ML20117M197

Application for Amend to License NPF-3,App A,Modifying TS 6.2.3 by Removing Specific Overtime Limits & Working H from TS Consistent W/Nrc Recent Determination,On Generic Basis, That Limits Need Not Be Specified

ML20117M197
Person / Time
Site:	Davis Besse
Issue date:	09/04/1996
From:	Jeffery Wood CENTERIOR ENERGY
To:
Shared Package
ML20117M170	List: ML20117M166 ML20117M197 ML20117M220
References
2402, NUDOCS 9609170334
Download: ML20117M197 (8)

Text

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Docket Number 50-346 1

• License Number NPF-3 Sarial Number 2402

. Enclosure )

Page 1 l APPLICATION FOR AMENDMENT TO l

FACILITY OPERATING LICENSE NUMBER NPF-3 l DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 l

l Attached is the requested change to the Davis-Besse Nuclear Power Station, Unit Number 1 Facility Operating License Number NPF-3. Also included is l the Safety Assessment and Significant Hazards Consideration.

The proposed change (submitted under cover letter Serial Number 2402) concerns: j 1

Appendix A, Technical Specifications (TS):

TS 6.2.3 Facility Staff Overtime j By:

J. K[ Wood, Vice P're'sident - Nuclear Sworn to and subscribed before me this 4th day of September, 1996.

M pm /&

Notary Public, State of Ohio My commission expires 9/3/97.

9609170334 960904 PDR ADOCK 05000346 p PDR

. _ - . - . _ - _ . . . - . - . ~ . . - . . .

pocket Numbei 50-346 License Number NPF-3 Serial Number 2402

. Enclosure Page 2 The following information is provided to support issuance of the requested revision to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Operating License NPF-3, Appendix A, Technical Specifications. The revision involves changes to TS 6.2.3, Facility Staff Overtime, and i relocation of specific overtime limits and working hours to the DBNPS l Updated Safety Analysis Report (USAR) Technical Requirements Manual (TRM). I Technical Specification 6.2.3, Facility Staff Overtime, contains the j specific controls to limit overtime hours and working hours for facility  ;

staff who perform safety-related functions. <

A. Time Required to Implement: This change is to be implemented within 90 days after NRC issuance of the License Amendment. l B. Reason for Change (License Amendment Request 96-0011): Portions of TS 6.2.3 may be relocated to the DBNPS Updated Safety Analysis Report (USAR) consistent with the NRC's recent determination that specific overtime limits and working hours need not be specified within the TS.

Future proposed changes to limits and working hours may then be evaluated in accordance with 10 CFR 50.59 and implemented if an unreviewed safety question or Technical Specification change is not involved.

C. Safety Assessment and Significant Hazards Consideration. (See Attachment). 7

Docket Number 50-346 License Number NPF-3 Serial Number 2402 Attachment SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST 96-0011 (6 pages follow) 1 I

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l LAR 96-0011

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SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION l FOR LICENSE AMENDMENT REQUEST NUMBER j 96-0011 TITLE:

Proposed Revision to the Davis-Besse Nuclear Power Station (DBNPS)

Operating License NPF-3, Appendix A, Technical Specifications to Change j Technical Specification (TS) 6.2.3, Facility Staff Overtime i

DESCRIPTION:

i The purpose of this License Amendment Request is to revise the Davis-Besse j Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A,

Technical Specifications (TS) by changing TS 6.2.3, Facility Staff Overtime, and relocating portions of it to the DBNPS Updated Safety 1 Analysis Report (USAR) Technical Requirements Manual (TRM). This revision

! will allow the DBNPS to evaluate future proposed changes to specific

! overtime limits and working hours under Section 50.59, " Changes, Tests and i Experiments," of Title 10 of the Code of Federal Regulations (10CFR), and

implement those changes which are not an unreviewed safety question or do

{ not involve a change to a TS.

l The attached markup of TS 6.2.3 shows which requirements are being removed and the text being added to facilitate this removal. The added text is editorial, with an exception being that a new requirement has been added

} for procedures to ensure that an individual's overtime is reviewed monthly l by the Plant Manager or his designee (s) to ensure that excessive hours have i

not been worked. As discussed under " Effects on Safety' below, this requirement being proposed for inclusion in TS 6.2.3 is eensistent irith the j latest NRC guidance which also determined that specific overtime littits and j working hours need not be specified within the TS.

SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:

This proposed license amendment affects the TS Administrative Controls for facility staff overtime.

FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES The overall function of the Operating License, Appendix A, TS is to impose ~

those conditions or limitations u,on reactor operation necessary to pre-serve the validity of the res'h af USAR design bases accidents. The function of the TS Section 6 Aaministration Controls, is to provide provi-sions relating to organization and management, procedures, record keeping, review, audit, and reporting necessary to assure plant operation in a safe manner.

LAR 96-0011 Page 2 The function of 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 not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or their decision-making ability.

EFFECTS ON SAFETY Facility staff overtime is described in DBNPS USAR Section 13.0, " Conduct of Operations," as controlled by administrative procedures to limit over-time hours for staff who perform safety-related functions. The USAR also states that these limits are in accordance with NUREG-0737, " Clarification of THI Action Plan Requirements," and NRC Generic Letter 82-12, " Nuclear Power Plant Staff Vorking Hours." The proposed revision to TS 6.2.3 retains control of overtime by the use of administrative procedures, that in turn, generally follow the guidance of NUREG-0737 and Generic Letter 82-12. The proposed revision is also consistent with the NRC guidance for changing and relocating TS specific overtime limits and working hours as discussed below.

10 CFR Section 50.36 establishes the regulatory requirements for licensees to include TS as part of applications for operating licenses. In addition, the Nuclear Regulatory Commission's " Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated July 22, 1993, and other NRC documents provide guidance regarding the required content of TS. The fundamental purpose of the TS, as described in the j NRC's Final Policy Statement, is to impose those conditions or limitations upon reactor operation necessary 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 that are of controlling importance to nuclear safety and establishing on them certain TS conditions of operation which cannot be changed without prior NRC approval.

The NRC's Final Policy Statement recognized, as had previous statements related to the NRC Staff's 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. Those items relocated to the USAR vould, in turn, be controlled in accordance with the requirements of 10 CFR Section 50.59. 10 CFR Section 50.59 provides criteria to determine when facility or operating changes 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. l The proposed changes and relocation 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. This determination was documented in the NRC's Staff's Safety Evaluation for Amendment Numbers 127 and 116 (NRC TAC Numbers M86191 and M86192) to the Operating Licenses (Numbers NPF-10 and NPF-15) for the Southern California Edison Company's

LAR 96-0011 Page 3 San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, approved February 9, 1996. This generic change vill be incorporated in a future revision to the NRC's " Improved Standard Technical Specifications" by the NRC Staff.

The specific overtime limits and working hours currently contained in TS 6.2.3 vill be relocated to the USAR TRM. The new requirement being added to TS 6.2.3, that plant procedures require individual overtime be reviewed monthly by the Plant Manager or his designee (s) to ensure that excessive hours have not been worked, is currently being met by the practice of supervisors reviewing individual's overtime reports on a weekly basis. The other changes to TS 6.2.3 are editorial and do not change any requirements.

Overtime vill remain controlled by plant administrative procedures and the USAR TRH generally following the guidance of the NRC's Policy Statement on working hours contained within Generic Letter 82-12, " Nuclear Power Plant Staff Vorking Hours." Changes to these plant documents vill be evaluated, prior to implementation, in accordance with the requirements of 10 CFR Section 50.59.

In summary, the proposed TS 6.2.3 changes and relocation vill not impact the ability of plant staff who perform safety-related functions, or increase fatigue and reduce the mental alertness or decision-making ability of plant staff. These TS changes are administrative and consistent with guidance from the NRC. Any future changes to these relocated requirements vill be evaluated as required by 10 CFR 50.59. Therefore, there is no adverse effect on safety as a result of these changes and relocation.

