ML20101Q482

License Change Request 92-05 to License NPF-57,changing TS 6.3 Re Unit Staff Qualifications & 6.4 Re Training to Clarify Current Requirements for Licensed Operator Training & Qualification

ML20101Q482
Person / Time
Site:	Hope Creek
Issue date:	07/08/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101Q485	List: ML20101Q482 ML20101Q487
References
NLR-N92083, NUDOCS 9207140297
Download: ML20101Q482 (7)

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PutAc Service

. Electric and Oas j Company Stanley LaBruna Pubhc Semco Electne and Gas Company P O. Box 230. Hancoc.ks Bridge, NJ 08038 609-339-1200 j vu %w, o saw twen.-s JUL 0 81992 i

NLR-N92083 l LCR 92-05 l

United States Nuclear-Regulatory Commission i Document Control Desk Washington, DC 20555 )

f Gentlemon:

}  !

! LICENSE AMENDMENT APPLICATION

}- CLARIFICATION OF REQUIREMENTS FOR LICENSED OPERATOR QUALIFICATIONS AND TRAINING HOPE CREEK GENERATING STATION i FACILITY OPERATING LICENSE NPF-57

! DOCKET NO. 50-354 i

i This letter constitutes an application for amendment to Appendix

A of Facility Operating License HPF-57 for the Hope Creek--

Generating Station and is being filed in accordance with the

provisions of 10CFR50.90. This amendment application proposes l changes to Technical Specifications (TSs)<6.3, " Unit Staff Qualifications" and'6.4, " Training" to clarify the current requirements for licensed operator qualifications and

_ training. Attachment 1 contains a detailed description of the

! proposed changes along with our'10CFRSO.92 analysis _of j significant hazards. Marked up TS pages showing'the proposed changes are included as Attachment.2.

l l Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall ba implemented within-60 days of issuance. This_ latitude permits time to complete the actions

necessary to implement the proposed changes.

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! Should you have any queations or; comments on this transmittal, do l not hesitate to contact u.

{ Sincerely, Affidavit / / ms i

Attachments (2) l Q

r 9207140297[9'20708 PDR ADOCK 05000354 h\\1

i. P PDR

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Documeb. Control Desk 2 i NLR-N92003 JUL 0 81992 i

l C Mr. T. T. Martin, Administrator - Region I l U. S. Nuclear Regulatory Commission

! 475 Allendale Road King of Prussia, PA 19406

Mr. J. Stone, Licensing Project Manager (Acting)

U. S. Nuclear Regulatory Commission One White Flint North

! 11555 Rockville Pike -

i Rockville, MD 20852 i

l Mr. T. P. Johnson (SOS) ,

j USNRC Senior Resident Inspector

{ Mr. K. Tosch, Chief NJ Department of Environmental Protection 1 i] Division of Environmental Quality )

Bureau of Nuclear Engineering

! CN 415 q Trenton, NJ 08625 l

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REF: NIR-N92083 LCR 92-05 STATE OF NEW JERSEY ) .)

) SS.

CO'UMTY OF' SALEM )

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

I am Vice President - Nuclear Operatione. of Public Servico Electric and Gas Company, and as such, I find the matters set forth in our letter dated Jul 0 81992 , concerning the Hope Croek Generating Station., are trua to the bast of my knowledge, information and belief.

/ s. - (Men Subscribe and Sworn to before no this day of ( '

, 1992 lAAA$

[NotaryPublicofNhaJersey ,

SHERRY L CAGl.E ,

NOTARY PUBUC 0F NEW JERSEY My commission expires on M * "3" * " * ' # ' #

A7TN3MNr 1 HOIMED GAIEES 70 71I3NICAL SITf.IFICA770E ]

l LIQ 2EE NOUENT APPLICATIW NIR--lG2083 CIARIFICNIYW OF RDGJIRIMNIS Im LIG2GFD II31 92-05 OIY3EM QUALIFICNITOG M4D TTRD(DC  !

IDPE GEEK CDURTDC STNTIN FACILITY OPD&TDC LICDEE NPP-57 J DOCKET 10. 50-354 I. Description of Onmg

!URD3-1262, " Answers to Questions at Public Meetings IWJartling Inplementation of Title 10, code of Foderal Regulations, Part 55 on Operatom' Licenses", was published in 11ovember 1987 to dmwnt the information ani guidance prvvided by the NRC on the requirements of the revised 10GR55, " Operator's Licenses".

