NLS2005037, License Amendment Request to Revise Technical Specifications - Unit Staff Qualifications

License Amendment Request to Revise Technical Specifications - Unit Staff Qualifications

ML051740472
Person / Time
Site:	Cooper
Issue date:	06/20/2005
From:	Minahan S Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2005037
Download: ML051740472 (17)

Text

Nebraska Public Power District Always there when you need us 50.90 NLS2005037 June 20, 2005 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

License Amendment Request to Revise Technical Specifications -Unit Staff Qualifications Cooper Nuclear Station, Docket No. 50-298, DPR-46 The purpose of this letter is for the Nebraska Public Power District (NPPD) to request an amendment to Facility Operating License DPR-46 in accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90 to revise the Cooper Nuclear Station (CNS) Technical Specifications (TS). The proposed amendment revises TS 5.3, Unit Staff Qualifications, to upgrade the qualification standard for the Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer from Regulatory Guide 1.8, Revision 2, to Regulatory Guide 1.8, Revision 3. It also clarifies qualification requirements applicable to the Operations Manager position. provides a description of the TS change, the basis for the amendment, the no significant hazards consideration evaluation pursuant to 10 CFR 50.91(a)(1), and the environmental impact evaluation pursuant to 10 CFR 51.22. Attachment 2 provides the proposed changes to the current CNS TS on marked up pages. Attachment 3 provides the revised TS pages in final typed format. There are no Bases for TS 5.3.

NPPD requests approval of the proposed amendment by May 31, 2006, with a 60-day implementation period.

This proposed TS change has been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). Amendments to the CNS Facility Operating License through Amendment 211 issued March 22, 2005, have been incorporated into this request. NPPD has concluded that the proposed changes do not involve a significant hazards consideration and that they satisfy the categorical exclusion criteria of 10 CFR 51.22(c)(10). This request is submitted under oath or affirmation pursuant to 10 CFR 50.30(b).

By copy of this letter and its attachments, the appropriate State of Nebraska official is notified in accordance with 10 CFR 50.91(b)(1). Copies to the Nuclear Regulatory Commission Region IV COOPER NUCLEAR STATION P.O. Box 98 / Brownville. NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5217 www.nppd.com

NLS2005037 Page 2 of 2 office and the CNS Resident Inspector are also being provided in accordance with 10 CFR 50.4(b)(1).

Should you have any questions concerning this matter, please contact Mr. Paul Fleming, Licensing Manager, at (402) 825-2774.

I declare under penalty of perjury that the foregoing is true and correct.

Executed On:

c

- sL 0 -0 5 Date Stewart inahan General Manager of Plant Operations

/lb Attachments cc:

Regional Administrator w/ attachments USNRC - Region IV Senior Project Manager w/ attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachments USNRC Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/ attachments

NLS2005037 Page 1 of 10 ATTACHMENT 1 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS UNIT STAFF QUALIFICATIONS COOPER NUCLEAR STATION NRC DOCKET 50-298, LICENSE DPR-46 Revised TS Page 5.0-4 1.0 Description 2.0 Proposed Change 3.0

Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria 6.0 Environmental Consideration 7.0 References

NLS2005037 Page 2 of 10

1.0 DESCRIPTION

This letter is a request to amend Operating License DPR-46 for Cooper Nuclear Station (CNS).

The proposed change revises the Operating License by revising the Technical Specifications (TS) to upgrade the unit staff qualifications for the Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer from Regulatory Guide 1.8, Revision 2, to Regulatory Guide 1.8, Revision 3. This change updates requirements that have become outdated based on the licensed operator training program being accredited by the Institute of Nuclear Power Operations (INPO), promulgation of the revised 10 CFR Part 55 (Operators' Licenses) in 1987, and issuance of 10 CFR 50.120 (Training and Qualification of Nuclear Power Plant Personnel) in 1993. The proposed change also clarifies the qualification requirements for the Operations Manager position. These changes provide clarity and consistency to the CNS licensing basis. The revisions are administrative in nature.

2.0 PROPOSED CHANGE

This license amendment request proposes changes to TS 5.3, Unit Staff Qualifications.

