ML20195G420

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Rev 2 to Proposed Amend 138,revising Tech Specs to Reflect Addl Organizational Changes Due to Need for Addl Mgt Staffing for Present Outage & from Expansion of long-term Mgt Function
ML20195G420
Person / Time
Site: Rancho Seco
Issue date: 09/16/1987
From: Andognini G
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Miraglia F
Office of Nuclear Reactor Regulation
Shared Package
ML20195G423 List:
References
GCA-87-034, GCA-87-34, TAC-60162, NUDOCS 8709220153
Download: ML20195G420 (9)


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( )SMUD SACAAMENTO MUNICIPAL UTIUTY DISTRICT O P. O. Box 15830, Sacramento CA 95852 1830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART c'F CALIFORNIA i

SFP f 61987 GCA 87-034 Associate Director for Projects Attn: Frank J. Miraglia, Jr.

Philips Bldg U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 Docket No. 50-312 Rancho Seco Nuclear Generating Station Unit # 1 License No. DPR-54 PROPOSED AMENOMENT NO. 138, REV. 2

Dear Hr. Miraglia:

In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend its Operating License DPR-54 for Rancho Seco, and herewith submits Proposed Amendment No. 138, Rev. 2, for this purpose.

Proposed Amendment No. 138 was submitted on October 16, 1985, and Proposed Amendment No. 138, Revision 1 on August 12, 1986. Both submittals concerned changes to the Administrative Controls (Section 6) of the Rancho Seco Technical Specificatic,ns. In general, the proposed changes involved restructuring of the organization and expansion of the management staff.

After the submittal of Proposed Amendment No.138 and its first revision, other organizational changes occurred. These changes resulted from the need for additional management staffing for the present outage and from expansion of the long-term management function. Consequently, a second revision to the proposed amendment became necessary.

Por discussions with the NRC, it was agreed that the second revision to Proposed Ameadment No.138 should await finali:tation of the organization that would be in effect at the time of plant restart. In the meantime, an NRC-requested District submittal of documentation showing compliance of the interim organization functions with the technical specifications requirements was transmitted to the NRC on October 17, 1986. In that transmittal the

' District requested that the NRC continue its review of Proposed Amer.dment No.

138, Rev. I so that NRC concerns could be identified and resolutions incorporated in Revision 2 of the proposed amendment. The NRC comments, sent to the District on January 15, 1987, consisted of requests for additional information, and comments on Proposed Amendment No. 138, Rev. 1 (Enclosures 1 and 2, respec;1vely, of th9 NRC letter). y t

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CANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

. GAC 87-034 i

. F.J. Miraglia, Jr. This submittal consists of the following attachments:

  • Attachment I: Submittal of Requested Information
  • Attachment II: Response to NRC Comments on Proposed Amendment No. 138, Rev. 1
  • Attachment III: Technical Specification Pages Affected by Proposed Amendment No. 138, Rev. 2
  • Attachment IV: Description, Reason for Change, and Evaluation and Basis for Safety Findings
  • Attachment V: No Significant Hazards Consideration.

Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health S6rvices has been informed of this proposed amendment by mailed copy of this submittal.

The District has determined that no license fees are required with this revision because a check for $150.00 was sent to the Commission with the initial submittal of Proposed Amendment No.138.

In view of the proposed changes consistir,g exclusively of improvements in management oversight resulting from the addition of higher level management and organizational restructuring, it is the intention of the District to begin implementing these changes promptly whenever effective transitions can be made.

Should you require any further information concerning Proposed Amendment No.

138, Revision 2, please contact Mr. Ronald H. Colombo at (916) 452-3211, extension 4236.

