ML20065N375

Proposed Tech Specs Incorporating Requirements of Revised Regulation 10CFR55.31(a)(4) & 10CFR55.59(c) Which Require Accredited Training & Requalification Program

ML20065N375
Person / Time
Site:	Summer
Issue date:	12/07/1990
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20065N373	List: ML20065N369 ML20065N375
References
NUDOCS 9012120092
Download: ML20065N375 (3)

Text

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, ADMINISTRATIVE CONTROLS

6. 2. 3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources of plant design and operating experience information, including plants of similar design, which may indicate areas for improving plant safety.

COMPOSITION 6.2.3.2 The ISEG shall be composed of a multi-disciplined dedicated onsite group with a minimum assigned complement of five engineers or appropriate specialists.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISEG shall make detailed recommendations for procedure revisions, equipment modifications, maintenance activities, operations activities or other means of improving plant safety to the General Manager, Nuclear Safety.

l 6.2.4 SHIFT TECHNICAL ADVISOR The Shift Technical Advisor shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit.

6. 3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI N18.1-1971 for comparable positions and the supplemental require-ments specified in Sections A and C of Enclosure 1 of the March 28, 1980 letter to'all licensees as clarified in NUREG-0737,Section I.A.2.1, except for the Associate Manager, Health Physics who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, the Shift Technical Advisor who shall meet or exceed the qualifications ref7rred to in Section 2.2.1.b of Enclosure I of the October 30, 1979 NRC letter to all operating nuclear power plants, and the members of the Independent Safety Engineering Group, each of whom shall have a Bachelor of Science degree or registered Professional Engineer and at least two years experience in their field. At least one year experience shall be in the nuclear field.

l 6.4 TRAINING -

6.4.1 Metrainingandreplacementtrainingprogram be maintained ;nd shall mut ;r acud th; r;e.f :t: =rs d frc::r fora the unitOfstaff shall nd:tfer 0m mu, 0.2 e d 0.0 ef ANSI 0.1 1001 end 10 CIR 00 Z, ;; me.. mitted i: in App;ndim CA ef the rin;l R.f t3 An;13 i ip;rt. 77ese. 7:<ainen opawn.*//

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• Not responsible for sign-off function.

SUMMER - UNIT 1 6-3 AmendmentNo.7E,5$,K i

9012120092 901207 PDR ADOCK 05000395 P PDC

2 Enclosure-2 to Document Control Desk Letter TSP.900004-0 Page 1 PROPOSED TECHNICAL ~ SPECIFICATION CHANGE - TSP 900004-0 VIRGIL C. SUMER NUCLEAR STATION DESCRIPTION AND SAFETY EVALVATION TS 6.4 TRAINING DESCRIPTION OF AMENDMENT REQUEST SCE&G proposes to modify the VOSNS TS to revise TS 6.4, " Training," to reflect that the. training programs are INP0 accredited and are based on the #

systems approach to training and.to delete references to superseded requirements. VCSNS has INPO accredited training and requalification programs based on the systems approach to training. Title 10. CFR 55.31 and 55.59, allows licensees to use accredited training and requalification

-programs. NUREG 1262, " Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses," asserts that an INP0 accredited program does not constitute a decrease in the scope, content or frequency of requalification training programs.

SAFETY EVALUATION

- VCSNS has substituted its initial and requalification training programs, previously approved by the NRC, with INP0 accredited training programs. The training programs are enhanced by the use of.the systems approach to training. These programs implement the INP0 " Guidelines for Continuing.

Training of Licensed Personnel - INP0 86-025."

The proposed-change is administrative in nature because the change merely deletes references to requirements superseded by the issuance of 10CFR55.

The proposed change does not alter the plant configuration and requirements, methods and manner of plant operation, or affect any technical specification margin of safety.

Therefore, this amendment' request does not adversely affect or endanger the health or safety.of the general public and does not involve an unreviewed safety question.

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. .: O Enclosure 3 to Document Control Desk Letter TSP. 900004-0

Page 1 PROPOSED TECHNICAL SPECIFICATION CHANGE - TSP 900004-0 VIRGIL C. SUMER NUCLEAR STATION DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF AMENDMENT REQUEST

- SCE&G proposes to modify the VCSNS TS to revise TS 6.4, " Training," to reflect that the training programs are INP0 accredited and are based on the systems approach to training and to delete references to superseded

. requirements. VCSNS has INPO accredited training and requalification programs based on the systems approach to training. Title 10. CFR 55.31 and 55.59, allows licensees to use accredited training and requalification programs. NUREG 1262, " Answers to Questio at Public Meetings Regarding Implementatior of Title 10 Code of Federal Regulations, Part 55 on Operators' Licenses," asserts that an INP0 accredited program does not constitute a decrease in the scope, content or frequency of requalification training programs.

BASIS FOR PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided certain examples (51 FR 7744) of actions likely to. involve no significant hazards considerations. The proposed amendment to Section 6.4 is consistent with example (i) which states, "A purely administrative change to TS: for example, a change to achieve consistency throughout the TS, correction of an error, or a change in nomenclature."

SCE&G has determined that a no significant hazards evaluation is justified and that should this request be implemented-it will not:

1. ' Involve a significant increase in the probability or consequences of any accident previously evaluated because no plant equipment has been changed. Th.is amendment is an administrative change involving the deletion of superseded requirements and incorporation of the revised

- regulation'in 10CFR55,

2. Create the possibility of a new or different kind of accident from any previously evaluated because the proposed amendment-is an administrative change involving the deletion of superseded documents and incorporation of revised regulation. No physical plant configuration, setpoint-or

, . operation changes are proposed.

3. . Involve a significant reduction -in a margin of safety because this amendment is an administrative change involving the deletion of superseded requirements and the incorporation of revised regulation in 10CFR55.

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