L-PI-11-008, License Amendment Request (LAR) to Revise Technical Specification (TS) 5.2.1, Onsite and Offsite Organizations and TS 5.3, Plant Staff Qualifications.
| ML110390081 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/04/2011 |
| From: | Schimmel M Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-11-008 | |
| Download: ML110390081 (21) | |
Text
I FEB 0 4 2011 L-PI-I 1-008 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 License Amendment Reauest (LAR) to Revise Technical Specification (TS) 5.2.1, "Onsite and Offsite Oraanizations" and TS 5.3, "Plant Staff Qualifications" Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, hereby requests an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to make administrative changes which will: 1) allow certain requirements of onsite and offsite organizations to be documented in the Quality Assurance Topical Report (QATR); and 2) remove reference to specific education and experience requirements for operator license applicants. NSPM evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded that they involve no significant hazards consideration.
The enclosure to this letter, "Evaluation of the Proposed Changes contains the licensee's evaluation of the proposed changes.
NSPM requests approval of this LAR within one calendar year of the submittal date.
Upon NRC approval, NSPM requests 90 days to implement the associated changes. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR by transmitting a copy of this letter and enclosure to the designated State Official.
If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.
1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651-388.1121
Document Control Desk Page 2 Summarv of Commitments This letter contains no new commitments and no revisions to existing commitments I declare under penalty of perjury that the forsgoing is true and correct.
Executed on 8 4 2011 Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (1) cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota
ENCLOSURE Evaluation of the Proposed Changes License Amendment Request (LAR) to Revj7se TFachnicaI SpFacMc;atlon$ (18%5,2.1,)
"Onsite and Off#ita Organizations" and ds33, "'Plant Staff QualCficatlons"
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION
- 2. IProposed Changes
2.2 Background
- 3. TECHNICAL EVALUATION
- 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions
- 5. ENVIRONMENTAL CONSIDERATION
- 6. REFERENCES I
ATTACHMENTS:
- 1. Technical Specification Pages (Markup)
- 2. Technical Specification Pages (Retyped)
Page 1 of 13
- 1.
SUMMARY
DESCRIPTION This LAR is a request to amend Operating Licenses DPR-42 and DPR-60 for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2 respectively.
Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requests Nuclear Regulatory Commission (NRC) review and approval of proposed revisions to TS 5.2.1, "Onsite and Offsite Organizations" and TS 5.3, "'Plant Staff Qualifications". The proposed administrative changes will: 1) revise Technical Specification 5.2.1(a) by addition of the Quality Assurance Topical Report (QATR) as an allowed location for documentation of requirements for lines of authority, responsibility, and communication; and 2) revise TS 5.3.1 by removal of the exception to operator license applicants' education and experience requirements, and the reference to a letter which references a specific industry guidance document.
- 2. DETAILED DESCRIPTION 2.1 Proposed Changes Brief descriptions of the associated proposed TS changes are provided below along with discussion of the justification for the changes. The specific wording changes to the TS are provided in Attachments Iand 2 to this enclosure.
TS 5.2.1, "Onsite and Offsite Organizations": This LAR proposes to revise TS 5.2.1(a) by the addition of the QATR as an allowed location for documentation of requirements for lines of authority, responsibility, and communication, as described in TS 5.2.l(a). This administrative change is acceptable because it is consistent with NRC guidance provided in Generic Letter (GL) 88-06, Reference 1 and NUREG-1431, Reference 2.
TS 5.3, "Plant Staff Qualifications" paragraph 5.3.1: This LAR proposes to delete "(I)" which implies there are two items and remove all of item (2) which references a specific industry guidance document as the basis for the education and experience eligibility requirements for operator license applicants. Item (2) contains "NMC" which is footnoted and therefore the footnote is also removed.
The purpose of item (2) was to take exception to the education and experience eligibility guidance for operator license applicants in Regulatory Guide (RG) 1.8, Reference 3, and invoked use of a specific industry guidance document. This administrative change is acceptable because the specific document has been superseded and reference to specific industry guidance is not needed due to NRC involvement in the licensing of operator applicants.
There are no TS Bases changes associated with this LAR.
