ML20097F678

Application for Amend to License NPF-57,proposing Change Which Would Require OM to Either Hold SRO License or to Have Held SRO License on Similar Unit

ML20097F678
Person / Time
Site:	Hope Creek
Issue date:	06/04/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20097F686	List: ML20097F678 ML20097F702
References
LCR-91-13, NLR-N91166, NUDOCS 9206150468
Download: ML20097F678 (8)

Text

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o p Pubhc Ser< ice Doctnc and Gan Con pany Stanley LaBruna Pubbe Service Dectric and Gas Company P,0. Box 236, Hancocks Bod;;e, NJ 08038 609 339-t?00 we ncu n cw.m JUN 0 41992 NLR-N91166 LCR 91-13 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION UNIT STAFF LICENSE REQUIREMENTS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby submits a request for amendment of Facility Operating License HPF-57 for the Hope Creek Generating Station in accordance with 10 CFR 50.90. A copy of th;s submittal has been sent to the state of New Jersey as indicated below pursiuant to the requirements of 10 CFR 50.91(b) (1) .

Technical Specifications currently require the Operations Manager to hold a senior reactor operator (SRO) license. The proposed change would require the Operations Manager to elther hold a SRO license or to have held a SRO license on a similar unit (BWR).

Attachment 1 includes a description, justification and significant hazards analysis for the proposed change.

Attachment 2 contains marked up Technical Specification.(TS) pages which reflect the proposed change. Please note that the pages affected by this change request are also affected by Hope Creek LCR 89-15 submitted on January 24, 1990 and which is currently under NRC review. Although the changes requested by these two submittals are different and independent, they affect some of the same TS items. Therefore, if LCR 89-15 is approved while'this amendment request is under review, the format and location of the changes contained in Attachment 2 will be affected. In this event, PSE&G will submit a revision to this submittal.

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4 Document Control Desk 2 NLR-N91166 ,JUN041992-PSE&G believes that this. submittal contains sufficient technical justification to conclude that a detailed specialist review should not be required and that the proposed change can be classified as a category 2 change.

Upon NRC approval, please issue a License Amendment which will be effective upon issuance and chall be implemanted within 60 days of issuance.

Should you have any questions or comments on this submittal, please do not hesitate to contact us.

Sincerely, ,

tj2 /

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Affidavit Attachments (2)

C Mr. S. Dembek Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. W. T. Russell Administrator - Region I Mr. Kent Tosch, Chief -New Jersey Department of Environmental Protection Division-of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton,-NJ 08625

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Ref: NLR-N91166 LCR 91-13 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

S. LaBruna, being duly sworn according to law deposes and says:

I am Vice President - Nuclear Operations of Public Service I find the matters set Electric forth onand Gas our Company, letter dated and as JUNsuch,992 0 41 , concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

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Subscrf d and Sworn o before m2 Letter prepared for review this _'f day of l/lLL. , 4-9fri lk9N and approval in 1991 -

final approval obtained in 1992

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/otary Puylic'of !MW JerseySHERRY U L CAGl.E NOTARY PUBUC OF NEW JERSEY My Commission Exp!rts March 5,1997 My Commission expires on

ATTACHMENT 1 REQUEST FOR LICENSE AMENDMENT UNIT STAFF LT ENSE REQUIREMENTS FACILITY OPERATING LICENSE NPF-57 IlOPE CREEK GENERATING STATION DOCKET NO. 50-354 s

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m tu NIR4191166 IDIE CRIIK ICR 91-13 I. Descrintion of_the Prononed ChanSE2 Thia amendment request proposos the following:

1. SpecifiestJon 6.2.2.f is revised to doloto the Operations Mangor as a +osition requiring a SRO licenso.

2. A now Specification 6.2.2.g is added to delinaato the requiromonto for the Operations Maragor position. ,

3. Specification 6.3.1 is revised and a now Specification 6.3.2 is added to dolineate tne requirements for the Operations Manager position.

