ML20245B610

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Proposed Tech Specs Deleting Specific Refs to Staff Positions & Review Group Compositions in Section 6.0, Administrative Controls & Adding to Responsibilities of Shift Superintendent or Other Senior Reactor Operator
ML20245B610
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 06/19/1989
From:
SYSTEM ENERGY RESOURCES, INC.
To:
Shared Package
ML20245B604 List:
References
NUDOCS 8906230257
Download: ML20245B610 (13)
v • d • e


Text

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PROPOSED TECHNICAL SPECIFICATION MARKED UP PAGES FOR NL 88/10 i

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.,NL 88/10 A MINISTRATIVE CONTROLS PLANT SAFETY REVIEW COMMITTEE (PSRC) (Continued)

COMPOSITION 6.5.1.2 The PSRC shall be composed ofgthe-Cha Manager, Plant Support Vice Chair ember:

Manager, Plant Operations Member:

Manager, Plant Maintena Member:

tions Super ent Member:

Manage rmance and System Engineering Member:

r, Qua rvices Member:

Chemistry / Radiation 1 Superintendent Member:

I&C Superintendent Mem Plant Licensing Superintendent ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the GGNS General Manager to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PSRC activities at any one time.

MEETING FREQUENCY

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6.5.1.4 The PSRC shall meet at least once per calendar month and as convened 1

by the PSRC Chairman or Vice Chairman.

QUORUM 6.5.1.5 The quorum of the PSRC necessary for the performance of the PSRC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or Vice Chairman and four members including alternates.

RESPONSIBILITIES 6.5.1.6 The P5RC stall be responsible for review of:

a.

Station administrative procedures and changes thereto.

b.

The safety evaluations for (1) procedures, (2) changes to procedures, i

1 equipment or systems, and (3) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question and all programs required by Specification 6.8 and changes thereto.

3 c.

Proposed procedures and changes to procedures, equipment or systems j

which may involve an unreviewed safety question as defined in l

Section 50.59, 10 CFR.

d.

Proposed tests or experiments which may involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

Proposed changes to Technical Specifications or the Operating License.

e.

1 GRAND GULF-UNIT 1 6-7 Amendment No. 47, 1

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NL 88/10

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Insert to Page 6-7

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.nine members of GGNS onsite operating organization management at.- the Superintendent _ level or above.

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HL 88/10 I

ADMINISTRATIVE CONTROLS

~6.5.2 SAFETY REVIEW Co mITTEE (SRC)

FUNCTION J

i 6.5.2.1 The SRC shall function to provide independent review and audit'of designated activities in the areas of:

a.

nuclear power plant operations b.

nuclear engineering.

c.

chemistry and radiochemistry d.

metallurgy e.

instrumentation and control f.'

radiological safety g.

mechanical and electrical engineering h.

quality assurance practices COMPOSITION 6.5.2.2 Th; 0"C :h:11 5; :x;;;;;' :' ti..

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Vice President, Nuclear Operations Member:

Vice President, Nuclear Engineering & 5 Member:

tor, Nuclear Plant Engineeri Member:

Site )

r, GGNS Member:

Director, Qua s

Member:

. Designated R enta

'U System Services, Inc.

Member:

GGNS a Manager Member:

ector, Nuclear Licensin

' Membe r-Manager, Radiological and environmental Serv h.

h sEr g r:

Manager, Operational Analysis A

KTwo or more additional voting members shall be consultants to System Energy Insert B Resources, Inc. consistent with the recommendations of the Advisory Cosaittee on Reactor Safeguards letter, Mark to Palladino dated October 20. 1981. a

'The SRC members shall hold a Bachelor's degree in an engineering or physical science field or equivalent experience and a minimum of five years of technical expe'rience of which a minimum of three years shall be in one or more of the Q disciplines of 6.5.2.la through h.

In the aggregate, the membership of the committee shall provide specific practical experience in the majority of the disciplines of 6.5.2.la through h.

ALTERNATES 6.5,2.3 All alternate members shall be appointed in writing by the SRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SRC activities at any one time.

GRAND GULF-UNIT I-6-9 Amendment No. 42, 1'

'NL 88/10 Insert A The SRC shall be composed of a Chairman and nine voting members.

Insert B The Chairman and members shall meet the qualifications below.

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NL 88/10 Insert c The SRC Chaiman'shall hold a Bachelor!s degree in an engineering or physical science field or an equivalent and a minimum of six years i

of professional level managerial experience in the power field. In addition, the Chairman shall have the necessary overall nuclear background to determine when.to call consultants and contractors for dealing with complex problems beyond the scope of System Energy Resources, Inc. expertise.

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. A.

. SUBJECT-

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PS 88/02.

Implementation of Generic Letter 86-04 2..

Revised Technical Specification:

'a.