Page 2 of 13
Enclosure NSPM TS 5.2.115.3.1 In summary these administrative changes are acceptable because they are consistent with current regulatory guidance and the plant will continue to be operated in a safe manner with these changes, 2.2 Background NSPM currently operates two nuclear power plants, PlNGP and the Monticello Nuclear Generating Plant (MNGP). For both of the plants, TS 5,2.l(a) specifies that "lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions," These relationships are currently documented in the USAR for PINGP. However, TS 5.2.l(a) for MNGP currently allows the relationships to be documented in either the USAR or the QATR.
The change proposed in this LAR would allow for a document common to PINGP and MNGP, the QATR, to contain the organizational relationships required per TS 5.2.l(a).
PlNGP TS 5.3.1, through reference to a Nuclear Management Company (NMC) letter dated March 19, 2003, ML030860604, requires use of an outdated National Academy for Nuclear Training (NANT) document ACAD 00-003, Reference 4, for qualification of operator license candidates. The NRC has determined that more recent Institute for Nuclear Power Operations guidance provides acceptable methods for meeting the regulations. This LAR proposes to remove reference to the specific guidance which will allow use of the more recent guidance documents.
With the administrative TS changes proposed in this LAR the plant will continue to operate safely and the health and welfare of the public is protected.
- 3. TECHNICAL EVALUATION PlNGP is a two unit plant located on the right bank of the Mississippi River approximately 6 miles northwest of the city of Red Wing, Minnesota. The facility is owned and operated by NSPM. Each unit at PlNGP employs a two-loop pressurized water reactor designed and supplied by Westinghouse Electric Corporation. The initial PlNGP application for a Construction Permit and Operating License was submitted to the Atomic Energy Commission (AEC) in April 1967. The Final Safety Analysis Report (FSAR) was submitted for application of an Operating License in January 1971. Unit 1 began commercial operation in December 1973 and Unit 2 began commercial operation in December 1974.
The PlNGP was designed and constructed to comply with NSPM1sunderstanding of the intent of the AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. PlNGP was not licensed to NUREG-0800,
Enclosure NSPM TS 5.2.115.3.1 "Standard Review Plan (SRP)" and was not part of the NRC Systematic Evaluation Program (SEP).
Current TS Requirements and Basis (1) Current TS 5.2.1 Requirements and Basis TS 5.2.1(a) currently states:
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Updated Safety Analysis Report (USAR).
License amendments 105 and 98 (LA 105/98), ML022240386, for Units 1 and 2 respectively, dated May 4, 1993, found it acceptable to delete the corporate and plant organizational charts from the TS and add new specifications that capture the essential aspects of the organizational structure, consistent with GL 88-06, Reference 1. LA 105198 added the following language to the Administrative Controls section of TS, under Onsite and Offsite Organizations:
Lines of authority, responsibility and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Operational Quality Assurance Plan or the Updated Safety Analysis Report.
From this we see that the flexibility proposed in this license amendment was previously in the PlNGP TS.
In the license amendment request and supplements associated with LA 141/132, ML022260707, issued December 7, 1998, changes to the TS section for "Onsite and Offsite Organizations" were proposed that generally utilized the wording in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants" Revision 1, dated April 7, 1995. This paragraph of the TS was revised to state:
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all Page 4 of 13
Enclosure NSPM TS 5.2.115.3.1 operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Updated Safety Analysis Report.
Although the reason for removing "Operational Quality Assurance Plan" from TS was not explicitly discussed in the LAR or NRC Safety Evaluation (SE), it appears to have been removed because that option was not included in NUREG-1431, Revision 1, guidance and the stated intent to allow title changes and addition of appropriate documentation in the USAR in accordance with the requirements of 10CFR50.59.
NUREG-1431 , Revision I, was the current approved version of this NUREG when the license amendment request supporting LA 1411132 was written.
(2) Current TS 5.3.1 Requirements and Basis TS 5.3.1 currently states:
Each member of the plant staff shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision I , September 1975 except for (1) the operations manager who shall meet the requirements of ANSl N18.1-1971, except that NRC license requirements are as specified in TS 5.2.2.e, and (2) the education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in NMC* letter dated March 19, 2003.
