ML13310B550

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Amend Application 122 to License DPR-13,revising Tech Specs to Add Requirements Re Administration & Use of Unit Staff Overtime,Per Generic Ltrs 82-12 & 82-16
ML13310B550
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 07/17/1984
From: Baskin K
Southern California Edison Co
To:
Shared Package
ML13310B549 List:
References
GL-82-012, TAC-54127, TAC-54700, TAC-54701 NUDOCS 8407190425
Download: ML13310B550 (7)


Text

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application ofSOUTHERN CALIFORNIA EDISON

)

COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY )

for a Class 104(b) License to Acquire,

) DOCKET NO. 50-206 Possess, and Use a Utilization Facility as Part of Unit No. 1 of the San Onofre Nuclear ) Amendment Application No. 122 Generating Station

)

SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 122.

This amendment application consists of Proposed Change No. 119 to Provisional Operating License No. DPR-13. Proposed Change No. 119 modifies the Technical Specifications incorporated into Provisional Operating License No. DPR-13 as Appendices A and B.

Proposed Change No. 119 is a request to revise the Appendix A, Technical Specifications to add requirements on the administration and use of unit staff overtime. These revisions were requested by the NRC in Generic Letter Nos. 82-12 and 82-16 dated June 15, 1982 and September 20, 1982, respectively.

In the event of conflict, the information in Amendment Application No. 122 supersedes the information previously submitted.

9407190425 840717 PDR ADOCK 05000206 P

POR i

-2 Based on the safety analysis provided in the Description of Proposed Change and Safety Analysis, it is concluded that (1) the proposed changes do not involve an unreviewed safety question as defined in 10 CFR 50.59, nor do they present significant hazards considerations not described or implicit in the Final Safety Analysis, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.

Pursuant to 10 CFR 170.12 as revised in 49 FR 21293 dated May 21, 1984, the fee of $150.00 is herewith remitted.

-3 Subscribed on this /7' day of d

/0da Respectfully s bmitted, SOUTHERN CALIFORNIA EDISON COMPANY By 2er Kenneth P. Baskin Vice President Subscri ed and sworn o before me this

/7 day of

/"

OFFICIAL SEAL AGNES CRABTREE NOTARY PUBLIC -

CALIFORNIA PRINCIPAL OFFICE IN 4

LOS ANGELES COUNTY My Commission Expires Aug. 27, 1986 Nota~ Public in and for the County of Los Angeles, State of Callfornia My Commission Expires:

?/2 6 Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company By Ja A. Beoletto

-4 Subscribed on this _

__ day of Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By J. C. Holcombe Vice Prest By E. Hamrick Vice President Subscribed and sworn to before me this day of OFFICIAL SEAL DONNA MARIE McGUIRE NOTARY PUBLIC -CALIFORNIA PRINCIPAL OFFICE IN SAN DIEGO COUNTY My Commission Exp. Feb. 8, 1988 Notary Public in and for the County of San Diego, State of California My Commission Expires:

f David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By K J David R. Pigott

DESCRIPTION OF PROPOSED CHANGE AND SAFETY ANALYSIS PROPOSED CHANGE NO. 119 TO THE TECHNICAL SPECIFICATIONS SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 PROVISIONAL OPERATING LICENSE DPR-13 This is a request to revise Appendix A, Technical Specification 6.2.2, Unit Staff.*

Description The purpose of this proposed change is to comply with NRC requests for a Technical Specification on unit staff overtime as discussed in Generic Letters 82-12 and 82-16.

The proposed change revises the administration of staff overtime at San Onofre Nuclear Generating Station, Unit 1. Technical Specification 6.2.2 describes the unit organization and defines the minimum personnel required to perform operations tasks. The purpose of this proposed change is to add a requirement that controls the use of overtime at the plant in response to the NRC, "Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors."

This change conforms to the Commission policy on plant staff working hours as defined in Generic Letter 82-12. The proposed wording is consistent with the model Technical Specification provided to all licensees in Generic Letter 82-16. In addition, key maintenance personnel are defined in Specification 6.2.2.f.** The wording conforms to the definition of "key maintenance personnel" provided in Generic Letter 83-14 and specifically classifies those members of the Station staff that are covered by this Techncial Specification.

Existing Technical Specification Not Applicable Proposed Technical Specification See Attachment The words unit staff were used to be consistent with Proposed Change No. 130.

Section f of Technical Specification 6.2.2 is used to be consistent with the redesignations of Proposed Change No. 130.

-2 Safety Analysis The proposed change shall be deemed to constitute a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with these proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The administrative controls.imposed by these proposed changes will ensure that the use of plant staff overtime is monitored and controlled. The maintenance of plant staff in an alert state will reduce the probability or consequences of accidents previously evaluated. Therefore, operation of the facility in accordance with these proposed changes will not increase the probability or consequences of an accident previously evaluated.

2. Will operation of the facility in accordance with these proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The revision of overtime restrictions is administrative in nature and does not alter the configuration or operations of the plant in any way. Therefore, operation of the facility in accordance with these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Will operation of the facility in accordance with these proposed changes involve a significant reduction in a margin of safety?

Response: No The limitation of staff working hours in accordance with these proposed changes will ensure that the use of plant staff overtime is monitored and controlled. The maintenance of the plant staff in an alert state will enhance the design margin of safety. Therefore, these proposed changes to the administrative section of the technical specifications do not involve a significant reduction in a margin of safety.

These proposed changes are in response to a need to draft appropriate Technical Specifications for plant staff overtime for San Onofre Nuclear Generating Station, Unit 1. These Technical Specifications are necessary to implement the NRC's final policy statement on staff overtime. Therefore, the proposed changes are similar to example (vii) of amendments not likely to involve a significant hazards consideration published in 48 FR 14864 dated April 6, 1983.

-3 Safety and Significant Hazards Determination Based on the Safety Analysis, it is concluded that (1) Proposed Change No. 119 does not involve a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is reasonable assurance that the health and safety of the public will not be endangered by these proposed changes; and (3) this action will not result in a condition which alters the impact of. the station on the environment as described in the NRC Final Environmental Statement.

GvN:1933F Attachment