ML20029B173
| ML20029B173 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/25/1991 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20029B172 | List: |
| References | |
| NUDOCS 9103060083 | |
| Download: ML20029B173 (8) | |
Text
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UNITED STATES NUCLPAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR CENERATING PIANT DOCKET NO. 50 282 50 306 REQUEST TOR AMENDMENT '10 OPERATING LICENSES DPR 42 6 DPR 60 LICENSE AMENDMENT REQUEST DATED FEBRUARY 25, 1991 Northern States Power Company, a Minnesota corporation, requests autnorization for changes to Appendix A of the irairie Island Operating License as shown on the attachments labeled Exhibits A, B,
and C, Exhibit A describes the proposed changes, reasons for the changes, and a significant hazards evaluation. Exhibit B contains current Praitie Island Technical Specification pages marked up to show the proposed changes.
Exhibit C contains the revised Technical Specification a
pages.
This letter contains no restricted or other defense information.
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, Thomas
'arker Manager, Nuclear Support Services
-On this.# 5rlday of
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/p4/before me a notary public in and for said County, personally appeare(TThomas M Parker, Ma_ nager, Nuclear Support Serviccu, and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Nortbarn States Power Company, that he knows the contents thoreof, and that to the best of his knowledge, informatlon, and belief the statements made in it are true and that it is not interposed for delay.
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3 Exhib'.t A i.
Prairie Island Nuclear Cencrating plant License Amendment Request Dated February 25, 1991 Ivaluation of Proposed Changes to the Technical-Specifications Appendix A of Operating License DPR 42 and DPR 60 Pursuant to 10 CFR Part 50, Sections 50.59 and 50.90, the holders of Operating Licenses DPR 42 and DPR 60 hereby propose the following changes to Appendix A, Technical Specifications:
1.
Remove Corr. orate and Plant Ornanizational Charts L
Prooosed Changes i
Remove the corporate and plant organizational charts, Figures 6.1-1 and 6.1 2, from the Technical Specifications as shown in Exhibit B, pages TS.6.1 1, TS.6.1 2, rigure TS.6.1-1, and Figure TS.6.1 2.
Add new Specifications which capture the essential requirements for the organizational structure as shown in Exhibit B, pages TS.6.1 1. TS.6.1 2, and Inserts A and B, Additionally, certain titles in Section 6 have been renamed to correspond with more generically used terminology.
These are shown in Exhibit B pages TS.6.1 1. TS.6.1-2, TS.6.1 1 TS.6.2 1, TS.6.2 3,
'TS.6.2-4, TS.6.2 6. TS.6.4 1, TS.6.5 4, and TS 6.7 5.
Clarify the person designated as performing the Shift Technical Advisor functions as shown lo Exhibit-B, pages TS.6.1-2 and Table TS.6.1 1, 4
In addition, identified typographical errors on the above pages are corrected as shown in Exhibit B.
Reasons for Changes-Generic Letter 88 06 dated March 22, 1988 entitled, "Reinoval of Organizational Charts from Technical Specifications Administrative Control Requirementa" states, "The staf f has determined that with the appropriate changes to these administrative control requirements, the onsite and offsite orbanizational charts may be removed."
This License Amendment Request would delete the corporate and plant torganizational charts from the_ Technical Specifications and add now SpecificationsLthat capture the essential aspects of the organizational structure. The new Specifications are modeled after the " Markup of Westinghouse Standard Technical Specifications", Enclosure 2 to Generic Letter 88 06, The referenced title changes-to more generically _used nomenclature are proposed in order;to allow personnel' title changes without requiring changes to the Technical Specifications.
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The " Shift iechnical Advisor" no longer identifies a position at prairie Island; the functions of the " Shift Technical Advisor' are performed by the shift mana6ers. The Specifications are being changed to reflect this.
?
Safety Evduation and Deter;gination of SignillecJit Harnrds Considerations The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 10_CPR part 50, Section 50.91 using the standards provided in Section 50.92.
This analysis is provided below:
j_
- 1. The proposed amendment will not involve a significant increase in the p_rphability or consecuences of an accident previousiv evnluated.
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The NRC staff has found that the roplacement of organizational charts with appropriate admitiistrative control requirements of Generic Letter 88 06 is a desirable administrative change.
The Prairic Island proposed Technical Specifications are modeled after Enclosure 2 to Generic Letter 88 06.
Therefore the proposed changes are in conformance with NRC Staff requirements.
The important organizational features depicted on organizational charts are also required or controlled by other regulatory-control mechanisms.
