ML20083D689

Application for Amend to Licenses DPR-57 & NPF-5,changing Tech Specs & ETS to Clarify Organizational Changes & Shift Staffing to Meet NUREG-0737 Levels

ML20083D689
Person / Time
Site:	Hatch
Issue date:	12/20/1983
From:	Head G GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20083D690	List: ML20083D689 ML20083D696
References
RTR-NUREG-0737, RTR-NUREG-737 NED-83-595, TAC-49076, TAC-49077, NUDOCS 8312280210
Download: ML20083D689 (5)

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Georg:a Power Company 313 Pedmont Avenuo I -

% Avantai Georg:a 30308 T& phone 404 526-7893 -

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. Madng Address Post Omce Box 4545 AManta Georg.a 30302 G.F. Head

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sena vice Prescem NED-83-595 per Gene *>"

Decenber 20, 1983 Director or Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing 1U. S. Nuclear Regulatory Conunission Washington, D. C. 20555 NRC D00GTPS,50-321, 50-366 OPERATIIG LICENSES DPR-57, NPF-5 ENIN I. HA'ICH NUCIEAR PLANP UNITS 1, 2 CLARIFICATIN OF 01GANIZATIONAL CHAfGES Gentlemen:

Pursuant to 10 CFR 50.90, as required by 10 CFR 50.59(c) (1), Georgia Power Conpany (GPC) hereby proposes changes to Appendices A (Technical Specifications) and B (Environmental Technical Specifications) to Operating Licenses DPR-57 and NPF-5 to clarify previous subnittals. For sinplicity and canpleteness, GPC has combined the previous subnittals ir.to one package of ' proposed changed pages for administrative changes in the Technical Specifications and the Environmental Technical Specifications (ETS). The proposed charges update our submittals of: June 11,1982 (changes in shift manning to meet NUREG 0737 levels), July. 9,1982 (organizational changes),

October 15, 1982 (corrected errors in the shift manning submittal), March 31,1983 (changes audit requirements of Emergency and Security Plans), April 22, 1983 ('IMI Action Plan Items), October 6, 1983 (Radiological Effluent Tedinical Specifications), October 24, 1983 (organizational changes), and

October 27,1983 '(mechanical snubbers) .

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The pages for- the Radiological Effluent Technical Specifications (RETS) subnittal (Attachment 5) assume the approval of all proposed changes to the Technical Specifications and ETS in Attachments 2 thru 4. The proposed

changes for IETS (Attachment 5) also reflect the organizational changes.

Since there is a shift in philosophy between the bases of the current Technical Specifications and RETS, the changed pages for RETS are not, and should not be, identical to those in Attachments 2 thru 4 . It was GPC's g intention in the RETIS submittal to incorporate all outstanding

adninistrative changes. This was not done. It should be noted that the 4.

RETIS subnittal used a cannon administrative section for both Units.

Therefore, there is only one set of insertion instructions for Appendix A Technical Specifications for RETS. Since this subnittal is a revision to previous submittals, there is no fee remittance required.

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Geor laPower d Director of Nuclear Reactor Regulation Attention: Mr. John Stolz, Chief Operatirg Reactors Branch No. 4 December 20, 1983 Page Two The proposed charges to tha Technical Specifications are administrative in nature. 'Ihe changes are briefly sunmarized below. For further details see the original submittal packages.

1. In all Attachments, changes to the onsite organization are reflected in revised Figure 6.2.2-1 of the Technical Specifications. There have been changes of titles throughout the organization and the respective Specifications have been revised to reflect the new titles. One of the sources of confusion, which we are attenpting to rectify by this subnittal, is due to inconsistencies between the October 6, 1983, and the October 24, 1983, submittals.

2. In all Attachments, offsite promotions, new positions, and title charges have made necessary additional charges to the Technical Specifications to reflect the organization which exists. These include: Executive Vice President-Power Supply, Manager-Nuclear Engineering and Chief Nuclear Ergineer, and General Manager QA and Radiological Health and Safety. As before, the October 6, 1983, and the October 24, 1983, submittals did not consistently change all of the titles to their respective new designation.

