ML20070F280

Application for Amend to License NPF-3,changing Tech Spec 6.2.2,Table 6.2-1 Re Min Shift Crew Composition,Per Generic Ltr 86-04

ML20070F280
Person / Time
Site:	Davis Besse
Issue date:	03/01/1991
From:	Shelton D CENTERIOR ENERGY
To:
Shared Package
ML20070F275	List: ML20070F272 ML20070F280 ML20070F287
References
1903, GL-86-04, GL-86-4, NUDOCS 9103080218
Download: ML20070F280 (7)

Text

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• Decrat Husber 50-346 Lic2nso Nurbar NPF-3 Serial Nrmber 1903

. Enclosure Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 Attached is the requested change to the Davis-Besse Nuclear Power Station, c Unit Number 1 Facility Operating License Number NPF-3. Also included are the Safety Assessment and Significant Hazards Consideration.

Th6 proposed change (submitted under cover letter Serial Number 1903) concernst-Technical Specifications Section 6,2.2, Facility Staff.

1 E C. Shelton, Vice President - Nuclear Svorn and subscribed before me this let day'of March,1991.- I kosAth]$ RJJ Notary Publfd,~ State of Ohio EVELYN L DRESS -

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$2 riel Numb 2r 1903 Enclosure Page 2 The following information is provided to support issunnee of the requested change to-the Davis-Besse Nuclear Power Station, Unit Number 1 Operating License Number NPT-3, Appendix A, Technical Specifications Section 6.2.2.

A. Time Required to Implement: This change is to be implemented within 45 days after the NRC issuance of the L! cense Amendment.

B. Reason for Change (License Amendment Request Number 90-0039): The addition of the footnote, to the Technical Specifications to allov one of the two required individuals filling the SOL positions to assume the STA function, vill provide greater flexibility for meeting shift manning requirements while maintaining on shift expertise to recognize and effectively deal with plant transients or other abnormal conditions.

C. Safety Assessment and Significant liarards Consideration: See Attachment 1.

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Liccnso Nu2bar HPF-3 Ssriel Numb 2r 1903 Attachment Page 1 SAFETY ASSESSHERT AND SIGNIFICANT HAZARDS CONSIDER ** ION FOR LICENSE AMENDPENT REQUEST NUMBER 90 0019 TITLE:

License Amendment kequest (LAR) to Revise the Minimum Shift Crew Composition in Technical Specification (TS) 6.2.2, Facility Staff.

DESCRIPTION:

The purpose of the proposed change is to revise Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3. Appendix A, TS 6.2.2

.(Administrative Controls - Facility Staff), Table 6.2-1, Minimum Shift Crew Composition. The proposed change is consistent with the Nuclear Regulatory Commission's (NRC's) guidance (Generic Letter (GL) 86-04, dated February 13, 1986, Policy Statement on Engineering Expertise on Shift, Log Number 1919) to allow one of the two positions of Senior Reactor Operator (SRO), and the position of Shift Technical Advisor (STA) to be filled by a single, properly trained individual. This guidance specified two options for meeting the .

current requirements for providing engineering expertise on shift (NUREG-0737, Clarification of Three Mile Island (THI) Action Plan Requirements, Item 1.A.1.1) and meeting licensed operator staffing requirements (10 CFR 50.54(m)(2)) of the required STA position. Option 1 provides for the elimination of the separate STA position by allowing a licensee to combine one of the required SR0 positions with the STA position into a dual-role (SR0/STA) position. Option 2 states that a licensee may continue to-use an NRC-approved STA program while meeting license operator staffing requirements. A licensee may use either option on eacP shift.

This LAR proposes that TS 6.2.2, Table 6.2-1 be revised to allow Toledo Edison to utilire either option in meeting the minimum shift crew composition requiiements. i footnote (**) is proposed to be added to the SR0 and STA categories of Table 6.2-1 which states:

One of the two required individuals filling the SOL positions may also '

assume the STA function provided the individual meets the qualifications for the combined SR0/STA position specified for Option 1 of the Commission's Policy Statement on Engineering Expertise on Shift. If this option is used for a shift, then the separate STA position may be eliminated for that shift.

At the DBNPS, the-Shift Manager currently functions as the STA. Undcr this proposed change, the Shift Manager may function as both the STA and one of the required SRO positions (i.e., a dual-role SR0/STA function).

This proposed TS revision is similar to that approved by the NRC in Amendment No. 64 to the Grand Gulf Nuclear Station, Unit 1, Facility Operating License No. NPF-29, dated September 28, 1989.

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• Lic;nsa Nu bar NPF-3 S2rici Numb 2r 1903 Attachment Fage 2 SYSTEMS, COMPONENTS AND ACTIVITIES AFFECTED:

The proposed change vould affect the requirements for meeting minimum shift crev staffing requirements. More specifically, it vould affect control room activities involving the STA position.

SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIES:

The function of the TS requirements for a minimum shift crev composition is to ensure that a sufficient number of trained and qualified personnel are available on each duty shift to operate the station in a safe manner. The function of the STA is to provide on shift engineering and accident assessment advice to the shift supervisor in the event of abnormal or accident conditions.

