ML20205E979

Application for Rev 1 to Proposed Amend 138 to License DPR-54,changing Corporate Organizations That Provide Support to Nuclear Safety & Revising Complement of Shift Crew Personnel for Compliance w/10CFR50.54(m)(2)(i)

ML20205E979
Person / Time
Site:	Rancho Seco
Issue date:	08/12/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML20205E985	List: ML20205E979 ML20205E992
References
JEW-86-322, TAC-60162, NUDOCS 8608190055
Download: ML20205E979 (9)

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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, PO. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JEW 86-322 August 12, 1986 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION FRANK J MIRAGLIA DIRECTOR PWR-B DIVISION U S NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET N0. 50-312 LICENSE N0. DPR-54 PROPOSED AMENDMENT NO. 138, REVISION 1 In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend its Operating License DPR-54 for Rancho Seco Nuclear Generating Station Unit No. 1.

Proposed Amendment No. 138, Revision 1 supersedes the originally Proposed Amendment No. 138 submitted to the NRC on October 16, 1985. Subsequent to the original submittal, there have been organization changes made by the District, both on site and at the corporate offices. This proposed amendment presents the Rancho Seco organization changes to date, and also identifies current corporate organizations that provide support to nuclear safety for Rancho Seco. Additionally, the complement of shift crew personnel is revised for compliance with 10 CFR 50.54(m)(2)(i). Details of this proposed amendment are provided in Attachments I, II and III, which are the Description of and Reason for Proposed Changes, the Safety Analysis, and No Significant Hazards Consideration, respectively.

The proposed changes are exclusive to Appendix A of the Technical Specifications.

Although the same organization changes are applicable to Appendix B, no amendment is proposed pending completion of NRC's review of Proposed Amendment No. 102 (December 12,1984), which requests deletion of Appendix B in its entirety from the Technical Specifications.

Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services 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 since a check for $150.00 was sent to the Commission with the initial submittal of Proposed Amendment No. 138.

The District would appreciate prompt review of this proposed amendment by the NRC, and upon issuance allow 90 days for implementation.

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Should you require any further information with respect to this revised proposed amendment, please contact Mr. Ron W. Colombo at Rancho Seco Nucl Generatin ta ion Unit 1.

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. Wird DEPUTY GENERAL MANAGER, NUCLEAR Attachments Subscribed and sworn to before me this 12 % day of Auo ost,' 1986.

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ATTACHMENT I DESCRIPTION OF AND REASONS FOR PROPOSED CHANGES Proposed Amendment No.138, Revision 1, supersedes the original submittal of Proposed Amendment No. 138 on October 16, 1985,'and consists of organization changes with respect to Rancho Seco made by the District subsequent to the original submittal. Specifically, the following changes to the Technical Specifications are proposed:

1. The title for Figure 6.2-1 is changed on the Table of Contents, List of figures, page xii. See item 5 for details.

2. Throughout the Technical Specifications, position and group titles are changed or added as shown in Figures 6.2-1 and 6.2-2. The title changes are considered more descriptive of the management function, and the new positions reflective of the broader management oversight with respect to Rancho Seco.

3. The staff individual's qualifications identified in Specification 6.2.2d.

(page 6-1) is expanded to include radiation protection practices as well as procedures, and in Specification 6.2.2g. (page 6-1a), the term " health physicists" is changed to " radiation protection personnel". The first change adds to the individual's qualification requirement; the second is the result of a title change.

4. Table 6.2-1, Shift Crew Personnel and License Requirements, (page 6-2) is revised to be in accord with 10 CFR 50.54(m)(2)(i).

5. Figure 6.2-1, SMUD Nuclear Safety Organization Chart, (page 6-2a) is retitled to SMUD Corporate Support of Nuclear Safety to Rancho Seco. Accordingly, many of the corporate organizations which do not provide routine nuclear safety support of the plant are deleted. This simplification of Figure 6.2-1 is in agreement with the Standard Technical Specifications. The revised title of Figure 6.2-1 is also shown on the Table of Contents, List of Figures (page xii).

6. Figure 6.2-2, Plant Organization Chart (page 6-2b) is amended to show the revised and new positions and organization titles. Also, shift crew personnel and their license requirements are deleted, being redundant with Table 6.2-1. The footnote " Routine Reporting Requirements on Personnel Changes" and the designations on the organization chart to which the footnote applies is replaced with a general footnote stating:

" Organization changes may be made per 10 CFR 50.59 without prior NRC approval."

