ML070310210

Proposed Amendment Consisting of an Administrative Change to the Technical Control Desk Con Edison Letter Dated January 22, 1999, A.A. Blind to Document Control Desk

ML070310210
Person / Time
Site:	Indian Point
Issue date:	07/20/1999
From:	Blind A A Consolidated Edison Co of New York
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2007-0060
Download: ML070310210 (10)

Text

A. Alan Blind Vice President Consolidated Edison Company of New York. fnic.Indian Point station Broadway & Bleakley Avenue Buchanan, NY 10511 Telephone (914) 734-53.40 Fax: (914) 734-5718Juy2,19 blinda~conoed.cmm uy2,19 Re: Indian Point Unit No. 1 Docket No. 5,0-3 Document Control Desk US Nuclear Regulatory Commission Mail Station P1-137 Washington, DC 20555-0001

Subject:

Proposed Amendment Consisting Of An Administrative Change To The Technical Specifications

Reference:

1) Con Edison Letter dated January 22, 1999, A. A. Blind To Document Control Desk Transmitted herewith are the original and two (2) copies of an "Application for Amendment to the Operating License," sworn on July 20, 1999. This application requests an amendment to the Consolidated Edison Company of New York, Inc. (Con Edison), Indian Point Unit No. 1 Technical Specifications.

In accordance with 10 CFR 50.91, a copy of this application and the associated attachments are being submitted to the designated New York State official.Con Edison transmitted (Reference

1) proposed changes to the Indian Point 2 Technical Specifications which included a revision to Section 6.2.2.h to change the senior reactor operator license requirement for the Operations Manager. This application provides a proposed amendment to the Indian Point 1 Technical Specifications to provide a similar change to Section 3.2. 1.i.Attachment I to this letter provides the proposed new Technical Specification 3.2. '1. i, while Attachment H provides the Safety Assessment.

It has been determined that the administrative change set forth herein does not represent a significant hazards consideration as defined by 10 CFR 50.92(c).Should you or your staff have any questions regarding this submittal, please contact Mr. John F. McCann, Manager, Nuclear Safety and Licensing.

Very truly yours, 9908030227 990720 P PDR Attachments cc: Mr. Hubert J. Miller Regional Administrator-Region I US Nuclear Regulatory Commnission 475 Allendale Road King of Prussia, PA 19406 Mr. John L. Minns, Project Manager Division of Reactor Program Management US Nuclear Regulatory Commission Mail Stop 101)4 Washington, DC 20555 Mr. Jefferey F. Harold, Project Manager.Project Directorate 1-1 Division of Reactor Projects 1/11 US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr.Paul Eddy State of New York Department of Public Service 3 Empire Plaza Albany, NY 12223 Mr. William F. Valentino, President New York State Energy, Research and Development Authority Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12223-6399 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of)CONSOLIDATED EDISON COMPANY )Docket No. 50-3 OF NEW YORK, INC.)(Indian Point Station,)Unit No. 1))APPLICATION FOR AMENDMENT TO OQPERATING LICENSE Pursuant to Section 50.90 of the Regulations of the Nuclear Regulatory Commission

("NRC"), Consolidated Edison Company of New York, Inc. ("Con Edison"), as holder of the Facility Operating License No. DPR-5, hereby applies for amendment of the Techni~cal Specifications contained in Appendix A of that license.This Application for amendment to the Indian Point 1 Technical Specifications seeks to amend Section 3.2. 1. i by revising the senior reactor operator license requirement for the Operations Manager.The specific proposed Technical Specification Revision is set forth in Attachment I to this Application.

A Safety Assessment of the proposed change is set forth in Attachment II to this Application.

This assessment demonstrates that the proposed change does not represent a significant hazards consideration as defined in 10 CFR 50.92(c).

Attachment III to this Application contains a summary of the proposed change.As requ 'ired by 10 CFR 50.91(b)(1), a copy of this Application and our analysis concluding that the proposed change does not constitute a significant hazards consideration have been provided to the appropriate New York State official designated to receive such amendments.

