ML17342B191
| ML17342B191 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/19/1988 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17342B193 | List: |
| References | |
| L-88-85, NUDOCS 8802290060 | |
| Download: ML17342B191 (16) | |
Text
IS ACCESSION l4BR FAC IL: 50-250 50-251 AUTH. NAME MOODY'. O.
REC IP. NAME REGULA'.
Y INFORMATION DISTR IBUTIO YSTEM (RIDS) 8802290060 DOC. DATE: 88/02/19 NOTARIZED:
YES Turkey Point Planti Unit 3i Flor ida Power and Light 'C Turkey Point Planti Unit 4i Florida Power and Light C
AUTHOR AFFILIATION Florida Power 5 Light Co.
RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 0 05000250 05000251
SUBJECT:
Application for amends to Licenses DPR-31 5 DPR-41I revising Tech Specs bg deleting Figure
- 6. 2-1 8c 6. 2-2 of Section 6i Administrative Controls 0 replacing w/more general organizational requirements.
Fee paid DIBTRIBUTION CODE.
AOOID COPIEB RECEIVED LTR l
ENCL J SIZE.
TITLE:
OR Submittal:
General Distribution NOTES:
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FEBRUggc 1 9 I988 L-88-85 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Re:
Turkey Point Units 3 and 4 Dockets 50-250 and 50-25 I Proposed License Amendment Administrative Controls ln accordance with IO CFR 50.90, Florida Power & Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-3 I and DPR-4I, Turkey Point Units 3
and 4
Technical Specifications, be amended to revise Section 6,
Administrative Controls, by deleting Figure 6.2-1 and 6.2-2 and replacing them with more general organizational requirements, to reflect recent and proposed organization changes affecting the onsite and offsite organization, to revise the designation of the Chairman of the Company Nuclear Review Board, and to revise reporting requirements with respect to the Plant Nuclear Safety Committee.
lt has been determined that the proposed amendment does not involve a
significant hazards consideration pursuant to IO CFR 50.92.
A description of the amendment request and the basis for a no significant hazards consideration determination is provided in Attachment I.
The proposed revised technical specification changes are shown on the pages included in Attachment 2.
ln accordance with IO CFR 50.9l(b)(l), a copy of this proposed license amendment is being forwarded to the State Designee for the State of Florida.
In accordance with 10 CFR l70.I2(c), FPL Check No. 7393 for $ I50 is attached.
The proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.
8802290060 88 00250'DOcz 0>0 J( ( )(0 TCG4/024/ I an FPL Group company
4
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U. S. Nuclear Regulatory Commission L-88-85 Page two We request your approval of this proposed amendment as soon as possible, so that we can implement the organization changes described in our letter dated January IS, l988 (FPL letter L-88-23).
The Topical Quality Assurance Report will be revised to reflect the new organization prior to implementation of the Technical Specification changes.
These organization changes do not reduce the Quality Assurance Program commitments previously accepted by the NRC.
Very truly yours, C. O. W Executive Vice President COW/TCG/gp Attachment cc:
Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. Jacob Daniel Nash, Florida Dept. of Health and Rehabilitative Services TCG4/024/2
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STATE OF FLORIDA
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COUNTY OF PALM BEACH )
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That he is Executive Vice President of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and
- belief, and that he is authorized to execute the document on behalf of said Licensee.
C. O.
o y
Subscribed and sworn to before me this
/'P d1ay ofU
, 195.
NOTARY-PUBLlC, in and for the County of Palm Beach, State of Florida My Commission expires:
NOZARY PUBLIC Sl'AZE OF FLORIDA I(Y CONRISSIOR EXP SEPt l8,1909 80NOED ZNRU GENERAL Iks. uka.
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ATTACHMENT I DESCRIPTION OF AMENDMENTREQUEST AND BASIS FOR NO SIGNIFICANTHAZARDS CONSIDERATION DETERMINATION TCG4/024/3
Re:
Turkey Point Units 3 and 4 brackets 50-250 and 50-25I Proposed License Amendment Administrative Controls Descri tion of Admendment Re vest:
This proposed amendment revises TS 6.2.I and TS 6.2.2 by deleting Figures 6.2-l, "Off-site Organization for Facility Management and Technical Support," and 6.2-2, "Plant Organization Chart,"
and replacing them with more general organizational requirements, which reflect the significant organizational features now depicted in Figures 6.2-I and 6.2-2 for ensuring that the plant will be operated safely.
Organizational relationships and responsibilities will continue to be described in detail in the FPL Quality Assurance Program.
Appendix B to IO CFR 50 and IO CFR 50.54(a)(3) govern changes to the organization described in the Quality Assurance Program.
Changes to the quality assurance program description that reduce commitments previously accepted by the NRC require NRC approval prior to implementation.
Deletion of these figures will eliminate the need to process license amendment requests for changes in the onsite or offsite organizations which are administrative.
TS 6.2-2, "Facility Staff," was revised by adding the requirement that the-Operations Supervisor hold a Senior Reactor Operator s License.
The requirement currently in Figure 6.2-2 that the Operation Superintendent hold an active NRC Senior Operator (SRO) License is not included.
T.S. Section 6.3.l, "Facility Staff Qualifications" requires that each member of the facilitystaff meet or exceed the minimum qualifications of ANSI NI3. I-I97I. This standard states that at the time of appointment, the "Operations Manager" hold an SRO license.
