ML17229A749
| ML17229A749 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/27/1998 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17229A750 | List: |
| References | |
| L-98-130, NUDOCS 9806030225 | |
| Download: ML17229A749 (17) | |
Text
REGULAT CATEGORY ly Y INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:980 6030225 DOC.DATE: 98/05/27 NOTARIZED: YES DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power &, Light Co. 05000335
...50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH.NAME AUTHOR AFFILIATION STALL,J.A. Florida Power &. Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to licenses DPR-67 & NFP-16,revising TS 6.2.2.f to allow use of longer operating shifts of up to twelve hours duration by plant's operating crews.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution E
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 LA 1 1 PD2-3 PD 1 1 GLEAVES,W 1 1 INTERNAL: ACRS 1 1 E CENTER 01 1 1 NRR/DE/ECGB/A 1 1 CB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRZB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR D
U E
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL 13
Florida Power & Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 May 27, 1998 L-98-130 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments 0 erations Shift Schedules In accordance with 10 CFR 50.90, Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-67 and NPF-16 be amended to modify the St.
Lucie Units 1 and 2 Technical Specifications by deleting the Technical Specification 6.2.2.f.
requirement "...to have operating personnel work a normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day, 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week while the plant is operating." The proposed change will allow FPL to implement various controlled shift structures and durations during a nominal (36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week. The proposed changes will allow the use of up to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts without routine heavy use of overtime. The Technical Specifications will continue to require the controls and guidelines for work hours to be contained in administrative procedures.
FPL has determined that the proposed license amendments do not involve a significant hazards consideration pursuant to 10 CFR 50.92. A description of the requested amendments is provided in Attachment 1 The no significant hazards determination in support of the proposed Technical
~
Specification changes is provided in Attachment 2. Attachment 3 provides the proposed revised Technical Specifications.
In accordance with 10 CFR 50.91(b)(1), a copy of these proposed license amendments are being forwarded to the State Designee for the State of Florida. The proposed license amendments have been reviewed by the St. Lucie Facility Review Group and the FPL Company Nuclear Review Board. Should there be any questions on this request, please contact us.
Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/EJW Attachments
'7806030225 980527 PDR ADQCK 05000335 P PDR an FPL Group company
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a L-98-130 P~ae 2 cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant W. A. Passetti, Florida Department of Health and Rehabilitative Services
L-98-130 P~ae 3
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) ss.
COUNTY OF ST. LUCIE )
J. A. Stall being first duly sworn, deposes and says:
That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
J. A. Stall L~
STATE OF FLORIDA COUNTY OF S~
Sworn to and subscribed before me e
this c~dayof 19 ~B by J. A. Stall, who is personally known to me.
Signature of Notavj2o ic-State of Florida LOSIIO J. WhiNYell
- e: $ f
- i=, MY CONCSSION CC646T63 EXPIRES May 12, 200i 80HOEO THRU TROY FARI NSURMICE. INC.
Name of Notary Public (Print, Type, or Stamp)
2 L-98-130 Page 1 ATTACHMENT1 DESCRIPTION OF AMENDMENTSRE UEST 1.0 Introduction Florida Power and Light Company (FPL) is requesting that Appendix A of Facility Operating Licenses DPR-67 and NPF-16, for St. Lucie Units 1 and 2, respectively, be revised to allow for the use of longer operating shifts of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> duration by the plant's operating crews. The longer shifts would result in a reduced number of shift turnovers each day and result in more efficient shift-to-shift communications and continuity. From a quality of life perspective, longer shift schedules result in more consecutive days off between work periods and more rested personnel. The implementation of longer shifts would result in plant operators working a nominal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week (e.g.,
three consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days or four consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days) during normal plant operation.
Changes are proposed to revise St. Lucie Units 1 and 2 Technical Specifications (TS) Administrative Controls, Section 6.2.2.f., to delete the requirement "...to have operating personnel work a normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day, 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week while the plant is operating." The proposed change will allow FPL to implement various controlled shift structures and durations during a nominal (36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week. The proposed changes will allow the use of up to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shiAs without routine heavy use of overtime. The TS will continue to require the controls and guidelines for work hours to be contained in administrative procedures.
