ML20072C161
| ML20072C161 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/11/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20072C151 | List: |
| References | |
| NUDOCS 9408170104 | |
| Download: ML20072C161 (6) | |
Text
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UNITED STATES t
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NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20555-0001 0
.... 9 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 178 TO FACILITY OPERATING LICENSE N0. DPR-65 NORTHEAST NUCLEAR ENERGY COMPANY THE CONNECTICUT LIGHT AND POWER COMPANY THE WESTERN MASSACHUSETTS ELECTRIC COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT N0. 2 DOCKET N0. 50-336
1.0 INTRODUCTION
By letter dated June 24, 1994, the Northeast Nuclear Energy Company (NNECO or the licensee) requested an amendment to change the Technical Specifications (TS) for the Millstone Nuclear Power Station, Unit No. 2.
The proposed amendment would revise the Administrative Controls section (TS 6.3.1) to require an individual who serves as the Operations Manager to either hold a Millstone Unit 2 senior reactor operator (SRO) license or hold an SR0 license at another pressurized water reactor.
If the Operations Manager does not hold a Millstone Unit 2 SR0 license, then an individual serving as the Assistant Operations Manager would be required to possess an SR0 license at Millstone Unit 2.
2.0 BACKGROUND
AND DISCUSSION The intent of the licensee's proposed amendment is to strengthen the Millstone Unit 2 Operations Department and to improve the operational performance of Millstone Unit 2.
The planned organizational changes would permit an individual to serve in the role of Operations Manager who possesses skills and experience diverse from Millstone Unit 2.
The proposed changes would allow the licensee to continue with their efforts to enhance the performance of the Millstone Unit 2 Operations Department. The proposed change would require an individual who serves as the Operations Manager to either hold a Millstone Unit 2 SR0 or have held an SR0 license at another pressuri_ed water reactor.
If the Operations Manager does not hold a Millstone Unit 2 SRO license, then an individual serving as the Assistant Operations Manager (newly created position) would be required to possess an SR0 license at Millstone Unit 2.
This individual would be required to meet the requirements for and would have the responsibilities as recommended by the American Nuclear Standards Institute (ANSI)/American National Standard (ANS)-3.1-1987 for %9 Operations Middle Manager position.
TS 6.5.1 currently endorses ANSI N18.1-1971. This standard recommends that the Operations Manager hold an SRO license for the 9408170104 940811 PDR ADOCK 05000336 P
e t unit. The proposed request is requesting a limited exception to ANSI N18.1-1971.
Specifically, the exception would require the Assistant Operations Manager (functionally equivalent to Operations Middle Manager referenced in ANSI /ANS-3.1-1987) to hold and continue to hold an SR0 license if the Operations Manager does not hold an SR0 license for the unit. The proposed changes have been requested on an exigent basis to permit the licensee to accelerate the organizational changes that would strengthen the Millstone Unit 2 Operations Department.
3.0 EVALUATION The Millstone Unit 2 Operations Manager is currently required to hold an SR0 license.
In their submittal dated June 24, 1994, NNEC0 proposed changes to the Millstone Unit 2 TS modifying this requirement. The proposed modification would require an individual who serves as the Operations Manager to either hold a Millstone Unit 2 SR0 license or have held an SR0 license at another pressurized water reactor.
If the Operations Manager does not hold an Millstone Unit 2 SRO license but meets the remaining Operations Manager qualifications described in ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel," then an individual serving as the Assistant Operations Manager will be required to hold a Millstone Unit 2 SR0 license.
The individual serving as Assistant Operations Manager will be required to meet the qualification requirements described in Section 4.3.8, Operations, of ANSI /ANS-3.1-1987, "American National Standard for Selection, Qualification, and Testing of Personnel for Nuclear Power Plants."
The Code of Federal Regulations at 10 CFR 50.54(1) requires the licensee to
" designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators...." Additionally, the licensee has committed to ANSI N18.1-1971,
" Selection and Training of Nuclear Power Plant Personnel," for Millstone Unit 2.
ANSI N18.1-1971 requires the Operations Manager to hold, at time of appointment to the active position, an SR0 license.
This standard is intended to ensure that the Operations Manager has the necessary and relevant operational experience and knowledge for the particular reactor technology in question.
The staff maintains that an individual who holds or has held an SR0 license at a PWR has sufficient and relevant operational experience and knowledge to fill the position of Operations Manager at another PWR.
Similarly, if that individual holds or has held a license at a BWR he or she has sufficient and relevant operational experience to fill the Operations Manager position at another BWR.
The staff concludes that the specification that either the Operations Manager or Assistant Operations Manager hold a Millstone Unit 2 SR0 license, is consistent with the requirements of 10 CFR 50.54(1) and ensures that a licensed off-shift senior operator is directing the licensed activities of the licensed operators.
Requiring an ANSI /ANS-3.1-1987 qualified and licensed Assistant Operations Manger when the Operations Manager does not hold a valid Millstone Unit 2 SR0 license is consistent with the requirements of TNSI N18.1-1971 and ensures there is site-specific detailed relevant technical and systems knowledge in a senior operations management position.
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4 l Therefore, the staff concludes that the proposed modifications and additions to the Millstone Unit 2 TS modifying the requirements for the operations management individual required to hold a valid Millstone Unit 2 SR0 license is consistent with and meets the intent of the relevant review criteria and is, therefore, acceptable.
