ML20082M111

Suppl to 901207 & 910611 Applications for Amend to License NPF-12,consisting of TS Change TSP 900004-2,updating TS Section 6.4 Re Training Requirements of Unit Staff Personnel

ML20082M111
Person / Time
Site:	Summer
Issue date:	08/26/1991
From:	Skolds J SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082M114	List: ML20082M111 ML20082M117
References
NUDOCS 9109050029
Download: ML20082M111 (4)

Text

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Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 TECHNICAL SPECIFICATION CHANGE - TSP 900004-2 CERT!flCATION OF TRAINtNG PROGRAMS

References:

SCE&G 1etters to the NRC dated June 11, 1991, and December 7, 1990, same subject as above Via letter dated June 11, 1991 South Carolina Electric & Gas Company (SCE&G)

[ requested approval of a revised amendment request originally submitted on l December 7, 1990. This requested amendment was to updato Technical l Specification (TS)section6.4regardingtrainingrequirementsofunitstaff personnel. However, based cn discussions with NRC staff personnel, SCELG

, understands that the proposed revision to its original submittal is not deemed acceptable by the NRC. Therefore, SCE&G has decided to pursue a revision to the June 11, 1991, submittal.

This revision to the June 11, 1991, submittal deletes the reference to

, Regulatory Guide (RG) 1.8, Revision 2, April 1987, in TS 6.3 and 6.4, l provides the specific applicable section of ANSI 3.1, 1981 in TS 6.4, and incorporates the revised regulcion in 10CFR55.

The proposed TS change is identified in Enclosure 1. The safety evaluation i is provided in Enclosure 2. The proposed no significant hazards I

consideration is provided in Enclosure 3.

This proposed TS change has been reviewed and approved by the Plant Safety Prview Committee and the Nuclear Safety Review C0mmittee.

I declare that the statements and matters set forth herein are true and correct to the best of my knowledge, information, and belief.

Should you have any questions concerning this issue, please call Mr. Manuel W. Gutierrez at (803) 345-4392 at your convenience.

Very truly yours, John L. Skolds

! MWG:JLS:lcd l Enclosures i c: See page 2 9109050029 910826

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Enclosure 2 to Document Control Letter TSP 900004-2  !

Page 1 PROPOSED TECHNICAL SPECIFICATION CHANGE - TSP 900004-2 f VIRGIL C. SUMMER NUCLEAk STATION l

DESCRIPTION AND SAFETY EVALVATICW l TS 6.4 1 RAINING j DESCRIPTION OF AMENDMENT REQUEST SCE&G proposes te modify the VCSNS TS to revise TS 6.4, " Training," to reflect that it, training prograr;$, INP0 accredited and based on the systems  !

approach to ' ' *11ng, meet the requirements of Section 5.5.2 of ANSI 3.1, 1981, for not i censed unit staff, and 10 CfR 55.59 (c) and 55.31 (a)(4) for  !

licensed personnel. Title 10, CFR 55.31 and 55.59, allows licensees to use accredited training and requalification programs. NUREG 1262, Anpfff, to [

Questions at Public Meetinas Reaardinq Imp]ementation of Title 10. Code of l Federal Reculations. Part 55 on Operators' ticensej, asserts that an INPO l 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 INPO accredited training programs. The  :

training programs are enhanced by the use of the systems approach to }

training. These programs implement the INP0 Guidelines for Continuina Trainina of Licensed Perignnel - INP0 86-025. l The proposed change is administrative in nature because the change nerely provides clarification on the scope of the training and qualification programs, corrects the reference to ANSI 3.1, and inenrporates the revised ,

regulation in 10CFR55. l The proposed change does not alter the plant configuration and requirements. l l method and manner of plant operation, or affect any technical specification  !

margin of safety.  !

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

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, t Enclosure 3 to Document Control Letter .

TSP 900004-2  !

Page 1  ;

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PROPOSED TECHNICAL SPECIFICATION CHANGE - TSP 900004-2 VIRGIL C. SUMMER NUCLEAR STATION l DETERMINATION Or NO SIGNIFICANT HAZARDS CONSIDERATION I

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DESCRIPTION OF AMENOMENT REQUEST t SCE&G proposes to modify the VCSNS TS to revise TS 6.4, " Training," to l l reflect that its training programs, INP0 accredited and based on the systems approach to training, meet the requirements of Section 5.5.2 of ANSI 3.1, i 1981, for non-licensed unit staf f, and 10 CFR 55.59 (c) and 55.31 (a)(4) for  !

licensed personnel. Title 10, CFR 55.31 and 55.59, allows licensees to use i accredited training and requalification programs. NUREG 1262. Answers to  ;

Ouestions at Public Meetings Regardinq Implementation of Title 10. Code of Federal Regulations. Part 55 on Olerators' Licensn , asserts that an INPO ,

accredited program does not constitute a decrease in the scope, content, or '

frequency of requalification training programs. l BASIS FOR PROPOSED N0 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, etc." and example (vii) which states, "A change to make a license conform to i changes in the regulations. ...." SCE&G has determined that a no  ;

significant hazards consideration is justified and that should this request .

be implemented it will not:

l

1. Involve a significant increase in the probability or consequences of any i

, accident previously evaluated because no plant equipment has been l

changed. This amendment is an administrative change involving the i

clarification on the scope of the training and qualification programs, corrects the reference to ANSI 3.1, and incorporates the revised regulation in 10CFR55. ,

2. Create the possibility of a new or different kind of accident from any  :

l previously evaluated because the proposed amendment is administrative in nature. No physical plant configuration, setooint. or operation changes are proposed.

3. Involve a significant reduction in a margin of safety because this l amendment is administrative in nature and does not affect any TS margin s of safety.

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