NL-09-0172, License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

ML091400381
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	05/19/2009
From:	Ajluni M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-09-0172
Download: ML091400381 (31)

Text

Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Blrrnlll!jildlfl, AialJal1ld 352lJ1-129'j Il' I ~: ~i)

SOUTHERN'\.

COMPANY May 19, 2009 Ellel~'l,Y to Serve lour \¥/orid Docket Nos.: 50-321 50-348 50-424 NL-09-0172 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the Technical Specifications (TS) for the Edwin I. Hatch Nuclear Plant (HNP), Joseph M. Farley Nuclear Plant (FNP),

and Vogtle Electric Generating Plant (VEGP).

The proposed amendment would delete those portions of TS superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." The availability of this TS improvement was announced in the Federal Register on December 30, 2008 (73 FR 79923) as part of the consolidated line item improvement process (CLlIP).

Enclosure 1 provides a description of the proposed change to the HNP, FNP, and VEGP TS, the requested confirmation of plant-specific applicability, verifications, and variations. Enclosures 2, 4, and 6 provide the existing TS pages marked up to show the proposed changes for HNP, FNP, and VEGP, respectively.

Enclosures 3,5, and 7 provide revised (clean) TS pages for HNP, FNP, and VEGP, respectively. Enclosure 8 provides the commitments associated with this letter.

SNC requests approval of the proposed license amendment by August 15, 2009, to support implementation of the TS changes concurrent with SNC implementation of the new 10 CFR 26, Subpart I requirements.

U. S. Nuclear Regulatory Commission NL-09-0172 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the appropriate designated Alabama and Georgia officials.

If you should have any questions regarding this submittal, please contact me.

Mr. M. J. Ajluni states he is Nuclear Licensing Manager of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

The NRC commitments contained in this letter are provided as a table in .

Respectfully submitted, ~, . ~ .. , - .

SOUTHERN NUCLEAR OPERATING COMPANY "

~~or M. J. Ajluni Manager, Nuclear Licensing rn to and subscribed before me this .if.!day of ~ ,2009.

My commission expires:  ?' e21- ,;u,I ,;L..,

MJAlTWS/daj

Enclosures:

1. Basis for Proposed Change

2. Markup for HNP Proposed TS Change

3. Clean Typed Pages for HNP Proposed TS Change

4. Markup for FNP Proposed TS Change

5. Clean Typed Pages for FNP Proposed TS Change

6. Markup for VEGP Proposed TS Change

7. Clean Typed Pages for VEGP Proposed TS Change

8. NRC Commitments

U. S. Nuclear Regulatory Commission NL-09-0172 Page 3 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. R. Madison, Vice President - Hatch Mr. T. E. Tynan, Vice President - Vogtle Ms. P. M. Marino, Vice President - Engineering RType: CFA04.054; CHA02.004; CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Ms. D. N. Wright, NRR Project Manager - Hatch Ms. D. N. Wright, NRR Project Manager - Vogtle Mr. E. L. Crowe, Senior Resident Inspector - Farley Mr. J. A. Hickey, Senior Resident Inspector - Hatch Mr. M. Cain, Senior Resident Inspector - Vogtle Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer State of Georgia Mr. C. Clark, Commissioner - Department of Natural Resources

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 1 Basis for Proposed Change

Enclosure 1 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Assessment 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations 2.3 License Conditions Regarding Initial Performance of New Surveillance and Assessment Requirements 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination 4.0 Environmental Evaluation E1-1

Enclosure 1 Basis for Proposed Change 1.0 Description On April 17, 2007, the NRC Commissioners approved a final rule amending Title 10, Part 26, of the Code of Federal Regulations (CFR) which, among other changes, established requirements for managing worker fatigue by designating individual break requirements, work hour limits, and annual reporting requirements. Subpart I was published in the Federal Register on March 31, 2008, with a required implementation period of 18 months. Compliance is, therefore, required by October 1, 2009. Prior to publication of 10 CFR Part 26, controls on worker fatigue were incorporated in plant-specific Technical Specifications (TS). With the publication of 10 CFR Part 26, these plant-specific controls are no longer needed.

