ML20154D753

Application for Amend to License DPR-54,consisting of Rev 1 to Amend 168,replacing Organization Charts W/More General Administrative Controls

ML20154D753
Person / Time
Site:	Rancho Seco
Issue date:	09/08/1988
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154D756	List: ML20154D753 ML20154D759
References
AGM-NPP-88-464, NUDOCS 8809160092
Download: ML20154D753 (7)

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Osuun U SACRAMENTO MUNICIPAL UTILITY DISTRICT C 62ot S Street. P.O. Box 15830. Sectamento CA 958521830,4916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA SEP 0 81988 i

AGM/NPP 88-464 l

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U. S. Nuclear Regulatory Commission Attn: Document Control Desk i

Washington, D. C.

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Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 PROPOSED AMENDMENT NO. 168. REVISION 1 l

Attention: George Knighton In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend Operating License DPR-54 for Rancho Seco and therefore I

l submits Proposed Amendment No. 168. Revision 1.

Proposed Amendment No. 168 was submitted on July 1, 1988.

The submittal concerned changes to the Administrative Controls (Section 6) of the Rancho Seco Technical Specifications.

The proposed changes involved replacing the i

organization charts with more general administrative controls.

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Proposed Amendment No. 168, Revision I supersedes the original Proposed l

Amendment No. 168. Per discussions with the NRC, minor changes included as part of Revision 1 are: removal of the clarification that the Shift l

Operations Superintendent SRO license may be either active or inactive; I

removal of the "as shown in the USAR" phrase from the PRC and MSRC membership Technical Specifications; a clarification of appropriate ANSI N18.1-1971 sections used to qualify PRC members; a clarification that Q.1411ty Assurance reports to the CEO, Nuclear, and removal of the requirement to notify the i

Director of Nuclear Operations and H&intenance if a Safety Limit is violated.

i Attachment I contains the revised Safety Analysis Report and the No Significant Hazards Consideration for the changes made by Proposed Amendment No. 168, Revision 1.

Attachment II contains the list of Technical Specification pages affected by Proposed Amendment No. 168. Revision I and the proposed replacement pages.

Pursuant to 10 CFR 50.9)(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of Proposed Amendment No. 168, Revision 1 by mailed copy of this submittal.

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RANCHO SECo NUCLE AR GENERATING STATION O 1444o Ten Ctes Roa1 Heraid. C A 95638 9799.(209i 333 2935 L

AGM/NPP 88-464 l

Document Control Desk t The District has determined that no license fees are required with this revision since a check for $150.00 was sent to the Commission with the initial i

submittal of Proposed Amendment No. 168.

Members of your staff with questions requiring additional information or clarification may contact Ms. Ellen Banaghan at (916) 452-3211, extension 4917.

State of California SS County of Sacramento l

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Dan R. Keuter, being first duly sworn, deposes and says:

that he is AGM, I

Nuclear Power Production of Sacramento Municipal Utility District (SMUD), the c

licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his i

i knowledge, information, and belief, and that he is authorized to execute this i

document on behalf of said licensee.

-).

j Dan R. Keuter l

Assistant General Manager,

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Nuclear Power Production i

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, 1988.

day of h Subscribed and affirmed to before me on this l

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NeltucHItt.

tohin Michell j

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Notary Pubite

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Attachments I

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cc:

A. D'Angelo. NRC, Rancho Seco J. 8. Martin, NRC, Walnut Creek f

f J. S. McGurk, State of California j

i INPO MIPC (2)

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ATTACHMENT I Safety Analysis Report and No Significant Hazards Consideration I

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Proposed Amendment No. 168 Log No. 1073 Safety Analysis Rev. 2 Page 1 of 4 i

SAFETY ANALYSIS REPORT Dtitr_tailon of Changt l

Replacement of Technical Specification (Tech Spec) Figures 6.2-1 and 6.2-2 with more gencral organizational requirements including Removal of organization charts from Section 6 of Tech Specs.

Modification of Tech Spec Section 6 PRC and MSRC membership l

qualifications to reference the USAR instead of Tech Spec ciganization L

charts.

j Addition of requirem6nt to establish and control lines of authority, I

responsibility and communication from highest levels through all operating organization positions.

Addition of a requirement to designate an executive position that has overall responsibility of plant nuclear si.fety and a management l

position responsible for overall facility operatie.

l Addition of the statement that the Shift Operations Superintendent shall hold l

a Senior Reactor Operator (SRO) License in accordance with 10 CFR 56.

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'ddition of statement that functions of Health Physics, Quality Assurance and Training of Operations Staff maintain sufficient organizational freadom to be independent of operational pressures.

