ML20046A387

Application for Amends to Licenses NPF-39 & NPF-85 Requesting TS to Allow Dual Role Sro/Sta Position

ML20046A387
Person / Time
Site:	Limerick
Issue date:	07/16/1993
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20046A382	List: ML20046A381 ML20046A387 ML20046A401
References
NUDOCS 9307280028
Download: ML20046A387 (7)

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t Attachment 1 i LIMERICK GENERATING STATION UNITS 1 and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST

" Allow One of the Required On-Shift' Senior Reactor Operator.

Positions to be combined with the Required Shift Technical Advisor Position" Supporting Information for Changes - 6 pages 9307280028 930716 "7h PDR ADOCK 05000352 kaid P ppa gl@

U. S. Nuclear Regulatory Commission July 16,1993 Document Control Desk Page 1 Philadelphia Electric Company (PEco), license under Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications (TS) be amended as proposed below to allow one of the required on-shift Senior Reactor Operator (SRO) positions to be combined with the required Shift Technical Advisor position, i.e., dual role SR0/STA position. This proposed change from a dedicated STA position to a dual-role SR0/STA position is in accordance with the recommendation in the NRC's

" Policy Statement on Engineering Expertise on Shift," issued on October 28, 1985, and transmitted to all power reactor licensees and applicant.; by NRC Generic Letter 86-04, " Policy Statement on Engineering Expertise 01 Shift," dated February 13, 1986.

This TS Change Request for LGS, Units 1 and 2, provides a discussion and description of the proposed changes, a safety assessment, information supporting ,

a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

The Unit I and Unit 2 TS pages showing the proposed changes are provided in Attachment 2.

We request that, if approved, the TS changes be effective upon issuance.

Discussion and Description of the Proposed Chanaes The NRC " Policy Statement on Engineering Expertise on Shift," provides two options for meeting the minimum requirements for shift staffing in 10 CFR  !

50.54(m) (2) and the recommendation for a Shift Technical Advisor (STA) in NUREG-0737, " Clarification of TMI Action Plan Requirements," Item I . A. l .1 " Shift Technical Advisor." These two options are:

1. 4nue with the current approved dedicated STA program in ance with the description in NUR'G-0737 t ( i.e., Item I.A.1.1), or

2. combine one of the required licensed Senior Reactor Operator (SRO) positions and the Shift Technical Advisor (STA) position (i.e., dual-role SR0/STA).

The NRC Policy Statement states that either option may be used on each shift. If the second option is used, the person filling the dual-role SR0/STA position, in addition to holding an active SR0 license on the unit (s) assigned, will be required to meet the criteria for education and training specified in the NRC Policy Statement. The education and training qualifications for the dual-role SR0/STA position are the same as those currently applicable to the STA required by Limerick Generating Station (LGS) Technical Specifications (TS)

Section 6.2.4 except that the education qualifications for a individual filling the dual-role SR0/STA position may be satisfied by any of l.he following four alternatives.

(1) Bachelor ,9 ee in engineering from an accredited institution;

U. S. Nuclear Regulatory Commission July 16,1993 Document Control Desk Page 2 (2) Professional Engineer's (PE's) license obtained by successful completion of the PE exae; (3) Bachelor's degree in engineering technology from an accredited <

institution, including course-work in physical, mathematical,- or engineering sciences; or (4) Bachelor's degree in physical science from an accredited institution, including course-wc-k in physical, mathematical, or engineering sciences.

The following proposed changes to the LGS TS will permit the operating shift complement to meet the NRC's recommendations for engineering expertise on shift using either of tha options discussed in the NRC's " Policy Statement on Engineering Expertise on Shift." The proposed changes are as follows.

o TS Table 6.2.2.-1 The position title " Shift Technical Advisor" will be marked with a triple asterisk symbol, "***" that will refer to the following note.

• • • The STA position may be filled by the on-shift Shift Superintendent, Shift Supervisor, or other SR0 provided the individual meets the 1985 NRC Policy 1 St;' ament on Engineering Expertise on Shift.  !

Change TS Table 6.2.2-1 notation regarding the absence from the Main Control Room  !

(MCR) of Shift Supervision (SS) to delete the parenthetical statement prohibiting l the STA from assuming the MCR command function. 'l j

o TS Section 6.2.4 The statement specifying the education requirements for the STA will be replaced  !

with the following. 1 The Shift Technical Advisor shall meet the qualifications specified by the 1985 NRC Policy Statement on Engineering Expertise on Shift.

