ML20238D679
| ML20238D679 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/08/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20238D668 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM GL-83-02, GL-83-2, NUDOCS 8709110321 | |
| Download: ML20238D679 (8) | |
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l BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION l
l In the Matter of Docket Nos. 50-277 50-278 PHILADELPHIA ELECTRIC COMPANY FOURTH AMENDMENT TO FEBRUARY 11, 1982 APPLICATION FOR AMENDMENT OF FACILITY OPERATlNG LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Ccmpany 8709110321 070900 ADOCK 050g2 7 PDR P
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BEFORE THE
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UNITED' STATES NUCLEAR REGULATORY COMMISSION
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In the-Matter of-Docket Nos. 50-277 50-278 PHILADELPHIA ELECTRIC COMPANY l
FOURTH AMENDMENT TO FEBRUARY 11, 1982 l
APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On September 30, 1986, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56, for Peach Bottom Atomic Power Station Unit Nos. 2 and 3, respectively, amended its February 11, 1982 Application for Amendment of the Licenses which had requested that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by incorporating overtime work restrictions for certain plant personnel.
The February 11, 1982 Application had been previously amended on August 24, 1983 and November 1, 1985. I m
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FolloWing discussions witn the NRC staff, Licensee is further amending its Application of February 11, 1982, as previously amended by deleting the proposed revised Technical Specification pages 270 and 271 referred to in the September 30, 1986 Amended Application and substituting therefor updated pages 270 and 271 which is attached hereto and incorporated herein by l
reference.
j The changes to the proposed Application reflected herein serve to clarify provisions of the proposed Technical Specifications discussed with the NRC staff.
Specifically, the i
word " alternate" is substituted for the word " designee" in proposed specification 6.20.3.
Additionally, proposed specification 6.20.3 has been revised to require the Manager-Nuclear Plant or his alternate as being responsible for the monthly review of the overtime records of all personnel subject to the overtime work limits.
Further, the Bases for specification 6.20 (page 271) is proposed to be revised to define the word " alternate" as used in the specification.
The 1
definition will assure the proper selection of supervisors l
responsible for authorizing deviations from the overtime limits, and performing the monthly review of overtime records.
Also, the designation of personnel authorized to approve deviations from the overtime work limits is revised to (1) include the supervisors of all key maintenance, construction, and testing personnel, and (2) identify the highest level of supervision assigned to the on-site management organization.
The revisions to the the September 30, 1986 Application are identified by a vertical bar in the margin of the attached pages. - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
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1 Safety Analysis l
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Studies indicat,e that with fatigue, especially because of loss of sleep, an individual's detection of visual signals deteriorates markedly, the time it takes for a person to make a h
decision increases, and more errors are made.
Other studies show I
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that fatigue results in personnel ignoring some signals because they develop their own subjective standards as to what is i
l important, and as they become more fatigued, they ignore more j
i signals.
The objective of the overtime limits specified in the proposed Technical Specification is to assure that, to the extent
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i practicable, personnel are not assigned to perform safety-related functions while in a fatigued condition.
The controls will limit both continuous working ~ hours, and accumulated working hours during any seven-day period.
Additionally, the controls will ensure adequate rest breaks between work periods.
The effect of these overtime work limits will be to reduce personnel fatigue, and consequently reduce the probability of personnel error, and improve personnel attentiveness to safety-related activities.
Significant Hazards Consideration Determination This App]ication, as amended, does not reduce the requirements of the current Technical Specifications.
The proposed change constitutes additional administrative controls not presently included in the Technical Specifications, and is in the interest of enhancing safe operations and complying with requirement I.A.l.3.,
Shift Manning of NUREG-0737, Clarification of TMI Action Plan Requirements.
The Commission has provided guidance concerning the application of the standards for A
determining whether license amendments involve no significant hazards considerations by providing certain examples (51 PR 7750).
One of the examples (ii) of actions involving no significant hazards consideration is a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications.
The changes proposed j
by this application fit this example of an action not involving a significant hazard consideration since it incorporates the overtime limitations, restriction, and controls requested by the NRC in Generic Letter No. 83-02, issued January 10, 1983, and in NUREG-0737, Item I.A.l.3.
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The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated since the proposed overtime limits are intended to reduce personnel fatigue and consequently improve attentiveness to safety-related activities in the interest of
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reducing the probability or consequences of an accident.
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The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated since the reduction in personnel fatigue resulting from these changes enhances plant personnel's capability of maintaining the status of systems and operational parameters within the envelope of acceptable
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d conditions required by established procedures and regulations, j
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The changes do not involve a significant reduction
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in the margin of safety since they reduce the d
possibility of personnel error in activities q
related to nuclear safety.-
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The Plant Operating Review Committee and the Nuclear Review Board have reviewed the changes to the Technical
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Specifications, proposed in the Licensee's February 11, 1982 1
Application, as previously amended and as amended herein, and j
have concluded that they do not involve an unreviewed safety t
question or a significant hazards consideration, and will not 1
endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY l
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COMMONWEALTH OF PENNSYLVANIA :
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1 COUNTY OF' PHILADELPHIA I
J. W. Gallagher, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Fourth Amendment to February 11, 1982 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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Subscribed and sworn to before me this
'P " day of StfT-1987 Qu.hE4h k w LL' s'
Notary Public JUDITH Y. FRANKLIN Notary PubHe, Phila, Phila. CO.
My Commission Empires July M IN _ _ _ _ _ _ _ - _ _
4 CERTIh'ICATE OF SERVICE l
I hereby certify that copies of the foregoing Fourth Amendment to February 11, 1982 Application were served on the following by deposit.in the United States mail, first-class postage prepaid, on this 8th day of September 1987 8th Regional Administrator U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 T.
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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 o
Third 6 Locusts Streets Harrisburg, PA 17120 j
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EugeneJ./Bradley Attorney for Philadelphia Electric Company l
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