ML090400465

License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Work Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

ML090400465
Person / Time
Site:	North Anna
Issue date:	02/06/2009
From:	Hartz L Dominion, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-083
Download: ML090400465 (15)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 6,2009 U.S. Nuclear Regulatory Commission Serial No.09-083 Attention: Document Control Desk NL&OS/ETS RO Washington, D.C. 20555 Docket Nos. 50-338/339 License Nos. NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF*511, REV 0 ELIMINATE WORK HOUR RESTRICTIONS FROM TS 5.2.2 TO SUPPORT COMPLIANCE WITH 10 CFR PART 26 Pursuant to 10 CFR 50.90, Dominion requests amendments in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed amendments will delete those portions of the TS superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Work Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." The availability of this TS improvement was announced in the Federal Register on December 30, 2008 (73 CFR 79923) as part of the consolidated line item improvement process (CLlIP). provides an evaluation of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the proposed TS change in final typed format.

The proposed change has been approved by the Facility Safety Review Committee.

This letter contains one regulatory commitment as identified in Attachment 4.

Dominion requests approval of the proposed license amendments by August 1, 2009.

This will support the implementation of the TS changes concurrent with Dominion's target date of August 14, 2009 for the implementation of the new 10 CFR Part 26, Subpart I requirements. Implementation must be completed by the firm regulatory date of no later than October 1, 2009.09-083 Docket Nos. 50-338/339 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the appropriate designated officials of Virginia.

If you have any questions regarding this submittal or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Very truly yours,

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Leslie N. Hartz Vice President - Nuclear Support Services Attachments

1. Evaluation of Proposed Change

2. Marked-up Technical Specification Change

3. Proposed Technical Specification Change

4. List of Regulatory Commitments Commitment made in this letter:

1. Removal of the plant specific TS requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than October 1, 2009.

COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services, of Virginia Electric and Power Company. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

-rn Acknowledged before me this (0 ~ day of Fe '0'1' v...p.Y\.l\ ,2009.

My Commission Expires: \\Alw\ ~ \ .;> 0 10

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VICKI L. HULL Notary Public Commonwealth at VIrginia

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Pub IC 140542 My Commission Expire. May 31, 2010 ~

09-083 Docket Nos. 50-338/339 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 State Health Commissioner Virginia Department of Health h

James Madison Building - i floor 109 Govenor Street Suite 730 Richmond, Virginia 23219 NRC Senior Resident Inspector North Anna Power Station Mr. J. F. Stang, Jr.

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mai I Stop 0-8 G9A Rockville, Maryland 20852-2738 Ms. D. N. Wright NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mai I Stop 0-8 H4A Rockville, Maryland 20852-2738

Attachment 1 (Serial No.09-083)

Evaluation of Proposed Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No.09-083 Docket Nos. 50-338/339 Page 1 of 5 DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGE

1.0 DESCRIPTION

Virginia Electric and Power Company (Dominion) is requesting amendments to Operating Licenses NPF-4 and NPF-7 for North Anna Units 1 and 2, respectively. The proposed amendments would delete those portions of the Technical Specifications (TS) superseded by 10 CFR Part 26, Subpart I. This change is consistent with the NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." Dominion does not take any exception to the change proposed by TSTF-511. The availability of the TS improvement was announced in the Federal Register on December 30, 2008 (73 CFR 79923) as part of the Consolidated Line Item Improvement Process (CUIP).

2.0 PROPOSED CHANGE

S Consistent with the NRC approved Revision 0 of TSTF-511, the proposed TS change deletes TS 5.2.2.d, which has been superseded by 10 CFR Part 26, Subpart I requirements.

This application is being made in accordance with the CUIP. Dominion is not proposing variations or deviations from the TS change described in TSTF-511, Revision 0, or the NRC staff's model safety evaluation (SE) published on December 30, 2008 (73 CFR 79923) as part of the CUIP Notice of Availability.

3.0 BACKGROUND

The NRC issued a Federal Register notice (73 FR 16966, March ~:1, 2008) of the issuance of a final rule that amended 10 CFR Part 26. The revised regulations in 10 CFR Part 26, Subpart I supersede the working hour restrictions in paragraph d of TS 5.2.2. The background for this application is adequately addressed by the NRC Notice of Availability published on December 30,2008 (73 CFR 79923).

4.0 TECHNICAL ANALYSIS

Dominion has reviewed the SE published on December 30, 2008 (73 CFR 79923) as part of the CUIP Notice for Availability. Dominion has also concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to North Anna Units 1 and 2.

Serial No. 09-Q83 Docket Nos. 50-338/339 Page 2 of 5 10 CFR Part 26, Subpart I, supersedes existing worker fa,:igue guidance.

10 CFR Part 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens the requirements for both. Underthe new rule, work hour restrictions include not only work hour limitations for rolling 24-hiour, 48**hour, and 7-day periods, but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from restrictions) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility. Subpart I also strengthens reporting requirements. Finally, the new rule's work hour control scope includes certain operating and maintenance personnel, as well as individuals directing those operating and maintenance personnel, health physics and chemistry personnel who are part of the on-site emergency response organization minimum shift complement, the fire brigade member who is responsible for understanding the effects of fire and fire suppressants on safe shutdown capability, and certain security personnel.

The proposed change removes working hour limits in the Technical Specifications in order to support compliance with 10 CFR Part 26, Subpart I. Work hour controls and fatigue management requirements have been incorporated into the NHC's regulations, therefore, it is unnecessary to have work hour control requirements n the Technical Specifications.

Removal of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requirements, even if the Technical Specification change is implemented prior to the October 1, 2009 deadline.

