ML15167A315

Issuance of Amendments Change to TS Requirements Regarding Education and Experience Eligibility Requirements for Licensed Operators

ML15167A315
Person / Time
Site:	Nine Mile Point
Issue date:	07/08/2015
From:	Mozafari B Plant Licensing Branch 1
To:	Orphanos P Exelon Generation Co, Nine Mile Point
Mozafari B, NRR/DORL/LPLI-1
References
TAC MF4786, TAC MF4787
Download: ML15167A315 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 8, 2015

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS. 1 AND 2 - ISSUANCE OF AMENDMENTS - RE: CHANGE TO TECHNICAL SPECIFICATION REQUIREMENTS REGARDING EDUCATION AND EXPERIENCE ELIGIBILITY REQUIREMENTS FOR LICENSED OPERATORS (TAC NOS. MF4786 AND MF4787)

Dear Mr. Orphanos:

The Commission has issued the enclosed Amendment No. 218 to Renewed Facility Operating License No. DPR-63 and Amendment No. 148 to Renewed Facility Operating License No.

NPF-69 for the Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2). The amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated September 11, 2014.

The amendments revise the licensed operator training and qualification education and experience eligibility requirements specified in NMP1 TS 6.3.1 and NMP2 TS 5.3.1 to the eligibility requirements specified in this License Amendment Request. The proposed eligibility requirements correspond to the eligibility requirements contained in the current National Academy for Nuclear Training (NANT) Academy Document, ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators," dated February 2010.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, v~~lffixtl~

Brenda L. Mozafari, Sr. Pr~:<J.J.nager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosures:

1. Amendment No. 218 to DPR-63

2. Amendment No. 148 to NPF-69

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-220 NINE MILE POINT NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 218 Renewed License No. DPR-63

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee), dated September 1, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter 1; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-63 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 218, are hereby incorporated in the license. Exelon Generation Company, LLC, the licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULA TORY COMMISSION

~~__d Michael I. Dudek, Acting Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of lssuance:Jul y 8, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 218 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 4 4 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 349 349

(2) Exelon Generation pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40 and 70, to

• receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components.

(5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30; Section 40.41 of Part 40; Section 50.54 and 50.59 of Part 50; and Section 70.32 of Part 70. This renewed license is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect and is also subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 1850 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. is hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.

(3) Deleted Renewed License No. DPR-63 Amendment No. 191 through 210, 211, 213, 214, 215, 216, 217, 218 Correction Letter Dated August 7, 2012 Correction Letter Dated March 17, 2015

(1) Maximum Power Level Exelon Generation is authorized to operate the facility at reactor core power levels not in excess of 3988 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Fuel Storage and Handling (Section 9.1, SSER 4)*

a. Fuel assemblies, when stored in their shipping containers, shall be stacked no more than three containers high.

b. When not in the reactor vessel, no more than three fuel assemblies shall be allowed outside of their shipping containers or storage racks in the New Fuel Vault or Spent Fuel Storage Facility.

c. The above three fuel assemblies shall maintain a minimum edge-to-edge spacing of twelve (12) inches from the shipping container array and approved storage rack locations.

d. The New Fuel Storage Vault shall have no more than ten fresh fuel assemblies uncovered at any one time.

(4) Turbine System Maintenance Program (Section 3.5.1.3.10, SER)

The operating licensee shall submit for NRC approval by October 31, 1989, a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities.

(Submitted by NMPC letter dated October 30, 1989 from C.D. Terry and approved by NRC letter dated March 15, 1990 from Robert Martin to Mr. Lawrence Burkhardt, 111).

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-69 Amendment 117 through 140, 141, 143, 144, 146, 147,218

e. As a minimum, either the Manager Operations or the General Supervisor Operations shall hold an SRO license.

f. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift supervision 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.

6.3 Unit Staff Qualifications 6.3.1 Each member of the unit staff, with the exception of the operator license applicants and the radiation protection manager, shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The licensed operators shall comply only with the requirements of 10 CFR 55.

