ML20237F992
| ML20237F992 | |
| Person / Time | |
|---|---|
| Site: | Hatch |
| Issue date: | 08/10/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20237F976 | List: |
| References | |
| TAC-60982, TAC-60983, TAC-61637, TAC-61638, NUDOCS 8708130266 | |
| Download: ML20237F992 (9) | |
Text
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UNITED STATES I
I,t NUCLEAR REGULATORY COMMISSION h g,3, WASHINGTON, D. C. 20555 I
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%, '... + p SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION I
SUPPORTING AMEhDMENTS NOS. 345 AND 80 TO FACILITY OPERATING LICENSES DPR-57 AND NPF-5 i
GEORGIA POWER COMPANY i
OGLETFf0D E POWER CORPORATION MUNICIPAL ELECTRIC AUIHORITY OF GEORGIA CITY OF DALTON, GEORGIA EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 i
DOCKET NOS. 50-321 AND 50-366 j
INTRODUCTION By letters dated February 17, 1986 (Reference 1), May 16, 1986 (Reference 2),
fugust 27, 1986 (Reference 3), October 27, 1986 (Reference 4), and November 24, i
1986 (Reference 5), the Georgia Power Compan changes to the Technical Specifications (TS)y (GPC, the licensee) requested for the Edwin I. Hatch Nuclear Plant, Units 1 and 2.
The requested changes would amend: (1) Section 5.0, l
Design Features, of the Hatch Unit 2 Appendix A Technical Specification; (2) 4 Section 6.0, Administrative Controls, of the Hatch Units 1 and 2 Appendix A l
Technical Specification; and (3) Section 5.0, Administrative controls, of the Hatch Units 1 and 2 Appendix B Technical Specifications. The organizational changes requested in References 1-4 reflected a continuing evolution of the licensee's organization.
Reference 5 provided a clarification of the quali-fications and minimum plant department representation on the revised Plant Review Board that had been requested by Reference 2.
However, it did not change the request for the Technical Specification amendment as described in Reference 2.
Specifically, the proposed changes would:
1.
Revise Section 5, Design Features, of the Hatch Unit 2 Appendix A TS to delete Figure 5.1.1-1 and change the references in Specifications 5.1.2 and 5.5.1 from Figure 5.1.1-1 to Figure 3.11-1, 2.
Revise Section 6.1, Responsibility, of the Appendix A TS for Hatch Units l
1 and 2 to reflect the addition of an onsite executive position and several title and responsibility changes.
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3 Revise Section 6.2, Organization, of the Appendix A TS for Hatch Units I and 2 to amend Figure 6.2.1-1 to reflect changes to the offsite and onsite organizations. The October 27, 1986 letter (Reference 4) also proposed to delete Figures 6.2.1-1 and 6.2.2-1 from the Appendix A TS.
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4.
Revise Section 6.5, Review and Audit, of the Appendix A TS for Hatch Units 1 and 2 to change the membership, quorum requirements, and responsibilities of tio Plant Review Board and the Safety Review Board.
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5.
Revise Section 6.6, Reportable Occurrence Action, of the Appendix A TS for Hatch Units 1 and 2 to make the reporting requirements consistent with the organization and title changes proposed in Sections 6.1 and 6.2 (items 2 and 3 above).
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Revise Section 6.7, Safety Limit Violation, of the Appendix A TS for Hatch Units 1 and 2 to make the reporting requirements consistent with the organization and title changes proposed in Sections 6.1 and 6.2 (items 2 and 3 above).
7.
Revise Section 6.8, Procedures, of the Appendix A TS for Hatch Units 1 and 2 to change approval authorities for procedures.
8.
Revise Section 5, Administrative Controls, of the Appendix B TS for Hatch Units 1 and 2 to be consistent with the organization and title changes proposed in Sections 6.1 and 6.2 of the Appendix A TS (items 1 and 2 dbove). The October 27, 1986 letter (Reference 4) also proposed to delete Figure 5.2-1 from the Appendix B TS.
EVALUATION 1.
Section 5.0, Design Features, Hatch Unit 2 Appendix A TS Figure 5.1.1-1 shows the exclusion area (area inside the site boundary), the low population zone (coincides with the exclusion area) and the location of the old meteorological tower. This same information is shown on Figure 3.11-1 in Section 3/4.11, Radioactive Effluent 1, of the TS.