In particul
- t. NSp's Operational Quality Assurance plan is required by 10 CFR 50, Appendix B to-include'similar information related to the organizational structure.
The Operational Quality Assurance plan, in 4-fact, develops the organizationr.1 structure in greater detail than the
-Technical Specifications and changes made to the plan are submitted to the NRC St least annually. These changes to the.echnical Specifications do not constitute any cht.nge in t.he snanner in which the plant is operated or maintained.
The corrections of the typographical errors do not change the meaning of the specifications.
Therefore, these administrative changes have no effect on the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a nov or different kind of accisitta from any,2ccident previous 1v annivred_.
As stated above, the proposed change vill not cause a change in the way E
in which the plant is operated or maintained. Therefore, theso administrative changes will not create the possibility of a new or different kind of accident from any-accident previously analyzed.
- 3. The proposed amendment will not. involve a significant reduction in the marr.in of safety.
-As stated above, the proposed change vill not cause a chango in the way in which the plant is operated or maintained.
Therefore, theso
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j tahlblt A Pa,e 3 of 7 administrative changes will not involve a significant reduction in the margin of safety.
1 The Commis6 ion has provided guidance (March 6, 1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists.
The guidance provides certain examples of amendments that will likely be found to involve no significant hazards considerations.
The changes to tne Prairie Island Technical Specifications proposed in this amendment request are representative of NRC example (1): because they are a purely administrative change. There is no change to the physical configuration of the plant or how the plant is operated.
Based on this guidanca and the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
Environmental Assesmagni
.These proposed changes will not_ change effluent types or total effluent amounts nor will they involve an increase in power level.
Therefore, they will not result in any significant environmental impact.
2
- 2.
Qp entions Committee Membershin Recutrements e
Pronosed Changes Change the words in the first sentence contained in Technical Specification 6.2.B.1, " Membership" from "... at least six (6) members... "
to "... at least six (6) regular members Add three now sentences after the first sentence of Technical Specification-6.2.B.1, " Membership" which read "The key supervisors include, at Icast, the following positions:
plant manager, operations manager, maintenance manager, radiation protection manager, and
. engineering supervisors. Alternates to the regular members shall be designated in writing by the Chairman to serve on a temporary basis.
No more than two alternates shall participate as voting members of the Operations-Committee at any one time."
Change the words in the last sentence contained in Technical Specification 6.2.B.1, " Membership";from "... appoint a Vice Chairman from the OC membership to-act in his absence." to "... appoint a regular member to act as Chairman in his: absence."-
Change the words in the sentence contained in Technical-Specification-6.2,B.3, ? Quorum" from "A majority of the permanent members... " to "A
- majority of the. membership..... "
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tahlblt A Page 4 of 7 4
l Reasons for Chances The Prairie Island Technical Specifications currently do not address the use of alternates on the Operations Committee in meeting the quorum requirement. The time demand for the multiple responsibilities of the individuals who make op the regular membership of the Operations Committee is heavy.
The need for flexibility in meeting this requirement was recognized in the development of the Standard Technical Specifications and was addressed by the use of alternates. This change is being submitted to allow the use of alternates and maintain the flexibility necessary for day to day operation of the plant.
Under this change the term " members" will be defined as the positions which make up the Operations Committee with the regular membera beir.g the individuals who normally fill those positions.
The key supervisors from i
which the members are drawn are listed because they will no longer be shown on the organization chart which is bed.ng removed as discussed earlier in this License Amendment Request. Alternates are defined as member-positions filled by anyone other than the regular member. To allow flexibility in meeting the quorum requirement a simple majority of the membership is required, including the Chairman.
No more than two alternates can participate as voting members of the Operations Committee at any one time.
Safety Evaluq11on and Determir.ation of Significant Hazards Considerations The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 10 CFR Part 50, Section 50.91_using the standards provided in Section 50.92. _This analysis'is provided below:
- 1. The proposed amendment will not involve a significant increase in-the probabili.ty or conscouences of an accident previous 1v evaluated.
The review function of the Operations Committee is not effectively-diminished by the proposed change.
During the early days of plant life, expertise resided in fewer people and it was important that the
. Operations Committee membership be more tightly controlled.
Currently, the plant staff has' accumulated expertise through almost 20 years of operating experience such that thern is a large pool of personnel qualified to perform the Operations smmittee review functions.
Therefore, utilizing alternate Operations Committee members will not involve a significant_ increase in the cubability or consequences of an accident previously evaluated, 2._ The proposed amendment will not create the possibility of a new or different kind of accident from any p ident previcualv annivzed.
