ML20235K533
| ML20235K533 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/29/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235K531 | List: |
| References | |
| NUDOCS 8710050134 | |
| Download: ML20235K533 (5) | |
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DAFETYEVALUATIONBYTHEOFFICEOFNUCLEARREACTORREGULATIONSUPPORTIN AMENDMENT NOS. 126 AND 129 TO FACILITY OPERATING LICENSE NOS. DPR-44 and DPR-56 PHILADELPHIA ELECTRIC COMPANY PUBLIC SERVICE ELECTRIC AND GAS COMPANY DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 and 3 DOCKET NOS. 50-277 and 50-278
1.0 INTRODUCTION
By letter dated August 10, 1987, Philadelphia Electric Company requested an amendment to Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station Unit Nos. 2 and 3.
This amendment would provide interim relief, while operating in cold shutdown conditions prior j
to any startup of the facility, from the requirement in Figure 6.2-2 of the Technical Specifications which requires that either the Plant Manager or the Superintendent-0perations shall hold a Senior Operator license.
2.0 EVALUATION As noted above, Figure 6.2-2 (enclosed) of the Technical Specifications shows the Organization for Conduct of Plant Operations. The organizational block for the positions of Superintendent of Operations and Manager Nuclear Plant have a 1 in the lower lqft corner of the block. Note I states that "either the Plant Manager or Superintendent of Operations shall hold an SR0 license." Philadelphb Electric requests that note 1 be annotated with the statement "except during cold condition operations resulting from the NRC order of March 31, 1987."
The staff has reviewed this request and found it acceptable for the following reasons:
1)
The individual to be assigned to the position of Superintendent of Operations meets all requirements for the position of Operations Manager (a position comparable to the Peach Bottom Superintendent of Operations) described in Section 4.2 of ANSI N18.1-1971 except for holding an SR0 license. The individual is a Degreed Engineer with about 20 years nuclear experience and has held a Senior Operator license at the Limerick Station, a BWR similar to Peach Bottom.
2)
The Shift Superintendents (Shift Supervisors) report to an Operations Engineer who meets the qualifications requirements for the position of Operations Manager described in Section 4.2 of ANSI N18.1-1971.
The Operations Engineer is in a position between the Shift Superintendents and the Superintendent of Operations.
3)
Peach Bottom, Units 2 & 3, will be in a cold shutdown condition.
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3.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION Response to Comments Comments'were received in response to the Federal Register Notice published September 2, 1987 (52 FR 33305).
Comments were received as follows:
1)
A comment was received from Ms. Janet Unfried by phone on September 17, 1987. She expressed her opposition to what she understood were the proposed usage of " uneducated people to run the plant." Ms. Unfried's-concerns seemed to be answered somewhat following discussion of the proposed amendment.
2)
Consnents were received from Patricia T. Birnie of the Maryland Nuclear Safety Coalition, by letter dated September 15, 1987. Ms.
Birnie expressed opposition to the proposed amendment which she understood would excuse "the utility from requiring their plant manager and superintendent of operations to obtain senior operator licenses." Ms. Birnie also expressed opposition to a " weakening of the regulations" for Peach Bottom.
The staff notes that there are no exceptions to the NRC's regulations involved with the proposed amendment.
Further, the amendment does not remove the SRO requirement from the Technical Specifications; however, interim relief is provided under certain specified condition.
3)
Comments were received from Ms. Jean S. Ewing by letter dated September 15, 1987. Ms. Ewing expressed opposition to the proposed emendment which she understood would exempt the licensee from the SRO requirement. Ms. Ewing expressed concern tha;. the proposed l
amendment represented an exceptinn to proof of management competence and a breach of procedures.
The staff notes that the amendment does not exempt the licensee from the SRO requirement altogether; it does however provide interim relief under certain specified conditions.
The staff notes that the licensee, as part of its response to the NRC's Order of March 31, 1987, has made changes in the management organization at the plant.
The licensee proposes to make the changes regarding the position of Superintendent-Operations with the objective of strengthening and enhancing the management of the PBAPS, The NRC staff, for the reasons stated in Section 2.0 finds the licensee's proposal to be
. acceptable.
The staff has not identified any breach of procedures involved with the licensee's application for amendment to the Technical Specifications which is limited both in the scope and the duration of the requested relief.
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'4)
Coments were provided by Mr. Marvin Lewis, by letter dated September i
15, 1987. Mr. Lewis expressed concern that the departure of certain individuals from the plant staff would result in a lack of needed insight during the restart of the plant and proposed that the change-over be deleyed until after restart. The staff notes that approval nf the proposed amendment does not represent a decision to any degree
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regarding the adequacy of the licensee's programs and the staff's j
requirements for restart of the PBAPS. These decisions will be.the j
subject of further actions by the NRC. The relief grerted by the amendment applies only to operations while in a cold shutdown I
condition and do not extend to criticality of the reactor or other f
modes of startup operations.
l 5)
Coments were received from Debra L. Hamilton of Nuclear Free America on September 22, 1987. Ms. Hamilton expressed opposition to the proposed amendment which she understood "...would excuse l
Philadelphia Electric from requiring a senior operator's license for the plant manager and for superintendent of operations." She requested that the NRC "...not allow this further weakening of regulations to cause further ercsion of public trust "
The staff's response to the above comments is the same as that provided for items 2 and 3, above.
