ELV-04016, Application for Amends to Licenses NPF-68 & NPF-81,revising Qualification Requirements of Independent Safety Engineering Group to Allow Two Members W/Current or Previous SRO License to Serve in Lieu of Holding Bachelors Degree

Application for Amends to Licenses NPF-68 & NPF-81,revising Qualification Requirements of Independent Safety Engineering Group to Allow Two Members W/Current or Previous SRO License to Serve in Lieu of Holding Bachelors Degree

ML20126E248
Person / Time
Site:	Vogtle
Issue date:	12/22/1992
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20126E251	List: ELV-04016, Application for Amends to Licenses NPF-68 & NPF-81,revising Qualification Requirements of Independent Safety Engineering Group to Allow Two Members W/Current or Previous SRO License to Serve in Lieu of Holding Bachelors Degree ML20126E253
References
ELV-04016, ELV-4016, NUDOCS 9212290073
Download: ML20126E248 (6)

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Docket Nos. 5(M24 5(M25 U. S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECITtlC GENERATING PLANT PROPOSED CHANGES TO TECHNICAL SPECIFICATION OUALIFICATION REOUIREMENTS OF TIIE INDEPENDENT SAFETY ENGINEERING GROUP in accordance with the provisions of 10 CFR 50.90, Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF-81.

The proposed amendment would revise the qualification requirements of the Independent Safety Engineering Group (ISEG). 'Ihe proposed changes and their bases are described in enclosure 1.

An evaluation pursuant to 10 CFR 50.92 showing that the proposed change does not involve a significant hazards consideration is provided in enclosure 2. Instructions for incorporation of the proposed change into the Technical Specifications and a markup of the affected pages are provided as enck>sure 3.

In accordance with 10 CFR 50.91, the designated state official will be sent a copy of this letter and di enclosures.

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'U. S. Nuclear Regulatory Commission -

ELV-01016 F

Page 2 Mr. C. K. McCoy states that he is a Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company and, that to the best of his-knowledge and belief, the facts in this letter and enclosures are true.

GEORGIA POWER COMPANY By: ~ ~

C. K. hicCoy Sworn to and subscribed before me this B day of 1992.

Amn fL %

Nhtary Public MY 00MMisst0N EXPlRES JANUARY 12,1993 CKM/JMG

Enclosures:

1. Basis for Proposed Change 2.10 CFR 50.92 Evaluation

3. Instmetions for incorporation and Revised Page C(w): Georgia Power Comoany Mr. W. B. Shipman Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Ihxx1, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle State of Georgia Mr. J. D. Tanner, Commissioner, Department of Natural Resources l.

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ENCLOSURE 1 VOG'ILE EIECIRIC GENERAllNG PLANT PROPOSED CIIANGES TO TECilNICAL SPECIFICATION OUAUFICATION-  ;

REQUIREMENTS OF Tile INDEPENDENT SAFETY ENGINEERING GROUP-l BASIS EOR PROPOSED CIIANGES Proposed Changej The proposeditmendment would revise the qualification requirements for Independent Safety.

Engineering Group (ISEG) members. Currently all ISEG members must have a bachelor's 1

- degree in engineering or related science. Specification 6232 would be revised to allow up to two ISEG members with either (1) a current or previously held Senior Reactor Operator's.

!icense and 5 years of professional level experience in the nuclear field or (2) at least 10 years of professional level experience in his field with at least 5 years of nuclear field experience to be-substituted in lieu of a bachelor's degree.

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i ENCLOSURE 2 VOGTLE ELECITUC GENERA'UNG PIANT -

PROPOSED CllANGES TO TECIINICAL SPECIFICATION QUALIFICATIOND REQUIREMENTS OF THE INDEPENDENT SAFETY ENGINEERING GROUP 10 CFR 50.92 EVALUATION 4

Pursuant to 10 CFR 50.92, GPC has evaluated the proposed amendment and has detennined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations.

Background

NUREG-0737 Section I.B.1.2 requires all applicants for operating licenses to implement an ISEG. As a result of this requirement, with the issuance of the operating license for Vogtle Electric Generating Plant Unit 1, an ISEG was established at VEGP. As required in NUREG-0737, the principal function of the ISEG is to examine plant operating characteristics, NRC issuances, industry advisories and other appropriate sources of plant design and operating-experience information that may indicate areas for improved plant safety. The ISEG is also to -

perform independent review of plant activities including maintenance, operational problems and .

operational an;dysis. Where useful improvements can be achieved, it is expected that this group will develop and present detailed recommendations to corporate management.