TS 5.3.1 currently commits to American National Standards Institute (ANSI) N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," for unit staff qualifications with the exception that the Shift Manager, Senior Operator, Licensed Operator, Shift Technical Engineer, and radiological manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2.

This proposed change upgrades the qualification requirements for the Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer to Regulatory Guide 1.8, Revision 3.

Qualification requirements for the Operations Manager position are added to clarify that the Operations Manager shall meet or exceed the qualifications of ANSI N18.1-1971, except for the requirement to have a current Senior Reactor Operator's (SRO) license. If not currently licensed, the Operations Manager will be required to have previously held a SRO license. At CNS, the Operations Supervisor is the individual required to hold a current SRO license in accordance with TS 5.2.2.e. NOTE: The Operations Supervisor title is currently a lowercase generic title in TS. The Operations Manager title is also proposed to be a lowercase generic title in TS.

In addition, a minor change is made in TS 5.3.1 to correct the title of ANSI N18.1-1971.

NLS2005037 Page 3 of 10

3.0 BACKGROUND

On March 20, 1985, the Nuclear Regulatory Commission (NRC) issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (Reference 1) which endorsed the training accreditation program developed by INPO, in association with its National Academy for Nuclear Training (NANT). Subsequently, Generic Letter 87-07 (Reference 2) was issued on March 19, 1987, and provided licensees the option to substitute an accredited training program based on a systems approach to training for their operator training program previously approved by the NRC.

This option was in accordance with revisions to 10 CFR Part 55. CNS adopted this option and notified the NRC of such in August 1987. The CNS Updated Safety Analysis Report (FSAR) was updated accordingly in July 1988 to reflect the revised operator training program. However, at that time, a corresponding change was not made to the CNS TS which committed to ANSI N18.1-1971 for staff qualifications.

In 1993, 10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel, was issued which required that a training program based on a systems approach to training be applied to the training programs for various personnel including the shift supervisor and shift technical advisor by November 22, 1993.

In July 1998, the NRC issued a "Request for Additional Information Related to Plant Staff Qualifications" to CNS. This request asked CNS to describe how our commitment to an ANSI standard other than that endorsed by Regulatory Guide 1.8, Revision 2 meets the requirements of Part 55. As a result of that request, CNS submitted a license amendment request to upgrade our commitment from ANSI N18.1-1971 to Regulatory Guide 1.8, Revision 2, for the positions of Shift Supervisor, Senior Operator, Licensed Operator, Shift Technical Advisor, and Radiological Manager. License Amendment 181 was subsequently granted by the NRC on March 15, 2000 (Reference 3).

In May 2000, the NRC issued Regulatory Guide 1.8, Revision 3 (Reference 4), which endorsed ANSI/ANS 3.1-1993 (Reference 5), with certain clarifications and exceptions.

This revision made changes to education and experience requirements for licensed personnel and also specifically endorsed a systems approach to training.

In January 2001, the NRC issued Regulatory Issue Summary (RIS) 2001-001 (Reference

6) to familiarize licensees with the NRC's current guidelines for qualification and training of reactor operator and senior operator license applicants. This RIS made the following statements:

"...a facility licensee's training program would be considered approved by the NRC when it is accredited by the National Nuclear Accrediting Board (NNAB)."

NLS2005037 Page 4 of 10 "The NRC staff has reviewed the NANT guidelines and considers them to be equivalent to the NRC's guidelines in Revision 3 of Regulatory Guide (RG) 1.8, which was published in May 2000."

"The staff encourages all facility licensees to review their requirements and commitments related to RO [Reactor Operator] and SO [Senior Operator]

education and experience and to update their documentation (e.g., FSAR, TS, and training program descriptions) to enhance consistency and minimize confusion."

"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 of 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; any required TS changes would be considered administrative in nature."

The proposed revision to TS 5.3.1 updates requirements for training and qualification of licensed operating personnel as discussed above. It also upgrades the training and qualification requirements for the Shift Technical Engineer and Shift Manager to be consistent with Regulatory Guide 1.8, Revision 3.