BY:_ _ __A. Alan Blind Vice President

-Nuclear Power Subscribed and sworn to before me this ýý day July, 1999, 9908030229 990720 PDR ADOCK 05000003 P PDR Notary Public KA:2EN L. L.ANCA.STER Notary Public, Stae rf New yc~rk No. 60-4643659 Qualified In Westchester County Term Expires 913dqq3 ATTACHMENT I PROPOSED TECHNICAL SPECIFICATION CHANGE CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.INDIAN POINT UNIT NO. 1 DOCKET NO. 50-3 JULY 20, 1999 9?908030232 990720 PDR ADOCK 05000003 p PDR

f. The Nuclear Facilities Safety Committee shall function to provide independent review and audit of designated activities in areas of nuclear engineering, chemistry, radiochemistry, metallurgy and non-destructive testing, instrumentation and control, radiological safety, mechanical and electrical engineering, administrative controls and quality assurance activities, and radiological environmental effects.g. All fuel handling shall be under the direct supervision of a licensed operator.h .The Senior Watch Supervisor is responsible for operations at the Unit No. 1 facility.i. The qualification requirements of the Operations Manager and the Assistant Operations Manager are provided in Sections 6.2.2 and 6.3 of Appendix A to the Indian Point Unit No. 2 Facility Operating License No. DPR-26.*Licensed operator for IP-2 3.3 Operating Instructions and Procedures 3.3.1 No fuel will be loaded into the reactor core or moved into the reactor containment building without prior review and authorization by the Nuclear Regulatory Commission.

3.3.2 Detailed

written instruction setting forth procedures used in connection with the operation and maintenance of the nuclear power plant shall conform to the Technical Specifications.

3.3.3 Operation

and maintenance of equipment related to safety when there is no fuel in the reactor shall be in accordance with written instructions.

Amendment No. Pg Page 7 ATTACHMENT H1 SAFETY ASSESSMENT CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.INDIAN POINT UNIT NO. 1 DOCKET NO. 50-3 JULY 20, 1999 SE!CTION I -Description of Chang Con Edison transmitted (Reference

1) proposed changes to the Indian Point 2 Technical Specifications which included a revision to Section 6.2.2. h and to Section 6.3. 1 to change the senior reactor operator license requirement for the Operations Manager. This application provides a proposed amnendnment to the Indian Point 1 Technical Specifications to provide a similar change to Section 3.2. 1.1i.Currently Indian Point Unit No. 2 Technical Specification 6.2.2.h states: "The Operations Manager shall hold a senior reactor operator license." Reference 1 proposes to change the Indian Point Unit No.2 Technical Specification 6.2.2.h to: "The Operations Manager or Assistant Operations Manager shall hold a senior reactor operator license." Currently Indian Point Unit No.2 Technical Specification

6.3.1 states

"Each membe r of the facility staff shall meet or exceed the minimum qualifications of ANSI N18. 1-1971. for comparable positions, except for the Radiation Protection Manager who shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, September 1975." Reference 1 proposes to change the Indian Point Unit No.2 Technical Specification 6.3.1 to: "Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18. 1-1971 for comparable positions, except for (1) the Operation Manager's and the Assistant Operation Manager's SRO license requirement which shall'be in accordance with Technical Specification 6.2.2.h, and, (2) the Radiation Protection Manager who shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, September 1975." Currently Indian Point Unit No.1I Technical Specification 3.2. 1. i states: "The Operations Manager shall hold a senior reactor operator license. **Licensed operator for IP-2" This submittal proposes to change the Indian Point Unit No.1I Technical Specification 3.2. 1. i-to: "The qualification requirements of the Operations Manager and the Assistant, Operations Manager are provided in Sections 6.2.2 and 6.3 of the Indian Point Unit No. 2 Technical Specifications." Page 1 of 4 SECTION II -Evaluation of Change Presently Indian Point Unit No. 1 Technical Specification 3.2. 1. i and Indian Point Unit No. 2 Technical Specification 6.2.2.h have identical requirements.