The snswer to Question 98 of IURDG-1262 states that a facility with an accredit.ed training program, that has a store restrictive requirement in their Technical Specifications (TSs) than requirud by the rule, is permittod to apply for relief and that the charge would be considered an administrative charge to conforn with the ruvised regulation.

IURD3-1262 indicates that accreditation obviates the need to confom to Regulatory Guide (RG) 1.8, " Qualification arxl Training of Port.onnel for Nuclear Power Plants," Revision 2, and the associated standards endorsed by the PG 1.8 *1.e. , A!EI/NtS 3.1 and NEI/MG 18.1) . Specifically, Question 100 states mat a facility which has an accredited program is no lcrger obligated to 'ollcw BG 1.8 and that the NRC consideru the INPO guidelines equivalent to the staff guicelines contained in the 33. PSE&G's licensed operator training prograns have been accredited by INPO ard are based on a systems approach to trainirg. Licensed operator qualifications and the licensed operator retrainirn and replacement training programs nust cxrply with the requirenents of the revised 10GR55 which, as stated in IUREG-1262, supersedes the supplenental requirements spo:ified in the March 28, 1980 NRC letter to all licensees.

This amendment application is being subnitted in accordance t?ith the above guidance and proposes charges to 7Ss 6.3.1 and 6.4.1 to delete 7S requirements that are superseckxl based on accreditation of our licensed operator trainirg programs, adoption of a " systems approach to trainirg", and prunulgation nf the revised 10G R55. The following administrative charges are preparai to clarify the current requitutents for licensed cperator qualifications arri trainirg:

1. Delete the requiromit frun TS Section 6.3.1 that licensed operators moet or exceed the mininum qualifications of NGI/NE 3.1-1981 ard the supplemental requiruments specified in Sections A arrl C of the March 28, 1980 NPC letter to all licensees. This is replaced by a requiru ent that licensed operators emply with the requirements of 10CFR55.

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. Atttchm:nt 1 NLR-N92083

Clarification of Operator Qualifications and Training LCR 92-05 1

2. Delete the requirument frtn TS Section 6.4.1 that the liceirat operator retraining ard replacement training prtgrarrs moot or excood the requirwents of NGI/NG 3.1-1981 ard the supplcnontal Itquirments specified in Sections A aM C of Enclocum 1 of the lurch 28, 1980 NRC Ictter to all licensees. 21s is replaced by a requirment that the

, trainirg programs emply with the requirments of 10CIR55.

me licensod cperator qualifications and training programs will contints to be required to ccmply with the requirements of 10CFR55, ard the qualifications ard training programs for all other affected unit staff will centinue to be raquired to moet or exceed the stardards of NGI/NG 3.1-1981 (except for tho Radiation Protection )hnager to will continue to be required to moet or  !

exceed the qualifications of IG 1.8, September 1975) . I i

l II. Ibancn for 00D90 Weso changes are being pr-M to delete 7s requiromants that are superm*vi based on accreditation of our licensed operatcr trainirq program, aiption of a " systems aIproach to training", and pra ulgation of the revised 10dFR55,

" Operator's Licenses", Wich becam effective on May 26, 1987.

III. Justificaticn for_ Chi 1030 This Charge Rcquert involves a propocod administrative charge to the 7S to clarify the current requirements correrning licensed operator qualifications ard training sugans. m e TS requirements for all other affected unit staff qualifications ard trainirg prtgram ranin uncharged. We licensed operator cpslifications and trainirg programs will continue to be required to conply with the requircoents of 10CFR55. Licensed oferator qualifications and trainirg can he e an irdirect inpact on accidents previously evaluatedl however, the NRC ocnsidertd this impact durity the rulonnking process, and by pruulgation of the revised 10CFR55 rule, detcIminod that this inpact remains acocptable een licensees have ar' accredited licensed cperator training program which is based on a syst ms approach to training. m is is because the NRC h'un concluded, as stated in WRD3-1262, that the stardards ard guidelines applied by DTIO in their trainity accreditation program'are equivalent to those put forth or erdersed by the imC'. Therefore, naintainirg INIO accrtdited, systens based licensed operator training prtgrams is equivalent to mintainirg NRC approvod liomsod operator trainiry program which conform with applicable imC Regulatory Guides or NRC erdorsed NGI/NG stardarda.

