ML20148H798

Application for Amend to License DPR-16,consisting of Tech Spec Change Request 167 Re Replacement of Organization Charts in Tech Specs W/More General Organization Requirements.Fee Paid

ML20148H798
Person / Time
Site:	Oyster Creek
Issue date:	03/22/1988
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20148H803	List: ML20148H798 ML20148H816
References
NUDOCS 8803300084
Download: ML20148H798 (7)

Text

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1 GPU Nuclear Corporation l G PJ Muclear  ;; :l " "L at ,o,0s.

201-316 7000 I

l TELEX 136-482 I Writer's Direct Dial Number:

US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sir:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Technical Specification Change Request No.167 Pursuant to 10 CFR 50.90, GPU Nuclear Corperation, operator of the Oyster Creek Nuclear Generatir] Station (0CNGS), Provisional Operating License No. DPR-16, requests a change to Appendix A of that license.

This Technical Specification Change Request primarily deals with the replacement of organization charts in the Technical Specifications with more general organization requirements. The important organizational features depicted on the organization charts are also required or controlled by other regulatory control mechanisms.

This submittal is similar in content te the Shearon Harris Nuclear Power Plant, Docket 50-400/ License No. NPF-63, Technical Specification Change Request submitted June 12, 1987. This request was approved by the NRC as Amendment No. 3 to the Shearon Harris Technical Specifications on January 27, 1988.

Pursuant to 10 CFR 50.91(a)(1), we enclose our analyses, using the standards in 10 CFR 50.92 of significant hazards considera lons. This change request has been reviewed in accordance with Section 6. of the Oyster Creek Technical Specifications and we have concluded that this proposed change does not constitute a significant hazards consideration.

Pursuant to 10 CFR 50.91(b)(1). a copy of this change request has been sent to 1 the State of New Jersey, Department of Environmental Protection. In addition, l a check for $150.00 pursuant to 10 CFR 170.12 is enclosed for the application  !

fee. ,

Sincerely, P7 d ,

Vice President & Director Oyster Creek g g fo PBF/DVH/spb:0083T tF 0 cc's on next page 8803300084 880322 :orporation is o :aabsidiary of General Pubhc UtAties Corporat;on PDR ADOCK 05000219 l p DCD

cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Comission 475 Allendcle Road King of Prussia,.PA. 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station i Forked River, N.J. 08731 Mr. Alex Dromerick, Jr.

U.S. Nuclear Regulatory Comission Washington, D.C. 20555 l

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1 UNITED STATES-0F AMERICA j NUCLEAR REGULATORY COMMISSION i

IN THE MATTER OF DOCKET N0. 50-219 GPU NUCLEAR CORPORATION l CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.167 for Oyster Creek Nuclear Generating Station Technical Specifications, filed with the U.S. Nuclear Regulatory Comission on March 22, 1988 ,

has this day March 22, 1988 , been served on the Mayor of Lacey Township, Ocean County, New Jersey, by deposit in the United States mail, addressed as follows:

The Honorable Christopher Connors Mayor of Lacey Township 818 West Lacey Road Forked River, N. J. 08731 BY: 77 Lif >h PetePMedler Vice President & Director Oyster Creek

l GPU NUCLEAR CORPORATION l

OYSTER CREEK NUCLEAR GENERATING STATION Provisional Operating License No. DPR-16 Technical Specification Change Request No.167 Docket No. 50-219 Applicant submits, by this Technical Specification Change Request No.167 to the Oyster Creek Nuclear Generating Station Technical Specifications, a change to Section 6.

BY: My J '- O Peter'B N 1er Vice President & Director, Oyster Creek Sworn and Subscribed to before me this A J d day of /k/a/tpf ,1988.

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' Notary Publ/c 6f h. J.  ;

DIANA M. D2BLAS o NOTARY PUGUC Of tlB7 My Cc.u::si:n ErpireL6 JS?SEY5- Q l

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OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST N0.167

1. Sections to be changed:

a. Section 6 - all pages.

2. Extent of Changes-

a. Organization charts on pages 6-3, 6-4 and 6-5 are deleted,

b. Section 6.2 is revised to reflect deletion of organization charts.

c. Section 6.3 - this is deleted and is now included in the updated-FSAR.

d. Section 6.4 - this is revised to reflect revised 10 CFR Part 55 and to delete reference as to who will direct training of the licensed operators and Fire Brigade,

e. Section 6.5.1 and 6.5.2.1 revised to reflect deletion of the organization charts.

f. Section 6.5.3.1 deleted title of Vice President - Quality and Radiological Controls,

g. Section 6.5.3.2 deleted title of Vice President - Technical Functions.

h. Section 6.5.4 deleted titles.

