ML20096G633
| ML20096G633 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/19/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20096G634 | List: |
| References | |
| NUDOCS 9205260178 | |
| Download: ML20096G633 (8) | |
Text
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10 CFR 50.90 PillLADEI.I'lllA El.ECTRIC COMI'ANY NUCLEAR GROUP llEADQUARTERS 955-65 CilESTERBROOK BLVD.
WAYNE, PA 19087 5691 (215) 640 6000 l
May 19, 1992 l
NUCtIAR ENGINCER.fNO A SLPVICES dei %IUMLNT Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.
S.
Nuclour Regulatory Commission ATTN Document Control Desk Washington, DC 20555 l
SUBJECT:
Lir urick Generating Station, Units 1 and 2 Technical Specifications Change Request Gentlemen:
Philadelphia Electric Company is submitting Technical Specifications Change Request (TSCR) No. 91-01-0, in accordance with 10 CFB 50.90, requesting an amendment to the Technical
-Specifications (TS) (Appendix A) of Operating License Nos. NPF-39 and NPF-85.
Information supporting this Change Request is contained in Attachment I to this letter, and the-proposed replacement pages are centsined in Attachment 2.
This subt.iittal requests changes to TS Sections 6.3.1 and 6.4.1 to-clarify the current requirements for licensed operator qualifications ~and training.
These changes are being proposed to delete..TS requirements that cre superseded based on the licensed operator training programs being accredited-and based on a
" systems approach to training," and promulgation of the revised 10 l'
CFR 55, " Operator's Licenses," which became effective on May 26, 1987.
If you have-any questions regarding this matter, please contact us.
Very truly yours, f FEE I
G. J. Geck, Manager -
Licensing-Section Attachments cc T.
T.
Martin, Administrator,-Region I, USNRC T.
J.
Kenny, USNRC Senior Resident inspector, LGS W.
P.
Dornsife, Director, PA Eureau of Radiological Protection 9205260178 920519
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A PDR ADOCK 05000352 P
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COMMONWEALTil OF PENNSYLVANIA ss.
" COUNTY OF CliESTER D.
R.
lielwig, being first duly sworn, depos<. ' and says:
J That he is Vice President of Philadelphia Electric Company; the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License Nos. NPF-39 and NPF-85 (Technical Specifications Change Request No. 91-01-0) to clarify the licensed operator qualification and-training requirements, and knows that the contents thereof; and that the statements and matters set forth therein are true and correct to the best of hie knowledge, information and belief.
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ATTACHMENT 1 LIMERICK GENERATING STATION Units 1 and 2 Docket Nos.
50-352 50-353 License Nos.
NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST
" Clarification of Licensed Operator Qualification and Training Requirements" Supporting Information for Changes - 5 pages o
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9 Philadelphia Electric Company (PEco), Licensee under j
Facility Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A of the Operating Licenses be amended as proposed herein to clarify the requirements for licensed operator qualifications and training.
The proposed changes are indicated by a vertical bar in the margin of TS pages 6-6 and 6-7 for both LGS Unit 1 and Unit 2 TS, and are contained in Attachment 2.
We request the changes proposed herein be effective upon issuance of the Amendments.
This Change Request provides a discussion and description of the proposed TS changes, a safety assessment of the proposed TS
- changes,'information supporting a finding of No Significant Hazards Consideration, and information supporting an l:
Environmental Assessment.
Discussion and Description of the Proposed Changes.
On Msrch 20, 1985, the NRC issued " Commission Policy Statement on Training and Qualification of-Nuclear Power Plant Personnel" (50FR11147) which endorsed the training accreditation program developed by the Institute of Nuclear Power Oparations (INPO), in association with its National Academy for Nuclear Training.