In addition, Figure 3.11-1 shows the location of the new meteorological tower and a recreation area that has been added adjacent to the site boundary for the use of Hatch employees and their families.
The licensee proposes to delete Figure 5.1.1-1.
Specifications 5.1.1 v d 5.1.2 would be revised to reference Figure 3.11-1 instead of Figure 5.1.1-1.
Specification 5.5.1 would be revised to state that the primary and backup meteorological tower are located as shown on Figure 3.11-1.
Elimination of Figure 5.1.1-1 removes the redundancy that presently exists in the TS between Figure 5.1.1-1 and Figure 3.11-1 and thus eliminates a potential source of conflict and confusion.
There is no change to the physical boundary and thus no change to the exclusion area or low population zone. lle find this deletion of the redundant Figure 5,1,1-1 and the changs in references to Figure 3.11-1 to be acceptable. The new meteorological tower which is now the primary source of meteorological information provides an added capability.
Retention of the old meteorological tower as an installed, operating backup c.ssures that data from the new primary tcwar can be correlated with the historical meteorological data at the site.
The new tower thus provides an enhanced capability and is acceptable.
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l 2.
Section 6.1, Responsibility, Units 1 and 2 Appendix A TS j
Specification 6.1.0 has been added to indicate the eddition of!the onsite executive position, the Vice President-Plant Hatch who shall provide direct l
executive oversight for all aspects of Plant Hatch.
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Specification 6.1..'
has been revised to reflect that the Plant Support Manager has responsibility for plant support functions.
The former 6.1.2 and 6.1.3 specifications (new 6.1.2) have been combined to reflect the change in title and responsibilities of the Manager Radiological Safety as described below in Item 3.a.
In addition, specification 6.1.4 has become the new 6.1.3 specification.
These changes should promote improved corporate control and support of plant operations and, since they meet the criteria of Sections 13.1.1 and 13.1.2 of -
NUREG-0800, the Standsrd. Review Plan (SRP), are acceptable.
I 3.
Section 6.2, Organization, Units 1 and 2 Appendix A TS 3.a Revisions to the Offsite Organization Chart, Figure 6.2.1-1 l
The of? site organization Figure 6.2.1-1, has been revised as follows:
Addition of a new position. Senior Executive Vice President and deletion of the Executive Vice President Power Supply position.
The position of Senior Executive Vice President who reports directly to the President GPC and is responsible for hil activities related to power supply, is similar
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in function to the former position of Executive Vice President Power.
l Supply. The new positions, Senior Vice President Nuclear Operations and the General Manager Quality Assurance, report to this position.
Addition of a new position, Senior Vice President Nuclear Operations who has assumed all the functions for Plant Hatch fonnerly assigned to the Senior Vice President Nuclear Power position, which has been deleted. The new positions, Manager Nuclear Support and Manager Nuclear Performance, l
report to this position.
Addition of a new position, Vice President Plant Hatch who is onsite and, who reports directly to the Senior Vice President Nuclear Operations.
This position maintains the line authority and' responsibility previously l
held by the corporate position of Vice President and General Manager Nuclear Operations which has been deleted.
In addition, the following new positions report to the Vice President Plant Hatch:
Plant Manager; Plant Support Manager; Manager Plant Training and Onsite Emergency Preparedness; and Manager Nuclear Safety and Compliance.
Addition of a new position, Manager _ Radiological Safety (formerly titled l
Manager of. Nuclear Chemistry and Health Physics) who:
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. 1.
Has assumed responsibility for the Radiological Monitoring Program.
The responsibility for this program was formerly divided between the General Manager-Plant Hatch, the Manager of Nuclear Engineering and Chief Nuclear Engineer, and the Manager of Environmental Affairs.
2.
Continues to have responsibility for the management of the Health Physics and Chemistry Program, and l
3.
Has assumed the responsibilities of the Radiological Health and Safety Representative position which has been deleted.
Additf un of a new position, Plant Manager (formerly titled General Manager-Plant Hatch), who has overall and direct responsibility for activities strictly related to the safety and effectiveness of day to day operation of the plant, while support type functions are the responsibility of the new position, Plant Support Manager.
Addition of a new position, General Manager Quality Assurance (formerly -
titled General Manager Quality Assurance and Radiological Health and Safety) whose responsibilities for radiological health and safety have been transferred to the Manager Radiological Safety as described above.
