ML20205K104

Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will State That If Site Executive Officer Is Unavailable,Responsibilities Will Be Delegated to Another Staff Member,In Writing

ML20205K104
Person / Time
Site:	FitzPatrick
Issue date:	04/05/1999
From:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20205K103	List: JPN-99-011, Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing ML20205K104 ML20205K109
References
NUDOCS 9904120329
Download: ML20205K104 (11)

Text

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of )

POWER AUTHORITY OF THE STATE OF NEW YORK ) Docket No. 50-333 l

James A. FitzPatrick Nuclear Power Plant )

i APPLICATION FOR AMENDMENT TO OPERATING LICENSE l Pursuant to Section 50.90 of the regulations of the Nuclear Regulatory Commission (NRC), the Power Authority of the State of New York, as holder of Facility Operating License No. DPR-59, hereby applies for an Amendment to the Technical Specifications contained in Appendix A and Appendix B of the license.

This application for amendment seeks to revise Appendix A (Section 6.1) and Appendix B (Section 7.1) of the James A. FitzPatrick Technical Specifications. These changes will remove the position title of General Manager from these sections and will state that if the Site Executive Officer is unavailable, he will delegate his responsibilities to another staff member, in writing. In addition, the position title of Resident Manager, used in Appendix B, Section 7.1, will be replaced by Site Executive Officer.

The proposed changes to the Technical Specifications are included as Attachment I to this l application. The Safety Evaluation is included as Attachment 11.

l POWER AUTHORITY OF THE STATE OF NE YORK

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ATTACHMENT I TO JPN-99-011 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING ADMINISTRATIVE CONTROLS (JPTS-99-002) i i

NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT l l

DOCKET NO. 50-333 DPR-59 i

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JAFNPP 6.0 ADMINISTRATIVE CONTROLS Administrative Controls are the means by which plant operations are subject to management control. Mearures specified in this section provide for the assignment of responsibilities, plant organization, staffing qualifications and related requirements, review and audit mechanisms, procedural controls and reporting requirements. Each of these measures are necessary to ensure safe and efficient facility operation.

6.1 RESPONSIBILITY l The Site Executive Officer is responsible for safe operation of the plant and shall delegate in writing the succession to this responsibility during his absence.

6.2 ORGANIZATION 6.2.1 Facility Manaaement and Technical Suonort 1

Onsite and offsite organizations shall be established for plant operation and corporate management, respectively. The onsite and offsite organizations shall include the j positions for activities that affect the safety of the nuclear power plant.

l 1. Lines of authority, responsibility, and communication shall be established and defined l for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be oocumented and updated, as appropriate, in the form of organization charts, functional descriptions of department responsibilities and relationships, and job descriptions for key personnel l positions, or in equivalent forms of documentation. These requirements shall be

documented in the Updated FSAR.

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! 2. The Site Executive Officer shall be responsible for overall plant operation, and shall l have control over those onsite activities that are necessary for safe operation and l main'.anance of the plant.

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3. The Chief Nuclear Officer shall take any measures needed to ensure acceptable '

performance of the staff in operating, maintaining, and providing technical support to  ;

l the plant to ensure nuclear safety. I

4. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

l 6.2.2 Plant Staff 1

The plant staff organization shall be as follows:

1. Each shift crew shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; Amendment No. - 50, 60, 78, l ' 1,130,137, ' 78, 203, 220, 2287 247 i

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, JAFNPP 7.0 ADMINISTRATIVE CONTROLS j 7.' 1' RE$PONSIBILITY I

a. The Site Executive Officer shall have direct responsibility for assuring the operation of l the James A. FitzPatrick Plant is conducted in such a manner as to provide continuing protection to the environment and shall delegate in writing the succession to this responsibility during his absence.

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b. Implementation of the Radiological Effluent Technical Specifications is the responsibility of the General Manager - Operations, with the assistance of the plant staff organization.

7.2 PROCEDURES Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5

" Facility Administrative Policies and Procedures" of ANSI 18.7-1972 and Regulatory Guide 1.33, November 1972, Appendix A. In addition, procedures shall be established, implemented and maintained for the PCP, ODCM, and Quality Control Program for effluent and environmental monitoring using the guidance in Regulatory Gu ds 4.1, Revision 1.

7.3 REPORTING REQUIREMENTS

a. Planned Liauid and Gaseous Releases The limits for radioactive materials contained in liquid and gaseous effluents are l contained in Specifications 2.3,3.3 and 3.4. I

b. Environmental Samoles Exceedina Limits of Table 6.1-2 When the limits of Table 6.1-2 are exceeded, refer to Specification 6.1.b for reporting I requirements.

c. Semiannual Radioactive Effluent Release Report Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year. The period of the first report shall begin with the date of initial criticality.

