ML20195H636

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Proposed Tech Specs,Deleting Figures 3.1 & 3.2 from Unit 1 Tech Specs & Figures 6.2.1 & 6.2.2 from Unit 2 Tech Specs Per Guidance of Generic Ltr 88-06
ML20195H636
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/30/1988
From:
CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML20195H600 List:
References
GL-88-06, GL-88-6, NUDOCS 8806280332
Download: ML20195H636 (11)


Text

Attachment A Technical Specification Page Revision 1

Consolidated Edison Company of New York, Inc.

Indian Point Units No. 1 and 2 Docket Nos. 50-03 and 50-247 June, 1988 P

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. I LIST OF FIGURES I

Ti t19. Fin. No. I Four Loop Operation Safety Limits - 100% Flow 2.1 1 Three Loop Operation Safety limits - 73% Flow 2.1-2 PORV Opening Pressure for Operation Less Than or Equal to 2950F 3.1.A-1 Maximum Pressurizer Level with PORVs Inoperable and One Charging Pump Energized 3.1.A-2 q Maximum Reactor Coolant System Pressure for Operation With PORVs Inoperable and One Safety Injection Pump and/or Three Charging Pumps Energized 3.1.A-3 Indian Point Unit No. 2 Coolant Heatup Limitations Applicable for Periods up to 15 Effective Full Power Years 3.1.B-1 Indian Point Unit No. 2 Coolent Cooldown Limitations Applicable for Periods up to 15 Effective Full Power Years 3.1.B-2 Limiting Fuel Burnup versus Initial Enrichment 3.8-1 Required Hot Shutdown Margin versus Reactor Coolant Boron Concentration 3.10-1 Hot Channel Factor Normalized Operating Envelope 3.10-2 Rod Bank Insertion Limits, Four-Loop Operation 100 Step Overlay 3.10-3 Rod Bank Insertion Limits, Three-Loop Operation 100 Step Overlay 3.10-4 Target Band on Indicated Flux Difference as a Function of Operating Power Level 3.10-5 Permissible Operating Band on Indicated Flux Difference as a Function of Burnup 3.10-6 Indian Point Unit No. 2 Vessel Leak Test Limitations Applicable for Periods up to 15 Effective Full Power Years 4.3-1 Map Defining Unrestricted Areas for Radioactive Gaseous and Liquid Effluents 5.1-1 viii Amendment No.

6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Vice President-Nuclear Power shall be responsible for overall facility activities and shall delegate in writing the succession to this responsibility during his absence.

6.1.2 The General Manager-Nuclear Power Generation shall be responsible for facility operations and shall delegate in writing the succession to this responsibility during his absence.

6.2 ORGANIZATION 6.2.1 Facility Management and Technical Sunnnrt Onsite and offsite organizations 'shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant,

a. Lines of authority, responsibility, and communication shall be established and definad for the highest management levels through intermediate levels to and including all operating organization positions. Thece relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, a
  • job descriptions for key personnel positions, or in equivalent forms of documentation. These cequirements shall La documented in the Updated FSAR
b. The General Manager-Nuclear Power Generation shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of l the plant.
c. The Vice President-Nuclear Power shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

Amendment No. 6-1

4 d.

The individuals who trc.in the operating staff and those who cttry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient orgaaizational freedom ta ensure their independence from operating pressures.

6. 2.2 Facili ty Staff
a. Each on duty shift shall be composed of ac least the minimum shift crew composition shown in Table 6.2-1.

b.

At least one licensed Opocator shall be in the control room when fuel is in the reactor,

c. At least two licensed Operators shall be present in the control room during reactor startup, scheduled reactor shutd.;wn, and during recovery from reactor trips, d.

An individual qualified in radiation protection procedures shall be onsite whon fuel is in the reactor.

e.

ALL CORE ALTERATIONS af ter the initial fuel loading shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling. This individual shall have no other concurrent resronsibilities during

this cperation.

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l Amendment No. 6-2 i

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P f.