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7. Specification 6.5.1, Plant Review Committee (PRC), (pages 6-3 through 6-5) is revised to reflect the currently proposed charter. Composition of the PRC is revised, and responsibilities are amended to specify review of procedures' safety evaluations rather than the total procedures (Specification 6.5.1.6a).

A similar change is made with respect to proposed changes and modifications (Specification 6.5.1.6d). In addition, since the PRC reviews facility operations for potential safety hazards through routine review of design changes, procedure changes or violations, operating deficiencies, etc.,

Specification 6.5.1.6e and 6.5.1.6f are considered redundant and are deleted.

8. Specification 6.5.2, Management Safety Review Comittee, (pages 6-6 through 6-10a) is revised extensively to reflect the currently proposed charter.

Included in this is deletion of items a. through h., in Specification 6.5.2.1, Function, (page 6-6) and reference to listing of item a. through g. in Specification 6.5.2.7, Review, (pages 6-7 and 6-8). In Specification 6.5.2.3, it is made clear that the limitation on alternates is for the purposes of establishing a quorum. In addition, Specification 6.5.2.9, Records, is moved for editorial reasons to 6.5.2.8, and the forwarding of audit reports to the Deputy General Manager-Nuclear and to the General Manager is deleted. This is administratively made the responsibility of Nuclear Quality which also has the audit responsibilities. As revised, the MSRC reviews the QA program and does an oversight review of the QA Audit Program (see 6.5.2.7m and n).

9. Specification 6.5.2.8, Audits (page 6-9) is changed to Specification 6.5.4, which, in view of changes described in item 8 above, is a more appropriate location.

10. Specification 6.5.3, Technical Review and Controls, (pages 6-10 and 6-10a) is added in its entirety. This addition describes a new review and approval process for procedures, test and experiments, and plant modifications and describes overall responsibilities for these reviews which affect the safety of the plant. This change will broaden the safety review process and permit greater attention to detail in the performance of safety reviews. The PRC will maintain an oversight responsibility but will no longer be the sole safety review organization. The safety review process proposed in Specifica-tion 6.5.3 is consistent with the safety review process currently in use at several other licensed facilities.

11. Specification 6.8.2, (page 6-11), regarding temporary changes to procedures listed in Specification 6.8.1 is deleted in its entirety, being now addressed in the newly added Specification 6.5.3.

12. Cognizance of facility activities audits (Specification 6.5.4, formerly Specification 6.5.2.8) is made the responsibility of the Manager, Nuclear Quality rather than the MSRC as previously specified. The District considers this proposed change, placing cognizant responsibilities with the department performing the audits (Nuclear Quality) and oversight responsibilities with the MSRC (6.5.2.7m), a more efficient balance of management responsibilities with respect to audit coverage and performance.

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13. Specification 6.5.4.7 replaces existing Specification 6.5.2.9, and adds MSRC reporting requirements of Specification 6.5.2.7 reviews to responsible management. Sections 6.5.2.7e, f, g and h are excluded from such reporting by the MSRC since the immediacy of such events as significant Technical Specification violations, operating abnormalities, LERs and design or operating deficiencies would administratively result in earlier notification to the Deputy General Manager-Nuclear and the General Manager and staff by the affected department (s).

14. Specification 6.6.1 on LERs is edited slightly, and 6.6.1b is revised, deleting position titles and adding instead the MSRC which is made up of or reports to these previously listed positions.

15. Specification 6.8.2 is modified to eliminate redundancy with the newly introduced Specification 6.3.1, and for the same reason, Specification 6.8.3 is deleted.

16. Specification 6.9.3 is. changed to show the current NRC addresses to which monthly reports are submitted.

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ATTACl#ENT II SAFETY ANALYSIS Proposed Amendment No. 138, Revision 1, supersedes the original Proposed Amendment No. 138 submitted to the NRC on October 16, 1986. Both proposed amendments address the same topic, that of organization changes.

Subsequent to the original submittal, there have been organization changes made by the District, both on site and at the corporate offices, resulting

.in revised and new position titles and organization groups.

The proposed amendment will require changes to Chapter 12 of the USAR. These are administrative changes and do not change the intent of Chapter 12.

