ML022000259

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License Amendment, Clarify Requirements for Licensed Operator Qualifications (TAC Nos. MB2695 & TAC MB2696)
ML022000259
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 09/17/2002
From: Boska J
NRC/NRR/DLPM/LPD1
To: Skolds J
Exelon Generation Co
Boska J, NRR, 301-415-2901
References
TAC MB2695, TAC MB2696
Download: ML022000259 (14)


Text

September 17, 2002 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 -

ISSUANCE OF AMENDMENT RE: CLARIFICATION OF REQUIREMENTS FOR LICENSED OPERATOR QUALIFICATIONS (TAC NOS. MB2695 AND MB2696)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendments Nos. 245 and 249 to Facility Operating License Nos. DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station, Units 2 and 3.

These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 1, 2001 as supplemented on June 19 and September 9, 2002.

These amendments revise TS 5.3.1 to state that the licensed operators shall comply with the qualification requirements in 10 CFR Part 55, rather than the American National Standards Institutes (ANSI) standard ANSI N18.1-1971.

A copy of the safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice.

Sincerely,

/RA by SWall for/

John P. Boska, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosures:

1. Amendment No. 245 to DPR-44
2. Amendment No. 249 to DPR-56
3. Safety Evaluation cc w/encls: See next page

Peach Bottom Atomic Power Station, Units 2 and 3 cc:

Vice President, General Counsel and Secretary Exelon Generation Company, LLC 300 Exelon Way Kennett Square, PA 19348 Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Rich Janati, Chief Division of Nuclear Safety Bureau of Radiation Protection Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.

Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Manager Licensing-Limerick and Peach Bottom Exelon Generation Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348

Peach Bottom Atomic Power Station, Units 2 and 3 cc:

Director - Licensing Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Vice President-Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President, Mid-Atlantic Operations Support Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Manager License Renewal Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

ML022000259 changes made.

OFFICE PDI-2/PM PDI-2/LA IEHB*

OGC PDI-2/SC(A)

NAME SWall for JBoska TLC for MOBrien DTrimble AFernandez JAndersen DATE 9/16/02 7/24/02 07/12/02 9/16/02 9/17/02

EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-277 PEACH BOTTOM ATOMIC POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 245 License No. DPR-44 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 1, 2001, as supplemented on June 19 and September 9, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I.

B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. DPR-44 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 245, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James W. Andersen, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 17, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 245 FACILITY OPERATING LICENSE NO. DPR-44 DOCKET NO. 50-277 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 5.0-5 5.0-5

EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-278 PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 249 License No. DPR-56 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 1, 2001, as supplemented on June 19 and September 9, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I.

B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. DPR-56 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 249, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James W. Andersen, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 17, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 249 FACILITY OPERATING LICENSE NO. DPR 56 DOCKET NO. 50-278 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 5.0-5 5.0-5

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 245 TO FACILITY OPERATING LICENSE NO. DPR-44 AND AMENDMENT NO. 249 TO FACILITY OPERATING LICENSE NO. DPR-56 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR, LLC PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1.0 INTRODUCTION

By letter dated August 1, 2001, Exelon Generation Company, LLC (Exelon, parent company of the licensees of the following plants) submitted an application for license amendments for Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Clinton Power Station; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Three Mile Island Nuclear Station, Unit 1; and Quad Cities Nuclear Power Station, Units 1 and 2, to the Nuclear Regulatory Commission (NRC) for approval. Exelon provided additional information by letters dated June 19 and September 9, 2002. Exelon requested approval of changes to the plant-specific technical specifications (TSs) to revise the requirements regarding facility staff qualifications and licensed operator and non-licensed personnel training programs. The application stated that the changes would revise requirements that have been superseded based on licensed operator training programs being accredited by the Institute for Nuclear Power Operations (INPO), promulgation of the revised 10 CFR Part 55, Operators Licenses, which became effective on May 26, 1987, and adoption of a systems approach to training as required by 10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel. Exelons June 19 and September 9, 2002, letters provided clarifying information within the scope of the Federal Register notice and did not change the NRC staffs proposed no significant hazard consideration determination dated October 31, 2001 (66 FR 55018).

While Exelons application covered all its nuclear facilities listed above, this safety evaluation is specifically for Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 (PBAPS).

2.0 REGULATORY BACKGROUND On March 20, 1985, the NRC issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, which endorsed the training accreditation process and the National Academy for Nuclear Training (NANT). In Generic Letter 87-07, Information Transmittal of Final Rulemaking for Revisions to Operator Licensing -

10 CFR Part 55 and Conforming Amendments, dated March 19, 1987, and in NUREG-1262, Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses," published November 1987, the NRC staff indicated it would accept a facilitys licensed operator training program if the facility certified in writing that the program was accredited and based on a systems approach to training (SAT). This certification would supersede the requirement of American National Standards Institute (ANSI) N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, and ANSI/ANS-3.1-1978, Selection, Qualification and Training of Personnel for Nuclear Power Plants. Facility licensees were advised to submit a request to the NRC for an administrative change to their licensing basis documents to revise or delete, as appropriate, the requirements that had been superseded.

