Text

Duke Energy Carolinas, LLC - License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26
	ML091120200
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	02/27/2009
From:	Rosalyn Jones; Duke Energy Carolinas, Duke Energy Corp
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-511, Rev 0
	Download: ML091120200 (29)
	v • d • e

Duke RONALD A.

JONES Energy

.SVP, Nuclear Operations Po~nrgy@Nuclear Generation Duke Energy Corporation 526 South Church St.

February 27, 2009 Charlotte, NC 28202 Mailing Address:

ECO7H / PO Box 1006 U: S. Nuclear Regulatory Commission Charlotte, NC 28201-1006 Attn: Document Control Desk Washington, DC 20555-0001 704 382 8149 704 382 6056 fax rajones@duke-energy. corn

Subject:

Duke Energy Carolinas, LLC (Duke)

Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, 50-270, 50-287 McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369, 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413, 50-414 License Amendment Request for Adoption of TSTF-51 1, Rev.0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR PART 26" In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (1 OCFR), Duke is submitting a request for an amendment to the Technical Specifications (TS) for Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2.

The proposed amendment would delete those portions of TS superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical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-51 1, "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).

Duke is requesting NRC approval of the following for all three sites:

1. An interim TS 5.2.2.e that will be in effect until midnight on September 30, 2009.

2. A TS that deletes the requirement of TS 5.2.2.e and becomes effective on October 1, 2009 This is a minor difference from TSTF-511 and does not adversely affect the NRC staff's model. 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 changes in final typed format. Attachment 4 provides the regulatory commitments.

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

This letter contains regulatory commitments as described in Attachment 4.

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U. S. Nuclear Regulatory Commission February 27, 2009 Page 2 In accordance with 10 CFR 50.91, a copy of this proposed amendment is being provided to the appropriate officials of the States of North Carolina and South Carolina.

If there are any questions please contact R. L. Gill at 704-382-3339.

Sincer y, Ron J nes Sen irice President, Nuclear Operations Attachments:

1. Evaluation of Proposed Change

2. Proposed Technical Specification Change (Mark-Up)

.3. Proposed Technical Specification Change (Re-Typed)

4. List of Regulatory Commitments

U. S. Nuclear Regulatory Commission February 27, 2009 Page 3 xc:

L. A. Reyes, Region II Administrator U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center, 23 T85 61 Forsyth St., SW Atlanta, GA 30303-8931 J. F. Stang, Jr., Senior Project Manager U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 J. H. Thompson, Project Manager U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 G. A. Hutto, NRC Senior Resident Inspector Oconee Nuclear Station J. B. Brady, NRC Senior Resident Inspector McGuire Nuclear Station A. T. Sabisch, NRC Senior Resident Inspector Catawba Nuclear Station S. E. Jenkins, Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 B. 0. Hall, Section Chief Division of Environmental Health, Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699

U. S. Nuclear Regulatory Commission February 27, 2009 Page 5 Ronald A. Jones affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowled Ronal A. 4,nls, Senior Vice President, Nuclear Operations Subscribed and sworn to me:

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Date SEAL

Attachment I Evaluation of Proposed Change License Amendment Request for Adoption of TSTF-51 1, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26" 1.0 Description 2.0 Proposed Change

3.0 Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory Requirements / Criteria 6.0 Environmental Consideration 7.0 References Page 1 of 6

1.0 DESCRIPTION

The proposed amendment would delete those portions 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-51 1, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." Minor differences between the proposed plant specific TS changes, and the changes proposed by TSTF-511 are listed in section 2.0. 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-51 1, the proposed TS changes delete those portions of TS superseded by 10 CFR Part 26, Subpart I.

This application is being made in accordance with the CLIIP. Duke is proposing a minor difference from the TS changes described in TSTF-51 1, Revision 0, published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability.

Duke is requesting NRC approval of the following for all three sites:

1. An interim TS 5.2.2.e that will be in effect until midnight on September 30, 2009.

2. A TS that deletes the requirement of TS 5.2.2.e and becomes effective on October 1, 2009.

This is a minor difference from TSTF-511 and does not adversely affect the NRC staffs model.

