ML20059E362
| ML20059E362 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/27/1993 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059E365 | List: |
| References | |
| NUDOCS 9311030178 | |
| Download: ML20059E362 (9) | |
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10CFR50.90 PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 October 27, 1993 (215) 640-6000 l
Docket Nos. 50-277 50-278 License Nos. DPR-44 l
STATION SUPPORT DEPARTMENT U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 93-10 Gentlemen:
Philadelphia Electric Company hereby submits Technical Specifications Change Request No. 93-10, in accordance with 10CFR50.90, requesting a change to Appendix A of the Peach Bottom Facility Operating Licenses. Attachment I to this letter describes the proposed change and provides justification for the change. Attachment 2 provides the revised Technical Specifications (TS) pages.
This submittal requests a change to the Unit 2 and Unit 3 TS to allow one of the required on-shift Senior Reactor Operator (SRO) positions to be-combined with the required Shift Technical Advisor (STA) position as recommended by the NRC's " Policy Statement on Engineering Expertise on Shift,"
issued on October 28, 1985.
Presently, a licensed SR0 who is not assigned to one of the required SR0 positions, but who is assigned operating duties commensurate with the knowledge and abilities of a licensed SR0 is assigned as the STA. The current position assignments comply with the approved dedicated STA program.
l If you have any questions regarding this matter, please contact us.
Very truly yours, 1
ff fAh G. A. Hunger, Jr., Director Licensing Section
Enclosures:
Affidavit, Attachment 1, Attachment 2 cc:
T. T. Martin, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident Inspector, PBAPS W; P. Dornsife, Commonwealth of Pennsylvania 9311030178 931027 J%
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1 COMMONWEALTH OF PENNSYLVANIA:
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COUNTY OF CHESTER~
d G. R. Rainey, being first duly sworn, deposes and.says:'-
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u That he is Vice President of' Philadelphia Electric Company;.the-Applicant.
herein; that he has read the attached Technical Specifications Change Request ~
(Number 93-10) for Peach Bottom Atomic Power Station Facility.0perating Licenses.
DPR 44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct' to the best of his knowledge, i
information and belief.
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. VicePresident/
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ATTACHMENT I PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos.150-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGE REQUEST 93-10
" Allow One of the Required On-Shift Senior Reactor Operator Positions to be Combined with the Required Shift Technical Advisor Position" j
Supporting Infonmation for Changes - 6 Pages
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Philadelphia Electric Company (PEco), Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS)
Unit No. 2 and Unit No. 3, respectively, requests that the Technical Specifications (TS) be amended as proposed below to allow one of the required on-shift Senior Reactor Operator (SRO) positions to be combined with the required Shift Technical Advisor (STA) position, i.e., dual-role SR0/STA position. This proposed change will permit PBAPS to continue to satisfy the NRC policy for engineering expertise on shift using either of the options discussed in Generic Letter 86-04, " Policy Statement on Engineering Expertise on Shift,"
dated February 13, 1986.
This TS Change Request for PBAPS, Units 2 and 3, provides a discussion and description of the proposed changes, a safety assessment, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
The proposed revised TS pages for Units 2 and 3 are provided in Attachment 2.
Proposed changes are indicated by vertical bars in the margin of pages 245 and 246.
We request that, if approved, the TS changes be effective upon issuance.
Discussion and Descriotion of the Proposed Chanaes The 1985 NRC " Policy Statement on Engineering Expertise on Shift," provides two options for meeting the minimum requirements for shift staffing in 10CFR50.54(m)(2) and the recommendation for an STA in NUREG-0737, " Clarification of THI Action Plan Requirements," Item I.A.I.1, " Shift Technical Advisor."
These two options are:
1.
Continue with the current approved dedicated STA program in accordance with the description in NUREG-0737 (i.e., Item I.A.1.1), or 2.
Combine one of the required licensed SR0 positions and the STA position (i.e., dual-role SR0/STQ.
Generic letter 86-04 states that either option may be used on each shift.
If the second option is used, the person filling the dual-role SR0/STA position, in addition to holding an active SR0 license on the unit (s) assigned, will be required to meet the criteria for education and training specified in the 1985 NRC Policy Statement on Engineering Expertise on Shift. The education and training qualifications for the dual-role SR0/STA position are the same as those currently applicable to the STA required by PBAPS TS Section 6.3.1 except that the education qualifications for an individual filling the dual-role SR0/STA position may be satisfied by any of the following four alternatives:
i Docket Nos. 50-277 50-278 j
License Nos. DPR-44 1
DPR-56 1.