1. Section 6.9 revised location to which reports are sent.

J. Section 6.13.1 deleted title.

k. Pages 6-4, 6-6, 6-12, 6-14, 6-15, 6-17 and 6-18 retyped - no changes other than page number.

3. Changes Requested Replace page 111 and entire Section 6 with the now pages attached. I

4. Reason for Change The proposed change deletes the organization charts from the Technical Specifications (TS). 10 CFR 50.36 (c)(5) requires administrative controls necessary to assure operation of the facility in a safe manner.

to be included in the Technical Specifications. However this does not specifically require the inclusion of organization charts in the

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. . Technical Specifications. Chapter 13 of the Oyster Creek Updated FSAR l ,

(UFSAR) will contain a detailed organization structure and a description

! of the conduct of operations. This information is required by 10 CFR 50.34. In addition 10 CFR 50.71 requires the Updated FSAR to be me ntained and updated annually. The organization details will be l included in an Update of the Oyster Creek UFSAR. This will be l accomplished via a change to the Updated FSAR to include the organization

! charte and Facility Staff Qualifications.

Over the past y0ars, there have been several Oyster Creek Technical Specification Change Requests (TSCR) that have addressed organization changes. These TSCRs did not' delete any organization structure but rather rearranged various positions / groups / divisions. Deletion of the organization charts from the Technical Specifications will eliminate the need of GPUN and the NRC to expend time processing these changes. It has been the experience that organization charts by themselves have little use in assessing safety significance of change to the plant and license.

The NRC Senior Resident Inspector will be advised of significant organization changes as they occur.

This submittal is similar in content to the Shearon Harris Nuclear Power Plant, Docket 50-400/ License No. NPF-63, Technical Specification Change Request submitted June 12, 1987. This request was approved by the NRC as Amendment No. 3 to the Shearon Harris Technical Specification on January 27, 1988.

- Along with deleting the organization charts, other changes in this TSCR includes references to the deleted figures, references to what departments are responsible for training of the licensed operators and fire brigade, and titles were made generic where deemed appropriate.

5. Safety Evaluation Justifying Change The deletion of the organization charts, position titles, and Facility Staff Qualifications from the Technical Specifications does not have an adverta effect on safety. Also removing reference to what department is responsible for training of the licensed operators and fire brigade does not have an adverse effect on safety. Although these items no longer will be detailed in the Technical Specification, the details are included in the Updated FSAR. The Updated FSAR will be revised to include the organization charts and the Facility Staff Qualifications.

This will be contained in update number 3 planned for April 1988.

The remaining items in this TSCR are administrative in nature and do not have an effect on safety.

6. Significant Hazards Consideration ,

l This proposed change is similar to example (1) of the "Amendments Not  !

Likely to Involve Significant Hazards Consideration" from the Federal  !

Register V01, 48, No. 67 at 14870 on April 6, 1983. j This change is considered an administrative change. This Technical Specification Change Request does not involve significant hazards consideration as stated below.

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(1 ) Involve a significant increase in the probability or consequences of an accident previously evaluated, i The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated

.because deletion of the organization charts and position titles ,

from the Technical Specifications does not affect plant operation. 1 As in the past, the NRC will continue to be infonned of organizational changes through other required controls. In accordance with 10 CFR 50.34-(b)(6)(1) the applicant's organizational structure is required to be included in the Updated Final Safety Analysis Report. Chapter 13 of the Updated Final Safety Analysis Report provides a description of the organization and detailed organization charts.

As required by 10 CFR 50.71 (e) GPUN submits annual updates to the Updated FSAR. Appendix B to 10 CFR Part 50 and 10 CFR 50.54 (a)(3) govern changes to organization described in the Quality Assurance Program. Some of these organizational changes require prior NRC approval. Also, it is GPUN's practice to inform the NRC of organizational changes affecting the nuclear facilities prior to implementation.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated because the proposed change is administrative in nature, and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.

(3) Involve a significant reduction in a margin of safety.

The proposed amendment does not involve a significant reduction in a margin of safety because GPUN, through its Quality Assurance programs, its comitment to maintain only qualified personnel in positions of responsibility, and other required controls, assures that safety functions will be perfonned at a high level of competence. Therefore, removal of the organization chart and Facility Staff Qualifications from the Technical Specifications will not affect the margin of safety.

7. Implementation It is requested that the amendment authorizing this change become effective upon issuance.

8. Amendment Fee (10CFR170.21)

Pursuant to the provisions of 10CFR170.21, a check for $150.00 is included with this request.