Sincerely, l

. Carl ndo ni Chief Executive Officer, Nuclear Sworn to and subscribed before me this /4 day of September, ufv d. W

$ Notary Public EE Attachment cc ulatchm' -

. h , e.. wN, sum G. Kt.. dan, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco J. B. Hartin (2)

HIPC (2)

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  • d GCA 87-034 F.J. Hiraglia, Jr. bc w/atch:

' 1 X General Manager MS 41 X Chief Executive Officer, Nuclear MS 209 (2)*

X Executive Assistant MS 209 AGH, Nucl. Tech. & Adm. Services MS 206 AGH, Nuclear Power Production MS 254 Director, Nuclear Quality MS 271 Director, Nuclear Tech. Services MS 206A Director, Nuclear Ops, & Maint. MS 257 Director, Plant Support MS 258 Director, Sys. Rev. & Test Prgm. MS 206B Hodifications Manager HS 201 X Hanager, Nuclear Training MS 296 Hanager, Nuclear Licensing MS 286 '

X Manager, Nuclear Engineering MS 208-6 Manager, Cost Control Services MS 270 X Public Information MS 204 Hanager Maintenance MS 254 Plant Support Eng. Manager HS 208-6 Hanager Operations MS 255

___. Manager, Env. Protection MS 292A Hanager, Rad. Protection MS 244 [

Nuclear Chemistry Manager HS 243 Risk Manager (D. Nears) MS 40 MSRC Secretary (T. Ferrando) HS 274

% Surveillance Coordinator MS228204 IIRG HS 298 X NAC (47lo HS 209

_X_ T. Baxter (Esq.)

X F. Burke (B&H)

_X_ Fourth Fl.cor Files MS 43 LER Files MS 298

_X. Licensing Files MS 286

_X_ PRC Files PS 286

_X_ RIC Files HS 224 Special Report Files MS 286

_X- Tech. Spec. Files

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. ATTACHMENT I SUBHITTAL OF REQUIRED INFORMATION P4GE 1 0F 2 Following are the District's replies to NRC's request of January 15, 1987, for additional information concerning Section 6, Administrative Controls, of the Rancho Seco Technical Specifications. For the convenience of the reviewers, the NRC inquiry is presented before each District reply:

1. Fiaure 6.2-1 ,
a. With respect to each of the functional units under the Chief Executive Officer, Nuclear, provide a description of their function and responsibilities.

Reply The position descriptions of each manager of the functional units under the Chief Executive Officer, Nuclear, were submitted to the NRC on February 11, 1987, as Attachment C. These position descriptions include details of unit function and responsibility.

b. Is the responsibility for the Rancho Seco Sacurity Program under the block "Security" that reports to the AGH, Administration and Services?

If not, who has responsibility for that function?

Reply s The responsibility for the Rancho Seco Security Plan is under the Director, Security, reportable to the AGH, Utility Services, (see Figure 6.2-1 in Attachment III).

c. You state that the AGH, Engineering is not responsible for Nuclear Engineering. Does the AGH, Engineering have any responsibility for engineering associated with Rancho Seco Nuclear Generating Station, Unit No. 17 Rep.1x Engineering associated with Rancho Seco is provided by the Nuclear Engineering Department and by system engineers in the Plant Performance Department (see Figure 6.2-2 in Attachment III). Both of these i

departments are located on site. The AGH, Engineering and Production I

in the District headquarters office has no responsibility for Rancho Seco engineering.

l

PAGE 2 0F 2

d. Your Nuclear Restart Implementation organization shows functional units titled Plant Hodifications, Implementation Manager, and Support Services Manager. Describe where these functions will be assigned in the organization shown in Figure 6.2-1.

Reply The functional units titled Plant Hodifications, Implementation Manager, and Support Services Manager on the Restart Implementation Organization are assigned, respectively, in the revision to Figure 6.2-2, Attachment III, to the Manager, Nuclear Engineering, Manager Scheduling and Outage Management, and the Director, Administrative Services.

2. Flaure 6.2-2 The positions of Engineering and Quality Control Superintendent, Senior Power Plant Engineer - Nuclear /Hechanical/ Electrical, and Quality Control Personnel, have been deleted from the revised Figure 6.2-2. Describe where the functions associated with those positions have been assigned.

Reph The previous functions of Engineering and Quality Control Superintendent, and Senior Power Plant Engineer - Nuclear /Hechanical/ Electrical are assigned to the Plant Performance Departmenc. The function of Quality ,

Control is part of the Quality Assurance Department.