The proposed change, coupled with the changes proposed in Reference 1, will maintain the same requirements in both Technical Specifications Indian Point Unit No. 2 Technical Specification 6.2.2.h currently requires the Operations Manager (OM) to hold a Senior Reactor Operator's (SRO) license. In Reference I Con Edison proposed to modify this requirement to have the OM or the Assistant Operations Manager (AOM) hold an SRO license. Current practice at Indian Point 2 is to have two SRO licensed positions in charge of shift Activities.

These two positions are the Senior Reactor Operator and the Senior Watch Supervisor (SWS). The AOM is directly in the reporting hierarchy between the SWS and the GM. The day-to-day activities of the Operations Department are carried out under the direction of the AOM. Thus, by requiring either the GM or the AOM to hold an SRO license, there is assurance that the SWS will report to an individual with an SRO license.Indian Point Unit No. 2 Technical Specification

6.3.1 currently

requires that facility staff meet or exceed all the requirements of ANSI N18. 1-197 1 ("Selection and Training of Nuclear power Plant Personnel").

Section 4.2.2 of ANSI N18.1-1971, states: "At the time of. ... appointment to the active position the operations manager shall hold a Senior Reactor Operator's License." While, ANSI N18. 1-1971 makes no mention of an Assistant Operations Manager, NUREG-1431, Rev. 1 ("Standjard Technical Specifications

-Westinghouse Plants"), Section 5.2.21f, states: "The Operations Manager or Assistant'Operations Manager shall hold an SRO license." Thus the Reference 1 proposed changes to Indian Point Unit No. 2 Technical Specifications 6.2.2.h and 6.3.1 are consistent with Section 5.2.2.f of NUREG-1431.

Since the GM and the AOM will still be required to meet or exceed all of the other ANSI N18. 1-1971 minimum requirements, there is assurance that the GM and the AOM will be knowledgeable and qualified individuals.

By requiring that either the GM or the AOM hold an SRO license, there is assurance that high-level management within the Operations Department will maintain a knowledge of current pla nt systems and operation.

Therefore, the Con Edison proposal (Reference

1) to modify the requirement to have the OM and the AOM meet all the qualification requirements of ANSI N18. 1-197 1 except for the SRO license requirement which would be in accordance with the Technical Specifications, will allow an individual who does not hold a current SRO license to be appointed as Operations Manager or Assistant Operations Manager provided all the other qualification requirements of ANSI N18.1-1971 are met.Page 2 of 4 SECTION 1H -No Significant Hazards Evaluatioi The proposed change does not involve a significant hazards consideration because: 1) Does the proposed license amendment involve a significant increase in the probability or in the consequences of an accident previously evaluated?

No. This proposed change is administrative in nature. In addition, this proposed change is consistent with the statement in NUREG-143 1, Rev. 1, Section 5.2.21f. This change does not affect possible initiating events for accidents previously evaluated or alter the configuration or operation of the facility.

The Limiting Safety System Settings and Safety Limits specified in the current Technical Specifications rem~ain unchanged.

Therefore, the proposed change would not involve a significant increase in the probability or in the consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

No. This proposed change is administrative in nature. The safety analysis of the facility remains complete and accurate.

There are no physical changes to the facility and the plant conditions for which the design basis accidents have been evaluated are still valid. The operating procedures and the emergency procedures are unaffected.

Consequently no new failure modes are introduced as a result of the proposed change. Therefore, the proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

.3) Does the proposed amendment involve a significant reduction in a margin of safety?No. This proposed change is administrative in nature. Since there are no changes to the operation or the physical design of the facility, the Updated Final Safety Analysis Report (UFSAR) design basis, accident assumptions, or Technical Specification Bases are not affected.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.'Therefore, the proposed change to the Technical Specifications does not involve a significant hazards consideration.

In addition, the proposed change to the Technical Specifications has been reviewed by both the Station Nuclear Safety Committee (SNSC) and the Con Edison Nuclear Facility Safety Commn-ittee (NFSC). Both Committees concur that the proposed change does not represent a significant hazards consideration.

Page 3 of 4 SEFCTION IV -Reference 1. Coni Edison Letter from A. A. Blind, to the USNRC Document Control Desk,

Subject:

"Proposed Amendment Consisting Of Administrative Changes To The Technical Specifications," dated January 22, 1999.Page 4 of 4