energy requests approval of the proposed amendment by December 31, 2010. Onceapproved, the amendment will be implemented within 60 days. Revisions to each station'sUFSAR will be made in accordance with 10 CFR 50.71(e).

Pursuant to 10 CFR 50.91, a copy of this proposed amendment is being provided to theappropriate officials of the States of North Carolina and South Carolina.

If you have any questions, please contact Tolani Owusu at 704-382-1420.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the16th day of September, 2010.

Sincerely,

Mike Glover

Enclosure: Evaluation of the Proposed ChangeAttachment 1: Oconee Technical Specification Marked Up Pages,Attachment 2: McGuire Technical Specification Marked Up PagesAttachment 3: Catawba Technical Specification Marked Up Pages

U. S. Nuclear Regulatory CommissionSeptember 16, 2010Page 3

xC:

L. A. Reyes, Region II AdministratorU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Ave. NE, Suite 1200Atlanta, GA 30303-1257

J. F. Stang, Jr., Senior Project ManagerU. S. Nuclear Regulatory Commission11555 Rockville PikeMail Stop 0-8 G9ARockville, MD 20852-2738

J. H. Thompson, Project ManagerU. S. Nuclear Regulatory Commission11555 Rockville PikeMail Stop 0-8 G9ARockville, MD 20852-2738

G. A. Hutto, NRC Senior Resident InspectorCatawba Nuclear Station

J. B. Brady, NRC Senior Resident InspectorMcGuire Nuclear Station

A. T. Sabisch, NRC Senior Resident InspectorOconee Nuclear Station

S. E. Jenkins, Manager.Radioactive & Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201

W. Lee Cox, III, Section Chief.Division of Environmental. Health, Radiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service Center.Raleigh, NC 27699

ENCLOSURE

Evaluation of the Proposed Changes

Subject: License Amendment Request to Revise Technical Specifications for Unit StaffQualifications

1. SUMMARY DESCRIPTION

2. DETAILED DESCRIPTION

2.1. PROPOSED CHANGES

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION

4.1. Applicable Regulatory Requirements/Criteria

4.2. Precedent

4.3. Significant Hazard Consideration

4.4. Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES

ATTACHMENTS:1. Marked Up Pages for Oconee Technical Specification2. Marked Up Pages for McGuire Technical Specification3. Marked Up Pages for Catawba Technical Specification

Page .1 of 10

ENCLOSURE

1. SUMMARY DESCRIPTION

This evaluation supports a request to amend Operating"Licensees DPR-38, DPR-47, andDPR-55 for Oconee (ONS) Units 1, 2, and 3; NPF-9 and NPF-1 7 for McGuire (MNS) Units 1and 2; and NPF-35 and NPF-52 for Catawba (CNS) Units 1 and 2.

ONS, MNS, and CNS propose to update the qualification requirements for Station Manager(SM) and Radiation Protection Manager (RPM) to meet or exceed ANSI/ANS 3.1-1993 asendorsed by RG 1.8, Revision 3, dated May 2000.

2. DETAILED DESCRIPTION

The proposed TS change will update the qualification standards for the ONS, MNS, and CNSSM and RPM to meet or exceed ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Revision 3. Thisproposed change represents an update to current guidance. This update for SM and RPMqualifications will provide ONS, MNS, and CNS the needed flexibility to appoint SM and RPMfrom a larger candidate pool. The current qualification requirements restrict the pool ofpersonnel capable of performing the SM and RPM functions. Updating the qualificationrequirements to meet or exceed ANSI/ANS 3.1-1993 endorsed by RG 1.8, Revision 3 willexpand the pool of potential candidates. The proposed change will also revise the current ONS,MNS, and CNS TS 5.3.1 qualification requirements for SM and RPM to be consistent among allthree stations.

The proposed change is administrative in nature.

2.1. PROPOSED CHANGES

2.1.1. ONS-TS 5.3.1

a) On ONS TS 5.3.1 page 5.0-5, notation ":" is added after "except" then delete theremainder of the sentence "for the Operations Superintendent and the Shift OperationsManager" for clarity.

b) The second paragraph, "The Operations Superintendent shall have a minimum of eightyears of responsible nuclear or fossil station experience,/ of which a minimum of threeyears shall be nuclear station experience. A maximum of two years of the remaining fiveyears of experience may be fulfilled by academic training, or related technical training,on a one-for-one time basis" remains the same and is itemized as Item 1.

c) The third paragraph, "The Shift Operations Manager shall have a minimum of eightyears of responsible nuclear or fossil station experience, of which a minimum of threeyears shall be nuclear station experience. A maximum of two years of the remaining fiveyears of experience may be fulfilled by academic training, or related technical -training ona one-for-one time basis" remains the same and is itemized as Item 2.

d) Add "The Station Manager shall meet or exceed the minimum qualifications ofANSI/ANS 3.1-1993 as end6rsed, by Regulatory Guide 1.8, Revision 3, May 2000,"Itemized as Item 3.

