AECM-87-0246, Application for Amend to License NPF-29,revising Tech Specs to Incorporate Changes Resulting from Revised 10CFR55 Rule. Fee Paid

Application for Amend to License NPF-29,revising Tech Specs to Incorporate Changes Resulting from Revised 10CFR55 Rule. Fee Paid

ML20237D339
Person / Time
Site:	Grand Gulf
Issue date:	12/16/1987
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20237D341	List: AECM-87-0246, Application for Amend to License NPF-29,revising Tech Specs to Incorporate Changes Resulting from Revised 10CFR55 Rule. Fee Paid ML20237D342
References
AECM-87-0246, AECM-87-246, NUDOCS 8712230205
Download: ML20237D339 (6)

Text

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b SYSTEM ENERGY RESOLJRCES. INC.

Clura D KmGl[Y',Jf2 EN$$$1ms December 16, 1987 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Implementation of Revised 10CFR55 Rule Proposed Amendment to the Operating License (PC0L-87/14)

AECM-87/0246 The NRC published a revision to 10CFR55 which became effective May 26, 1987. System Energy Resources, Inc. (SERI) is submitting this proposed amendment to the Grand Gulf Nuclear Station Unit 1 Operating License and Technical Specifications to incorporate changes resulting from the revised rule.

On April 9,1987, SERI representatives attended the NRC-sponsored meeting held to discuss changes in the revised 10CFR55 and actions licensees should take to implement the revision. Based on guidance provided at that meeting, SERI prepared the proposed changes to the operating license and technical specification, discussed in Attachment II to this letter. Attachment II also provides SERI's determination that the proposed changes involve no significant hazards considerations. Attachment III provides marked-up pages to the GGNS Unit 1 Operating License and Technical Specifications showing proposed changes associated with SERI compliance with the revised rule.

In accordance with the provisions of 10CFR50.4 and 50.30, the signed original of the requested amendment is enclosed and the appropriate copies will be distributed. The proposed changes have been reviewed and accepted by both the Plant Safety Review Committee and the Safety Review Committee.

Based on the guidelines presented in 10CFR50.92, SERI has concluded that this proposed amendment involves no significant hazards considerations.

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AECM-87/0246 Page 2 The application fee of $150 in accordance with the requirements of 10CFR170.21 is enclosed.

Yours truly, 4

ODK:vog Attachments: 1. Affirmation per 10CFR50.30

2. Deletion of Training Commitments

3. Affected Pages of the GGNS Unit 1 Operating License and Technical Specifications cc: Mr. T. H. Cloninger (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Dr. Alton B. Cobb (w/a)

State Health Officer State Board of Health Box 1700 Jackson, Mississippi 39205 J07AECM87121501 - 2

Attachment I to j AECM 87/0246 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION l

LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of System Energy Resources, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information a lief.

7 0.\Dj Kingsle ', .

STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 befor me, a Notary Public, in and for the County and State above named, this . day of Sh, , 1987.

(SEAL) r> 8k d o d>. W) A d o Notary Public My commission expires:

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Attachment II to AECM 87/0246 l A. SUBJECT

1. PS-87/04 Deletion of Training Commitments j

2. Affected Documents:

(a) OperatingLicense(0L) Condition 2.C.(30),TrainingInstructors,  ;

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page 10 (b) Technical Specification (TS) 6.3, Unit Staff Qualifications, l Page 6-6 (c) Technical Specification 6.4, Training, Page 6-6 B. DISCUSSION The changes proposed below incorporate the revision to 10CFR55 which became effective May 26, 1987.

1. OLCondition2.C.(30) states,"Permanenttrainingcenterinstructors anr! consultants assigned to training who, after initial criticality will teach systems, integrated responses, transients, and simulator courses to license candidates or NRC-licensed personnel, shall either demonstrate or have previously demonstrated their competence to the NRC staff by successful completion of a senior operator examination prior to teaching licensed operators."

SERI proposes to delete this condition, since the Grand Gulf Nuclear Station (GGNS) operator training program is now INP0 accredited.

2. TS 6.3 states, "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees,..."

SERI proposes to delete the phrase "and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees" from the above TS.

Deletion of this phrase will bring SERI into compliar<ce with the revision to 10CFR55, which superseded the referenced letter.

3. TS 6.4 states, "A retraining and replacement training program for the unit staff...shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10CFR Part 55 and the supplemental requirements specified in Sections A and C of Enclosure ] of the March 28, 1980 NRC letter #

i to all licensees ..."