Minimum Shift Crew Composition, Table 6.2.2 Page 6-5.

B.

DISCUSSION 1.

Presently, Table 6.2.2-1 requires one individual be dedicated to the position of Shift Technical Advisor (STA).

In Generic Letter'86-04, the Commission encouraged licensees to move toward a dual-role (Senior Reactor Operator (SR0)/STA) position.

In order to accomplish this goal for GGNS, a change to the GGNS Technical Specifications is necessary.

2.

The proposed administrative change adds a footnote, applicable to

'the STA position, to Table 6.2.2-1.

In addition to the new footnote, the proposed change modifies the statement made on Page 6-5 concerning individuals who may assume.the Control Room command function'during the absence of the Shift Superintendent from the Control Room while the unit is in Operational Conditions 1, 2 or 3.

The affected Technical Specification page showing the requested change is attached.

3.

The effect of the proposed change is that the STA position may be fulfilled by an individual who meets the requirements of the STA position stated in. Regulatory Guide 1.8. Revision 2, 1987. The revised Regulatory Guide allows the STA position to be fulfilled by an independent STA or an SR0 who meets the requirements set forth in the Regulatory. Guide. The proposed change will make the GGNS

. Technical Specifications consistent with Generic Letter 86-04 guidance.

4.

Following the accident at Three Mile Island in March 1979, a number of studies were conducted to determine why the accident occurred, what factors might have contributed to its severity, and what the 4

industry and the NRC could do to prevent the recurrence of the same or similar accident. These studies concluded, among other things, that a number of actions should be taken to improve the expertise of shift operating personnel to recognize and effectively deal with plant transients or other abnormal conditions.

5.

To address these recommended improvements, the NRC initiated both short-term and long-term efforts. The short-term efforts required that each nuclear power plant have on duty an STA whose function was to provide engineering and accident assessment advice to the Shift Supervisor in the event of abnormal or accident conditions. The STA was required to have a bachelor's degree in engineering or the equivalent and specific training in plant response to transients and accidents.

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Concurrently, the' NRC and industry embarked on a long-term effort f

-aimed atLupgrading staffingLlevels and the training and

. qualifications of the operating staff, improving the man-machine 1nterface,'and 1.ncreasing capabilities for' responding to emergencies.. At the time the'STA requirement.was imposed,'it was:

intended that.the use of.the dedicated STA would be an' interim measure. onlyJuntil these longer-term goals were achieved.

7.

The Commission's " Policy. Statement on Engineering Expertise on Shift" was' published October 28, 1985, in Volume 50 of the Federal Register and issued February 13.-1986, to all licensees.in Generic. Letter

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86-04. The' Policy Statement offers the licensee two options for-meeting theicurrent requirements for providing engineering expertise on shift =(NUREG-0737, Item 1.A.1.1) and meeting licensed operator-staffing requirements;(10'CFR 50.54-(m)(2)). Option 1 provides for elimination of the separate'STA position by allowing a licensee to' r

c combine one of the required SR0 positions with the STA position into' a dual-role-(SR0/STA) position.- Option 2 states that>a licensee may continue >to use an NRC approved STA program while meeting licensed operator staffing requirements. A licensee may use either option on each shift.-

8..

In Generic Letter 86-04, the Commission encouraged licensees to move toward.theLdual-role (SR0/STA) position; however, the Commission realized that'some licensees may prefer the dedicated STA position

'for a number of reasons.

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C.

? JUSTIFICATION 1.

The proposed administrative Technical Specification change in conjunction wath previously submitted PCOL 87/14 will allow either option. of the Policy. Statement to be applied.to the STA position at GGNS. The proposed change will allow the: Shift Superintendent or another SR0 on shift to serve as both SR0 and'STA given-that specific

-training and education requirements are met, which.is.in direct agreement with the policy option (0ption 1) favored by the Commission as stated in Generic Letter 86-04.

In addition, the. option for continued use of the dedicated STA position is retained. Allowance is provided in the proposed change for using either option on each shift.

.2.

The qualifications for the dual-role SR0/STA described for Option 1 R

in the Commissioner's Policy Statement on Engineering Expertise on R

Shift are as follows:

R a.

Licensed as a senior operator on the nuclear power unit (s) to R'

which assigned, and' R

b.

Meets the STA training criteria of NUREG-0737 Item I.A.1.1, R

and.one of the following educational alternatives:

R (1) ' Bachelor's degree in engineering from an accredited R

institution; R

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-(2) Professional Engineer's license obtained'by the successful R

completion of the'PE examination; R

(3) Bachelor's degree in engineering technology from an

~R accredited institution, including course work in the R

physical, mathematical. or engineering sciences; or R

' (4) Bachelor's degree in a physical science from an accredited R institution, including course work in the physical, R

mathematical, or engineering sciences.