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 on December 30, 2008 (73 FR 79923).

4.0 TECHNICAL ANALYSIS

Duke has reviewed the Safety Evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. Duke has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2.

10 CFR Part 26, Subpart I, supersedes existing worker fatigue guidance.

Page 2 of 6

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 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, on October 1, 2009. Along with this License Amendment Request (LAR), Duke 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 Duke has reviewed the no significant hazards determination published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability.

Duke has concluded that the determination presented in the notice is applicable to Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2. Duke 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, 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 Page 3 of 6

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 affect 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 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, Duke 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.

Page 4 of 6

5.2 APPLICABLE REGULATORY REQUIREMENTS I 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). Duke 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 Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, 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 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.

6.0 ENVIRONMENTAL CONSIDERATION

Duke has reviewed the environmental evaluation included in the safety evaluation (SE) published on December 30, 2008 as part of the CLIIP Notice of Availability. Duke has concluded that the staffs findings presented in that evaluation are applicable to Oconee Nuclear Station, Units 1, 2, and 3, McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 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)(1 0). 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.

Page 5 of 6

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).

Proposed Technical Specification Change (Mark-Up)

Proposed Technical Specification Change (Re-Typed)

List of Regulatory Commitments Commitment 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.

Page 6 of 6

ATTACHMENT 2 Proposed Technical Specification Pages (Mark-Up)

Oconee Nuclear Station, Units 1, 2, and 3 McGuire Nuclear Station, Units 1 and 2 Catawba Nuclear Station, Units 1 and 2

Organization 5.2 5.2 Organization 5.2.2 Station Staff (continued)

b.

At least one licensed Reactor Operator (RO) per unit shall be present in the control room when fuel Is In the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided Immediate action is taken to fill the required position.

f.

The Operations Superintendent or Shift Operations Manager shall hold an SRO license.

g.

The Shift Work Manager, whose functions includq those of a 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 Shift Work Manager shall meet the qualifications for STA specified by the Commission Policy Statement on Engineering Expertise on Shift.

OCONEE UNITS 1, 2, & 3 5.0-3 Amendment Nos4gZ5;j I

Organization 5.2 5.2 Organization 5.2.2 Station Staff (continued)

b.

At least one licensed Reactor Operator (RO) per unit shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew membersprovided 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and Implemented to limit the working hours of unit staff who perform safety related functions (e.g.,

licensed SROs, licensed ROs, health physicists, Non-Licensed operators, and key maintenance personnel).

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be periodically reviewed to ensure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

f.

The Operations Superintendent or Shift Operations Manager shall hold an SRO license.

g.

The Shift Work Manager, whose functions include those of a Shift Technical Advisor (STA), shall provide advisory technical support to the

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Shift Supervisor (SS) in the areas of thermal hydraulics, reactor it engineering, and plant analysis with regard to the safe operation of the n* *)*)*

unit. In addition, the Shift Work Manager shall meet the qualifications for Ie ~

(

STA specified by the Commission Policy Statement on Engineering jye.

Expertise on Shift.

OCONEE UNITS 1, 2, & 3 5.0-3f Amendment o4

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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.

e.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

ministrative procedures shall be developed and implemented to Ii working hours of station staff who perform safety related f (e.g., licensed SROs, licensed ROs, radiation on technicians, auxiliary operators, and key mainte personnel).

Adequate shift ge shall be maintained without routine heavy use-d overtim e objective shall be to have operating personn a 12 ay with alternating 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months w Is i e the unit is operating. However, in the event tha seen problems require substantial amounts of ove

used, or during extended periods of shutdown for refueli

, ajr maintenance, or plant modification, on a temporary b e following guidelines shall be followed:

1.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time; McGuire Units 1 and 2 5.2-2 Amendment Nos.(

W

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and implemented to limit the working hours of station staff who perform safety related functions (e.g., licensed SROs, licensed ROs, radiation protection technicians, auxiliary operators, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months day with alternating 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months weeks while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or plant modification, on a p"

temporary basis the following guidelines shall be followed:

1.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months 9 O

)

cJj straight, excluding shift turnover time; b, Drt M

(continued)

McGuire Units 1 and 2 5.2-21 C*l Amendment Nos

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

3.

