ML20012A036
| ML20012A036 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/26/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20012A037 | List: |
| References | |
| NUDOCS 9003080170 | |
| Download: ML20012A036 (18) | |
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i 10"CFR 50.90 I
PHILADELPHIA' ELECTRIC COM PANY-NUCLEAR GROUP HEADQUARTERS g
955 65 CHESTERBROOK BLVD.
p WAYNE, PA 19087 5691 (at s) sao sooo 2
February 26, 1990 Docket Nos.
50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D..C.
20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request
Dear Sir:
. Philadelphia Electric Company hereby submits Technical
-Specifications Change Request No. 89-12, in accordance with 10 CPR.50.90, requesting an amendment to the Technical Specifications.(Appendix A) of Operating License Nos. DPR-44 and DPR-56; Information. supporting this Change Request is contained-inLAttachment 1 to this letter, and the proposed replacement'page
'is' contained in Attachment 2.
This submittal reflects changes to'the Technical Specifications which~ commits the Peach Bottom Atomic Power Station to ANSI /ANS-3.1-1981,- entitled, " Selection, Qualification and. Training'of Personnel for' Nuclear Power Plants."
If'you-have any questions regarding this matter, please contact us.
Very trul
- yours, G.A.Hungeg,J8 0.
m a, I Director Licensing Section Nuclear Services Department Attachments
- cc:
J. J. Lyash, USNRC Senior Resident Inspector W. T. Russell, Administrator, Region I, USNRC T. M. Gerusky, Commonwealth of Pennsylvania g
g y anuv/uu 9003000170 900226 PDR ADOCK 05000277
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3 COMMONWEALTH OF PENNSYLVANIA i
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CHESTER COUNTY D. R. Belwig, being first duly sworn, deposes and sayu:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the attached request (No.
89-12) for changes to. Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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m Vice P es* dent l
Subscribed and sworn to j-before me this 8 7 day of -7<4 %,.s 1990.
dada d. %4/
Notary Public NOTARAL SEAL CATHERNE A. MENOEI No:ary Pubuc Trecyrtrin Twp., Chester County j__ My Comtnission Exceres Sect 4.1993 s
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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket _Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 89-12
" Commitment to ANSI /ANS-3.1-1981, entitled " Selection, Qualification and Training of Personnel for Nuclear Power Plants""
Supporting Information for Changes - 15 pages 5
Dockot Nos. 50-277-l 50-278 j
- l Philadelphia Electric Company (PECo), Licensee under Facility Operating Licenses-DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS) Unit Nos. 2 and 3, requests that the Technical: Specifications contained in Appendix A of_the Operating Licenses be amended.
Proposed changes to the Technical Specifications are indicated by vertical bar in the margin of page 246 contained in k.
In accordance with the. agreement (transmitted in-a letter dated June 27, 1989 from W. Russell (NRC) to C. McNeill (PECo)) between PEco and the Commonwealth of Pennsylvania (the Commonwealth),.PEco agreed to submit an application.to the Nuclear Regulatory Commission (NRC) requesting an amendment to the Peach Bottom Atomic Power Station Units 2 and 3 Technical Specifications such that PECo would commit to standards set forth in ANSI /ANS-3.1-1981 entitled, " Selection, Qualification and Training of Personnel for Nuclear Power Plants"-for PBAPS.
Additionally, the agreement stated that the Technical l
Specifications amendment may specify, however, that to the extent that the standards set forth in ANSI /ANS-3.1-1981 apply to individual job positions at Peach Bottom, those standards shall not apply to PECo employees holding those positions as of l l
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'Dockst No2.-50-277 o
i 50-278 License Nos. DPR-44
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' February 27, 1989, so long aus those Lindividuals continue: to hold Dc 5
.those-positions.-
l This application satisfies this commitment.-
i-Description of Changes:
i
-Licensee proposes the following changes to the Technical I
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Specifications:-
s,
-li Section 6.3.lL(Facility Staff Qualifications") of'the PBAPS.
t TechnicalLSpecifications statestthat:
"Each memberLof the facility staff:shall.
meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for (1) Senior-Health Physicist (radiation protection manager) who shall meet or exceed t'he qualifications of Regulatory Guide 1.8, September.1975 and (2) the Shift Technical Advisor who shall have a
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bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and m 1
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Docket No2. 50-277 4
50-278 License Nos. DPR-44 DPR-56 response and analysis of the plant for l:
transients _.and accidents."