Page 2 of 10

ENCLOSURE

e) Add "The Radiation Protection Manager shall meet or exceed the minimum qualificationsof ANSI/ANS,3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000."Itemized as Item 4.

2.1.2. MNS - TS 5.3.1

a) On MNS TS 5.3.1 page 5.3-1, notation "" is added after "except" then delete theremainder of the sentence "the Radiation Protection Manager, who shall meet or exceedthe qualifications of Regulatory Guide 1.8, September 1975" for clarity.

b) Add "The Station Manager shall meet or exceed the minimum qualifications ofANSI/ANS 3.1-1993 as endorsed-by Regulatory Guide 1.8, Revision 3, May 2000."Itemized as Item 1.

c) Add "The Radiation Protection Manager shall meet or exceed the minimum qualificationsof ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000."

'Itemized as Item 2.

2.1.3. CNS - TS 5.3.1

a) On CNS TS 5.3.1 page 5.3-1, notation "" is added after "except" then delete the /

remainder of the sentence "the Radiation Protection Manager, who shall meet or exceedthe qualifications of Regulatory Guide 1.8, September 1975",for clarity.

b) Add "The Station Manager shall meet or exceed the minimum qualifications ofANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000."Itemized as Item 1.

c) Add "The Radiation Protection Manager shall meet or exceed the minimum qualificationsof ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000."Itemized as Item 2.

3. TECHNICAL EVALUATION

The following is the technical evaluation of the proposed changes to revise the currentTS. 5.3.1 qualification requirements'for the Oconee, McGuire, and Catawba NuclearStation Manager (SM) and Radiation Protection Manager (RPM).positions to meet orexceed the minimum qualifications in ANSI/ANS-3.A1-1993, "Selection, Qualifications,and Training of Personnel for Nuclear Power Plants" endorsed by Regulatory Guide 1'.8,Revision 3, May 2000. Current requirements and proposed requirements for eachchange are discussed below. Applicable regulatory requirements and any.precedentsfor these proposed changes are-included.

3.1. Station Manager (SM) Requirements-

3.1.1. Current Requirements _

ONS TS 5.3.1- currently requires the SM to meet the minimum qualifications of- " ANSI/ANS-3.1-1978, while MNS and CNSTS 5.3.1 require1theSM tomeet the

minimum qualifications of ANSI-N18.1-1971. .

Page 3 of 10

ENCLOSURE

ANSI/ANS-3.1-1978, Section 4.2.1 Plant Managers states in part:

"At the time of initial core loading or appointment to the position, whichever islater, the plant manager shall have ten years of power plant experience, of whichthree years shall be nuclear power experience. A maximum of four years of theremaining seven years of experience may be fulfilled by academic training on aone-for-one time basis. To be acceptable, this academic training shall be in anengineering or scientific field associated with power plants. The plant managershall have acquired the experience and equivalent training normally required tobe eligible for a Senior Reactor Operator's license whether or not theexamination is taken.

In an organization which includes one or more persons who are designated asprincipal alternates for the plant manager and who meet the nuclear power plantexperience and training requirements established for the plant manager, therequirements of the plant manager may be reduced, such that only one of his tenyears of experience need to be nuclear power plant experience and he need notbe eligible for NRC examination.' 1

3.1.2. Proposed Requirements

ANSI/ANS-3.1-1993 Section 4.2.1 Plant Manager qualification allows an alternative forthe Plant Manager that states in part:

"Education: Baccalaureate in engineering or related science.Minimum experience for the position:Power Plant 6 yr

which shall includeNuclear Power Plant 4 yrSupervisory or Management 5 yrOnsite 0.50 yrSpecial requirements;(1) Shall meet one of the following:

(a) Hold a Senior Operator's license, or(b) Have held a Senior Operator's license,

Or(c) Have been certified for equivalent senior operator knowledge, or:(d) Have plant operational knowledge consistent with the requirements ofthe Plant Manager's job."2

Section 4.2, "Manager Level" further clarifies that the experience requirement is notnecessary to be met as long as the experience exception is limited to one of theManager level positions, and the collective experience requirement is met.

