ML20101G016

Application for Amend to License NPF-42,revising TS Sections 6.0 Re Administrative Controls & 3.3 Re Instrumentation to Clarify Approval Process for Plant Procedures & Make Editorial Changes

ML20101G016
Person / Time
Site:	Wolf Creek
Issue date:	06/19/1992
From:	Rhodes F WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101G018	List: ML20101G016 ML20101G020
References
ET-92-0121, ET-92-121, NUDOCS 9206250262
Download: ML20101G016 (10)

Text

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l WRxLF CREEK

.l NUCLEAR OPERATING CORPORATION -

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Forrest T. Rhodes

! Vice President

j. Engineenno & Technicd! Services l . June 19, 1992 ET 92-0121 i-

} U. S. Nuclear Regulatory Commission l_ ATTN: Document Control Desk i Mail Station F1-137 j Washington, D. C. 20555

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Subject:

Docket No. 50-482:. _

Revision to Technical Specification.

. Sections 6.0, Administrative Controls and, 3.3, l

Instrumentation

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i Gentlemen:

f f_ The purpose of this letter is to trensmit an application for' amendment to

} Facility Operating License No,' NPF-42 for Wolf Creek Generating _ Station -

j (WCGS), Unit No. 1. This license amendment request proposes-revising l Technical Specificatien Sections 6,5.1.'2 and 6.8.3 to reflect miscellaneous changes to the WCGS organization and_ position titles, and clarify the i approval process for plant procedures. .An editorial change to Section 3.3.3 j is-also included.

l Attachment ,I provides a description of the amendment along with a Safety l Evaluation. Attachment II provides the Significant Hazards Consideration l Determination. Attachment III provides the. Environmental . Impact l Determination. The proposed changes to =t.ae technical- specifications is i provided as Attachment IV.

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In accordance with 10 CFR 50.91, a copy of this application. with j attachments, is being provided to the designated Kansas State official.

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ET 9'2-0121

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j If you have any questions concerning this matter, please contact me or l Mt. S. G. Wideman of my staff.

, Very truly yours, h'/ y' 4

i Forrest T. Rhodes j 'Vice-President Engineering & Technical Services l

FTR/mes j Attachments: I - Safety Evaluation l II - Significant Hazards Consideration' Determination

, III - Environmental Impact Determination 3 IV - Proposed Technical Specification _ Change I-i ect G. W. Allen (KDHE), w/a l A. T. Howell (NRC), w/a

!- R. D. Martin (NRC), w/a l- G. A. Pick (NRC), w/a l W. D. Reckley (NRC), w/a 4

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4 STATE OF KANSAS )

) SS COUNTY OF COFFET )

Forrest T. Rhodes, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering and Technical Services of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the content thereof that he has executed chat same for and on behalf of said Corporation with full power and authority to do so; and that the E

facts therein stated are true and correct to the best'of his knowledge, information and belief.

Q By I s Forrest T. Rhodes Vice President Engineering & Technical Services SUBSCRIBPD and sworn to before me this /f day of , 1992.

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Attachment I to ET 92-0121 Page 1 of 3 g

ATTACIMENT I SATETY EVALUATION

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m Attachment I to ET 92-0121 Page 2 of 3 Safety Evaluation Proposed Change i F

The purpose of the proposed Technical Specification change is to revise Section 6.8 to clarify the approval process for plant procedures. The current wording could be misinterpreted to require organizations besides Operations to attain the Shift Supervisor's approval for changes to plant procedures, increasing the administrative burden on the Shift Supervisor. An editorial correction-- to Section 3.3 is also, proposed which corrects references to Technical Specifications which were moved to the Offsite _ Dose Calculation Manual in- Amendmer.t 42 to the Technical Specifications. A change is also. proposed which would revise Section 6.5.1.2 to reflect a position title change.

Evaluation Section 6.8.3 of the Technical Specification states,

" Temporary changes to Major Procedures, of the categories listed in Specification 6.8.1 which_do not change the intent or generate an unreviewed safety question of the original or subsequent approved procedure, may be made provided such changes to operating procedures are approved by the Shift Supervisor (SRO licensed) and one of the Call Superintendents. For temporary changes to Major Procedures under the jurisdiction of Maintenar.:a, Instrumentation and .

Control, Reactor Engineering, Chemistry, or Health Physics-which_ do not change the intent or generate an unreviewed safety question, changes may be made upon- approval of the Cognizant Group Leader and Call-Superintendent."

It also states

• All temporary or permanent changes to Minor' Operating -

Procedures (checkoff lists, alarm responses, data sheets, operating instructions, etc.)_shall be approved by the Shift Supervisor, and shall-be subsequently reviewed and approved by the Operations PSRC Subcommittee. All temporary >or permanent changes to other Minor Procedures _ under the jurisdiction of Maintenance, Instrumentation and Control, Reactor Engineering, Chemistry, or Health Physics shall be approved by- a Ccgnizant Group Leader and shall be subsequently reviewed and approved by the appropriate PSRC Subcommittee."