1. The Radioactive Effluent Release Report shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit l

using as guidance Regulatory Guide 1.21, Revision 1, June 1974, " Measuring, Ewaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", with data summarized on a quarterly basis following the format of Appendix B thereof.

Amendment No. 03, 203, 65 i

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• 9 ATTACHMENT 11 TO JPN-99-011 SAFETY EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING ADMINISTRATIVE CONTROLS (JPTS-99-002)

NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59

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i Attachment ll j JPN-99-011 Page 1 of 5 1

SAFETY EVALUATION RELATED TO PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING ADMINISTRATIVE CONTROLS (JPTS-99-002)

Section 1 - Description of Channes This application for amendment setAs to revise Appendix A (Section 6.1) and Appendix B (Section 7.1) of the James A. FitzPatrick Technical Specifications (TS). These changes will remove the stipulation that if the Site Executive Officer (SEO) is unavailable, one of the dyee General Managers will assume his responsibilities. Instead, the TS section will say that the SEO will delegate, in writing, the succession of his responsibilities during his absence. In addition, the position title of Resident Manager, used in Appendix B, Section 7.1, will be replaced by Site Executive Officer. The specific TS changes are as follows.

Appendix A. Section 6.1 Replace:

"The Site Executive Officer is responsible for safe operation of the plant. During periods when the Site Executive Officer is unavailable, one of the three General Manager will assume this responsibility. In the event all four are unavailable, the Site Executive i Officer may delegate this responsibility to other qualified supervisory personnel."

With:

"The Site Executive Officer is responsible for safe operation of the plant and shall i delegate in writing the succession to this responsibility during his absence."

Appendix B. Section 7.1 Replace:

"The Resident Manager shall have direct responsibility for assuring the operation of the James A. FitzPatrick Plant is conducted in such a manner as to provide continuing i protection to the environment. During periods when 'e Resident Manager is unavailable, onc of the three Generall&nagers w. .:ume his responsibility. In the event all four are unavailable, the Resident Manager may delegate this responsibility to other qualified supervisory personnel."

With:

l "The Site Executive Officer shall have direct responsibility for assuring the operation of the James A. FitzPatrick Plant is conducted in suc5 a manner as to provide continuing

( protection to the environment and shall delegate in writing the succession to this I responsibility during his absence."

i Attachment 11 JPN-99-011 Page 2 of 5 Section ll- Purpose of Proposed Channes The proposed changes model the General Electric Standard Technical Specifications (NUREG-1433) and will allow the SEO to delegate his responsibilities to qualified personnel without specifying their position titles in Section 6.1 of TS Appendix A or Section 7.1 of TS Appendix B.

Section ill - Safety implications of the Proposed Chanaes This proposed amendmer't request revises Appendix A (Section 6.1) and Appendix B .

(Section 7.1) which discuss the delegation of the SEO's responsibilities in his absence.

Currently, these specifications state that the SEO will delegate his responsibilities to one of the l

I General Managers if he is unavailable. If the SEO and General Managers are unavailable, then the SEO may delegate his responsibilities to other qualified supervisory personnel.

The current wording ithe TC does not allow the SEO to delegate his responsibilities to t!

Plant Manager (a newly created management position) unless all three General Managers se also unavailable. Since the Plant Manager is the second highest level of management at the plant and the General Managers report to him, the Plant Manager should be permitted to undertake the SEO's responsibilities,in his absence, regardless of the availability of the General Managers. Therefore, this amendment request eliminates the specific reference to the General Manager positions in Appendix A (Section 6.1) and Appendix B (Section 7.1) and allows the SEO to delegate, in writing, his responsibilities to a qualified personnel member, such as the Plant Manager.

This TS change does not change the intent of the current specifications, in that the Plant Manager or other qualified personnel, such as one of the General Managers, will assume the responsibilities of the SEO in his absence. However, it eliminates the need for future TS amendments to these sections based solely on organizational changes such as the creation of '

new or revised management positions (such as the Plant Manager), title changes to the position of General Manager, or a change to the number of General Managers. These types of organizational changes can then be evaluated through the use of 6he 10 CFR 50.59 process, rather than the TS amendment process. This will reduce the unnecessary burden on NRC and licensee resources associated with processing license amendment requests related to these areas. This TS change models the comparable administrative controls section of the General Electric Standard Technical Specifications (b"' REG-1433).

