ML13330A442
| ML13330A442 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/07/1984 |
| From: | Paulson W Office of Nuclear Reactor Regulation |
| To: | Baskin K Southern California Edison Co |
| References | |
| TAC-54700, TAC-54701, TAC-54893 LSO5-84-09-006, LSO5-84-9-6, NUDOCS 8409100321 | |
| Download: ML13330A442 (11) | |
Text
September 7, 1984 Docket No. 50-206/361/362 DISTRIBUTION LS05-84-09-006 Docket PM NRC PDR OELD Local PDR ELJordan ORB Reading JNGrace Mr. Kenneth P. Baskin, Vice President NSIC ACRS (10)
Nuclear Engineering WPaulson SEPB Licensing and Safety Department CJamerson Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
Dear Mr.-Baskin:
SUBJECT:
PROPOSED TECHNICAL SPECIFICATION CHANGES ON ADMINISTRATIVE CONTROLS Re:
San Onofre Nuclear Generating Station, Units 1, 2, and 3 By letters dated May 1, 1984 (Unit 1) and March 7, 1984 (Units 2 and 3),
you submitted applications to revise parts of Section 6, Administrative Controls of the Technical Specifications for San Onofre Nuclear Generating Station, Units 1, 2, and 3.
As discussed in the enclosure additional information is required to support several of the proposed changes in such areas as onsite organization, review responsibilities and control room command function.
To most efficiently resolve these issues, the staff proposes that a meeting be held, using the enclosure as the agenda. We will be contacting you in the near future to arrange such a meeting.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents, therefore, OMB clearance is not required under P.L.96-511.
Walter A. Paulson, Acting Chief Operating Reactors Branch #5 Division of Licensing
Enclosure:
As stated cc w/enclosure:
See next page D
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Mr. Kenneth.
September 7, 1984 cc Charles R. Kocher, Assistant General Counsel James Beoletto, Esquire Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montogmery Street San Francisco, California 94111 Dr. Lou Bernath San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS c/o U.S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego San Diego, California 92101 Director Energy Facilities Siting Division Energy Resources Conservation &
Development Commission 1516 -
9th Street Sacramento, CA 95814 U.S. Environmental Protection Agency Region IX Office ATTN:
Regional Radiation Representative 215 Freemont Street San Francisco, California 94105 John B. Martin, Regional Administrator Nuclear Regulatory Commission, Region V 1450 Maria Lane Walnut Creek, California 94596 SAN ONOFRE UNIT 1 TECHNICAL SPECIFICATION CHANGES By letter dated May 1, 1984, the licensee requested changes to Section 6, "Administrative Controls" of the Technical Specifications for San Onofre Unit 1. Staff questions relating to these proposed changes are given below.
Specification Number 6.1.2 This proposed additional specification would permit the "shift superintendent or the control room supervisor (or during their absence from the Control Room Area, a designated individual)" to be responsible for the control room command function. The staff has-the following concerns:
(1) The intent of the Standard Technical Specification that addresses this matter is to have all personnel aware that the shift superintendent has the ultimate authority and responsibility for shift operations, and that this authority and responsibility cannot be assumed by any person not qualified for the position. Anyone who is authorized to relieve the shift superintendent must be specified.
Based upon this intent, only the shift superintendent can have the responsibility for the control room command function. Since it is recognized that there will be times when the shift superintendent will not be in the control room, the second of the two required SROs on shift would logically perform the shift superintendent's control room duties, as designated.
The term "control room command function" is intended to cover all shift operations and-personnel, given that the control room is the "command post" for such operations.
-2 Based upon the above, the inclusion of "or the control room supervisor" may be confusing, and that phrase should not be included in the specification. The control room supervisor is included in "a designated individual."
(2) There must always be, during operating modes 1-4, two SROs on shift, one of whom should always be in a loca tion from which the reactor operator can be observed and supervised. Therefore, the shift superintendent and the control room supervisor cannot both be away from the control room at the same time.
6.2.1 The proposed additional sentence would permit changes to be made in the organization shown in the Technical Specifications without prior license amendment. Although this matter is under review by the Commission, final action has not been taken. Therefore, the proposed change cannot be approved at this time.
6.2.2b The proposed additional sentence would permit the SRO, required for control room supervision, to be in the shift superintendent's office as well as in the control room proper.
We have reviewed a plan drawing of the control room and shift superintendent's office and conclude that the SRO could be in the open doorway to the shift superintendent's office and still be able to observe the-control board, but could not do so if he were in the office. Therefore, the proposed change is acceptable only by deleting the word "Area" from 6.2.2b and the words "or the Shift Superintendent's office" in the double-asterisked footnote.
Figures 6.2.2.1 The licensee proposes to change both the offsite organization and 6.2.2.2 and the facility organization. However, the licensee has not provided any discussion of the proposed.changes that would permit the staff to evaluate the functions and responsibilities of the new organizational positions as opposed to those of the old. Therefore, additional information is required to support these proposed changes.