The proposed amendment updates and functionally enhances the following:

1. Table 6.2-1, Shift Crew Personnel and License Requirements expanded for compliance with 10 CFR 50.54(m)(2)(i).

2. The overall organization, position titles, responsibilities and PRC and MSRC composition based on the reorganization.

3. Actions and processes required for activities whichfd affect nuclear safety.

Specifically, Proposed Amendment 138, Revision 1, revises much of Section 6, Administrative Controls which describe or delineate the following:

1. the assignment of plant operating responsibilities;

2. the reporting chain up through the General Manager;

3. the organization of the plant staff;

4. the function and responsibilities of each major safety review committee;

5. the minimum shift crew complement, and

6. the qualification requirements for key members of the plant staff.

This safety analysis has reviewed the above items against:

10 CFR 50.36(c) iib (5), Administrative Controls; 10 CFR 50.4(b), Common Standards; 10 CFR 50.54(j) through (m), and

! NUREG 0737/1.A.1.1 and I.A.1.3.

On the basis of District reviews of the proposed changes against the above listed regulations, it is concluded that the proposed amendment is acceptable.

Acceptability of the proposed amendment delineating the revised operating organization is a significant input to the requirement that the District is technically qualified as required by 10 CFR 50.40(b); that adequate licensed l operators are available to meet the requirements of Section 50.54(j) through i (m); the adequacy of the on shift personnel to provide initial facility response l in the event of an emergency; organizational requirements for the Nuclear Plant Manager and Radiation Protection Superintendent; qualification requirements of the plant personnel in the USAR and safety review functions of the on and off site review conmittees. In addition, Rancho Seco complies with the requirements of TMI Action Plan items 1.A.1.1 and 1.A.1.3.

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ATTACHMENT III NO SIGNIFICANT HAZARDS CONSIDERATION Proposed Amendment No. 138, Revision 1, supersedes the originally submitted

, Proposed Amendment No. 138 sent to the NRC on October 16, 1986. Both proposed amendments address the same subject, that of organization changes. Revision 1 of the Proposed Amendment is submitted as a result of further changes to the organization made by the District subsequent to the original submittal.

Specifically, the proposed changes to the Rancho Seco Technical Specifications are as follows:

1. The title for Figure 6.2-1 is changed on the Table of Contents, List of Figures, page xii. See item 5 for details.

2. Throughout the Technical Specifications, position and group titles are changed or added as shown in Figures 6.2-1 and 6.2-2. The title changes are considered more descriptive of the management function, and the new positions reflective of the broader management oversight with respect to Rancho Seco.

3. The staff individual's qualifications identified in Specification 6.2.2d.

(page 6-1) is expanded to include radiation protection practices as well as procedures, and in Specification 6.2.2 9. (page 6-1a), the term " health-physicists" is changed to " radiation protection personnel". The first change adds to the individual's qualification requirement; the second is the result of a title change.

4. Table 6.2-1, Shift Crew Personnel and License Requirements, (page 6-2) is revised to be in accord with 10 CFR 50.54(m)(2)(i).

5. Figure 6.2-1, SMUD Nuclear Safety Organization Chart, (page 6-2a) is retitled to SMUD Corporate Support of Nuclear Safety to Rancho Seco. Accordingly, many of the corporate organizations which do not provide routine nuclear

! safety support of the plant are deleted. This simplification of Figure

! 6.2-1 is in agreement with the Standard Technical Specifications. The

revised title of Figure 6.2-1 is also shown on the Table of Contents, List of Figures (page xii).

l 6. Figure 6.2-2, Plant Organization Chart (page 6-2b) is amended to show the revised and new positions and organization titles. Also, shift crew personnel and their license requirements are deleted, being redundant with Table 6.2-1. The footnote " Routine Reporting Requirements on i Personnel Changes" and the designations on the organization chart to l which the footnote applies is replaced with a general footnote stating:

l " Organization changes may be made per 10 CFR 50.59 without prior NRC l

approval."

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. 7. Specification 6.5.1, Plant Review Committee (PRC), (pages 6-3 through 6-5) is revised to reflect the currently proposed charter. Composition of the PRC is revised, and responsibilities are amended to specify review of procedures' safety evaluations rather than the total procedures (Specification 6.5.1.6a).

A similar change is made with respect to proposed changes and modifications (Specification 6.5.1.6d). In addition, since the PRC reviews facility operations for potential safety hazards through routine review of design changes, procedure changes or violations, operating deficiencies, etc.,

Specification 6.5.1.6e and 6.5.1.6f are considered redundant and are deleted.