The changes to Appendix B (Section 7.1) also include the replacement of the position title of Resident Manager with Site Executive Officer. This position title change was approved by the NRC in Amendment 228 (Reference). However, the reference to Resident Manager in this section was inadvertently missed and is being corrected as part of this amendment application.  !

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l 1-Attachment ll JPN-99-011 Page 3 of 5 Section IV - Evaluation of No Sionificant Hazards Consideration Consistent with the criteria of 10 CFR 50.92, the enclosed application is judged to involve no signincant hazards based on the following information:

(1) Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously ar.alyzed?

Response

The proposed changes to Appendix A (Section 6.1) and Appendix B (Section 7.1) are administrative in nature in that they do not change the intent of the Technical Specifications. If the SEO is unavailable, he will still delegate his responsibilities to a qualified personnel member, such as the Plant Manager or one of the General Managers. These changes can not cause an accident or contribute to the probability or consequences of one.

The replacement of the position title of Resident Manager with Site Executive Officer in Appendix B, Section 7.1, was already approved by the NRC in Amendment 228.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously analyzed.

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

Response:  ;

The proposed changes to Appendix A (Section 6.1) and Appendix B (Section 7.1) are administrative in nature as they do not affect the function of plant equipment or the way the equipment operates. The changes do not change the intent of the current TS, in that if the SEO is unavailable, he will delegate his responsibilities to another personnel member such as the Plant Manager or one of the General Managers. Appendix A (Section 0.1) and Appendix B (Section 7.1) are being revised to eliminate the need for future TS changes to these sections resulting solely from the creation of new or revised management positions (such as the Plant Manager), title changes to the position of General Manager, or a change to the number of General Managers. These types of crganizational changes will be evaluated using the criteria of 10 CFR 50.59.

The replacement of the position title of Resident Manager with Site Executive Officer in l

l Appendix B, Section 7.1, was already approved by the NRC in Amendment 228.

Therefore, the proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. j

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i Attachment 11 JPN-99-011 Page 4 of 5 l

(3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response

The proposed changes to Appendix A (Section 6.1) and Appendix B (Section 7.1) are

! administrative changes associated with the delegation of the SEO's responsibilities

when he is unavailable. These changes do not change the intent of the current TS, in that in the SEO's absence, he will still delegate his responsibilities to other personnel members such as the Plant Manager or General Mnnagers.

The replacement of the position title of Resident Manager with Site Executive Officer in Appendix B, Section 7.1, was already approved by the NRC in Amendment 228.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Section V -Implementation of the Proposed Chanees This amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows:

(i) the amendment involves no significant hazards consideration.

As dertirestrated in Section IV of this evaluation, the proposed change involves no significant hazards consideration.

(ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes do not involve a physical alteration to the plant or revisions to any plant operating procedures. The changes are administrative in nature and do not affect the amounts of any effluents that may be released offsite.

l (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

The propo md changes do not alter plant operating or surveillance procedures, and therefore will not change individual or cumulative occupational radiation exposure.

Based on the above, it is concluded that there will be no impact on the environment resulting from the proposed changes and the proposed changes meet the criteria specified in 10 CFR i

51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a L

specific environmental assessment by the Commission. Additionally, implementation of the proposed changes will not adversely alter or affect the ALARA program or the Fire Protection Program.

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l Attachment II JPN-99-011 Page 5 of 5 Section VI - Conclusion Based upon the discussion in previous sections, the changes to Appendix A, Section 6.1 and Appendix B, Section 7.1 are administrative in nature as they do not change the intent of the current Technical Specifications.

The Plant Operating Review Committee (PORC) and Safety Review Committee (SRC) have reviewed these proposed changes and have concluded that the changes do not involve an unreviewed safety question or a significant hazards consideration as defined in 10 CFR 50.92, and do not endanger the health and safety of the public.

Section Vil- Reference NRC letter (Amendment 228), C. Carpenter to W. Cahill, Jr., " Issuance of Amendment for James A. FitzPatrick Nuclear Power Plant," dated October 13,1995.

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l ATTACHMENT lil TO JPN-99-011 MARK-UP OF TECHNICAL SPECIFICATION PAGES REGARDING ADMINISTRATIVE CONTROLS (JPTS-99-002)

NOTE 1: Deletions are shown in Str?.cret, and additions are shown in bold.

l NOTE 2: Previous amendment revision bars are not shown.

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I NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 j DPR-59 l 1

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