ML20115H152

Proposed Tech Specs Section 6.2.2.i Re App a

ML20115H152
Person / Time
Site:	Nine Mile Point
Issue date:	07/12/1996
From:	NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML20115H148	List: ML20115H145 ML20115H151 ML20115H152
References
NUDOCS 9607220241
Download: ML20115H152 (7)

Text

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s ATTACHMENT A NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 Pronosed Changen to Technical Soncifications Replace the existing page 6-2 with the attached revised page 6-2.

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l 9607220241 960712  !'

PDR ADOCK 05000410 P PDR '

6.0 ADMINISTRATIVE CONTROLS s

ORGANIZATION UNIT STAFF 6.2.2 (Continued)

f. A Licensed Senior Operator or Licensed Senior Operator Limited to Fuel Handling shall be responsible for all movement of new and irradiated fuel within the site boundary. All core alterations shall be directly supervised by a Licensed Senior Operator or Licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation. All fuel moves within the core shall be directly monitored by a member of the reactor analyst group.

g. A Fire Brigade

• of five members shall be maintained on site at all times. The Fire Brigade shall not include the Shift Supervisor and the two other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.

h. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g., Licensed Senior Operators, licensed operators, health physicists, auxiliary operators, and key maintenance personnel.

i. Adequate shift coverage shall be maintained without routine heavy use of overtime. The ,

objective shall be to have operating personnel work an 8 to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> day, nominal 40-hour l week while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major main;enance, or major unit modifications, on a temporary basis the following guidelinea sr.all be followed:

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

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3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including shift I turnover time.

• The radiation protection qualified individual and Fire Brigade composition may be less than the mir.imum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

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j NINE MILE POINT - UNIT 2 6-2 Amendment No. d, M

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'. l ATTACHMENT B NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 Hand Marked-Uo Version of the Pronosed Chanaes The current version of the NMP2 Technical Specifications page 6-2 has been hand-marked up to reflect the proposed change.

" l 6O ADMfNIS?RATIVE CONTROLS i i

/ ORGANIZATION UNIT STAFF 1

6.2.2 (Continued) j

f. A Licensed Senier Operator or Licensed Senior Operator Limited to Fuel l Wandling shall be responsible for all movement of new and irradiated fuel l

.itnin the site boundary. All core alterations snall be directly supervise:: l cy a Licensed Senior Operator or Licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during.this operation. All fuel moves within the core shall be directly monitored by a member of the reactor analyst group.

g. A Fire Brigade

• of five members shall be maintained on sitt at all times.

The Fire Brigade shall not include the Shif t Supervisor and the two otner members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other. essential functions during a fire  ;

emergency.

h. Administrative procedures shall be developed and implemented to limit the working hours of Unit staff who perform safety-related functions; e.g.,

Licensed Senior Operators, licensed operators, health physicists, auxiliary a operators a_ key maintenance personnel, an 9 -to 12 houv- day i nensma.

-'-+^-Adequate 1hift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a = =;I 9 hum Joy, 40-hour week while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major unit modifications, on a temporary basis the following guidelines shall be followed:

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.  ;

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any  ;

24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more J than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, l including shift turnover time.

• The radiation protection qualified individual and Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

6-2 Amendment No. 9, 14 NINE MILE POINT - UNIT 2 1

9001180201 900108 PDR ADOCK 05000410 P PNU

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s ATTACHMENT C NIAGARA MOHAWK POWER CORPORATION LICENSE NO, NPF-69 DOCKET NO. 50-410 hanortina information and no Slanificant Harards Consideration Analvsis l i

INTRODUCTION Nine Mile Point Unit 2 (NMP2) Technical Specifications Section 6.2.2.1. establishes the '

normal work hours for NMP2 operating personnel as, "...a normal 8-hour day,40-hour _ l week..." The proposed change revises this section to state, "...an 8 to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> day, t

nominal 40-hour week...". The change is consistent with Section 5.2.2.e. of NUREG-1434, i Rev.1, " Standard Technical Specifications, General Electric Plants, BWR/6." The change is i also similar to amendment requests previously approved by the Nuclear Regulatory i Commission Staff which were submitted by Northern States Power Company (Prairie Island Nuclear Generating Plant, Units 1 and 2, approved May 4,1993), Public Service Electric & j Gas Company (Hope Creek Generating Station, approved April 22,1991), Detroit Edison  !