The proposed change, applicable to the Edwin I. Hatch Nuclear Plant (HNP),

Joseph M. Farley Nuclear Plant (FNP), and Vogtle Electric Generating Plant (VEGP), modifies Administrative Controls TS 5.2.2, to delete paragraph e associated with work hour restrictions. The proposed change is consistent, except as noted in Section 2.2 below, with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-511, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." The availability of this TS improvement was published in the Federal Register on December 30, 2008 (73 FR 79923) as part of the consolidated line item improvement process (CUIP).

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Southern Nuclear Operating Company (SNC) has reviewed the safety evaluation dated December 30,2008 as part of the CUIP.

This review included a review of the NRC staffs Safety Evaluation, as well as the supporting information provided to support TSTF-511.

SNC has concluded that the justifications presented in the TSTF and the Safety Evaluation prepared by the NRC staff are applicable to Units 1 and 2 of HNP, FNP. and VEGP and justify this amendment for the incorporation of changes to the TS for Units 1 and 2 of HNP, FNP, and VEGP.

Based on this review, SNC has identified one deviation from the TSTF and corresponding NRC model SER, as it applies to the HNP, FNP, and VEGP TS. Specifically, TSTF-511. Revision 0, identifies the affected paragraph to be paragraph d of TS section 5.2.2. The affected section for HNP, FNP, and VEGP is paragraph e of TS section 5.2.2. With the exception of this deviation, the remainder of the TSTF and corresponding NRC model SER, including the conclusions contained therein, are applicable to the proposed TS change.

E1-2

Enclosure 1 Basis for Proposed Change 2.2 Optional Changes and Variations SNC is not proposing changes or deviations from the TS changes described in TSTF-511, Revision 0, except as noted below:

1. The affected TS paragraph applicable to HNP, FNP, and VEGP is TS 5.2.2(e) as opposed to TS 5.2.2(d) described in TSTF-511, Revision 0, and the NRC model SER.

2. In lieu of renumbering the remaining sections in TS 5.2.2, SNC proposes to annotate TS 5.2.2(e) to indicate that it has been deleted without renumbering the remaining TS 5.2.2 sections (Le .. TS 5.2.2(f) and 5.2.2(g)).

2.3 Licensing Commitment to implement 10 CFR Part 26, Subpart I, Concurrent with Elimination of TS 5.2.2(e)

SNC will implement the requirements of 10 CFR Part 26, Subpart I, concurrent with elimination of TS 5.2.2(e) as described in Enclosure 8 of this submittal.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination SNC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CU/P. SNC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Units 1 and 2 of HNP, FNP, and VEGP and the evaluation is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a) for this application.

4.0 Environmental Evaluation SNC has reviewed the environmental evaluation included in the model safety evaluation dated December 30,2008 as part of the CUIP. SNC has concluded that the staff's 'findings presented in the published evaluation are applicable to Units 1 and 2 of HNP. FNP, and VEGP and the evaluation is hereby incorporated by reference for this application.

E1-3

Edwin J. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 2 Markup for HNP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room for each unit that contains fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c. The minimum shift crew composition shall be in accordance with 10 CFR 50.54(m)(2)(i). Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a 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 on duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not Deleted more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

(continued)

HATCH UNIT 1 5.0-3 Amendment No. ~

Organization 5.2 5.2 Organization 5.2.2 Unit Staff

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift supervisor in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

HATCH UNIT 1 5.0-4 Amendment No. ~

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room for each unit that contains fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c. The minimum shift crew composition shall be in accordance with 10 CFR 50.54(m)(2)(i). Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a 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 on duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not Deleted more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

(continued)

HATCH UNIT 2 5.0-3 Amendment No.~

Organization 5.2 5.2 Organization 5.2.2 Unit Staff

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift supervisor in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

HATCH UNIT 2 5.0-4 Amendment No. ~

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF*511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 3 Clean Typed Pages for HNP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room for each unit that contains fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c. The minimum shift crew composition shall be in accordance with 10 CFR 50.54(m)(2)(i). Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a 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 on duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e. Deleted.

