ML17056A114
| ML17056A114 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/10/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17056A113 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 8907180456 | |
| Download: ML17056A114 (8) | |
Text
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF-NUCLEAR.REACTOR. REGULATION RELATED.TO-AMENDMENT.NO. %08 TO-FACILITY.OPERATING LICENSE NO. DPR-63 NIAGARA MOHAWK POWER CORPORATION NINE-MILE POINT NUCLEAR POWER. STATION UNIT NO. I DOCKET N0..50-220 INTRODUCTION By letters dated June 3, 1988 as amended September 28 and November 15, 1988, Niagara Mohawk Power Corporation (the licensee) proposed changes to -Technical Specifications (TS) 6.2.1, Offsite Organization, and 6.2.2, Unit Staff.
The proposed changes would remove Figure 6.2-1, Offsite Organization, and Figure 6.2-2, Unit Organization, and replace them with a narrative description of the offsite and onsite organizations functional requirements in TS 6.2.1 (and unit staff qualifications in 6.2.2).
Guidance for these proposed changes to the TS was provided to licensees and applicants bg'eneric Letter 88-06, dated March 22, 1988.
The proposed amendment would also add administrative changes to Sections 6.1., "Responsibility," 6.2, "Organization," 6.5, "Review and Audit," 6.6, "Reportable Event Action," and 6.7, "Safety Limit Violation."
Section 6.9, "Reporting Requirements,"
is being revised to make the Unit 2 Specifications consistent with 10 CFR 50.4.
Additional administrative changes are included in the amendment to reflect the creation of the Executive Vice President-Nuclear Operations position.
This title replaces all current references to Senior Vice President in the Specifications.
BACKGROUND Consistent with the guidance provided in the Standard Technical Specifications, Specifications 6.2.1 and 6.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are provided as figures to these sections.
On a plant specific
- basis, these organization charts have been provided by applicants and included in the TS issued with the operating license.
Subsequent restructuring of either the offsite or unit organizations, following the issuance of an operating license, has required licensees to submit a
license amendment for NRC approval to r eflect the desired changes in these organizations.
As a consequence, organizational changes have necessitated the need to request an amendment of the operating license.
Because of these limitations on organizational structure, the nuclear industry has highlighted this as an area for improvement in the TS.
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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 were 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 are 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.
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.
The Section 6.9, "Reporting Requirements,"
are changed to be consistent with the written communications requirements of 10 CFR 50.4.
e Creation of the position entitled, Executive Vice President-Nuclear Operations, requires administrative changes to the Nuclear Division Management Organization.
The changes involve replacing all r eferences to Senior Vice President in the Specifications with the new title.
The new position incorporates the authority and funct'ions formerly performed by the Senior Vice President.
EVALUATION The licensee's proposed changes to its TS addressed the items below and are in accordance with the guidance provided by Generic Letter 88-06.
(I)
Specifications 6.2.1 and 6.2.2 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 Final Safety Analysis Report (FSAR).
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(3)
The senior reactor operator and reactor operator license qualified positions, identified on the organization chart for the facility staff, were noted as being required by Specification 6.2.2.
Therefore, this requirement will be retained as a requirement following the removal of the organization chart for the unit staff.
(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 (I) 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 the acceptability of such changes as noted in Generic Letter 88-06.
Accordingly, the staff finds the proposed changes to be acceptable.
The change to Section 6.9, "Reporting Requirements,"
is an administrative revision, citing 10 CFR 50.4 for written communications requirements.
The licensee's proposal to replace the position and title of Senior Vice President, with'xecutive Vice President-Nuclear Operations is essentially only a title change to the Specifications.
On the basis of the staff's review, the proposed changes are acceptable.:
ENVIRONMENTAL CONSIDERATION This amendment involves a change in record keeping, or administrative procedures requirements.
The staff has determined that this amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.
Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec 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.
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CONCLUSION 1<e 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 these amendments will not be inimical to the common defense and security or to. the health and safety of the public.
Dated:
July 10, 1989 PRINCIPAL CONTRIBUTORS:
T,. Dunning V. McCree
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