As stated above, the proposed change will not cause a decline in the effectiveness of the operationo-Committee reviews and, thus, wJli not affect the physical configuration of the plant or how it is operated.
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(nhibit A Vege b et i Therefore, it will not create the possibility of a new or different j
kind of accident from any accident previously analyzed.
- 3. The proposed anendment will not involve a significant reduction in tho
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nargin of safety.
As stated above, the proposed change will not cause a decline in the effectiveness of the Operations Committee reviews and, thus, will not affect the physical configuration of the plant or how it is operated.
Therefore, it will not involve a significant reduction in the margin of safety.
1 The Commission has provided guiaance (March 6, 1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists. The guidanca provides certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairic Island Technical Specifications proposed-in this amendment request are representative of NRC example (1): because they are a purely administrative chanCs.
There is no change to the physical configuration i
of the plant _or how the plant is operated.
Based on this guidance and the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
Environmental Assessment These proposed changes will not change effluent types or to?.a1 effluent amounts nor will they involve an increase'in power level. Therefore, they will not result in any significant environmental impact.
-3.
, Changes in Vorking Hour Limitations Proposed Changes Prairio Island Technical Specification 6.1.F.1_ presently states, in part,-
-"The objective shall be 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". As shown in Exhibit B,-
the proposed license amendment would change this sentence to read, "The objective shall be to have operating personnel work a nominal 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".
Reason For Changes-The-proposed changes would eliminate the reference to sui 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day, thereby providing for more flexible shif t schedules, with normal shif t durations of up_to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Rather'than provide specific limits on the number of hours in a normal work day, the proposed changes specify that the objective is to have personnel work a nominal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week.
Other
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!aMbit A Pope 6 of 7 provisions of specification 6.1.F regarding overtime, maximum shift lengths and minimum break time between work periods remain unchanged.
e The objective of the statement in specification 6.1.F.1 on " normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> days" is to provide assurance that adequate shift coverage is maintained without routine heavy use of overtime.
Because the proposed changes do not change the intent of the existing specification with respect to the number of hours which shoald be normally worked per week, specification 1.F.1 vill continue to provide adequate assurance that routine heavy use
- c. overtime will not be required.
S a fe ty Evaluntion and Deterninntion of Strnificant linrardt Considerations The proposed changes to the. Operating License have been ovaluated to determine whether they constitute a significant hazards consideration as required by 10 CPR Part 50, Section 50.91 usin6 the standards provided in
- Section 50.92. This analysis is provided below:
l' The: proposed amendment will not involve a significant increase in the probability or consecuences of an accident prevlongly evnlusted.
The proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated because:
- a. The proposed changes are administrative in nature,
- b. The proposed changes do not change the intent of the existing specification and continue to provide adequate assurance that routine heavy use of overtime will not be necessary to provide adequate shift coverage, and
- c. Because tha other provisions of specification 6.1.P regarding overtime, maximum shift lengths and minimum. break time between work j
l periods remain unchanged.
2, The proposed amendment will not create the-possibility of a new or different kind of accident from any accident oreviousiv annivred,_
1he proposed changes are administrative in nature and only affect normal shift durations.
No safety.related equipment, safety function, er plant-operations will be altered as a result of the proposed changes. Therefore, the proposed amendment does not in any way eteate the possibility of a new or different kind of accident from any accident previcusly evaluated.
- 3. The proposed amendment will not involve a significant reduction.in the mnrrin of-safety.
The margin of safety provided by the current Technical Specifications
. remains unchanged. The removal of administrative Technical
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l Inhibit A Page 7 of ?
Specification limits on the number of hours in a normal work day will not affect the margin of Safety because the proposed changes do not change the intent of the Technical Specifications with respect to the aumber of hours which should be worked per wenk. The Technical Specifications will continue to provide adequate assurance that routine heavy use of overtime will not be required, j
a The Comroission has provided guidance concerning the application of the standards in 10 CPR 50.92 for determining whether a significant hazards consideration exists by providing cestain exampics of amendments that will likely be found to involve no significant hazards considerations. These examples were published in the Federal Register on March 6. 1986.
The changes to the Prairie Island Technical Specifications proposed in j
this amendment request are equivalent to NRC example (1). because they involve purely administrative changes to the Technical Specifications.
Based on this guidance and the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
f Environmental Assessment-This license amendment request does not change effluent types or total 3
effluent amounts nor does it involve an increase in power level.
- Therefore, this change will not result in any significant environmental
- impact, t
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