The Operations Superintendent is a senior manager at the plant who is responsible for operations, chemistry, reactor engineering and health physics.
The direct supervision of operations activities is the responsibility of the Operations Supervisor who will continue to hold an active NRC SRO License.
Deleting the license requirement for the Operations Superintendent will not be contrary to the requirements of Technical Specification 6.3.l which references the qualifications of ANSI NI8.I-197l (selection and training of nuclear power plant personnel).
At FPL's other licensed reactors, the ANSI requirement is met by the Operations Supervisor, and the Technical Specifications do not require the Operations Superintendent to hold an active SRO license.
The original Turkey Point FSAR (Rev. 23) included a requirement for the position entitled "Assistant Plant Superintendent Operations" to hold an SRO license.
This was the highest position on the organization chart requiring an SRO license.
This position no longer exists, however, this individual was shown on the chart as the direct supervisor of the "Plant Supervisors."
Our proposal for the Operations Supervisor to be the highest position in the operations organization requiring an SRO license is consistent with this original organization chart because he is the direct supervisor of the Plant
'Supervisors-Nuclear.
TCG4/024/4
I
FPL had requested relief from this requirement by letter L-87-48 I dated November l8, l987 to allow an individual who held an SRO license at FPL's St.
Lucie Plant, but not the Turkey Point Plant, to assume the duties of Operations Superintendent.
Discretionary enforcement from the T.S.
Figure 6.2-2 requirement was granted by the NRC in a letter dated January l5, l 988, until the individual receives a current Turkey Point SRO
- license, or until the T.S.
is changed to delete the requirement.
References to the "Vice President-Nuclear Operations" and/or "Group Vice President-Nuclear Energy" in T.S. 6.5. I.6.e, 6.5. I.7.e, 6.5. I.8, 6.6. I.b, 6.7. I.b, and 6.7.l.d are changed to "senior corporate nuclear officer".
The proposed changes are consistent with the intent of the current T.S. regarding level of reporting and are consistent with the changes to T.S. 6.2. I.
T.S. 6.5.I.7.c is revised to require written notification "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" vs.
"immediately".
This is consistent with the Standard Technical Specifications for Westinghouse Pressurized Water Reactors, and will allow time for a written report to be prepared.
The CNRB composition specified in T.S. 6.5.2.2 is revised to delete "Chairman:
Group Vice President-Nuclear Energy" and add the "Senior Vice President-Nuclear" as a member to reflect a position title change.
To be consistent with the St.
Lucie Plant Technical Specifications, approved by the NRC Staff, the Chairman will nof be specified.
T.S. 6.5.2.2 is modified to require only that the Chairman be a member of the CNRB and that he be specified in writing. Also, "Senior Project Manager-Power Plant Engineering" is replaced by "Manager-Power Plant Engineering".
This engineering department membership change provides an equivalent level of engineering expertise and experience to the CNRB.
Basis for No Si nificant Hazards Consideration Determination:
The Commission has provided standards for determining whether a significant hazards consideration exists (IO CFR 50.92(c)).
A proposed amendment to an operating license for the facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
(I) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
TCG4/024/5
Operation of Turkey Point Units 3 and 4
in accordance with the proposed amendments would not:
(I) & (2)
Involve a significant increase in the probability or consequences of an accident previously evaluated, or create the possibility of a new or different kind of accident than previously evaluated.
This change in administrative in nature, and does not involve a change in the operation, the physical configuration of the power plant, or affect the accident analysis.
(3)
Involve a significant reduction in a margin of safety.
Deletion of Figures 6.2-I and 6.2-2 and the other the organization changes discussed above will not decrease the effectiveness of the onsite and offsite organization to manage the Turkey Point Plant or provide technical support to ensure continued safe operation.
The NRC will continue to be informed of organizational changes through other required controls.
The Quality Assurance Program provides detailed descriptions of organization and responsibilities and detailed organization changes.
Changes to the Quality Assurance Program description that reduce commitments previously accepted by the NRC require NRC approval prior to implementation.
FPL will-continue to inform the NRC of organization changes affecting its nuclear facilities.
The proposed change deleting the requirement that the Operations Sueperintendent hold an SRO is consistent with the requirements of T.S.
6.3. I.
P lant supervisors are directly supervised by the Operations Supervisor who meets the quali fications of the "Operations Manager" in ANSI Standard NI8. I I 97 I.
Therefore, not including the SRO requirement for the Operations Superintendent will not impact safe plant operation.
The changes from "Vice President-Nuclear Operation," and/or "Group Vice President-Nuclear Energy" to "senior corporate nuclear officer" and the changes relating to the CNRB are administrative and do not affect plant operation.
The increase in time allowed to provide written notification (T.S.
6.5.1.7.c) regarding disagreement between the PNSC and the Plant Manager-Nuclear is consistent with industry practice and allows time for a written report to be prepared.
Since the Plant Manager is responsible for resolving such disagreements, and also for safe operation of the plant, no decrease in any margin in safety will result.
Therefore, operation of the facility in accordance with the proposed amendment would pose no threat to the public health and safety, and would not involve a significant hazards consideration.
TCG4/024/6