ML18010B056

Application for Amend to License NPF-63,revising TS 6.4 Re Initial & Requalification Training for Licensed Personnel to Allow Training Program to Be Based on GL 87-07

ML18010B056
Person / Time
Site:	Harris
Issue date:	03/04/1993
From:	Starkey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18010B057	List: ML18010B056 ML18010B058
References
GL-87-07, GL-87-7, NLS-93-024, NLS-93-24, NUDOCS 9303100249
Download: ML18010B056 (12)

Text

ACCEI ERA DOCUMENT DIST UTION SYSTEM REGULA INFORMATION DISTRIBUTIO YSTEM (RIDS)

)r ACCESSION NBR:9303100249 DOC.DATE: 93/03/04 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION STARKEY,R.B. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-63,revising TS 6.4 re initial requalification traning for licensed personnel to l

6 allow training program to be based on GL 87-07.

DZSTRZBUTZON CODE: ROOZD COPZES RECEZVED:LTR L ENCL SZSE: 8~~

TITLE: OR Submittal: General Distribution NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT. COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 LE,N '2 2 INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 . 1 NRR/DSSA/SCSB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 O~CQZHB 1 0 OGC/HDS1 1 0 EG FZ 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK,-

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20

"0 CplLL Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602

,ea 04: m83 R. B. STARKEY, JR. SERIAL: NLS-93-024 Vice President Nuctear Services Oepartment 10 CFR 50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO NPF-63 REQUEST FOR LICENSE AMENDMENT TRAINING Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2 101 r Carolina Power & Light Company (CP&L) hereby requests a revision to the

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Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP). The proposed amendment revises Technical Specification 6.4 concerning the initial and requalification training for licensed personnel.

Specifically, the proposed change would allow the training program to be based on a systematic approach to training as permitted by 10 CFR 55.31, 10 CFR 55.59, and NRC Generic Letter 87-07.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides page change instructions for incorporating the proposed revisions.

Enclosure 5 provides the proposed Technical Specification pages.

In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina with a copy of the proposed license amendment.

090108 9303200249 930304 PDR ADOCK 05000400 (1899HNP )

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Document Control De~

NLS-93-024 / Page 2~

In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CPGL requests that the proposed amendment, once approved by the NRCi be issued such that implementation will occur within 60 days of issuance of the amendment.

Please refer any questions regarding this submittal to Mr. R. W. Prunty at (919) 546-7318.

Yours very truly, R. B. Starkey, Jr.

LSR/jbw

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Environmental Considerations

4. Page Change Instructions

5. Technical Specification Pages cc: Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. N. B. Le Mr. J. E. Tedrow R. B. Starkey, Jr., having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power 6 Light Company.

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ENCLOSU TO SERIAL: NLS-93-024 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TRAINING BASIS FOR CHANGE RE VEST Backcaeound NRC Generic Letter 87-07, dated March 19, 1987, transmitted information to licensees concerning Final Rulemaking for Revisions to Operator Licensing.

The revisions affected both initial license and requalification training for operators and allowed the substitution of an accredited training program in lieu of training programs previously approved by the NRC. Such a substitution could be implemented upon written notification to the NRC and did not require any NRC staff review. The Generic Letter also noted that the training program description described in the FSAR need not be amended until the next update required by 10 CFR 50.71(e).

By letter dated May 24, 1988, CPQL notified the NRC that the initial and requalification training programs for operators, as required by 10 CFR 55.31(a) and 10 CFR 55.59(c), were accredited and based on a systematic approach to training. SHNPP FSAR Section 13.2.1.1.2 was revised accordingly; however, Technical Specification 6.4, which required conformance to the NRC letter of March 28, 1980, was not revised. As a result, CPGL has been satisfying two different guidelines. NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 .on Operators'icenses," dated November 1, 1987 (Question No. 98, Page 23) states that "[there) are a number of facilities that have a more restrictive requirement in their Technical Specifications than that for which they would have to apply; amending their Technical Specifications to obtain relief is p'ermitted under the rule. It would be an administrative change in order to conform with the regulation."

Pro osed Chan e The proposed Technical Specification change would allow the initial and requalification training program for licensed personnel to be based on a systematic approach to training as permitted by 10 CFR 55.31, 10 CFR 55.59'nd NRC Generic Letter 87-07.

Basis This revision to the Shearon Harris Nuclear Power Plant (SHNPP) training requirements has no relevance to any Final Safety Analysis Report (FSAR)

Chapter 15 accident initiators; therefore, no increase in the probability of such accidents would occur. The proposed administrative change does not involve any modifications to plant equipment and therefore does not affect other equipment that could initiate an accident. Further, no new procedures are being created and no existing procedures are being modified. Therefore, the proposed change does not increase the consequences of an accident previously evaluated, will not increase the probability or consequences of an equipment malfunction previously evaluated in the FSAR, and will not create (1899HHP)

ENCLOSU TO SERIAL: NLS-93-024 Page 2 of 2 the possibility of a new or different kind of accident from an accident previously evaluated. Accordingly, the proposed change would not result in a reduction in the margin of safety as defined in the Technical Specifications.

Conclusions The proposed change simply revises the Technical Specifications to be consistent with the FSAR, as permitted by NUREG-1262. This change is purely administrative in nature and does not constitute an unreviewed safety question.

(1899HNP)

0'NCLOSU TO SERIAL: NLS-93-024 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO, 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TRAINING 10 CFR 50 92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation 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, (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. Carolina Power 6 Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:

Pro osed Chan e The proposed Technical Specification change would allow the initial and requalification training program for licensed personnel to be based on a systematic approach to training as permitted by 10 CFR 55.31, 10 CFR 55.59, and NRC Generic Letter 87-07.

Basis This change does not involve a significant hazards consideration for the following reasons:

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

This administrative change to Technical Specification 6.4 has no affect on equipment, procedures, or accident initiators. Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Since this is an administrative change, there are no modifications or additions to plant equipment. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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ENCLOSU TO SERIAL: NLS-93-024 Page 2 of 2 The proposed amendment does not involve a significant reduction in the margin of safety.

The proposed change does not affect any parameters which relate to the margin of safety as defined in the Technical Specifications. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

ENCLOSU TO SERIAL: NLS-93-024 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TRAINING ENVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site; (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power 6 Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e The proposed Technical Specification change would allow the initial and requalification training program for licensed personnel to be based on a systematic approach to training as permitted by 10 CFR 55.31, 10 CFR 55.59, and NRC Generic Letter 87-07.

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1~ As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2~ The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site.

The proposed amendment does not introduce any new equipment, nor does it require existing systems to perform a different type of function than they are currently designed to perform. As such, the change can not affect the types or amounts of any effluents that may be released off-site.

ENCLOSU TO SERIAL: NLS-93-024 Page 2 of 2 The proposed amendment does not result in an increase in individual or cumulative occupational .radiation exposure.

The proposed change does not result in changes to Technical Specification surveillance requirements and does not affect personnel radiation exposure. Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

(1899HHP)