ML20102B359

Application for Amend to License DPR-50,consisting of TS Change Request 218,changing Administrative Requirements for Licensed Operator Eligibility & Requalification

ML20102B359
Person / Time
Site:	Three Mile Island
Issue date:	07/22/1992
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20102B349	List: ML20102B347 ML20102B359 ML20102B367
References
NUDOCS 9207280347
Download: ML20102B359 (5)

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.. f METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STA110N, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specificatior. Change Request No. 218 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. As a part of this request, proposed replacement pages for Appendix A are'also included.

GPU NUCLEAR CORPORATION  ;

BY: bb #^

Vice PresidenU and Director, TMl-1 Signed and sworn before me this A30A day of Chdu .- , 199t.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR C0hPORATION LICENSE NO. DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Recuest-No. 218 to Appendix A of the Operating License for Three'Hile-Islanc Nuclear Station Unit 1, has, on the date given below, been filed with executives of Londonderry Township, Dauphin County, Pennsylvania; Dauphin County, Pennsyllania; and the Pennsylvania Department of Environmental Resources,. i Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. Russell L. Sheaffer, Chairman Board of Supervisors of Board of County Commissioners.

Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 , Harrisburg, PA 17120 Mr. Williai P. Dornsife, Acting Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 ,

GPU-NUCLEAR-CORPORATION-BY- d" Vice: President)and Director. THI-l DATE:

July 22', 1992

C311-92-2089

1. TECHNICAL SPECIFICATION CHANGE RE00EST fTSCR) NO. 218 GPUN requests that the attached revised page replace page 6-3 of the THI-1 Technical Specifications.

II. REASON FOR CHANGE ,

This request involves an administrative change to the THI-1 Technical Specifications for Unit Staff Qualifications. Presently, licensed operators are required to meet the supplemental requirements of Section A and C of Enclosure I to an NRC letter from Denton to all licensees dated March 28, 1980 (The "Denton Letter" reference 1). The prescriptive requirements of the letter were included in the TMI-l Technical Specifications in Section 6.4 Training and Section 6.3 Unit Staff Qualifications.

Subsequent to the issuance of the Denton Letter, the guidance contained in the letter was incorporated into a variety of regulatory guidance and finally a portion of it was included in 10 CFR 55.59(c).

Consistent with the guidance in 10 CFR 55.59, the THI-1 Licensed Operator Requalification (LOR) Program was transferred from a set of regulatory-based performance criteria to one with SAT based (Systems Approach to Training) performance criteria. The LOR program was certified to the NRC in Reference 2 as being SAT based.

Under the SAT based program, 10 CFR 55.t. c) provides relief from Sections (2), (3) and (4) of 55.59 (c) which prescribed the content of the LOR program (The Denton Letter, section C of Enclosuro I). In effect the-b requirements of the Denton Letter (Enclosure I, Section C) were superseded by 10 CFR 55 and the SA1 process.

Additionally,10 CFR 55.31(a)(4) states that facilities uith certified simulators and programs using the SAT process need not-provide a detailed accounting of candidate experience. References 3 and 4 olaborate, stating that such a facility may establish a process for determining eligibility.

TMI-1 has implemented a program to establish candidate eligibility thru and the FSAR, various administratrlve Chapter 12.1. This program procedures (references addresses candidate 5 and 6)lity requirements.

eligibi A Technical Specification change was completed which updated Section 6.4, Trairiing (Amendment No.139) but section 6.3 was not corrected. This change deletes the reference to the re.quirements'of the Denton Lotter in Section 6.3.1 as these requirements are now prescribed by regulations in 10 CFR 55.

. 1 C311-92-2089 III. SAEEIYJVALUATION JUSTIFYING CHANGE The proposed revised Technical Specification Section 6.3.1 is consistent ,

with the ragulatnry requirements stated in 10 CFR 55.31(a)(4), 55.45(b)(1) '

and 55.59(c). These parts of the regulations allow licensee discretion in the requalification program content and also allow discretion in establishing licensed operator eligibility if certain conditions are met.

These conditions are that licensees must have a Systems Approach to Training (SAT) based training program and have a certified simulator facility both of which exist at THI-1.

This proposed change will also make the THI-l Technical Specifications consistent in that a change has already been issued to Section 6.4, Training, which specifies that Licensed Operator Training meet the requirements of 10 CTR Part 55. This change does not in ety way change the manner in which training will be conducted or the manner in which personnel are selected for qualification. The program will continue to comply with applicable portions of 10 CFR Part 5~.

IV~ NO SIGNIFICANT HAZARDS CONSIDERATI0l(S GPUN has determined that this Technical Specification Change Request involves no significant hazards consideration as defined by NRC in 10 CFR 50.92.

1. Operation of the facility in accordance with the proposed amendment would not involve a signific ant increase in the probability of occurrence or the consequertes of an accident previously evaluated.

This proposed change is a, administrative change that will result in ,

Technical Specifications that accurately represent the present methods of establishing lit.ensed operator qualifications and maintaining adaquate training and requalification. These methods are in compliance with appropriate regulatory requirements that are specified in 10 CFR, Part 55.

2. Operation of the facility in accordan'ce with the proposed amendment would not create the possibility of a new or different kind of accident from anv accident previously evaluated. This is an administrative change and will not modify plant hardware or change methods of operation. The facility will continua to be operated within the limits of existing accident analysis and margins of safety.

3. Operation of the facility'in acccrdance with the proposed amendment would not involve a significant reduction in a margin of safety since the change contained in the proposed amendment does not change any.

existing safety margins.

' C311-92-2089 -

V. , REFERENCES

( l. March 28, 1980 NRC letter to all licensees from H. R. Denton j " Qualifications of Reactor Operators"

2. 1Mi-1 letter, C311-88-2066, dated May 19, 1988, " Certification of THI-l Licensed Operator Requalification Program"

3. NUREG-1262 Answers to Questions at Public Meetings Regarding implementation of Title 10, Code of Federal Regulation's, Part 55 on operator Licenses

4. Reg-Guide 1.3 - Qualifications and- Training of Personnel 'for Nuclear j Power Plants i 5. THI-1 Procedure, 6211-PGD-2610 Rev. 6, TMl-1 Senior Reactor Operater Training Program E

6. THI-l Administrative Procedure, AP-1058 Rev. 7, Operator Licenses j

VI. IMPLEMENTATIQB l

it is requested that the amendment authorizing this change become

effective upon issuance.

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