Although it could be interpreted that NUREG-0737 did imply that the members of the ISEO should be " engineers," it (nor its listed references of NUREG460 and NUREG494) did not specify any minimum educational qualification requirements for ISEG. It only called for an-

" increase in the avaiLble technical expertise located onsite" and to " provide continuing, systematic, and independent assessment of plant activities" In the spirit of this concept, a more knowledgeable and experienced ISEG group would produce higher quality and useful recommendations fer improvement as emisioned by NUREG-0737.-

Current Technical Specifications prohibit highly trained and' experienced personnel in, for example, the Operations or Operations Support Departments who do not possess a bachelor's degree from being eligible for ISEG consideration even though a significant portion of ISEG evaluations review plant aethities invoMng Operations, Maintenance, and Instrumentation and Control. hs, this change would allow a person with either (1) a current or previously held Senior Reactor Operator's license and 5 years of professional leve.1 experience in the nuclear field or (2) at least 10 years of professional level experience in his field with at least 5 years of nuclear field experience to be substituted in lieu of a bachelor's degree.

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s ENCLOSURE 2 (Continued)  ;

.VOGTIE ELECTRIC GENERATIb . " 'NT PROPOSED CIIANGES TO TECHNICAL SPECIFK GON OUALIFICATION REQUIREMENE OF TIIE INDEPENDENT SAFIrl Y ENGINEERING GROUP-10 CFR 50.92 EVALUATION De ability to add a person to the Vogtle Electric Generating Plant ISEG staff who has specific ,

nuclear experience would be very valuable by enhancing the ISEG's knowledge level and insight of its evaluations.

The criteria requiring a bachelor's degree used in Vogtle Electric Generating Plant Technical Specification 62.32 stemmed from Section II.D.2.b of NUREG4)731 which stated " Qualification requirements for these individuals sho_uld be at a level generally comparable to that descrit>cd in

_ Section 42 of ANSI /ANS 3.1 (December 1979 draft), i.e., a bachelor's degree in engineering o with two to four years experience in their field, or equivalent as described in Section 4.1 of ANSI /ANS 3.1." However, Section 4.1 of ANSI /ANS 3.1 (1981) also states that " Individuals who do not Ix>ssess the formal education requirements specified in this section shall not be automatically eliminated where other factors provide sufficient demonstration of their abilities.

These other factors should be evaluated on a case-by-case basis." Vogtle Electric Generating Plant is committed to Regulatory Guide 1.8 (1987), which endorses ANSI /ANS 3.1 (1981).

The level of training and knowledge needed to obtain a Senior Reactor Operator's license is well documented and known. his change would provide the ability of the Vogtle Electric L Generating Plant ISEG to broaden its expertise with direct first-hand operations experience. In

! addition to the Senior Reactor Operator requirement, this change would require 5 years of professional level experience in the nuclear field, which is above the current Vogtle Electric Generating Plant Technical Specification criteria of 2 years experience and is .in accordance with Secdon 4.72 of ANS 3.1 (1981). A second option would ~ substitute 10 years of professional level experience in his field with at least 5 years of which experience shall be in the nuclear field.

These options have already been approved by the NRC for the F:-wer Valley Power Station.

This Technical Specification change would limit the ISEG to a maximum of two such substitutions. This revision will allow an adequate mix of engineering expertise with practical plant experience.

l In summary, this change to Vogtle Electric Generating Plant Technical Specification 6232 l would provide the opportunity to significantly increase the Vogtle Electric Generating Plant ISEG knowiedge level and experience in nuclear power plant operation activities without suffering any discernible reduction in technical knowledge or skills.

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1 ENCLOSURE 2 (Continued) _

VOGTLE ELECTRIC GENERATING PIANT PROPOSED ClIANGES TO TEClINICAL SPECIFICATION OUALIFICATION ,

REQUIREMENTS OF VIE INDEPENDENT SAFETY ENGINEERING GROUP.-

10 CFR 5092 EVALUATION Analysis Georgia Power Company has reviewed the requirements of 10 CFR 50.92 as they relate to the proposed change to section 6.0 of the Technical Specifications and has determined that the change does not involve a significant hazards consideration. In support of this conclusion, the following analysis is provided.

1. He proposed change will not significantly increase the probability or consequences of an-accident previously evaluated because the change only addresses qualification requirements of an independent review group and has no change to any plant equipment or structures.

2. Dis change does not create the possibility of a new or different kind of accident from any accident previously evaluated. There would be no change to system configurations, plant equipment, or analysis as a result of this proposed amendment.

3. He proposed change will not involve a significant reduction in a margin of safety. He proposed revised Technical Specification will substitute appropriate qualification criteria '

for an Independent Review Group and thus will not alter any margin of safety.

Conclusion Based upon the analysis provided herein, Georgia Power Company has determined that the; proposed changes to the Technical Specifications will not significantly increase the probability or . _

consequences of an accident previomly evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, the proposed changes do not involve a significant hazards consideration as defined by 10 CFR 50.92 (c).

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