Bachelor's degree in engineering from an accredited institution; j
2.
Professional Engineer's (PE) license obtained by successful completion of the PE exam; J
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3.
Bachelor's degree in engineering technology from an accredited
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institution, including course-work in physical, mathematical, or l
engineering sciences; or 4.
Bachelor's degree in physical science from an accredited institution, including course-work in physical, mathematical, or engineering sciences.
The proposed changes to the PBAPS TS are as follows:
TS Table 6.2.1 The position title " Shift Technical Advisor" will be marked with a double asterisk symbol (**) that will refer to the following note.
4 TS Section 6.3.1 The statement specifying the education requirements for the STA will be replaced with the following.
The Shift Technical Advisor shall meet the qualifications specified by the 1985 NRC Policy Statement on Engineering Expertise on Shift.
The affected TS pages marked to show the proposed changes are provided in.
These proposed changes are consistent with the corresponding requirements in the Improved Standard TS, NUREG-1433, " General Electric Plants, BWR/4."
Safety Assessment j
While the number of on-shift SR0s, Reactor' Operators (R0s) and non-licensed plant operators normally exceeds the minimum requirements specified in TS Table 6.2.1 and 10CFR50.54(m)(2), the proposed TS changes to adopt a dual-role SR0/STA has been evaluated for the conditions when the shift staffing is at the minimum level permitted by the TS Table 6.2.1.
Nevertheless, the information in the following documents will be taken into account in the development of the administrative controls governing the shift composition upon implementation of the proposed dual-role SR0/STA position:
1.
NRC Information Notice 91-77, " Shift Staffing at Nuclear Power Plants,"
dated November 26, 1991.
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f Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 2.
NUREG-1275, Vol. 8, " Operating Experience Feedback Report-Human Performance in Operating Events," dated December 1992, transmitted by NRC letter dated February 22, 1993.
3.
NRC Information Notice 93-44, " Operational Challenges During a Dual-Unit Transient," dated June 15, 1993.
j The dual-role SR0/STA position option permitted by the 1985 NRC Policy 1
Statement on Engineering Expertise on Shift combines one of the required SRO positions and the STA position. Therefore, use of the dual-role SR0/STA position option will not result in the need to assign an additional licensed SR0 to meet minimum shift staffing requirement (i.e., the two licensed SR0s currently required by TS Table 6.2.1).
The 1985 NRC Policy Statement specifically states that the number of shift personnel specified in 10CFR50.54(m)(2) and reflected in TS Table 6.2.1 is sufficient to allow the dual-role SR0/STA to provide accident assessment expertise and to analyze and respond to off-normal occurrences when needed.
The purpose of the STA' position is to ensure that engineering and accident assessment expertise is available on each shift. The 1985 NRC Policy Statement concludes that the dual-role SR0/STA position can provide this expertise and simultaneously function as one of the licensed SR0s required to meet staffing levels in 10CFR50.54(m)(2).
In addition to the staffing requirements in 10CFR50.54(m)(2) and TS_ Table 6.2.1, sufficient and appropriately qualified personnel must be available at all times to meet the TS requirements for the fire brigade. TS Section 6.2.2.f requires that a fire brigade of at least five members be maintained onsite at all times.
The fire brigade may not include the minimum shift crew necessary for safe shutdown of the unit (s) or any personnel required for other essential functions during a fire emergency.
Additionally, the fire brigade leader and at least two fire brigade members must have sufficient training in or knowledge of plant safety-related systems to i
understand the effects of fire and fire suppressants on safe shutdown capability. The brigade leader must also be competent to assess the potential safety consequences of a fire and advise Main Control Room (MCR) personnel.
PBAPS Fire Protection Plan (Revision 5) states that such competence by the brigade leader is evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.
These requirements for the fire brigade and fire brigade leader would, upon implementation of the proposed dual-role SR0/STA position, continue to be satisfied as follows.
Minimum Crew Necessary for Safe Shutdown and the Fire Briaade Shift staffing requirements are established in 10CFR50.54(m)(2) and TS Table 6.2.1.
These requirements are based on criteria in NUREG-0737, Item I.A.1.3, which also specify the minimum shift crew necessary to achieve safe shutdown of the unit (s) and the personnel required for other essential functions during a fire emergency.
