ML17291A842

Application for Amend to License NPF-21,changing TS 6.0, Administrative Controls by Revising Assistant Managing Director,Operations & Plant Manager Position Titles

ML17291A842
Person / Time
Site:	Columbia
Issue date:	06/06/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17291A843	List: ML17291A842 ML17291A844
References
GO2-95-106, NUDOCS 9506140372
Download: ML17291A842 (10)

Text

I RIDRITY CELE RATE D Rl DS P ROCESSli G) 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9506140372 DOC.DATE: 95/06/06 NOTARIZED: YES DOCKET I FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to license NPF-2l,changing TS 6.0, "Administrative Controls" by revising Assistant Managing TITLE:

NOTES OR Director, Operations & Plant Manager position titles.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR Submittal: General Distribution j ENCL I SIZE: 7 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR' ENCL PD4-2 LA 1 1 PD4-2 PD 1 CLIFFORD,J 1 1 INTERNAL: ACRS 6 '

CEKTE Ol 1 1 NRR/DE/EMCB 1 1 /DRCH7HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 YO'I'E TO ALL"RIDS" RECIPI EYTS:

PLEASE HELP US TO REDUCE KVASTE1 COYTACT'I'IIE DOCL'ifEYTCONTROL DESK, ROONI Pi.37 IE>;T. 504.0083 I TO FLIXIINATEYOL'R i'AifLFROif DISTRIBUTIOYLIS'I'S I'OR DOCL'b,f Ei'I'S YOI 'ON" I YLTI'.I)!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 17

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Q vi WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 993S2-0968 ~ (509) 372-$ 000 June 6, 1995 G02-95-106 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPF-21, REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS In accordance with Code of Federal Regulations (CFR), Title 10 Parts 50.90 and 2.101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications.

The proposed amendment will change Technical Specification 6.0, "Administrative Controls",

by (a) revising the Assistant Managing Director, Operations and Plant Manager position titles to reflect recent title changes, (b) replacing the position titles of the Plant Operations Committee (POC) membership with the functional areas represented in the POC, (c) removing the Plant Manager from the position of POC Chairman, and (d) making a minor editorial correction.

This Technical Specification amendment request contains three attachments. Attachment 1 provides a discussion and the justification for the proposed changes. Attachment 2 describes the Supply System's evaluation of the proposed changes performed in accordance with 10 CFR 50.92(c). Attachment 3 includes the Technical Specification affected pages with the proposed changes indicated.

This Technical Specification amendment request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.

In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.

950b140372 950bOb PDR ADOCK 05000397 p PDR

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Page 2 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Should you have any questions or desire additional information, please call me or D.A. Swank at (509) 377-4563.

Sincerely

. V. Parrish (Mail Drop 1023)

Vice-President, Nuclear Operations JMP Attachments CC: LJ Callan, NRC-RIV KE Perkins, Jr., NRC-RIV, Walnut Creek Field Office

'JW Clifford - NRC NS Reynolds, Winston 8c Strawn NRC Sr. Resident Inspector (Mail Drop 927N)

DL Williams, BPA (Mail Drop 399)

FS Adair - EFSEC

REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Attachment 1 Page 1 of 3 DISCUSSION OF AND JUSTIFICATION FOR THE PROPOSED CHANGES The Supply System proposes to revise Technical Specifications (TS) Section 6.0, "Administrative Controls" for WNP-2. The proposed changes will (a) reflect Supply System titles for senior management throughout Section 6.0, (b) modify the Plant Operations Committee (POC) composition to specify members according to functional areas rather than by organizational titles, and (c) replace the Plant Manager as the POC Chairman with an individual appointed by the Plant General Manager, and (d) make an editorial correction.

Descri tion of Chan es

1. Where the titles of Plant Manger, Assistant Managing Director for Operations, and .

Assistant Managing Director, Operations, appear in TS 6.0, the following changes are proposed:

"Assistant Managing Director for Operations" is changed to "Vice-President, Nuclear Operations" "Assistant Managing Director, Operations" is changed to "Vice-President, Nuclear Operations" "Plant Manager" is changed to "Plant General Manager"

2. TS 6.4.1 is changed by deleting the reference to "Appendix A" of 10 CFR Part 55.

3. TS 6.5.1.2 is modified to specify the Plant Operations Committee (POC) composition in terms of the following plant functional areas rather than by designating members by organizational titles:

Operations Administration arid Records Management Maintenance Radiation Protection Engineering Technical Services Quality Chemistry Planning/Scheduling/Outage The proposed change would require the Plant General Manager appoint, in writing, the POC chairman, Vice Chairman, and individual members from the designated functional areas.

REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Attachment 1 Page 2 of 3 Justificati n for TS Chan es The proposed senior management organizational title changes result from a reorganization of the Supply System's Operations Directorate. The title changes are administrative in nature and do not involve a change in position responsibilities.