1 "Extracted from American National Standard ANSI/ANS-3.1-1978 with permission of the publisher, the

American Nuclear Society"2 "Extracted -from American National Standard ANSI/ANS-3.1-1993 with permission of the publisher, the.American Nuclear Society"

Page 4 of 10

ENCLOSURE

Note: At ONS, MNS and CNS, Plant Manager is the Station Manager (SM).

The proposed change in this license amendment from ANSI/ANS 3.1-1978 for ONS andfrom ANSI-N18.1-1971 for MNS and CNS will require the qualification requirements forSM to meet or exceed the minimum qualifications of ANSI/ANS-3.1-1993, endorsed byRegulatory Guide 1.8, Revision 3, May 2000. This proposed change represents anupdate to current guidance. This update for SM qualifications will provide ONS, MNS,and CNS the needed flexibility to appoint SM from a larger candidate pool. The currentqualification requirements restrict the pool of personnel capable of performing the SM

- functions. Updating the qualification requirements to meet or exceedANSI/ANS 3.1-1993 endorsed by RG 1.8, Revision 3 will expand the pool of potentialcandidates. The proposed change will also revise the current ONS, MNS, and CNSTS 5.3.1 qualification requirements for SM to be consistent among all three stations.

3.2. Radiation Protection Manager (RPM) Requirements

3.2.1. Current Requirements

ONS TS 5.3.1 currently requires the RPM to meet the minimum qualifications ofANSI/ANS-3.1-1978, Section 4.4.4 for RPM. One of the requirements in the-ANSIstandards, Section 4.4.4 paragraph two states:

"...The individual shall have a bachelor's degree or the equivalent in a science orengineering subject, including some formal training in radiation protection. Theindividual shall have at least five years of experience in applied radiationprotection. (A master's degree may be considered equivalent to one year ofprofessional experience, and a doctor's degree may be considered equivalent totwo years of experience where course work related to radiation protection isinvolved). At least three years of experience shall be in applied radiationprotection work in a nuclear facility dealing with radiological problems similar tothose encountered in nuclear power stations, preferably in an actual nuclearpower station."3

While ONS TS 5.3.1 currently requires the RPM to meet the minimum qualifications ofANSI/ANS-3.1-1978, MNS and CNS TS 5.3.1 requires the-RPM to meet RegulatoryGuide (RG) 1.8, September 1975. One of the requirements in RG 1.,8, September 1975,paragraph two states:

"The RPM should have a bachelor's degree or the equivalent in a science orengineering subject, including some formal training in radiation protection. TheRPM should have.at least five years of professional experience in applied.radiation protection... At least three years of this professional experience shouldbe in applied radiation protection work in a nuclear facility dealing with.radiological.problems similar to those encountered in nuclear power stations,preferably in an actual nuclear power station."•

- " Extracted from American National Standard ANSI/ANS-3.1-i 978 with permission-of the publiSher, the-

:American Nuclear Society"

,Page 5 of 10.

ENCLOSURE

3.2.2. Proposed Requirements

ANSI/ANS-3.1-1993 Section 4.3.3 Radiation Protection qualification allows analternative for the RPM that states in part:

"Education: Baccalaureate in science, health physics, or engineering.Related experience 4 yr.

which shall includeNuclear Power Plant 3 yr.Supervisory or Management 1 yrOn-site 0.50 yrSpecial Requirements:(1) Management and supervisory skills in accordance with those specified in 6.3.(2) During the years of nuclear power plant experience, the individual shall haveparticipated in supervision or management activities at an operating nuclearpower plant during the following periods:

(a) 1 month of routine refueling outage, and(b) 2 months of operation above 20% power."4

The RG 1.8 Revision 3, May 2000, Section 2.7 also states:

"For the radiation protection manager, the three years of nuclear power plantexperience should be at a level requiring policy planning and decision makingrelated to the programmatic aspects of the radiation protection program as awhole."

Section 4.3, Middle Manager Level further states in part:

"An individual may be accepted for a specific position even if the person does notmeet the requirements for that position if the individual is provided a staff ofindividual(s) whose qualifications meet the selected middle managerqualification."'

