ML20235A586
| ML20235A586 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/30/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20235A589 | List: |
| References | |
| CON-NRC-87-133 VPNPD-87-546, NUDOCS 8801120337 | |
| Download: ML20235A586 (6) | |
Text
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WISCONSIN Electnc powca couraur 231 W. MIChlGAN. P.O. BOX 2046, MILWAUKEE, WI 53201 (414) 7 2345 VPNPD-8 7-54 6 10 CFR 50.90 NRC-8 7 133 December 30, 1987 i
CERTIFIED MAIL i
U.S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D.C.
20555 I
Gentlemen:
DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATION CHANGE REQUEST 120 STAFF ORGANIZATIONAL CHANGES AND DELETION OF ORGANIZATION CHART _S POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.59 and 50.90, Wisconsin Electric Power Company (Licensee) hereby submits an.
application for amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2.
This-application proposes modifications.to Technical Specification (TS)
Section 15.6, " Administrative Controls," to document changes to the plant organizational structure.
The requested changes are numbered and listed below.
Proposed TS pages, with the changes identified by margin bars,.are.also' attached.
1.
The first proposed change is a deletion of Figure 15.6.2-1,
" Management Organization Chart," and Figure 15. 6. 2-2,
" Conduct of Plant Operations."
The'NRC staff has approved a similar change for the McGuire Nuclear Station, Units 1 and 2, on March 16, 1986.
The deletion of organization
,we charts from the Technical Specifications has also been endorsed by the Westinghouse Owners' Group as a lead
-l plant item.
Shearon Harris is the lead-plant for this item.
NS
- O The content of the Administrative Controls Section of the.
M Technical Specifications is specified in' 10 CFR. 50.36.c(5).
no This regulation requires that the Technical Specifications N
contain the controls and provisions that are'necessary to
}
Z assure operation of the facility in a safe manner.
The regu--
lation does not require inclusion of organization charts, om
@@r and we believe that the inclusion of organization charts in the Technical Specifications contributes little t ward achieving the intent of the regulation.
W T1Flep No.- M1YI
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bocument Control Desk December 30, 1987 Page 2 Maintaining these organization charts in the Technical Specifications has resulted in the Licensee's processing and the NRC's review of frequent license amendments for purely administrative purposes.
This necessitates a needless expenditure of resources for both organizations.
Deletion of the organization charts is in keeping with NRC and industry commitments to improve Technical Specifications and with the NRC Interim Policy Statement on Technical Specifications delineated in 52FR3788.
In accordance with 10 CFR 50.34 (b) (6) (i), the organizational structure of the Licensee is required to be included in the Final Safety Analysis Report (FSAR).
While the Management Organization Chart (TS Figure 15.6.2-1) is in Chapter 12 of the Point Beach FSAR (as Figure 12. 2-1), a detailed FSAR Plant Operations Organization Chart does not exist.
We are including a Plant Operations Organization Chart in our next FSAR update.
2.
TS Figure 15.6.2-2 and its accompanying notes contain operational requirements which will remain in the specifications.
Specifically, these requirements are the Operations Group shif t make-up (as delineated by the chart) and the four chart notes.
We have relocated these requirements in TS 15.6.2.1 (previously TS 15. 6. 2. 2).
New TS 15.6.2.1.g has been added.
This specification defines deportability responsibilities for the Superintendent -
Health Physics rather than the Health Physicist and reflects the creation of the new Superintendent position.
Additionally, the Superintendent - Health Physics is now a member of the Manager's Supervisory Staf f (MSS), whose composition is described in TS 15.6.5.1.2.
3.
F.ecent changes in our Fire Protection organization, both off site and on site, have prompted a revision of existing TS Figure 15.6.2-3, " Wisconsin Electric Power Company Off-Site Management Fire Protection Organization," and existing TS Figure 15.6.2-4, " Point Beach Nuclear Plant Fire Protection i
Organization."
