ML022600529

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License Amendment Revision to TSs Change Request - Clarification of Requirements for Licensed Operator Qualifications & Training
ML022600529
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/24/2002
From: Pickett D
NRC/NRR/DLPM/LPD3
To: Skolds J
Exelon Generation Co, Exelon Nuclear
Pickett D, NRR/DLPM, 415-1364
References
TAC MB2687
Download: ML022600529 (12)


Text

September 24, 2002 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555

SUBJECT:

CLINTON POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT (TAC NO. MB2687)

Dear Mr. Skolds:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 154 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit 1. The amendment is in response to your application dated August 1, 2001, and as supplemented by letters dated June 19 and September 9, 2002.

The amendment revises technical specification requirements that have been superseded based on the licensed operator training program being accredited by the Institute of Nuclear Power Operations, promulgation of the revised 10 CFR Part 55, and adoption of a systems approach to training as required by 10 CFR 50.120.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosures:

1. Amendment No. 154 to NPF-62
2. Safety Evaluation cc w/encls: See next page

ML022600529 OFFICE PM:PD3-2 LA:PD3-2 IQMB OGC SC:PD3-2 NAME DPickett THarris DTrimble*

AFernandaz AMendiola DATE 09/17/02 09/17/02 07/12/02 09/23/02 09/24/02

Clinton Power Station, Unit 1 cc:

Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Vice President - Mid-West Opns Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Senior Vice President - Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Manager Licensing - Clinton and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director-Licensing Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Senior Counsel, Nuclear Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Document Control Desk-Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, IL 62704 Site Vice President - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Clinton Power Station Plant Manager AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Regulatory Assurance Manager - Clinton AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351

Clinton Power Station, Unit 1 cc:

Resident Inspector U.S. Nuclear Regulatory Commission RR#3, Bo x 229A Clinton, IL 61727 R. T. Hill Licensing Services Manager General Electric Company 175 Curtner Avenue, M/C 481 San Jose, CA 95125 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Chairman of DeWitt County c/o County Clerks Office DeWitt County Courthouse Clinton, IL 61727 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603

AMERGEN ENERGY COMPANY, LLC DOCKET NO. 50-461 CLINTON POWER STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 154 License No. NPF-62 1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by AmerGen Energy Company, LLC (the licensee), dated August 1, 2001, and as supplemented by letters dated 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. NPF-62 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.

are hereby incorporated into this license. AmerGen Energy Company, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

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

FOR THE NUCLEAR REGULATORY COMMISSION

/RA by LRaghavan for/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 24, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 154 FACILITY OPERATING LICENSE NO. NPF-62 DOCKET NO. 50-461 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 a marginal line indicating the area of change.

Remove Pages Insert Pages 5.0-5 5.0-5

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 154 TO FACILITY OPERATING LICENSE NO. NPF-62 AMERGEN ENERGY COMPANY, LLC CLINTON POWER STATION, UNIT 1 DOCKET NO. 50-461

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 a letter dated June 19, 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, 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. Additional information was provided by Exelon in its letters of June 19 and September 9, 2002.

Exelons letters dated June 19 and September 9, 2002, provided clarifying information within the scope of the original application and did not change the NRC staffs proposed no significant hazard consideration dated October 31, 2001 (66 FR 55009).

While Exelons application covered all its nuclear facilities listed above, this safety evaluation is specific for the Clinton Power Station.

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 writing 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 is 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 TS for the Clinton Power Station, 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 of 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 TS 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 assure 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 TS, 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 Illinois 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 impacts statement or environmental assessment need be prepared in connection with the issuance of the amendment(s).

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 24, 2002