ML20076C701
| ML20076C701 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/17/1991 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-91-067, CON-NRC-91-67 VPNPD-91-232, NUDOCS 9107230412 | |
| Download: ML20076C701 (2) | |
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Wisconsin Electnc POMR COMPANY w s owyr, m n. m t,ww.v u w mv.w VPNPD 2 32 NRC 0 67 July 17, 1991 Document Control Desk U.
S.
NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:
DQCEri[S 50-266 AND.50-301 TECHNICAL SPECIFICnTION CllANGE REOUEST 120 ETAFF ORGANIZATION CHANGES AND DELETION OF ORGANIZATlQN QJ1ARTIi POINT BEACil NUCLEAR PLANT, UNITS 1 AND 2 In a letter dated August 1, 1909, and subsequently modified by letter dated March 29, 1990, Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, requested license amendments to document changes to the staff organization and to l
permit removal of the staff organization charts from the technical specifications as permitted by the NRC guidance in Generic Letter 88-06.
During a telephone cal. on June 27, 1991, Mr. Robert Samworth, the NRC NRR Project Manager for the Point Beach Plan *;,
discussed with Mr. Charles Krause of my staff two additions tro NRC staff intends to make concerning this change request.
The first of those additions concerns our proposed specification 15.6.2.1.a which roads:
"The organizations for facility management and technical support are provided in the Point Beach Nuclear Plant Final Safety Analysis Report."
Mr. Samworth has proposed that this paragraph be replaced by paragraph 6.2.1.a from enclosure 2 to the staff Generic Letter 88-06 dated March 22, 1988 which reads:
" Lines of authority, responsibility, and c.,mmunication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions.
These role.cionships shall be documented and updated, as appropriate, in the form of organizat. ion charts, functional descriptions of departmental l
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Documont Control Dock July 17, 1991 Pago 2 responsibilities and relationships, and job descriptions for key. personnel positions or in equivalsnt forms of documentation.
Those requiremonto shall be documented in the Final Safety Analysis Report or plant proceduros."
We have discussed this addition to our proposed specification internally and have no objection to this HRC revision.
The second concern discussed with Mr. samworth involved our proposed deletion of Figurou 15.6.2-3 and 15.6.2-4 which address the firo protection organization.
As discussed on pago 3 of our August 1, 1989 letter, we proposed deletion of thoso figurou because the ossential olomonts of the fire brigado organization are contained in specification 15.6.2.2.f, and the fire protection organization and fire brigado organization charts are contained in the Point Beach " Administrative Control Policios and Procedures Manual" in proceduro PBNP 1.7.5.
Mr Samworth indicated that it was his intention to includo a statomont which references this proceduro directly in specification 15.6.2.2.f.
We are concerned that a reference to the organization charts being documented in a specific proceduro, PUNP 1.7.5, could necessitato a future technical specification revision if the specific referenco changed.
Accordingly, we believe a general reference to plant proceduros, similar to the treatmont discussed in the first item addressed in this lotter, is more appropriato.
Wo would have no objections to the NRC including such wording in the Technical Specification.
Very truly yours,
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by 0 f,'
C.' W. Fay Vice President Nuclear Power Copy to:
NRC Resident Inspector NRC Regional Administrator l
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