A Fire Brigade of at least five members shall' be maintained on-site'at all times.* This excludes four. members of. the minimum shif t crew necessary 'for safe shutdown of the' plant.and any personnel required for other essential functions during a fire emergency. . During periods of cold shutdown, the Fire Brigade will exclude two members of: the minimum shift crew.

g. Administrative' procedures shall be' developed and implemented to limit the working hours of unit staff .who perform safety-related functions (e g. , licensed Senior Operators, licensed Operators, health physicists, auxiliary operators,.and key maintenance personnel).

The amount of overtime worked by unit staff members performing safety related functions shall be limited in accordance with the NRC Policy Statement on working hours (Generic Letter No. 82-12).

h. The Operations, Manager shall hold a senior reactor operator license.

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t Fire Brigade composition may be one member less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of Fire Brigade members provided immediate action is taken to restore the Fire Brigade to within the minimum requirements.

Amendment No. 6-3

6 3.0 Administrative and Procedural Safeguards 3.1- Organizatioa 3.1.1 Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear power plant,

a. Lines of authority, responsibility, and communication shall established and defined for the highest management levels through, intermediate levels to. and including all operating organization' positions. These relationships shall be documented a'nd updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or .in equivalent forms of documentation. These requirements shall be documented in the Updated FSAR.
b. The General- Manager-Nuclear Power Generation shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. He shall delegate in writing the succession to this responsibility during his absence,
c. The Vice President-Nuclear Power shall have corporate responsibility for overall plant nuclear safety and shall

'- take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. He shall delegate in writing the succession to this responsibility during his absence, f

d. The individuals who train the operating staff and those who l

carry out health physics and quality assurance functions may

l. report to the appropriate onsite manager; however, they

[. shall have sufficient organizational freedom to ensure their l

independence from operating pressures.

l: e. The operation of the facility, the operating organization, the procedures for operation, and modifications to the facility shall be subject to review by the Station Nuclear Safety Committee. The committee shall report to the Vice

j. President, Nuclear Power.

l f. The Nuclear Pacilities Safety Committee shall function to l provide independent review and audit of designated activities

[. in areas of nuclear engineering, chemistry, radiochemistry, l metallurgy and non-destructive testing, instrumentation and Amendment No.

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control, radiological safety, mechanical and electrical engineering, administrative controls and quality assurance practices, and radiological environmental effects,

g. All fuel handling shall be under the direct supervision of a licensed operator.*
h. The Support Facilities Supervisor is responsible for operations at the Unit No. I facility.
i. The Operations Manager shall hold a senior reactor operator license.

3.2 Operating Instructions and Procedures i

3.2.1 No fuel will be loaded into the reactor core or moved into the reactor containment building without prior review and authorization by the Nuclear Regulatory Commission.

3.2.2 Detailed written instruction setting forth procedures used in connection with the operation and maintenance of the nuclear power plant shall conform to the Technical Specifications.

3.2.3 Operation and maintenance of equipment related to safety when there is no fuel in the reactor shall be in accordance with written instructions.

  • Licensed operator for IP-1 or IP-2 l

Amendment No.

Attachment B Safety Assessment Consolidated Edison Company of New York, Inc.

Indian Point Units No. 1 and 2 1 Docket Nos. 50-03 and 50-247 June, 1988

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SAFETY ASSESStriT r

Discussion:

Proposed changes to the Indian- Point Unit No . _ 1 and 2 Technical

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Specifications are set forth in Attachment A to .this application. These changes .are responsive to the Commission's encouragement expressed in Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements, issued on March 22, 1988. Con' Edison ' has, as suggested, followed the guidance provided in Enclosures 1 and 2 to GL 88-06.

The fundamental safety issue in this license amendment request is whether there can be reasonable assurance that the organization will operate the plant ' safely and remain effective without requiring prior staff approval for changes reflected in the organization charts.