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Docket Nos. 50-277 50-278 l
License Nos. DPR-44 DPR-56 The TS Table 6.2.1 minimum shift staffing with 2 units operating consists of:
one Shift Manager (SRO); one Shift Supervisor (SRO); three Reactor Operators; five Operators; and one STA. This minimum staffing level is based on meeting the following specific requirements: one SR0 in the MCR at all times when i
either unit is operating with a second SR0 available for relief; one R0 at the controls for each operating unit with a third R0 available for relief on either unit; and one non-licensed plant operator assigned to each unit and a third non-licensed plant operator assigned to the MCR.
Upon implementation of the proposed dual-role SR0/STA position, the staffing necessary to achieve safe shutdown and man the fire brigade will continue to comply with TS requirements. Accordingly, to meet the restrictions of TS Section 6.2.2.f, the SRO available for assignment to the Fire Brigade cannot be the Shift Manager or SR0/STA if the dual-role SR0/STA option is being used.
Qualification of Fire Briaade and Briaade Leader In accordance with TS Section 6.2.2.f, the fire brigade at PBAPS consists of at least five members and may not include the minimum shift crew necessary to achieve safe shutdown.
Fire brigade members must be trained in accordance with the requirements specified in UFSAR Section 13.3.5.8, " Fire Protection Training."
Additionally, PBAPS Fire Protection Plan (Revision 5) requires that the brigade leader and at least two brigade members must have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability.
PBAPS Fire Protection Plan (Revision 5) requires that the brigade leader be competent to assess the potential safety consequences of a fire and advise MCR personnel.
Such competence by the brigade leader is evidenced by possession of an operator's i
license or equivalent knowledge of plant safety-related systems.
The composition of the fire brigade upon implementation of the proposed dual-role SR0/STA position will continue to ensure that the brigade leader and at least two brigade members will have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability and that the fire brigade leader is competent to assess the potential safety consequences of a fire.
This proposed change does not directly impact any accidents previously evaluated because: the function and responsibilities of the STA will be executed by appropriately qualified individuals filling the dual-role SR0/STA position; the function and responsibility of the fire brigade leader will be executed by an appropriately qualified plant operator; and shift staffing is maintained as required by the staffing levels in TS Table 6.2.1.
Additionally, implementation of this proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected.
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Information Supportina a Findina of No Sianificant Hazards Consideration The changes proposed in this Application do not constitute a Significant Hazards Consideration in that:
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The oroposed chances do not involve a sianificant increase in the orobability or consecuences of an accident oreviously evaluated because implementation of the proposed changes will not involve any physical changes to plant SSC or the manner in which these SSC are j
operated, maintained, modified, tested, or inspected. Therefore, l
the proposed use of the dual-role SR0/STA position does not increase j
the probability of an accident previously evaluated.
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1 The consequences of an accident previously evaluated could be affected by the performance of the individual filling the dual-role SR0/STA position. However, implementation of the proposed change will result in personnel with enhanced operational knowledge being assigned to perform the STA function of providing accident assessment expertise and analyzing and responding to off normal occurrences when needed. The NRC's stated preference in the October 28,1985, " Policy Statement on Engineering Expertise on Shift,"
indicates that the NRC has concluded that the individual filling the dual-role SR0/STA position may perform these functions better than a i
non-licensed individual filling the STA position even when the SR0/STA is concurrently functioning as one of the required shift SR0s.
Furthermore, implementation of the proposed cchangeswill not j
affect the staffing or qualification of the fire brigade members.
l Therefore, the proposed TS changes do not increase the consequences of an accident previously evaluated.
11)
The proposed chanaes do not create the possibility of a new or different kind of accident from any accident oreviously evaluated l
because implementation of the proposed TS changes will not involve physical changes to plant SSC, or the addition of new SSC.
Furthermore, implementation of the proposed changes will not adversely affect the manner in which plant SSC are operated, maintained, modified, tested, or inspected. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created.
iii) The proposed chanaes do not involve a sianificant reduction in a marain of safety because the STA and fire brigade leader positions will be filled by appropriately qualified personnel and shift staffing required by TS Table 6.2.1 and 10CFR50.54(m)(2) is maintained.
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Docket Nos. 50-277 50-278 i
License Nos. DPR-44 DPR-56 i
Information Supportina an Environmental Assessment An environmental impact assessment is not required for the changes proposed by this Application because the changes conform to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed changes do not involve a Significant Hazards Consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released offsite.
In addition, the proposed changes do not involve a significant increase in individual or cumulative occupation radiation exposure.
Conclusion The Plant Operations Review Committee-and the Nuclear Review Board have reviewed the proposed changes to the TS and have concluded that the changes do not l
involve an unreviewed safety question and are not a threat to the health and safety of the public.
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