The requirements in item (2) were incorporated into TS by LA 1591150, ML031910136 and ML032090047, dated July 22,2003. The purpose of these amendments was to provide:
. . . flexibility for candidates to complete the licensed operator training program who meet the experience eligibility requirements of an accredited training program consistent with 10 CFR 55.31, "How to apply," paragraph 4, but may not meet the Regulatory Guide (RG) or American National Standards Institute (ANSI) experience requirements referenced in the current Technical Specification 5.3. I .
The March 19, 2003, NMC letter, ML030860604, specifically references NANT document ACAD 00-003, Reference 4.
Since RG 1.8, Reference 3, endorses ANSl N18.1-1971, item (2) in effect is taking exception to the ANSl N18.1-1971 operator license applicant education and experience eligibility guidance and in lieu requires use of ACAD 00-003 guidance.
Enclosure NSPM TS 5.2.115.3.1 Proposed Changes (1) TS 5.2.7 proposed changes This LAR proposes to revise the TS 5.2.1(a) by the addition of the words "or Quality Assurance Topical Report" to the end of the last sentence of TS 5.2.I(a). The proposed change would revise the TS to allow the requirements listed in TS 5.2.1(a) to be documented in either the PlNGP USAR or the NSPM QATR.
(2) TS 5.3. Iproposed changes This LAR proposes to revise TS 5.3.1 by removing the "(I)", the clause, "and (2) the education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in NMC* letter dated March 19, 2003",and the footnote,
"*NMC is maintained as historical information". The proposed changes would allow use of more current guidance for selection and qualification of operator license candidates.
Since the exception to meeting RG 1.8, Reference 3, would be removed, this change would also have the effect of requiring the guidance of ANSI N18.1-1971 to be met for operator license applicant education and experience eligibility requirements, Technical Basis for Chancre (I) TS 5.2.1 changes This proposed change would reinstate the ability to store information in a quality assurance document that is maintained under regulatory control.
GL 88-06, Reference 1 states, "The staff has determined that with appropriate changes to these administrative control requirements, the onsite and offsite organization charts may be removed." The changes included a requirement that certain organizational relationships would be described in a document such as the FSAR, Quality Assurance Plan, or other appropriate document which would be referenced in the TS.
The proposed amendment would allow these relationships to be documented in the QATR which is the quality assurance plan for NSPM. QATR revisions are reviewed by NSPM senior management and approved by the NSPM Vice President, Chief Nuclear Officer. Also, changes to the QATR are governed by and made in compliance with 10CFR50.54(a). With these regulatory controls, the QATR is an appropriate document in which the organizational relationships described in TS 5.2.1(a) may be delineated.
This proposed change will provide greater flexibility to implement changes in both the onsite and offsite organizational structure consistent with Commission policy expressed in GL 88-06.
Page 6 of 13
Enclosure MSPM TS 5.2.115.3.1 This proposed change will not affect the changes to administrative control requirements implemented by LA 105198 that capture the essential aspects of organizational structure that bear directly on operational safev.
(2) TS 5.3.1 changes The proposed TS 5.3.1 change will require the guidance of ANSl N18.1-1971 to be met and allow use of more recent industry guidance for the selection and qualification of operator license applicants. The current TS 5.3.1 includes an exception to the requirements of RG 1.8, Reference 3, which effectively takes exception to ANSI N18.1 guidance and by reference to an NMC letter invokes industry guidance ACAD 00-003, Reference 4. Since this provision was incorporated into the PlNGP TS in 2003, updated guidance has been periodically issued as the industry has continued to work with the NRC in refining the guidance for license candidate qualifications. The updated I guidance documents have addressed identified weaknesses in the selection process for initial license candidates as identified by industry and NRC feedback. Specifically, ACAD 10-001, Reference 5, is the most recent guidance document which improves the guidance.