Licensee proposes to rewrite this paragraph to commit personnel reassigned, transferred or hired on or after k
February. 28, 1989 to the ANSI /ANS-3.1-1981 standard.
The paragraph shall state:
"6.3.1 Each member.-of the facility staff shall meet or i
exceed the minimum qualifications of ANSI N18.1-
-l 1971 for comparable positions so long as those individuals hold those positions on and after I
. February 27, 1989.
6.3.2 Each member of the facility staff who has been I
reassigned,-transferred or hired on or after February 28, 1989, shall meet or exceed the minimum requirements of ANSI /ANS-3.1-1981, and
-qualification requirements for the INPO accredited training programs, for those comparable positions.
The Shift Technical Advisor shall also be required
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to have a bachelor's degree or equivalent in a scientific or engineering discipline,,in addition i
to the requirements of ANSI /ANS-3.1-1981, and qualification requirements for the INPO accredited l l l
Dockst Nos. 50-277 1
50-278 j
License Nos. DPR-44 i
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training program, with specific. training-in plant design, and response and analysis of the plant for transients and' accidents."
As noted.in the above, Licensee proposes to add to e
Tection 6.3.1 the words "so long as those individuals 1
hold those positions on and after February-27, 1989."
A new section 6.3.2 will be created that states:
"Each t
member of the facility staff who-bas been reassigned, transferred or hired on or after February 28, 1989, shall meet or exceed the minimum requirements of ANS/ ANSI-3.1-1981, and qualification requirements for the INPO accredited training programs, for those comparable positions."
Included in these words is reference to the
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qualification' requirements for the INPO accredited training programs.
These words are added to ensure that qualification requirements established by the INPO accredited training programs are maintained.
a
-Additionally, Licensee proposes to delete from the existing paragraph the words "except for (1) Senior-Health Physicist (radiation protection manager) who shall meet or exceed the qualifications of Regulatory -
p, Dockst No2. 50-277 50-278.
License Nos. DPR-44 DPR-56 Guide 1.8, September.1975 and (2)".
Reference to this
. regulatory guide is being deleted because the requirements of this guide are now included in the ANSI /ANS-3.1-1981 standard, i.
Licensee also proposes to delete the word "who" and add the words "also be-required to" such that a new sentence will state: "The Shift Technical Advisor shall also be required to'have-a bachelor's degree or equivalent in a scientific or engineering discipline, in addition to the requirements of ANSI /ANS-3.1-1981, and qualification requirerents for the INPO accredited training program, with specific. training in plant design, and response and analysis of tha plant for transients and accidents."
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This change clarifies the requirements for the Shift I-L Technical Advisor in that it clearly specifies that.the I
i Shift Technical Advisor shall also be required to have a bachelors' degree in addition tx) meeting the requirements of ANSI /ANS-3.1-1981.
l Included in these words is reference to the qualification requirements for the INPO accredited training program.
These words are added to ensure that qualification requirements established by the INPO i
accredited training program are maintained.,
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Dockst Nos. 50-277 50-278 License Nos. DPR-44 I
DPR-56 2.
Licensee proposes to delete the reference to "Section
'5.5'of ANSI N18.1-1971" in paragraph 6.4.1
(" Training")
and replace it-with reference to "Section 5 of ANSI /ANS-3.1-1981".
Section S.5 of ANSI N18.1-1971 concerns'
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retraining and replacement training.
Criteria for T
.t retraining and replacement training are now contained-in Section 5 of ANSI /ANS-3.1-1981.
