U-601858, Application for Amend to License NPF-62,changing Tech Specs 6.2.3.2, Composition, Subsection 6.2.3, Independent Safety Engineering Group to Provide Second Set of Acceptable Qualifications,Per NUREG-0737

Application for Amend to License NPF-62,changing Tech Specs 6.2.3.2, Composition, Subsection 6.2.3, Independent Safety Engineering Group to Provide Second Set of Acceptable Qualifications,Per NUREG-0737

ML20085J912
Person / Time
Site:	Clinton
Issue date:	10/22/1991
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20085J918	List: ML20085J920 U-601858, Application for Amend to License NPF-62,changing Tech Specs 6.2.3.2, Composition, Subsection 6.2.3, Independent Safety Engineering Group to Provide Second Set of Acceptable Qualifications,Per NUREG-0737
References
RTR-NUREG-0737, RTR-NUREG-737 U-601858, NUDOCS 9110300009
Download: ML20085J912 (5)

Text

,, . . .. . . . . . - . . . - - . . . . .

!bnos Powet Company

c .

Conton Power station P.O. Don 678 Clinton. (L 61727

. ,4 ; ' Tel 217 915 6226 J. Stephen Perry Vro Pret, dent ELLIN9tS - -

JSP-0667-91 U-601858

'* October 22, 1991 L47-91 (10 -2 2 )-LP ,

8E.100a Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed' Amendment of Facility Op3Iptinct License No. NPF-62

Dear Sir:

~ Pursuant'to 10CPR50.90, Illinois Power (IP) hereby applies for amendment-of Facility Operating License No. NPF-62, Appendix A"- Technical Specifications,- for Clinton Power Station (CPS) .

This request consists of-proposed changes to Technical-Specification 6.2.3.2, "COMPOSICION", which is a subsection of 6 2.3, " INDEPENDENT SAFETY ENGldEERING GROUP (ISEG)". .A description of the proposed Technical Specification change, the associhted justification (including a Basis'Fo. Significant' Hszards Consideration), and a marked-up copy of t'.e  : page from the current' Technical Specifications are provided in Attachment 2.

In; addition, an-affidavit supporting the facts set forth in thic letter and its attachments in provided in Attachment 1.

IP-has reviewed the proposed changes against the criteria of

-10CFR51.22 for' categorical'exclusjon from environmental impact-considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase the

amounts:or change the types of effluents that may be released offsite, nor do they significuntly-increase itidividual or cumulative occupational radiation exposures. - Based on the foregoing, IP concludes that the proposed changes meet the.

~ criteria given in 10CFR51.22 (c) (9) for a categorical exclusion

, from the requirement for an Environmental Impact Statement.

Sincerely yours, oo. hfY L EW }

"' c '

. S. Perry oh Vjce President o.:e

Og JCA/alh-oc lS"- Attachments

"' . cc: _Regi'onal Administrator, Region III, USNRC gdf S NRC Clinton Licensing Project danager

'v 6 hV.n

A r- s NRC Resident Inspector, V-690 th Illinois Department of Nuclear Safety ji -

, . , . ,. , ..,_m.. , , , + . -~

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Atta:hmont 1

, to U-601858 STATE OF ILLINOIS COUNTY OF DEWITT John G. Cook, being first duly sworn, deposes and says: That he is Manager of Illinois Power's Clinton Power Station and has been duly authorized to submit 'his application for amendment of Facility Operating License NPF-62; that the application for amendment of Facility Operating License NPF-62 has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said application and the facts contained therein are true and correct.

DATE: This N day of October 1991 Signed:

k John n.cUhfNh

%, c y

. Subscribed and sworn to befo e', '

i'o[S day of October 1991.

'/ b'f/

aj f.!

Rg2@ / J h Vl ,

" Notary Public

L Attechment 2

, to U-601858 IS-91-015 Pago 1 of 5 Hacketround NUREG-0737, " Clarification of THI Action Plan Requirements,"

Section I.D.1,2 required all applicanta for an operating licenso to implomont an Indopondent Safety Engincoring Group (ISEG).

Thus, Clinton Power Station (CPS), with the issuance of its operating licenso in 1986, established an ISEC at CPS. Por NUREG-0737 and the CPS Technical Specificatiens, the principal function of the ISEG is to examino plant operating characteristics, NRC issuancos, industry advisories, Liconaco Event Reports (LERa) and other appropriato sources of plant design and operating experience information that may Jndicato areas for improving plant safety. The ISEG also performs indopondent reviews of plant activition including maintenanco, oporational probloms, and oporational analyson. Whera unoful improvements can be achieved, the ISEG develops and presents detailed recommendations to corporato management.

NUREG-0737 (nor ita listed references of NUREG-0660, 'NRC .Tction Plan Developed as a Posult of the TMI-2 Accident," and NUREG-0694, "TMI-Rolated Requirements for New Operating 'icenson") did not specify any minimum qualification requirements or members of the ISEG. It only called for an " increase in the availablo technical exportiso located onsite" and to "provido continuing, systematic, and independent assessment of plant activf*.ios." In the spirit of this concept, a more knowledgeable and experienced ISEG should produce higher quality and more useful recommendations for improvement as envisioned by NUREG-0737. The current CFS Technical Specifications prohibit highly trained and experienced personnel from the Operations Department who do not peasons a bachelor's degroo in engineering or related science from being members of tno ISEG, evon though a significant portion of ISEG ovaluations involvo reviews of plant activities involving operating activities.