Subsequen*.ly, NRC Generic Letter (GL) No. 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10CFR55 and Conforming Amendments," dated March 19,-1987, and NUREG-3262, Answers to Questions at Public l
Meetings Regarding Implementation of Title 10, code of Federal l
Regulations, Part 55 on Operators' Licenses," published November 1987, indicated.that the NRC will accept a licensee's licensed operator training-program if it is certified to be accredited and l
based on a " systems approach to training," and that this L
accreditation obviates-the need to-conform to Regulatory Guide (RG)-1.8, Qualification and Training of Personnel for Nuclt I
Power Plants," Revision 2, April 1987, and Standard ANSI /ANS J.1, L
" Selection, Qualification and Training of Personnel for Nuclear l
Power Plants."
PECo, by letters dated April 27, 1990 and June 19, 1990'in response to GL 87-07, certified that the licensed operator training programs for LGS, Unita 1 and 2, were initially accredited by INPO on October 30, 1986 and then again on January 25, 1990, and that these programs are based on a systems approach to training.
TS;Section=6.3.1, " Unit-Staff Qualifications," for LGS, Units 1 and 2,-currently states "Each member of the unit staff shall meet I
or exceed the minimum qualifications of ANSI /ANS 3.1-1978.
.The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifications of the supplemental requirements specified in-Sections A and C of Enclosure 1 of the March 28, l
1980 NRC letter to all licensees."
Additionally, TS Section l
6.3.1,
" Training," for LGS, Units 1 and 2, currently states, "A
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retraining and replacemant training program.
. shall meet or exceed the requirements of ANSI /ANS 3.1-1978 and 10CFR55 and the supplemental requirements specified in Sections A and C of Enclosuro 1 of the March 28, 1980 NRC lottor to all licensees.
Licensed operator qualifications and the licensed operator retraining and replacement training programs must comply with the requirements of the revised 10CFR55 which, as stated in NUREG-1262, supersedes the supplemental requirements specified in the March 23, 1980 NRC letter to all licensees.
Also, NUREG-1262 indicates that standard ANSI /ANS 3.1 and RG 1.8, which endorsee ANSI /ANS 3.1, are superseded by INPO accreditation in accordance with the revised rule, and that licenseos r.1y submit a request to the NRC for an administrative change to thuir TS to delete the TS requirements which have been superseded.
Accordingly, the following administrative changes are proposed to TS Sections 6.3.) and 6.4.1 for LGS, Unita 1 and 2 (see ), to clarify the current requirements for licensed operator qualifications and training.
1.
Delete the requirement from TS Section 6.3.1 that licensed operators shall meet or exceed the minimum qualifications of
" ANSI /ANS 3.1 1978" and "the supplomontal requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licenseos."
2.
Delete the requirement from TS Section 6.4.1 that the licensed operator retraining and replacement training programs ".
.shall meet or excoed the requirements of ANSI /ANS 3.1-1978.
and the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.
As shown in the proposed TS Sections 6.3.1 and 6.4.1, the licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55, and the qualifications and training progrcms for all other affected unit staff will continue to be required to meet or exceed thF standards of ANSI /ANS 3.1-1978 (except for Senior Heitth-Physicists who will continue to be required to moot or exceed the qualifications of RG 1.8, September 1975).
Safety Assessment This Chango Request involves a proposed administrative change to the TS to clarify the current requirements concerning licensed operator qualifjcations and-training programs.
The TS requirements for all other affected unit staff qualifications and training programs remain unchanged.
The licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55.
Licensed operator qualifications and training can have an indirect. impact on accidents previously evaluated.
Howevar, the NRC considered this impact during the rulemaking process, and by promulgation of the revised 10CFR55 rule, determined that this impact remains
~
Page 3 unchanged when licensees certify, in response to GL 87-07, that their licensed operator training piograms are accredited and are based on a systems approach to training.
This is because the NRC has concluded, as stated in NUREG-1262, that the standards and d
guidelines applied by INPO in their training accreditation 1
program are equivalent to those put forth or endorsed by the NRC.
]
Therefore, maintaining INPO accredited, systems based licensed 3
L operator training programs is equivalent to maintaining NRC j
approved licensed operator training programs which conform with applicablo NRC RGs or NRC endorsed ANSI /ANS standards.
Additionally,.the proposed TS changes do not affect plant design, hardware, system operation, or procedures.