The affected TS pages marked to show the proposed changes are provided in 1 Attachment 2. These proposed changes are consistent with the corresponding requirements in the Improved Standard TS, NUREG-1433, " General Electric Plants, l

BWR/4."

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t U. S. Nuclear Regulatory Commission July 16,1993 Document Control Desk Page 3 ,

Safety Assessment While the number of on-shift SR0s, Reactor Operators (R0s), and non-licensed plant operators normally exceeds the minimum requirements specified in TS Table 6.2.2-1 anc 10 CFR 50.54(m) (2), the proposed TS changes to adopt a dual-role SRO/STA has been evaluated for the conditions when the shift staffing is at the minimum level permitted by the TS Table 6.2.2-1. Nevertheless, the information in the following documents will be taken into account in the development of the administrative controls governing the shift composition upon implementation of the proposed dual-role SR0/STA position.

o NRC Information Notice 91-77, " Shift Staffing at Nuclear Power Plants," dated November 26, 1991.

o NUREG-1275, Vol. 8, " Operating Experience Feedback Report-Human Performance in Operating Events," dated December 1992, transmitted by NRC letter dated February 22, 1993, o NRC Information Notice 93-44, " Operational Challenges During a Dual-Unit Transient," dated June 15, 1993.

The dual-role SR0/STA position option recommended by the NRC " Policy Statement on Engineering Expertise on Shift," combines one of the required SR0 positions and the STA position. Therefore, use of the dual-role SR0/STA position option will not result in the need to assign an additional SRO to meet rcinimum s shift staffing requirement (i.e., the two (2) SR0s currently required by TS Table 6.2.2-1). The NRC Policy Statement specifically states that the number of shift personnel specified in 10 CFR 50.'.,4(m) (2) and reflected in TS Table 6.2.2-1 is sufficient to allow the indivhual filling the dual-rA SR0/STA position to provide both accident assem..ent expertise, and to analyu and respond to off-normal occurrences whm, needed. The purpose of the STA position is to ensure that engineering and accident assessment expertise is available on each shift.

The NRC Policy %atement concludes that the dual-role SR0/STA position can provide this expertise and simultaneously function as one of the SR0s required to meet staffing levels in 10 CFR 50.54(m) (2) and TS Table 6.2.2-1.

In addition to the staffing requirements in 10 CFR 50.54(m) (2) and TS Table 6.2.2-1, sufficient and appropriately qualified personnel must be available at all times to meet the TS requirements for the fire brigade. TS Section 6.2.2.e requires that a fire brigade of at least five (5) members be maintained onsite at all times. The fire brigade may not include the minimum shift crew ,

necessary to achieve safe shutdown of the unit (s) er any personnel required for l other essential functions during a fire emergency.

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I U. S. Nuclear Regulatory Commission July 16,1993 Documen* Control Desk Page 4 i l

Additionally, the fire brigade leader and at least two fire brigade members must have sufficient training in, or knowledge of, plant ' safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability. The brigade leader must also be competent to assess the potential safety consequences of a fire and advise Main Control Room (MCR) personnel. LGS' Updi.ted Final Safety Analysis Report (UFSAR), Section 13.1.2.5.5, states that such competence by the brigade leader is evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems These requirements for the fire brigade and fire brigade leader would, upon implementation of the proposed dual-role SR0/STA position, continue to be satisfied as follows.

Minimum Cr g Necessary to Achieve Safe Shutdown and Man the Fire Briaade Shift staffing requirements are established in 10 CFR 50.54(m) (2) and TS Table 6.2.2-1. These requirements are based on criteria in NUREG-0737,

" Clarification of TMI Action Plan Requirements," Item I.A.1.3, " Shift manning,"

which also specifies the minimum shift crew necessary to achieve safe shutdown ,

of the unit (s) and the personnel required to achieve other essential functions during a fire emergency.

The TS Table 6.2.2-1 minimum shift staffing with two units operating consists of: one Shift Superintendent holding an active SR0 license; one Shift Supervisor holding an active SR0 license; three licensed R0s; five non-licensed plant operators; and one STA. This minimum staffing level is based on meeting ,

the following specific requirements: one SR0 in the MCR at all times when either unit is operating with a second SR0 available for relief; one R0 at the controls for each operating unit with a third R0 available for relief on either unit; one non-licensed plant operator assigned to each unit; and a third non-licensed plant operator assigned to the MCR.