R-3.

The proposed. Technical Specification change would allow an R

individual with an SR0 license at GGNS-(the Shift Superintendent or R

another SR0 on-shift who meets the qualifications to be an STA) to.

R also be the required STA.on-shift; therefore. the Option 1

'R qualification' requirement to have an SR0'. license will be met.

R 4.

The GGNS STA training program is accredited by the National Nuclear' R

Accrediting Board. The training an individual. receives to become a R

dual-role SR0/STA meets the STA training criteria of NUREG-0737, R

Item I.A.1.1.

Therefore, the Option 1 training qualification will R

be fulfilled by the individual performing the dual-role SR0/STA R

function allowed by the proposed Technical Specification amendment.

.R 5.

Technical Specification 6.3 requires the STA meet or exceed the R

education'and experience requirements of ANSI /ANS 3.1-1981 as R

endorsed by Regulatory Guide 1.8, Revision 2, 1987. Technical.

R Specification 6.3 will also apply to the dual-role SR0/STA position R

since the individual filling the dual-role position must meet the R

STA qualification requirements. Regulatory Guide 1.8, Revision 2, R

1987 requires an STA to have a bachelor's degree or equivalent in a R

scientific or engineering discipline. An individual functioning at R

GGNS ds a dual-role SR0/STA will'be required then to have a R

bachelor:s degree or equivalent (Professional Engineer's license)

R in a scientific or engineering discipline. Therefore, the R

educational qualifications of Option I will be implemented by the R

proposed Technical Specification amendment.

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6.

With the proposed change, GGNS operating shift personnel will l

continue to have the expertise to recognize and effectively deal with plant transients or other abnormal conditions. Greater flexibility for meeting shift manning requirements will also result from the proposed change.

7.

Other reasons it is favorable to have the ability to utilize Option 1 (currently GGNS utilizes only Option 2) are as follows:

o It is believed to be beneficial to combine operating experience l

with engineering expertise.

o Experience has shown that an STA, who is also an SRO, is better accepted by the Shift crew; therefore, the assessment and L

direction by an SR0/STA in an Off-Normal event might be better i

accepted by the crew than assessment and advice by a dedicated l

STA.

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.1 8.

The analysis of sccidents such as Rod Withdrawal Error, Rod Drop Accidents, etc., that concern operator error, do not take credit for.

the STA as decreasing the probability of occurrence or mitigating the consequences of these accident. These accidents are mitigated by plant design (i.e. Rod Pattern Control System, Shutdown Margin, Core Monitoring Instrumentation, etc.). Thus, accident analyses are not affected by combining the SR0 and.STA positions.

9.

Currently, the Technical Specifications require an SR0 to assume but prohibits the STA from assuming the Control Room command function.

Technical Specifications require two SR0s be on shift during Operational Conditions 1, 2 or 3, of which one is the Shift Superintendent.

If one of the two required SR0s on shift is a dual-role (SR0/STA), then the individual must be allowed to assume the Control Room command function if necessary. Therefore, if the dual-role (SR0/STA) position (Option 1) is to be utilized Lt GGNS; the restriction of not allowing the STA to assume the Co.itrol Room' command function must be deleted. However, the requirement of having a valid SRO license to assume the command function is being retained which prevents an individual qualified only as an STA from assuming the command function on those shifts for which Option 2 is utilized.

'D.

NO SIGNIFICANT HAZARDS CONSIDERATIONS As discussed in:10 CFR 50.92, the following discussions are provided to the NRC Staff in support of no significant hazards considerations.

11.

No significant increase in the probability or consequences of an accident previously evaluated results from this change.

a.

The objective of the STA requirement is to improve the ability of an operating shift to recognize, diagnose and effectively deal with plant transients or'other abnormal conditions. The analysis of accidents such as Rod Withdrawal Error, Rod Drop Accidents, etc., that concern operator error, do not take credit for the STA as decreasing the probability of occurrence of these accidents. The proposed change simply provides flexibility in meeting an administrative requirement and does not involve any modifications or changes in the plant.

b.

With the proposed change, GGNS operating shift personnel will

. continue to have the expertise to recognize and effectively deal with plant transients or other abnormal events. The analysis of accidents such as Rod ' Withdrawal Error, Rod Drop Accidents, etc., that concern operator error, do not take credit for the STA as mitigating the consequences of these accidents.

Rather, these accidents are mitigated by plant design (i.e. Rod Pattern Control System, Shutdown Margin, Core Monitoring Instrumentation,etc.). The proposed change is administrative.

The expertise of the operating shift is not jeopardized and the radiological consequences of any evaluated accident remain unchanged.

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Therefore.;there is'no increase in the probability or..

-consequences;of.previously. analyzed accidents'due to the.

proposed; change.

p m j,* This ' change would not create: the possibility of-a new or different-kind of accident,from any-previously evaluated.