Note: At ONS, MNS and CNS, RPM is considered a middle manager. The RPMprovides the intermediate management level(s) between the first line supervisor leveland the manager level functions.

The proposed change in this license amendment from ANSI/UANS 3.1-1978 for ONS andfrom RG 1.8, September 1975, for MNS and CNS will require the qualificationrequirements for RPM to meet or exceed the minimum qualifications ofANSI/ANS-3.1-1993, endorsed by Regulatory Guide 1.8, Revision 3, dated May 2000.This proposed change represents an update to current guidance. This update for RPMqualifications will provide ONS,. MNS, and CNS the needed flexibility to appoint RPM

"Extracted from American National Standard ANSI/ANS-3.1-1993 with permission of the publisher, theAmerican Nuclear Society"

"Extracted from American National Standard ANSI/ANS-3.1-1993 with permission of the publisher, theAmerican Nuclear.Society"

Page6 of 10

ENCLOSURE

from a larger candidate pool. The current qualification requirements restrict the pool ofpersonnel capable~of performing the RPM functions. Updating the qualificationrequirements to meet or exceed ANSI/ANS 3.1-1993 endorsed by RG 1.8, Revision 3will expand the pool of potential candidates. The proposed change will also revise thecurrent ONS, MNS, and CNS TS 5.3.1 qualification requirements for RPM to beconsistent among all three stations.

4. REGULATORY EVALUATION

4.1. Applicable Regulatory Requirements/CriteriaThe NRC regulatory requirements that are related to the content of the TechnicalSpecifications (TSs) are contained in Title- 0 of the Code of Federal Regulations(10 CFR), Part 50, Section 50.36. Section 50.36 requires that the TSs include items inthe following specific categories: (1) safety limits, limiting safety system settings, andlimiting control settings (50.36(c)(1)); (2) limiting conditions for operations (50.36(c)(2));(3) surveillance requirements (50.36(c)(3); (4) design features (50.36(c)(4); and (5)administrative controls (50.36(c)(5)).

RG 1.8, Rev 3, "Qualification and Training of Personnel for Nuclear Power Plants," datedMay 2000, contains guidance that is acceptable to the NRC staff regarding qualificationsand training for nuclear power plant personnel. This RG endorses ANSI/ANS-3.1-1993,"Selection, Qualification, and Training of Personnel for Nuclear Power Plants," withcertain clarifications, additions, and exceptions.

4.2. Precedent

The NRC has previously approved similar requests to revise TS 5.3.1, "Unit StaffQualifications" to update the qualification standard to more recent requirementscontained in RG 1.8, Revision 3, May 2000 and ANSI/ANS 3.1-1993. The precedentsinclude:.

a) NRC letter dated September 4, 2002 (ML022200571) approved Comanche PeakSteam Electric Station (CPSES), Units 1 and 2 request to revise TS 5.3.1 to require

- licensed Reactor Operators (ROs) and licensed Senior Reactor Operators (SROs) tomeet or exceed the minimum qualifications in RG 1.8, Revision 3, and. that all othermembers of the staff meet or exceed minimum qualifications in RG 1.8,Revision 2, 1987.

b)' NRC letter dated December 15, 2005 (ML0532000540) approved Cooper NuclearStation request to revise.TS 5.3, to update the qualification, standard for the shift.manager, senior operator, licensed operator, and shift technical engineer from RG1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 2,April 1987, to RG 1.8, Revision 3, May 2000. -

4.3. .Significant Hazards Consideration

Duke Energyhas evaluated whether or not a significant hazards consideration is- in•olved with the proposed amendments by focusing on -theethree standards set°forth in

Page 7 of 10

ENCLOSURE

10 CFR 50.92, "Issuance of Amendment, " as discussed below:

(1) Does the proposed amendment involve a significant increase in theprobability or consequences of an accident previously evaluated?

Response: No

The proposed change to TS 5.3.1 is an administrative change to update the minimumqualification requirements for Station Manager and Radiation Protection Manager tomeet or exceed ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3,dated May 2000. This update for Station Manager and Radiation Protection Managerqualifications will also provide Oconee, McGuire, and Catawba the needed flexibility toappoint Station Managers and Radiation Protection Managers from a larger candidatepool. The current qualification requirements restrict the pool of personnel capable ofperforming the Station Manager and Radiation Protection Manager functions. Thischange will also revise the current Oconee, McGuire, and Catawba TS 5.3.1 qualificationrequirements for Station Manager and Radiation Protection Manager to be consistentamong all three stations.

