ML18022A597
| ML18022A597 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/04/1988 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLS-87-283, NUDOCS 8801110533 | |
| Download: ML18022A597 (9) | |
Text
REGULA Y INFORMATION DISTRIBUTIO, YSTEM (RIDS)
ACCESS/ON NBR:880iii0533 DOC. DATE: 88/Oi/04 NOTARIZED: YES DOCKET 0 FACIL: 50-400 Shearon Harris Nuclear Poeer Planti Unit ii Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION EURYz L..W. Carolina Poeer 5 Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch <Document Control Desk)
SUBJECT:
Application for amend to License NPF-63'evising requirement in Tech Spec 6. 2 that manager operations hold senior reactor operator license. Significant hazards analysis encl.
Fee paid.
DISTRIBUTION CODE: M003D COPIES RECEIVED: LTR I ENCL 0 SIZE:
TITLE: Operator Requalification Program NOTES: Application for permit reneeal filed. 05000400 RECIPIENT COP IES REC IP IENT 'COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-i LA PD2-i PD BUCKLEY'S B INTERNAL: AEOD/DOA AEOD/DSP/TPAB NRR/DLPG/HFB NRR/DLPG/OLB E RQN2 EXTERNAL: LPDR NRC PDR NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR i2 ENCL
- J CALL Carolina Power 8 Ught Company P. O. Box 1551 ~ Raleigh, N. C. 27602 JAIL SERIAL
- NLS-87-283 10CFR 50 '0 LYNN W. EUAY Senior Vice President Operattons Support 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 SRO REQUIREMENTS FOR MANAGER OPERATIONS Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CPSL) hereby requests a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP). The proposed change revises the requirement in TS 6.2 that the Manager - Operations hold a Senior Reactor Operator (SRO) license. This requirement currently exists in Figure 6.2-2 and was included in our December 30, 1987 submittal as TS 6.2.2.e.
DISCUSSION The Harris Plant organization includes an Operations Supervisor who is the immediate supervisor of the individual Shift Foreman. The Operations Supervisor reports to the Manager Operations. This position provides an additional level of supervision between the Manager Operations and the Shift Foreman. There is no explicit requirement for this position in ANS 3.1 (September 1979 Draft) which is the governing standard for SHNPP. The existing SHNPP TSs currently require the Manager Operations and the Operations Supervisor to maintain Senior Reactor Operator (SRO) licenses.
Carolina Power 6 Light Company has reviewed this requirement, and determined that maintaining an SRO license is not necessary to fulfill the obligations of the Manager Operations. The Operations Supervisor will continue to hold an SRO license; however, the Company proposes to revise the TSs such that the Manager - Operations must: (1) hold an SRO license; (2) have at one time held an SRO license; or (3) meet the qualifications for plant managers specified in Section 4.2.1 of the September 1979 draft of ANS 3.1.
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Document Control Des NLS-87-283 / Page 2 Section 13.1.2.2.3.3 of the SHNPP PSAR provides the following description of the Manager - Operations responsibilities.
He (Manager Operations) is responsible for primary and secondary system performance and the timely completion of the scheduled periodic tests and for adherence to the requirements of the operating license and technical specifications. He is also responsible for coordinating and overseeing the duties of the Operating Supervisor assigned to the plant, the Radwaste Supervisor, and the Operations Support Supervisor. He is responsible for orderly and safe operations, turnovers, and compliance with operating instructions.
These responsibilities require a technically sound background, knowledge of nuclear plant operations, and a significant amount of time to administratively manage these functions. However, the in-depth, plant-specific knowledge which is demonstrated by maintaining an SRO is not required. The functions requiring such knowledge are performed by the Operations Supervisor. The Operations Supervisor is responsible for adherence to the requirements of the Operating License and Technical Specifications, scheduling and reviewing surveillance tests, reviewing operating data, logs and records, shift reports of equipment malfunctions or unusual system behavior, and initiating corrective action.
Much of the Manager Operations'ime must currently be dedicated to maintaining an SRO license. CP&L estimates that an average of 7 weeks each year are spent in classroom and simulator requalification and preparation for NRC testing required to maintain an SRO license. The Company believes that in the interest of nuclear safety this time would be better spent by the Manager Operations in the performance of his intended duties.
