PY-CEI-NRR-2207, Application for Amend to License NPF-58,revising TS 5.2.2.e, Organization-Unit Staff, by Removing Ref to NRC Policy Statement on Working Hours

Application for Amend to License NPF-58,revising TS 5.2.2.e, Organization-Unit Staff, by Removing Ref to NRC Policy Statement on Working Hours

ML20210T956
Person / Time
Site:	Perry
Issue date:	09/08/1997
From:	Myers L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210T962	List: ML20210T963 PY-CEI-NRR-2207, Application for Amend to License NPF-58,revising TS 5.2.2.e, Organization-Unit Staff, by Removing Ref to NRC Policy Statement on Working Hours
References
PY-CEI-NRR-2207, NUDOCS 9709160209
Download: ML20210T956 (8)

Text

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CENTEREOR ENERGY Pdwer Generation Group Perry Nuclear Power Plant Mail Address: 216-280-6915 Low W. Myers 10 Center Roaj P.O. Box 97 FAX:216-280 8029 W; Presidert Perry. Ofe 44081 Perry. OH 44081 September 8,1997 PY-CEl/NRR 2207L

- Uniteo States Nuclear Regulatory Commission Document Control Desk

' Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90: Proposed Revision of Technical Specification 5.2.2.e, " Organization - Unit Staff' Ladies and Gentlemen:

Nuclear Regulatory Commission (NRC) review and approval of a license amendment for the Perry Nuclear Power Plant (PNPP)is requested. The proposed amendment would revise Technical Specification (TS) 5.2.2.e, " Organization - Unit Staff," by removing the reference to the NRC Policy Statement on working hours. The revised TS 5.2.2.e incorporates a requirement for administrative procedures necessary to ensure that the working hours of unit staff who perform safety-related functions are limited and controlled. The revised TS is consistent with die policy statement, with the exception that specific overtime limits and working hours are relocated to plant administrative procedures.

This revision will allow changes to specific overtime limits and working hours to be evaluated in accordance with 10 CFR 50,59, " Changes, Tests and Experiments," and will allow implementation of those changes which are not an unreviewed safety question or do not involve a change to the TS. This change is consistent with the NRC's recent determination, on a generic basis, that such limits need not be specified in the TS.

Attachment I provides the Summary, Description of the Proposed Change, Safety Analysis, and ,

Environmental Consideration. Attachment 2 provides the Significant Hazards Consideration.

Attachment 3 provides the annotated TS page reflecting the proposed change.

If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory AfTairs, at (440) 280-5606.

- Very truly yours, f Mo Attabts M',[(Ul i cc: NRC Region ill NRC Project Manager NRC Resident inspector llllllll@gll

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State of 0hio 9709160209 970900 PDR ADOCK 05000440 P PDR

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a 1, Lew W. Myers, being duly sworn state that (1) I am Vice President - Nuclear, of the Centerior Service Company, (2) I am duly authorized to execute and file this certification on behalf of The Cleveland Electric illuminating Company and Toledo Edison Company, and as the duly authorized agent for Duquesne Light Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief.

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_,_ Attachment i PY-CEl/NRR 2207L Page1of4

SUMMARY

The proposed :hange, which is consistent with recent Nuclear Regulatory Commission (NRC) guidance, requests revision of the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS) to revise existing TS 5.2.2.e regarding limits and controls placed on overtime worked by unit staff members performing safety related functions. The current TS states:

The amount of overtime worked by unit staff members performing safety related functions shall be limited and controlled in accordance with NRC Policy Statement on working hours (Generic Letter 82-12).

The proposed TS change removes the reference to the NRC Policy Statement on working hours, and adds a requirement for administrative procedures necessary to ensure that the working hours of unit staff who perform safety-related functions are limited and controlled. The revised TS is consistent with the NRC policy statement, with the exception that controls for specific overtime limits and working hours are relocated to plant administrative procedures. This revision will allow changes to specific overtime limits and working hours to be evaluated in accordar.cc with 10 CFR 50.59, " Changes, Tests and Experiments," and will allow implementation of those changes which are not an unreviewed safety question or do not involve a change to the TS. This change is consistent with the NRC's recent determination, on a generic basis, that specific overtime limits and working hours need not be specified within the TS, DESCRIPTION OF THE PROPOSED CHANGE The proposed change would revise Technical Specification 5.2.2.e such that it would read:

e. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety related fimetions (e.g., licensed SROs, licensed ROs, health physicists, auxiliary operators, and key maintenance personnel). The procedures shall include guidelines on working hours that ensure that adequate shift coverage is maintained without routine heavy use of overtime.

- Attachment 3 provides a copy of the annotated TS page.

SAFETY ANALYSIS The overall function of the TS is to impose conditions or limitations upon reactor operation necessary to preserve the Updated Safety Analysis Reports (USAR) design basis accidents analyses. The function of TS Section 5, " Administrative Controls," is to describe the provisions -

relating to organization and management, procedures, programs and manuals, reporting requirements, and controls for high radiation areas, necessary to assure plant operation in a safe

- manner.