Information Supporting a Finding of No Significant_ Hazards Contidoration l
We have concluded that the proposed changes to the LCS TS, which clarify the qualifiertion and training requirements for licensed operators, do not ccastitute a Significant Hazards Convideration.
In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.
1.
The proposed TS changes do not involve a significant increase in_the probability or consequances of an accident previously evaluated.
She proposed TS changes are administrativo changes to clarify the current requirements for licensed operator qualifications and training programs.
Although licensed operator qualifications and training can have an indirect impact on accidents previously evaluated, the NRC considered this impact during the rulemaking process, and by promulgation of the rule, concluded that this impact remains unchanged as long as licensed operator training programs are certified to be accredited and based on a systems approach to training in response to GL 87-07.
PECo provided such certification for LGS, Units 1 and 2, by letters dated April 27, 1990 and June 19,.1990.
The proposed TS changes take credit for the INPO accreditation of the licensed operator training programs and require continued compliance with the requirements of 10CFR55.
The TS requirements for all other unit staif qualifications and training programs remain l
unchanged.
Therefore, the proposed TS changes do not increase the probability or consequences of an accident previously evaluated, i
2.
The proposed TS changes do not create the possibility of a new or different kind of accident from any accident p_reviously evaluated.
The proposed TS changos are administrative changes to clarify.the current requirements for licensed operator qualifications and training programs.
Although licensed operator qualifications and training can have an indirect
Page 4 j
impact on the possibility of a new or different kind of accident from any accident previously etaluated, the NRC considered this impact during the rulemaking process, and by promulgation of the rule, concluded that this impact remainL unchangvt as long as licenced operator training programs are 1
certifieo to be accredited and based on a systems approach to training in response to GL 87-07.
PECo provided such certification for LGS, Units 1 and 2, by letters dated April t
27, 1990 and June 19, 1990.- The proposed TS changes take credit for the INPO accreditation of the licensed operator training programs and require continued compliance with the requirements of 10CFR55.
The TS reqotrements for all other unit staff qualifications and training programs remain unchanged.
Additionally, the proposed TS changes do not affect plant design, hardware, system operation, or procedures.
Therefore, the proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed TS changes do not involve a significant J.
reduction in a margin of safety.
The proposed TS changes are administrative changes to clarify the current requirements applicable to licensed operator qualifications and training programs.
The TS requirements for the qualifications and training programa for all other unit staff remain unchanged.
The licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55.
Licensed operator qualifications und training can have an i
indirect impact on a margin of safety.
However, the NRC considered this impact during the rulemaking process, and by promulgation of the res! sed 10CFR55, determined that this impact remains unchanged when li'ansees certify that their licensed-operator training programs are accredited and based on a sybtems approach to training in response to GL 87-07.
PEco provided such certification for LGS, Units 1 and 2, by letters dated April 27, 1990 and June 19, 1990.
The NRC has concluded, as stated in NUREG-1262, that the standards and guidelines applied by INPO in their training accreditation prograu are equivalent to those put forth or endorsed by the NRC.
As a renult, maintaining INPO accredited, systems based licensed operator training programs is equivalent to maintaining NRC approved licensed operator training progrars which conform with applicable NRC RGs or NRC endorseJ l
ANSI /ANS standards.
The margin of safety is maintained by virtue of maintaining INPO accredited licensed operator training programs and through continued compliance with the requirements of 10CFR55.
Therefore, the proposed TS changes do not reduce e margin of safety.
=
Page 5 r
Information supporting an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the requested changes conform to the criteria f or "er t ions eligible for categorical exclusion," as specif1?d in 10CIR51.22(c)(10).
The requested changes will have no impact on the environment.
The requested changes do not involve a significant hazards consideration as discussed in the preceding section.
The requested changes do not involve a significant change in the types or significant increase in the amounts of any offluents that may be released offsite.
In addition, the proposed changes do not involve a significant increase in individ..a1 or cumulative occupational radiation exposure.
Conclusion The Plant Operations Re\\lew Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not jnvolve an unroviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public, i
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