ML20206U436
| ML20206U436 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/30/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20206U424 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM GL-83-02, GL-83-2, NUDOCS 8610070500 | |
| Download: ML20206U436 (8) | |
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 THIRD AMENDMENT TO FEBRUARY ll, 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 P
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 THIRD AMENDMENT TO MEBRUARY 11, 1982 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On November 1, 1985, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56, for Peach Bottom Atomic Power Station Unit Nos. 2 and 3, respectively, amended its February 11, 1982 Application for Amendment of the Licenses which had requested that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by incorporating overtime work restrictions for certain plant personnel.
The February 11, 1982 Application had been previously amended on August 24, 1983.
Subsequently, on June 11, 1986, the NRC Peach Bottom Project Manager, informed the Licensee that the NRC staff reviewing the Application require changes to the overtime limits proposed in the November 1, 1985 Application as follows:
1.
Add the phrase "for refueling, major maintenance, or major unit modification, on either unit, on a temporary basis" to the second paragraph of the work limits to conform with the standard overtime policy enclosed with Generic Letter No. 82-12, Nuclear Power Plant Staff Working Hours.
The words "on either unit" are retained as a clarification that acknowledges the presence of two units at Peach Bottom.
2.
Substitute the titles of the managers authorized to approve deviations from the overtime limits for the general description of " employing officer".
l 3.
Replace the proposed review requirement of overtime deviations with the following: " controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the (Plant Superintendent) or his designee to assure that excessive hours have not been assigned."
I Accordingly, Licensee hereby further amends its Application of February ll, 1982, as amended August 24, 1983 and November 1, 1985, by deleting the proposed revised Technical Specification page 268 referred to in the November 1,1985 Amended Application and substituting therefor updated page 270 which is attached hereto and incorporated herein by reference.
The Bases on page 269 are substantively unchanged and are resubmitted as..
.page'271.
The revisions to the November 1, 1985 Application are identified by a vertical bar in the margin of the attached pages, and conform to the revisions requested by the NRC on June 11, 1986.
Additionally, the reference to "Research and Testing Division personnel" in proposed Technical Specification 6.20.1 is replaced with the generic description of " testing personnel".
This change would avoid the need to amend the license in the event of an organizational title change.
Safety Analysis Studies indicate that with fatigue, especially because of loss of sleep, an individual's detection of visual signals deteriorates markedly, the time it takes for a person to make a decision increases, and more errors are made.
Other studies show that fatigue results in personnel ignoring some signals because they develop their own subjective standards as to what is important, and as they become more fatigued, they ignore more signals.
The objective of the overtime limits specified in this section is to assure that, to the extent practicable, personnel are not assigned to perform safety-related functions while in a fatigued condition.
The controls will 1.imit both continuous working hours, and accumulated working hours during any seven-day period.
Additionally, the controls will ensure adequate rest breaks between work periods.
The effect of these overtime work limits will be to reduce personnel fatigue, and consequently reduce the probability of personnel error, and improve personnel attentiveness to safety-related activities... _.
Significant Hazards Consideration Determination This Application, as amended, does not reduce the requirements of the-current Technical Specifications.
The 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 requirement I.A.1.3, Shift Manning of NUREG-0737, Clarification of TMI Action Plan Requirements.
T,he commission had provided guidance concerning the application of the standards for determining whether license amendments involve no significant hazards considerations by providing certain examples (48 FR 14870).
One 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 Technical Specifications.
The change proposed by this application fits this example of an action not involving a significant hazards consideration since it incorporates the overtime limitations, restrictions, and controls requested by the NRC in Generic Letter No. 83-02, issued January 10, 1983, and in NUREG-0737, Item I.A.l.3.
1.
The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated since the proposed overtime limits are intended to reduce personnel fatigue and consequently improve their attentiveness to safety-related activities in the interest of reducing the
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probability or consequences of an accident.
2.
The proposed changes do not create the possibility of a new or different. kind of accident from any accident previously evaluated since the reduction in personnel fatigue resulting from these changes enhances plant personnel's capability of maintaining the status of systems and operational parameters within the envelope of acceptable conditions r'equired by established procedures and regulations.
3.
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 Review Board have reviewed these proposed changes to the Technical Specifications, and have concluded that they do not 1
I involve an unreviewed safety question or a significant hazards consideration, and will not endanger the health and safety of the i
public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY i
'Vice President
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COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S.
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Daltroff, being first duly sworn, deposes and says:
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 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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Subscribed and sworn to P
before me this.fd ay d
of
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Jm Notary Public MELAN!E R. CAMPANELLA Notary Public, Philadelphia. Ph!!adelphia Co.
My Commission Expires February 12. 1990
CERTIFICATE OF SERVICE I certify that service of the foregoing Amendment was made upon the Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to Thomas R. Gerusky, Director, Bureau of Radiological Protection, P. O. Box 2063, Harrisburg, PA 17120; all this30th day of September, 1986.
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Eu J. Bradley
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Attorney for Philadelphia Electric Company i
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