ML20106E418

Proposed TS Section 6.2.2.f Deleting Requirement That Operations Manager Hold or Have Held Senior Reactor Operator License Prior to Assuming Operations Manager Position

ML20106E418
Person / Time
Site:	Seabrook
Issue date:	11/03/1992
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20106E412	List: ML20106E410 ML20106E415 ML20106E418
References
NUDOCS 9211090021
Download: ML20106E418 (9)

Text

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6.0 ADMINISTRATIVE CONTROLS 6.2.2 STATION STAFF

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1;

b. At least one licensed Operator shall be in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Operator sull be in the control room;

c. A Health Physics Technician

• shall be on site when fuel is in the f

reactor;

d. All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation; and

e. Administrative procedures shall be developed and implemented to limit the working hours of ttation staff who perform safety related func-tions, e.g., licensed Senior Operators, licensed Operators, health physicists, auxiliary operators, and key maintenance personnel. The amount of overtime worked by station staff members performing safety-related functions shall be limited in accordance with the NRC Policy Statement on working hours (Generic Letter No. 82-12).

,.3 #' The(@fodtSc1 1 r'fpfa'geyphf) Assistant Operations Manager shall hold a senior reactor operator license.

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• The Health Physics Technician may be less than the mirimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided imediate action is taken to fill the required positions.

SEABROOK - UNIT 1 6-2 9211090021 921103 PDR ADOCK 05000443 p PDR

Ill, littiny of Proposed Chanari See the attached retype of the proposed changes to Technical Specifications, The attached retype reflects the currently issued version of Technical Specificatiens.

Pending Technical Spnification (hanges or Technical Specification changes issued subsequcnt to this subinittal are not reflected in the enclosed retype. The enclosed rc t> pe should be checked for continuity with Technical Specifications prior to issuance.

Revision bars are provided in the right hand rnargin to designate a change in the it st.

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• 6.0 ADMINISTRATIVE CONTROLS 6.2.2 $TATION staff

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1;

b. At least one licensed Operator shall be in the control room when fuel is in the reactor, in addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Operator shall be in the control room;

c. A Health physics Technician

• shall be on site when fuel is in the reactor;

d. All CORE ALTERATIONS shall be observed and directly supervised by g either a licensed Senior 0)erator or licensed Senior Operator Limited to Fuel llandling w1o has no other concurrent '

responsibilities during this operation; and

e. Administrative procedures shall be developed and implemented to limit the working hours of station staff who perform safety-related functions, e.g., licensed Senior Operators,--licensed

( Operators, health physicists, auxiliary operators, and key maintenance personnel. The amount of overtime worked by station staff members performing safety-related functions shall be limited ->

in accordance with the NRC Policy Statement on working hours (Generic Letter No. 82-12).

f. The Operations Manager shall hold or have held a senior reactor 1 operator license for Seabrook Station prior to assuming-the Operations Manager position.

g. The Assistant Operations Manager shall hold a senior reactor operator license. _

• The Health Physics Technician may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is-tcken to fill the required positions.

. SEABROOK - 1) NIT 1 6-2 Amendment No.

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4 IV. _N a fy t y lauluution of Ilren3e Amendinent % guest 9bo.8 P inost d Chnnue_s

't h e proposed Technical Specification change does not ads c r sely af fect the safe operation of Seabrook Station. 'I bc cur r ent r equir e ment in Technical Specification 6Bf for the Operations Manner to hold a senior remtor operator license requires a signific ant amount of the operations Manager's time to be spent in requalification.

During requahfication training, the Oper ations Manager can not desole one hundred percent of his ellorts to his primary r e s po n sibilitie s of managing the e f fective performance of the Operations Department.

As stated in scetion 1.LI.11 of the t!pdated l'inal Saf ety Analysis Iteport, (UI S Alt) the (urrent requirement foi the Operations Manager to hold a senior reactor operator license is based on the minimum qualifications recommended in ANSI /ANS tl 1971 llowcVer, this guidance was icsised in the 1987 resision of ANSl/ANS 3.1.

'I he current guidante recommends sescral option % one of which is for the Operations Manager to base held a licente for a similar unit, in the case where the Operations M a n age r does not hold an NitC littuse, ANS/ ANSI 3.1 1987 recommends that the "O pe r ations Middle Manager" hoh i N it C senior reactor operator license. The propostd "Icchnical S) etiutation change does not revise the existing requirement for the Assistant Operations Manager to 1 old a senior reactor operator license, and is consistent with the guidance of ANSl/ANS 3.1-1987,

'I he Ope r ations M anage r is respontible for managing the operation of the Station.

This includes ensuring the clicctive performance of Operations Dcpartment personnel and the ef f ectis e utili/ation of Operations Department resourecs. To f acilitate itu ple m e n t a tion of this i c spon sibilit y (ht ()pe r ations Department is structuled to proside sever al layers of direct technical suptivision. liach lesel of supersision, f rom the Supcivisory Control ltoom Ope r ator on shilt, to the Shift Superintendent, is direttly supervised by an NitC licensed indisidual, The most senior personnel on each shill, the Shift Superintendents, are dircelly supenised by the Assistant Operations Manager, who will c ontinue to hold a senior reactor operator license.