The proposed change does not impact the physical configuration or function of plantstructures, systems, or components or the manner in which structures, systems, orcomponents are operated, maintained, modified, tested, or inspected. Updating theminimum qualification requirements for Station Manager and Radiation ProtectionManager is not an initiator of any accident previously evaluated. Updating the minimumqualification requirements for Station Manager and Radiation Protection Manager is notan assumption in the consequence mitigation of any accident previously evaluated.

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

(2) Does the proposed amendment create the possibility of a new or differentkind of accident from any accident previously evaluated?

Response: No

The proposed change to TS 5.3.1 is an administrative change to update the minimumqualification requirements for Station Manager and Radiation Protection Manager tomeet or exceed ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Revision 3, datedMay 2000. This represents an update to current guidance. This update for StationManager and Radiation Protection Manager qualifications will also provideOconee,McGuire, and Catawba the needed flexibility to appoint Station Manager and RadiationProtection Manager from a larger candidate pool. The-current qualification requirementsrestrict the pool of personnel capable of performing the Station Manager and RadiationProtection Manager functions. This change will also revise the current Oconee, McGuireand Catawba TS 5.3.1 qualification requirements for Station Manager and RadiationProtection Manager to be consistent among all three stations..

Page.8 of10 0

ENCLOSURE

The proposed change does not impact the physical configuration or function of plantstructures, systems, or components or the manner in which structures, systems, orcomponents are operated, maintained, modified, tested, or inspected. In addition, thereis no change in the types or increases in the amounts of effluents that may be releasedoffsite, and there is no increase in individual or cumulative occupational radiationexposure.

As the proposed change is administrative in nature, operation of the facility inaccordance with the proposed amendment does not create the possibility of a new ordifferent kind of accident from any accident previously evaluated.

(3) Does the proposed amendment involve a significant reduction* in a margin

of safety?

Response: No

The proposed change to TS 5.3.1 is an administrative change to update the minimumqualification requirements for Station Manager and Radiation Protection Manager tomeet or exceed ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Revision 3, day May 2000.This update for Station Manager and Radiation Protection Manager qualifications will,also provide Oconee,. McGuire, and Catawba the needed flexibility to appoint StationManager and Radiation Protection Manager from a larger candidate pool. The currentqualification requirements restrict the pool of personnel capable of performing theStation Manager and Radiation Protection Manager functions. This change will alsorevise the current ONS, MNS, and CNS TS 5.3.1 qualification requirements for StationManager and Radiation Protection Manager to be consistent among all three stations.

The proposed change does not impact the physical configuration or function of plantstructures, systems, or components or the manner in which structures, systems, orcomponents are operated, maintained, modified, tested, or inspected. The proposedchange does not alter the manner in which safety. limits, limiting safety system settingsor limiting conditions for operation are determined. The safety analysis acceptancecriteria are not affected by this change. The proposed change will not result in plantoperation in a configuration outside the design basis. The proposed change does notadversely affect systems that respond to safely shutdown the plant and to maintain theplant in a safe shutdown condition.' The proposed change is administrative in nature;thus operation of the facility in accordance with the proposed amendment does notinvolve a significant reduction in a margin of safety.

4.4. Conclusions

* * In conclusion, based on the considerations discussed above, (1) there is reasonableassurance that the healt.hand safety of the public will not be endangered by operation inthe proposed manner,;(2) such activities will be conducted in compliance with the.commission's regulations, and (3) the issuance of the amendment will not be inimical tothe common defense and security or to the health and safety-of the public.

*Page 9 of 10

ENCLOSURE

5. ENVIRONMENTAL CONSIDERATIONS

Duke Energy has reviewed the proposed change and has determined that the proposedchange does not involve a significant hazards consideration, a significant change in thetypes of or significant increase in the amount of any effluents that may be releasedoffsite, or a significant increase in the individual or cumulative occupational radiationexposure. Therefore, the proposed change meets the eligibility criteria for categoricalexclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change isnot required.

6. REFERENCES

1. Regulatory Guide 1.8, Revision 3, "Qualification and Training of Personnel forNuclear Power Plants," May 2000.

2. ANSI/ANS-3.1-1993, "Selection, Qualification, and Training of Personnel for NuclearPower Plants."

3. ANSI/ANS-3.1-1978, "Selection, Qualification, and Training of Personnel for Nu6learPower Plants."

4. ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel."

