ML20246N091

Application for Amends to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,changing Tech Specs Re Administrative Controls & Organizational Charts,Per Generic Ltr 88-06

ML20246N091
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	03/13/1989
From:	Mrockza E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246N097	List: B13098, Proposed Tech Specs Re Administrative Controls & Organizational Charts ML20246N091
References
B13098, GL-88-06, GL-88-6, NUDOCS 8903270299
Download: ML20246N091 (4)

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T UM General Offices

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HARTFORD CONNECTICUT 06141-o270 k L iJ ",,,,% %"O",,,,,,, (203) 685-5000 March 13, 1989 Docket Nos. 50-213 50-245 50-336 50-423 B13098 Re: 10CFR50.90 U.S._ Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 Proposed Revision to Technical Specifications Administrative Controls--Organizational Charts Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) hereby propose amending Operating License Nos. DPR-61, DPR-21, DPR-65, and NPF-49 by in'corporating the changes identified in Attachment Nos. I, II, III, and IV into the plant Technical

[ Specifications for the Haddam Neck Plant and Millstone Unit Nos.1, 2, and 3, respectively.

I Discussion The content re' quired in the Administrative Controls Section of the Technical i Specification is specified in 10CFR50.36c(5). The regulation requires that the Technical Specifications centain the controls and provisions that are i necessary to assure operation of the facility in a safe manner and does not specifically require inclusion of organizational charts in the Technical Specifications.

Appendix B to 10CFR50 and 10CFR50.54(a)(3) govern changes to the organization described in the Quality Assurance Program. The QA Topical Report contains organization charts for personnel having quality functions in all of Northeast Utilities (NU) nuclear facilities. Since the QA Topical Report is updated on an annual basis, it is unnecessary for CYAPC0 and NNECO to amend its Technical Specifications for each organizational change. Deletion of the organization charts from the ' Technical Specifications is recommended to e.liminate this needless expenditure of resources by NU and subsequent review by the NRC.

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, U.S. Nuclear Regulatory Commission B13098/Page 2 '

March 13, 1989 t

The changg proposed herein reflect the recommendations of Generic Let-ter 88-06. The only clarification regarding the guidance provided in Generic Letter 88 is noted in Section 6.2.1, Offsite and Onsite Organizations, Item d. We would like to clarify that Nuclear Training and Quality Assurance Site personnel, although located at both stations, report to corporate management and not the onsite manager. Further, Health Physics Site personnel report to the Station Services Superin'tendent at both stations. The Station Services Superintendent has sufficient' organizational freedom to ensure his independence from operating pressures. He reports to the Site l

Superintendent. The plant operating staff reports to the Unit Superintendent for each unit. The . Unit Superintendents also report to the Site Superintendent. -

As part of our continuing effort to make our Section 6 Administrative Technical Specifications consistent with our four nuclear facilities, we have included a title change for Millstone Unit No. 3. Specifically, Section 6.3 will be revised to read Facility Staff Qualifications. This change will bring Millstone Unit No. 3's Section 6.3 into consistenc'y with a recent similar change for our three other nuclear facilities. .

, In summary, the proposed changes are consistent with the guidance provided by Generic Letter 88-06 and the Commission's Interim Policy Statement on Technical Specification Improvements. Based upon the above discussion, CYAPC0 and NNEC0 have determined that the changes are administrative in nature, and can in no way affect nuclear safety.

Significant Hazards Consideration CYAPCO, and NNECO have reviewed the proposed changes in accordance wi,th 10CFR53.92 and have concluded that they do not involve a significant hazards consideration in that these changes would not:

1. Involve a signifi:: ant increase in the probability of occurrence or consequences of an accident previously analyzed. The proposed changes are strictly administrative in nature. This administrative change will not increase the probability of occurrence or the consequences of an accident previously analyzed.

2. Create the possibility of a new or different kind of accident from any previously analyzed. Since there are no changes in the way the plant is operated, the potential for an unanalyzed accident is not created. No new failure modes are introduced. The proposed changes are administra-tive and have no affect on plant operation.

(1) Removal Of Organization Charts From Technical Specification Administrative Control Requirements (Generic Letter 88-06), dated March 22, 1988.

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i B13098/Page 3 March 13, 1989  !

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3. Involve a significant reduction in a margin of safety. The proposed changes remove the offsite and onsite organization charts from the i Technical Specifications and are strictly administrative. Similar i organization charts are contained in the QA Topical Report, which is )

updated annually. Since the proposed changes do not affect the conse- j quences of any accident previously analyzed, there is no reduction in the margin of safety.

t Moreover, the Commission has provided guidance concerning the application of l standards in 10CFR50.92 by providing certain examples (March 6, 1986, 51FR7750) of amendments that are considered not likely to involve a significant hazards consideration. While the changes proposed herein are not enveloped by a specific example, they are consistent with the provisions of Generic Letter 88-06.

Based upon the information contained in this submittal and the environmental assessment for the Haddam Neck Plant and Millstone Unit Nos.1, 2, and 3, there are no significant radiological or nonradiological impacts associated with the proposed change, and the proposed license amendments will not have a significant effect on the quality of the human environment.  !

The Haddam Neck Plant and Millst'one Site Nuclear Review Boards have reviewed and approved the attached. proposed revisions and have concurred with the above determinations.

In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.

These proposed changes are not required to support continued plant operatio'n.

Therefore, no specific schedule for amendment issuance has been proposed.

I Very truly yours, {

CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY E. W Mroefka 6/

Senior Vice President cc: Kevin McCarthy, Director l Radiation Control Unit l Department of Environmental Protection Hartford, Connecticut 06116 W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 '

D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 ,

l A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 1 J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant l

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U.S. Nuclear Regulatory Commission B13098/Page 4 March 13, 1989 STATEOFCONNECTICUT)

COUNTY OF HARTFORD I ss. Berlin Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he is author-ized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in s id information L are true and correct to the best of his knowledge and beli

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