ML20205C865
| ML20205C865 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/19/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20205C869 | List: |
| References | |
| GL-88-06, GL-88-6, WM-88-0276, WM-88-276, NUDOCS 8810270010 | |
| Download: ML20205C865 (8) | |
Text
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LF CREEK W@ NUCLEAR OPERATING l
Bert D. Whhers Pres.swa one cher esecuevo omeer October 19, 1988 l
WH 88-0276 l
l U. S. Nuclear Regulatory Comnission ATTN: Document Control Desk Mail Station P1-137 Vashington, D. C. 20555 Subject Docket tio. 50-482: Revision of Technical Specifications to Remove Organization Charts Figures 6.2 1 and 6.2-2 per l
Generic Letter 88-06 Gentlemen This letter transmits an application to amend Facility Operating License No.
NPF-42 for Wolf Creek Generating Station (WCGS),
Unit No.
1.
The arendment would revise the Administrative Controls section of the VCGS Technical Specifications by deleting Figures 6.2-1 and 6.2 2, the organization charts for the operating corporation organization and the unit organisation respectively. This request is in accordance with NRC Generic Letter 88-06,
' Removal of Organization Charts from Technical Specification Administrative Control Requirements'.
A Safety Evaluation and Significant Hazards Consideration Determination are provided as Attachments I and II.
The proposed changes to the Technical Specifications are provided as Attachment III.
L In accordance with 10 CFR 50.91, a copy of this application, with eno attachments is being provided to the designated Kansas state official.
58' Enclosed is a check (No.
2175) for the $150.00 application fee required by 10 Q
CFR 170.21.
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- enerating Station Technical
- c. x The proposed revision to the Wolf Creek X '=
Specifications will be fully implemented within 30 days of formal Nuclear Regulatory Commission approval.
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WH ss-0276 Page 2 of 2 October 19,19ss If you have any questions concerning this matter, please contact me or
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Mr. O. L. Haynard of my staff.
Very truly yours.
Et;.n i
- 3. D. Withers President and
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Chief Executive Of ficer BDW/jad f
Enclosure i
Attachments:
I - Safety Evaluation II - Significant Hazards Consideration Determination III - Proposed Technical Specification Changes I
cca G.
W. Allen (KDNE). w/a 4
3.
L. Bartlett (NRC), w/a D.
D. Chamberlain (NRC) w/a i
R.
D. Martin (NRC). w/a D.
V. Pickett (NRC), w/a (2) 4 l
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STATE OF KAIISAS
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) 33 COUllTY OP 00PPBY
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c Bart D. Withers, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer of Wolf Creek Nuclear Operating Corporations that he has read the foregoing document and knows the content thereof; that he has executed that same for and on behalf of said Corporation with full power and authority to do sol and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
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Bart D. Withers President and Chief Executive Officer i
i SUBSCRIBED and sworn to before me this //
day of M 1988.
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0 ATTACBENT I SAFETY EVALUATION l
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Attachment I to VM 88-0276 Page 1 of 2 October 19, 1988 SAFETY EVALUATION Description of Proposed Amend.aent The proposed amendment would remove the operating corporation and onsite organization charts (Figure 6.2 1 and 6.2 2) from Section 6 of the VCGS Technical Specifications and would incorporate essential organization requirements, such as lines of authority, responsibility, and communication.
The amendment would also make additional editorial changes to delete references to the removed organization charts. The proposed changes are in accordance with NRC Generic Letter 88-06, ' Removal of Organization Charts from Technical Specification Administrative Control Requirements'.
Reason For Proposed Amendment As discussed in Generic Letter 88-06, removal of organization charts from the Technical Specifications would have the benefit of permitting the implementation of changes to the structute of the operating corporation or onsite organization without first having to obtain NRC approval, through the license amendment process, to update the organization charts in the Technical Specifications.
In
- addition, this proposed change is consistent with Technical Specification improvement objectives endorsed by the NRC Interim Policy Statement on Technical Specification Improvement.