The NRC recognizes that more recent guidance is acceptable for qualifying license candidates. NUREG-1021, "Operator Licensing Examination Standards for Power Reactors", Revision 9, July 2004, states that the NANT guidelines issued in January 2000 (i.e., ACAD 00-003) outline acceptable methods for implementing the regulations for operator licensing. In response to a question on the NRC "Operator Licensing Program Feedback" webpage, the NRC noted that the NANT guidelines issued in February 2010 (that is, ACAD 10-001) provide an acceptable method for meeting the regulations (not withstanding an exception that was also previously taken to ACAD 00-003). The NRC response to the question concluded that, "The next update to NUREG-1021 will be revised to clarify that the NANT's 'current version' of the guidelines for training and qualification of licensed operators is an acceptable method for meeting 10CFR55.31". The NRC response also reiterated the guidance from Regulatory Issue Summary 01-001, "Eligibility of Operator License Applicants":
When a facility licensee's licensed operator training program description or licensing basis documents contain education and experience requirements that are more restrictive than either Revision 3 or RG 1.8 or the current NANT guidelines, the most restrictive requirements will continue to apply pending the initiation of action by the licensee to amend these requirements; [and] any required TS changes would be considered administrative in nature.
Thus, this proposed amendment to PlNGP TS 5.3.1 is required to allow use of recent NANT guidance.
The proposed removal of the education and experience eligibility requirements exception clause exception will effectively require ANSl N18.1 to be fully met for Page 7 of 13
Enclosure NSPM TS 5.2.115.3.1 operator license candidate qualifications.
Other nuclear plant TS, such as NSPMb MNGP, do not take exception to the requirements of their TS referenced personnel seiection and training standard (ANSI N18.1 at MNGP) for license candidate qualifications. MNGP may use the current industry guidance for determining the qualification of license candidates unencumbered by TS references to any guidance in addition to ANSl N18.1. The requirements of MNGP TS 5.3.1 were reviewed under their TS conversion to Improved TS in 2006 and no exceptions to this standard were incorporated into their TS. Thus NSPM proposes to meet the ANSl N18.1 license candidate qualification requirements through use of recent industry guidance without an exception.
Furthermore, TS control of the guidance used for qualification of license candidates is not required due to the direct NRC oversight of operator licensing activities, The NRC has regulatory authority under 10CFR Part 55 to issue a license to an applicant if they determine that an applicant for an operator license or a senior operator license meets the requirements of the Atomic Energy Act and its regulations. NSPM must present candidates for operator licenses that have the appropriate qualifications, training and demonstration of knowledge. The NRC reviews the candidate qualifications, administers tests to determine adequacy of their knowledge and skills, and ultimately issues a license. The NRC is fully empowered to deny licenses to persons who do not possess the requisite qualifications regardless of the standards or guidance NSPM applies in selection and presentation of candidates.
The benefit of industry guidance is that it enables an efficient (for consideration of time and money), consistent process for selection and presentation of candidates. That is, candidates that are selected in accordance with industry standards which the NRC has endorsed are more likely to be licensed by the NRC and thus time and money are less likely to be spent on unworthy candidates.
NSPM proposes in this LAR to remove the exception to RG 1.8, Reference 3, which effectively removes an exception to ANSl N18.1 from the TS and removes the indirect reference to a specific industry guide.
Conclusions This LAR proposes to: 1) allow the organization relationships described in TS 5.2.1(a) to be documented in either the USAR or QATR; and 2) remove the exception to operator license applicants1education and experience requirements, and the reference to a specific industry guidance document in TS 5.3.1. The first change is consistent with the Commission policy expressed in GL 88-06! Reference 1. The second change effectively requires compliance with ANSl N18.1-1971 by removing an exception to RG 1.8, Reference 3, which is cited in the TS.
Enclosure NSPM TS 5.2.115.3.1 These are administrative changes; thus, operation, maintenance and testing of the Prairie Island Nuclear Generating Plant with the proposed licensing basis and TS revisions will continue to protect the health and safev of the public.
- 4. REGULATORY SAFETY ANALYSIS
! 4.1 Applicable Recrulatory RequirementslCriteria Title 10 Code of Federal Requlations 50.36, "Technical s~ecifications":
1 (c) Technical specifications will include items in the following categories:
- 5) Administrative controls. Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in 10 CFR 50.4.