Along with this LAR, Dominion has submitted a cornmltrnent to comply with 10 CFR Part 26 concurrently with the implementation of the Technical Specification changes.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Determination Dominion has reviewed the no significant hazards determination published on December 30, 2008 (73 CFR 79923), as part of the CUIP Notice of Availability.

Dominion has concluded that the determination presented in the nonce is applicable to North Anna Units 1 and 2. Dominion has evaluated the proposed change to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. An analysis of tHe issue of no significant hazards consideration is presented below:

Criterion 1: The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated

Serial No.09-083 Docket Nos. 50-338/339 Page 3 of 5 The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. Removal of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requirements. The proposed change does not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. Worker fatigue is not an indicator of any accident previously evaluated. \JVorker fatigue is not an assumption in the consequence mitigation of any accident previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2: The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Accident Previously Evaluated The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. Working hours will continue to be controlled in accordance with NRC requirements. The new rule allows for deviations from controls to mitigate or prevent a condition adverse to safety or as necessary to maintain the security of the facility. This ensures that the new rule will not unnecessarily restrict working hours and thereby create the possibility of a new or different kind of accident previously evaluated.

The proposed change does not alter the plant configuration, reoulre new plant equipment to be installed, alter accident analysis assumptions, add any initiators, or effect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected.

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

Criterion 3: The Proposed Change Does Not Involve a Significant Reduction in a Margin of Safety The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. The proposed change does not involve any physical changes to the plant or alter the manner in which plant systems are operated, maintained,

Serial No.09-083 Docket Nos. 50-338/339 Page 4 of 5 modified, tested, or inspected. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by these changes. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Removal of plant specific Technical Specification administrative requirements will not reduce a margin of safety because the requirements in 10 CFR Part 26 are adequate to ensure that worker fatigue is managed.

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

Based upon the above, Dominion concludes that the proposed change 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 Regulatory Requirements/Criteria A description of the proposed Technical Specification change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on December 30, 2008 (73 CFR 79923). Dominion has reviewed the NRC staff's model SE published on December 30,2008 (73 CFR 79923) as part of the CUIP Notice of Availability and concluded that the regulatory evaluation section is applicable to North Anna Units 1 and 2.

The proposed change eliminates the plant specific Technical Specification administrative controls on working hours. The Technical Specification guidance has been superseded by 10 CFR Part 26.

10 CFR Part 26, Subpart I, "Managing Fatigue," contains the requirements for managing worker fatigue at operating nuclear power plants.

10 CFR 50.36 provides, among other things, the regulatory requirements for the content in the Administrative Controls section of the Technical Specifications. The inclusion of requirements to control working hours and manage fatigue is not required to be in the Administrative Controls by 10 CFR Part 50.36. Because the requirements to control working hours and manage fatigue is provided in 10 CFR Part 26, Subpart I, it is unnecessary for the Technical Specifications to contain similar controls.

Serial No.09-083 Docket Nos. 50-338/339 Page 5 of 5

6.0 ENVIRONMENTAL CONSIDERATION

Dominion has reviewed the environmental evaluation included in the SE published on December 30, 2008 (73 CFR 79923) as part of the CUIP Notice of Availability.

Dominion has concluded that the staff's findings presented in thl3 evaluation are applicable to North Anna Units 1 and 2. The proposed amendments change recordkeeping, reporting, or administrative procedures. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CI=R 51.22(c)(1 0).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment is required in connection with the issuance of the amendments.

7.0 REFERENCES

1. Federal Register Notice, Final Rule 10 CFR Part 26 published on March 31, 2008 (73 CFR 16966)

2. Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 1(I CFR Part 26,"

Revision 0

3. Federal Register Notice, Notice of Availability published on December 30, 2008 (73 CFR 79923)

Attachment 2 (Serial No.09-083)

Marked-up Technical Specifications Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (DominiOn)

Organization 5.2 5.2 Organlzatlon 5.2.2 Unit Staff The unit staff organization shal r include the fol lowing:

a. An auxll iary operator shall be assigned to each reactor conta in i n9 fue I and an add it i ona I aux iii ary operator sha I I be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4. .

Two unit sites with both units shutdown or defueled require a total of three auxiliary operators for the two units.

b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m) (2)(i) and 5.2.2.a and 5.2.2.f for a per lod of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c . A rad i at ion protect ion techn i c ian sha I I be on site when fue lis in the reactor. The pasit i on may be vacant for not more, than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fil I the required position d" Oe.\..E'Tt.~

I 1m it the work i ng hours of personne I who perform safety re I ated ctions (e.g., I icensed Senior Reactor Operators (SROs),

lie ed Reactor Operators (ROs) , health physicists, aux' 'ary operata and key maintenance personnel). '

The controls s I include gUidelines on work' ensure adequate s . t coverage shal I be m .

routine heavy use of rtime.

in Contr shal I be included in the procedures to requi ~a p 'odic independent review be conducted to ensure that~.

xcessive hours have not been assigned. ~

North Anna Units 1 and 2 5.2-2 Amendments 231/212

Attachment 3 (Serial No.09-083)

Proposed Technical Specifications Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Organization 5.2 5.;~ Organization 5.;~. 2 Unit Staff The unit staff organization shall include the following:

a. An auxiliary operator shall be assigned to each reactor containing fuel and an additional auxiliary operatnr shall be assigned for each control room from which a reactor is operating in MODES I, 2, 3, or 4.

Two unit sites with both units shutdown or defueled require a total of three auxiliary operators for the two units.

b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. A radiation protection technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d. Deleted North Anna Units 1 and 2 5.2-2 Amendments

Attachment 4 (Serial No.09-083)

List of Regulatory Commitments North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

List of Regulatory Commitments

1. Removal of the plant specific Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than October 1, 2009.