3. In Attachment 5, addition of administrative limits on overtime as required by NUREG 0737 was not included in the REIS Submittal.

4. In Attachment 5, chages in shift manning levels, as required by NUREG 0737, were not included in the RETS Sutmittal.

5. In Attachment 5, changes in the audit requirements of the Emergency Plan and Security Plan were not totally incorporated. The change in frequency was included in the RETS sutmittal but not the restrictions on personnel.

6. Change, for RETS only, the audit frequerry of the Operational Quality Assurance Program to the frequency specified in existing Technical Specifications. Through an administrative error the frequency was incorrectly listed as annually in the October 6,1983 subnittal.

7. In Attachment 5, requirements fcr documentation of challenges to, and failure or malfunction of safety / relief valves were not included in the RE"Is subnittal.

8. In Attachment 5, charges in the documentation requirement for Type B and Type C Leakage Tests were not included in the RETS Subtittal.

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Ge'orgia Power A

, Director of Nuclear Reactor Regulation

. Attention: Mr. John Stolz, Chiel Operating Reactors Branch No. 4

' December 20, 1983

- Page % ree

9. In Attachment 5, requirements on the service life of hydraulic and mechanical snubbers were not included in the RETS Submittal.

'10. In Attachments 2 and 3,. the effective dates of the NPDES Permit were not included in the October 24, 1983 sutnittal.

11. In Attachments 4 and 5, correct one typographical error, "or" to L "of", in the Environmental hchnical Specifications Section 5.5.2 of RETS and.Section 5.6.2 of the existing Ers. %ese are the same l specification, but have different section ntabers due to the

, deletions made necessary by the moving of a large portion of ETS to

! Appendix 'A' in the RETS package.

The Plant Review Board and Safety Review Board have reviewed the proposed changes and determined, pursuant to 10 CFR 50.59, that they do not constitute an unreviewed safety question. All changes are administrative in

, nature. No plant systems are affected. Neither the probability of, nor the j consequences of, analyzed accidents is affected. No new types of accidents are created. Margins of safety are unaffected. The intent of the revised i organization is to strengthen management through the formation of new positions for well gaalified personnel. The changes are expected to result in an overall increase in plant safety through greater management l attention.- he charges in reporting requirements are expected to increase l attention to safety by all personnel.

Pursuant to the requirements of 10 CPR 50.92, J. L. Ledbetter of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments. %e Significant Hazards analysis for the l- proposed changes is included as Attachment 1 to this letter.

G. F. Head states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set fcrth in this letter are true.

1 GE0fGIA POWER COMPANY By: , P. /

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G. F. Head Sworn to and subscribed before me this 20th day of December, 1983.

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I, e GeoigiaPower sh Director of Nuclear Reactor Regulation Attention: Mr. John Stolz, Chief Operatirs Reactors Branch No. 4 December 20, 1983 Page Four MJB

Enclosures:

1. Determination of No Significant Hazards

2. Instructions for Incorporation, Unit 1 Appendix A -

3. Instructions for Incorporation, Unit 2 Appendix A

4. Instructions for Incorporation, Units 1 and 2 Appendix B

5. Instructions for Incorporation, Radiological Effluent Technical Specifications (RE:TS), Units 1 and 2 xc: H. C. Nix, Jr.

Senior Resident Inspector, Plant Hatch J. P. O'Reilly, (NIC-Region II)

J. L. Ledbetter (DNR) l l

ATTICHMENP 1 NBC DOCKETS 50-321, 50-366 OPERATDG LICENSES DPR-57, NPF-5 EDhTIN I. HATCH NUCLEAR PIANT UNITS 1 AND 2 PROPOSED CIWGES TO TECHNICAL SPECIFICATIONS Pursuant to the standards of 10 CFR 50.92, Georgia Power Company has evaluated the proposed changes and determined that no significant hazards are involved. This change is administrative in nature and has no effect on accident probabilities or consequences. No new types of accidents are created. The margin of safety is unaffected.

Each of the requested changes is consistent with item (i) of " Examples of amendments that are considered not likely to involve significant hazards considerations" as published in the Federal Register, April 6, 1983, page 14870, as each change is administrative in nature.