Additicnally, the proposed TS changes do ret affect plant design, hardware, system operation, or proccdures.

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Attcch:B:nt 1 HLR-N92083 Clarification of Operator Qualifications and Training IIR 92-05 IV, Sinnificant ILuania OTnihdt;ito Evalmt100 The proposcd changes to the Hope Croek Generatirg Station Tochnical Spocifications:

1. Do not involvo a significant incruano in the protability or mummooo of an accidmt previously evaluata2.

The propocod TS changes are achninistrative ciurges to clarify the current ,

requitumnts for licensal cperator cpslifications ard trainirg programs l and to confona to the ruvised 10CTR55 rule. . Althatgh lleensed cperator l qualifications and trainirn can have an inilroct inpact on accidents '

previcusly evaluated, the NRC considered this inpact durity the j rulemakirg process, and by pruulgation of the i svised rule, oorcluded l that this inpact remains acceptable as log as licensed cperator training programs are accredited ard based on a systems approach to training.

PSEto's licensed operator trainirg prograns have bocn accredited by DRO ard are based on a systems approach to trainity. The propocal TS charges take credit for the DiPo accruditation of the licensed operator trainirn progmis and require continued ampliance with the requirements of 10C2Tt55. The 7S ruquirements for all other unit staff qualifications and trainirg programs remain uncharged. Werefore, the proposed is changes do not ircrease the probability or consoquences of an accident previously evaluated.

2. [b not croata the possibility of a new or different kind of accident frun any accidcnt previcusly evaluated.

The propocod TS charges are administrative ciarges to clarify the currunt requirements for licensed cperator qualifications and trainire programs ard to conform to the revised 10CFR55 rule. The changes do not affect plant design, hardware, systan operation, or procedures. Additican11y, in prumulgatirq the revised Ivle, the NRC concluded that the inpact of the revised rule on the possibility of creatirn a new or difforent kini cf accident is acceptable as Icsq as liceind operator trainirg programs are accredited and based on a systems approach to trainiJg. As notcd previously, PSEtwG's licensed operator trainirg programs have been accredited by DGO and are based on a systaas approach to training. The propocod TS charges take credit for the DRO accreditation and require continuod conpliarce with the requirements of 10CFR55. The TS ruquirunents for all other unit staff qualifications ard trainirg prograru remain uncharged. Therefore, the propocod TS charges do not create the pxsibility of a new or diffen .t kind of accident frun any accident previously evaluated.

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e Attcch2^,nt 1 liLR-1192 08 3 Clarification of Operator Qualifications and Training LCR 92-05

3. Do not involve a significant rodtetion in a mrgin of safety.

7ho proposed TS charges are administrativo dunges to clarify the current Itglirements for licensad operator qualificaticris and training pmgram and to confom to the revised 10Cm55 rule. Licensed operator qualifications and trainim can have an . indirect h: pact en a mrgin of safety; bcuever, the IUC, in prutulgatirq the revised rule, determined that the impact on mrgin of safety was acceptable When licensees mintain licensai operator trainim progtums that we arxrodited and based on a system approach to trainirg. hs noted previc;usly, PSE&G's licensed operator trainim program have boon accredited by 1100 and are based on a system approach to trainim. The IEC has concitded, as stated in liURID-1262, that the stardartis and guidelines applied by DHO in their training accreditation program are equivalent to those put forth ,

or endorsed try the 10C. As a result, mintainirq DUO accredited, l systems based licensed operator trainlig programs is equivalent to  !

mintaining !UC approved licensed operator training program which l confom with applicable 100 regulatory guides or 100 endorsed MISI/Alis standartis. The TS requiremnts for the qualifications and training progrars for all other unit staff remain uncharged. The licensed operator qualifications and trainhg program will continue to be required to cxmply with the requirements of 10CFR55. The mrgin of safety is maintained by virtue of maintainirg DUO accredital licansed operator trainire prug416 and thrugh contirmed canpliance with the requiremnts of 10cm55. Therefore, the propocod TS charges do not ruduco a mrgin of safety.

V. Conclusicri As dimwal in Item IV above, PSE&G has concluded that the propocod changes to the 7tchnical Specifications do not involve a sigaificant hazartis consideration since the charges (i) do not involve a significant increase in the prtbability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kird of accident frun any accident previously c. valuated, and (iii) de not involve a significant reduction in a mrgin of safety.

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