Upon implementation of the proposed dual-role SR0/STA position, the-staffing necessary to achieve safe shutdown and man the fire brigade will continue to comply with TS requirements. Accordingly, to meet the restrictions of TS Section 6.2.2.e, the SR0 available for assignment to the fire brigade will not be the Shift Superintendent or SR0/STA if the dual-role SR0/STA option is being used.

Qualification of Fire Briaade and Briaade Leader In accordance with TS Section 6.2.2.e, the fire brigade at LGS consists of at least five members and may not include the Shift Superintendent, the STA, nor the other two members of the shift crew necessary to achieve safe shutdown (i.e.,

one R0 and one non-licensed plant operator for each Unit). Fire brigade members are trained in accordance with the commitments specified in UFSAR Section 13.2.1.6, " Fire Protection Training," and at least two brigade members must have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability.

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. i U. S. Nuclear Regulatory Commission July 16,1993 l Document Control Desk Page 5 Additionally, LGS UFSAR Section 13.1.2.5.5 states that the brigade leader be competent to assess the potential safety consequences of a fire and advise MCR personnel. Such competence by the brigade leader is avidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.

Currently, and upon implementation of the proposed dual-role SR0/STA position, the fire brigade leader at LGS is normally the Shift Supervisor or other on-shift qualified individual who is not acting as the Shift Superintendent, STA, or SR0/STA. The composition of the fire brigade will continue to ensure that the brigade leader and at least two brigade members will have sufficient training in, or knowledge of, plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability, and that the fire brigade leader is competent to assess the potential safety consequences of a fire.

The proposed changes do not directly impact any accidents previously evaluated because: the function and responsibilities of the STA will be executed by an appropriately qualified individual filling the dual-role SR0/STA position; the function and responsibility of the fire brigade leader will be executed by an appropriately qualified plant operator; and shift staffing will be maintained as required by TS Table 6.2.2-1. Additionally, implementation of this proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected.

Information Suonortina a Findina of No Sianificant Hazards Consideration We have concluded that the proposed changes to Limerick Generating Station (LGS), Unit 1 and Unit 2 Technical Specifications (TS) to allow one of the required on-shift Senior Reactor Operator (SRO) positions to be combined with the required Shift Technical Advisor (STA) position, as recommended by the NRC's

" Policy Statement on Engineering Expertise on Shift," do not involve a Significant Hazards Consideration. In support of this determinati a an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Implementation of the proposed changes will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected. Therefore, the proposed use of the dual-role SR0/STA position does not increase the probability of an accident previously evaluated.

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U. S. Nuclear Regulatory Comission July 16,1993 ,

Document Control Desk Page 6 The consequences of an accident previously evaluated could be affected by the performance of the individual filling the dual-role SR0/STA position.

However, implementation of the proposed changes will result in personnel with enhanced operational knowledge being assigned to perform the STA function of providing accident assessment expertise, and analyzing and responding to off normal occurrences when needed. The NRC's stated preference in the October 28, 1985, " Policy Statement on Engineering Expertise on Shift," indicates that the NRC has concluded that the individual filling the dual-role SR0/STA position may perform these functions better than a non-licensed individual filling the STA position even when the SR0/STA is concurrently functioning as one of the required shift SR0s. Futhermore, implementation of the proposed changes will not affect the staffing or qualification of the fire brigade members. Therefore, the proposed TS changes do not increase the consequences of an accident previously evaluated.

2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Implementation of the proposed TS changes will not involve physical changes to plant SSC, or the addition of new SSC. Furthermore, implementation of the proposed changes will not adversely- affect the manner in which plant SSC are operated, maintained, modified, tested, or inspected. Therefore, the possibility -

of a new or different kind of accident from any accident previously evaluated is not created.

3. The proposed changes do not involve a significant reduction in a margin of safety.

The margin of safety is not affected because the STA and fire brigade leader positions will be filled by appropriately qualified personnel and shift staffing required by TS Table 6.2.2-1 and 10 CFR 50.54(m) (2) will continue to be maintained.

Information Supportina an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the renuested changes conform to the criteria for

" actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c) ,

(9). The requested changes will have no impact on the environment. The proposed changes do not involve a Significant Hazards Consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that '

may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupation radiation exposure.

CONCLUSION The Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposod changes to the TS and determined that these changes do not involve an Unreviewed Safety Question and will not endanger the health and safety .

of the public. I

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