Table 6.2.2.2 For the reasons discussed in 6.1.2 and 6.2.2b above, the portions of the proposed Table 6.2.2.2 relating to the "Control Room Supervisor," the "Control Room Area," and the single-and double-asterisked notes require further justifica tion.
6.5.1.9 The proposed change would delete the requirement, presently expressed in the ultimate phrase of the existing specifica tion, for review to verify that the actions taken do not constitute an unreviewed safety question. Justification is required before this change can be approved.
-3 6.5.1.12 and The proposed change would permit reviews to be performed by 6.5.1.13 individuals in on-site organizations other than those reporting to the Station Manager. Although the staff can envision benefits from such an arrangement, (since these other individuals are to be previously designated by the Station Manager), the licensee has not provided justification for having people who are not managed by the Station Manager perform the specified actions.
6.5.1.14 The proposed changes would permit changes to the station security program and procedures to be approved by the Deputy Station Manager or the Manager, Station Security, as well as by the Station Manager. It would also eliminate the require ment that such changes be sent to upper management and to the Nuclear Audit and Review Committee (NARC).
The licensee has not provided justification for the proposed downgrading of approval authority, nor for the deletion of the opportunity for upper management review.
6.5.1.15 The proposed change is similar to that proposed for 6.5.1.14 except that it applies to the station emergency plan.
The comments given in 6.5.1.14 above apply.
6.5.1.16 The proposed change would require only major changes to the radwaste treatment systems to be reviewed.The licensee has not justified the proposed downgrading of the review require ments and has not provided a definition of the word "major" for our evaluation.
6.5.1.17 The proposed change would delete the requirements for reporting certain activities to upper management and the NARC.
The licensee justification for this deletion merely states that publishing reports of review activities is 'not necessary "since each review is individually documented for the record."
Such a deletion would mean that upper management and the NARC would not see these reports unless they were specifically requested. See comments under 6.5.1.14.
6.5.2.1 With one exception, the proposed change would bring this specification, concerning the functions of the NARC, into conformance with the STS. The exception would permit diluting the attention given by the NARC to important safety matters by having the NARC "responsible to provide for the" indepen dent review and audit of designated activities. The phrase in quotation marks should not be included. The STS phrase is "the [NARC] shall function to provide independent review and audit..." and the existing Technical Specifications for San Onofre Unit 1 states "the NARC provides independent review and audit..."
The potential for dilution, as noted above, is of concern.
-4 6.5.2.2 The proposed change would change the position titles of four of the members of the NARC. The acceptability of the proposed change is contingent upon the acceptability of the organiza tion changes discussed above concerning Figure 6.2.2.1.
6.5.2.7 The proposed change would make the NARC "responsible for" the listed activities. The comment under 6.5.2.1 above, applies.
6.5.2.1G0b The proposed change would delete the requirement that reports of certain of the NARC reviews be prepared, approved, and forwarded to the Nuclear Control Board. The licensee has provided no justification for this deletion.
6.8.2 The licensee has proposed to limit the applicability of this specification to "implementing" procedures, but no definition of "implementing," as an adjective, is given, nor has the licensee provided a justification for this change.
The licensee has also proposed to permit procedure approval authority to be given to the Manager, Nuclear Generation Services, and to Cognizant Managers who report directly to the Vice President and Site Manager or the Station Manager or to the Deputy Station Manager or to the Manager, Nuclear Generation Services. The staff has the following concerns:
(1) Specification 6.5.1.9 requires that procedure preparation and review be accomplished under the authority and responsibility of the Station Manager. However, according to proposed Figure 6.2.2.1, the Station Manager has no authority over the Manager, Nuclear Generation Services nor over any Cognizant Managers that may report to the Manager, Nuclear Generation Services.
(2) The existing specification permitsprocedure approval by certain managers who report to the Station Manager or Deputy Manager, as previously designated by the Station Manager. However, the proposed specification does not maintain the Station Manager's control over which Manager can approve particular procedures.
(3) As noted above in our evaluation of the proposed changes to Figures 6.2.2.1 and 6.2.2.2, the licensee has provided no information about the functions and responsibilities of the Manager, Nuclear Generation Services and his Cognizant Managers. Therefore, we are unable to determine the appropriateness of including these managers in the procedure approval process.
.- 5 6.8.3b The proposed change would permit temporary changes to procedures to be approved by "station/site supervisors/
management staff" rather than by plant management staff as in the existing specification.
For the reasons given in 6.8.2 above, and because the quoted terminology is so vague, the proposed change requires furtherjustification/
clarification.
6.8.3c The proposed change would reference the management staff identified in 6.8.2 rather than particular managers as in the existing specification. This change cannot be found acceptable until our concerns about Specification 6.8.2 are resolved.