6.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 6.3.1, perform the functions described in 10 CFR 50.54(m).

6.4 Procedures 6.4.1 Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and cover the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 3, 1972; AMENDMENT NO. 142. 157. 158. 160. 162. 181. 198. 203, 218 349

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NINE MILE POINT NUCLEAR STATION. LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 148 Renewed License No. NPF-69

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee), dated September 11, 2014. complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter 1; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2. C. (2) of Renewed Facility Operating License No. NPF-69 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 148 are hereby incorporated into this license.

Exelon Generation Company, LLC, shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Michael I. Dudek, Acting Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: July 8, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 148 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 5.3.1 5.3.1

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff, with the exception of the operator license applicants and the radiation protection manager, shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions.

The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The licensed operators shall comply only with the requirements of 10 CFR 55.

NMP2 5.3-1 Amendment 91, 127, 148

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS NOS. 218 AND 148 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-63 AND NPF-69 NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY, LLC DOCKET NOS. 50-220 AND 50-410 NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2

1.0 INTRODUCTION

By letter dated September 11, 2014, Exelon Generation Company (EGC), requested changes to Nine Mile Point 1 (NMP1) Technical Specifications (TS) Section 6.3.1 and Nine Mile Point 2 (NMP2) Technical Specifications (TS) Section 5.3.1 (Agencywide Document Access and Management System (ADAMS) Accession No. ML14254A007). The current requirement specifies that operator license applicant's education and experience eligibility requirements and changes thereto shall be reviewed and approved by the U.S. Nuclear Regulatory Commission (NRC) and described in an applicable station training procedure. The proposed amendment would revise NMP1 TS 6.3.1 and NMP2 TS 5.3.1, "Unit Staff Qualifications," to state that Licensed Operators shall comply with Title 10 Part 55 of the Code of Federal Regulations (10 CFR) Part 55.

2.0 REGULATORY EVALUATION

In March 1985, the NRC issued the Commission Policy Statement on training and qualification of nuclear power plant personnel which endorsed the training accreditation process and the National Academy for Nuclear Training (NANT) guidelines. In Generic Letter 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10 CFR 55 and Conforming Amendments," dated March 19, 1987, and in NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses," published November 1987, the NRC indicated it would accept a facility's licensed operator training program if the facility certified in writing that the program was accredited and based on a systems approach to training (SAT). This certification would supersede the requirements of American National Standards Institute (ANSI) N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," and ANSl/ANS-3.1-1978, "Selection and Training of Nuclear Power Plant Personnel." Facility

licensees were advised to submit a request to the NRC for an administrative change to their licensing documents to conform to their accredited program status.

In January 1992, the NRC published its proposed rule 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel." The proposed rule stated that, if adopted, the rule would supersede the Commission's Policy Statement on training and qualification of nuclear power plant personnel and would not result in any change to accredited programs. The Commission concluded that accredited programs, implemented consistent with industry objectives and criteria, would be in compliance with this regulation.

In April 1993, the NRC published its final rule on training and qualification of nuclear power plant personnel. The rule requires nuclear power plant licensees to establish, implement, and maintain SAT-based training programs for nine non-licensed positions. Accreditation of these nine training programs is an acceptable means of meeting the requirements of 10 CFR 50.120.

In January 2001, the NRC published NRC Regulatory Issue Summary (RIS) 2001-1, "Eligibility of Operator License Applicants," to familiarize licensees with the NRC's current guidelines for the qualification and training of reactor operator and senior operator license applicants. The RIS 2001-01 acknowledged that 10 CFR 55.31(a)(4) allows the NRC to accept an application for an operator's license if the facility certifies that the applicant has successfully completed a Commission approved training program that is based on a SAT. In addition, RIS 2001-01 stated that: (1) a training program would be considered approved by the NRC when it receives or renews accreditation from the National Nuclear Accrediting Board (NNAB); (2) accreditation of operator training programs suggests that facilities are implementing the education and experience guidelines endorsed by the NNAB; (3) NANT guidelines for education and experience outline acceptable methods for implementing the Commission's regulations; and (4) the staff encourages all facility licensees to review their requirements and commitments related to licensed operator and senior operator education and experience and to update their documentation (e.g., Updated Final Safety Analysis Report (UFSAR), TSs, and training program descriptions) to enhance consistency and minimize confusion.