2.0 Pro osedChan es:Descri tionandBases/Justification 2.1 B~ack round 0 Ph Rl, 2, h RRCPhllhdl h ~dd 4*447PR7222) h **Pllp Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In June 1982, the NRC revised the policy and subsequently disseminated the revision in Generic Letter 82-12, "Nuclear Plant Staff Working Hours," which recommended that licensees incorporate specific working hour limits in plant TS to minimize the potential for personnel errors resulting from fatigue. The staff subsequently determined that'few events at U. S. nuclear plants have been attributed to inadequate control of working hours and that control of working hours through administrative procedures provides reasonable assurance that personnel overtime will not jeopardize safe plant operation. Control of overtime through administrative procedures is consistent with Action Item I.A.1.2.1, "Limit Overtime," of NUREG-0737, "Clarification of TMI Action Plan Requirements," dated November 1980. St. Lucie Units 1 and 2 TS 6.2.2.f. include specific limits on the number of hours an individual
L-98-130 Page 2 can be at work in a 24-hour period, 48-hour period, and any 7- day period. St. Lucie Units 1 and 2 Technical Specifications 6.2.2.f. state:
Administrative procedures shall be developed and implemented to limit the working
'ours ofunit staff who perform safety-related functions; e.g., senior reactor operators, reactor operators, health physicists, 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 normal 8-hour day, 40-hour week while the plant 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:
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 /> straight, excluding shift turnover time.
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 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.
- 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, 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 by the Plant Manager or his deputy, or 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 Plant-Manager or his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.
St. Lucie Units 1 and 2 now work an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> operator shift schedule. Each day, there are three shift-to-shift turnovers from one operating crew to its relief. FPL desires to have the option of using up to a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift schedule which would reduce the number of shift-to-shift turnovers. While the change to longer shifts is focused on quality of life improvements for the plant's operators, the fewer number of shift-to-shift turnovers will reduce the potential for miscommunication and errors.
L-9S-130 Attachment 1 Page 3 2.2 Descri tion of Chan es The following changes in each unit's TS, included in Attachment 3, are proposed:
TS 6 2 2 PLANT STAFF REVISE Technical Specification 6.2.2.f., to read (revisions only presented below):
Administrative procedures shall be developed and implemented to limit the working hours ofunit stafFwho perform safety-related functions; e.g., senior reactor operators,
'reactor operators, health physicists, auxiliary operators, and key maintenance personnel.
jiihea'dttntgst'udtve:: Lioredeuthssiuh dtnehtdegstudt'ute':." sontvoriuitghohinat haunt catt.ru
.g'iit!stradequate shift coverage slndHm t't'i: maintained without routine heavy use of
.H,i that unforeseen problems require substantial amounts of overtime to be used, or h
during extended periods'of shut-down for refueling, major maintenance, or major plant modifi'cation, on a temporary basis the following guidelines shall be followed:
There are no additional proposed changes to the balance Basis/Justification of Technical Specification 6.2.2.f.
2.3 forPr osed Chan es Specific working hours are not required to be included in the TS under 10 CFR 50.36(c)(5),
"Administrative Controls." The NRC policy is that licensees are to establish controls to ensure that personnel are not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or their decision making capability. The NRC stafF has found, in license amendments issued on other dockets (including Turkey Point Units 3 and 4), that shifts of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> duration have not significantly impaired personnel performance, provided the overtime guidelines and controls are observed, as incorporated in the St. Lucie Units 1 and 2 TS and restated above. The proposed license amendment does not change the overtime limits TS and FPL proposes to retain the limits on the use of overtime and the administrative controls which implement the Technical Specification requirements.
. The proposed changes to TS 6.2.2.f. willpermit FPL to implement operating shifts of up to 12-hours duration and will result in quality of life improvements for the plant's operators. The longer shifts will result in more consecutive days ofF between the alternating three and four day work weeks, resulting in more rested operating crews. Additionally, the fewer number of shift-to-shift turnovers will reduce the potential for miscommunication and errors.
'ttachment 1
Page 4 The proposed changes to TS 6.2.2.f. will not allow the routine heavy use of overtime and the limits that are placed on overtime for each individual have not been altered. Since the controls on overtime willbe retained, the proposed St. Lucie Units 1 and 2 TS provide reasonable assurance that personnel are not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or their decision making capability. Therefore, FPL proposes that the TS be revised to allow for the use of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts by the plant's operating crews.