(Fermi 2, approved August 27,1990), and Georgia Power Company (Hatch Units 1 and 2, 'i ap' proved November 24,1987). I i

EVALUATION l

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Establishing operating personnel hours at, "an 8 to 12-hour day, nominal 40-hour week,"

improves the quality of life for operating personnel and does not adversely affect their i performance. The change also reduces the potential for shift-to-shift misinformation and l enhances overall plant operations and maintenance coherence by a potential reduction in i errors by operating personnel because interruptions in activities caused by shift turnovers are reduced. Furthermore, implementation of 12-hour shifts potentially allows completion of plant testing and other important evolutions that normally require more than 8-hours to complete, without the interruption of shift turnovers that result in a loss of continuity. This increases the productivity and effectiveness of the operating personnel and persorinel of other departments that require operations support.

Operating personnel awcreness of plant conditions is maintained. All technical specification sensor checks remain on the required technical specification frequencies. Shift checks to monitor plant conditions will continue. Since NMP2 Technical Specifications define shift frequency as "at least once par 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," any possible reduction in the number of shift checks resulting from the proposed change (reduction from 3 checks to 2 checks per day),

would be in accordance with the NMP2 licensing bases.

While the length of operating personnel shifts is increased, the intent of this section is to j ensure excessive overtime is not utilized to complete normal or routine operations i department tasks. The proposed change meets the intent of the section in that overtime remains controlled by site administrative procedures in accordance with the NRC Policy Page 1 of 3

Statement on working hours (Generic Letter 82-12). NMP2 has been implementing 12-hour operator shifts for over one year on a trial basis. Over this period, plant productivity and the effectiveness of operations personnel have been maintained. In addition,12-hour shifts are consistent with the work schedules of other plants in the nuclear industry.

CONCLUSIONS The proposed change in operating personnel shift length is consistent with Section 5.2.2.e.

of NUREG-1434, Rev.1, " Standard Technical Specifications, General Electric Plants, BWR/6." The change meets the intent of the current NMP2 Technical Specification section in that overtime remains controlled by site administrative procedures in accordance with the NRC Policy Statement on working hours (Generic Letter 82-12). In addition, NMP2 has sufficient operating personnel to ensure that excessive use of overtime is not required for conduct of normal plant operations. Utilization of 12-hour shifts is also consistent with the  !

work schedules of other plants in the nuclear industry. NMP2 has employed 12-hour I operator shifts for over one year with no discernable decline in the performance of operating l personnel. For these reasons, this proposed change does not endanger the health and safety of the public and is consistent with common defense and security.

ANALYSIS NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS 10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis, using the standards in 10CFR50.92 concerning the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91, the following analyses have been performed with respect to the requested changes.

ENVIRONMENTAL CONSIDERATION 10CFR51.22 provides criteria for, and identification of, licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. Niagara Mohawk has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(10). Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

The ooeration of Nine Mile Point Unit 2. In accordance with the orooosed amendment. will not involve a sionificant increase in the orobability or consecuence of an accident oreviousiv evaluated.

Establishing operating personnel work hours at, "an 8 to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> day, nominal 40-hour week," allows normal plant operations to be managed more effectively and with enhanced continuity. Thare has been no noticeable increase in safety related problems during the trial period. Overtime remains controlled by site administrative procedures in accordance with the NRC Policy Statement on working hours (Generic Letter 82-12). The probability for operating personnel error due to (1) incomplete or insufficient turnover or (2) interruption of in-plant maintenance and testing is reduced. No physical plant modifications are involved, and none of the precursors of previously evaluated accidents are affected. Therefore, this change wi!! not involve a significant increase in the probability or consequences of an accident previously evaluated.

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• l The coeration of Nine Milo Point Unit 2. In accordance with the oronosed amendment will i not create the nossibility of a new or different kind of accident from any accident oreviousIV

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evaluated.

Establishing operating personnel hours at, "an 8 to 12-hour day, nominal 40-hour week,"

improves the quality of life for operating personnel and does not adversely affect their performance. Overtime remains controlled by site administrative procedures in accordance with the NRC Policy Statement on working hours (Generic Letter 82-12). No physical modification of the plant is involved. As such, the change does not introduce any new failure modes or conditions that may create a new or different accident. Therefore, operation in accordance with the proposed amendment will not create the possibility of a new or different kind ri accident from any previously evaluated.

The coeration of Nine Mile Point Unit 2. In accordance with the cronosed amendment will not involve a significant reduction in a margin of safetn Establishing operating personnel hours at, "an 8 to 12-hour day, nominal 40-hour week,"

improves the quality of life for operating personnel and does not adversely affect their performance. This change also decreases the risk of miscommunication between shifts and increases operations and maintenance efficiency by promoting continuity in ongoing plant activities. Overtime remains controlled by site administrative procedures in accordance with the NRC Policy Statement on working hours (Generic Letter 82-12) and is consistent with the improved Standard Technical Specifications. The proposed change involves no physical modification of the plant, or alterations to any accident or transient analysis. There is no Basis to section 6 of the Technical Specifications, and the changes are administrative in nature. Therefore, the change does not involve any significant reduction in a margin of safety.

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