The function of unit staff overtime limits is'to prevent situations where fatigue could reduce the ability of operating personnel to maintain the plant in a safe condition. These limits apply to

- plant staff who perform safety-related functions, and are established to assure that personnel are

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PY CEl/NRR 2207L l Page 2 of 4 4  !

not assigned to shift duties u hile in a fatigued condition that could reduce their mental alertness 3 or their decision making ability The proposed TS change, and rehication of overtime controls to i plant administrative procedures, will continue to assure that personr:cl are not assigned to shill

! duties while la a fatigued condition. '

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• scribed in PNPP USAR Chapter 13. " Conduct of Operations," facility staff overtime is contrelled by administrative procedures to limit maximum working hours for those personnel i

performing safety related functions. These limits are in accordance with NUREG 0737, i " Clarification of TMI Action Plan Requirements," and NRC Generic Letter 8212. " Nuclear j- Power Plant Staf! Working flours." The proposed revision to TS 5.2.2.c retains control of i overtime by the use of administrative procedures. The proposed revision is also consistent with the NRC guidance for changing and relocating TS specific overtime limits and working hours as discussed below.

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10 CFR 50.36, " Technical Specifications," establishes regulatory requirements for licensees to include TS as part of applications for operating Ikenses. In addition, the NRC's " Final Policy Statement on Technical Specification improvements for Nuclear Power Reactors," dated July 22, j 1993, and other NRC documents provide guidance regarding the required content of TS. The fundamental purpose of the TS, as described in the NRC's Final Policy Statement, is to impose necessary conditions or limitations upon reactor operation to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

This is accomplished by identifying those features of controlling importance to nuclear safety J

and establishing certain TS conditions of operation for these features, which cannot be changed 4- without prior NRC approval.

1 The NRC's Final Policy Statement recoanized, as had previous statements related to the NRC Staffs TS Improvement Program, that implementation of the policy would result in the relocation of some existing TS requirements to licensee-controlled documents such as the USAR or Operational Requirements Manual (ORM). Items relocated to licensee-controlled documents would, in turn, be controlled in accordance with the requirements of 10 CFR 50.59, " Changes, l Tests and Experiments," which provides criteria to determine when facility or operating changes l planned by a licensee require prior NRC approval in the form of a license amendment in order to >

address any unreviewed safety questions or TS changes.

The proposed change is consistent with the NRC's recent determination, on a generic basis, that '

specific overtime limits and working hours need not be specified within the TS. His determination was documented in the NRC Staffs Safety Evaluation for Amendment Numbers

127 and 116 to the Operating Licenses (Numbers NPF 10 and NPF 15) for the Southem l' California Edison Company's San Onofre Nuclear Generating Station, Units 2 and 3, approved February 9,1996. In addition, this NRC detennhiation was also recently documented in the NRC Staffs Safety Evaluation for Amendment Number 212 to operating License NPF 3 for the Davls Besse Nuclear Power Station, Unit 1 These safety evaluations also indicate that a generic -

I change will be incorporated in a future revision to the NRC's " improved Standard Technical Specifications" by the NRC Staff.

, Attachment i I PY CEl/NRR 2207L i Page 3 of 4 )

i The reference to the NRC Policy Statement on working hours, which discusses specine overtime limits and working hours, currently contained in TS 5.2.2.e will be removed from the TS. The revised TS 5.2.2.e incorporates a requirement for administrative procedures necessary to ensure that the working hours of unit staff wbo perform safety related functions are limited and controlled. The revised TS is consistent with the policy statement and NUREG 1434," Standard Technical Speci0 cations, General Electric Plants, llWlU6," with the exception that specinc overtime limits and working hours are relocated to plant administrative proevdmes. Overtime will be controlled by adherence to plant administrative procedures, and changes to these plant documents are required l to be evaluated in accordance with the requirements of 10 CFR 50.59. l In summary, the proposed TS 5.2.2.e change will not impact the ability of plant stalT who perform safety related funcdons, or increase fatigue and reduce the mental alertness or decision-making ability of picnt stalT. This TS change is administrative and consistent with guidance from the NRC. Changes to these relocated requirements will be evaluated, as required, by 10 CFR 50.59. Therefore, there is no adverse effect on safety as a result of the proposed change.

ENYlROMIENTALCOMIDDMI1QN The proposed TS change request was evaluated against the criteria of 10 CFR 51.22 for i environmental considerations. The proposed change does not signincantly increase individual or cumulative occupadonal radiation exposures, does not signincantly change the types or signincantly increase the amounts of efnuents that may be released off site and, as discussed in Attachment 2, does not involve a signincant hazards consideration. Based on the foregoing, it has been concluded that the proposed TS change meets the criteria given in 10 CFR S t.22(c)(9) for categrical exclusion from the requirement for an Environmentalimpact Statement.

