ML14183A132
| ML14183A132 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/03/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML14183A131 | List: |
| References | |
| GL-88-006 NUDOCS 8811070149 | |
| Download: ML14183A132 (3) | |
Text
~pjoREGN UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 120 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION
By letter dated May 25, 1988 and amended by letter dated October 13, 1988, the Carolina Power & Light Company (the licensee) submitted a request for changes to Technical Specifications (TS) 6.2, Organization. The proposed changes would remove Figure 6.2-1, Offsite Organization & Facility Manage ment, and Figure 6.2-2, Facility Organization, and replace them with a narrative description of the offsite and onsite organizations functional requirements in TS 6.2-1. Guidance for these proposed changes to the TS was provided to licensees and applicants by Generic Letter 88-06, dated March 22, 1988.
2.0 BACKGROUND
Consistent with the guidance provided in the Standard Technical Specifi cations, Specifications 6.2.1 and 6.2.3 of the administrative control requirements have referenced offsite and facility (onsite) organization charts that are provided as figures to these sections. Restructuring of either the offsite or unit organizations has required the licensee to submit a license amendment for NRC approval to reflect the desired changes in these organizations.
Because of these limitations on organizational structure, the nuclear industry has highlighted this as an area for improvement in the TS.
The Shearon Harris licensee proposed changes to remove organization charts from its TS under the lead-plant concept that included the endorsement of the proposed changes by the Westinghouse Owners Group. In its review of the Shearon Harris proposal, the staff concluded that most of the essential elements of offsite and onsite organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR Part 50. However, there are aspects of the organizational structure that are important to ensure that the administrative control requirements of 10 CFR 50.36 would be met and that would not be retained with the removal of the organization charts. The applicable regulatory requirements are those administrative controls that are necessary to ensure safe operation of the facility.
Therefore, those aspects of organization charts for Shearon Harris that were essential for conformance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organizations and (2) to Specification 6.2.2 to define qualification requirements of the unit staff.
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-2 By letter dated January 27, 1988, the staff issued Amendment No. 3 to Facility Operating License NFP-63 for the Shearon Harris Nuclear Power Plant that incorporated these changes to their TS. Subsequently the staff developed guidance on an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88-06 provided this guidance to all power reactors.
3.0 EVALUATION The licensee's proposed changes to its TS are in accordance with the guidance provided by Generic Letter 88-06 and addressed the items listed below.
(1) Specifications 6.2.1 and 6.2.3 were revised to delete the references to Figures 6.2-1 and 6.2-2 that were removed from the TS.
(2) Functional requirements of the offsite and onsite organizations were defined and added to Specification 6.2-1 and they are consistent with the guidance provided in Generic Letter 88-06. The specification notes that implementation of these requirements is documented in the FSAR and updated in accordance with 10 CFR 50.71(e).
(3) The organization chart for the unit staff does not stipulate senior reactor operator or reactor operator license qualified positions except for 3 control operators. Hence, this is not an applicable consideration related to the removal of the organization charts from the TS for the plant.
(4) Consistent with requirements to document the offsite and onsite organization relationships in the form of organization charts, the licensee has confirmed that this documentation currently exists in the FSAR.
(5) The licensee has confirmed that no specifications, other than those noted in item (1) above, include references to the figures of the organization charts that are being removed from TS for their plant.
Hence, this is not an applicable consideration, with regard to the need to redefine referenced requirements as a result of the removal of these figures.
On the basis of its review of the above items, the staff concludes that the licensee has provided an acceptable response to these items as addressed in the NRC guidance on removing organization charts from the administrative control requirements of the TS. Furthermore, the staff finds that these changes are consistent with the staff's generic finding on acceptability of such changes as noted in Generic Letter 88-06.
Accordingly, the staff finds the proposed changes to be acceptable.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment relates to changes in recordkeeping, or administrative procedures or requirements. Accordingly, the 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 these amendments.
5.0 CONCLUSION
The Commission made a proposed determination that this amendment involves no significant hazards consideration, which was published in the FEDERAL REGISTER (53 FR 24506) on June 29, 1988, and consulted with the State of South Carolina.
No public comments or requests for hearing were received, and the State of South Carolina did not have any comments.
The Staff has 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.
Principal Contributors:
Ronnie H. Lo, PDII-1 Thomas G. Dunning, OTSB Dated: November 3, 1988