In 1992 the NRC published its proposed rule 10 CFR 50.120. The proposed rule stated that, if adopted, the rule would supersede the Policy Statement on Training and Qualification of Nuclear Power Plant Personnel and would not result in any change to accredited programs.

The NRC concluded that accredited programs, implemented consistent with industry objectives and criteria, would be in compliance with this regulation. In April 1993 the NRC published its final rule on training and qualification of nuclear power plant personnel. The rule requires nuclear power plant licensees to establish, implement, and maintain SAT-based training programs for nine non-licensed positions. Accreditation of these nine training programs is an acceptable means of meeting the requirements of 10 CFR 50.120.

On January 18, 2001, the NRC published NRC Regulatory Issue Summary (RIS) 2001-01, Eligibility of Operator License Applicants, to familiarize licensees with the NRC's current guidelines for the qualification and training of reactor operator and senior operator license applicants. RIS 2001-01 acknowledged that 10 CFR 55.31(a)(4) allows the NRC to accept an application for an operators license if the facility licensee certifies that the applicant has successfully completed a Commission-approved training program that is based on a systems approach to training. In addition, RIS 2001-01 stated that: (1) a training program would be considered approved by the NRC when it receives or renews accreditation from the National Nuclear Accrediting Board (NNAB); (2) accreditation of operator training programs suggests that facilities are implementing the education and experience guidelines endorsed by the NNAB; (3) NANT guidelines for education and experience (those in effect in 1987 or those issued in January 2000) outline acceptable methods for implementing the Commission's regulations; and (4) the NRC staff encourages all facility licensees to review their requirements and commitments related to licensed operator and senior operator education and experience and to update their documentation (e.g., Final Safety Analysis Report, Technical Specifications, and training program descriptions) to enhance consistency and minimize confusion.

3.0 TECHNICAL EVALUATION

The changes proposed by Exelon will revise, clarify, or delete, as appropriate, requirements regarding facility staff qualifications and licensed operator and non-licensed personnel training programs at the facilities named above in Section 1.0. The requested changes will update requirements that had been outdated based on licensed operator training programs being accredited by INPO, promulgation of the revised 10 CFR Part 55, and adoption of a systems approach to training as required by 10 CFR 50.120.

The licensed operator training programs and the training programs for the nine non-licensed positions required by 10 CFR 50.120 at the Exelon facilities are accredited by the NNAB and are based on a systems approach to training as stated in the August 1, 2001, submittal.

Proposed TS Section 5.3, Unit Staff Qualifications, describes the requirements for unit staff qualifications. In addition, the education and experience eligibility requirements for reactor operator and senior reactor operator license applicants will be described in applicable station training procedures. The revised wording of this section specifies that the education and experience eligibility requirements of the operator license applicants, and changes thereto, shall be approved by the NRC and described in an application station training procedure. Changes to the procedures addressing issues other than education and experience eligibility requirements may be made consistent with the Exelon procedure revision process. Exelon stated that a note will be added to the applicable procedures to serve as a reminder for the procedure writer to ensure that the requirements imposed by this TS section are followed (i.e.,

content of the applicable sections/pages will not be changed without prior NRC approval).

The NRC staff concludes that the modified education and experience eligibility requirements in Section 5.3 of the TSs for PBAPS, and the procedural excerpts providing education and experience eligibility flowcharts as described in the submittal of June 19, 2002, are adequate because they conform with the reactor operator and senior reactor operator license eligibility criteria and standards acceptable to the NRC, and, per the wording in the TSs, affords the NRC final approval authority for changes to eligibility criteria contained within the applicable procedures. In order to assure that approval of future changes to the operator qualifications will be done by a license amendment, the staff clarified the TSs by adding a specific document reference (the licensees letter of June 19, 2002) that contains the operator qualifications. The licensees letter of September 9, 2002, acknowledged that this clarification was being added to the TSs. In addition, the changes will not affect the 10 CFR 50.36(c)(5) requirement to ensure the licensee maintains administrative controls that ensure the operation of the facility in a safe manner.

4.0

SUMMARY

The NRC staff concludes that the modified education and experience eligibility requirements in Section 5.3 of the TSs, and the procedural excerpts providing education and experience eligibility flowcharts submitted with the June 19, 2002, submittal are adequate because they conform with the reactor operator and senior reactor operator license eligibility criteria and standards acceptable to the NRC, and that with the revised TS wording and reference to the licensees June 19, 2002, letter, it is clear that the NRC has final approval authority through the license amendment process for changes to eligibility criteria. Further, the proposed TS changes are consistent with 10 CFR Part 55 and 10 CFR 50.120 and do not adversely affect nuclear safety or plant operations.

5.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State Official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Pelton Date: September 17, 2002