8. Specification 6.5.2, Management Safety Review Committee, (pages 6-6 through 6-10a) is revised extensively to reflect the currently proposed charter.

Included in this is deletion of items a. through h., in Specification 6.5.2.1, Function, (page 6-6) and reference to listing of item a. through g. in Specification 6.5.2.7, Review, (pages 6-7 and 6-8). In Specification 6.5.2.3, it is made clear.that the limitation on alternates is for the purposes of establishing a quorutn. In addition, Specification 6.5.2.9, Records, is moved for editorial reasons. to 6.5.2.8, and the forwarding of audit reports to the Deputy General Manager-Noclear and to the General Manager is deleted. This is administratively made the responsibility of Nuclear Quality which also has the audit responsibilities. As revised, the MSRC reviews the QA program and does an over sist review of the QA Audit Program (see 6.5.2.7m and n).

9. Specification 6.5.2.8, Audits (page 6-9) is changed to Specification 6.5.4, which, in view of changes described in item 8 above, is a more appropriate location.

10. Specification 6.5.3, Technical Review and Controls, (pages 6-10 and 6-10a) is added in its entirety. This addition describes a new review and approval process for procedures, test and experiments, and plant modifications and describes overall responsibilities for these reviews which affect the safety of the plant. This change will broaden the safety review process and permit greater attention to detail in the performance of safety reviews. The PRC will maintain an oversight responsibility but will no longer be the sole

! safety review organization. The safety review process proposed in Specifica-

l. tion 6.5.3 is consistent with the safety review process currently in use at several other licensed facilities.

f 11. Specification 6.8.2, (page 6-11), regarding temporary changes to procedures listed in Specification 6.8.1 is deleted in its entirety, being now addressed in the newly added Specification 6.5.3.

12. Cognizance of facility activities audits (Specification 6.5.4, formerly Specification 6.5.2.8) is made the responsibility of the Manager, Nuclear Quality rather than the MSRC as previously specified. The District considers this proposed change, placing cognizant responsibilities with

-the department performing the audits (Nuclear Quality) and oversight responsibilities with the MSRC (6.5.2.7m), a more efficient balance of management responsibilities with respect to audit coverage and performance.

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13._ Specification 6.5.4.7 reolaces existing Specification 6.5.2.9, and adds MSRC reporting requirements of Specification 6.5.2.7 reviews to responsible-management. Sections 6.5.2.7e, f, g and h are excluded from such reporting by the MSRC'since the immediacy of such events as Technical Specification violations, significant operating abnormalities, LERs and design or operating deficiencies would administratively result in earlier notification to the Deputy General Manager-Nuclear and the General Manager and staff by the affected department (s).

14. Specification 6.6.1 on LERs is edited slightly, and 6.6.1b-is revised, deleting position titles and adding instead the MSRC which is made up of or reports to these previously listed positions.

15. Specification 6.8.2 is modified to eliminate redundancy with the newly introduced Specification 6.3.1, and for the same reason, Specification 6.8.3 is deleted.

16. Specification 6.9.3 is changed to show the current NRC addresses to which monthly reports are submitted.

The District has reviewed the above changes and the reasons for them (Items 1 through 16) and concluded that all are purely administrative. With the exception of one change (Item 4, above), the proposed changes have no effect on plant design or operation. The exception, Item 4, which updates the shift crew personnel and license requirements on Table 6.2-1 affect plant operations, but in an enhancing manner.

The District has reviewed the proposed rr. organization changes against each of the criterion of 10 CFR 50.92 and concle.ded that plant operation with the proposed reorganization would not:

a. involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed reorganization is purely administrative which, with the exception of the increased shift crew personnel and license requirements, an enhancement, is judged to have no effect on plant design or operation. Accordingly, it is concluded that the proposed changes do not have any involvement with previously evaluated accidents.

b. create the possibility of a new or different kind of accident from any previously analyzed. For the reasons given in a.) above, it is concluded that the proposed changes do not introduce a new or different accident from any previously analyzed.

c ., involve a significant reduction in a margin of safety. As discussed above, the proposed changes have no effect on plant design and, with one exception, none also on plant operation. The one exception, which involves an increase in the quantity of shift crew oersonnel and their license requirements, is an enhancement to plant operations. None of the changes are seen as constituting a redaction in safety margins.

On the basis of the above, the District concludes that the proposed changes, purely administrative, do not constitute any significant hazards and in no way endanger the health and safety of the public.

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