The new position, Manager huclear Safety and Licensing)(formerly titled Manager Nuclear Engineering and Chief Nuclear Engineer and the new position Manager Nuclear Training report to the Senior Vice President Nuclear Operations which is a higher reporting level than the former position had. The following four new positions report to the Manager, Nuclear Safety and Licersing: Nuclear Licensing Manager, Hatch; Nuclear Licensing Manager, Vogtle; Nuclear Safety Manager; and Nuclear Safety Reviews Manager.
The Hatch Quality Assurance Site Manager's primary onsite line of communication is with the Vice President Plant Hatch (a higher reporting level) instead of with the General Manager-Plant Hatch (now Plant Manager).
Deletion of the following positions from the Engineering and Construction Services Department:
Vice President and Chief Engineer Power Supply Engineering and Services, Manager Engineering Services, and Hatch Project Manager. The title, Hatch Project Manager has been changed to Manager Nuclear Projects and this positicr. now reports to the Nuclear Operations Department.
Deletion of the position of Deputy General Manager-Plant Hatch. This position reported to the former General Manager-Plant Hatch.
The responsibilities of the General Manager-Plant Hatch and the Deputy General Manager-Plant Hatch have been assumed by the new positions -
Plant Manager and Plant Support Manager, who have replaced the General Manager-Plant Hatch position.
- Deletion of the position of Manager HJClear Generation Who had Corporate responsibility for fire protection. This position reported to the former Vice President and General Manager Nuclear Operations.
The latter position
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was replaced by the Vice President Plant Hatch and moved onsite.
The responsibilities of the Manager Nuclear Generation including f.f re protection have been assumed by the new position, Manager Engineering Liaison. The designation for corporate responsibility for fire protection has been removed from the Offsite Organization Chart but ccntinues to be addressed in the Fire Protection Program, as required by Appendix R of 10 CFR 50.
The responsibility of the former Manager Nuclear Generation for receiving r
l reports, written notifications, and minutes of the PRB; reportable l
occurrence notifications; and safety limit violation notifications is now assumed by the Vice President Plant Hatch.
l Titles of positions mentioned above have been changed throughout Section 6.0 i
to reflect the proposed changes.
We find that the organization and staffing, as revised (1) should promote a higher level of management control, (2) should promote management ree. possibility for distinct functional areas, thereby increasing accountability and (3) meet 1
the acceptance criteria of Sections 13.1.1 and 13.1.2 of the SRP and are, therefore, acceptable.
3.b Deletion of Organization Charts, Figures 6.2.1-1 and 6.2.2-1 The licensee's submittal of October 27,1986 (Reference 4) proposed to delete Figures 6.2.1-1 and 6.2.2-1 from the Appendix A TS.
The staff has been examining the requirement for organization charts in the TS to see if an alternate means might be used to maintain an awareness of and appropriate controls over the organizations of licensees.
This is being handled generically and, at such time as t decision is reached, any relief will be offered to all licensees.
Pending a generic decision however, no action is being taken on this request.
4 Section 6.5, Review and Audit, Units 1 and 2 Appendix A TS I
4.a Revisions to the Plant Review Board Composition and Ouorum, Specifications i
6.5.1.2 and 6.5.1.5 f
The proposed changes to the Plant Review Board (PRB) membership requirements would allow for supervisory level personnel from six onsite departments to serve as pemanent members. The PRB, which had eight voting members would be revised to have six pemanent members.
The minimum quorum requirement for the PRB would be reduced from five to four members to coincide with the proposed reduction in the minimum membership requirement. These changes would also delete the requirement for the Plant Manager (fomerly General Manager-Plant l
Hatch) and the Deputy General Manager-Plant Hatch (whose position, has been deleted) to se've as permanent members on the PRB. The PRB chaiman and his designated alternate would be required to be a manager of one of the six onsite departments listed in the proposed technical specification or higher.
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i Therefore, they will be of sufficiently high level of management to deal j
effectively with the other PRB members.
The remainder of the members j
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will be at the level of supervisor or higher and, therefore, will be of sufficiently high level to deal with issues that the PRB has responsibility for.
i The requested revision does not change the minimum qualification req'uire-ments for membership on the PRB (per Regulatory Guide 1.8).
