ML18052B528

Proposed Tech Specs Re Limitations on Overtime Work by Plant Staff Performing safety-related Functions Per Generic Ltr 82-12

ML18052B528
Person / Time
Site:	Browns Ferry
Issue date:	11/05/1985
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18052B527	List: ML18052B526 ML18052B528
References
GL-82-12, TVA-BFNP-TS-214, NUDOCS 8511180418
Download: ML18052B528 (9)

Text

ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION REVISIONS BROWNS FERRY NUCLEAR PLANT as11100410 a~Al,8~59

~DR ADOCI'.. 0 --*

PDR..

UNITS 1, 2, AND 3 (TVA BFNP TS 214)

PROPOSED CHANGES UNIT 1

UNIT 1

~**..

6.0 ApliI~ISTRJ\\TIVE COtn'ROLS 6.l Pr0<;edures A.

Detailed.written proced11re2, including applicable check-off lists covering items listed below ahall be prepared, approved and adhered to.

1.

Normal startup, operation and shutdOoln of the reactor and of all syste~s and components involving

. nuclear safety of the facility.

2.

Refueling operations.

3.

Actions to be taken to* correct specific and foreseen potential malfunctions of systelJ\\S or components, including responses to alarms, suspected primary system leaks and abnormal reactivity changes.

Q.

Emergency conditions involving potential or actual release of Radioactivity.

S.

Preventive or corrective mainten.c\\nce operat.ionR which could have an effect on the' safety *of the reactor.

6.

7.

e.

. 9.

\\ ;o.

11.

Surveillance and testing requ~rements.

Radiation control procedures.

Radiol0gical Emergency Plan implementing procedures.

Plant security program implen1enting procedures *

.. Fir*e* protection and* prevention procedures.'*

Llmitations on the aroount of overtine worked by indi vi.duals performing safety-related functions in accordance with the NRC policy statenEI'lt on working hours (Generic Letter No. 82-12).

B.

Written procedures pertaining to thoee items liat.e~

above shall be rcvie~ed by PORC and approved by t.he plant _auperi_ntendent prior to _iinpl_ell~nt.a~on *. Temporary changes to a procedures which do not change the intent of the approved procedu::e r:.ay be rnade by a :ne:nbe:: of the plant staff knowledgeable in the a::ca ~f~eC-CGc by the procedure except. that tf;':nporary ch&llgeo to t.t.oae iteo.s listed csbov-c except itcr:l s.. require: the a~ci-:!.cnal approval of a tnf'::tber of t.t11~ plant ato~f who !":olds a Sen.!.or Reactor Oj><?::at.or l~ccnoe on the ur.it affeC".:ed.

SUch changes !'~.al: t.e c.:>c-.. :.;ner.-:.-?c cl~G S\\1bS1?0\\le:-itj,.*1 rev!ewed by ?ORC anc a;?p::-ovec by tr.e f)la~

• oupe::intendcn--:..

33$

• o

PROPOSED CHANGES UNIT 2

UNIT 2

~**..

6.0 AQMI?tISTAATIVE CONTROLS 6.3 Pr0<;edures A.

Detailed written procedures, including applicable check-off lists covering items listed below ahall be prepared, approved and adhered to.

1.

Normal startup, operation and strutdOoln of the reactor and of all systems and components involving nuclear safety of the facility.

2.

Refueling operations.

3.

Actions to be taken to correct specific and foreseen potential malfunctions of systeD\\B or components, including responses to alar~e, suspected primary system leaks and abnormal reactivity changes.

Q.

Emergency conditions involving potential or actual release of Radioactivity.

s.

Preventive or corrective malnte~1nce operationR which could have an effect on the*aafety of the reactor.

6 *.

1.

e.

9.

i o.

11.

Surveillance and ~eating requ~rements.

Radiation control procedures.

Radiological Emergency Plan implementing procedures.

Plant security program impleo1enting procedures.

Yi re protecti.on. and. pre_ve~tion proc:edu.res.

Llmitations on the armunt of overtine worked by individuals perfonning safety-related functions in accordance with the NRC policy staterrent on working hours (Generic letter No~ 82-12).

B.

Written procedures pert3in1ng to those items liat.e~

above shall be rcvie'fed by PORC and approved by t.he plant euperintendent prior to iinpleJientation.

Temporary changes to a procedures \\.lhich do not chaD::}e ~he intent of the approved procedu::-e r:ay be rnade by a :n~e: of t.he plant staff knowledgeable in the a=ea ~f:eci:6c by the

• procedure except that tt-:nporary cha11geo to tt.oee ite~

liated above except itcr:i 5*. requi.r<: the a~ci-::.!.cnal approval of a Dlf'::\\be: of tli1~ plant ata!f "'ho holde a Sen!or Reactor O?<?=at.or l::.ccnoe on the ur.it a!!ec-~ed.