ATTACHMENT II RESPONSE TO COMMENTS ON PROPOSED PAGE 1 0F 4 AMEN 0HENT NO. 138, REV. 1 Following are the District's replies to NRC's comments of January 15, 1987, concerning Proposed Amendment No. 138, Rev. 1. For the convenience of the reviewers, the NGC comment is presented before each District response:

1. Fiaures 6,2-1 and 6.2-2_

Figure 6.2-1 should be changed to show position titles rather than functional groups. Figure 6.2-2 should be expanded to show a staff under the department head and the shift staffing. In addition, the proposal to add the statement that changes may be made per 10 CFR 50.59 without prior NRC appron1 is not acceptable. All Technical Specification changes r2 quire prior NRC approval.

ReDIY Figures 6.2-1 and 6.2-2 have been revised (see Attachment III) to show position titles rather than functional groups. Figure 6.2-2 shows these positions down to the department manager's level.

In a telecon with the NRC (G. Kalman, NRC and C. Stephenson/V. Grayhek, SHUD) and subsequently in an on-site March 25, 1987, meeting with the NRC, it was agreed that, in general, position titles below the department (

manager level need not be shown. However, the NRC requested that certain specific superintendent levels, or equivalent, be shown for the following departments: --

  • Operations
  • Maintenance
  • Plant Performance The revised Figure 6.2-2 incorporates these changes. In addition, reference to organization changes per 10 CFR 50.59 without NRC approval has been deleted from both figures.
2. Section 6.2.2.c This section should be revised to reflect the requirements of 10 CFR 50.54(m)(2), i.e., two licensed operators, one of whom shall be senior licensed, shall be present in the control room when the unit is in other than cold shutdown or refueling.

Reply The suggested revision has been made. Also in accord with the Standard Technical Specificatioas, the title has been changed, and the Equipment Attendant levels deleted.

- PAGE 2 0F 4

3. Sgction 6.5.1.4 This proposed section on the use of subcomittees is not required by the ,.

"Standard Technical Specifications (STS), and should be deleted. t Reply The section on use of subcomittees has been deleted, as suggested.

4. 51ction 7.5.1.6.f (current section)

Section 6.5.1.6.f of the current Specification has been deleted. This section should be reinstated as there is no basis for its removal.

Eftall Section 6.5.1.6.f has been rainstated, as suggested. ,

5. Sections 6.5.1.7.e and a The proposed changes to the current sections e and g are not acceptable as they delete actual review of violations and events by the PRC, and Section 6.5.1.7.e deletes the requirement for the preparation and distribution of reports.

EDDh It is assumed that items e and g of Section 6.5.1.6 are the object of the NRC's coment, not sections 6.5.1.7.e and g, which are non-existent.

Hith the exception of position title changes and minor editing, Sections 6.5.1.6.e and g are restored to the current wording.

6. Section 6.5.2.1 This section, which currently is consistent with the Standard Technical Specificttions, has been revised to reduce the overall responsibility of the Management Safety Review Comittee (HSRC). Therefore, we find this proposed change unacceptable.

Reoly Section 6.5.2.1 has been restored to its current wording.

7. Section 6.5.2.7.a This section has been changed to substitute the word analysis in place of evaluation. This is unacceptable since the wording "safety analysis" is inconsistent with the Standard Technical Specifications and 10 CFR 50.59.

Reph The wording "safety evaluation" has been restored to Section 6.5.2.7a.

PAGE 3 0F 4

8. Section 6.5.2.7.e This section has been revised such that the requirement for the review of internal procedures or instructions having nuclear safety significance has been deleted. This change is unacceptable as it does not conform to the Standard Technical Specifications.

Lt9h Section 6.5.2.7.e has been restored to its current wording.

9. Section 6.5.3 This is a new section that provides for independent review of many items by other than the Plant Review Committee. While the concept is acceptable, several items need to be changed and/or expanded. These are as follows:

. There has been no approval authority designated for proposed changes or modifications to plant nuclear safety-related structures, systems and components, or proposed tests and experiments that affect nuclear safety. Additionally, the approval authority for procedures should be predesignated and assigned at a manager level. Approval for temporary changes to procedures should include an appropriate review and approval within seven days.