In accordance with TS 5.3.1, CNS is currently committed to ANSI N18.1-1971 for the generic operations manager position as described in the standard. One of the requirements for this position is, "At the time of initial core loading or appointment to the active position the operations manager shall hold a Senior Reactor Operator's License."

The CNS Updated Safety Analysis Report currently identifies that the Operations Supervisor is filling the generic operations manager role described in the ANSI standard.

The Operations Supervisor is directly in the reporting hierarchy between the Shift Managers and the Operations Manager and is the primary individual responsible for directing the activities of the operating crews. TS 5.2.2.e currently states, "The operations supervisor shall hold an SRO license."

The most current guidance for staff qualifications found in ANSI/ANS 3.1-1993 specifically allows the Operations Manager to either hold a Senior Operator's license or to have held a Senior Operator's license. It also states that if the Operations Manager does not hold a Senior Operator's license, then the Operations Middle Manager shall hold a Senior Operator's License. At CNS, the Operations Middle Manager would be the Operations Supervisor. Therefore, the approach proposed in this license amendment request is consistent with current guidance. The addition of the Operations Manager

NLS2005037 Page 5 of 10 qualification provisions to TS 5.3.1 eliminates confusion regarding the applicable qualification standard for this position.

4.0 TECHNICAL ANALYSIS

The changes to TS 5.3 proposed by this license amendment request are administrative in nature and have no impact on plant safety systems or design basis accidents. No plant equipment is being changed, and no methods of plant operation or maintenance are being changed.

By promulgation of the 10 CFR Part 55 rule change, the NRC determined that an accredited licensed operator training program based on a systems approach to training provides an acceptable means of qualifying licensed operating personnel. The NRC has concluded in both NUREG-1262 (Reference 7) and RIS 2001-001 (Reference 6) that the standards and guidelines applied by INPO in their training accreditation program are equivalent to those put forth or endorsed by the NRC. Therefore, maintaining an INPO accredited training program based on a systems approach to training is equivalent to maintaining an NRC approved licensed operator training program. Regulatory Guide 1.8, Revision 3, endorses the use of a systems approach to training and provides education and experience requirements consistent with those used by the NANT.

The licensed operator training and qualification program will continue to comply with the requirements of 10 CFR 55. The CNS licensed operator training program is accredited by INPO and is based on a systems approach to training.

This change is proposed in consideration of the guidance of RIS 2001-001 which encouraged licensees to review their requirements and commitments related to RO and SO education and experience and to update their documentation (including TS) to enhance consistency and minimize confusion.

CNS also applies an accredited process based on a systems approach to training to the Shift Manager and Shift Technical Engineer training programs. This is consistent with the requirements of 10 CFR 50.120. Regulatory Guide 1.8, Revision 3, requires application of a systems approach to training to these programs. The education and experience requirements endorsed by the NRC in Regulatory Guide 1.8, Revision 3, will also be applied. Therefore, the proposed change that upgrades the qualifications of the Shift Manager and Shift Technical Engineer to Regulatory Guide 1.8, Revision 3, is acceptable.

CNS TS 5.2.2.e currently requires the Operations Supervisor to hold a SRO license. The Operations Supervisor at CNS is directly in the reporting hierarchy between the Operations Manager and the Shift Managers and is the primary individual responsible for directing the activities of the operating crews. The Operations Manager does not directly supervise reactor operators, but provides a higher level managerial oversight of the

NLS2005037 Page 6 of 10 Operations Department. The proposed requirement to hold or have previously held a SRO license provides adequate assurance that the Operations Manager has an appropriate level of operations knowledge. This approach is consistent with that currently contained in ANSI/ANS 3.1-1993. The Operations Manager will be required to meet or exceed the remaining qualifications of the generic operations manager position described in ANSI N18.1-1971.

5Property "ANSI code" (as page type) with input value "ANSI N18.1-1971.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration 10 CFR 50.91(a)(1) requires that licensee requests for operating license amendments be accompanied by an evaluation of any significant hazard posed by issuance of the amendment. Nebraska Public Power District (NPPD) has evaluated this proposed amendment with respect to the criteria given in 10 CFR 50.92(c).