The proposed changes to the PRB would allow the Plant Manager to devote more time to line duties while maintaining adequate management representation on the PRB. The Plant Manager would, therefore, have more flexibility.
In addition, plant management control of the PRB would be maintained since the Plant Manager will be responsible for PRB membership appointments.
The new minimum quorum requirement is acceptable since four members is a majority of the revised total PRB membership of six.
The pro' posed changes to the PRB are acceptable since they provide for interdisciplinary reviews of the subject matter, meet the relevant requirements of Regulatory Guide 1.33 and meet the acceptance criteria of Section 13.4 of the SRP.
4.b Plant Review Board Responsibilities, Specification 6.5.1.6 1
In specification 6.5.1.6a, concerning PRB review of all procedures required by specification 6.8, the licensee added the words "except those for the Radiological Environmental Monitoring Program" which will be the responsi-bility of the Manager Radiological Safety.
In specification 6.5.1.6e. concerning PRB responsibility for investigation t
of all violations of the TS, the licensee added the word " reportable" befor9 the word " violations" and added the position of " Senior Vice President l
Nuclear Operations" to receive reports.
Specification 6.5.1.6f has been changed as follows:
The words "24-hour" have been deleted and new words have been added so that it now reads " Review of events requiring written notification to the Commission per the Technical Specifications and/or reporting requirements of 10 CFR 50.73."
In specification 6.5.1.61, concerning PRB responsibility for review of changes to the Process Control Program and the Offsite Dose Calculation Manual (ODCM), the licensee added the words "except for the section on the Radiological Environmental Monitoring Program in the ODCM" which is now the responsibility of the Manager Radiological Safety.
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In specification 6.5.1.6m, the title " Manager, Nuclear Engineering and Chief Nuclear Engineer" has been deleted and replaced by the " Manager l
Radiological Safety."
The above changes to the Plant Review Board's responsibilities are acceptable, 3
in that they are consistent with the responsibilities of the new position, Manager Radiological Safety, described in Section 2.2 above, and are consistent with the acceptance criteria of SRP Section 13,4
, 4.c Plant Review Board Authority and Records, Specifications 6.5.1.7 and 6.5.1.8 These specifications have been changed to delete the title of Mangger of Nuclear Generation and add the titles of Vice President Plant Hatch and Senior Vice Prcsident Nuclear Operations.
This is acceptable in that it provides notification to higher level managers and is consistent with the chan;es described in Section 2.2 above.
I 4.d Revisions to the Safety Review Board (SRB), Specification 6.5.2 4
The proposed changes to the Safety Review Board (SRB) inclufe:
Reducing the SRB membership from seven persons (Specification 6.5.2.2) and quorum requirements from four persons (Specification 6.5.2.6) to the l
levels specified in Sections 4.3.2.1 and 4.3.2.3 of ANSI Standard N18.7-1976. The SRB will be composed of a minimum of five persons.
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requested revision does not change the minimum qualification requirements l
for membership on the SRB.
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Shifting the corporate management responsibility for the SRB (Specification 6.5.2.3) from the Executive Vice President Power Supply position which has been deleted, to the new position Senior Vice President Nuclear Operations since the latter position now has full direct responsibility for matters pertaining to GPC operating nuclear fa:ilities.
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Rewording of the lead statement for Specification G.5.2.7 from "The SRB shall review:" to "The SRB shall be responsible for the review of:".
This change would allow the SRB to delegate certain review tasks while
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retaining the overall responsibility for the perfonnance of those reviews.
Spelling out of the acronyms "0DCM" to Offsite Dose Calculation Manual and "PCP" to Process Control Program and replacing " biennially" with "at least once per 24 months."
The proposed changes to the SRB would improve the consistency between the Hatch Technical Specifications and the Vogtle Technical Specifications regarding the SRB organization and Functions.
Consistency in the SRB organization and functions for both Plant Hatch and Plant Vogtle is needed, since a single SRB will function for both Hatch and Vogtle.
The above changes are acceptable since they conform to the new organization as discussed in Section 2.2, provide for independent review as described in Section 4.3 of ANS 3.2, ANSI N18.7-1976 and meet the acceptance criteria of l
SRP Section 13.4.
5.
Section 6.6, Reportable Occurrence f.ction, Units 1 and 2 Appendix A TS This specification concerning reportable occurrence action has been changed l
to be consistent with the change in specification 6.5.1.6f as described in i
ltem 4.b above and is, therefore, acceptable.