5. Regulatory Guide 1.8, Revision 1, "Qualification and Training of Personnel forNuclear Power Plants," September, 1975.

Page 10 of 10

Attachment 1

Oconee Nuclear Station, Units 1, 2, and 3Technical Specification Marked Up Pages

Unit Staff Qualifications5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Station Staff Qualifications

5.3.1 Each member of the station staff shall meet or exc ed the minimumqualifications described in Section 4 of ANSI/ANS- .1-1978, "Selection andTraining of Nuclear Power Plant Personnel" except for the Ope..tio""Suporintendcnt and the Shift O)Eoratians Manacler.

The Operations Superintendent shall have a minimum of eight years ofresponsible nuclear or fossil station experience, of which a minimum of threeyears shall be nuclear station experience. A maximum of two years of theremaining five years of experience may be fulfilled by academic training, orrelated technical training, on a one-for-one time basis.

2The Shift Operations Manager shall have a minimum of eight years ofresponsible nuclear or fossil station experience, of which a minimum of threeyears shall be nuclear station experience. A maximum of two years of theremaining five years of experience may be fulfilled by academic training, orrelated technical training on a one-for-one time basis.

INSERT

3. The Station Manager shall meet or exceed the minimum qualifications ofANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3,May 2000.

4. The Radiation Protection Manager shall meet or exceed the minimumqualifications of ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8,Revision 3. Mav 2000.

Note

By letter dated April 26, 2010, Duke Energy submitted aLicense Amendment Request (LAR) to revise TS Sections5.1, 5.2, 5.3, and 5.7 conceming Administrative Controls.Both of these LARs on "Unit Staff Qualifications" affect page5.0-5 (ONS) and pages 5.3-1 (MNS & CNS). Depending onwhich amendment is approved.first, coordination of theretyped page is necessary.

OCONEE UNITS 1, 2, & 3 5.0-5 Amendment Nos. 300, 300, & 300

Attachment 2

McGuire Nuclear Station, Units 1 and 2Technical Specification Marked Up Pages

Unit Staff Qualifications5.3

5.0 ADMINISTRATIVE CONTROLS5.3 Unit Staff QualificationsI. .

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 theRadiation PFotection Manager, who shall meot , r axced tGequalificationes of Regulato Guide 1.8, SgeptembeFr 1975.

INSERT

1. The Station Manager shall meet or exceed the minimumqualifications of ANSI/ANS 3.1-1993 as endorsed by RegulatoryGuide 1.8, Revision 3, May 2000.

2. The Radiation Protection Manager shall meet or exceed theminimum qualifications of ANSI/ANS 3.1-1993 as endorsed byRegulatory Guide 1.8, Revision 3, May 2000.

Note

By letter dated April 26, 2010, Duke Energy submitted aLicense Amendment Request (LAR) to revise TS Sections5.1, 5.2, 5.3, and 5.7 concerning Administrative Controls.Both of these LARs on "Unit Staff Qualifications" affect page5.0-5 (ONS) and pages 5.3-1 (MNS & CNS). Depending onwhich amendment is approved first, coordination of theretyped page is necessary.

McGuire Units 1 and 2 5.3-1 Amendment Nos. 24~-/-1-94McGuire Units 1 and 2 5.3-1 Amendr-hent Nos. -212 -1194

Attachment 3

Catawba Nuclear Station, Units land 2Technical Specification Marked Up Pages

Unit Staff Qualifications5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or excee the minimum qualifications ofANSI-N 18.1-1971 for comparable positions, except the Radiation ProtectionManageR, who shall moot or exceed the qualificatfion of RegulateT' Guido 1.8,Septebe 15.

INSERT

1. The Station Manager shall meet or exceed the minimum qualifications ofANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3,May 2000.

2. The Radiation Protection Manage r shall meet or exceed the minimumqualifications of ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide1.8, Revision 3, May 2000.

Note

By letter dated April 26, 2010, Duke Energy submitted a LicenseAmendment Request (LAR) to revise TS Sections 5.1, 5.2, 5.3,and 5.7 concerning Administrative Controls. Both of these LARson "Unit Staff Qualifications" affect page 5.0-5 (ONS) and pages5.3-1 (MNS & CNS). Depending on which amendment isapproved first, coordination of the retyped page isnecessary.

. Catawba Units 1 and 2 5.3-1 w Ui 1 m,,,m,,t Nb. 16 1/173