Piph Section 6.5.3.b has been reworded to specify approval of proposed changes or modifications to plant systems or equipment by the AGH, Nuclear Power Production, or his designee. Such designee can be no lower than a division director level.

Section 6.5.3.a has been reworded to specify approval of pmcedures as delineated in writing by the AGH, Nuclear Power Production, but not lowcr than the department manager level'. ~ Approval of plant administrative procedures Security Plan Implementing Procedures and Emergency Plan Implementing Procedures is solely by the AGH, Nuclear Power Production.

In addition, Section 6.5.3.a is reworded to specify approval within fourteen (14) days of implementation. This span of days is in conformance with the Standard Technical Specifications.

10. Seciton 6.5.4.n Thir section which requires certain audits has been removed from the cognizance of the HSRC and placed under the Manager, Nuclear Quality.

While we accept the audits being conducted by the quality assurance department, audit reports resulting from Section 6.5.4 audit should continue to be forwarded to the Chairman of the HSRC within 30 days after completion of the audit.

Leph The closing paragraph of Section 6.5.4 has been reworded to comply with the above NRC comment.

i PAGE 4 of 4

11. Section 6.6.1

.The revision to this section deletes the requirement that each Licensee Event Report (LER) be transmitted to upper level management. A statement needs to be added to the offect that the LER reports shall be submitted to the Deputy General Manager, Nuclear.

ReDIY The position of Department General Manager, Nuclear, has been changed throughout Proposed Amendment No.138, Rev. 2 to Chief Executive Officer (CEO), Nuclear. Accordingly, the wording of Section 6.6.1.b has been revised to state th?t each LER shall be submitted to the CEO, Nuclear, and reviewed and appidved by the CEO, Nuclear, or his designee.

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7/PP '7 -/VO RANCHO SECO CORRESPONDENCE CHECK SHEET r

GCA 87-034 Comments Due By: dan!" W/4'[f7 Letter No.:

/ Ext. 3905 k!r"}h! Jerry Delezenski / Ext. 3909 hdNYd  !~VernGrayhek ggng i Vern Grayhek / Ext.3905{fyning:

Regulatory Agency: US NRC PROPOSED AMENDMENT NO. 138, REV @ 2 Title cr

Subject:

Summary:

Proposed Amendment,No. 138 Rev. 2 updates the earlier submittal of PA. No. 138 on 10-16-85 and 3-12-86. These amendments are all concerned with chanaes to Section 6.

Administrative Controls of the Tech Specs Rev. 2, reflects the l_atest_.manaaement oositions acornoriate

$[NNNsYi@Nisletter: Voon NRC acoroval of this orocosed amendment.

channes will be made in the USAR and olant orecedu-es.

Due Date: N/A Commitment (s) Assigned To: Licensina cent Oper. Procedures /Proj Supv Due Date: N/A N/A Commitment Number (s):

Licensing / Record Summary: k Final Letter Concurrence with Dates; N Rev w Initial _ Qatt Discioline/Deoartment Reauled Hame 00 '1/r/O J. Firlit AGH.' Nuclear Power Production 17 QC Sss An*msb G. Coward AGH. Tech. and Adm. Services Director, Nuclear Quality 56 6 art Ace _

J Vinquis,t B. Croley Director, Technical Services @ .sta. 4%nuerg __

Director, Nuclea. Ops. & Maint. [g-) ssE Ancero D. Keuter Director, Plant Support [Z~) sus. m marn J. McColligan '

Director, Sys. Review & Test Program i i _

J. Shetler In90ED,KETifG #1711_ _ R .'> 1. 97

_PRC MSRC E M d M t M 7,L _ .3.*.2 ~2 7 L ,_J .

MLn3ger. Nucl. Licensina Ecpt. DO , 3 8.7 K. Meyer M, Anderson Ettcntive Assistant /CEO Ofc (last) 00'h_ # $/M2 -

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t 3 SACRAMENTO s dh. 'IPAL UTILITY DISTRICT of in < 'AORANDUM To: dam G. Carl Andognini September 2, 1987 Prepared by:/

I dd5 Reviewed by: ..