'I he Operations Manager, by having been licensed as a senior reactor operator at Seabrook Station, will base geined the necessary stills, level of knowledge, ind cxperience to fully understand the operation of Station equipment, the requirements f or proper watchstanding, and for ensuring that the Station is operated in compliance with Technical Specifications and other license requirements. The Operations Manager does not stand Control lloom watches not manipulate controls such that a senior reactor optrator license is required.

Deleting the requirement lor the Operations Manager to hold a senior reactor operator lic e nse does not alter the design or operation of any plant system, component, or st r u( t ure. It does not change the way any plant system is operated, does not reduce the knowledge, qu .lifications or skills of any watchstander, and does not af f ect the way the Operations Department is managed other than to allow the operations Manager to focus his efforts on the e f f-ct ive perf ormance of his personnel, it does not introduce any new f ailure m lhis proposed change does not at ic ct any previously analy /ed accident or n.. , u n ctio n, does not create the possibility of a dif ferent accident or malfunction not picsiously analy/ed, and does not reduce the margin of safety as delined in the basis of any Technical Specification.

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Tir proposed Technical Spt ;;fication changs- would tahance plan' safety by allowing tir 'sperations Manager to de.' . ate more time to the rnanagement i f the Operations Department and to ensuiing that the piant is operated safely and in accordance with

• tbc Operating 1.iccase rr .irements.

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E l>ctermination or Stunificant llururds for I.lcense Amendment Reguest 92 01 Proposed Channes (1) T he proposed c hange does not involve a aign;ficent increase in the probability or e,nsequences of an accident previously e.aluated.

't he proposed change af fects only an administratise control, which was based on the existing industry guidance in ANSI /ANS 3.1- 1978, t h at recommended the Operations hlanager hold a senior reactor operator license. The current guidgnce in ANSI /ANS Gl%7 recomt.iends, as one option, that the Operations Manager have held a license on a similar unit with the Operut;ons hiiddle hianager holding a senior reactor ope r ator iicense. The proposed change in t his License Amendment Request is consistent with the current guidance.

The proposed change does not alter the design of any system, structure, or _

con onent. It does not change the way any plant systems are operated. It does not reduce the k now le dge, q u alific a t h' n s, or skil:s of any watchstander, and does not affect the way the Operations De par t ment is managed othei than to allow the operations hianager to focus his efforts on maintaining the effective performance of his pe.sonnel and to ensuring the plant is operated safely and in accordance with the requirements of the Operating License.

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• (' The proposed change does not detrut from the Op rations hl a n age r 's ability to

??' peitorm his primary responsibilities. By having g reviously held a senior reactor operator license he will have gained the necessary training, skdis, and experience to tully un? n stand the operation of plant equipment and the requirements for proper watchstanding.

I he proposed change does not weaken the supersisory chain thrt presently exists in the Operations Department. All Cont r ol Room operators v.ill continue to be super vised by NRC licensed peisonnel.

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'I he proposed change is intended to improve the abiiity of the Operations hianager -

to preside the piant os e r sight required of his position. It does not have any affe-on the probability or consequences of any previously evaluated accident, e

(2) Tbc proposed change does not create the possibility of a new or different kind if accid e nt from any accident previously evaluated.

The proposeJ change to Technical Specification 6.2.2 does not af fect the design or tunction of any plant system, structure, or component, it does not affect in any way the performance of NRC licensed operators, nor does it chat . > th way any plant equipment is operated. Operation of the [.. ant in conformccce with Technical Specification and other license requirements wil! continue to be supervised by personnel who hold an NRC senior reactor operator license, The proposed change doc- not introduce m ay new f ailure modes.

The proposed change is intended to remme an administra ise requirement which adds a significant burden to the Operations ' tanager without signiticantiv contributing to his effectiveness in managing plant op, ation and ensuring that the plant is operated safely and in accordance with the r qui;ements of the Operating License.

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(3) 1 hc proposed change does not result in a significant reduction :n the margin M safety.

The proposed change involves only an administrative control which is rot related to '

the margin of safety as defined in the Technical Specifications. The proposed change does not reduce the level of knowledge or experience required of an individual who fills the Operations Manager positios., nor does it affect the conservative manner in which the plant is operated. All Contro! Room operators will continue to he

..upervised by personnel v ho hold a senior reactor operator license. This incluues' ,

the Ast.istant Operations Manager, who will continue to be required to hold a senior reactor oper ator license.

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VI. Proposed Schedule for License Amendment issunnee und Effectiseness North Atlantic tequests ' NRC review of License Amendment Request '92 04 and issuance of a license amendment having immediate effectiveness by April 30, 1993,.

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-4 Vil, I?nsironmental Impact Statement-North Atlantic Energy - Service Corporation (horth Atlantic) _ has reviewed ~ the proposed license . amendment ag sinst the criteria of 10CFR51.22 for environmental considerations. -The proposed _ change does not involve a 6lgnificant hazards consideration, nor increase the types and amounts of effluents that may be re! cased-offsite, nor significantly increase individual or cumulative occupational radiation exposures. Ilased on the foregoing, North Atlentic concludes that the proposed change meets the criteria delineated in 10CFR$1.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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