11. Reason for the Proposed Changga In order to maintain a SRO licenso as currently required, the Operaticr.; Manager (OH) must attend roqualification training for four two-week segments occh year. Dur1ng the time that the OM in in training, that individual is displaced from the position's managerial activition cnd the operating Engincor (OE) must fulfill the responsibilitics of both positions. This creates additional burden for both individuals.

The deletior of the requiroment for the OM to hold a SRO licenso will enhanco both the OM's and OE's ability to offectively carry out their primary responsibilition and will improve the consistency and continuity of managerial oversite for the Operations Department. PSE&G balloves that this chango will have an overall positive impact on the safo and efficient operation of the Hopo Crook Generating Station.

UI. JustificatLion for the Pronotw1_gjiangga The Operations Department at Hopo Crook Generating Station is managed through the Operations Manager (OM), operating Engineer (OE) and the on-shift supervision consisting ef the Senior Nuclear Shift Supervisor (SNSS) and Nuclear Shift Supervisor (NSS). Technical Specifications currently require all of those positions to hold a SRO license. This requirement is in I accordance with hilSI/ANS-3.1-1981, "Solection, Qualification and Training of Personnel for Nuclear Power Plants".

Current industry guidanco provided by ANSI /ANS-3.1-1987 allows relaxation of the SRO licenso requiremont for the OM position, provided cortain conditions are met. This allows greater management flexibility while maintaining the high standards nocoscary to ensuro safe and officient operation of a nuclear I power plant. PSE&G supports this philosophy ar.d is thereforo submitting this amendment request.

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10R-U913 G6 1DPE CREEK IfR 91-13 Tne proposed chango would require the Operations Manager to either hold a SRO license or to have held a SRO license on a  :

similar (BWR) unit. Those special requirements ensure that a i selected candidate has demonstrated knowledge at the SRO lovel, j although he/she may i.ot hold a current SRO licenso. Insofar as i the OE is required to hold a SRO license, senior licensed I personnel on shift will continue to be directly managed by a SRO licens6d individual.

Based on the specific knowledge requirements to fulfill the OM '

i position, and the requirement for the OE to hold a SRO license, PSE&G belloves that the issuance of this amendment request will not adversely impact plant safety.

IV. Significant 11 azar.ds considerat. ion Eva(aation PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to determine whether our request involves a significant hazards considoration. We have determined that operation of the llopo Crook Generating Station in accordance with the proposed changes:

1. Will not involvo a significant incredse in the probability or consequences of an accident previously evaluated.

An individual selected to fill the OM position will have not current industry guidance on the selection, qualification and training of personnel for nuclear power plants in accordance with ANSI /ANS-3.1-1987 and as specified in Technical Specifications.

2. Will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The deletion of the requirement for the OM to hold a SRO license, unlike a procedure or design change, does not constitute a potential new accident precursor.

3. Will not involve a significant reduction in a margin of safety.

Operations Department personnel will continue to be directly managed by a SRO licensed individual.

Candidates who are not currently holding SRO licenses and who are selected _for.the OM position nust meet the education, experience and training requirements of ANSI  !

N18.1-1971 and the special requirements delineated in Technical Specifications.

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NIR-N91166 IOP8 01EEK 10191-13 Additionally, this chango is expocted to have an overall positive inpact on safety by onhancing both the OM's and OE's ability to offectively carry out their primary responsibilities snd b-/ improving the consistency and continuity of managotial oversite for the operations Department.

V. Conclusion Based on the procoding discussion, PSE&G has concludod that the proposed change to the Technical Specificationn does not involvo a significant hazards considoration insofar an'the chango: (1) doos not involve a significant increase in the probability or consequences of an acnident previously evaluated, (ii) does not 4 creato the possibility of a now or different kind of accident from any accident previously evaluatod, and (iii) does not involve a significant reduction in a margin of safoty.

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lilR-1191166 1101E CREEK IIR 91-13 ATTACllME!1T 2 REQUEST FOR LICENSE AMENDMENT UNIT STAFF LICENSE REQUIREMENTS FACILITY OPERATING LICENSE NPF-57

!! OPE CREEK GENERATING STATION DOCKET No. 50-354

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