This license amendment request proposes to: 1) revise Technical Specification (TS) 5.2.1(a) by the addition of the Quality Assurance Topical Report (QATR) as an allowed location for documentation of requirements for lines of authority, responsibility, and communication, as described in TS 5.2.l(a); and 2) revise TS 5.3.1 by removing exception (2) which has the effect of requiring compliance with ANSI N18.1 for operator license applicant qualifications. These changes are administrative changes. With these changes, the Technical Specifications will continue to provide administrative controls relating to organization and management of the Prairie Island Nuclear Generating Plant (PINGP) to assure operation of the facility in a safe manner.
Thus with the changes proposed in this license amendment request, the requirements of Title 10 CFR 50.36 continue to be met.
Title 10 Code of Federal Regulations 55.31, "How to Apply":
(a) The applicant shall:
(4) Provide evidence that the applicant has successfully completed the facility licensee's requirements to be licensed as an operator or senior operator and of the facility licensee's need for an operator or a senior operator to perform assigned duties. An authorized representative of the facility licensee shall certify this evidence on Form NRC-398. This certification must include details of the applicant's qualifications, and details on courses of instruction administered by the facility licensee, and describe the nature of the training received at the facility, and the startup and shutdown experience received. In lieu of these details, the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based Page 9 of 13
I i
I Enclosure TS 5.2.115.3.1 NSPM on a systems approach to training and that uses a simulation fecility acceptable to the Commission under $j55,45(b) of this part; This license amendment request proposes to revise TS 5,3,1 by removing exception (2) which has the effect of requiring compliance with ANSl N18.1 for operator license applicant qualifications. This change will allow Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, to utilize updated industry guidance for selection and qualification of operator license candidates. The updated guidance meets the requirements of ANSl N18.1 for operator license applicant qualifications.
Ultimately, the NRC will not issue a license to a candidate unless the requirements of IOCFR 55.31 are met. Thus with the changes proposed in this license amendment request, the requirements of Title 10 CFR 55.31 continue to be met.
4.2 Precedent (1) TS 5.2.1 proposed changes The TS equivalent to TS 5.2.1(a) for the Monticello Nuclear Generating Station (MNGP) currently specifies that either the Updated Safety Analysis Report (USAR) or Quality Assurance Topical Report (QATR) may be used to record organizational information.
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in the Technical Specifications shall be documented in the USAR or Quality Assurance Topical Report.
The proposed revision to TS 5.2. I(a) would make the PlNGP and MNGP TS consistent.
(2) TS 5.3.1 proposed changes The TS equivalent to TS 5.3.1 for the MNGP currently cites ANSl N18.1-1971 for operator license candidate qualifications. MNGP TS 5.3.1 states, "Each member of the unit staff shall meet or exceed the minimum qualification of ANSl N18.1-1971 for comparable positions, except for the radiation protection manager." The PlNGP TS 5.3.1 cites Regulatory Guide 1.8, Revision I , September 1975 which endorses ANSl N18.1-1971, except for radiation protection manager qualifications. Thus, with the proposed revision to TS 5.3.1, the PlNGP and MNGP TS would be functionally equivalent with respect to operator license applicant qualifications.
Page 10 of 13
Enclosure NSPM TS 5.2.115.3.1 4.3 Significant Hazards Consideration Northern States Power Company, a Minnesota corporation (NSPM), has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
I Does the proposed amendment involve a significant Increase In the probability or consequence8 of an accident previously evaluabd?
Response: No This license amendment request proposes to 1) revise Technical Specification 5.2.1(a) by addition of the Quality Assurance Topical Report (QATR) as an allowed location for documentation of requirements for lines of authority, responsibility, and communication; and 2) revise Technical Specification 5.3.1by removal of an exception for operator license applicants' education and experience requirements, and the reference to a letter which references a specific industry guidance document. These are administrative changes.
The proposed changes are administrative and therefore do not significantly affect any system that is a contributor to initiating events for previously evaluated accidents. Nor do the changes significantly affect any system that is used to mitigate any previously evaluated accidents. Therefore, the proposed changes do not involve a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No This license amendment request proposes to 1) revise Technical Specification 5.2.1(a) by addition of the Quality Assurance Topical Report (QATR) as an allowed location for documentation of requirements for lines of authority, responsibility, and communication; and 2) revise Technical Specification 5.3.1 by removal of an exception for operator license applicants' education and experience requirements, and the reference to a letter which references a specific industry guidance document. These are administrative changes.
