ML20094D208
| ML20094D208 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/27/1995 |
| From: | Jackie Cook ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20094D210 | List: |
| References | |
| JGC-462-95, L47-95(10-27)LP, NUDOCS 9511030215 | |
| Download: ML20094D208 (8) | |
Text
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liknois Power Company Chnton Power Station P.O. Box 678 Chnton. IL 61727 Tel 217 935-5623 Fax 217 935-4632 John G. Cook Vice President P4WER U-602462 L47-95(10 - 27 )LP 8E.100a JGC-462-95 October 27, 1995 1
Docket No. 50-461 10CFR50.90 Document Control Desk Nuclear Regulatory C >mmission Washington, D.C. 20555
Subject:
Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-62 (PS-95-006)
Dear Sir:
Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No NPF-62,. appendix A - Technical Specifications, for Clinton Power Station (CPS). This request consists of proposed changes to Technical Specification 5.2.2.e, " Unit Staff," to revise the requirements for controls on the working hours of unit staffwho perform safety related functions. This request clarifies the approval requirements for deviations from the overtime guidelines and eliminates the requirement for a monthly review ofindividual overtime, consistent with GL 82-12,
" Nuclear Power Plant Staff Working Hours," dated June 15,1982.
r IP requests that this proposed change be classified as a cast beneficial licensing j
action (CBLA) in accordance with NRC Administrative Letter 95-02, " Cost Beneficial Licensing Actions," dated February 23,1995. The CBLA program provides for a more expeditious review and increased NRC management attention for licensee requests that l
seek to modify or delete requirements that have a small effect on safety ar.d are costly to implement. IP expects that elimination of the requirement to perform a monthly review of individual overtime will result in a cost savings of at least $100,000 over the remaining life of the plant without a reduction in the margin of safety. Therefore, this request meets the criteria of NRC Administrative Letter 95-02 to be considered a CBLA.
A description of the proposed changes and the associated justification (including a i
Basis For No Significant Hazards Consideration) are provided in Attachment 2. A marked-up copy of the affected page from the current Technical Specifications is provided in Attachment 3. Further, an affidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.
(;2004J 9511030215 951027 p)\\ I PDR ADOCK 05000461
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U-602462 Page 2 IP has reviewed the proposed changes against the criteria of 10CFR51.22 for categorical exclusion from environmentalimpact considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, IP concludes that the proposed changes meet the criteria given in 10CFR$ 1.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
Sincerely yours, V
.G. Cook Vice President AJP/csm Attachments ce; NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety l
i
t to U-602462 J. G. Cook, being first duly sworn, deposes and says: That he is Vice President ofIllinois Power; that the application for amendment of Facility Operating License NPF-62 has been prepared under his supervision and duection; that he knows the contents thereof; and that to the best of his knowledge and belief said letter and the facts contained therein are true and correct.
This _27'^ day of October 1995.
Date:
Signed:
Nh J. O. Cook STATE OF ILLINOIS l SS.
- 0mCW.8E4,'
[wgm.mmes 3< u)U1 COUNTY J
h
+:::::::::::::::::::::::
Subscribed and sworn to before me this 27 day of October 1995.
m/St 8 Yse e
w Notary Public) [
- l.
to U-602462 l
PS-95-006 Page1of4
'Hackaround l
On June 15,1982, the NRC issued Generic Letter (GL) 82-12 to clarify the commission's l
policy to restrict the use of overtime for licensee personnel performing safety-related l
activities. (The commission's previously issued policy statement had recently been revised l
at the time.) The GL requested that utilities revise the Adruinistrative Controls Section of l
the Technical Specifications to assure that plant administrative procedures follow the l
working hour guidelines set forth in the commission's final policy statement, including a provision for documentation of authorized deviations.
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The GL clarifies NUREG-0737, " Clarification of TMI Action Plan Requirements,"
l requirement I. A. I.3, "Shia Manning," and states that...
Licensees of operating plants and applicants for operating licenses shall include in their administrative procedures (required by license conditions) provisions govern'ng required shiR staffing and movement of key i
individuals about the plant. These provisions are required to assure that qualified plant personnel to man the operational shiRs are readily available in the event of an abnormal or emergency situation.
l These administrative procedures shall also set forth a policy, the objective l
of which is to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe condition. The controls established should assure that, to the extent practicable, personnel are not assigned to shia duties while in a fatigued condit. ion that s ould significantly reduce their mental alertness or their decision making ability. The controls shall apply to the plant staff who perform safety-related functions (e.g.,
senior reactor operators, reactor operators, auxiliary operators, health physicists, and key maintenance personnel).
NUREG-1434, " Standard Technical Specifications, General Electric Plants, BWR/6,"
dated September,1992 includes requirements for the control of overtime pursuant to the above requirements. Specification 5.2.2.e provides utilities with the option of (1) prescribing specific requirements in this section of the Technical Specifications, or (2) including a paragraph that simply commits the utility to the commission policy as described in GL 82-12. The requirements set forth by option (1) are identical to option (2) except that option (1) includes an additional paragraph addressing review ofindividual i
overtime. This additional paragraph s+ates, " Controls shall be included in the procedures
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such that individual overtime shall be reviewed monthly by the [ plant manager], or his designee, to ensure that excessive hours have not been assigned." The requirements set forth in this additional paragraph are not specifically required by GL 82-12.
