ML20211J544

Application for Amends to Licenses NPF-68 & NPF-81,proposing to Raise Level of Approval Authority for Deviations from Guidelines Provided to Minimize Unit Staff Overtime Specified in TS 5.2.2

ML20211J544
Person / Time
Site:	Vogtle
Issue date:	08/30/1999
From:	Beasley J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20211J549	List: ML20211J544 ML20211J551
References
LCV-1367, NUDOCS 9909030177
Download: ML20211J544 (4)

Text

r J. Bernie Beasigy,Jr P.E. . Southern Nuclear

~ %ce President Operating Company. Inc.

Vogtle Project 1 40 invemess Center Parkway .

PO Box 1295

. Birmingham, Alabama 35201 Tel 205 992 7110 Fax 205 992 0403 SOUTHERN COMPANY Energy to Serve) bur u'brid

August 30, 1999 LCV-1367 Docket Nos.: 50-424 -

50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Ladies and Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT PROPOSED CHANGE TO TECHNICAL SPECIFICATION 5.2.2 APPROVAL OF OVERTIME RESTRICTION DEVIATIONS In accordance with 10 CFR 50.90, Southem Nuclear Operating Company (Southem Nuclear) requests that Appendix A of Facility Operating Licenses NPF-68 and NPF-81 be amended to modify the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Technical Specifications (TS). The purpose of the proposed license amendment is to raise the level of the approval authority for deviations from the guidelines provided to minimize unit staff overtime specified in TS 5.2.2 The present wording of TS 5.2.2 lists "the applicable depanment superintendent or higher levels of management" as the approval authorities for deviations from the overtime guidelines. This wording has been in the VEGP TS's since initial licensing and was carried forward with the implementation of the improved TS's. However, in order to heighten the sensitivity to excessive use of overtime, Southem Nuclear wishes to replace ,

" department superintendent" with " department manager"in this proposed technical '

specification change.

A description of the proposed TS change along with a supportingjustification is provided in Enclosure 1. Southem Nuclear demonstrates in Enclosure 2 that the proposed license amendment does not involve a significant hazards consideration pursuant to 10 CFR '

50.92.. Enclosure 3 provides the revised TS pages, and the Environmental Impact g 7

Determination is included as Enclosure 4.

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l U.S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.91(b)(1), a copy of this proposed license amendment is being forwarded to Mr. L. C. Barrett, the designee for the State of Georgia.

Mr. J. B. Beasley, Jr. states he is a vice president of Southern Nuclear and is authorized to I execute this oath on behalf of Southern Nuclear, and to the best of his knowledge and L belief, the facts set forth in this letter and enclosures are true.

Please contact this office if you have any questions.

SOUTHERN NUCLEAR OPERATING COMPANY By:

M,f J. BI Beaspy, Jr7 Sworn to und subscribed before me this day of 1999 9

l Notary Public /

6. M wmexper:s i

Enclosures 1

JBB/BHW/gje cc: Southern Nuclear Operating Compar.y Mr. J. T. Gasser Mr. M. Sheibani t SNC Document Management i

U.S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. R. Assa, Project Manager, NRR Mr. J. Zeiler, Senior Resident inspector, VEGP State of Georgia l Mr. L. C. Barrett, Commissioner, Department of Natural Resources l

l I

L.

ENCLOSUREI VOGTLE ELECTRIC GENERATING PLANT PROPOSED CIIANGE TO TECilNICAL SPECIFICATION 5.2.2 APPROVAL OF OVERTIME RESTRICTION DEVIATIONS DESCRIPTION AND JUSTIFICATION Description of Proposed I.icense Amendment The present wording of TS 5.2.2 lists "the applicable department superintendent or higher levels of management" as the approval authorities for deviations from the overtime guidelines, in order to heighten the sensitivity to excessive use of overtime, Southern Nuclear wishes to replace " department superintendent" with " department manager" in this proposed technical specification change.

Justification for Proposed I icense Amendment The authority to approve deviations from the guidelines in place to limit the working i hours of plant staffin performance of safety-related functions was stated in the original l VEGP Units I and 2 technical specifications issued as NUREG-1343 dated February l 1989. Section 6.2.2.e of this document states:"Any deviation from the above guidelines shall be authorized by the applicable departm.:nt superintendent, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation." This same approval authority was carried fbrward as a part of the Improved Technical Specification effort and was subsequently included in Section 5.2.2.e of the current TS's. However, to enhance the assurance that plant personnel's effectiveness will not be adversely impacted, this proposed technical specification change will require that approval be obtained from the depanment manager I or higher levels of management before a deviation can be made from the overtime guidelines. If the department manager is unavailable for an extended time period (e.g.

illness, vacation, training, etc.), their approval authority will be designated to someone in their absence.

Summary Based on the justification presented above, Southern Nuclear has determined that the proposed technical specification change does not adversely affect or endanger the health and safety of the general public.

ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT PROPOSED CIIANGE TO TECIINICAL SPECIFICATION 5.2.2 APPROVAL OF OVERTIME RESTRICTION DEVIATIONS NO SIGNIFICANT IIAZARDS CONSIDERATION DETERMINATION Description of Proposed License Amendment The present wording of TS 5.2.2 lists "the applicable department superintendent or higher levels of management" as the approval authorities for deviations from the overtime guidelines. However, in order to heighten the sensitivity to excessive use of overtime, Southern Nuclear wishes to replace " department superintendent" with " department manager"in this proposed technical specification change.

Introduction The NRC has provided standards for determining whether a significant hazards consideration exists in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Discussion (1) The proposed license amendment would strengthen the administrative controls that )

permit plant personnel to work beyond those limits outlined in the TS's. As a result, there will be greater scrutiny on the amount of overtime being utilized to perform safety-related functions. Therefore, it has been determined that operation of the facility in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) There will be no physical changes to the systems, components or structure of the facility as a result of this proposed license amendment. The initial assumptions of the design accident analyses will be unaffected. Therefore, operation of the facility in ,

accordance with the proposed amendment will not create the possibility of a new or 1 different kind of accident from any accident previously evaluated.

(3) This amendment raises the administrative level of management approval required for overtime in excess of the limits outlined in the TS. Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.

Conclusion Based on the above discussion, it has been determined that the requested technical specification change does not involve a significant hazards consideration.

i ENCLOSURE 3 VOGTLE ELECTRIC GENERATING PLANT PROPOSED CllANGE TO TECIINICAL SPECIFICATION 5.2.2 APPROVAL OF OVERTIME RESTRICTION DEVIATIONS REVISED TECIINICAL SPECIFICATION PAGES l