ML18096A814
| ML18096A814 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/08/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18096A815 | List: |
| References | |
| NLR-N92084, NUDOCS 9207140280 | |
| Download: ML18096A814 (7) | |
Text
Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations JUL 0 8 1992 NLR-N92084 LCR 92-07 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION CLARIFICATION OF REQUIREMENTS FOR LICENSED OPERATOR QUALIFICATIONS AND TRAINING SALEM GENERATING STATION FACILITY OPERATING LICENSE DPR-70 AND DPR-75 DOCKET NO. 50-272 AND 50-311 This letter constitutes an application for amendment to Appendix A of Facility Operating Licenses DPR-70 and DPR-75 for the Salem Generating Station and is being filed in accordance with the provisions of 10CFR50.90.
This amendment application proposes changes to Technical Specifications (TSs) 6.3, "Unit Staff Qualifications" and 6.4, "Trainin~" to clarify the current
. requirements for licensed operator qualifications and training. contains a detailed description of the proposed changes along with our 10CFR50.92. analysis of significant hazards.
Marked up TS pages showing the proposed changes are included as Attachment 2.
Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall be.implemented within 60 days of issuance~
This latitude permits time to complete the actions necessary to implement the proposed changes.
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
I Affidavit Attachments (2)
,,,---92011402acr-9201oa --- -
I PDR ADOCK 05000272 P
PDR Sincerely, I
I Document Control Desk NLR-N92084 2
c Mr. T. T. Martin, Administrator - Region I
- u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. c. Stone, Licensing Project Manager -
Salem
- u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. T. P. Johnson (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 JUL 0 B 1992
STATE OF NEW JERSEY COUNTY OF SALEM SS.
REF: NLR-N92084 LCR 92-07 Stanley LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated JUL 0 8 1992
, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this f-M day of ~
, 1992 My Commission expires on SHERRY l. CAGLE NOTARY PUBLIC OF NEW JERSEY My Commission Expires March 5, 1997
LICENSE 1\\MEM.MENl'.APP.I.J:CATION ClARIFICATION OF REJJ(JIREMENIS FOR LicmsED OPERMUR gJALIFICATIOOS AND '1RAINING SAUM GENERATING S'mTION E\\CILI'IY OPERATING LicmsES Dm-70 AND Dm-75 OOCKEl' NOS. 50-272 AND 50-311 I.
Description of Cl1ame NIR-N92084 rm 92-07 NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses", was published in November 1987 to doa.nnent the info:ntlCition and guidance provided by the NRC on the requirements of the revised 10CFR55, "Operator's Licenses".
'!he answer to Question 98 of NUREG-1262 states that a facility with an accredited training program, that has a more restrictive requirement in their Technical Specifications ('ISs) than required by the nile, is pennitted to apply for relief and that the change would be considered an administrative change to confonn with the revised regulation.
NUREG-1262 indicates that accreditation obviates the need to confonn to Regulato:ry Guide (RG) 1. 8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 2, and the associated standards endorsed by the RG 1.8 (i.e., ANSI/ANS 3.1 and ANSI/ANS 18.1).
Specifically, Question 100 states that a facility which has an accredited program is no longer obligated to follow RG 1. 8 and that the NRC considers the INro guidelines equivalent to the staff guidelines contained in the RG.
PSE&G's licensed operator training programs have been accredited by INro and are based on a systems approach to training. Licensed operator qualifications and the licensed operator retraining and replacement training programs must corrply with the requirements of the revised 10CFR.55 which,. as stated in NUREG-1262, supersedes the supplemental requirements specified in the March 28, 1980 NRC letter to all licensees.
This amendment application is being submitted in accordance with the above guidance and proposes changes to 'ISs 6.3.1 and 6.4.1 to delete 'IS requirements that are superseded based on accreditation of our licensed operator training programs, adoption of a "systems approach to training", and promulgation of the revised 10CFR55.
'!he following administrative changes are proposed to clarify the current requirements for licensed operator qualifications and training:
- 1.
Delete the requirement from 'IS Section 6. 3.1 that licensed operators meet or exceed the minimum qualifications of ANSI/ANS 18.1-1971 and the supplemental requirements specified in Sections A and c of the March 28, 1980 NRC letter to all licensees. This is replaced by a requirement that licensed operators corrply with the requirements of 10CFR55.
Page 1 of 4 Clarification of Operator Qualifications and Training NLR-N92084 LCR 92-07
- 2.
Delete the requirement from TS Section 6. 4.1 that the licensed operator retraining and replacement training programs meet or exceed the requirements of ANSI/ANS 18.1-1971 and the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees. '!his is replaced by a requirement that the training programs comply with the requirements of 10CFR55.
The licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55, and the qualifications and training programs for all other affected unit staff will continue to be required to meet or exceed the standards of ANSI/ANS 18.1-1971 (except for the Radiation Protection Engineer who will continue to be required to meet or exceed the qualifications of RG 1.8, September 1975).
