ML20138N506
| ML20138N506 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/01/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20138N495 | List: |
| References | |
| NUDOCS 8511050210 | |
| Download: ML20138N506 (8) | |
Text
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of-Docket Nos. 50-277 50-278
. PHILADELPHIA ELECTRIC COMPANY SECOND AMENDMENT TO FEBRUARY 11, 1982 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 8511050210 851101 ADOCK 0 % 2 7 DR L
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION i
In the Matter of a
Docket Nos. 50-277 i
50-278 PHILADELPHIA ELECTRIC COMPANY SECOND AMENDMENT TO FEBRUARY 11, 1982 APPLICATION FOR AMENDMENT i
i OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On February 11, 1982, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56, filed an Application for Amendment of the Licenses which requested that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by incorporating certain NUREG-0737 raquirements.
i Generic Letter No. 83-02, issued January 10, 1983, Provided a Standard Technical Specification for certain NUREG-t I
E Generic Letter No. 83-02, issued January 10, 1983, provided a Standard Technical Specification for certain NUREG-0737 requirements, including the overtime limits identified in NUREG-0737, Item I.A.1.3.
On August 24, 1983, Licensee amended its February 11, 1982, Application to conform to the guidance of this Standard Technical Specifications.
The amended Application included the addition of overtime work restrictions for certain plant personnel.
The second paragraph of the Standard Technical Specification was excluded from the overtime work restriction proposed in the amended Application.
The reason for its exclusion was to avoid the use of non-explicit terminology such as " routine heavy use", " objective", " unforeseen", and
" substantial".
Subsequently, the NRC s'.af f reviewing the Application requested incorporation of this paragraph into the Technical Spe ci fications.
Accordingly, Licensee hereby further amends its Application of February 11, 1982, as amended August 24, 1983, by deleting the proposed revised Technical Specification page 265 referred to in the August 24, 1983 Amended Application and substituting therefore updated page 268.
The Bases on page 266 are unchanged and page 266 is resubmitted as page 269.
The changes in page numbers reflect a redistribution of material resulting from Amendments No. 102 and 104, for Units 2 and 3, respe ctively, issued August 3, 1984.
i The amendment Application incorporates the second paragrnph of the Standard Technical Specifications previously l
referenced with some minor editorial changes and a clarification that acknowledges the presence of two units at Peach Bottom.
A minor revision to Specification 6.19.1 provides additional clarification regarding the titles of personnel covered by these sp3ci fications.
Additionally, an editorial change is requested to Speci fication 6.19.2.c.
Finally, a change is requested to Specification 6.19.3 to permit deviations from the overtime limits to be be authorized by a senior staf f member.
This would permit the delegation of this authority by the employing of ficer to the senior staf f member responsible for the supervision of the group in which a deviation from the overtime limits is requested.
In this manner, the administrative burden would be distributed among several members of the station management.
Monthly review of the deviations will be limited to the employing officer or his designee.
As stated in the August 24, 1983 Application, the
. current Peach Bottom overtime policy regarding shift operating personnel and health physics-chemistry technicians complies with the four overtime guidelines specified in the most recent NRC criteria.
In correspondence dated September 20, 1985 (M. J.
Cooney, PEco, to H.
L. Thompson, Jr., NRC), Licensee expanded the commitment regarding the four overtime guidelines to include key maintenance, construction, and testing personnel.
However, some minor deviations exist between the administrativeiprovisions of Specification 6.19.3 and the previous commitments.
For this reason and to reflect the additional guidance incorporated into Specification 6.19.2, Licensee proposes that the overtime specification take effect three months from the issuance date of the License Amendment to provide aufficient time for the development of the necessary administrative controls and procedures.
Significant Hazards Consideration Determination t
This Application, as amended, does not reduce the requirements of the current Technical Specifications.
The 4
proposed change constitutes additional administrative controls not presently included in the Technical Specifications, and is in the interest of enhancing safe operations and complying with the 4
requirements of NUREG-0737.
The Commission has provided guidance 9
concerning the application of the standards for determining r
whether license amendments involve no significant hazards j
(48 FR 14870).
One considerations by providing certain examples of the examples (ii) of actions involving no significant hazards consideration is a change that constitutes an additional limitation, restriction, or control not presently included in the F
Technical Speci fications.
The change proposed by this application fits this example of an action not involving a significant hazards consideration.
The proposed changes do not involve a 'significant increase in the probability or consequences i
i of an accident previously evaluated since the proposed overtime t
limits are intended to reduce personnel fatigue and consequently improve their attentiveness to safety-related activities in the
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. interest of reducing the probability or consequences of an accident.
For the same reason, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The changes do not involve a significant reduction in the margin of safety since they reduce the possibility of personnel error in activities related to nuclear safety.
The Plant Operating Review Committee and the Nuclear 4
Review Board have reviewed the proposed changes to the Technical Specifications, and have concluded that they do not involve an unreviewed safety question or a significant hazards consideration, and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY
/
Vice Presiden# (
i
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF PHILADELPHIA S.
L. Daltrof f, being first duly sworn, deposes and says:
t That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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a j j Subscribed and sworn to beforemethis/
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of (EJJL /M Notary Public PATRICIA 0. SCHOLL Notery Publ c, Philade;phia, Phi!,dct:hia Co.
My Commission bpass February 10. 1966 m
~,-s,
CERTIFICATE OF SERVICE I certify that service of the foregoing Second Amendment was made upon the. Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to Thomas R. Genisky, Director, Bureau of Radiological Protection, P. O.
Box 2063, Harrisburg, PA 17120; all this 1st day of Novenbar
, 1985.
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E ne/J." Bradley
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Attorney for Philadelphia Electric Company
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