An individbual should not be permitted to work more rk 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in anyt24 hour period, nor more thadneurs in anc witha edadmin i

straftivurn o

ceurs or by hiso m48 hour period, nor ord e than 72 houeny 7 day period, all Conrol shaull be ionsierd in theiprocedures such thatnindividual overtime Sha reon e moti by heS des cuigng o

hf enurnoe r

thtecsivehushv o besind Rne deviation srmg e

authorized. i fdvaThe Oper~ations Manager salhl or have hedein, an aRclcense.*',

wthe Shp*frt T re Advisor pST)ursh oirwy technical supottotemContro RacomrSncwior ReactorlisOpedrato (

aSOnd wthe reas of theal hraule rhor engihne rinwad peatiana wor withvregardtoithe safevoront o

the u

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tionMana design es reg t

shiftunve-ors time; ntbe sind Aotny deviation fromth above

=guidelines ishl not authorized. in adv nceb s tt Manager salhl or have deineld in SccRO license docum T

entation ofechic a

s disfor SA)salproidiR e adeviatorytcnicl.

oveprtime the Conrol e

RoomSnthly byteatorOeationMagr (CrSO hinshe Sareas of thermal hydraulics, reactor engineering, and plant analysis

]f wihrgrd to the safe operation of the unit.

McGuire Units 1 and 2 5.2-3 Amendment Nos.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

2.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day period, all excluding shift turnover time;

3.

A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be. allowed between work periods, including shift turnover time;

4.

Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Station Manager or his designee to ensure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

f.

The Operations Manager shall hold or have held an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the Control Room Senior Reactor Operator (CRSRO) in thee areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

Mcuie UnMi 1 2-Ae t

McGuire Units 1 and 2 5.2-3~--

Amendment Nosiý-ý

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 when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and implemented to limit the working hours of station staff who perform safety related function (e.g., licensed SROs, licensed ROs, radiation prote=

cnicians, auxiliary operators, and key maintenangconnel).

Adequate shift cov!er all be maintained without routine heavy use of overtime. Th ective shall be to have operating personnel work a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months d ith alten ating 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months weeks while the unit is j,

rating. However, in the event that unforeseen problems r substantial amounts of overtime to be used, or dunn nded periods of shutdown for refueling, major maintenance, ajor plant modification, on a temporary basis the following guid shall be followed:

1.

An individual shou ot be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, ex ing shift turnover time;

2.

ndividual should not be permitted to Work more 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hou y 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day

, all excluding shift turover time;

3.

A break of at le hours should be allowed between work periods, including turnover time;

4.

Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

~- t I

_ii's ()(

' q,-

(CoatlMigd_

Catawba Units 1 and 2 5.2-2 Amendment Nos.

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 when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and implemented to limit the working hours of station staff who perform safety related functions (e.g., licensed SROs, licensed ROs, radiation protection technicians, auxiliary operators, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months day with alternating 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months weeks while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major plant modification, on a temporary basis the following guidelines shall be followed:

1.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time;

2.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day period, all excluding shift turnover time; 3.

on be,_rer

)v Catawba Units 1 and 2 A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift turnover time; Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

(continued) 5.2-2 ice Amendment Nos.(

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Station Manager or his designee torn ensure that excessive hours-have-not been assigned. Routine deviation andm pln abnls witelines is not au fe oration The Shift Operations Manager, Shift Supervisor,fand Assistant Shift b

Supervisor shall hold an SRO license. The Reactor Operator shall hold a

~Reactor Operator License.

g.

The Shift Work Manager, whose functions include those of a Shift Technical Advisor (STA), shall provide advisory technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering, Eand plant analysis with regard to the safe operation of the unit. In addition, the Shift Work Manager shall meet the qualifications.for STA specified b~y the Commission Policy Statement on Engineering Expertise on Shift.

Catawba Units 1 and 2 5.2-3 Amendment Nos.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Station Manager or his designee to ensure that excessive hours have not :been assigned. Routine deviation from the above guidelines is not authorized.

f.