Description of Pronosed Chongog In accordance with 10CFR50.90. IP proposes to chango CPS Technical Specification 6.2.3.2, which describes the composition of the ISEG, to provido a second set of acceptablo qualifications for ISEG members. The proposed change would allow a person who holds or has hold a CPS Senior Reactor Operator (SRO) licenso and has at least fiva yonrs of nuclear power experience to be a member of the ISEG. IP also proposes to include a restriction which tu ald require at least four of the ISEG members to hold a bachol;c's degree in engineering or rokated science. This rentriction-uould limit the number of non-dogrood SROs to no more than one of the five required ISEG members.- Thu proposed changos are indicated on the attached marked-up page from the CPS Technical Specifications. (Sco page 4 of thia request.)

Attcchm:nt-2 to U-6018f3 LS-91-015 Page 2 of 5 Justification for Pron _op_sd Chance 0 This proposed change would allow a person with a current or praviously held SRO license for CPS and five years of experience in the nuclear field to be substituted in lieu of a person with a ,

bachelor's degree in engineering or related science. The ability to add such an experienced operations person to tne CPS ISEG staff would bc very valuable by enhancing the ISEG's knowledge level and insight in the areas of plant operating activities.

This proposed change would also provide an additional career path option for SRO personnel.

The criterion included in CPS Technical Specification 6.2.3.2 for requiring a bachelor's degree stems from Section II.B.2.b of NUREG-0731, " Guidelines for Utility Managemant Structuro and Technical _ Resources," which states, " Qualification requirements for-these individuals (members of ISEG) should be at a level generally comparable to that described in Section 4.2 of' ANSI /ANS 3.1 (December 1979 draft), i.e., a bachelor's degree in engineering with two to four years experience in their field, or equivaler.t as described in Section 4.1 of ANSI /ANS 3.1."

However,-Section 4.1 of ANSI /ANS 3.1 (December 1979 draft) Liso states, " Individuals who do not possess the formal-oducation requirements specified in this section shall not be automatically eliminated where other factors provide sufficient demonstration of their abilities. These other factors should be evaluated on a case-by-case basis."

The level of training and knowledge required to obtain an SRO license is well documented and known . The proposed change to Technical Specification 6.2.3.2 would provide the ability of the CPS ISEG to broaden its expertise with direct first-hand operations experience. As noted previously, the proposed change would also require five years of experience in the nuclear field.

This is above the-current experience requirement of three years for ISEG members and is in accordance with Section 4.7.2 of ANS

, 3.1-1981. Furthar, under the proposed change. the Technical

, Specifications would. continue to require that at least four of the required ISEG members h71d a bachelor's degree in engineering

! or related science.

l l In summary,---the proposed change would provide the opportunity to b

increasc:the knowledge and experience level of the CPC ISEG in

-nuclear power plant operating activities without any disccrnible reduction in technical knowledge or skills. Hence, if the proposed option is utilized, it would increase the quality of ISEG evaluation recommendations in the area of plant operating activities.

hpsis For No Slanificant Hazards ConsidREDtion In accordance with 10CFR50.92, a proposed change to the operatJng license'(Technical Specifications) involves no significant hazards-considerations if operation of the facility in accordance with the proposed change would not: (1) involve a significant increase in the probability or consequences of any accident

Attechm:nt 2 to U-601858 LS-91-015 Page 3 of 5 ,

previously evaluated, or (2) create the possibility of a nov or different kind of accident from eny accident previously j ovaluated,'or (3) involve a significant reduction in a margin or i safnty. The proposed change is evaluated against each of these )

critoria as follows,  !

1. The proposed change is administrative in nature as it only addresses the qualification requirements of ISEG members and does not alter any plant equipment, system configurations, or operation. As a result, the proposed change cannot increase the probability or the consequences of any accident previously evaluatsd.

2. The proposed change only addresses the qualification requirements of ISEG members. The proposed chhage dvuw not alter any plant equipment, system configurations or ar.alyses. As a result, this proposed change does not introduce any new failure modes. Therefore, the proposed change cannot create-the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change only addresses the_goalification requirements of ISEG members. The proposed alternate qualification requirement of currently or previously holding an SRO. license for CPS and h;ving at least five years experience in the nuclear field is consistent with the qualification requirements recommended in Section 4.7.2 of ANS 3.1-1981. Additionally, the proposed change wjll continue to require that at least four of the ISEG members hold a bachalor's degree in engineering or related science.

As a result, the proposed change will enhance the quality, knowledge level, and insight of the CPS ISEG in the areas of

. plant operations without-any-discernible reduction in technical knowledge or skills. Therefore, the proposed l

change will not result in a significant reduction in any margin of safety.

Based upon the foregoing, Illinois Power has concluded-that this proposed change does not involve a significant hazards consideration.

.