PLA-6474, Amendment Request No. 304 and 275, Adoption of TSTF-511, Rev 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

Amendment Request No. 304 and 275, Adoption of TSTF-511, Rev 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

ML090920414
Person / Time
Site:	Susquehanna
Issue date:	03/24/2009
From:	Spence W Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6474, TSTF-511, Rev 0
Download: ML090920414 (15)

Text

William H. Spence President PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 610.774.3683 Fax 610.774.5019 Whspence@pplweb.com 4(#i

• 41*

P U.-TM MAR 2 4 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION AMENDMENT REQUEST NO. 304 TO LICENSE NPF-14 AND AMENDMENT REQUEST NO. 275 TO LICENSE NPF-22:

ADOPTION OF TSTF-511, REV. 0, "ELIMINATE WORKING HOUR RESTRICTIONS FROM TS 5.2.2 TO SUPPORT COMPLIANCE WITH 10 CFR PART 26" PLA-6474

)ocket Nos. 50-387 and 50-388 In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), PPL Susquehanna, LLC (PPL) is submitting a request for an amendment to the Technical Specifications (TS) for Susquehanna Steam Electric Station Units 1 & 2. The proposed amendment would delete TS Section 5.2.2.e, which is superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical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-5 11, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26" with no variations. The availability of this TS improvement was announced in the Federal Register on December 30, 2008 (73 FR 79923) as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. provides the existing TS pages marked up to show the proposed change. provides the listing of regulatory commitments.

PPL requests approval of the proposed license amendment by September 1, 2009 to support implementation of the changes concurrent with implementation of the new 10 CFR 26, Subpart I requirements by October 1, 2009.

This letter contains one regulatory commitment as identified in Attachment 3.

ODD1 LWA6 Document Control Desk PLA-6474 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Commonwealth of Pennsylvania Official.

If you should have any questions regarding this submittal, please contact Ms. Mari J. Jaworsky at (570) 542-3270.

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

Executed on:

07 Attachments: - Evaluation of the Proposed Change - Proposed Technical Specification Changes, Units 1 & 2, (Mark-ups) - List of Regulatory Commitments cc:

NRC Region I Mr. R. R Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager to PLA-6474 Evaluation of the Proposed Change License Amendment Request for Adoption of TSTF-5 11, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26"

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

to PLA-6474 Page 1 of 5 EVALUATION OF PROPOSED CHANGE

1.0 DESCRIPTION

The proposed amendment would delete Section 5.2.2.e of 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-5 11, "Eliminate Working 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 FR 79923) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

Consistent with the NRC approved Revision 0 of TSTF-5 11, the proposed TS change deletes Section 5.2.2.e of TS superseded by 10 CFR Part 26, Subpart I for Susquehanna Steam Electric Station, Units 1 & 2.

This application is being made in accordance with the CLIIP. PPL Susquehanna, LLC (PPL) is not proposing variations or deviations from the TS changes described in TSTF-5 11, Revision 0, or the NRC staff s model safety evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability.

3.0 BACKGROUND

The NRC issued a Federal Register Notice (73 FR 16966, March 31, 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 working hour restrictions contained in paragraph e of TS 5.2.2. The background for this application is adequately addressed by the NRC Notice of Availability published December 30, 2008 (73 FR 79923).

4.0 TECHNICAL ANALYSIS

PPL has reviewed the SE published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. PPL has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Susquehanna Steam Electric Station, Units 1 & 2 (SSES).

10 CFR Part 26, Subpart I, supersedes existing worker fatigue guidance. 10 CFR Part 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens the requirements for both. Under the new rule, work hour restrictions include not only work hour limitations for rolling 24-hour, 48-hour, and 7-day periods, but also to PLA-6474 J,..

Page 2 of 5 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 a 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 imposed 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 NRC's regulations; therefore, it is unnecessary to have work hour control requirements in 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, PPL has submitted a commitment to comply with 10 CFR Part 26 concurrently with the implementation of the Technical Specification change.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Determination PPL has reviewed the no significant hazards determination published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. PPL has concluded that the determination presented in the notice is applicable to Susquehanna Steam Electric Station, Units 1 & 2 (SSES). PPL has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do 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 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, to PLA-6474 Page 3 of 5 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 initiator of any accident previously evaluated. Worker 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 from any accident previously evaluated.

The proposed change does not alter the plant configuration, require 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 or 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 plant or alter the manner in which plant systems are operated, maintained, 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 this change. The proposed change will not result in plant operation in a to PLA-6474 Page 4 of 5 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 on the above, PPL 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 TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on December 30, 2008 (73 FR 79923). PPL has reviewed the NRC staffs model SE published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to Susquehanna Steam Electric Station, Units 1 & 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 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 requirement 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.

to PLA-6474 Page 5 of 5

6.0 ENVIRONMENTAL CONSIDERATION

PPL has reviewed the environmental evaluation included in the safety evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. PPL has concluded that the staffs findings presented in that evaluation are applicable to Susquehanna Steam Electric Station, Units 1 & 2. The proposed amendment changes recordkeeping, reporting, or administrative procedures.

Accordingly, the amendment meets 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 amendment.

7.0 REFERENCES

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

2. TSTF-51 1, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."

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

to PLA-6474 Proposed Units 1 & 2 Technical Specification Changes (Mark-ups)

PPL Rev.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b.