4.0 TECHNICAL SPECIFICATION CHANGES The following TS changes have been proposed. The staff finds these changes acceptable.
(1)
For TS 6.3.1, Item (a.) would be changed to:
"If the Operations Manager does not hold a senior reactor operator license for Millstone Unit 2, then the Operations Manager shall have held a senior reactor operator license at a Pressurized Water Reactor other than Millstone Unit 2 and an individual serving in the capacity of the Assistant Operations Manager shall hold a senior reactor operator license for Millstone Unit 2" (2)
For TS 6.3.1, Item (c.) (current Item (a.)) would be added and read as follows:
"The Health Physics Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1."
5.0 EXIGENT CIRCUMSTANCES
l Pursuant to 10 CFR 50.91(a)(6), the licensee requested the proposed amendment on an exigent basis.
The proposed changes would permit Millstone Unit 2 to accelerate efforts to strengthen the Millstone Unit 2 Operations Department.
The decision to make the organizational changes which would be permitted by the proposed license amendment was only recently finalized.
Requesting the amendment in anticipation of this decision and thereby obviating the need for exigent treatment of this the request would have been premature.
Notice of the staff's proposed determination that this proposed amendment involves no significant hazards consideration was published in the Federal Reaister on July 7, 1994 (59.FR 34872).
Given that this notice has provided 30 days notice as required by 10 CFR 50.91(a)(2), there is no need to issue the amendment on an exigent basis. The Commission has made a final determination that the proposed amendment does not involve a significant hazards consideration, as discussed in Section 6.0.
6.0 FINAL N0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission has made a final determination that the amendment involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92(c), this means that the operation of the facility in accordance with the proposed amendment would not (1) Involve a significant increase in the
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' probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.
The Commission has evaluated the proposed changes against the above standards as required by 10 CFR 50.91(a) and has concluded that the changes do not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change affects an administrative control, which was based on the guidance of ANSI N18.1-1971. ANSI N18.1-1971 recommended that the Operations Manager hold an SR0 license.
The current guidance in Section 4.2.2. of ANSI /ANS-3.1-1987 recommends, as one option, that the Operations Manager have held a license for a similar unit and the Operations Middle Manager hold an SRO license. While the Operations Middle Manager position does not exist at Millstone Unit 2, the licensee has proposed to create the position of Assistant Operations Manager (staffed by an individual with an SR0 license at Millstone Unit 2).
This individual would be required to meet the requirements for, and would have responsibilities as recommended in ANSI /ANS-3.1-1987 for the Operations Middle Manager position.
Therefore, the proposed change requests an exception to ANSI N18.1-1971 to allow use of ANSI /ANS-3.1-1987 in a limited circumstance.
Specifically, the proposed revision to Technical Specification 6.3.1 would require the Operations Manager to either hold an SR0 license at Millstone Unit 2 or have held an SR0 at a pressurized water reactor (PWR) other than Millstone Unit 2.
If the Operations Manager does not hold an SR0 license at Millstone Unit 2, the proposal will require the Assistant Operations Manager to hold, and continue to hold, an SR0 license.
The proposed change includes the requirement to have held a license for a similar unit (a PWR) in accordance with Section 4.2.2 of ANSI /ANS-3.1-1987, if the Operations Manager does not hold an SR0 license at Millstone Unit 2.
For those areas of knowledge that require an SR0 license, the Assistant Operations Manager will hold an SR0 license and provide technical guidance normally provided by the Operations Manager.
The proposed change does not alter the design of any system, structure, or component, nor does it change the way plant systems are operated.
It does not reduce the knowledge, qualifications, or skills of licensed operators, and does not affect the way the Operations Department is managed by the Operations Manager. The Operations Manager will continue to maintain the effective performance of his personnel and ensure the plant is operated safely and in accordance with the requirements of the operating license.
Additionally, the Control Room operators will continue to be supervised by the licensed Shift Supervisors.
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s The proposed change does not detract from the Operations Manager's ability to perform his primary responsibilities.
In this case, by having previously held an SR0 license for a similar unit, he has achieved the necessary training, skills and experience to fully understand the operation of plant equipment and the watch requirements for operators.
In summary, the proposed change does not affect the ability of the Operations Manager to provide the plant oversight required of his position. Thus, it does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change to Technical Specification 6.3.1 does not affect the design or function of any plant system, structure, or component, nor does it change the way plant systems are operated.
It does not affect the performance of NRC licensed operators. Operation of the plant in conformance with technical specifications and other license requirements will continue to be supervised by personnel who hold an NRC SRO license.
The proposed change to technical Specification 6.3.1 ensures that the Operations Manager will be a knowledgeable and qualified individual by requiring the individual to have held an SR0 license at a PWR.
Based on the above, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
3.
Involve a significant reduction in a margin of safety.
The proposed change involves an administrative control which is not related to the margin of safety as defined in the technical specifications.
The proposed change does not reduce the level of knowledge or experience required of an individual who fills the Operations Manager position, nor does it affect the conservative manner in which the plant is operated. The Control Room operators _will continue to be supervised by personnel who hold an SR0 license.
Thus, the proposed changes do not involve a significant reduction in a margin of safety.
7.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Connecticut State official.was notified of the proposed issuance of the amendment.
The State official had no comments.
8.0 ENVIRONMENTAL CONSIDERATION
The amendment relates to changes in recordkeeping, reporting or administrative
-procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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9.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, 1
that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
G. Vissing R. Pelton Date: August 11, 1994 l
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