ML18016A616

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Safety Evaluation Supporting Amend 83 to License NPF-63
ML18016A616
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 10/07/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML18016A615 List:
References
NUDOCS 9810090390
Download: ML18016A616 (6)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON< D.C. 2055&0001 S

FETY EVALUATI B

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EAR A R KET 05 A 1.0 D

By "HNP-97-100, Application for Amend to License NPF-63,amending TS 6.0, Administrative Controls, TS 6.2.2.e & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid..f|letter dated June 12, 1997]], as supplemented by letter dated August 27, 1998, Carolina Power and Light Company (CP8L, the licensee) submitted to the NRC a proposed revision to the Harris Nuclear Plant (HNP) Technical Specification (TS) 6.0, "Administrative Controls."

Speciflically, this amendment revises TS 6.2.2.e by designating an off-shift Operations superintendent with a senior reactor operating (SRO) license as the supervisor of shift work and licensing activities when the Manager - Operations does not hold an SRO license.

Previously, TS 6.2.2.e required the Operations Supervisor to hold an SRO license ifthe Manager-Operations did not hold an SRO license.

This amendment also revises other sections of TS 6.0, "Administrative Controls," to reflect recent title changes. The August 27, 1998, supplemental letter provided clarifying information only, and did not change the initial no significant hazards consideration determination.

2.

The staff evaluated the licensee's submittal of June 12, 1997, as supplemented by letter dated August 27, 1998, against the relevant criteria in NUREG-0800, "Standard Review Plan" Section 13.1.1, "Management and Technical Support Organization," and Section 13.1.2-13.1.3, "Operating Organization," and the applicable American National Standards Institute (ANSI)/ANS standards.

The licensee proposed to revise their commitment to the ANSI requirements contained in TS 6.4 and section 1.8 of the Final Safety Analysis Report (FSAR) by revising its exception for the position of Manager - Operations.

CP8L's commitment to ANSI 3.1 (September 1979 draft) requires the Operations Manager (fulfilledby the position of Manager - Operations at HNP) to hold an SRO license at the time of appointment to the active position. Amendment 9 to the HNP operating license, dated March 2, 1989, granted an exception for the position of Manager-Operations.

The exception allows the Manager - Operations to either (1) hold an SRO license or (2) have held an SRO license provided the Operations Supervisor (an Operations middle manager) holds an SRO license.

As result of organization'al changes, the Operations Supervisor position no longer exists. Therefore, CP8L proposes to revise its exception to better reflect the HNP's Operations organizational structure.

The revised exception would allow the Manager - Operations, in lieu of meeting the ANSI 3.1 (September 1979 draft) requirement of holding an SRO license, to (1) hold an SRO license at the time of appointment, or (2) have held an SRO license provided an off-shift Operations superintendent who reports directly to the Manager - Operations holds an SRO license.

The off-shift Operations superintendent would then supervise shift work and licensed activities. This approach is supported by ANSI/ANS 98i0090390 98i00T PDR ADOCK 05000400 P

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II 3.1-1987 and 3.1-1993, "American National Standard for Selection, Qualification, and Training of Personnel for Nuclear Power Plants," which allow individuals to be appointed to the position of Operations Manager based on the options proposed by HNP.

The licensee proposed change to TS 6.2.2.e ensures that the position responsible for supervising shift work and licensed activities is in the direct chain-of-command of the Operations organization.

The licensee has described the position as off-shift and requiring an SRO license.

The Operations superintendent reports directly to the Manager - Operations and willhave the on-shift supervisors as direct reports.

10 CFR Part 50.54(l) requires that the individuals designated by a licensee to direct the licensed activities of licensed operators shall be licensed as a senior operator.

Based on a review of the licensee's submittal, the proposed change continues to meet this requirement by ensuring the Operations management personnel directing the activities of licensed operators maintain the appropriate qualification.

The staff concludes that specification 6.2.2.e, requiring that either the Manager - Operations or an off-shift Operations superintendent hold an SRO license is consistent with the requirements of 10 CFR 50.54(l) and ensures that a licensed off-shift senior operator willdirect the licensed activities of the licensed ope'rators.

Further, the requirement that an Operations Middle Manager (Operations superintendent) hold an SRO license when the Manager - Operations does not hold an SRO license is consistent with the requirements of ANSI 3.1- (September 1979 draft) and ensures there is site-specific detailed relevant technical and systems knowledge in a senior operations management position.

The licensee's submittal also proposed to revise TS section 6.0 to reflect title changes.

Specifically, CP8 L proposed to change (1)'the title Shift Foreman" to "shift-superintendent operations (S-SO)," and (2) the title "Vice President - Harris Nuclear Project" to "Vice President - Harris Nuclear Plant." These changes are administrative, in that the positions maintain the same responsibilities.

The staff concludes that the proposed modifications to the HNP Technical Specifications described above are consistent with and meet the intent of the relevant review criteria and are, therefore, acceptable.

3.0 STATE C N

LT 0

In accordance with the Commission's regulations, the State of North Carolina officialwas notified of the proposed issuance of the amendment.

The State official had no comments.

4.0 V

EN L CONSIDERAT 0 This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements.

Accordingly, this amendment meets the eligibilitycriteria 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.

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5.0 L

I The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public willnot be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments willnot be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: S. Flanders Date:

October 7, 1998,

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