ML20078R257

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Proposed TS 6.3.1 Re Administrative Controls
ML20078R257
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 12/16/1994
From:
CENTERIOR ENERGY
To:
Shared Package
ML20078R252 List:
References
NUDOCS 9412230274
Download: ML20078R257 (4)


Text

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ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.1 The ISEG shall function to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources

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of unit design and operating experience information, including units of similar design, which may indicate areas for improving unit safety. The ISEG shall make detailed recommendations for revised procedures, equipment u

modifications, maintenance activities, operations activities, or other means of improving unit safety to the Engineering Department Head.

COMPOSITION 6.2.3.2 The ISEG shall be composed of at least five, dedicated, full-time engineers or technically oriented individuals located onsite.

Each shall have either (1) a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field, at least 1 year of which experience shall be in the nuclear field, or (2) equivalent work experience as described in Section 4.1 of ANSI /ANS 3.1, December 1981.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of unit activities to provide independent verification

  • that these activities are performed correctly and that human errors are reduced as much as practical.

RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to the Engineering Department Head.

6.2.4 SHIFT TECHNICAL ADVIS0

6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to safe operation of the unit.

The Shift Technical Adviscr shall have a bachelor's degree or equivalent in a scientific or engineering discipline and shall have received specific train Sg in the response and analysis of the unit for transients and accidents, and in unit design and layout, including the capabilities of instrumentation and controls in the control room.

6.3 UNIT STAFF OVALIFICATIONS j

6.3.1 Each member of the unit s ff shall meet or exceed the minimum qualifications of ANS! N_lg.1-197 for comparable positiu.is, except Mthe Plant Health Physicist @ shall meet or exceed the qualifications of i

Regulatory Guide 1.8, September 1975. The licensed Operators and Senior

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OperMors shall also meet or exceed the minimum qualifications of the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.

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j prDRY - IINIT 1 6-7 Amendment No. //, (7, 47,65 9412230274 941216 PDR ADOCK 05000440 P

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PY-CEI/NRR-1892 L

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Page 2 of 2 t

TECHNICAL SPECIFICATI0lf CHANGE Insert for page 6-7:

the operations manager or an operations middle manager shall-hold a Senior

' Reactor Operator (SRO) license, and c

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PY-CEI/NRR-1892 L Page 1 of 2 SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations, 10 CFR 50.92, which state that the operation of a facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an occident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in the margin of safety.

The proposed change has been reviewed with respect to those three factors and it has been determined that the proposed change does not involve a significant hazard because:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change affects an administrative control, which was based on the guidance of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." ANSI N18.1-1971 recommended that the Operations Manager hold a senior reactor operator (SRO) license. The current guidance in Section 4.2.2 of ANSI /ANS-3.1-1993, "American National Standard for Selection, Qualification, and Testing of Personnel for Nucicar Power Plants" recemmends, as one alternative, that the Operations Manager have plant operational knowledge consistent with the requirements of the Operations Manager's position, providing an Operations middle manager holds an SR0 license. This individual (currently designated as the operations Superintendent) would be required to meet the criteria for, and would have responsibilities as recommended in, ANSI /ANS-3.1-1993 for the Operations Middle Manager position. The proposed change is consistent with the recommendations of ANSI /ANS-3.1-1993.

The proposed change does not alter the design of any system, structure or component, nor does it change the way plant systems are operated.

It does not reduce the knowledge, qualifications, or skills of licensed operators, and does not affect the way the Operations Section is managed by the Operations Manager. The Operations Manager vill continue to maintain the effective performance of section personnel and ensure the plant is operated safely and in acccrdance with the requirements of the operating license.

Additionally, the control room operators vill continue to be supervised by the licensed senior operators such as the Unit Supervisors and the Shift Supervisors.

For those areas of knowledge that require an SR0 license, the Operations Superintendent vill provide the appropriate technical guidance to the enntrol room staff, i

In summary, the proposed change does not affect the ability of the Operations Manager to provide the plant oversight required of the position. Thus, it does not involve a significant increase in the probability or consequences cf an accident previously evaluated.

PY-CEI/NRR-1892 L Page 2 of 2

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change to Technical Specification 6.3.1 does no'; affect the design or function of any plant system, structure,.or component, nor does it chango the way plant systems are operated.

It does not affect the performance of NRC licensed operators.

Operation of the plant in conformance with the Technical Specifications and other license

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requirements will continue to be supervised by personnel who hold an NRC SRO license. The proposed change to Technical Specification 6.3.1 ensures that either the Operations Manager or Operations Superintendent vill be a knowledgeable and qualified individual by requiring one of the individuals to hold an SRO license for PNPP. Based on the above, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not result in a significant reduction in the margin of safety.

The proposed change involves an administrative control which is not reinted to the margin of safety as defined in the Technical Specifications. The proposed change provides an alternative which ensures that the level of knowledge and experience required of an individual who fills the Operations Manager position is acceptable. The proposed change does not affect the conservative manner in which the plant is operated.

The control room operators vill continue to be supervised by personnel who hold an SRO license.

Thus, the proposed change does not involve a significant reduction in a margin of safety.

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?4-CET/AM-et L 9A6d4 Organization 5.2

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5.2 Organization (continued) 5.2.2

- Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be on site when fuel is in the reactor vessel, and an additional non-licensed operator shall be on site while the unit is in MODE 1. 2. or 3.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor.

In addition. while the unit is in MODE 1. 2. or 3. at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c.

Shift crew composition may be one less than the minimum requirements of 10 CFR 50.54(m)(2)(1) and Specifications 5.2.2.a and 5.2.2.g for a period of time not to exceed two hours in order to accommodate unexpected absence of on-duty shift crew members. provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A health physics technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

The amount of overtime worked by unit staff members performing safety related functions shall be limited and controlled in accordance with NRC Policy Statement on working hours (Generic Letter 82-12).

f.

The operations manager or at least one operations middle manager shall hold an SR0 license, y

g.

The shift technical advisor (STA) shall provide advisory technical support to the shift supervisor (SS) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Ex)ertise on shift.

The STA position may be filled by an on-slift SS or SRO provided the individual meets the Commission Policy Statement on Engineering Expertise on shift.

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PERRY - UNIT 1 5.0-3 Amendment No. C

T4-Cfd MU-18'it 1-Unit Staff Qualifications O* J.=<d 4 5.3 1

sy z4t 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 dch member of the unit staff shall meet or exceed the minimum I

qualifications of ANSI N18.1-1971 for enmnarable positions as Wified by Specification 5.2.2.f/tEcept for tne rauiauivo

)rotection manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The licensed Reactor 0)erators and Senior Reactor Operators shall also meet or exceed t1e minimum qualifications of the supplemental requirements s)ecified in Sections A and C of Enclosure 1 of the March ~28,1980 NRC letter to all licensees.

l PERRY - UNIT 1 5.0-4 Amendment No. C

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