ML20236P286
| ML20236P286 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/10/1987 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20236P259 | List: |
| References | |
| NUDOCS 8708120286 | |
| Download: ML20236P286 (12) | |
Text
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 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 j
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ADOCK 05000p77 PDR i
L' BEFORE THE 1
UNITED STATES NUCLEAR REGULATORY COMMISSION j.1 1
In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 l
' APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Units 2 and 3,
respectively, hereby requests that the Technical Specifications contained in Appendix A of the Operating Licenses be. temporarily amended as indicated by a vertical bar in the margin of the attached page 245.
The requested change would suspend, o' a temporary basis, the requirement that either the Plant Manager or the Superintendent - Operations hold a Senior j
Reactor Operator (SRO) License.
The requested change would allow the individual who is currently serving as Assistant-to-the-Manager to assume the Superintendent-Operations position prior to being issued an SRO License for the Peach Bottom Atomic Power
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Station BWR Units.- The position change is being effected as part of the continuing efforts by Philadelphia Electric Company to strengthen and enhance the management of the Peach Bottom i
l facility.
The Technical Specification change is requested on a L
temporary; basis so that it will be' effective only between the time that the intended Superintendent-Operations successfully completes his Peach Bottom specific classroom training as demonstratedLby.the audit exam and the time.when he is issued his SRO License by the NRC.
During this time period, estimated to.be approximately three months, the individual will be taking the written and oral exams required for the SRO License.
During the time that the temporary Technical Specification relief will be in effect, both Peach Bottom units will be in the cold condition as a result of the NRC Shutdown Order of March 31, 1987.
The bases for'the requested change are set forth below.
The. conduct of operations at-Peach Bottom Atomic Power Station is managed through a Plant Manager, Superintendent -
Operations, Operations Engineer, and Shitt Supervision.
The current Plant Manager is not licensed.
The F trent Superintendent-Operations holds an SRO License.
The' current Operations Engineer also holds an SRO License.
In the implementation of Peach Bottom management changes, a highly experienced individual is presently undergoing Peach Bottom specific training to obtain an SRO License thus completing all requirements for that position.
Upon successful completion of the classroom portion of the training as demonstrated by the audit exam, it is intended that this individual assume the day-to-day duties and responsibilities of, and replace, the current _ _ _ -. -__-__________-_____-_ ____ _ _ -
Superintendent-operations.
In order to implement this aspect of the Peach Bottom management changes as expeditiously as possible, and since this individual is otherwise qualified to assume and perform the duties of the Superintendent-Operations, a temporary change to the Technical Specifications is requested.
During the time that the temporary amendment would be in effect, both Peach Bottom units will be in the cold condition.
By the time one of the units is ready to return to power operation, it is expected that the written and oral exams will have been successfully completed by the candidate, recognizing that plant specific control room experience and power manipulations can not be obtained until a unit returns to power operation.
We propose that the Operations Engineer will provide adequate site-specific experience for the management of operations through the shift supervision until the candidate is issued an SRO License.
A summary of the candidate's extensive training and work experience is attached.
The following accomplishments are highlighted:
received Bachelor cf Science Degree in Mechanical Engineering from U.S.
Naval Academy; completed U.S.
Navy Nuclear Power Training School; completed U.S. Navy Nuclear Power prototype training and qualified as Engineering Officer of the Watch on SIW prototype reactor; completed U.S. Navy Officers Submarine School; completed two-week research reactor training at Pennsylvania State University; completed 12-week BWR Simulator Senior Operator Certification-Limerick Training Center; completed 8-week Limerick Systems Review course; received SRO License for Limerick Generating Station Unit 1.
Considering the candidate's qualifications and the similarities between the Peach Bottom and l
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l l-Limerick reactors and systems, it is expected that the candidate will successfully complete the SRO written and oral exams to be given by the NRC in October 1987 followed by issuance of a limited.SRO License which recognizes that plant-specific control room experience and power manipulations can not be obtained until a unit returns to power operation.
Since the candidate has been assigned to the Peach Bottom Atomic Power Station as Superintendent-Plant Services, and currently as Assistant-to-the-Manager, he is qualified to perform the duties of the Superintendent-Operations except for being certified as an SRO for the Peach Bottom units.
Accordingly, it is hereby requested that the Peach Bottom Technical Specifications be temporarily amended to suspend the requirement that either the Plant Manager or the Superintendent-Operations hold an SRO License between the time when the intended Superintendent-Operations successfully completes his Peach Bottom specific classroom training (currently scheduled for mid August, 1987) and the time when he is issued an SRO License by NRC.
The attached Technical Specification page 245 indicates the temporary change requested.
License further requests, in accordance with Section 50.91 of the Commission's Regulations, that the license amendment requested herein be issued without 30-day prior notice and opportunity for a hearing or for public comment.
The Commission's Regulations recognize that the notice provisions may be dispensed with or shortened if the Commission finds that an emergency situation or exigent circumstances justify such - _ - _ _ _ _ _ _ _ _ _ _
h actions.
Until the requested relief is granted, facility management' changes.can not be effected in accordance with plans to satisfy the Commission's Shutdown Order'of March 31, 1987.
Delay.of appointment of a new Superintendent-Operations will impede needed' changes in the management of operations and could delay the resumption of power operations at Peach Bottom.
l Philadelphia Electric-Company could not have anticipated the i
Shutdown Order of March 31, 1987 which initiated significant changes in the management staffing of the facility'beginning-on May 4,.1987.