Additionally, reference to " Appendix A" of 10 CFR 55 has been deleted due to 10 CPR 55 being revised.
i Also added are the words "INPO accredited training programs shall be an acceptable substitute for meeting the training requirements of ANSI /ANS-3.1-1981 for-those comperable positions addressed in the accreditation programs.. Training programs for comparable positions not covered by INPO accredited programs shall meet the requirements of ANSI /ANS-3.1-1981 by March.31, 1991 and until then, Section 5.5 of ANSI N18.1-1971."
These words are added to clarify the relationship between INPO i
accredited training programs and the requirements of ANSI /ANS-3.1-1981.
Wording has also-been added which permits that training programs for comparable positions not covered by INPO L
[h Docket"Nos. 50-277 I
50-278 6
License Nos. DPR-44 DPR-56 accredited programs shall meet the requirements of ANSI /ANS-3.1-1981 by March 31, 1991.
This time delay is necessary to provide for the training program upgrades necessary to meet the requirements of ANSI /ANS-3.1-1981.
The paragraph shall state:
"A retraining and replacement training 9
program for the facility staff shall be maintained under the direction of the o
Superintendent-Training and shall neet the requirements of Section 5 of i
ANSI /ANS-3.1-1981 and 10 CFR 55.
INPO accredited training programs shall be an acceptable substitute for meeting the training requirements of ANSI /ANS-3.1-1981 for those comparable positions-i addressed in the accreditation programs.
Training programs for comparable positions not covered by INPO accredited programs shall meet the requirements of ANSI /ANS-3.1-1981 by March 31, 1991 and until then, Section 5.5 of ANSI N18.1-1971.",-
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Dockst Non. 50-277 50-278 i
License Nos. DPR-44 DPR-56 i
. Safety Assessment The personnel of the operating organization who have the responsibility for the safe and efficient operation of a nuclear power plant:throughout its' operational lifetime must understand the complexities of the plant design and must be capable of properly manipulating the plant controls as well as maintaining l.
and repairing the plant equipment.
The selection of the V
operating and support personnel-for nuclear power plants and the training of these personnel to provide sound judgment, based on-knowledge and experience of nuclear and power plant systems, are essential to the safe and successful operation of these plants.
l Subcommittee ANS-3, Reactor Operations, American Nuclear l
Society Standards Committee, developed a standard containing criteria for the qualification and training of nuclear power plant personnel.
This standard was approved by the American National Standards Institute (ANSI) Committee N18, Design Criteria for Nuclear Power Plants, and designated ANSI N18.1-s 1971, " Selection and Training of Nuclear Power Plant Personnel."
p It is to this standard that Peach Bottom has committed per Section 6.3.1 ("Pacility Staff Qualifications") of the PBAPS p
Technical Specifications and Section 13.2 of the PBAPS UFSAR.
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Docket Non. 50-277
-i 50-278 1
License Nos. DPR-44 DPR-56 l
Since approval of ANSI N18.1-1971, the ANSI standard has been revised and designated ANSI /ANS-3.1-1978, " Selection and
' Training of Nuclear Power Plant Personnel."
As a result of 1
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-lessons learned from the Three Mlle Island Unit 2 incident as well as changing regulatory requirements, the 1978 version has been revised and reissued as ANSI /ANS-3.1-1981, " Selection, Qualification and Training of Personnel for Nuclear Power Plants."
Y Revision 2 of NRC's Regulatory Guide 1.8 endorses Sections 14.3.1.1, " Shift Supervisor," 4.3.1.2,
" Senior Operator,"
4.5.1.2, " Licensed Operators,"
4.4.8.,
and 4.4.4, " Radiation Protection" of ANSI /ANS-3.1-1981, with exceptions.
NRC's endorsement for all other positions remains with ANSI'N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."
As noted in the NRC's publication, NUREG-1262 (which was transmitted by Generic Letter 87-16, dated November l
12, 1987), if the training programs are INPO accredited, there is no obligation to follow Regulatory Guide 1.8, Revision 2 because l
the INPO guidelines are equivalent to the staff guidelines in the Regulatory Guide.
At Peach Bottom, 11 training programs are INPO accredited.