The proposed administrative changes do not alter the design, function, or operation of any plant component, nor do they involve installation of any new or different equipment. Therefore, the possibility of a new or different kind of accident from those previously evaluated has not been created.
Page 11 of 13
- 3. Does the proposed amendmsnt Dnvoivtsl a significant reduction in a margin of safety?
Response: No This license amendment requast proposes to 1) revise Technical Specification 5.2.1(a) by addition of the Qualiw Assurance Topical Report (QATR) as an allowed location for documentation of requirements for lines of authority, responsibility, and communication; and 2) revise Technical Specification 5.3.1 by removal of an exception for operator license applicants' education and experience requirements, and the reference to a letter which references a specific industry guidance document. These are administrative changes.
The proposed changes are administrative and therefore do not involve a significant reduction in a margin of safety.
Based on the above, NSPM concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4 Conclusions In conclusion, based on the considerations discussed in above, ( I ) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
- 5. ENVIRONMENTAL CONSIDERATION The proposed amendment is confined to (i) changes to surety, insurance, andlor indemnity requirements, or (ii) 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)(I 0). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
- 6. REFERENCES
- 1. Generic Letter 88-06! "Removal of Organization Charts From Technical Specification Administrative Control Requirements", March 22, 1988.
Page 12 of 13
- 2. NUREG-1431, "StandardTechnical Specifications, Westinghouse Plants",
Revision 3.0.
- 3. Regulatory Guide 1.8, "'PersonnelSelection and Training", Revision 1, September 1975,
- 4. ACAD 00-003, "'Guidelinesfar initial Training and Qualification of Licensed Operators,"dated January 2000,
- 5. ACAD 10-001, "Guidelines for lnitial Training and Qualification of Licensed Operators", dated February 2010.
Page 13 of 13
ENCLOSURE, AVACNMENT 1 Technical SpecificatIan Pages (Markup) 2 pages follow
Organization 5.2 5.0 ADMMISTRATIVE CONTROLS 5.2 Organization Onsite and offsite organizations shall be established for plant operation and covorate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.
- a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Updated Safety Analysis Report (USAR) ~x.Qua!it~
A,ssurance Topi~i11
-- Remrt;
- b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;
- c. A corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; and
- d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
Prairie Island Unit 1 - Amendment No. 4%
Units 1 and 2 5.0-2 Unit 2 - Amendment No. 1-49
PImt Staff Qualifications 5.3 5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September I975 except for (&+the operations manager who shall meet the requirements of ANSI N18.1- 1971, except that N3CC license requirements are as specified in TS 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).
Prairie Island Unit 1 - Amendment No, 4-84 4-88 Units 1 and 2 5.0-5 Unit 2 - Amendment No. K4 4 7 7
ENCLOSURE, AmAEHMENT 2 2 pages follow
5.0 AD STBATIW CONTROLS 5.2 Organization Onsite and offsite organizations shall be established for p l m operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant,
- a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Updated Safety Analysis Report (USAR) or Quality Assurance Topical Report;
- b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;
- c. A corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; and
- d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
Prairie Island Unit 1 - Amendment No. 44%
Units 1 and 2 5.0-2 Unit 2 - Amendment No. 4-49
Plant Staff Qualifications 5.3 5.0 ADMINIS TIVE CONTROLS 5.3.1 Each member of the plant saff shall meet or exceed the minimum qu~llificationsof Regulatov Guide 1.8, Revision I, September 1975 except for the operations mmager who shall meet the requirements of ANSI I N 18.1 1971, except that NRC license requirements are as specified in TS 5.2.2.e.
I For the purpose of 10 CFR 55.4, a licensed senior reactor operatar (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).
Prairie Island Unit 1 - Amendment No. 4-84 4-88 Units 1 and 2 5.0-5 Unit 2 - Amendment No. 4% 477