3.0 TECHNICAL EVALUATION

The licensee has proposed to remove operator license applicant education and experience requirements from the TS. The licensee states in its letter that Nine Mile Point Nuclear Station's (NMNPS) education and experience requirements are administratively controlled through each unit's UFSAR, accredited licensed operator training program, or training procedures that ensure the operation of the facility in a safe manner. The licensee further states that NMPNS Operator Training Programs are designed in accordance with accreditation programs described in the latest approved NANT guidelines and that a station authorized representative will continue to certify that licensed operator applicants meet educational and experience requirements outlined by NANT guidelines.

The licensee has proposed to revise TS 5.3.1/6.3.1, "Unit (Facility) Staff Qualifications," to remove operator license applicant education and experience requirements and add the requirement that licensed operators shall comply with 10 CFR Part 55. The licensee states in its letter dated September 11, 2014, that EGC's education and experience requirements for operator license applicants are administratively controlled through each station's updated FSAR. The letter also states that the licensed operator training programs are based on an SAT

and are accredited by the NANT. Since 10 CFR 55.31(a)(4) allows the NRC to accept an application for an operator's license if the facility licensee certifies that the applicant has successfully completed a Commission-approved training program, that is based on an SAT in lieu of providing details of the applicant's education and experience, this change meets the 10 CFR 55.31 (a)(4) requirements to apply for an operator's license and ensures the facility licensee maintains administrative controls that assure the operation of the facility in a safe manner by properly qualified licensed operators. Therefore, the staff concludes that the proposed changes to TS 5.3.1/6.3.1 are acceptable.

Based on the above discussion, the NRC staff concludes that the proposed revision is consistent with 10 CFR Part 55 and does not affect nuclear safety or plant operations.

Therefore, the proposed changes to NMP1 TS 6.3.1 and NMP2 TS 5.3.1 are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State officials were notified of the proposed issuance of the amendment. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to TS administrative controls associated with eligibility of licensed operators. As such, the amendments relate to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(1 O)(ii). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: S. Currie Date: July 8, 2015

July 8, 2015 Mr. Peter Orphanos Vice President Nine Mile Point Exelon Generation Company, LLC Nine Mile Point Nuclear Station, LLC P. 0. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS. 1 AND 2 - ISSUANCE OF AMENDMENTS - RE: CHANGE TO TECHNICAL SPECIFICATION REQUIREMENTS REGARDING EDUCATION AND EXPERIENCE ELIGIBILITY REQUIREMENTS FOR LICENSED OPERATORS (TAC NOS. MF4786 AND MF4787)

Dear Mr. Orphanos:

The Commission has issued the enclosed Amendment No. 218 to Renewed Facility Operating License No. DPR-63 and Amendment No. 148 to Renewed Facility Operating License No.

NPF-69 for the Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2). The amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated September 11, 2014.

The amendments revise the licensed operator training and qualification education and experience eligibility requirements specified in NMP1 TS 6.3.1 and NMP2 TS 5.3.1 to the eligibility requirements specified in this License Amendment Request. The proposed eligibility requirements correspond to the eligibility requirements contained in the current National Academy for Nuclear Training (NANT) Academy Document, ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators," dated February 201 O.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, IRA/

Brenda L. Mozafari, Sr. Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosures:

1. Amendment No. 218 to DPR-63

2. Amendment No. 148 to NPF-69

3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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DATE 6/16/2015 7/07/2015 5/28/2015 6/24/2015 6/30/2015 7/08/2015 OFFICIAL RECORD COPY