ML20045H861
| ML20045H861 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/15/1993 |
| From: | Rosenblum R, Shotwell J SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML20045H854 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-1432, RTR-NUREG-737 GL-82-16, NUDOCS 9307220028 | |
| Download: ML20045H861 (14) | |
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{{#Wiki_filter:+,4- - p 'k ' g ' E ENCLOSURE 1 PCN-428 PROPOSED CHANGES TO UNIT 2 LICENSE CONDITION 2.C.(19)b - AND UNITS 2 AND 3 TECHNICAL SPECIFICATIONS 6.2.2.f-j
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A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA ) Docket No. 50-361 EDISON COMPANY, ET AL. for a Class 103 )' License to Acquire, Possess, and Use ) a Utilization Facility as Part of ) Amendment Application Unit No. 2 of the San Onofre Nuclear ) No. 133 ; Generating Station ) ! SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 133. 1 This amendment application consists of Proposed Change Number (PCN)-428 to Facility Operating License No. NPF-10. PCN-428 is a request to delete Unit 2_ l License Condition 2.C.(19)b, " Shift Manning (I.A.1.3, SSER #1, SSER #5)," and ; l replace this License Condition with a new shift manning Technical Specification (TS) 6.2.2.f. The proposed TS 6.2.2.f is based on NUREG-1432_ I (Combustion Engineering Owners Group Standard Technical Specifications), dated ) September 28, 1992, and the model TS provided in Enclosure 2 of Generic Letter J (GL) 82-16, "NUREG-0737 Technical Specifications." l l i 1 R 1
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Subscribed on this /5 M day of JetLV ,1993. Respectfully. submitted,- SOUTHERN CALIFORNIA EDISON COMPANY ' y By: 74 / R. M. Rosenblum Vice President State of California l} l9 before me, BM8 Area A. NC CAATHYfAlWAAY perschally appeared J7/r#MB M. h5 Met uM i Personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument. WITNESS my hand and official seal. ___ 0 Signature AlstA u k - - BARBATA AR l l Notory PubRc Californio . ORANGE COUNTY h4 Commlulon Edes . Much SL 1996 I James P.-Scott Shotwell Attorney for Southern Californi Edison Company By: .
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ames P. Scott Sh6twell
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UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION
-Application of SOUTHERN CALIFORNIA ) Docket No. 50-362 EDISON COMPANY, ET AL. for a Class 103 )
License to Acquire, Possess, and Use ) , a Utilization Facility as Part of Amendment Application , Unit No. 3 of the San Onofre Nuclear No. 117 Generating Station , SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 117. - This amendment application consists of Proposed Change Number (PCN)-428.to Facility Operating License No. NPF-15. PCN-428 is a request to revise Unit 3 Technical Specification 6.2.2.f based on NUREG-1432 (Combustion Engineering-Owners Group Standard Technical Specifications), dated September 28, 1992, and_ i the model TS:provided in Enclosure 2 of Generic Letter (GL) 82-16, "NUREG-0737f Technical Specifications." . [ r
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Subscribed on this /8E day of ,1993. JtAL[ ; Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By: ~ M R. M. Rosenbluni Vice President State of California . of Orange gy aguGp County On 7 //5/93 before me, 3MB/)4A A, //C(WATNV// , persdnally appeared Pfi-N/1Lb M Tc3rrrBt.u M , persdnally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, , and that by'his signature on the instrument the person, or the entity upon s behalf of which the person acted, executed the instrument. WITNESS my hand and official seal. Signature W N. E 6 f s' OmCIAL SEAL BARBARA A. MC CARTHY k Notary Pubic-Coilfornia l ORANGE COUMY Much _-_ 1996 l James P. Scott Shotwell Attorney for Southern- 1 California Edison Company I
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l DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-428 I 1 PCN-428 is a. request to 1) delete Unit 2 License Condition 2.C.(19)b, " Shift Manning (I.A.1.3, SSER #1, SSER #5)," 2) replace this Unit 2 License Condition -{ with a new Unit 2 shift manning Technical Specification (TS) 6.2.2.f, and 3)~ ! revise Unit 3 TS 6.2.2.f. , Existino License Condition Attachment A - Existing License Condition, Unit 2 - Existino Specifications Attachment B - Existing Specifications, Unit 2 , Attachment C - Existing Specifications, Unit 3 Proposed License Condition Attachment D - Proposed License Condition, Unit 2 Proposed Specifications Attachment E - Proposed Specifications, Unit 2 Attachment F - Proposed Specifications, Unit 3 -; DESCRIPTION CHANGES TO LICENSE CONDITION 2.C.(19)b FOR UNIT 2 Unit 2 Facility Operating License Condition 2.C.