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to U 602462 PS-95-006 Page 2 of 4 2
Description of Proposed Change In accordance with 10 CFR 50.90, IP proposes to revise CPS Technical Specification (TS) 5.5.2.e. Specifically, IP proposes to delete wording from the last two paragraphs of this Technical Specification and combine the paragraphs into one paragraph that states:
"Any deviation from the above guidelines shall be authorized by the plant manager or his designee, in accordance with administrative procedures with documentation of the basis for granting the deviation. Routine deviation from the above guidelines is not authorized."
This overall change, as reflected in the marked-up copy of the page from the current TS contained in Attachment 3, effectively results in two changes to the Technical 4
Specification, as further described below, htstification for Proposed Changes First, the proposed changes to TS 5.2.2.e will clarify the requirements for the plant manager or his designee to approve deviations from the overtime guidelines in accordance with administrative procedures. IP understands the current TS requirements potentially permit any of three levels of responsibility to approve deviations from the overtime guidelines: (1) the plant manager, (2) persons designated by the plant manager in 3
accordance with approved administrative procedures, and (3) levels of management higher than the plant manager. The last classification of personnel does not need to be specified in the TS since, for administrative activities such as this, higher levels of management always have the authority to authorize activities under their area of responsibility. The inclusion of this option in the TS results in confusion with rejard to the level of personnel the plant manager may designate for this function. It is not tl'e intent that only higher levels of management may be designated to perform this appraval for the plant manager.
The proposed changes do not alter any technical requirements since the same level of approval will be required; merely one option for this approval is being deleted. The proposed changes thus maintain the same required level of assurance of alertness for the unit staff who perform safety-related functions (e.g., licensed SROs, licensed R0s, radiation protection technicians, non licensed operators, and key maintenance personnel).
Secondly, the last paragraph within TS 5.2.2.e is being revised to conform the TS with GL 82 12 as the requirement to perform a monthly review ofindividual overtime is not specified in GL 82-12. When revising plant TS for implementation of NUREG-1434, licensees are given the option to simply commit to the requirements of GL 82-12 (in lieu ofincluding prescriptive wording as currently specified in the CPS TS). Thus, the NRC has allowed licensees to adopt TS requirements that do not require a monthly review of individual overtime. From experience gained in complying with this requirement at CPS,
to U-602462 PS-95-006 Page 3 of 4 I -
such a review has not been proven to provide any additional benefit (beyond the 1
requirements or controls prescribed in GL 82-12) for controlling individual overtime.
Rather, compiling a monthly report to facilit' te a monthly review and performing such a a
review has proven to be a costly administrative burden that is not warranted. Deleting this requirement will not adversely impact safety because individual overtime is procedurally controlled as required by the TS and in accordance with the intent of GL 82-12.
l Basis for Significant Hazards Determination In accordance with 10CFR50.92, a proposed change to the Operating License (Technical Specifications) involves no significant hazards considerations if operation of the facility in 4
accordance with the proposed change would not: (1) involve a significant increase in the probability or consequences of any accident previously evaluated, or (2) create the J
possibility of a new or different kind of accident from any accident previously evaluated, 1
or (3) involve a significant reduction in a margin of safety. The proposed changes are evaluated against each of these criteria below.
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(1)
The proposed changes do not involve a change to the plant design or operation.
The proposed changes do not affect the level of approval required for deviations from the overtime guidelines. As the Technical Specifications will continue to require deviations from the guidelines for overtime control to be approved and documented, the proposed changes do not adversely affect the level of alertness for the unit staff who perform safety-related functions. The current requirement for the plant manager (or his designee) to perform a monthly review ofindividual overtime is an after the fact review that has not been proven to provide any significant benefit with respect to the control ofindividual overtime. In addition, the proposed changes do not directly affect the automatic operation of equipment or systems assumed to mitigate the consequences of previously evaluated accidents. As a result, the proposed changes do not affect any of the parameters or conditions that contribute to initiation of an accident previously evaluated, and thus, the proposed changes cannot increase the probability or the consequences of any accident previously evaluated.
(2)
The proposed changes do not involve a change to the plant design or operation.
The proposed changes do not afTect the level of approval required for deviations from the overtime guidelines and do not adversely affect the level of alenness for the unit staff who perform safety-related functions. As a result, the proposed changes do not affect any of the parameters or conditions that could contribute to initiation of an accident, and thus cannot create the possibility of an accident not previously evaluated.
to U-602462 PS-95 006 Page 4 of 4 (3)
The proposed changes do not involve a significant reduction in a margin of safety.
As noted previously, the proposed changes do not change the level of approval required for deviations from the overtime guidelines. Only the requirement for an afler-the-fact monthly review is proposed to be deleted. To the extent that personnel alertness may be regarded as a margin of safety, deleting this requirement will not result in a significant reduction in a margin of safety since overtime controls consistent with the guidelines and requirements of GL 82-12 will continue to remain in place.
Based on the foregoing, IP concludes that this request does not involve a significant hazards consideration.
Attaciunent 3 to U-602462 PS-95-006 Page1of3 Attached Marked-Up Pages of the Technical Specifications j
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