The most significant change to Figure 15.6.2-3 results from the transfer of the System Fire Pro-l tection Of ficer to the Human Resources Department.
The l
figure is also revised to show the General Superintendent -
)
Quality Assurance as part of the Fire Protection organization.
Figure 15.6.2-4 is modified to show the designation of the Shif t Operating Supervisor as the Fire Brigade Leader, omitting the previous additional title of Assistant Fire Brigade Chief.
The Fire Protection charts have been renumbered as Figures 15.6.2-1 and 15.6.2-2 as a result of deleting existing TS Figures 15.6.2-1 and 15.6.2-2.
i
Document Control Desk December 30, 1987 Page 3 4.
Technical Specification 15.6.3.1, which addresses Facility Staf f Qualifications, states that "each member of the staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions or as clarified in 15.6.3.2 through 15.6.3.4."
Both TS 15.6.3.2 and TS 15.6.3.3 address the "special qualifications" required of the senior person (s) in the Health Physics organization.
Due to the creation of the Superintendent - Health Physics position, we have revised both specifications to address this position as requiring the special qualifications.
5.
Technical Specification 15.6.5.1.2 has been modified to reflect the following changes to the Manager's Supervisory Staff:
a.
The position of Superintendent - Technical Services has been eliminated.
This position is an unnecessary tier of responsibility in the plant organizational structure.
b.
The position of Superintendent - Chemistry and Health Physics has been replaced by two new positions, Superintendent - Chemistry and Superintendent - Health Physics.
The ever-increasing demands placed on the Chemistry and Health Physics Group warranted a split of this group into the separate Chemistry Group and the Health Physics Group, each with a cognizant Superintendent.
c.
Because the PBNP staff has been augmented with the Superintendent - Health Physics position which is senior to the Health Physicist position, the Super-intendent - Health Physics replaces the Health Physicist as a MSS member.
It would be inappropriate for the Health Physicist to remain a member of the MSS.
I 6.
Technical Specification 15.6.5.1.5 addresses the composition of a quorum of the MSS, stipulating that a quorum "shall consist of tne Chairman or his designated alternate and four j
members, including alternates."
Our proposed change to this j
specification modifies the required number of members from 1
four to five.
This increase, in essence, raises a minimum j
requirement and serves to enhance the proper execution of staff functions by providing a broader review base.
i 7.
Lastly, the existing " Conduct of Plant Operations" chart, TS Figure 15.6.2-2, stipulates that the Superintendent - Operations i
shall maintain an NRC Senior Reactor Operator (SRO) License.
l With the deletion of the chart coincident with the relocation i
of pertinent chart requirements to new TS 15.6.2.1, we are proposing a deletion of the requirement that the SRO license 1
a
Document Control Desk December 30, 1987 Page 4 be maintained current.
We are not requesting relief from the standards of Facility Staff Qualifications delineated in TS 15.6.3.1, which states that the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971.
The ANSI standard, " Selection and Training of Nuclear Power Plant Personnel," states in Section 4.2.2,
" Operations Manager," that "... At the time of initial core loading or appointment to the active position, the operations manager shall hold a Senior Reactor Operator's License. "
We shall continue to adhere to that standard in that any staff member appointed to the Superintendent - Operations position shall hold a current SRO license at time of appointment.
Relief from the requirement to keep the license current will enhance the ability of the Superintendent - Operations to perform his assigned duties, which are mostly administrative in nature, by relieving him of the extensive training, watch-standing, and testing requirements necessary to maintain an SRO license.
As required by 10 CFR 50.91(a), we have evaluated this change in accordance with the standards specified in 10 CFR 50.92 to deter-mine if the proposed change constitutes a significant hazards con-sideration.
A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve significant reduction in a margin of safety.
a Regarding the first criterion, the proposed amendments do not affect plant operation and, therefore, do not affect previously evaluated accidents.
