ML14183A077
| ML14183A077 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/28/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML14183A076 | List: |
| References | |
| NUDOCS 8611170009 | |
| Download: ML14183A077 (3) | |
Text
UNITED STATES 0
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 105 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER AND LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 Introduction By letter dated April 2, 1986, Carolina Power and Light Company (CP&L) requested several changes to the Technical Specifications for the H.R.
Robinson Plant, Unit 2. The requested changes involve a corporate reorganization, changes to staff qualifications, Plant Nuclear Safety Committee membership, approval authority for plant modifications, and a title chanae. These chances would affect Figures 6.2-1 and 6.2-2, and Section 6.?, 6.3, and 6.5 of the plant Technical Specifications (TS).
Evaluation The first requested revision would change the Corporate Organization Chart, Figure 6.2-1, to reflect a recent reorganization of corporate management structure. Sections 6.5.2, 6.5.2.1, 6.5.2.2.C, and 6.5.3.4 would be revised to update organization titles. The reorganization involves a realignment of managerial responsibilities and a restructuring of areas of responsibilities within departments and sections. Overall, these changes do not appear to change existing responsibilities, but rather will realign them in a way which should increase management awareness and involvement in issues affecting plant operation. The reporting of QA audit results has been revised to include a full line of command from Senior Executive Vice President Power Supply and Engineering to Plant General Manager. Because these changes do not affect overall responsibilities or oraanizational commitments, we find them acceptable.
In addition to the organizational changes and title changes, this amendment request indicates that a statement would be added to Section 6.2.1 which would allow future changes to the corporate organization to be made without prior amendment to Figure 6.2-1, provided an amendment request is submitted within three months of the effective date of the chanqe. We find this additional statement to be unacceptable. Incorporation of such a statement in the Technical Specifications would effectively exempt the licensee from the requirements of10 CFR 50.59 and 10 CFR 50.90 which require a prior request for any changes of Technical Specifications.
The second requested revision would change the title of "Principal Engineer Operations" to "Operations Support Supervisor" (Figure 6.2-2).
Since this is only a title change and does not involve any change in qualifications 8611170009 861028 PDR ADOCK 05Q00261 P
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-2 or responsibilities, we find it to be acceptable. The submittal indicates that a statement has been added to Section 6.2.3 allowing changes to the organization without a prior license amendment request provided the chance request is submitted within three months. We find this additional statement to be unacceptable for the same reason previously stated - it is an implied exemption that has not been justified.
The third requested chance would expand the applicability of the licensee's commitments regardina staff qualifications. Because this change to TS 6.3.1 represents an overall improvement in staff oualifications by making ANSI N18.1 more widely applicable, we find this change acceptable.
The fourth chance requested by the licensee involves the addition of two members to the Plant Nuclear Safety Committee (PNSC).
This change affects Section 6.5.1.6.2 of the plant Technical Specifications. Since this change enhances the PNSC by providing a broader perspective of review, we find the chanqe acceptable.
We recommend that the licensee also reword Section 6.5.1.6.5 which specifies quorum requirements for the PNSC, to assure that the quorum represents a clear majority of the membership of the PNSC.
The last request is to revise Section 6.5.1.2.3 which establishes authority for final approval of plant modification packages. The change would restrict approval authority to the Manaqer of Robinson Nuclear Project and the General Manager of the Plant, or their designees. Currently, the Manager-Technical Support is also authorized to give final approval.
Because the deletion of Manaqer-Technical Support from the authorization list will assure that only the Manager of Robinson Nuclear Project or the General Manaaer (or their designees') can approve plant modifications, and because that deletion is not expected to cause any delays in implementing safety related modifications, we find the requested change acceptable.
Summary In summary, we find the changes to the plant Technical Specifications acceptable with the exception of the two statements that would exempt the licensee from the requirements of 10 CFR 50.59 and 10 CFR 50.90. Because the change to the PNSC membership affects the PNSC quorum requirements in Section 6.5.1.6.5, we recommend that Section 6.5.1.6.5 also be chanaed for the sake of consistency.
Environmental Consideration This amendment relates to changes in recordkeeping, reporting or administrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
-3 Conclusion We have concluded, based on the considerations discussed above,,that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: October 28, 1986 Principal Contributor:
G. Lapinsky