The Operations Superintendent shall hold or have held a SRO license.

The Shift Operations Manager, Shift Supervisor, and Assistant Shift Supervisor shall hold an SRO license. The Reactor Operator shall hold a Reactor Operator License.

g.

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

Catawba Units I and 2 5.2-3 N

Amendment Nos. i.M165j

ATTACHMENT 3 Proposed Technical Specification Change (Re-Typed)

D.U-3 Oconee Nuclear Station, Units 1, 2, and 3

3. U-35 5.0-3a 5.2-2 5.2-2 McGuire Nuclear Station, Units 1 and 2

-2 5.2-2a 5.2-3 5.2-3a Catawba Nuclear Station, Units 1 and 2 TS Pages (Re-Typed)

I To be Submitted at a Later Date

Organization 5.2 5.2 Organization 5.2.2 Station Staff (continued)

b.

At least one licensed Reactor Operator (RO) per unit shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted

f.

The Operations Superintendent or Shift Operations Manager shall hold an SRO license.

g.

The Shift Work Manager, whose functions include those of a 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 Shift Work Manager shall meet the qualifications for STA specified by the Commission Policy Statement on Engineering Expertise on Shift.

This Page is Effective October 1, 2009 OCONEE UNITS 1, 2, & 3 5.0-3 Amendment Nos.

Organization 5.2 5.2 Organization 5.2.2 Station Staff (continued)

b.

At least one licensed Reactor Operator (RO) per unit shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or'4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety related functions (e.g.,

licensed SROs, licensed ROs, health physicists, Non-Licensed operators, and key maintenance personnel).

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be periodically reviewed to ensure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

f.

The Operations Superintendent or Shift Operations Manager shall hold an SRO license.

g.

The Shift Work Manager, whose functions include those of a 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 Shift Work Manager shall meet the qualifications for STA specified by the Commission Policy Statement on Engineering Expertise on Shift.

This Page Expires Midnight September 30, 2009, and may be removed on or after October 1, 2009 OCONEE UNITS 1, 2, & 3 5.0-3a Amendment Nos.

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted

f.

The Operations Manager shall hold or have held an SRO license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the Control Room Senior Reactor Operator (CRSRO) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

This Page is Effective October 1, 2009 McGuire Units 1 and 2 5.2-2 Amendment Nos.

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Administrative procedures shall be developed and implemented to limit the working hours of station staff who perform safety related functions (e.g., licensed SROs, licensed ROs, radiation protection technicians, auxiliary operators, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months day with alternating 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months weeks while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or plant modification, on a temporary basis the following guidelines shall be followed:

1.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time; This Page Expires Midnight September 30, 2009, and may be removed on or after October 1, 2009 (continued)

McGuire Units 1 and 2 5.2-2a Amendment Nos.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

2.

An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day period, all excluding shift turnover time;

3.

A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift turnover time;

4.

Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized in advance by the Station Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Station Manager or his designee to ensure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

f.

The Operations Manager shall hold or have-held an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the Control Room Senior Reactor Operator (CRSRO) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

This Page Expires Midnight September 30, 2009, and may be removed on or after October 1, 2009 McGuire Units 1 and 2 5.2-3a Amendment Nos.

Catawba Nuclear Station Technical Specification Pages (Re-Typed)

To be Submitted at a Later Date Page I of I

ATTACHMENT 4 List of Regulatory Commitments The following table identifies the TS pages committed by Duke that will be removed on or after October 1, 2009, concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements in this document:

Oconee Nuclear Station, Units 1, 2, and 3

).u-i3a McGuire Nuclear Station, Units 1 and 2 5.2.2.e 5.2-2a, 5.2-3a Catawba Nuclear Station, Units 1 and 2 5.2.2.e 5.2-2a, 5.2-3a Page 1 of 1

v t e Letter Sequence Request
TAC:ME0951, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers 10 May 2013 Results Approval Other: ML13365A281, ML14056A167, ML15026A645, RBG-47389, Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RBG-47501, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RBG-47502, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
MONTHYEAR2013-08-28 [Table View]

ML091120200

Text

Subject:

3.0 Background

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

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