II. Reason for Cbanqe These changes are being pro:p:>sed to delete TS requirements that are superseded based on accreditation of our licensed operator training programs, adoption of a "systems approach to training", and promulgation of the revised 10CFR55, "Operator's Licenses", which became effective on May 26, 1987.
- m. Justification for 01am"e This Change Request involves a pro:p:>sed administrative change to the TS to clarify the current requirements concerning licensed operator qualifications and training programs.
The TS requirements for all other affected unit staff qualifications and training programs remain unchanged.
The licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55.
Licensed operator qualifications and training can have an indirect impact on accidents previously evaluated; however, the NRC considered this impact during the rulernaking process, and by promulgation of the revised 10CFR55 rule, detennined that this impact remains acceptable when licensees have an accredited licensed operator training program which is based on a systems approach to training. '!his is because the NRC has concluded, as stated in NURill-1262, that the standards and guidelines applied by INro in their training accreditation program are equivalent to those put forth or endorsed by the NRC.
Therefore, maintaining INro accredited, systems based licensed operator training programs is equivalent to maintaining NRC approved licensed operator training programs which confonn with applicable NRC Regulatory Guides or NRC endorsed ANSI/ANS standards.
Additionally, the pro:p:>sed TS changes do not affect plant design, hardware, system operation, or procedures.
Page 2 of 4 Clarification of Operator Qualifications and Training IV. Significant Hazams Consideration Evaluation NLR-N92084 LCR 92-07
'!he proposed changes to the salem Generating Station Technical Specifications:
- 1.
lb not involve a significant increase in the pnilability or cansequences of an accident previously evaluated.
'!he proposed 'IS changes are administrative changes to clarify the current requirements for licensed operator qualifications and training programs and to confonn to the revised 10CFR55 rule. Although licensed operator qualifications and training can have an indirect inpact on accidents previously evaluated, the NRC considered this inpact during the rulemaking process, and by promulgation of the revised rule, concluded that this inpact remains acceptable as long as licensed operator training programs are accredited and based on a systems approach to training.
PSE&G's licensed operator training programs have been accredited by INIO and are based on a systems approach to training. '!he proposed 'IS changes take credit for the INFO accreditation of the licensed operator training programs and require continued compliance with the requirements of 10CFR55.
'!he 'IS requirements for all other unit staff qualifications and training programs remain unchanged. 'lherefore, *the proposed 'IS changes do not increase the probability or consequences of an accident previously evaluated.
- 2.
lb not create the possibility of a new or different kini of accident frcm any accident previously evaluated.
'!he proposed 'IS changes are administrative changes to clarify the current requirements for licensed operator qualifications and training programs and to confonn to the revised 10CFR55 rule. '!he changes do not affect plant design, hardware, system operation, or procedures. Additionally, in promulgating the revised rule, the NRC concluded that the inpact of the revised rule on the possibility of creating a new or different kind of accident is acceptable as long as licensed operator training programs are accredited and based on a systems approach to training.
'As noted previously, PSE&G's licensed operator training programs have been accredited by INro and are based on a systems approach to training. '!he proposed 'IS changes take credit for the INro accreditation and require continued compliance with the requirements of 10CFR55.
'!he 'IS requirements for all other unit staff qualifications and training programs re.main unchanged" 'Iherefore, the proposed 'IS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Page 3 of 4
NLR-N92084 LCR 92-07 Clarification of Operator Qualifications and Training
- 3.
Ik> IDt involve a significant reduction in a margin of safety.
'!he proposed TS changes are administrative changes to clarify the current requirements for licensed operator qualifications and training programs and to confonn to the revised 10CFR55 rule. Licensed operator qualifications and training can have an indirect.inpact on a margin of safety; however, the NRC, in pro.rnulgating the revised rule, detennined that the.inpact on margin of safety was acceptable when licensees maintain licensed operator training programs that are accredited and based on a systems approach to training.
As noted previously, PSE&G' s licensed operator training programs have been accredited by INro and are based on a systems approach to training. '!he NRC has concluded, as stated in NCJREX;-1262, that the standards and guidelines applied by INro in their training accreditation program are equivalent to those put forth or endorsed by the NRC.
As a result, maintaining INro accredited, systems based licensed operator training programs is equivalent to maintaining NRC approved licensed operator training programs which confonn with applicable NRC regulato:ry guides or NRC endorsed ANSI/ANS standards. The TS requirements for the qualifications and training programs for all other unit staff remain unchanged.
The licensed operator qualifications and training programs will continue to be required to comply with the requirements of 10CFR55.
'!he margin of safety is maintained by virtue of maintaining INro accredited licensed operator training programs and through continued compliance with the requirements of 10CFR55.
'lherefore, the proposed 'IS changes do not reduce a margin of safety.
V.
Conclusion As discussed in Item r.v above, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards consideration since the changes (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.
Page 4 of 4