RBG-26367, Provides Info Re Util 870619 Submittal of Proposed Changes to Tech Spec Administrative Controls

Provides Info Re Util 870619 Submittal of Proposed Changes to Tech Spec Administrative Controls

ML20236N008
Person / Time
Site:	River Bend
Issue date:	07/31/1987
From:	Booker J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RBG-26367, NUDOCS 8708110334
Download: ML20236N008 (4)

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' G U Ks F STATES UTEX TTIES COMPANY RIVER BEND STAflON ' POST OFFICE 00X 220' ST. FRANCISV:LLE. LOUl51AN A 70775 AREA CODE 604 636 60944 346-8661 July 31, 1987

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RBG - 26367 0

File.Nos. 09.5, G9.25.1.4

.U.S. Nuclear Regulatory. Commission Document Control Desk Washington, D.C. 20555 Gentlemen:-

River Bend Station - Unit l Docket No. 50-458

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.This. letter' provides information as discussed with the Staff regarding Gulf. States Utilities Company's (GSU) June 19, 1987 (RBG26200) submittal -j on proposed changes to. technical specification administrative controls.

If further. ~information is. required, please contact Mr. Rick J. King at

-(504)381-4146.

Sincerely, .!

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bb hJ.E. Booker Manager, River Bend Oversight River Bend Nuclear Group JEB/ ERG / /RRS/ch Attachment j cc: U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

~NRC Resident Inspector l

.P.O. Box 1051 i St. Francisv111e, LA: 70775- I i

Mr. William H. Spell, Administrator Nuclear. Energy Division Louisiana Department of Environtnental Quality j P. O. Box 14690 1 Baton Rouge, LA 70898

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8708110334 870731

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ATTACHMENT GULF STATES UTILITIES COMPANY RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47 SIGNIFICANT HAZARDS CONSIDERATION As discussed in'10CFR50.92,:the following discussions are provided to support:the NRC' Staff in their determination of "no significant hazards considerations".1 l l

The offsite organization for. unit management and technical support is -)

. identified in Chapter.13 of the current Safety' Analysis Report.. The proposed change to the Technical Specification Section 6 deletes organizationalicharts (Figures 6.2.1-1 and 6.2.2-1). A 10CFR50.59 unreviewed safety question determination (USQD) will be performed on future' proposed changes per' River Bend Station procedures..

.The proposed change of requirements for the dedicated and dual role

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function.of Shift Technica1' Advisor as shown in Section 6.2.4, is being  ;

requested to comply with the. Nuclear Regulatory Commission Policy I Statement dated.0ctober 28, 1985, concerning " Engineering Expertise on l

, Shift". .This proposed change will enhance the required level of '

. engineering' expertise composit in the minimum shift ~ crew complement.

The addition,of two (2) members to the FRC, the Chemistry Supervisor and the-Process. Systems Supervisor, will provide a ,

representative: forum of respective areas of' plant operations. This. l proposed change will intensify the level of review and' add additional '

experience not presently provided in the Technical Specifications.

The proposed change of Assistant Plant Manager-Operations, Radwaste, and Chemistry to Assistant Plant Manager-Operations and Radwaste accompanied with the creation of the position of Chemistry Supervisor (mentioned above).is-a functional' change'of' responsibility that will enhance the level.of administrative control and the effectiveness of the'. chemistry program. This enhancement is administrative in nature only and has no impact on any accident analysis or safety margin.

The proposed change of Assistant Plant Manager-Maintenance and Material to Assistant Plant Manager-Maintenance involves the functional change of relieving responsibilities associated with the control of materials and offers greater' administrative control and effectiveness concerning selected maintenance activities.

Reporting:of the investigation of Technical Specification violations and related reports produced by the FRC shall be forwarded to the Senior

'Vice President-RBNG as shown in the proposed change to Technical

. Specifications Section 6.5.1.6. Written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shall be provided to the Senior Vice President-RBNG of disagreements between the FRC and the Plant Manager as shown in proposed changed to Section 6.5.2.1. These changes enhance the level of management involvement and attention on the subject reporting and approval responsibilities.

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i The NRB is composed of a Chairman, Member and Vice Chairman, and nine I (9) other members, with the Chairman, Member and Vice Chairman being }

manager level positions. '

These revisions provide a total of eleven (11) NRB members, down from j the previous twelve (12). The level of independent review and expertise is maintained, while ensuring that a split vote does not occur and that the simple majority vote rules.

I The proposed changes to the NRB membership are title changes in nature except for the addition of the Outage Manager and the Director-Joint Ownership Participation. The addition of these members provides an independent representation on the NRB to reflect experience from these respective disciplines in the NRB function of independent review and audit of its responsible activities and areas as specified in Section 6.5. In addition, the change to the NRB membership does not affect the level of expertise represented since the technical and management responsibilities are still embodied. The experience level is sufficient to implement the NRC responsibilities.

Routine Reports and Special Reports will be submitted to the U.S.

Nuclear Regulatory Commission, Document Control Desk, Washington, D.C.

70555, with a copy to the Regional Office and a copy to the NRC Resident Inspector as shown in the proposed changes to Sections 6.9.1 and 6.9.2.

These changes are being requested to comply with NRC rules and regulations (final rule) effective January 5,1987 concerning addressing and delivery of correspondence from licensees to the NRC.

These proposed changes affect administrative controls, organizational modifications, and enhancements and, as such, have no effect on plant equipment or the technical qualifications of plant personnel. In addition, they do not change any safety limit or safety analysis. .

Therefore, no increase in the probability or the consequences of an accident I previously evaluated exits.

These proposed changes do not create the possibility of a new or different kind of accident. Plant design and operation is not affected by the new organizational structure. No physical changes are being implemented as a result of the proposed changes in administrative controls. No change in performance criteria exists which would deviate from the technical specification limiting conditions for operation. These changes do not effect the qualifications of personnel who operate RBS nor do they involve any change to the overall operating philosophy of RBS.

No technical limits are being changed or reduced as a result of the proposed changes in administrative controls. They do not change NRB responsibilities and organizational modifications alone do not reduce the margin of safety. No significant reduction in the margin of safety will occur.

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Since the proposed amendment does not change any safety analysis as described in the FSAR nor does it create the possibility of a new or different type of accident or significantly reduce the margin of safety, GSU proposes that no significant hazards are involved.

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