(19)b, " Shift Manning (I.A.1.3, SSER #1, SSER #5)," is deleted. The shift manning requirement for Unit 2 is proposed as a new TS 6.2.2.f. CHANGES TO TS SECTION 6.2.2.f A new TS 6.2.2.f is proposed for Unit 2 and-TS 6.2.2.f is revised for Unit 3. TS 6.2.2.f is proposed for Unit 2 to make the location of the shift manning requirement consistent'with Unit 3. The proposed TS 6.2.2.f for both Units 2 and 3 is based on NUREG-1432 (Combustion Engineering Owners Group Standard Technical Specifications) dated September 28, 1992, and the model TS provided in Enclosure 2 of Generic Letter (GL) 82-16, "NUREG-0737 Technical Specifications." DISCUSSION CHANGES TO LICENSE CONDITION 2.C.(19)b FOR UNIT 2 Unit 2 Facility Operating License Condition 2.C.(19)b, " Shift Manning * (I.A.1.3, SSER #1, SSER #5)," is deleted because the shift manning requirement is proposed to be in the administrative controls section of the Unit 2 TSs as 1
TS 6.2.2.f. This change _also makes the Unit 2 TSs consistent with the Unit'3 TSs. CHANGES TO TS SECTION 6.2.2.f Unlike the Unit 3 TSs where the shift manning requirement is in the administrative-controls section of the TSs (TS 6.2.2.f), the Unit 2 shift manning requirement is in the' Low Power Operating-License as' License Condition 2.C.(19)b. To make the. location of the Unit 2' shift manning requirements consistent with the Unit 3 TSs, this proposed change deletes the Unit 2 - - License Condition 2.C.(19)b and adds TS 6.2.2.f to the Unit 2 TSs. This change also revises the existing Unit 3 TS 6.2.2.f to be consistent with the proposed Unit 2 TS 6.2.2.f. The proposed TS 6.2.2.f for both Units 2 and 3 is based on NUREG-1432 (Combustion Engineering Owners Group Standard Technical' Specifications) dated - September 28, 1992, and the model TS provided in Enclosure 2 of Generic Letter (GL) 82-16, "NUREG-0737 Technical Specifications." Further, this proposed change 1) allows the Cognizant Functional Division Managers to approve overtime deviations for the Station Manager in accordance with administrative procedures and 2) provides a 2 hour margin within a 48-hour period in TS 6.2.2.f.2) such that personnel on the 12-hnur shift schedule will be able to perform administrative duties such as Fitness for' Duty testing without affecting their shift rotation and requiring deviations from the overtime specifications. - The guidelines for overtime are the maximum limits, and margins are normally provided between the established 1iinits and the normal work shift. Therefore, the proposed-2 hour margin within a 48-hour period is considered appropriate. Since Units 2 and 3 implemented the 12-hour shift schedule, approximately 150 overtime deviations due to Fitness for Duty testing and routine switches from ' daylight savings to standard time were approved. The proposed change will eliminate the unnecessary task of initiating overtime deviations and requiring management approval for these types of overtime. . For Unit 2 TS 6.2.2.f, replace " Reserved" with the following: , Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions (e.g., licensed SR0s, licensed R0s, health physicists, nuclear plant equipment operators, and key maintenance personnel). Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work an 8 or 12-hour day, nominal 40-hour week, while the unit is operating. However, in the event' that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown , for refueling, major maintenance, or major plant modification, on a , temporary basis, the following guidelines shall be followed:
- 1) An individual should not be permitted to work more than 16 continuous hours, excluding shift turnover time.
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- 2) An individual should not be permitted to work more than 16 hours in any 24-hour period,' nor more than 24' hours in any 48-hour period, nor more than 72 hours in any 7-day period, all excluding shift turnover time.
- 3) A break of at least 8 hours should be allowed between work periods, including shift turnover time. .
- 4) Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift Any deviation from the above guidelines shall be authorized by the Station Manager or designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.
Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Station Manager or designee to ensure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.
- Personnel regularly assigned to 12-hour shifts may work up to 26 hours in a 48-hour period.
For Unit 3 TS 6.2.2.f, the changes are:
- 1. In the first paragraph after " functions," replace "; e.g., senior reactor operators, reactor operators" with "(e.g., licensed SR0s, licensed R0s." Next, replace " auxiliary operators" with " nuclear plant equipment operators," and add ")" after maintenance .
personnel." The " nuclear plant equipment operators" designation instead of " auxiliary operators" is specifically used at San Onofre. Except for this change, the remaining changes in this paragraph are consistent with NUREG-1432.