COMMITMENTS WITIIIN Tills Lf'TTEll There are no regulatory commitments made in this letter. Any actions discussed in this document represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments. Please notify the Manager Regulatory Affairs at Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.

REFEllENCES

1. Technical Speci0 cation 5.2.2.e," Organization Unit Stcff."

2, NRC " Final Policy Statement on Technical Speci0 cations improvements for Nuclear Power Reactors,"(58 FR 39132, dated July 22,1993).

3. NUREG 1434," Standard Technical Speci0 cations, General Electric Plants, DWR/6," dated April 1995.

4. USAR Chapter 13.0," Conduct of Operationi," Revision 8.

. Attachment i PY CElHRR 2207L Page 4 of 4

5. 10 CFR 50.36, " Technical Specifications." <

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6. 10 CFR 50.59, " Changes, Tests and lixperiments."

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7. NRC Generic 1.etter 8212," Nuclear Power Plant Staff Working llours," dated June 15, 1982.

l 8. NUREG 0737," Clarification ofTMl Action Plan Requirements," dated October 31,1980.

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9. NUREG 0887," Safety Evaluation Report Related to the Operation of Perry Nuclear Power j Plant, Units 1 and 2," dated May 1982, i

10. Letter from M. Fields (NRC) to 11. Ray (Southtrn Califointa Edison Company). " Issuance of Amendment for San onofre Nuclear Generating Station, Unit No. 2 (TAC No. M86191) and Unit No. 3 (TAC No M86192)," dated February 9,1996.

I1. I.etter from A. Ilansen (NRC) to J. Wood (Centerior Service Company), " Amendment I No. 212 to Facility Operating License No. NPF 3 Davis llesse Nuclear Power Station, Unit No. I (TAC No. M96518)." dated November 8,1996.

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, Attachment 2 PY CEl'NRR 2207L Page 1 of 2

+ *ijGNIElCANI,llAZARDS CONSIDrilAllON The proposed change to Technical Speci0 cation (TS) 5.2.2.c " Organization - Unit Staff" removes the reference to the Nuclear llegulatory Commission (NRC) policy Statement on working hours, and adds a requirement for administrative procedures necessary to ensure that the working hours of unit staff who perform safety related functions are limited and controlled. The speci0c overtime limits and working hours will be selocated to plant administrative procedures.

• lhe standards used to arrive at a determination that a request for amendment involves no signi0 cant hazards considerations are included in the Commission's Regulations,10 CI:R 50.92 l which state that the oyration of the facility in accordance with the proposed amendment would not (1) involve a signincant increase in the probability or consequences of an accident previously evaluated,(2) create the possibility of a r.ew or ditTerent kind of accident from any previously l evaluated, or (3) involve a signincant reduction in a margin of safety.

l The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed change does not involve a signi0 cant hazard because:

1. The proposed change does not involve a signincant increase in the probability or consequences of an accident previously evaluated.

• lte proposed change to TS 5.2.2.e o. ly alters the administrative location of and the regulatory controls applicable to unit staff speci0c overtime limits and working hours.

Overtime will remain controlled by plant administrative procedures. Changes to the relocated overtime limits and ivorking hours will be subject to review and evaluation under 10 CFR 50.59, " Changes, Tests and Experiments." There is not an increase in the probability of an accident previously evaluated because no change is being made to any accident initiator. No previously analyzed accident scenario is changed, and initiating conditions and assumptions remain as previously analyzed.

'I here is not an increase in the radiological consequences of an accident previously evaluated because the proposed change does not affect accident conditions or assumptions used in evaluating the radiological consequences of an accident. The proposed change does not alter the source term, containment isolation, or allowable radiological releases. Therefore, there is no increase in the radiological consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new of different kind of accident from any accident previously evaluated.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change does not change the way the plant is operated, and no new or different failure modes have been deOned for any plant system or component important to safety, nor has any limiting single failure been identified as a result of the proposed change, No new or different types of failures or accident initiators are introduced by the proposed change.

• Attachment 2 PY CE!/NRR 2207L Page 2 of 2 SIGhlDCANUIAZAlms coMiluttuTioN The proposed change to lS 5.2.2.e only alters the administrative location of and the regulatory controls applicable to unit staff specific overtime limits and working hours.

Therefore, there is no possibility created for a new or different kind of accident.

3. The proposed change does not involve a significant reduction in a margin of safety, i

lhe proposed change does not involve a reduction in a margin of safety because unit staff overtime is not an input in the calculation of a safety margin with regard to Technical Specification Safety Limits, Limiting Safety System Settings, other Technical Specification U'niting Conditions for Operation, the Operational itequirements Manual, or other previously defined margins for any structure, system, or component important to safety. The l

proposed change to TS 5.2.2.c only alters the administrative location of and the regulatory controls applicable to unit staff specific overtime limits and working hours.

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