3.0 Environmental Consideration The proposed license amendments do not change limitations with respect to installation or use of a facility component located'within the restricted area as defined in 10 CFR Part 20, nor do they change surveillance requirements for facility equipment. The proposed amendments involve no significant increase in the amounts and no significant change in the types of any efHuents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL has concluded that the proposed amendments involve no significant hazards considerations and meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
4.0 Conclusion This proposed change will allow FPL to implement different shift duration structures. FPL is proposing to delete the requirement which stipulates 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts. The proposed TS changes will allow St. Lucie Plant Operations personnel to work a regularly scheduled shift rotation of up to 12-hour duration, resulting in quality of life improvements for the plant's operators.
I L-98-130 Page 1 ATTACHMENT2 NO SIGNIFICANTHAZARDS CONSIDERATION DETERMINATION DESCRIPTION OF PROPOSED LICENSE AMENDMENTS Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-67 and NPF-16 be amended to modify the St. Lucie Units 1 and 2 Technical Specifications (TS) to delete the TS 6.2.2.f. requirement "...to have operating personnel work a normal 8-hour day, 40-hour week while the plant is operating." The proposed changes will allow FPL to implement various controlled shift structures and durations during a nominal (36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week. The proposed changes will allow the use ofup to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts without routine heavy use of overtime. The TS will continue to require the controls and guidelines for work hours to be contained in administrative procedures.
INTRODUCTION The Nuclear Regulatory Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92 (c)). A proposed amendment to an operating license for a facility involves no significant hazards consideration, ifoperation of the facility in accordance with the proposed amendment 'would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated," or (3) involve a significant reduction in a margin of safety. Each standard is discussed below for the proposed amendments.
DISCUSSION (1) Operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed amendments will delete the TS 6.2.2.f. requirement "...to have operating personnel work a normal 8-hour day, 40-hour week while the plant is operating." The proposed change will allow FPL to implement various controlled shift structures and durations during a nominal (36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week. The proposed changes will allow the use of up to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts without routine heavy use of overtime. The TS will continue to require the controls and guidelines for work hours to be contained in administrative procedures. The proposed amendments do not involve a change to any structure, system, or component that affects the probability or consequences of an accident previously evaluated.
L-98-130 Page 2 The proposed amendments are administrative in nature and do not involve a significant increase in the probability or consequences of any accident previously evaluated.
(2) Operation ofthe facility in accordance with the proposed amendments would not create the possibiTity of a new or difFerent kind of accident &om any accident previously evaluated.
The proposed amendments will not change the physical plant or modes of plant operation and therefore, will not create the possibility of a new or diFerent kind of accident from any accident previously evaluated. The proposed amendments will not result in the addition or modification of equipment for any systems, structures, or components at St. Lucie.
The proposed changes modify the controls on working hours for operating personnel without significantly changing the hours worked on a weekly or annual basis, and do not alter the current guidelines on the use of overtime. The changes are administrative in nature.
Consequently, operation of either unit in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any'accident previously evaluated.
(3) Operation of the faciTity in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
The proposed amendments'will delete the TS 6.2.2.f. requirement "...to have operating personnel work a normal 8-hour day, 40-hour week while the plant is operating." The proposed change will allow FPL to implement various controlled shift structures and durations during a nominal (36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week. The proposed changes will allow the use of up to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts without routine heavy use of overtime. The TS will continue to require the controls and guidelines for work hours to be contained in administrative procedures. This will result in fewer operating shift-to-shift turnovers per day and will allow more contiguous days ofFbetween work shifts. The net result of longer work shifts will be more rested crews with better communications between shifts.
The proposed changes do not alter the current guidelines on the use of overtime and will not alter the basis for any TS that is related to the establishment of, or maintenance of, a nuclear safety margin. Consequently, operation of St. Lucie Units 1 and 2 in accordance with the proposed amendments will not involve a significant reduction in a margin of safety.
Based on the above, FPL has determined that the proposed amendment request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2)
L-98-130 Page 3 create the possibility of a new or di6erent kind of accident from any accident previously evaluated, (3) involve a significant reduction in a margin of safety. Therefore the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 50.92.