ML18094B166

Application for Amends to Licenses DPR-70 & DPR-75, Consisting of Rev 3 to 890829 Request for Relief from Requirements of Tech Specs 6.2.2.g & 6.3.1 to Permit Individual to Assume Active Duties of Operations Manager

ML18094B166
Person / Time
Site:	Salem
Issue date:	11/14/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18094B167	List: ML18094B166 ML18094B168
References
NLR-N89210, NUDOCS 8911210231
Download: ML18094B166 (7)

Text

Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer NOV 1 4 1989 NLR-N89210 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

REQUEST FOR AMENDMENT, REVISION 3 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for' amendment of Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station, Unit Nos. 1 and 2 respectively. In accordance with 10CFR50.91 (b) (1) requirements, a copy of this request has been sent to the State of New Jersey.

On August 29, 1989, PSE&G submitted an Emergency License Change Request for temporary relief to the requirements of Technical Specification sections 6.2.2.g and 6.3.1. The request was submitted to permit a specific individual to assume the active duties of the Operations Manager, without currently holding a Senior Reactor Operator (SRO) license, for a period of 18 months.

Revision 1 to this License Change Request was transmitted on August 31, 1989, to clarify the time frame for the designated candidate obtaining a SRO license. Revision 2 was transmitted on October 11, 1989, to remove the "Emergency" status associated with previous versions of this request, and was a permanent change as opposed to temporary relief. Based on further discussions with Mr. J. Stone, the NRC Project Manager for Salem Generating Station, we are transmitting Revision 3 to this request. This revision removes two of the four previously requested alternative conditions for an individual to fill the position of Operations Manager, and clarifies one condition by specifying the type of "have held" license acceptable.

This revision also removes the previous reference to the (2)

Operating Engineers being assigned "one per each unit", since this limits our ability to implement short-term organizational changes. Some examples of anticipated situations that would not support unitized Operating Engineers are provided to illustrate our point.

( 8911210231 891114 PDR ADOCK 05000272 P PDC

Document Control Desk 2

• NOV 1 4 1989 NLR-N89210

1. While either Operating Engineer is attending Licensed Operator Requalification, the remaining Operating Engineer would be responsible for both Salem units.

2. During vacation periods, the remaining Operating Engineer would be responsible for both Salem units.

PSE&G intends to utilize unitized Operating Engineers to the fullest extent practical, but wants to retain the flexibility to alter our normal alignment as situations dictate.

PSE&G believes that the proposed change includes adequate technical justification to conclude that a detailed specialist review should not be required and that the proposed change can be classified as a category 2 change.

Attachment 1 includes a description, justification and significant hazards analysis for the proposed change. Attachment 2 contains the Technical Specification pages revised with pen and ink changes. Attachment 3 contains the Technical Specification pages with the changes incorporated.

This submittal includes one (1) signed original, including affidavit, and thirty seven (37) copies pursuant to 10CFRS0.4 (b)

(2) (ii).

Should you have any questions regarding this transmittal, please feel free to contact us.

Sincerely, Attachment

Document Control Desk 3 NOV 1 4 1989 NLR-N89210 C Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. W. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

REF: NLR-N89204 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

s. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated NOV 1 4 19S9 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me t:t1iis /'-/M day of 7}qy.f!n,/m , 1989 Lfi~7n 'LrA(lA/)~

• I-*

Notary Public of New Jersey Vt1t*l~Tt~ ~IL *r~1;":rji~ Et~ll NOTARY PUi'.iiJC OF 1-~EW JERSEY My Commission expires on My Commissioi1 Expires May 6, 1993

NLR-N89210 ATTACHMENT 1 LCR 89-11 PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I. Description of the Change Modify the present Technical Specification section 6.2.2.g to eliminate the Operations Manager as a position requiring a SRO license. Add a new Technical Specification section 6.2.2.h to specify the requirements for the Operations Manager.

II. Reason for the Change Provide flexibility in implementing future management changes.

III. Justification for the Change The Operations Department at Salem Generating Station is managed through an Operations Manager, (2) Operations Engineers and Shift Supervision. Technical Specifications presently require all of these individuals to hold a SRO license.

Current industry guidance on the selection, qualification and training of personnel for nuclear power plants (ANSI/ANS-3.1-1987), allows relaxation of the SRO license requirement for the Operations Manager position, provided certain conditions are met.

• This allows greater management flexibility while maintaining the high standards necessary to ensure safe and efficient operation of a nuclear power plant. PSE&G supports this philosophy and thus is requesting the enclosed license amendment.

An individual designated to fill the position of Operations Manager must satisfy one (1) of the following conditions:

(1) Hold a SRO license.

(2) Have held a SRO license for a similar unit (PWR).

These special requirements ensure that a selected candidate has demonstrated knowledge at the senior operator level, even though he may not hold a SRO license. Our present Operations Department Organization utilizes (2) Operating Engineers who are normally assigned the responsibility for overseeing the shift activities associated with a given Salem unit. Since the Operating Engineers are required to have a SRO license, the Operations Department licensed personnel (shift supervision and control room operators) are directly managed by an individual holding a SRO license.

Page 1 of 2 j

NLR-N89210 Based on the specified knowledge requirements to fill the position of Operations Manager, and maintaining SRO licensed Operating Engineers, PSE&G believes that approving this amendment request will not adversely affect the safe operation of the Salem Generating Station.

IV. Significant Hazards Consideration The proposed changes to the Technical Specifications:

1. Do not involve a significant increase in the.probability or consequence of an accident previously evaluated.

Any individual selected to fill .the Operations Manager position will meet current industry guidance on the selection, qualification and training of personnel for nuclear power plants, as specified in the Technical Specifications. These requirements ensure that any candidate has demonstrated knowledge at the senior operator level.

Therefore, it may be concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do not create the possibility of a new or different kind of accident from any previously evaluated.

The lack of a SRO license on the part of the Operations Manager, unlike a procedure or design change, is not a potential new accident precursor.

Therefore, it may be concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do not involve a significant reduction in a margin of safety.

The Operations Department licensed personnel (shift supervision and control room operators) will continue to be directly managed by an individual holding a SRO license (Operating Engineer).

Unlicensed candidates selected for the Operations Manager position must meet the education, experience and training requirements of ANSI NlB.1-1971 and have held a SRO license for a similar unit (PWR).

Therefore, it may be concluded that the proposed change does not involve a significant reduction in a margin of safety.

V. Conclusions Based on the information presented above, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.

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NLR-N89210 ATTACHMENT 2