SAN ONOFRE UNITS 2 AND 3 TECHNICAL SPECIFICATION CHANGES By letter dated March 7, 1984, the licensee requested changes to'Section 6, "Administrative Controls" of the Technical Specifications for San Onofre Unit 1. Staff questions relating to these changes are given below:
Specification Number Figures 6.2.-l The licensee proposed to change both the offsite organi and 6.2-2 zation and the facility organization. However, the licensee has not provided any discussion of the proposed changes that would permit us to evaluate the functions and responsibilities of the new organizational positions as opposed to those of the old.
Table 6.2-1 With one.exception, the proposed changes merely reflect the staffing requirements for two-unit operation in accordance with 10 CFR 50.54(m) and are acceptable.
The exception involves the ultimate sentence of-Table 6.2-1; if one of the units is in Mode 1, 2, 3 or 4 when the subject unit is in Mode 5 or 6, the Control Room command function may not be performed by an RO, but only by an SRO. Therefore, the ultimate sentence requires clarification.
Figure 6.2-3 The proposed inclusion of the Operations Support Office in the definition of "Control Room Area" cannot be approved at this time, as the licensee has provided no justification for extending the area in which the control room SRO may perform his functions for supervising the control room operators.
6.5.2.4 and The proposed change would permit reviews to be performed 6.5.2.5 by individuals in on-site organizations other than that reporting to the Station Manager. Although we can envision benefits from such an arrangement (since these other individuals are to be previously designated by the Station Manager), the licensee has not provided justification for having people who are not managed by the Station Manager perform the specified actions.
-2 6.5.2.6 The proposed change would have the station security program and implementing procedures reviewed in accor dance with 10 CFR 73.55(g)(4). The specification could be interpreted as taking precedence over Specification 6.8.1a, which invokes Regulatory Guide 1.33.
This Regulatory Guide endorses more rigid standards than does 10 CFR 73.55(g)(4).
The proposed change would also permit changes to the station security program and procedures to be approved by the Deputy Station Manager or the Manager, Station Security, as well as by the Station Manager. It would also eliminate the requirement that such changes be sent to upper management and to the Nuclear Safety Group (NSG).
The licensee has not provided, justification for the proposed down-grading of approval authority nor for the deletion of the.opportunity for upper management review.
6.5.2.7 The proposed change is similar to that proposed for 6.5.2.6 except that it applies to the station emergency plan. The above comment applies.
6.5.2.9 The proposed change would move the responsibility.for assuring review of changes to the Offsite Dose Calculation Manual from the Station Manager to the Manager, Nuclear Safety. The licensee has not provided justification for the proposed change.
6.5.2.10 The proposed change would eliminate the requirement that reports documenting each of the activities performed under Specifications 6.5.2.1 through 6.5.2.9 shall be maintained and copies of the reports shall be provided to the Manager of Nuclear Operations and the Nuclear Safety Group.
The licensee's justification for this deletion merely states that publishing reports of review activities is not necessary "since each review is individually docu mented for the record."
Such a deletion would mean that upper management and the NSG would not see these reports unless they were specifically requested.
Further justi
.fication is required.
6.8.2 The licensee has proposed to limit the applicability of this specification to "implementing" procedures., but no definition of "implementing," as an adjective, is given nor has the licensee provided a justification for this change.
The licensee has also proposed to permit procedure approval authority to be given to the Manager, Nuclear Generation Services, and to Cognizant Managers who report directly to the Vice President and Site Manager or to the Station Manager or to the Deputy Station Manager or to the Manager, Nuclear Generation Services. The staff has the following concerns:
(1) Specification 6.5.2.1 requires that procedure preparation and review be accomplished under the authority and responsibility of the Station Manager.
However, according to proposed Figure 6.2-1, the Station Manager has no authority over the Manager, Nuclear Generation Services nor over any Cognizant Managers that may report to the Manager, Nuclear Generation Services.
(2) The existing specification permits procedure approval by certain managers-who report to the Station Manager or Deputy Station Manager, as previously designated by the Station Manager. However, the proposed specification does not maintain the Station Manager's control over which manager can approve particular procedures.
(3) As noted above in our evaluation of the proposed changes to Figures 6.2-1 and 6.2-2, the licensee has provided no information about the functions and
- responsibilities of the Manager, Nuclear Generation Services and his Cognizant Managers. Therefore, we are unable to determine the appropriateness of including these managers in the procedure approval process.
6.8.3b The proposed change would permit temporary changes to procedures to be approved by "station/site supervisory/
management staff" rather than by plant management staff as in the existing specification.
For the reasons given in 6.8.2 above, and because the quoted terminology is so vague, the proposed change requires further clarification/
justification.
-4 6.8.3c The proposed change would reference the management staff identified in 6.8.2 rather than particular managers as in the existing specification. This change cannot be found acceptable until our concerns about Specification 6.8.2 are resolved.