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a.. iThe proposed change does not involve ~any modifications;or changes.

.in the plant..This is an administrative change.in which thec i

ability of the operating shift is not jeopardized. Sinc'e r the,

b

..STA has no operational: responsibilities.or duties on shift other

than those associated'with plant transients
and accidents,'

c' mbining. the Shift Superintendent.or the second SR0 function H

o with the STA willinot introduce any new opportunity for' operator error.to' occur.

b.

Therefore, the possibility of a new or different kind of

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(accident'from any previously evaluated is not created.'

. c 3..-

This change would not involve a significant reduction in the margin of safety.

a.

The proposed change will not have any effect on safety: limits; boundary performance or system performance. The STA:or SR0/STA

!will-continue to monitor thermal limits, thermal. power, core' z m

-flow, reactor pressure and level to_ ensure' safety. limits'are not exceeded in normal'or abnormal. situations.

- b.

The functions-of the STA will continue to be carried out by an.

individual on shift. That indivic'ual on. shift will' continue to' have-the~ knowledge, training, experience, and expertise required to assess, analyze,.and evaluate. plant transients'and accidents.

There will.be no detraction from the operating' duties of,the SRO.or STA.

L c.

The proposed change still would meet'the' current NRC position on training'and qualification of STAS.

In addition,.NRC. shift staffing requirements would still be met with~ the proposed changed.

d.

Therefore' this proposed changed will not involve a reduction in the margin of safety.

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TABtE 6.2.2-1

~ MINIMUM SHIFT CREW COMPOSITION POSITION NUMBER OF INDIVIDUALS REQUIRED 10 FILL POSITION CONDITIONS 1. 2, & 3 CONo!TIONS 4 & 5 55 I

1 SRO 1

None R0 2

1 A0 n 2

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STAU*

1 None TABLE NOTATION 55 - Shif t Superintendent with a Senior Reactor Operators License on Unit 1.

~ 5R0 - Individual with a Senior Reactor operators License on Unit 1.

R0 ; - Individual with a Reactor Operators License on Unit 1.

AD - Auxiliary Operator.

STA - Shift Technical Advisor.

Eacept for the Shift Superintendent, the Shift Crew Composition may be one less than the minimum requirements of Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to. accommodate unexpected absence of onduty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the sinimum requirements of Table 6.2.2-1.

This provision does not permit any shift crew position to be unmanned upon shif t change due to an oncoming shift crewman being late or absent.

During any absence of the Shift Superintendent from the Control Room while the unit is in OPERATIONAL CONDITION 1, 2 or 3 an individual tt:- in:: t': St!'t 7;;h.k:1 ft;h:: with a valid SR0 license shall be designated to assume the Control Room command function.

During any absence of the Shif t Superintendent from the Control Room while,the unit is in CPERATIONAt CONDITION 4 or 5, an

. individual with a valid SRO or R0 license shall be designated to assume tne Control Room command function.

  • A SS or another SR0 on shift who meets the qualifications for the combined 4

SR0/STA position specified for Option 1 of the Commission's Policy Statement on Engineering Expertise on Shift, may also serve as the STA.

If this option is used for a shift, then the separate STA position may be

' eliminated for that shift.

GRAND GULF-UNIT 1 6-5 Amendment No.

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r ADMINISTRATIVE CONTROLS i

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INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) (Continued)

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of unit activities to prcvide independent verification

  • that these activities are i

performed correctly and that human errors are reduced as much as practical.

j AUTHORITY I

6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance aethities operations activities or other j

means of improving unit safety to the Vice President, Nuclear Operations.

1 6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide technical support to the Shift Superintendent in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to safe operation of the unit.

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI N18.1-1971 for comparable positions, except for the j-.

Chemistry / Radiation Control Superintendent and Shift Technical Advisor, who shall meet or exceed the education and experience requirements of ANSI /ANS

'(

3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2,1987, and licensed personnel who shall meet or exceed the criteria of the accredited license training program; and those members of the Independent Safety Engineering

- Group used for meeting the minimum complement specified in Section 6.2.3.2, each of whom shall have a Bachelor of Science degree or be registered as a Professional Engineer and shall have at least two years experience in their field, at least one year of which experience shall be in the nuclear field.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Training Superintendent, shall meet or ex-ceed INPO accreditation criteria and 10 CFR Part 55, and shall include familiarization with relevant industry operational experience.

6.5 REVIEW AND AUDIT 6.5.1 PLANT SAFETY REVIEW COMMITTEE (PSRC)

FUNCTION 6.5.1.1 The PSRC shall function to advise the GGNS General Manager on all matters related to nuclear safety.

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  • Not responsible for sign-off function.

i GRAND GULF-UNIT 1 6-6 Amendment No. 79, 51

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