EFFECTS ON SAFETY:

The STA requirement was identified to licensees in NUREG-0578, THI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations, (July 1979) and NUBEG-0737 (November 1980), Clarification of THI Action Plan Requirements. Concurrently, the NRC and industry undertook a longer term effort to upgrade staffing levels and the training and qualifications of the operating staffs, improving the man-machine interface, and increasing the capabilities for responding to emergencies. At the time the STA requirement was imposed, it was intended that the use of the dedicated STA vould be an interim measure only until these longer term ef forts were co.npleted.

These longer term efforts have collectively resulted in an improvement in the capabilities and qualifications of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing increases, training and qualification program improvements, hardware modifications, emphasis on human factor considerations, procedural upgrades and the development of extensive emergency response organizations to augment on shift capabilities during abnormal conditions.

The proposed administrative TS change vill allov either option of the NRC's

" Policy Statement on Engineering Expertise on Shift" (GL 86-04) to be applied to the STA position at the DBNPS. The proposed change vill allov one of the two required individuals filling the SRO positions to also fill the STA position provided the individutil meets the qualifications for the combined SR0/STA position specified for Option 1 of the policy statement.

In addition, the option for continued use of the dedicated STA position is retained. Allowance is provided in t'ne proposed change for using either option on each shift.

The qualifications for the Jcal-role SR0/STA described for Option 1 in the Ccmmission's Policy Statement on Engineering Expertise on shift are as follovs

a. Licensed as a SR0 at assigned unit.

. Dockot Hunber 50-346 bicensa Nu ber NPF-3 S: rial Norber 1903 Attachment Page 3 l

b. Meets the S1A training criteria of NURF.G-0737, item 1.A.1.1, and one of the following educational alternatives:

1) Bachelor's degree in engineering from an accredited institution

2) Professional Engineer's (PC's) License obtained by the successful completion of the PE examination,

3) Bachelor's degree in Engineering technology f rom an accredited institution, including course work in the physical, mathematical, or engineering sciences; or

4) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematic.11, or engineering sciences.

The proposed TS change vill allow an individual with an SRO license at DBNPS (who meets the qualifications to be an STA) to also be the required STA on shifti therefore, the Option 1 qualification requirement to have an SRO license vill be met.

The DBNPS STA training program is accredited by the Institute of Nuclear Power Operations (INPO). The training an individual vill receive to become a dual-role SRO/STA vill meet the STA training criteria of NUREG-0737. Item 1.A.1.1. Therefore, the Option 1 training qun11tication vill be fulfilled by the individual performing the dual-role SRO/STA function allowed by this proposed TS revision. In addition, one of the educational alternatives of the policy statement will be met by an individual performing the SR0/STA function.

Vith the proposed change, DBNPS operating shift personnel vill continue to have the expertise on shift to recognize and effectively deal with plant transients or other abnormal conditions. Greater flexibility for meeting shift manning requirements vill also result from the proposed change.

Based on the above, it is determined that the proposed change is administrative in nature and has no detrimental effect on safety.

SIGNIFICANT llAZARDS CONSIDERATION:

The NRC has provided_ standards in 10 CFR 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 vouldt (1) Not involve a significant increase'in the probability or consequences of r.n accident previously evaluatedi (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 change and determined that a significant hazards consideration does not exist because operation of the DBNPS, Unit Number 1, in accordance with this change voulds

. Docket Numbar 50-346 License Numbar NPF-3 Sorial Numbar 1903 Attachmen(

page 4 l la. Not involve a significant increase in the probability of an 2

accident previously evaluated because no accident initiators or assumptions are affected. The analyses of accidents that concern operator error, do not take credit for the STA as decreasing the

. probability of occurrence of these accidents. The proposed amendment simply provides flexibility in meeting an administrative requirement t.nd does not involve any mod!fications or changes in the plant.

Ib. Not involve a significant increase in the consequences of an accident previously evaluated because no accident conditions or i,

essumptions are affected. Vith the proposed changes, shift p'irsonnel vill continue to have the expertise to recognize and etfectively deal with plant transients or other abnormal events.

The analyses of accidents do not take credit for the STA as mitigating the consequences of these accidents. The proposed hange is admiaistrative. The expertise of the operating shift is not jeopardized and the radiological consequences of any evaluated accident remain unchanged.

2a. Not create the possibility of a new kind of accident from any accident previously evaluated because no accident initiators are created. The proposed change does not involve any modifications or changes in the plant. This is an administrative change in which the ability of the operating shift is not jeopardized.

Since the STA has no operational responsibilities or duties on shift other than those associated with plant transients and accidents, combining the STA position with the SRO-function vill not introduce any new opportunity for operator error to occur.

2b. Not create th9 possibility of a different kind of accident from any accident previously evaluated because the administrative change has ut. of fect on plant systems, accident initincors or accident assumptions. The change does not affeet any system functional requirements, plant maintenance, or operability requirements.

3. Not involve a significant reduction in a margin of safety. The proposed change vill not have any significant effect on safety limits, boundary performance or system performance. The STA or SR0/STA vill continue to provide engineering and accident assessment expertise on shift. The training, experience, and expertise on shift to analyre, assess, and evaluate plant transients and accidents vill not be diminished.

. CONCLUSION:

On the basis of the above, Toledo Edison has determined that the LAR does not involve a significant hazards consideration. As this LAR concerns a proposed change to the Facility Operating License that must be revieved by the NRC, this LAR does not constitute an unreviewed safety question.

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. Licenso Number NPP-3 Sortal Numb 2r 1903 Attachment Page 5 ATTACHMENT:-

Attached is the proposed marked-up change to the Operating License.

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