(continued)

HATCH UNIT 1 5.0-3 Amendment No.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift supervisor in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

HATCH UNIT 1 5.0-4 Amendment No.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room for each unit that contains fuel in the reactor. In addition, while the unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c. The minimum shift crew composition shall be in accordance with 10 CFR 50.54(m)(2)(i). Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a 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 on duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e. Deleted.

(continued)

HATCH UNIT 2 5.0-3 Amendment No.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift supervisor in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

HATCH UNIT 2 5.0-4 Amendment No.

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 4 Markup for FNP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room. A single SRO may fill this position for both units.

c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g 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 on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. A Health Physics Technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide Deleted for unexpected absence, provided immediate action is taken to fill the required position.

e.

(continued)

Farley Units 1 and 2 5.2-2 Amendment No. IH§ (Unit 1)

Amendment No. l!B (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

/

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the responsible SRO in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. The same individual may fill this position for both units.

Farley Units 1 and 2 5.2-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 5 Clean Typed Pages for FNP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room. A single SRO may fill this position for both units.

c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g 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 on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. A Health Physics Technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e. Deleted.

(continued)

Farley Units 1 and 2 5.2-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. The Shift Technical Advisor (STA) shall provide advisory technical support to the responsible SRO in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. The same individual may fill this position for both units.

Farley Units 1 and 2 5.2-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from T5 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 6 Markup for VEGP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) 2, 3, or 4. With both units in MODES 5 or 6 or defueled, a total of three non-licensed operators are required for the two units.

b. At least one licensed RO shall be present in the control room when fuel is in the reactor.

---

NOTE-----------------------------------------------

A single SRO licensed on both units may fulfill this function for both units.

In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed SRO shall be present in the control room.

c. The shift crew composition may be less than the minimum requirement of 10 CFR 50.54 (m)(2)(i) and 5.2.2.a and g 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 on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. ---------------------------------------- NOTE-----------------------------------------------

A single Health Physics Technician may fulfill this position for both units.

A Health Physics Technician shall be on site when fuel is in the reactor.

Deleted The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, proVided immediate action is taken to fill the required position.

e.

(continued)

Vogtle Units 1 and 2 5.2-2 Amendment No. ~ (Unit 1)

Amendment No. ~ (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. An individual shall be assigned who provides technical support in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall be available for duty when the plant is in modes 1-4. At other times, this individual is not required. In addition, this individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This position may also be filled by the Shift Superintendent or (continued)

Vogtle Units 1 and 2 5.2-3 Amendment No. ~ (Unit 1)

Amendment No. ~ (Unit 2)

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF*511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 7 Clean Typed Pages for VEGP Proposed TS Change

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) 2, 3, or 4. With both units in MODES 5 or 6 or defueled, a total of three non-licensed operators are required for the two units.

b. At least one licensed RO shall be present in the control room when fuel is in the reactor.

---

NOTE-----------------------------------------------

A single SRO licensed on both units may fulfill this function for both units.

In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed SRO shall be present in the control room.

c. The shift crew composition may be less than the minimum requirement of 10 CFR 50.54 (m)(2)(i) and 5.2.2.a and g 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 on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. ----------------------------------------NOTE-----------------------------------------------

A single Health Physics Technician may fulfill this position for both units.

A Health Physics Technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e. Deleted.

(continued)

Vogtle Units 1 and 2 5.2-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or at least one Operations Superintendent shall hold an SRO license.

g. An individual shall be assigned who provides technical support in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall be available for duty when the plant is in modes 1-4. At other times, this individual is not required. In addition, this individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

This position may also be filled by the Shift Superintendent or the individual with an SRO license provided that person meets the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Vogtle Units 1 and 2 5.2-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Edwin I. Hatch Nuclear Plant Units 1 and 2 Joseph M. Farley Nuclear Plant Units 1 and 2 Vogtle Electric Generating Plant Units 1 and 2 Request for Technical Specification Amendment License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26 Enclosure 8 NRC Commitments

NRC Commitments List of Regulatory Commitments The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENTS DUE DATE / EVENT

1. SNC will implement the Concurrent with requirements of 10 CFR Part 26, elimination of TS Subpart I, concurrent with 5.2.2(e) elimination of TS 5.2.2(e).

E8-1