ML20012E428
| ML20012E428 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/16/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20012E422 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 9004050115 | |
| Download: ML20012E428 (5) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION l
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e SAFETY EVAL,UATION BY THE_OFF1g 0F NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. InsTO FACILITY OPERATING LICENSE DPR-6 CONSUMERS POWER COMPANY DOCKET NO. 50-155 BIG ROCK POINTJUCLEAR PLANT 100 1_NT,R0_ DUCT 10N By letter dated September 8, 1988, and supplemented on April 12, 1989 Consumers Power Company (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, Plant Organization.
and replace them with a narrative description of the off-site and on-site crganizations' 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 liarch 22, 1988.
By letter dated February 6,1987, supplemented on July 23, 1987, September 21, 1988, and April 12 and December 21, 1989, the licensee requested an additional amendment to the TS for the Big Rock Point Plant. The proposed changes would make administrative and editorial corrections, capitalize defined terms consistent with the practice in the Standard Technical Specifications, correct references to the revised Code of Federal Regulations, delete the technical I
specification associated with environmental qualification of electrical l
Equipment, correct previous amendment omissions, and correct titles of senior l
on-site managers and other organizational elements.
2.0 FACKGROUND I
Consistent with the guidance provided in the Standard Technical Specifications, i
Specifications 6.2.1 and 6.2.2 of the administrative control requirements have I
referenced off-site and unit (on-site) organization charts that are provided as l
figures to these sections.
On a plant specific basis, these organization charts L
have been provided by applicants and included in the TS issued with the operating I
license. Subsequent restructuring of either the off-site or unit organizations, L
following the issuance of an operating license, has required licensees to submit l
a license amendment for NRC approval to reflect the desired changes in these organizations.
As a consequence, organizational changes have necessitated 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. The Shearon Harris licensee proposed changes to remove organization charts from its TS under the lead-plant concept that included the endorsen,ent of the proposed changes by the L
Westinghouse Owners Group.
In its review of the Shearon Harris proposal, the 9004050115 900316 g,DR ADOCK0500g5
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i staff concluded that most of the essential elements of off-site and on-site 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 t
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 off-site and on-site organizations, and (2) Specification 6.2.2 to define qualification requirements of the unit staff.
By letter cated 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.
300 EVALVATION 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) Specificatiens 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 off-site and on-site 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 FHSR, Quality (Assurance Program Description for Operational Nuclear Power Plants CPC-2A),NuclearOperationsDepartmentStandards(N005),or l
l Plant Administrative Procedures.
(3) The senior reactor operator and reactor operator license qualified positions of the unit staff were added to Specification 6.3.4 There-I fore, this requirement that was identified on the organization chart for the unit staff will be retained.
(4) Consistent with requirements to document the off-site and on-site organization relationshi)s in the form of organization charts, the licensee has confirmed t1at this documentation currently exists in the FHSR, Quality (Assurance Program Description for Operational NuclearCPC-1 l
Power Plants or Plant Administrative Procedures.
(5) The licensee has confirmed that no specifications, other than those noted in item (1) above, include references to the figures of the organization I
charts that are being removed from the 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.
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(6) The following defined terms have been capitalized to be consistent with the practice in the Standard Technical Specifications, where appropriate, on pages where other changes are made:
" SHUTDOWN, POWER OPERATION, CORE
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ALTERATION, MAJOR REFUELING, and DOSE EQUIVALENT."
(7) The neutron flux measuring instrumentation was changed in the 1988 refueling outage under Amendment 91.
Changing "CIC picoammeters" to
" power range monitor" corrects the terminology used in Section 7.3.2(e).
.Also Section 7.3.2(e) was clarified to allow for flexibility with the use of the power range monitors to show the overlap with the source range monitorstobeatleastonedegade.
This overlap will occur before the source range monitors reach 10 counts per second.
(8) Sections 4.1.2(c)1 and 4.1.2(c)2 referred to a " hot shutdown" condition.
This is not a defined term in the Big Rock Point Technical Specifications.
Therefore, it was changed to " shutdown" and refers back to the Definition Section 1.2.5.
(9) Sections 5.1.3(a) and 5.1.3(b) were changed to indicate the intent of the Specification that this applies to all control rod drives.
(10) Section 6.5.1.7 was changed to add the Plant Review Committee (PRC) using the routing process and will also be reviewing the Site Emergency Plan and its implementing procedures.