At least one licensed Reactor Operator (RO) shall be present in the control room of each unit which has fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room. This individual may be qualified on both Units and serving in this capacity for both Units.

c.

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.g 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.

d.

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.

e.

Deleted..A.di.s....trati..e procoduI r.. shall be developed and imtmit the woerking hours of unit stf whoperforrm safety relatod functions (o.g., licensed 9140, liconsod RGs ho6hpyiits, auxiliary oporators, and key maintenRG ncpersonnol).

Adequate shift copverage shall be main~tained wiAthou t routine heavy, use of AvR40ime.

The obiective shall be to have oeeratina D~ersonne(l Werk a; nominal 40 hou r weetk while the unit is operating. However, in the event that unforeseen problems require substantial amounts*of overtime to be used, or dulRing extendedp eri oof shutdow forF refueling, major mainten-Rance, or mnajor plant modific-ation, on a temporary basis the-followfing guidelines shall be folloe-ved:

A m

Im g I m

m I mS i I i m

il

• A I I.An.ndvdual s.*.u.

net be permtteo to work more than 1 b

.Flour stra:g,,t, oXcluding shift turnover time,

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> period, nor more than 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> in any 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> period, nor more than 72 hourFsi any 7 day period, all excluding shift tu1rnover timne; (continued)

SUSQUEHANNA - UNIT 1 TS/5.0-3 Amendment 4-7-8 1

PPL Rev.

Organization 5.2 5.2 Orqanization 5.2.2 Unit Staff (continued)

3. A. break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods,inudg Shift turnover time;

4. Except dur~ing extended shutdwnM perGiod, the use Of o19ertiMe should be on*edd

• o

-An indiVidu,-al -b;Asis* an*d-noGt fo-r the-entir-s

• aff o

a -hift.

AnY deviationm from the above guidelines sh-all beA -authorized inadvance by the plant manager or hi" desige*, in acordan. e w...ith approved adminisrative procedures, or by ige lv1els of managemen.t, in accordance With es...

tabli.he p-roedures -and4wth dceaOn of theb-asis for gr*antig the deviation.

Conrols6 6hall be included in the procedures sucGh that individual overtime shall be reviewed monthly by the plant m~anager or his6 designee to ensur~e that excesv hours6 have no~t been assigned. Rou1tine deviation fro~m the -above gulidelines isno authoried.

f.

The operations manager or assistant operations manager shall hold an SRO license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Supervisor (SS) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the'qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

SUSQUEHANNA - UNIT 1 TS/5.0-4 Amendment 4-7-9 1

PPL Rev.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room of each unit which has fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room. This individual may be qualified on both Units and serving in this capacity for both Units.

c. 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.g 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.

d. 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.

e. Deleted..Adini...trativ. p r..duros shall be developod and implemen ted toG imi the working hours of unit

,stav who p..om

.afety relatod functions (9.g.,

f.icenod_ SR_*s, I ens.d RO6, health physficists, auxiliar' operators, a*d key maintonanco* personnel).

Adequato shift covorago shall be Main*tainod_ without routino heavy 6168 of evoeime. ThG objoctiVo shall be to have perating poron ner work a n*oGmi 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> vok **hle thoe uit is operatig*.

HoWeVor, in tho* 9eVt th-At u'nf1, e n

probloms requiro substantial amonGRts_ Of ortim to8 bo ud, or duFrig oxtondod pGOriods of shutdoPwn for ref uoling, major m~afintenace or majo plant modification, on a timp*rarlI basis the following guidelines shall be followed:

1. An indivwdual should not be9 permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnoVer time;

2. An individual should not be8 permitted to work moere than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> inn 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> perord, nor more than 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> in any 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> periodn more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in an" 7 day period, all eXc6l1ud*g Shift turoW e time; (continued)

SUSQUEHANNA - UNIT 2 TS_._5.0-3 Amendment 4-5 1

PPL Rev.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

I il I I I

I i

2. A~ break or at 8os h fours snoula bo allowed Detwoen work ponods6, inclu6ding shift tu-rno-Vor time;L

4. Excop t during extended shutdoWn poriods, the,s oA f overtimoe ehould be orn.idoFed napn idvidual baris-,

and Rot f"o the,ontre-Staff on a shift.

Any deviation fromA the abovo gu;idelinos shall be authorized in -ad-vance by the plant mnanager or hi6 digne

, inacrac with approved administrative prhcodure6, or by highor lovels of maragemeRt, in accordanlr With 9otablished procedIuros and With dIocumontation of the basis for granting the doviation.

Conrols shall be included in the procoduros such that inividua-l ove;rtime -hall beA ro-ViewodC-monthly by the plant manager or his d~esignee to ensure that excessiVe hours ha-ve not been assignedI. Routine deitinfro the abov guidelines is no~tauhrzd

f. The operations manager or assistant operations manager shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Supervisor (SS) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

SUSQUEHANNA - UNIT 2 TS/5.0-4 Amendment 4Z4 1 to PLA-6474 List of Regulatory Commitments to PLA-6474 Page 1 of 1 List of Regulatory Commitments The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions, are provided for informational purposes, and are not considered to be regulatory commitments.

Regulatory Commitments Due Date/Event Removal of the plant-specific TS requirements will be performed This commitment will concurrently with the implementation of the 10 CFR Part 26, be completed no later Subpart I requirements.

than October 1,2009.