A ,.soved by: _/ -

susJEct MSRC MEETING 221 HELD ON SEPTEMBER 2, 1987 AT RANCHO SECO Members Present Non-Members Present D. Whitney - Chairman B. Harrington G. Coward R. Roehler B. Croley H. Story (UES)

S. Crunk P. Herbert D. Kauter (

J. McColligan )

K. Meyer T. Peterson J. Vinquist T. Ferrando (Non-voting Secretary)

1. Meeting was brought to order and commenced at 0807.
2. MSRC Minutes for MSRC Heating 220 were presented (MSRC 87-294). Discussion concerned PRC comments that depirat implerenting conditions that affect safety r.alyses. This item in the minutes is changed to ensure this specific point is correct.

MSRC Secretf 's ensure clarification with PRC Chairman. aw.' ' was made tr accept these minutes as % - ,

Motion Passed Unanimousiv. Jhis closed MSRC 87-29.4..

3. Safety Review of Proposed Amendment to Technical Specification PA 138 revision 2 log number 682 revision 6 concerning Rancho Seco and Corporate Office organizations and Administrative Controls (MSRC 87-293). Discua On was held and comm9nts concerned organization chart details, and text portion 6.5.1.2 aled 6.5.1.3 on the identification

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.G. Carl Andognini . September 2, 1987 j of members assigned to the PRC. A motion was made to accept this safety' review and Technical Specification change as. amended.

Motion Passed Unanimousiv. M'his closed MSRC 87-212.a.

4. The ALARA Manual revision '2 was presented (MSRC 87-

, 250). Discussion was held'concerning format, organization, program description, and details being involved in the program. A motion was made to accept this manual as presented.

-Motion Failed Unanimousiv. MSRC 87-250 reme1B1 9220.a.

  • The MSR1 c.aairman appointed Mr. T. Peterson as chairmat, cf the ALARA Oversight Subcommittee and i

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appointei Mrsnra D. Martin and F. Kellie as members. 1 t

The MSRC identified the task of reconstructing and making recommendations to the MSRC concerning the ALARA Manual revision to the ALARA Oversight i Committee. The recommendations should include "philosophy" of the manual, policy statement, and outline of manual. These recommendations are i 3 requested to be presented to the MSRC on September  :

16, 1987.

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5. Safety review of proposed procedure change log 1032 [

revision 1 concerning STP-961 Loss of Offsite Power a Test (MSRC 07-299). Discussions were held I concerning the definition of operability, the I review of a safety analyses applicable to a "draft" l procedure, and identification of compensatory l measures. The MSRC comment was to remove the i depiction of "draft" from the Gafety Analysis. A }

motion was made to accept this safsty review with j comment as an unreviewed safety question that is to be sent to NRC.

Motion Passed Unanimous 1v. This closed _MSRC 87-299. f

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6. NL 87-1146 concerning "Medificatior, of f Disagreement" between PRC Chairman and the Director ,

No.: lear Operations and IPintersnce (MSR7 87-300).  ;

Discussiona were held concerning vendor manual '

controls, generic letter 83-28, obligations to j i

>e' + -e G. Carl Andognini September 2, 1987 l>

, NOTEPAD and reportability under the provisions of 10CFR21. A motion was made to not make this item reportable under the provisiors of 10CFR2. due to the definition of "Basic Component."

Motion Passed Unanimousiv. This closed MSRC 87-2 Q.Q.a.

7. A motien was made to adjourn at 0943.

Nation Passed Unanimousiv.

cc: W. K. Latham .

R. Colombo D. Whitney G. Clefton G. Coward C. Linkhart i J. McColligan J. Irwin B. Croley G. Simmons D. Kauter T. Tucker K. Mayer M. Hieroninus D. Martin R. Dieterich J. Vinquist R. Bowser S. Crunk J. Reese P. Herbert G. Paptaun {

T. Peterson M. Price W. Hartley R. Lawrence F. Kellie M. Nickerson G. Cranston T. D'Angelo B. Kemper B. Harrington J. Delezenski R.sRoehler

  • J. Sullivan H. Storey s-

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