The proposed change would amend the operating license by revising Technical Specification 5.3, Unit Staff Qualification, to upgrade the unit staff qualifications for the Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer from Regulatory Guide 1.8, Revision 2, to Regulatory Guide 1.8, Revision 3.

In addition, qualification requirements for the Operations Manager position would be added to clarify that the Operations Manager shall meet or exceed the qualifications of ANSI N18.1-1971 except for the requirement to have a current Senior Reactor Operator's (SRO) license. If not currently licensed, the Operations Manager will be required to have previously held a SRO license. At CNS, the Operations Supervisor is the individual required to hold a current SRO license in accordance with Technical Specification 5.2.2.e. NOTE: The Operations Supervisor title is currently a lowercase generic title in TS. The Operations Manager title is also proposed to be a lowercase generic title in TS.

The following evaluation supports a finding of"no significant hazards consideration" associated with this proposed change.

l.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response

No These changes are administrative in nature and do not require any physical modifications, affect any plant components, or result in any changes in plant operation. They provide clarity and consistency to the CNS licensing basis.

Upgrading the unit staff qualifications for the Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer from Regulatory Guide 1.8,

NLS2005037 Page 7 of 10 Revision 2, to Regulatory Guide 1.8, Revision 3, is an administrative change that will clarify the current requirements for qualification and training of operations personnel. The changes are consistent with the application of a systems approach to training in an accredited training program. By promulgation of the 10 CFR Part 55 rule change, the NRC determined that an accredited licensed operator training program based on a systems approach to training provides an acceptable means of qualifying licensed operating personnel.

The addition of qualification requirements for the Operations Manager position clarifies SRO license requirements for Operations management personnel by specifying that the Operations Supervisor is the member of Operations management required to have a current SRO license at CNS. The Operations Manager is required to hold or have previously held a SRO license. This will ensure an acceptable level of operations knowledge to perform in a managerial oversight role. This approach is consistent with current guidance in ANSI/ANS 3.1-1993. This change is administrative in nature and has no impact on previously evaluated accidents.

Therefore, these changes do not involve a significant increase in the probability or consequences 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 These changes are administrative in nature and do not involve a physical alteration of the plant or a change to plant operations. No new failure mechanisms, malfunctions, or accident initiators are introduced. The proposed changes provide clarity and consistency to the CNS licensing basis in regard to training and qualification of operations personnel and SRO license requirements for Operations management personnel.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response

No These changes are administrative in nature and do not affect any Technical Specification safety limit or limiting condition for operation. No safety margins are affected by these changes. The proposed changes do not involve a change in

NLS2005037 Page 8 of 10 plant design or operation for the mitigation of postulated accidents. The proposed changes provide clarity and consistency to the CNS licensing basis in regard to training and qualification of operations personnel and SRO license requirements for Operations management personnel.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NPPD concludes that the proposed amendment presents no 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.

5.2 Applicable Regulatorv Requirements/Criteria

1.

10 CFR 55.3 1(a)(4) states in part, "..... the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based on a systems approach to training and that uses a simulation facility acceptable to the Commission under

§55.45(b) of this part."

2.

10 CFR 55.59(c) states in part, "The requalification program must meet the requirements of paragraphs (c) (1) through (7) of this section. In lieu of paragraphs (c) (2), (3), and (4) of this section, the Commission may approve a program developed by using a systems approach to training."

3.

Generic Letter 87-07 and NUREG-1262 indicated that the NRC would accept a licensee's licensed operator training program if it is accredited and based on a systems approach to training.

4.

10 CFR 50.120(b) states in part, "..... each nuclear power plant licensee, by November 22, 1993, shall establish, implement, and maintain a training program derived from a systems approach to training as defined in 10 CFR 55.4. The training program must provide for the training and qualification of the following categories of nuclear power plant personnel:... (ii) Shift supervisor, (iii) Shift technical advisor...."

5.

10 CFR 50.54(1) states, "The licensee shall designate individuals to be responsible for directing the licensed activities of licensed operators.

These individuals shall be licensed as senior operators pursuant to part 55 of this chapter."