- 2. In the second sentence of the second paragraph, change "a normal 8-hour day" to "an 8 or 12-hour day," add " nominal" before "40-hour week," and change " plant" to " unit." These changes are consistent with NUREG-1432.
The change from "a normal 8-hour day" to "an 8 or 12-hour day" allows members of the unit staff to work either 8-hour shifts or 12-hour shifts. The reference to an 8 or 12-hour day is made because different site organizations utilize different shift schedules. t In the third sentence of the second paragraph, add "," after " major. maintenance" and replace " modifications" with " modification." These changes are editorial. -i 3 i
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- 3. Under Item 1), revise "16 hours straight" to "16 continuous hours."
This change is editorial.
- 4. Under Item 2) add "*" after "24" to indicate a change that provides a 2 hour margin within a 48-hour period for personnel on the 12-hour shift schedule. This change will allow personnel to perform administrative duties such as random Fitness For Duty testing .
without affecting their shift rotation or requiring management approval for a deviation from the overtime specifications. Add a Footnote which reads "* Personnel regularly assigned to 12-hour shifts may work up to 26 hours in a 48-hour period." This change makes both the Units 2 and 3 TSs consistent.
- 5. Under Item 3) between "least" and " hours" change "eight" to "8."
This change is editorial. ,
- 6. In the first sentence of the seventh paragraph, which starts with~
"Any deviation," after " Station Manager" replace ", his deputy, the Manager, Operations" with "or designee, in accordance with approved "
administrative procedures," and insert "by" between "or" and :
" higher levels." These changes are consistent with NUREG-1432. ;
Make the second sentence of the existing paragraph which starts " with " Controls shall be" and the third sentence which starts with
" Routine" into a separate paragraph. This change is consistent with NUREG-1432.
Then delete "his" after "or." This change is editorial. Repl ace >
" assure" with " ensure." This change is consistent with NUREG-1432.
SAFETY ANALYSIS The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive _ finding in any one of the following areas:
- 1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an i accident previously evaluated?
Response: No Change to Unit 2 License Condition 2.C.(19)b The proposed deletion of Unit 2 License Condition 2.C.(19)b, " Shift-Manning (I.A.I.3, SSER #1, SSER #5,)" is administrative in nature and ! will not impact the probability or consequences of an accident previously evaluated. .This proposed change merely transfers the shift manning requirement, with proposed revisions, from a license condition to the administrative controls section of the Technical Specifications (TSs) to make the format of the Unit 2 TSs consistent with the format of l 4
t the Unit 3 TSs. Therefore, operation of the facility in accordance with this proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Change to Units 2 and 3 Technical Specification 6.2.2.f ; The proposed TS 6.2.2.f revises the shift manning requirements based on NUREG-1432 (Combustion Engineering Owners Group Standard Technical Specifications) dated September 28, 1992, and the model technical specification provided in Generic Letter 82-16, "NUREG-0737 Technical Specifications." , The proposed TS 6.2.2.f.2) change from "...no more than 24 hours in any 48-hour" to "...no more than 26 hours in any 48-hour period" merely adds 2 hours to the normal work shifts to eliminate the onerous task of initiating overtime deviations and obtaining management approval for the minor overtime deviations due to random Fitness for Duty testing and the routine switches from daylight savings to standard time. The overtime-guidelines are the maximum limits, and margins are normally provided between the established limits and the normal work shift. Therefore, the proposed change to TS 6.2.2.f.2) is consistent with the overtime ! guidelines. The proposed changes to TS 6.2.2.f, including the change to TS 6.2.2.f.2), are administrative in nature and will not impact the probability or consequences of an accident previously evaluated. Therefore, operation of the facility in accordance with these proposed . changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? !
Response: No Change to Unit 2 License Condition 2.C.(19)b The proposed deletion of Unit 2 License Condition 2.C.(19)b and transfer l of the shift manning requirement, with proposed revisions, from a 1 license condition to the administrative controls section of the TSs is administrative in nature and will not impact the configuration of any equipment, system, or the plant. Therefore, operation of the facility in accordance with this proposed change will not create the possibility , of a new or different kind of accident from any accident previously ' evaluated. Change to Units 2 and 3 Technical Specification 6.2.2.f j The proposed changes to TS 6.2.2.f, including the change to TS 6.2.2.f.2), are administrative in nature and will not impact the ! configuration of any equipment, system, or the plant. Therefore, l operation of the facility in accordance with this proposed change will j 5 , 2
n not create the possibility of a new or different kind of accident from any accidenti previously evaluated.
- 3. Will operation of the facility in accordance with this proposed change involve a.significant reduction in a margin of safety?