These will be in accordance with changes such as technical specification changes, tests or experiments, modifications, and procedure changes accomplished by the routing process approved by Amendment 71 dated December 10, 1984.
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(11) Section 10, subsection 6.13 under Administrative Controls was deleted because it was superseded and the license complies with 10 CFR 50.49.
i Section 6.10.2(k) was changed to indicate 10 CFR 50.49 instead of paragraph 6.13 which is being deleted.
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(12) Section 6.4.2(b) was corrected to refer to the proper reference under l
the Code of Federal Regulations, Section 70.24(a)(2).
(13) Section 9.3(b), and Section 12, Subsections 3.3.3.8(b), 3.7.11.1(a) and (c)(2), and 3.7.11.2(a) and (b) changed a reference from Section 6.9.4 to 6.9.3.
Section 6.9.3, "Special Reporta" is the proper reference.
Section 6.9.4 does not exist.
1 (14) Section 10, subsections 6.9.1, 6.9.1.6, and 6.9.3 of Administrative l
Controls were changed to reflect the current address for written l
correspondence to the NRC in accordance with 10 CFR 50.4.
t (15) Section 6.9.2.2.B. " Environmental Monitoring," was deleted.
This l
reflects an omission from Amendment 77 when the TS and Bases were l
changed to incorporate Radiological Effluent Technical Specifications l
(RETS) which meet the requirements of Appendix I to 10 CFR Part 50.
l (16) Section 11.3.1.4 and 11.4.1.4 were changed to reflect a change l
incorporated in Amendment 44 which approved t. 45 second diesel start time on Big Rock Point LOCA-ECCS analysis.
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1 4... (17) Section 13 Table 13.3-1, Items 3.a. b, and c had the word " isotopic" placed between the words "Garina" and " analysis" to provide the proper process identification. This is an editorial change missed in Amendment 77.
(18) Variousorganizationalmanagementtitleswerechangedtoreflect present site or Superintendent"ganizational status. For example, Plant was changed to
- Plant Manager.
(19) Section6.1.2modifiesthelastsentenceunderNote(1)because reporting requirements are included under 10 CFR 50.72 and 50.73.
This was an omission from Amendment 85.
(20) Section 6.1.2.3 modifies the second sentence to delete the reference to period recorders. This was inadvertently added under Amendment 91.
Period can be indicated but is not recorded.
(21) Several other editorial and typographical corrections were also mace on pages where other changes were proposed.
(22) Section11.4.5.3.A.1(h)waschangedtoaddthealternateshutdown battery to the capacity verification. Sections 11'.4.5.3. A.3(b) and (c) was modified to ref1tet that this is a weekly verification. Other editorialcorrectionsweremadetoSections11.4.5.3.A.3(b),(c)and.(d),
11.4.5.3.A.5 and to Section 12, subsection 3/4.7.13. These changes are purely administrative in nature. They were previously noticed but were inadvertently omitted when Amendment 97 was issued. Their inclusion in this amendment corrects the omissions.
Our review of the licensee's request shows that these changes were made (1)(3) for clarificationpurposes,(2)toindicatelicensee'sorganizatioralchanges.
tocorrectpreviousamendmentomissions,and(4)toreflectstandardtechnical specification 3ractices. The address for ccrrespondence was changed in I.
acenrdance wit 110 CFR 50.4 and Section 10 subsection 6.13 was deleted because I
the licensee complies with 10 CFR 50.49.
Also, the licensee has provided an I
ccceptable response to these items as addressed in the NRC guidance on removing organization charts from the administrative control requiren.ents of the TS.
Furthermore, the staff finds that these changes are consistent with the staff's t
gencric finding on the acceptability of such changes as noted in Generic Letter 88-06. Accordingly, the staff finds the proposed changes to be acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves changes in requirements with respect to the installa-l tion or use of a facility component located within the restricted area as l
L defined in 10 CFR Part 20. The staff has determined that the amendment l
involves no significant increase in the amounts, and no significant change in l
the types, of any effluents that may be released offsite and that there is no i
l significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this
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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 51.22(c)(9).
This amendment also involves changes in recordkeeping, reporting or administrative procedures or requirements.
Accordingly, with respect to these items, the amendment meets the eligibility criteria for categorical exclusion set forth 1
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the i
issuance of this amendment.
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5.0 CONCLUSION
We 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 operatiore in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
R. Pulsifer T. Dunning Dated: March 16, 1990 h
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