In addition, the Vice President Plant Hatch and the Senior Vice President Nuclear Operations have been added to receive notification. This provides for higher level manage-ment attention and is, therefore, acceptable.
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.6.
Section 6.7, Safety Limit Violation, Units 1 and 2 Appendix A TS In specifications 6.7.Ib and 6.7.Id the " Senior Vice President Nuclear l
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Operations" has been added to receive reports of safety limit vio ations.
l This is acceptable in that such violations will receive higher lev}el l
management attention.
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7.
Section 6.8, Procedures, Units 1 and 2 Appendix A TS 1
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In specification 6.8.2 and 6.8.3 concerning approval of procedures, the l
title General Manager-Plant Hatch has been replaced with the Plant Manager j
or Plant Support Manager.
However, for approval of the Emergency Plan I
implementing procedures (formerly the responsibility of the General Manager-Plant Hatch), the Manager Plant Training and Onsite Emergency Preparedness has been designated.
The Manager Plant Training and Onsite Emergency Preparedness reports directly to the Vice President Plant Hatch. This change should provide greater attention to emergency pre-l l
l paredness and does not diminish management responsibility for this area.
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We find this change acceptable in that it is consistent with the changes i
in organization and reporting requirements described in Item 3.a above.
Specification 6.8.4, concerning review and approval of changes to the Radiological Environmental Monitoring Program procedures, has been added l
to be consistent with the change in specification 6.1.2 concerning l
responsibilities of the Manager Radiological Safety as described in l
Item 3.a above and is, therefore, acceptable.
8.
Section 5. Administrative Controls, Units 1 and 2 Appendix B TS Specifications 5.0, 5.1, 5.3 and 5.5 would be changed to be consistent with the revised organization and titles as described and evaluated in items 2 and 3 above.
These changes provide for internal consistency in the TS and are, i
therefore, acceptable.
I Specification 5.2 would be revised to eliminate the reference to Figure 5.2 1 j
l and Figure 5.2-1 would be deleted.
As discussed in item 3.b above, this matter of organization charts in the TS is under generic review by the staff.
Delet'on of the charts at this time is premature.
Therefore, no action is l
being taken on this request.
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l Specifications 5.5 and 5.6 would be revised to eliminate the references to the j
l Environmental Program Description Document (EPDD). The environmental program j
described by this document is now complete, and continued reference to the j
t document in the TS is neither necessary nor desirable.
These changes are, i
therefore, acceptable.
Elimination of the references to the EPDD results in renumbering subsections of Specif; cations 5.5, 5.6 and 5.7.
These changes
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are consistent with the elimination of the references to the EPDD and are i
acceptable, i
ENVIRONMENTAL CONSIDERATIONS These amendments relate to changes in administrative procedures or requirements.
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l l Accordingly, the amendments meet the eligibility criteria for categorical ex-
~lusion set forth in 10 CFR 651.22(c)(10).
Pursuant to 10 CFR 551.22(b), no c
environmeistal impact statement or environmental assessment need b6 prepared in connection with the issuance of the amendments.
CONCLUSION The Comission made proposed d2 terminations that the amendments involve no significant hazards consideration which were published in the Federal Reafster (51 FR 16928) on May 7, 1986, (51 FR 24255) on July 2, 1986, (51 FR 41854) on October 19,1986, and (51 FR 45200) on December 17, 1986, and consulted with j
the state of Georgia. No public comments were received, and the state of Georgia did not have any comments.
l The staff has concluded, based on the considerations discussed above, that:
I (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such dCtivities Will be conducted in compliance with the Comission's regulations, j
and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
i REFERENCES 1.
Letter from J. T. Beckham, GPC, to D. Muller, NRC, dated February 17, 1986.
2.
Letter frcm J. P. O' Redly, GPC, to D. Muller, NRC, dated May 16, 1986.
1 3.
Letter from J. T. Beckham, GPC, to D. Muller, NRC, dated August 27, 1986.
4.
Letter from J. P. O'Reilly, GPC, to D. Muller, NRC, dated October 27, 1986.
I 5.
Letter from J. P. O'Reilly, GPC, to G. Rivenbark, NRC, dated November 24, 1986.
Principal Contributors:
I. Schoenfeld C. Goodman L. Crocker Dated:
August 10, 1987 l
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