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4 SERI proposes to delete the reference to " Appendix A" since the p revision to 10CFR55 deleted this appendix. SERI also proposes to delete the phrase "and the supplemental requirements :;pecified in

' Sections A and C of Enclosure 1 of the March 28,'1980 NRC letter #

to all licensees".to bring SERI into compliance with the revision to 10CFR55, which superseded the referenced letter.

C. JUSTIFICATION-These proposed changes result from the NRC revision to 10CFR55 in which ..

the rule was completely rewritten and from NRC guidance on the implemen- '

tation of the revised 10CFR55 as provided by Generic Letter (GL) No. 87-07 and subsequent public meetings. GL 87-07 states in the Introduction, "The Commission has become increasingly aware of the need to update its operator licensing regulations and related regulatory guides. These revisions are needed to... reflect upgraded requirements for licensed operator selection, training, and requalification programs resulting from the accident at TMI-2."

The proposed changes _to the OL and TS result in no change in facility operations or licensed operator training programs and clearly are in keeping with NRC regulations.

Specifically:

1. The revision to 10CFR55 abolished categories of two previously permitted licenses under 10CFR55.30, namely "special senior operator licenses" and " instructor certification" at industry accredited facilities. GL 87-07, in explaining the changes made to the rule, stated "The Commission has deleted the-provision for issuance of special senior operator licenses from the final rule. This action is l

in recognition of the industry accreditation of training programs

! ...and is in keeping with the intent of the Commission Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel...since industry accreditation includes instructor evaluation, current NRC instructor certification will not continue at f acilities with. industry accreditation." This is consistent with the position taken in NUREG-07371.A.2.3, " Administration of Training Programs", that the requirements for instructors to have senior reactor operator license qualifications were to be interim until accreditation of training institutions. The GGNS training program is industry accre'dited, having become a full member in the National .

Academy for Nuclear Training in April 1987.  !

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2. Enclosure 1, Section A of the March 28, 1980 NRC letter addressed )

eligibility requirements for license candidates to be adminis t.ced j license examinations. Enclosure 1, Section C of the March 28, 1980 '

NRC letter addressed requalification training programs. Licere candidates are not part of the Unit Staff discussed in TS 6.3 l

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@ These individuals by definition must be licensed. ~Therefore Section ,

A eligibility requirements for license candidates are not applicable. J fl

[ to this TS. Similarly, the requalification program discussed in Section C is not applicable to minimum qualifications for Unit Staff, since requalification is already a part of the requirement for being )

a licensed. operator. Further, SERI considers the revision to 10CFR55 {

supersedes,in their entirety Sections A and C of Enclosure 1 of the 1 March 28,.1980 NRC letter based upon statements made by NRC {

representatives at the April 9,1987 public meeting to discuss the J changes. presented by GL 87-07.

3. The revision to 10CFR55 incorporated into the body of the rule those l requirements previously contained in 10CFR55 Appendix A. Since  !

Appendix A no longer exists SERI considers retention of a reference  !

to it in TS is inappropriate. SERI also considers.the revision to 10CFR55 supersedes'in their entirety Sections A and C of Enclosure.1 of the Mt"ch 28, 1980 NRC letter as referenced in TS 6.4. SERI's basis for this opinion is statements to that effect which were made by NRC representatives at the April 9, 1987 public meeting to discuss GL 87-07 and the st'atement on page 6 of GL 87-07 which states, *Those facility licensees that have made a commitment different from or more than that required by these new rules for license amendments and technical. specifications' changes, may apply to the Commission so that they can conform to these new rules."

D. ~ SIGNIFICANT HAZARDS CONSIDERATION I These changes are proposed in response to the NRC revision to 10CFR55.

. GL 87-07 indicated the revisions "were to improve the operator licensing process and to achieve the following objectives: (1) Improve the safety of nuclear power plant operations by improving the operator licensing-process and examination content..."

SERI has evaluated the proposed changes to the OL and TS and determined the proposed changes are administrative in nature and do not involve a significant hazards consideration for the following reasons:

(1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because they involve only an incorporation of changes from 10CFR55 and recognition of an accredited training program such as the one at GGNS. Because of the administrative nature of the proposed changes the probability cr consequence of an accident are not affected.

(2) The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated because th proposed changes will have no effect on the design, construction er operation of safety related systems or components.

(3) The proposed changes do not involve a significant reduction in tu margin of safety because the revision to 10CFR55 superseded the C -

letter commitments referenced in the TS and addressed nuclear industry accreditation of training programs. The proposed changes are administrative in nature and clearly have no effect on the ma19 of safety.

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