TS 6,4.1 requires, in part, a retraining and replacement training program for the unit staff to meet or exceed the requirements and recommendations of Appendix A of 10 CFR 55. The Appendix no longer exists and its contents have been incorporated into the body of 10 CFR 55.59(c).

TS 6.5.1.2 defines the POC composition and designates POC members by specific organizational titles. The proposed TS change will delete the position titles and replace them with the functional areas to be represented in the POC. The POC serves as a multi-disciplinary review and advisory organization to the Plant Manager on matters related to nuclear and radiological safety. The proposed method of designating POC composition will provide the Plant General Manager with the flexibilityto appoint qualified individuals from disciplines within a functional area. This flexibility will strengthen the POC multi-disciplinary review and advisory responsibilities. 'The POC composition change willalso alleviate the need to process TS changes for future organizational changes involving organizational position titles, while maintaining the requirement for an multi-disciplinary POC membership.

The replacement of the Plant Manager as the POC Chairman by the proposed change will not impact the ability of the POC to execute its review and advisory responsibilities. The POC will continue to be tasked with the responsibility of recommending to the Plant General Manager approval or disapproval of TS specified items prior to their implementation. Final approval for the implementation of these items was and will continue to be the responsibility of the Plant General Manager. The proposed change to TS 6.5.1.2 establishes that the Plant General Manager will appoint, in writing, the POC Chairman, Vice Chairman, and individual members from each of the designated functional areas. POC member and alternate qualifications will continue to meet or exceed the qualification requirements of TS 6.3.1 for those individuals who fillorganizational positions considered part of the unit staff in TS 6.3. Those designated POC members and alternates not considered part of the unit staff will continue to be required to possess skills and knowledge commensurate with their organizational positions. This will ensure the POC will continue to be staffed by qualified personnel having a variety of expertise and experience.

Changes similar to those proposed for the POC composition in TS 6.5.1.2 were found acceptable by the NRC and approved in Amendment 107 for the Kewaunee Station, Amendment 101 for the Fermi 2 Station, and in Amendments 126 and 65 for St. Lucie Plants 1 and 2.

REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Attachment 1 Page 3 of 3 The proposed changes will not modify the functions, responsibilities, or authority of the POC, Plant General Manager, or Vice-President, Nuclear Operations. Based on the above discussion the Supply System considers the proposed changes to be acceptable.

REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Attachment 2 Page 1 of 2 EVALVATIONOF SIGNIFICANT HAZARDS CONSIDERATION In accordance with the'criteria for defining a significant hazards consideration established in 10 CFR 50.92, the Supply System has evaluated the proposed amendment to WNP-2 Technical Specification (TS) Section 6.0. This evaluation has determined that operation of the facility in accordance with the proposed amendment does not represent a significant hazards consideration.

The following discussion is provided in support of this conclusion, Does the change involve a significant increase in the probability or consequences of an accident previously evaluated'I The senior management title changes are title changes only and will not impact the plant safety responsibilities associated with these positions. The removal of the Plant Operations Committee (POC) organizational titles and replacement with functional areas, and the elimination of the Plant Manager as the POC Chairman, will not impact the POC function because membership qualifications will continue to be consistent with the unit staff qualifications in TS 6.3.1 for those POC members and alternates considered part of the unit staff. Those designated POC members and alternates not considered part of the unit staff will possess skills and knowledge commensurate with their organizational positions.

The proposed change ensures that POC will continue to be comprised of personnel who are experienced, have varied expertise, and are involved in daily plant activities. In maintaining the qualification requirements for members of POC, the POC will continue to fulfillits review and advisory responsibilities specified in TS 6.5.1.6 and TS 6.5.1.7.

The proposed changes do not involve any physical changes to plant systems, structures, or components (SSC) or the manner in which the SSC are operated, maintained, modified, tested, or inspected. The changes therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

Because the proposed changes are of an organizational nature and their implementation does not involve physical changes to the plant SSC or the manner in which the SSC are operated and maintained, the proposed changes do not create the possibility of a new or different kind of accident. The proposed changes do not introduce any new modes of operation or alter system setpoints which could create a new or different kind of accident.

Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created.

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REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS SECTION 6.0 ADMINISTRATIVECONTROLS Attachment 2 Page 2 of 2

3. Does the change involve a significant reduction in a margin of safety?

The senior management title changes do not impact the management responsibilities or functions associated with ensuring plant safety. Changes proposed in the POC composition will allow the scope of available expertise to be expanded without changing the POC function or responsibilities. Maintaining the current level of personnel qualifications and experience ensures the POC will continue to meet its TS review and advisory requirements. The proposed changes will not impact the basis for any Technical Specification related to the establishment of, or maintenance of, nuclear safety margins.

Therefore, operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin of safety.

Envir nmental C nside tions As discussed in the Significant Hazards Consideration, the proposed changes described in were concluded not to involve a significant, hazards consideration. Consequently, the proposed changes meet the eligibility criteria for a categorical exclusion as set forth in 10 CFR 51,22(c)(9). Therefore, in accordance with 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.