The abcse statements might be interpreted to requir- " ganizations -otner-than those listed such as Results, Engineering, Security, and Training to have the Shift Supervisor approve procedure change- forms for- procedures under their jurisdiction. This is not the.' intent of this technical specification section.

l Attaahment I to ET'92-0121-1

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i 1 l - The intent of this - section was to take exception to ANSI N18.7 which l requires a Senior Reactor Operator (SRO) signature on all Temporary j Changes. The intent was to only require this - for Operations group l procedures. For other groups, the group leader and call superintendent (PSRC j subcommittee for -minor) are the only required approval authorities. This

{ was done to minimize- the administrative burden placed on the Shift' i Supervisor / Supervising Operator. This proposed change to the Technical )

Specifications is administrative in nature and is intended only to clarify j- the approval process for plant procedures.

. Also included in this revision are corrections to Section 3.3 to reflect the transfer of the requirements in Section 3.11 to the Offsite Dose Calculation j Manual. References to Section 3.13.2.1 and Table 4.11-2 were mistakenly

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left unchanged. This change is editorial in-nature and reflects the changes j made previously in an approved License Amendment 42.

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! In addition. Technical Specification Section.6.5.1.2, Plant Safety Review l Committee-Composition, is revised to reflect a position title change from l Manzger Nuclear Plant Engineering Wolf Creek to Manager System Engineering.

j This title change reflects = a restructuring .of 4 the engineering support i tunction to provide increased emphacis on engineering support for. issues l related to plant operation and maintenance. This change does not involve a change in the current Plant Safety Review Committee membership.

} These proposed revisions do not change the operating procedures of the plant-

] or the administrative controls'for them. They also do not include'- any changes to plant equipment or systems. Therefore, based on the above-

discussions and the considerations presented in Attachment II, the proposed j

changes do not. increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report; or create-the possibility for an l accident or malfunction of a different type than any previously evaluated in l the safety analysis report; or reduc'e the margin of safety as defined in the j basis for any technical specification. -Therefore, the proposed. changes do-j not adversely affect or endanger the health or= safety of the general public j er involve a significant safety hazard.  ;

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• . l Attachment II to ET 92-0121 ,

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ATTAC1 MENT II a

SIGNIFICANT llAZARDS CONSIDERATION DETERMINATION i

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Attachment II to ET 42-0121 Page 2 cf 2 Significant Hazards Consideration Determination I

i The propased changes would revise Technical Specification Section 6.8 te clarify the approval process for plant procedures, Section 3.3 to reflect the relocation of the Radiological Effluent Technical Specification (REIS) to Offsite Dose Calculation Manual (ODCM), and section 6.5.1.2 to reflect a

modification in a position title.

t Standard 1 - Tavolve a Significaut Increase in the Probability or Consequences of an Accident Previously Evaluated i The clarification of the wording for the approval process for plant j procedures does not change the metSod of approval or the intent of the

process. Therefore approval of plant procedures continues to be given by 1 cognizant individuals and does not involve a significant increase in the j probability or consequences of an accident previously evaluated.

Changes to a technical specification to reflect the relocation of the RETS

to che ODCM does not change requirements or reduce the clarity of the j specification.

The information is readily available in the ODCM and the placement of this information in the ODCM has already been approved by the U.S. Nuclear ,

j Regulatory Commission in License Amendment 42.

The change to one of the position titles listed in Section 6.5.1.2 does not

, involve any change in the current membership -of the Plant Safety Keview Committee. This title change teflacts a restructuring of the engineering support function to provide increased emphasis on engineering support for i issues related to plant operation and maintenance.

Standard 2 - Create the Possibility of a New or Different Kind of Accident

from any Previously Evaluated These changes do not involve any change to the installed plaat systems or the operating procedures of WCt3. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Involve a Significant Reduction in the Margin of Safety Clarifying the intent of the approval process for plant procedures does not change the method of approval or the pr., cess by which they are reviewed to

, ensure the safety of the public and the plant._ The editorial correction-to Section 3.3 and the change to a position title in Section 6.5.1.2 are adsiaistrativa in natura and do not .2; pact any margin ci cafety. Therefore the proposed changes do not involve a significant reduction in the margin of

safety.

Based on the above discussion, it has been determined that the requested technical specification revision does not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of an new or different hind of accident or condition over previous evaluations; or involve a significant ' eduction in the margin of safety. The requested license amendment does not !wvnive a significant hazards consideration.

Attachment III to ET 92-0121=

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ATTACISIENT 111 ENVIRONKENTAL IMPACT DETERMINATION T

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Attachment III to ET 92-0121.

Page 2 of 2 i.

i i Environmental Impact Determination 4

{ 10 CFR 51.22(b) specifies the criteria for estegorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21. This l

-amendment request meets the criteria specified in 10 CFR 51.22(c)(9).

Specific criteria contained in this section are discussed below.

$ (1) _the amendment involves no significant hazards consideration As demonstrated in the Significant Hazards Consideration Determinat!on in

, Attachment II, the requested license amendment does not involve any

significant hazards consideration.

(ii) there is no significant change in the types or significant increase j in the amounts of any effluents that may be released offsite The requested license amendment involves no change to the facility or

operating procedures, therefore no increase 'n the amounts of effluents or new types of effluents would result.

i (iii) there is no significant increase in individual or cumulative occupational radiation exposure

! The nature of the changes is administrative and does not create additional j exposure to personnel nor affect levels of radiation present. The proposed

changes do not result in significant individual or cumulative occupational e radiation exposure.

I Based on the above it is concluded that there will be no impact on the

, environment resulting from these changes. The changes meet the criteria

specified in 10 CFR 51.22 for a categorical exclusion from the- requirements I sf 10 CFR 51.21 relative to specific environmental assessment by the Commission.

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