ML20210P171
| ML20210P171 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/10/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210P168 | List: |
| References | |
| NUDOCS 9908120101 | |
| Download: ML20210P171 (3) | |
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION s*
WASHINGTON D.C. 20666-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
RELATED TO AMENDMENT NOS. paa AND inn TO FACILITY OPERATING j
LICENSE NOS. DPR-66 AND NPF-73 DUQUESNE LIGHT COMPANY I
OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION. UNIT NOS.1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By letter dated March 3,1999, as supplemented May 27,1999, and June 22,1999, Duquesne Light Company (DLC, the licensee) requested approval to amend the Technical Specifications (TSs) for the Beaver Valley Power Station, Units 1 and 2 (BVPS-1 and BVPS-2). The proposed amendment incorporated two changes: (1) modifying the licensee's commitment to American National Standards Institute (ANSI) N18.1-1971 for the operations manager and (2) incorporating generic titles in the technical specifications to eliminate the need to request an amendrnent whenever the plant-specific titles are changed. Following Nuclear Regulatory Commission (NRC) review and subsequent discussions with the licensee related to their initial submittal, DLC provided a revised submittal on May 27,1999, as supplemented June 22,1999.
The information submitted on May 27,1999, incorporated revised qualifications for the operations manager into the TSs and changed the generic title proposed to replace the plant-specific title of Senior Vice President, Nuclear Power Division. The revisions provided in the May 27,1999, letter, as well as the June 22,1999, letter, which provided the final TS pages, did not change the initial proposed no significant hazards consideration determination or expand the amendment beyond the scope of the initial notice.
2.
EVALUATION DLC's current commitment to ANSI N18.1-1971," Selection and Training of Nuclear Power Plant Personnel," requires the operations manager to hold an SRO license. The proposed amendment would add item (g) to TS 6.2.1, "Onsite and Offsite Organizations," which allows the operations manager, in lieu of meeting the N18.1 requirement of holding an SRO license, to (1) hold an SRO license or (2) have held a SRO license for a pressurized water reactor. This 9908120101 990810 PDR ADOCK 05000334 P
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. approach is supported by ANSI /ANS 3.1-1987 and 3.1-1993, " Selection, Qualification and Training of Personnel for Nuclear Power Plants," which allow individuals to hold the position of operations manager based on the options proposed by DLC for TS 6.2.1(g). The 1987 and 1993 standards further state that if the operations manager does not hold a license then the operations middle manager shall hold an SRO license. The change to TS 6.2.1(g) proposed by the licensee, includes the requirement that the position of assistant operations manager hold a current SRO license.
In its letter of March 3,1999, the licensee stated that the operations manager has overall responsibility for the operations of both units. The assistant operations manager at each unit is responsible for the direct oversight of the licensed operators and is required to hold an SRO license for the unit managed. The requirement that the assistant operations managers hold a unit-specific SRO license is consistent with the requirements of 10 CFR 50.54(l) and ensures that a licensed off-shift senior operator will direct the licensed activities of the licensed operators. The requirement for the operations manager to hold or have held a license together with the requirement that the assistant operations manager hold a license is consistent with ANSI 3.1-1987 and 1993.
In their March submittal, DLC proposed that generic titles be incorporated into the TSs for both units. The licensee has stated that the proposed amendment would eliminate the need to request an amendment whenever plant-specific titles are changed. To support this request, the licensee modified Table 13.1-2, " Personnel Responsibilities and Qualifications," in the Unit 2 Updated Final Safety Analysis Report (UFSAR). The table has been changed to list the current plant-specific position title together with the generic title to be referenced in the TSs for both units. The generic titles of plant manager, radiation protection manager, operations manager, and assistant operations manager are consistent with the position titles in ANSI /ANS Standards N18.1-1971,3.1-1987, and 3.1-1993 for workers with comparable responsibilities.
Following NRC review and subsequent discussions with the licensee related to the generic title to be used for the individu'al with corporate responsibility for nuclear safety, DLC submitted revised information on May 27,1999, in their May submittal, the licensee proposed to incorporate " corporate officer with direct responsibility for the plant" into the TSs to identify the individual with overall responsibility for plant nuclear safety. The UFSAR indicates that the plant-specific position tasked with that responsibility is the President, Generation Group and Chief Nuclear Officer. The corporate officer selected is clearly responsible for nuclear activities without having ancillary responsibilities that might detract from attention to nuclear safety matters. The generic title and defined responsibilities meet the relevant criteria in NUREG-0800, Standard Review Plan, Section 13.1.1, " Management and Technical Support Organization."
2.1.
Summary The staff reviewed the licensee's submittals and concludes that the modifications to the TSs requiring the assistant operations manager to hold an SRO license is consistent with the requirements of 10 CFR 50.54(l) and ensures that a licensed off-shift senior operator will direct the licensed activities of the licensed operators. Further, requiring the operations manager to hold or have held an SRO license is consistent with the requirements of ANSI /ANS Standards N18.1-1971,3.1-1987, and 3.1-1993 and ensures site-specific, detailed, and relevant technical and systems knowledge in a senior operations management position. Therefore, the staff concludes that the proposed changes to the BVPS-1 and BVPS-2 TSs, which modify the
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The staff further concludes that the licensee's use of generic titles is consistent with the titles in the ANSI /ANS standards and meets the relevant review criteria in NUREG-0800 and is j
acceptable.
3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official asked if the amendment would allow the licensee to place an individual in the operations manager position who does not hold an SRO license, but who has substantial nuclear experience from the military, and take credit for the military experience as satisfying the requirement to hold or have held an SRO license.
i The NRC staff responded that military nuclear experience can not be substituted in lieu of the requirement for the operations manager to hold, or have held, an SRO license. While ANSI /ANS 3.1-1987, and 3.1-1993 do allow some credit to be taken for military experience toward required nuclear industry experience for management positions, the TS and UFSAR requirement for the operations manager to hold, or have held, an SRO license will not allow such credit to be taken - an SRO license is a specific NRC license, as defined in 10 CFR 55.4, and military experience / qualifications are not considered to be equivalents / substitutes in lieu of this license. Furthermore, DLC has not committed to ANSI /ANS 3.1-1987 or 3.1-1993 in their Quality Assurance plan and, thus, can not invoke the provisions of these standards to take credit for military experience without prior NRC approval. The State official had no further questions or comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change administrative requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (64 FR 19556). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: M. Ashley Date: August 10, 1999 m