SIGNIFICANT HAZARDS CONSIDERATION:

The Nuclear Regulatory Commission has provided standards in 10 CFR Section 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed the proposed changes and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1, in accordance with these changes vould:

la. Not involve a significant increase in the probability of an accident l 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.

The proposed change to Technical Specification (TS) 6.2.3, " Facility Staff  ;

Overtime," to relocate specific overtime limits and working hours to the  !

DLNPS Updated Safety Analysis Report (USAR) is consistent with the NRC Staff's determination previously provided on a generic basis in the Safety

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. LAR 96-0011 Page 4 Evaluation to License Amendment Number 127 and 116 to the Operating Licenses (Number NPF-10 and NPF-15), for the San Onofre Generating Nuclear Station, Units 2 and 3, dated February 9, 1996. The appropriate relocation of TS requirements, such as portions of TS 6.2.3, to licensee-controlled documents is also addressed generically in the NRC's " Final Policy Statement on l Technical Specification Improvements for Nuclear Power Reactors", dated July 23, 1993.

The relocated overtime limits and working hours will be subject to reviev l

' and evaluation under Section 50.59, " Changes, Tests, and Experiments", of Title 10 of the Code of Federal Regulations (10 CFR) prior to any changes being made. The other changes to TS 6.2.3 are editorial, with an exception l being that a new requirement has been added for plant procedures to ensure that an individual's overtime is reviewed monthly by the Plant Manager or his designee (s) to ensure excessive hours have not been assigned.

Overtime vill remain controlled by plant administrative procedures and USAR requirements generally following the guidance of the NRC's Policy Statement I

on working hours contained within Generic Letter 82-12, " Nuclear Power Plant Staff Vorking Hours."

lb. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed changes do not affect accident conditions or assumptions used in evaluating the radiological consequences of an accident. The proposed changes do not alter the source term, containment isolation or allovable radiological releases.

The proposed changes to TS 6.2.3 only alter the administrative location of and the regulatory controls applicable to plant staff specific overtime limits and working hours. Therefore, there is no significant increase in the consequences of an accident previously evaluated.

2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes do not change the l vay the plant is operated, and no new or different failure modes have been defined for any plant system or component important to safety, nor has any limiting single failure been identified as a result of the proposed changes.

No new or different types of failures or accident initiators are introduced by the proposed changes.

The proposed changes to TS 6.2.3 only alter the administrative location of and the regulatory controls applicable to plant staff specific overtime limits and working hours. Therefore, there is no possibility created for a new or different kind of accident.

3. Not involve a significant reduction in a margin of safety because facility I

staff overtime is not an input in the calculation of any safety margin with l regard to Technical Specification Safety Limits, Limiting Safety System

! Settings, other Technical Specification Limiting Conditions for Operation, I

or other previously defined margins for any structure, system, or component important to safety.

. LAR #6-0011 Page 5 The proposed changes to TS 6.2.3 only alter the administrative location of and the regulatory controls applicable to plant specific overtime limits and working hours. Therefore, there is no significant reduction in a margin of safety.

CONCLUSION:

On the basis of the above, Toledo Edison has determined that the License Amendment Request does not involve a significant hazards consideration. As this License Amendment Request concerns a proposed change to the Technical Specifications that must be reviewed by the Nuclear Regalatory Commission, this License Amendment Request does not constitute an unreviewed safety question.

ATTACHMENT:

Attached are the proposed marked-up changes for the Operating License.

REFERENCES:

1. Technical Specification 6.2.3, Facility Staff Overtime.

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2. The NRC " Final Policy Statement on Technical Specifications Improvements for  !

Nuclear Power Reactors", (58 FR 39132, dated July 22, 1993).

3. " Improved Standard Technical Specifications for Babcock and Vilcox Plants," f NUREG-1430, Revision 1, dated April 7, 1995.

4. USAR Section 13.0, " Conduct of Operations," through USAR Revision 19. l

5. 10 CFR 50.36, " Technical Specifications."

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

7. NRC Generic Letter 82-12, " Nuclear Power Plant Staff Working Hours," dated June 15, 1982.

8. NUREG-0737, " Clarification of TMI Action Plan Requirements", dated October 31, 1980.

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