Similarly, the proposed amendments do not create the possibility of a new or different kind of accident than previously evaluated.
No physical alterations of plant configuration or changes of set-points or operating parameters are proposed.
Regarding the third criterion, the proposed amendments do not involve a reduction in a margin to safety.
As discussed below, each specific item of these amendments reflects changes which will enhance the management of our facility.
Deletion of the organization charts, described in Paragraph 1 a.
above, does not involve significant reduction in a margin of safety.
The regulation at 10 CFR 5 0. 34 (b) (6) (i) requires
Document Control Desk l
December 30, 1987 Page 5 the applicant's organizational structure be included in the Final Safety Analysis Report (FSAR).
As you know, the FSAR is required by 10 CFR 50.71(e) to be updated at least annually.
Additionally, 10 CFR 50.54 and Appendix B to 10 CFR 50 govern changes to organization described in the Quality Assurance Program.
b.
Similarly, proposed changes described in Paragraphs 2, 3, 4, and 5 above do not affect a margin of safety.
These proposed changes are administrative in nature and result from changes to the staff organizational structure which were made to improve the effectiveness of the organization.
c.
The proposed change described in Paragraph 6 above involves an increase in the number of Manager's Supervisory Staff members necessary to establish a quorum.
Such a change increases the experience base and thus enhances the func-tioning of the Staf f.
d.
The proposed change described in Paragraph 7 above concerns the requirement for the Superintendent - Operations to main-tain a current NRC SRO license.
In accordance with the quali-fication requirements of ANSI N18.1-1971, the Superintendent -
Operations will be required to hold a current SRO license at time of appointment.
Relief from the time-consuming activities associated with maintaining the license will enable the Super-intendent - Operations to perform his functions in enhanced fashion.
We have enclosed a check in the amount of $150 for the application fee as prescribed in 10 CFR 170.
Please contact us if you have any questions concerning this request.
Very truly yours, cf C. W.
Fay Vice President j
Nuclear Power l
Enclosure Copies to NRC Regional Administrator, Region III NRC Resident Inspector Mr. R.
S.
Cullen, PSCW Copies to Britt/Gorske/Finke, Burstein, Charnoff>,, Krieser, Lipke, Newton, Zach - CWF Subscribed and swor to before me Ja j ~ ' , ' -
f this 2O?f~ day of L z~ A r 1987.
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Document Control Desk December 30, 1987 Page 5
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the applicant's organizational structure be included in the
]
Final Safety Analysis Report (FSAR).
As you know, the FSAR is required by 10 CFR 50.71(e) to be updated at least annually.
Additionally, 10 CFR 50.54 and Appendix B to 10 CFR 50 govern changes to organization described in the Quality Assurance Program.
l b.
Similarly, proposed changes described in Paragraphs 2, 3, 4, and 5'above do not affect a margin of safety.
These proposed 1
changes are administrative in nature and result from changes to the staff organizational structure which were made to improve the effectiveness of the organization.
c.
The proposed change described in Paragraph 6 above involves an increase in the number of Manager's Supervisory Staff members necessary to establish a quorum.
Such a change increases the experience base and thus enhances the func-tioning of the Staff.
l d.
The proposed change described in Paragraph 7 above concerns the requirement for the Superintendent - Operations to main-i tain a current NRC SRO license.
In accordance with the quali-fication requirements of ANSI N18.1-1971, the Superintendent -
Operations will be required to hold a current SRO license at time of appointment.
Relief from the time-consuming activities associated with maintaining the license will. enable the Super-intendent - Operations to perform his functions in enhanced fashion.
We have enclosed a check in the amount of $150 for the application fee as prescribed in 10 CFR 170.
Please contact us if you have any questions concerning this request.
Very truly yours, d O~
C. W.
ay Vice President Nuclear Power Enclosure Copies to NRC Regional Administrator, Region III NRC Resident Inspector Mr. R.
S.
Cullen, PSCW
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