The proposed changes conform to the above regulatory criteria. The NPPD licensed operator training program is accredited by INPO and based on a systems approach to training. The licensed operators' qualification and training program

NLS2005037 Page 9 of 10 will continue to comply with the requirements of 10 CFR Part 55. Regulatory Guide 1.8, Revision 3, endorses a systems approach to training for licensed operators, shift supervisors, and shift technical advisors. The education and experience requirements endorsed by Regulatory Guide 1.8, Revision 3, are consistent with those applied by INPO. The CNS Operations Supervisor is the individual responsible for directing the activities of licensed operators and is required to maintain a current SRO license.

6.0 ENVIRONMENTAL CONSIDERATION

NPPD has evaluated the proposed amendment for environmental considerations. The proposed amendment is confined to changes to administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

"Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel," 50 FR 11147, dated March 20, 1985.

2.

Generic Letter 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10 CFR 55 and Conforming Amendments,"

dated March 19, 1987.

3.

NRC to NPPD, Cooper Nuclear Station - Issuance of Amendment on Unit Staff Qualifications, (Amendment 181), dated March 15, 2000.

4.

Regulatory Guide 1.8, Revision 3, "Qualification and Training of Personnel for Nuclear Power Plants, dated May 2000."

5.

ANSI/ANS 3.1-1993, "American National Standard for Selection, Qualification, and Training of Personnel for Nuclear Power Plants."

6.

NRC Regulatory Issue Summary 2001-01, "Eligibility of Operator License Applicants," dated January 18, 2001.

7.

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.

NLS2005037 Page 10 of 10 The following references are similar amendments granted by the NRC.

8.

Comanche Peak Steam Electric Station, Units 1 and 2, Docket Nos. 50-445 and 50-446, Issuance of License Amendment 100 to Facility Operating License Nos.

NPF-87 and NPF-89, dated September 4, 2002.

9.

Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Docket Nos. 50-528, 50-529, and 50-530, Issuance of Amendment No. 39 to Facility Operating License NPF-41, Amendment No. 26 to Facility Operating License No. NPF-51, and Amendment No. 15 to Facility Operating License No. NPF-74, dated October 24, 1988.

10.

Indian Point Nuclear Generating Unit No. 3, Docket No. 50-286, Issuance of Amendment 134 to Facility Operating License No. DPR-64, dated June 15, 1993.

NLS2005037 Page 1 of 2 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS MARKUP FORMAT COOPER NUCLEAR STATION NRC DOCKET 50-298, LICENSE DPR-46 Listing of Revised Pages TS Page 5.0-4

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of the A

can National Standards njstiute NX8.1-1971, "Selection and Training of t perseiro,)

Pefsorsnsi.e mNuclear Power Plana," except for the Shift Manager, Scnior Operater, Lcned Operator, Shift Technical EngineeF, and radiological mnapoiruh oc exse Ilpifications of Regulatory Guide 1.8, Roevision 2' INSERT A:

a.

Te radiological manager shall meet or exceed the qualifications of Regulatory 5

Guide 1.8, Revision 2.

b.

The Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 3.

c.

The operations manager shall meet or exceed the qualifications of ANSI N18.1-1971 except for the requirement to have a current Senior Reactor Operator's (SRO) license, which shall be in accordance with Technical Specification 5.2.2.e.

If not currently licensed, the operations manager shall have previously held a

\\

~SRO license.

r Cooper 5.0-4 Amendment 200-

NLS2005037 Page 1 of 2 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS FINAL TYPED FORMAT COOPER NUCLEAR STATION NRC DOCKET 50-298, LICENSE DPR-46 Listing of Revised Pages TS Page 5.0-4

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of the American National Standards Institute N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," with the following exceptions:

a.

The radiological manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2.

b.

The Shift Manager, Senior Operator, Licensed Operator, and Shift Technical Engineer shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 3.

c.

The operations manager shall meet or exceed the qualifications of ANSI N 18.1-1971 except for the requirement to have a current Senior Reactor Operator's (SRO) license, which shall be in accordance with Technical Specification 5.2.2.e.

If not currently licensed, the operations manager shall have previously held a SRO license.

Cooper 5.0-4 Amendment

I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS(

Correspondence Number:

NLS2005037 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None I

PROCEDURE 0.42 l

REVISION 16 l

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