Considering.the unexpected nature of the problem, the Licensee could not have avoided this situation and the License Amendment is being requested in a timely manner.
Safety Assessments The education and experience qualifications of the intended' Superintendent-operations, which exceed the minimum requirements for the-position as specified in ANSI N18.1-1971, more than compensate for the lack of certain plant-specific power change and participation requirements required for a full SRO license,.and consequently support the temporary amendment request.
The candidate has almost 20 years of nuclear related experience, including 9 years at the Peach Bottom and Limerick plants. 'The most significant aspect of the individual's experience is that he has held an SRO License for 2 years at the Limerick Generating Station, a station similar in design to Peach Bottom (both are General Electric BWR facilities).
Further, his gradefobtained during his annual License Requalification exam
'while at Limerick was an impressive 95.5% average.
Dus'to the managerial' nature of-the Superintendent-Operations position, the candidate will not be performing hands-on. manipulations of the controls of either Peach Bottom unit while holding a limited SRO. license except for completion of the reactor power change requirements for his full SRO License after one of the units is returned to power operation.
A review of the overall qualifications of the Peach Bottom staff for managing operations was conducted against ANSI i
N18.1-1971.
The Standard calls for management of operations
'through a Site' Manager and an Operations Manager providing management direction to the shift supervision.
The Peach Bottom site organization, as shown in the attachment, goes beyond the Standard in that management direction is provided to the shift supervision through a Plant Manager, Operations Superintendent, and Operations Engineer.
The combined qualifications of the three~ individuals exceed the Standard's requirements for managing operations.
The Operations Engineer will be available to support the intended Superintendent-Operations during the requested relief period.
The Operations Engineer position is staffed by an individual possessing an SRO License, as required by the Technical Specifications.
Although this position is not specified.in ANSI N18.1-1971, the individual in this position meets the qualification requirements of Superintendent-Operations specified in the Standard and he is responsible for day-to-day operations of both Peach Bottom units.
In the Peach Bottom organizational scheme, the Operations Engineer reports directly to the Superintendent-Operations.
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Based on the candidate's extensive experience and training in nuclear power, the fact that he has already demonstrated the ability to obtain and maintain an SRO License at a similar facility, and the fact that the Operations Engineer position is and will be staffed by an individual who maintains an SRO License as required by the Technical Specifications and who therefore provides adequate compensation for the candidate's lack of plant specific power manipulating experience required for a full SRO License, Philadelphia Electric Company believes that permitting the candidate to provisionally assume the position of Superintendent-Operations by granting the temporary relief proposed herein will not adversely affect the safe operation of the Peach Bottom Station.
Significant Hazards Consideration:
The temporary change to the Technical Specifications to allow short-term operation of Peach Bottom Atomic Power Station in the cold condition with neither the Plant Manager nor the Superintendent-Operations holding an SRO License does not involve a significant hazards consideration for the following reasons:
(1)
The proposed revision does not involve a significant increase in the probability or consequences of an accident previously evaluated because (1) the individual who is intended to succeed the current Superintendent-Operations will have completed the majority of the training required for SRO License prior to the effective date of the temporary Technical Specification relief, l _.____ _______
(2) the individual has held an SRO License at a similar BWR facility (Limerick Generating Station) within the past1few years, and (3) the Operations Engineer maintains.an'SRO License, thus meeting ANSI.N18.1-1971 requirements for managing operations.
(2)
The proposed revision does not create the possibility of a new or different kind of accident from any accident
.previously evaluated because the lack of SRO Licenses on the part of the Plant Manager and the Superintendent-Operations, unlike a procedure or design change, is not a potential new accident precursor.
(3)
The proposed revision does not involve a significant reduction in a margin of safety because the candidate's training and experience qualifications more than compensate for the lack of certain plant-specific power change and participation requirements required for an SRO License, and adequate compensation is provided I
through the function of the' Operations Engineer who maintains an SRO License.as required by the Technical
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Specifications and by limiting plant status to operations in the cold condition.
The Plant Operational Review Committee and the Nuclear i
Review Board have reviewed the proposed temporary change to the
. Technical Specifications and have concluded that it does not i
- involve an unreviewed safety question or a significant hazards j
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consideration an'd will.not endanger the health and safety of the rpublic.
Based upon the foregoing, Licensee hereby requests that
- the Commission expeditiously amend Facility Operating Licenses DPR-44 and-DPR-56 as requested herein, find that an emergency situation or exigent' circumstances exist, and dispense with the 30-day prior public notice.
Respectf ully: submitted, PHILADELPHIA ELECTRIC COMPANY L
ufce President-I L
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COMMONWEALTH OF PENNSYLVANIA i
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l COUNTY OF PHILADELPHIA q
t J. S. Kemper, being first' duly sworn, deposes and says:
That he is Senior 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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JVice President Subscribed and sworn to before me this1* day o hsBU5r1987 U
(/ /Notar?' PGblic JUDITH Y, FRANKLIN Netary Public. Phila., Phita. Co.
My Commint,6on Expires July 28.15Hi l
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Application were served on the following by deposit in the United States mail, first-class postage prepaid, on this 10th day of August, 1987 Regional Administrator i
U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 T. P. Johnson, Resident Inspector U. S.
Nuclear Regulatory Commission Peach Bottom Atomic Power Station P. O.
Box 399 Delta, PA 17314 Mr. Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Fulton Bank Building, 5th Floor Third 6 Locusts Streets Harrisburg, PA 17120
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Eugpie J. Bradley [
Attorney for Philadelphia Electric Company 1
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