Safety Evaluation The rogulatory requirementf for Technical Specifications in 10 CFR Part 30.36 do not require that organization charts be included in the administrative controls section ut plant Technical Specifications. 50.36 requires that necessary organization and management be in place to assure safe operation of the plant. As long as the necessary administrative controls are in place, the presence or absence of organization charts does not affect safe plant operation.
To assure that the necessary administrative controls are available Generic Letter 88-06 identifies certain provisions that must remain in the Technical Specifications.
- 1) A requirement that lines of authority, responsibility, and communicatien shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions.
Those relationships shall be documented and updated, as appropriate, in the form of organization charts, function descriptions of departmental responsibilities and relationships, and job dercriptions for key personnel positions, or in equivalent forms of locumentation.
- 2) Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be teeded to ensure acceptable performance of staff in ope r a t ir.g.
maintaining, and providing technical support to the plant to ensure nuclear safety.
Attachment I to '/M 88 0276 Page 2 of 2 October 19, 1988 l
- 3) Designation of management position in the onsite organization that is responsible for overall unit operation and has control over those onsite f
activities necessary for safe operation and maintenance of the plant.
- 4) Designation of those positions in the onsite organization that require-a senior reactor operator ($R0) or reactor operator (RO) license.
- 5) Provisions of sufficisnt organisational freedom to be independent of operational pressures to those individuals who perform the functions of health physics, quality assurance, and training of the operating staff.
The proposed changes to the VCGS Technical Specifications reference Chapter 13 of the VCGS Updated Safety Analysis Report (USAR),
which contains the organizational information described in item 1 above, and address the remaining items 2 through 5.
Therefore, the required aspects of administrative controls will remain in the VCGS Technical Specifications: and removal of the organisation charts represents no reduction in safety commitments nor an adverse impact on a safe operation of VCGS.
Based on the above discussion, the proposed amendment would not increase the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously evaluated it the safety analysis reports or create a possibility of an accident or malfunction of a different type than any previously evaluated in the safety analysis reports or reduce the margin of 6afety as defined in the basis for any Technical Specification.
Therefore, the proposed changes do not adveraely affect or endanger public health and safety nor do they involve an unreviewed safety question.
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I ATTACMENT II SIGNIFICANT BAZARDS CONSIDEAATION DETERMINATION l
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Attachment II to VM 88-0276 Page 1 of 1 October 10. 1988 SIGNIFICANT narannS CONSIDERATION DETERMINATION The proposed amendment would remove the organization charts (Figures 6.2 1 and 6.2-2) from Section 6 of the VCGS Technical Specifications. 'the proposed amendment would also incorporate new requirements to assure that the essential organizational controls necessary to maintain safe operation of VCGS would remain in the Technical Specifications. VCNOC has reviewed the proposed changes and determined that:
- 1) The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed deletion of organisation charts does not affect facility design or operations. Additional Technical Specification requirements assure that the essential aspects of organizational structure remain in place in lieu of the organization charts. Therefore, the administrative controle essential for safe plant operation remain in affect under the proposed amendment. Also.
since the organisation charts will exist in other appropriate documents, i.e.
the VCGS Updated Safety Analysis Report, the proposed amendment is administrative in nature, because the changes do not
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affect the physical aspecte of the plant or equipment used for preventing or mitigating postulated accidents.
2)
The propused amendment does not cr6 ate the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes are administrative in natures no physical alterations to the plant or equipment or plant operations are proposed.
- 3) The proposed amendment does not invnive a significant reduction in a margin of safety.
Tne proposed Technical Specifications assure that the essential administrative controls remain in the Technical Specifications in place of the controls effected by the organization charts. Thus, no reduction in administrative controls commitments is involved.
Based on the above discussions and those presented in Attachment I.
It has been determined chat the requested Technical Specification revleions do not involve a significant increase in the probability or consequences of an j
accident or other adverse condition over previous evaluations:
or create the possibility of a new or different kind of accident over previoas evaluations:
or involve a significant reduction in a margin of safety.
Therefore.
the requested license amendment does not involve a significant hazards consideration.
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