The Commission staff, in Enclosure 1 to GL 88-06, has concluded that the details shown on the on-site and off-site organization charts are not essential to the safe operation of the facility. Con Edison concurs with this determination since these organization charts, to' the same level of' detail as currently exists in the Technical Specifications, will be included in the Final Safety Analysis Report for Indian Point Unit No. 2 in the next annual update scheduled for submitte1 prior to June 30, 1988 and all future changes to the organization charts will be assessed with a safety evaluation per 10 CFR 50.59. The only aspects of the organization charts which may be considered safety-significant and that will be included in the Technical Specifications are the conditions listed belows (1) A requirement that lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shal) be documented and updated, as appropriato, in the form of organization charts, functional descriptions of departnental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. (Con Edison will utilize the IP-2 FSAR for these purposes)

(2) Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority _ to take such measures as may be needed _to ensure acceptable performance of staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. (At Con Edison this position is the Vice President, Nuclear Power)

(3) Designation of a management position in the onsite organization that is responsible for overall unit operation and has control over those onsite activities necessary for safe operation and maintenance of the plant. (At Con Edison, this position is the General Manager, Nuclear Power Generation) l l

(4) Designation of those positions in the on-site organization that require a senior reactor . operator (SRO) .or reactor operator (RO) license. (At Con Edison, the Operations Manager is required to hold an SRO license)

-(5). Provisions of sufficient organizational freedom to be independent of operational pressures to those individuals who perform the fun:tions of health physics, quality assurance, and training of the operating staff.

Note ~ that the format of the Indian Point Unit No. 1 Technical Specifications in this area is somewhet different from that of Unit No. 2.

However, for each Unit's proposed changes herein, nothing has been deleted except the organization charts in Figures 3.1 and 3.2 for Unit No. 1 and in Figures 6.2.1 and 6.2.2 for Unit No. 2 and references to them. In both cases, those additions recommended 'in Enclosure 2 of GL 88-06 have been proposed in this application.

Basis for No Significant Hazards Consideration Determination The Commission has provihd standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. The enclosed application has been deemed not to involve a significant hazards consideration based on the following information in response to those standards.

1. Does the proposed license amendment involve a significant increase '"

the probability or consequences of an accident previously evaluated?

The deletion of the organization charts from the Technical Specifications does not effect plant operation nor does it affect any previously performed accident analysis since no change in the corporate or facility crganization is i ,olved. The organization charts, to the same lev el of ' detail is currently exists in the Technical Specifications, are to be included in the Final Safety Analysis Report via the next annual update to that document scheduled to be submitted to the Commission prior to June 30, 1998. Future annual updates to the FSA will include any relevant changes to those organization charts. Therefore, this proposed change does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create he possibility of a new or different kind of accident from any accident previously evaluated?

The deletion of the organization charts from the Technical Specifications is an administrative change in nature. No physical alterations of plant configuration or changes to setpoints, operating parameters, etc. are being proposed. The corporate or facility organizations are not being changed by reason of this app 13'ation.

The charts depicting these organizations are simply proposea to be deleted from the Technical Specifications and will be included in the updated Final Safety Analysis Report. Therefore, this proposed change does not create the possibility of a new or different kind of accident.

3. Does the proposed amendment involve a- significant reduction in a margin of safety?

We deletion of the organizational charts frcm the Technical' Specifications involves no plant cperating or configurational changes.

The organization- charts will be maintained .in the annually updated Final Safety Analysis Report. Any potential effect on the margin of safety due to future organization changes will be addressed via the efety evaluation process of 10 CFR 50.59. Werefore, this currently 1roposed change does not involve a significant reduction in the margin of safety.

We Ccomission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain exanples (48 FR 14870) of amendments that are considered not likely to' involve significant hazards considerations.

Exanple (i) relates to a purely administrative change to Technical Specifications: for exanple, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in ncmenclature.

In this case, the proposed change described in Attachments A are related to Exanple (i) , i.e. , a purely administrative change.

%erefore, since the application for amendment involves a proposed change that is siInilar to an example for which no significant hazards consideration exists, we have determined that the application involves no significant hazards consideration. We proposed changes have been revirwed by the Station Nuclear Safety Ccumittee and the Nuclear Facility Safety Ccomittee.

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