State Consultation In accordance with the Commission's regulations, consultation was held with the Commonwealth of Pennsylvania's Bureau of Radiation Protection by telephone. The NRC staff consulted with the Commonwealth of Pennsylvania representative on August 25, 1987, who concurred in general with the proposed amendment but expressed the view that the overall depth of experience of the revised operations staff should be carefully scrutinized. The staff notes, as stated previously, that the staff's approval of the proposed amendment does not represent a decision to any degree regarding the adequacy of the licensee's programs and the staff's requirements for restart of the PBAPS.
The relief granted by this amendment does not extend beyond the cold shutdown condition and J
decisions regarding restart of the plant, including qualifications of the staff to operate the plant, will be the subject of further actions by +Sa NRC.
No Significant Hazards Consideration Determination The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a proposed license amendment involves no significant hazards considerations 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
i 21 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.
The licensee has analyzed the problem identified in the NRC Order of March 31,1987 to determine the underlying causes and has developed a plan to assure that the PBAPS will operate safely. The licensee has taken action to address concerns identified in the Order which include changes in the management organization at the plant.
These changes include a change in the Superintendent-0perations. The licensee indicates that the individual designated for this position is scheduled to complete the examination requirements for the Senior Reactors Operator's license required to meet the requirements of the Technical Specification (TS) Figure 6.2-2 during October 1987.
The licensee submits that a temporary relief from the TS requirement, which would allow the individual to promptly assume the duties of Superintendent-Operations, would strengthen and enhance the management of the PBAPS and could avoid the potential for further delay in the licensee's readiness preparations for restart of Unit 2.
The individual who will succeed the current Superintendent-0perations has completed the majority of training required for the SR0 license on PBAPS; this individual has recently held a SR0 at a similar facility and the Operations Engineer who will report to the Superintendent-0perationt i
holds a SRO license. The relief to be granted is for an interim period of several months during which time the plant will remain in a cold shutdown condition.
Therefore, these proposed amendments do not involve a signifiednt increase in the probability or consequences of an accident previously evaluated. Since the lack of a SR0 license on the part of the Plant Manager or Superintendent-0perations under the conditions stated herein does not constitute a potential new accident precursor this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
1 The new Superintendent-0perations designee's training and experience qualifications, the support of the Operations Engineer who does hold a SRO license and the maintenance of the plant in a cold shutdown status during the period of the relief adequately compensate for the temporary j
lack of certain requirements and the conducting of the NRC examination required for the issuance of a SRO ' license.
Therefore, this change does not involve a significant reduction in the margin of safety.
The staff has determined, based on the review of the licensee's submittal that operation of the facility in accordance with the proposed amendments,
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in a cold shutdown condition, would not involve a significant reduction in the margin of safety and that:
1)
Operation of the facility in accordance with the proposed amendments would not significantly increase the probability or consequences of j
an accident previously evaluated.
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2)
Operation of the facility in accordance with the proposed amendments L
would not create the possibility of a new or different kind of accident from any accident previously evaluated.
3)
Operation of' the facility in accordance with the proposed amendments would not. involve a significant reduction in a margin of safety.
Therefore, the staff concludes that these amendments involve no significant hazards considerations.
4.0 ENVIRONMENTAL CONSIDERATION
S These amendments involve a change to a requirement with respect to the organization for the conduct of plant operations within the restricted area as defined in 10 CFR Part 20.
The staff has determined that the amendments involve no significant increase in the amounts, and no signi-ficant 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.
The Commission has received comments on the proposed finding as discussed above.
The Comission has determined that none of the comments impact the proposed finding for each of the three factors of 10 CFR 50.92 and, therefore, the Comission has made its final finding of no significant hazards consideration as noted above. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forthin10CFR51.22(c)(9). Pursuant to 10 CFp 51.?2(b), no environmental impact" statement nor environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has made a proposed determination that the amendments involve no significant hazards consideration, which was published in the Federal Register (52 FR 33305) on September 2,1987 and consulted with the Commonwealth of Pennsylvania.
Public comments and coments by the Commonwealth of Pennsylvania were received as discussed above. The Commission has detennined that none of the comments impact the proposed finding for each of the three factors of 10 CFR 50.92 and, therefore, the commission has made its final finding of no significant hazards consideration as noted above.
The staff 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, and (2) such activities will be conducted in compliance with the Commission's regulations, and 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:
F. R. Allenspach Dated:
September 29, 1987