Response: No Change to Unit 2 License Condition 2.C.(19)b The proposed deletion of Unit 2 License Condition 2.C.(19)b and transfer of the shift manning requirement, with proposed revisions, from.a license condition to the administrative controls section of the TSs is administrative in nature and will not impact any design basis events or margin of safety associated with these events. Therefore, operation of the facility in accordance with this proposed change will not involve a significant reduction in a margin of safety. Change to Units 2 and 3 Technical Specification 6.2.2.f The proposed changes to TS 6.2.2.f, including the change to TS 6.2.2.f.2), are administrative in nature and will not impact any design basis events or margin of safety associated with these events. Therefore, operation of the facility in accordance with this proposed change will not involve a significant reduction in a margin of safety. Safety and Sianificant Hazards Determination Based on the above Safety Analysis, it is concluded that: 1).the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; 2) there is reasonable assurance that the health and safety of - the public will not be endangered by the proposed change; and 3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement. 6 ; i l
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ATTACHMENT A
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EXISTING LICENSE CONDITION UNIT 2 .i i
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(18) Initial Test Pro;rtm (Section 14. SER) SCL snell . conduct the post-fuel loacing initial' test program- .I (te_t fortn in Section la of the -San Onof re units 2 and j 3 Final Safety Analysis Report. as amenoec) witnuut making -
- any major mocifications to this program unless such modifica- '
tiens have been identified and have received prior WTF j approval. Major socifications are defined as: !
- a. Elimination of any test identified in Section la of !
the Final Safety Analysis Repo,rt. as amencec. as being essential. . _,:F
- b. Mocification of test otjectives, metnoes, or. acceptance i criteria for any test identified in Section 14 of the -
Final Safety analysis Report. as amenoec, as being .. .; e ssential . t
- c. Performance of any test at a power level different -
inan that cescrined in tne . test procecure. ... l' ! l
- d. Failure to coa.plete any tests incluoec in the descriDed !
c program (plannec or scheculed for power levels up to l _I-i the autnerized power level).- 1l , (19) NUREb-0737 Conditions (Section 22) i Each of the following concisions shall be'completec to the ' satisfaction-of tne NRC. . Each item references the' relatec : subpart of Section 22 of the sex.and/or its supplements. I
- a. Snif t Technical Advisor (1. A.1.1. SSEk til q SCE shall provice a fully trained.cn-shif t technical .
advisor to the snif t supervisor (watch engineer).
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- b. Snif t Manning (1. A.1.3. S'5ER al .- SSER #5) 3CE shall develop and implement administrative procecures i
~ to limit the working hours of individuals of the nuclear power plant operating staff who are responsible'for manipulating.
plant controls or for acJusting on-line-systems and equipment ; affecting plant safety' which would have an-imediate impac
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Adequate shif t coverage shall be s.sintainec sithout routine l heavy use of overtime. However in the event tnat unf orasse . j problems require' substantial amounts of: overtime to 1 e be usec. the follo.ing guidelines shall be followec: . i..
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- 1. An indivicuti shall not be permitted to wort more than 16 hours straight (excluding shif t turnover time).
- 2. An individual shall not be permitted to ' work more than 16 hours in any 24-hour period, nor mere tnan 24 hours in any &B-hour period, nor more than 72 hours in any seven day ceriod (all excluding shif t turnover time).
- 3. A break of at least eight hours shall be allowed between wort periods (including shif t turnover time).
- 4. Tne use of overtime shall be considered on-an'indieidual basis and not for the entire staff on a shift.
Any deviation from the above guidelines shall be authorized by the station manager, his deputy, the operations manager, or higher . levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation. Controls shall .be included in the procedures such that individual evertime will be reviewed monthly Dy. the station manager or his designee to assure that excessi
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hours have not been assigned. Routine deviation from the above guidelines is not authorized.
- c. Indeoendent Safety Encineerino Group (1.B.1.2 SSER 81)
SCE shall have an on-site independent safety engineering group..
- d. Procedures for Transients and Accidents ~(1.C.1. 55ER 81.
55:A re . 55tA *n ) By May 1,1982, SCE shall provide emergency procedure guicelines. Emergency procedures based on guidelines approved by the WR; shall be implemented prior to startup following the first refueling outape.
- e. Procedures for Yerifying Correct Performance of Operatin:_
Activitie s (i .C.b . 55LR $ 1) Prior to fuel loading, SCE shall implement a system.for verifying the correct performance of operating activities, and shall keep the system in effect thereafter.
- f. Control Room Design Review (1.0.1. 55ER #11 Prior to exceeding five (5) percent power, SCE shall:
- 1. Prioritize the control room annunciator windows.
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