ML20195J126

Provides Addl Info Re Proposed Changes to Tech Spec Section 7, Administrative Controls, in Response to .Util Eliminated Position of Superintendent of Training, Results I&C Supervisor & Shift Supervisor Training

ML20195J126
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/23/1988
From:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
P-88212, TAC-67407, NUDOCS 8806290058
Download: ML20195J126 (3)

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O Public June 23, 1988 Service ~ Company of Colorado

$,nj,7c h e Fort St. Vrain Unit No. 1 R.O. WILLIAMS, JR.

vtcE PRESIDENT P-88212 NUCLEAR OPERATIONS U. S. Nuclear Regulatory Commission ATTN: Docu;nent Control Desk Washington, D.C. 20555 Attention: Mr. Jose A. Calvo Director, Project Directorate IV Docket No. 50-267

SUBJECT:

Additional Information on Proposed Changes to Section 7 of the FSV Technical Specifications

REFERENCES:

1) PSC Letter, Williams to Calvo, dated 2/5/88 (P-88053)

2) NRC Letter, Heitner to Williams, dated 5/24/88 (G-88183)

Dear Mr. Calvo:

This letter provides additional information as requested in Reference 2 and concerns PSC's submittal (Reference 1) of the proposed changes to Section 7, Administrative Controls, of the FSV Technical Specifications.

NRC Comment #7 l

Figure 7.1-2 Fort St. Vrain Conduct of Operations Chart l

FSV has eliminated the position of (1) Superintendent of Training, (2) Results I&C Supervisors, (3) Shift Supervisor Training, and (4)

Superintendent Scheduling Planning and Stores, We find the elimination of the positions of Superintendent of Training and Shift Supervisor Training acceptable as the training function is now under the new position of Nuclear Training Manager (see 1. above). We find the elimination of the position of Superintendent Scheduling Planning and Stores acceptable as we do not opl require that function to be a part of Figure 7.1-2. We find the  !

elimination of the Results I&C Supervisors not acceptable without a description as to how that function will be accomplished. ,

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'P-88212 Juno 23, 1988 PSC Response The Results I&C Supervisor position will continue in the actual FSV Nuclear Production Division Organization. The functions that would have been accomplished as a PORC Member are being fulfilled by the Superintendent of Nuclear Betterment Engineering and/or the Results Engineering Supervisor, both of whom are on the PORC Membership list and meet the requirements of ANSI 18.1, 1971.

The proposed changes (Reference 1) would be in accordance with planned PORC Membership reduction for the sake of enhanced continuity and as requested in NRC Letter, Heitner to Williams, dated 12/5/86.

NRC Comments #9, 10 Section 7.4.b. - Procedures FSV has revised the pr visions for review and approval of procedures to allow their review by a PORC subconnittee and subsequent approval by appropriate management prior to implementation.

We find this requested change unacceptable unless the Safety Evaluation for the change to the procedures are reviewed by the PORC and the procedures are approved by a manager predesignated in writing by the Station Manager.

Section 7.4.c. - Temporary Changes to Procedures FSV has revised the provisions for the review and approval of temporary changes to procedures to allow the changes to be reviewed by a subcommittee of the PORC and subsequent approval by the appropriate management.

We find the requested change unacceptable unless the Safety Evaluation for the change to the procedures is reviewed by the PORC and approved by a Manager predesignated in writing by the Station Manager.

l PSC Response I The approval of procedures and approval of changes to procedures will

not be changed by this amendment proposal. The purpose of the is to perform preliminary reviews and make subcommittees This recommendations to PORC prior to the procedures going to PORC.

will allow PORC to concentrate on the safety issues involved with the procedure change, if any. All procedures referenced in the Technical l

l Specifications AC 7.4.b and AC 7.4.c will continue to be reviewedG-2, by PORC and approved in accordance with Administrative Procedure FSV Procedure Systems, and Technical Specification AC 7.1.2.5.a.

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PSC considers that the subject areas in question will require further

' discussion with the NRC, including clarification of the extent to which Safety Evaluations are performed for procedure changes. In l many cases, procedures being revised are not described in the FSAR and do not involve safety concerns and, therefore, do not require a l

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P-88212 June 23, 1988 Safety Evaluation to be performed. It is possible that a revised Technical Specification amendment request may be necessary.

PSC has recently undergone a reorganization, therefore further changes to Section 7 will be required. Among the changes will be a proposal to eliminate the organization charts (NRC Generic Letter 88-

06) from the Technical Specifications and incorporate them in the FSAR, which is updated annually. Until such time as a new amendment proposal can be processed, PSC intends to pursue NRC approval of the existing amendment request.

If you have any questions regarding this infomation, please contact Mr. M. H. Holmes at (303) 480-6960.

Very truly yours,

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b R. O. Williams, Jr.

Vice President, Nuclear Operations R0W/DLF/Imb cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westeman, Chief Project Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain Albert J. Hazie Colorado Department of Health