SUch changes !>!".al1 :-.e c.:>c-.. :..:ne:r.":.<?G a:-.c S\\lbSO?que:1t~:.'

rev!ewed by ?ORC anc ll?p::ovec by the £)l.c.:r-oupe:: intendcn-;.

33S

PROPOSED CHANGES UNIT 3

J t' I

'UNIT 3 6.J Proccedures Detailed written procedures, including applicable check-off lists covering items listed below shall be prepared, approved and adhered to.

1.

Nonnal startup, operation and shutd°'1rn of the reactor and of all systems and components involving nuclear safety of the facility.

2.

Refueling operations.

3.

Actions to be taken to correct specific and foreseen potential malfunctions of systems or components,, including responses to alarms, suspected primary system leaks and abnormal reactivity changes.

4.

El'l\\er9ency conditions involving potential or actua1

s.

6.

7.

e.

9.

10.

11.

relea~ of Radioactivity.

Preventive or corrective maintenance operations which could have an effect on the safety of the reactor.

Surveil:lance and teating requirements.

Radiation control procedures.

Radiological Pmerqency Plan implementing procedures.

i;>~anit securi~y pr.ogra~_ implementing procedures.

l"ir! protection and prevention procedures.

I.imitations on the arrount of overtirre worked by individuals perfonrring safety-related functions in accordance with the NRG policy staterrent on working hours (Generic letter No. 82-12).

B.

Written procedures pert~in1ng to those items listed above shall be revie-..ed by PO.RC and approved by the plant superintendent prior to iirrpleJ\\entation.

Temporary changes to a procedures which do not change the intent of the approved procedu=e ~ay be made by a :ne.:nbe: of the plant etaff knowledgeable in the a~ea ~f:ec.-c6c by the

• procedure except. that t~:nporary changes to tJ-,ose ite"-8 listed above except item s,, require: the acci-::.icnal approval of a lllE-::\\be:: of t.h*~: plant ata!f 1o1ho t.olda a Senior ReactD~ OjY.?:-a~or l~cenoe on the ur~t affeC":ed.

SUc!l changes

~!-.al: be c.Jc-.:.:ner.~~c a:-.c s\\IDSi:!crue:it~*,

rev!.ewe<l by ?O.RC anc a;:ip::-ovec by the ;:>!.a:1e.

oupe:-1nt enden~.

368

~

1, ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION TVA BFNP TS 214-BROWNS FERRY NUCLEAR PLANT Pages 338 of units 1 and 2 and page 368 of unit 3 technical specifications were revised to add 6.3.A.11.

This specification requires written administrative instruction to limit personnel overtime in accordance with the NRC policy statement on working hours (Generic Letter 82-12).

NRC Generic Letter 82-12 dated June 15, 1982 provided guidance on limiting working hours of nuclear power plant staffs.

The generic letter forwarded as an enclosure, "Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In Generic Letter 83-02 dated January 10, 1983, the staff provided clarification on what constituted an acceptable specification.

The proposed specifications provided in enclosure 1 are in accordance with Generic Letter 83-02.

These specifications respond to NRC letter from D. B. Vassallo to H. G. Parris dated July 26, 1985.

In addition to inclusion of this proposed additional technical specification, the procedure g?Venling plant staff working hours was revised to include key maintenance personnel, in accordance with NRC Generic Letter 83-14, dated March 7, 1983.

...,,,,~

ENCLOSURE 3 DETERMINATION OF NO SIGNIFICANT HAZARDS

(-TVA BFNP TS-214)

Description of Proposed Changes to Technical Specifications This proposed change is addition of a reference to a procedure on limiting the_ amount of overtime worked by plant staff.

The procedure limits are to be in accordance with the NRC policy statement on working hours (Generic-Letter 82-12).

Basis for Proposed No Significant Hazards Consideration This proposed change affects the administrative method of implementing the overtime restrictions on nuclear plant staff, i.e., the previously existing procedure on overtime is now referenced in the technical specifications.

Also, the procedure was revised to increase its scope regarding personnel covered by the procedure, i.e., the procedure now covers "key maintenance personnel" as discussed in NRC Generic Letter *83-14 dated March 7, 1983.

Because the proposed technical specification changes would only affect administrati~e implementation of shift overtime pollcy, we have concluded that (1) the probability or consequences of previously analyzed accidents would not be increased; (2) the possibility of a new accident would not be created; and (3) no margin of safety will be decreased.

Accordingly, TVA proposes to determine that the requested technicai specifications will involve no significant hazards consideration.