Wording has been included in the Technical L
Specification change which ensures that all qualification and training requirements for the INPO accreditation programs are
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 included as a part of the facility staff qualifications and the PBAPS training program.
As noted in the " Description of Changes", wording has also been added which permits that training programs for comparable positions not covered by INPO accredited programs shall meet the requirements of ANSI /ANS-3.1-1981 by March 31, 1991.
This time delay is necessary to provide for the training program upgrades necessary to meet the requirements of ANSI /ANS-o 3.1-1981.
A comparison has been performed between the requirements of ANSI /ANS-3.1-1981 and ANSI.N18.1-1971.
The personnel i
selection, qualification and training requirements provided in ANSI /ANS-3.1-1981 are generally equivalent or greater than the 1971 version.
The 1981 version also encompasses additional positions not discussed in the 1971 version.
Therefore, I
compliance _with ANSI /ANS-3.1-1981 will improve the selection, qualification and training of the operating and support personnel-for the nuclear power plant station and will not adversely affect the safe operation of the plant. -
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'4 Dockot-No2. 50-277 50-278 License Nos. DPR-44 DPR Information Supporting a Finding of No Significant Hazards Consideration The Commission has provided guidance concerning the application of the standards for determining whether license amendments involve significant hazards considerations by providing certain examples (51 FR 7751).
One of the examples of amendments that are considered not likely to involve significant hazards consideration is "(ii) A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g.,
a more stringent surveillance requireraent."
The proposed changes to the Technical Specification impose additional controls not presently included in the Technical Specifications.
1 The proposed changes to the Peach Bottom operating licenses do not constitute a significant hazards consideration in that they do not:
1)
Involve a significant increase in the probability or consequences-of an accident previously evaluated.
The upgrade in personnel selection, qualification-and training standards to ANSI /ANS-3.1-1981 will ensure equivalent or higher levels of education, experience and..
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' Docket Non. 50-277 i
50-278 License Nos. DPR-44 f
training of plant personnel.
These equivalent or-higher standards in personnel selection, qualification and I
training will serve to reduce the probability of an i
accident as previously evaluated from' occurring, and r
reduce the consequences of an accident =as previously evaluated.
i Wording has been included in the Technical H
Specifications change which ensures that all qualification and training requirements for the INPO accreditation. programs are included as a part of the facility staff qualifications and.the PBAPS training program.
At Peach Bottom, 11 training programs are INPO_
' accredited.
This is an administrative change to the Technical Specifications which will not involve a significant increase in the probability or consequences of.an accident as previously evaluated.
11)
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The change of the Technical Specifications from the current requirements of ANSI N18.1-1971 to ANSI /ANS-3.1-l 1981 and the INPO accreditation requirements are administrative changes which will increase the level of l
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Docket Nos. 50-277' 50-278 License Nos. DPR-44 I
DPR-56 standards for selection, training and qualifications of o
plant personnel and will not create a new.or different kind of accident than previously evaluated.
iii) Involve a significant reduction in a margin of safety.
The change of the-Technical Specifications from the 1
current requirements of ANSI N18.1-1971 to ANSI /ANS-3.1-1981 and the INPO accreditation requirements are administrative changes which will result in an increase in. personnel selection, qualification and training standards and serve to increase margins of safety as defined in the PBAPS Technical Specifications.
i Information Supporting an Environmental Impact Assessment An environmental impact assessment.is not required for the changes proposed by this Application because the changes 1
conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CPR 51.22(c)(9).
The Application' involves no significant hazards consideration as demonstrated in the preceding section.
The Application involves no significant change in the types or significant increase in the amounta of any effluents that may be released offsite, and there is no,
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d Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve unreviewed safety questions or involve Significant Hazards Considerations, and will not endanger the health and safety of the public...
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l ATTACIDLENT 2 l
l PEACH BOTTOM ATOMIC POWER STATION 5
Units 2 and 3 i
Docket Nos. 50-277 50-278
-l License Nos..DPP.-44 DPR-56 I
TECHNICAL SPECIFICATION CHANGES
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i List of Attached Page j
246 i
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