ML20238F398
| ML20238F398 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/09/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20238F400 | List: |
| References | |
| ULNRC-1601, NUDOCS 8709160124 | |
| Download: ML20238F398 (7) | |
Text
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Umon Etscraic
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.qg 1901 Gratiot Street. St. Louis Donald F. Schnell Vice President September 9, 1987 U.S. Nuclear Regulatory Commission Attn:- Document Control Desk Washington ~, D.C.
20555 Gentlemen:
ULWRC '1601 DOCKET NUMBER 50-483 CALLAWAY ?LANT DELETION OF TECHNICAL SPECIFICATION FIGURES 6.2_-1 AND 6.2-2,2 Union Electric Company herewith transmits an application for Amendment to Facility Operating License No. NPF-20 for the Callaway Plant.
This application requests that callaway Technical Specification Figurer 6.2-1 and 6.2-2 be deleted and that additional sections be revised to remove all references to the deleted figures.
The content required in the Administrative Controls Section of the Technical Specifications is specified in 10CFR50.36.c(5).
The regulation requires that the Technical Specifications contain the controls and provisions that are necessary to assure operation of the facility in a safe manner and does not specifically require inclusion of organizational charts in the Technical Specifications.
Previously, organization changes would have resulted in Union Electric's processing and the NRC's review of unnecessary license' amendments.
Deletion of the organization charts will eliminate needless expenditure of resources frot both organizations.
This amendment request is consistent with the efforts of industry and the NRC to improve the Technical Specifications.
The proposal has been endorsed by the Westinghouse Owner's Group
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for Shearon Harris (Carolina Power and Light) as the lead plant.
The NRC is_ currently revjewing the' Shearon Harris submittal.
In addition, on March 16, 1986, the NRC approved a similar change
'j request for the McGuire Nuclear Station, Units 1 and 2.
The proposed amendment request will be implemented upon
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approval by the NRC.
The Callaway Plant On-Site Review Committee and Nuclear
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Safety Review Board have reviewed and approved this amendment request.
Attachments 1, 2, and 3 provide the Safety Evaluation, DO 49 n
the Significant Hczard Evaluation, and the Proposed Technical
- Specification Changec.
i as required by 10CFR170.21.pplication fee Enclosed is a check for the $150.00 a
( Attachment 4)
Very truly yours, W
Donald F. Schnell j
DJ%/ mat Attachments:
1.
Safety Evaluation 2.
Significant Hazard Evaluation 3.
Proposed Technical Specification Changes 4.
Application Fee l
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STATE OF MISSOURI )
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CITY OF ST. LOUIS )
Donald F. Schnell, of lawful age, being first duly se'rn upon oath says that he is Vice President-Nuclear and an offic.-
of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Donald F.
Schnell Vice President Nuclear SUBSCRIBEDandsworntobeforemethisf day of
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- M, 1987 l
&L BAR3 ARA FAF V
NOTARY PUBU0, STATE Of MISSOURI MY COMMISSION EXPIRES APRIL 22, 1989 ST. LOUIS COUNTE l
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l cc:
derald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C.
20037 Dr. J. O. Cermack CFA, Inc.
4 Professional Drive -(Suite 110) l Gaithersburgh, MD 20879 W. L.
Forney Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Reside ~.t Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesde, MD 20014 Ron Kucera, Deputy Direc tor Department of Natural Resources P.0, Box 176 Jefferson City, MO 65102 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 1
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U LNRC-1601
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-Safety Evaluation
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I This Technical Specification change requests that Yigures 6.2-1 and 6.?-2, Off sate Organization and Unit Organization, respectively, be deleted from the Technical Specifications and that additional sections be rev.ised to remove all references to the deleted Figures.
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1 This request does not impact components, systems, or plant
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equipment, but merely deletes two organizational charts from i
Section 6.0 and all reftrences to the charts.
The content required in the Administrative controls section of the Technical Specifications is specified in 10CFRf 0.?6.c (5).
The regulatio9 does not specifically require the inclusion of organizational charts in the Technical Specifications.
The exclusion of these charts does not af fect safe operation of the f acility., nor aff.ect any of Union Electric's organizational commitments.
Detailed organizational charts are maintained in Chapter 13 of the Final Safety Analysis Repor t, FSAR.
Changes to the FSAR will continue to be controlled based on 10CFR50.59.
In addition, as required by 10CFR50.71(e), updates of the FSAR are submitted. to the NRC on an annual basis.
This change request does not adversely affect or endanger the health or the safety of the general public, nor involve an unreviewed safety question.
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ULNRC-1601 SIGNIFICANT HAZARA", CONSIDERATION The Commission has provided stand &rds in 10CFR50.92(c) for determining.whether a significant hazards consideration exists.
A proposed amendment to an Operating License for a facility 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 f rom any accident previously evaluated, or (3) involve a significant j
reduction in a margin of safety.
Union Electric has reviewed the proposed change and determined that:
1.
The proposed amendment does not involve a significant i
increase in the probability or consequences of an accident previously evaluated because deletion of the organization charte from the Technical Specifications does not af fect plan
- operation.
As in the past, the NRC will continue to be informed of organizational changes through other required controls.
The Code of Federal Regulations, Title 10, Part 50. 3 4 (b) (6) (i) requires that the applicant's organizational. structure be included in the Final Safety Analysis Report.
Chapter 13 of the Final Safety Analysis Report provides a description of the organization and detailed organization charts.
As required by 10CFR50.71(e), the Company submits annual updates to the FSAR.
Appendix B to 10CFR50 and 10CFR50.54 (a) (3) govern changes to organization described in the Quality Assurance Program.
Some of these organizational changes require prior NRC approval.
Union Electric will continue its practice to inform the NRC of any future organizational changes affecting plant operation.
2.
The proposed amendment does not create the possiblity of a new or different kind of accident than previously evaluated because the proposed change is administrative in nature, and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.
3.
The. proposed amendment does not involve significant L
reduction.in a margin of safety.
Through Union l
Electric'n strong Onality Assurance programs and its l
commitment to maintain only qualified personnel in positions of responsibility, it is assured that sarcty f uncticns perforned by the on-site and the Corporate organizations will continue to be performed at a high level of competence.
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Attachment'2 U LNRC-lG 01
. Based on the above reasoning, Union Electric has determined l
that; the proposed amendment does not involve a significant l
hazards consideration.
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