P Removal of statement that the Director, Nuclear Operations and Maintenance shall be notified if a Safety Limit is violated.

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l Reason _for_Chanst NRC Generic Letter 88-06, "Removal of Organization Charts From Technical l

Specification Administrative Control Requirements," dated March 23, 1983, t

discusses the desirability of removing organization charts from Tech Specs.

This was rerommended in order to reduce the unnecessery Tech Spec changes resulting from organization changes not affecting plant safety. As stated in the Generic Letter, organization charts have been of little help in ensuring that the objectives of administrative control requirements are met.

By replacing the organization charts with more general requirements, the admini'.'.r 'Ive controls necessary to ensure safe operation of the facility are specified shile maintaining the freedom to make minor changes to organization charts without revising Tech Specs.

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i Propssed Amen >m it No. 168 Log No. 1073 j

Safety Analysis Rev. 2 Page 2 of 4 Evaluation The changes do not affect any systems, subsystems or components.

The changes affect administrative controls only.

Tech Spec Section 6 is renuired to contain the details of those administrative controls necessary to assure safe operation of the facility.

The proposed r glacement of the charts with more general requirements will capture the essence of those organizational features that are important for ensuring the plant will be operated safely.

The organization charts are also located in other plant controlled documents including the Rancho Seco Quality Manual and the Updated Safety Analysis Report (USAR).

10 CFR 50.71 requires that the USAR organization charts be kept current annually. Additionally, 10 CFR 50 Appendix B, Criterion I specifies the requirement for the QA program wherein the organization is described.

The statement that the Shift Operations Superintendent shall hold an SRO License is a restatement of information previously contained on the organization chart.

Reference to the governing regulatory standards which addrass the conditions and requirements of SRO licenses is made.

The Safety Limit Violation section of Tech Specs (6.7.1) is being amended to remove the notification of the Director, Nuclear Operations and Maintenance.

The amended section will be consistent with 10 CFR 50.36(c)(1)(1),

10 CFR 50.72, and with NUREG 0103 (Standard Tech Specs).

This change will remove the dependency on the title of Director, Nuclear Operations and Maintenance with regard to Safety Limit Violation reporting.

Sunnary Proposed Tech Spec Amendment No.168, Revision 1 consists of modifying Tech Spec Section 6 to remove the organization charts and amending the text to include general organizational requirements and responsibilit'es.

The purpose of the change is to eliminate unnecessary Tech Spec amendments resulting from minor organizational changes while maintaining organizational requirements important to ensuring plant safety (reference Generic Letter 88-06).

The change is consistent with the USAR and the USAR will continue to contain specific organization charts that will be updated.

This change is administrative only.

It is within the existing Licensing Pssis Decements and will not affect any USAR Chapter 14 accident analysis.

Proposed Amendment No. 168 Log No. 1073 Safety Analysis Rev. 2 Page 3 of 4 UDr.aviewed Safety Ouestion Determinaticri As stated in Generic Letter 88-06, replacing the organization charts with the general requirements will result in no reduction of safety requirements, and as stated in NRC Docket No. 50-400 "Safety Evaluation By the Offica of Nuclear Reactor Regulation Supporting Amendment No. 3 to Facility Operating License No. NPF-63, Carolina Power and Light Company":

"These general requirements capture the essence of those organizational features depicted on the charts that are important to the NRC for ensuring that the plant will be operated safety." Since the organization charts will be controlled in the USAR and QA manual, and because the Tech Spec organization charts are being replaced by general organization requirements, an Unreviewed Safety Question is not

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involved.

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Proposed Amendment No. 168 Log No. 1073 Safety Analysis Rev. 2 Page 4 of 4 NO SIGNIFICANT HAZARDS CONSIDERATION The District has reviewed the proposed changes against eacn of the criteria in 10 CFR 50.92 and based on the discussion in the above safety analysic concludes:

A significant increase in the probability or consequences of an accident previously evaluated in the SAR will not be created because...

The general organization requirements capture the essence of the organizational features in the charts important to ensure plant safety.

The proposed amendment will not create the possibility of a new or different type of accident previously evaluated in the SAR because...

Changes are administrative only and do not impact safety-related syster.2.

The changes provide adequate administrative control and do not provide any new mechanisms by which an accident could occur.

The proposed amendment will not involve a significant reduction in the margin of safety because...

Adequate administrative control will be maintained by the general requirements being placed in Tech Specs and the control of the organization charts in oth'. plant documents.

Based on the above discussion, the utstrict concludes tiat the proposed changes do not constitute a significant hazard to the public and in no way endanger the public's health and safety.

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