As an alternative to the current requirements, CP6L proposes that individuals holding the position of Manager Operations must: (1) hold an SRO license; (2) have at one time held an SRO license; or (3) meet the qualifications for plant managers specified in Section 4.2.1 of the September 1979 draft of ANS 3. 1, which states in part:
The plant manager shall have acquired the experience and equivalent training normally required to be eligible for a NRC Senior Operator license or hold such a license or have held such a license, or have been certified at a nuclear plant simulator for a similar unit (same NSSS) ~
Any of these three requirements would ensure that candidates for the Manager Operations position have the background and knowledge of nuclear plant operations necessary to perform the duties required by the position without unduly taxing the time that the Manager Operations can devote to these duties. The requirement for the Operations Supervisor to maintain an SRO license will remain. The combination of these two positions fulfills the guidance of the September 1979 draft of ANS 3.1 for the Operations Manager position.
In addition to the above benefit, the proposed revision would allow CPSL Management additional flexibility when choosing an individual to fill Manager Operations position. This ensures that the best available candidate the can be chosen for a vacant Manager Operations position. A major factor in
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Document Control Desk NLS-87-283 / Page 3 such a decision must currently be the status of the candidates'RO license.
Those individuals, whose SRO license is not current, require approximately 78 weeks of training to receive a valid SRO license. As such, it is conceivable that a more qualified person would be overlooked due to the need for filling a vacant Manager - Operations position.
SIGNIFICANT HAZARDS ANALYSIS The Commission has provided standards for determining whether a significant hazards consideration exists in 10CFR50. 2(c). 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 request and determined that:
- 1. The proposed change to the qualification requirements for the Manager Operations does not involve a significant increase in the probability or consequences of any accident previously evaluated because the change does not physically alter the facility in any manner and, as such, does not affect the means in which any safety-related system performs its intended safety function.
- 2. The proposed change to the qualification requirements for the Manager Operations does not create the possibility of a new or different kind of accident from any accident previously evaluated.
As stated in Item 1, there is no physical change to the plant resulting from the proposed amendment and, therefore, no possibility of creating a new accident.
- 3. The proposed change to the qualification requirements for the Manager Operations does not involve a significant reduction in a margin of safety. Two major benefits are derived from the proposed change. Alleviating the time which the Manager Operations is currently required to spend in classroom and simulator requalification and preparation for NRC testing required to maintain an SRO license allows him to dedicate that time to the performance of his intended duties. Requiring the Manager Operations to:
(1) hold an SRO license; (2) have at one time held an SRO license; or (3) meet the qualifications for plant managers specified in Section 4.2.1 of the September 1979 draft of ANS 3.1 ensures that candidates for the position have the background and knowledge of nuclear plant operations necessary to perform these duties.
Removing the requirement for the Manager Operations to have a valid SRO license would allow CP&L Management additional flexibility when choosing an individual to fill t'e Manager Operations position.
This ensures that the best available candidate can be chosen for a vacant Manager - Operations position. A major factor in such a decision must currently be the status of the candidates'RO licenses. Those individuals, whose SRO license is not current, require approximately 78 weeks of training to receive a valid SRO
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m Document Control Des NLS-87-283 / Page 4 license. As such, it is conceivable that a more qualified person would be overlooked due to the need for filling a vacant Manager Operations position.
The Operations Supervisor will continue to hold an SRO license. The combination of the Manager Operations and the Operations Supervisor positions at SHNPP fulfull the guidance of the September 1979 draft of ANS 3. 1 for the Operations Manager's position. The benefits derived from the proposed change, as discussed above, serve to enhance overall nuclear safety and, therefore, increase the margin of safety.
Based on the above reasoning, CPSL has determined that the proposed change to the qualification requirements for the Manager Operations does not involve a significant hazards consideration.
ADMINISTRATIVE INFORMATION The Company has evaluated this request in accordance with the provisions of 10CFR170.12 and determined that a license amendment application fee is required. A check for $ 150 is enclosed in payment of this fee.
Carolina Power 6 Light Company requests issuance of this amendment by February 12, 1988. Please refer questions regarding this matter to Sherwood R. Zimmerman at (919) 836-6242.
Yours very truly, L. W. Eur MAT/crs (S3S4MAT)
Enclosure CGA Mr. B. C. Buckley Dr. J. Nelson Grace Mr. G. F. Maxwell Mr. D. H. Brown L. W. Eury, 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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