ML20247F724

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Safety Evaluation Supporting Amend 137 to License DPR-59
ML20247F724
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 09/07/1989
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247F721 List:
References
GL-88-06, GL-88-6, NUDOCS 8909180256
Download: ML20247F724 (3)


Text

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E WASHINGTON, D. C. 20555 f '... + st" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.137 TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 i

INTRODUCTION By "05000333/LER-1989-006-01, :on 890419,standby Liquid Control Sys Declared Inoperable When Pump Discharge Accumulator [[Atomic Element" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Precharge Was 0 Psig.Caused by Slow Leak in Charging Connector Spring Loaded Valve.Bladder Repaired|letter dated May 19 1989]] the Power Authority of the State of New York (PASNY or the licensee! propo, sed changes to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant which would replace the organization charts in Section 6 with more general organizational requi rements. Guidance for the proposed changes was provided to the lictosee by Generic Letter 88-06, dated harch 22, 1988.

BACKCROUND Consistent with the guidance provided in the Standard Technical Specifications, Specifications 6.2.1 and 6.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are provided as figures to these sections.

On a plant specific basis, these organization charts have been provided by applicants and included in the TS issued with the operating license.

Subsequent restructuring of either the offsite or unit organizations followir.g the issuance of an operating license, has required licensees to submit a license amendnent for NRC approval to reflect the desired changes in these organizations.

As a consequence, organizational changes have necessitated the need to request an amendment of the operating license.

l Because of these limitations on organizational structure, the nuclear industry has highlighted this as an area for improvement in the TS.

The Shearon Harris licensee proposed changes to renove organization charts from its TS under the lead-plant concept that included the endorsement of the proposed changes by the Westinghouse Owners Group.

In its review of the Shearon Harris proposal, the staff concluded that most of the essential elements of offsite and onsite organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR 50. However, there were aspects of the organizational structure which are important to ensure that the administrative control requirements of 10 CFR 50.36 would be net and which would not be retained with the removal of the organizational charts. The applicable regulatory requirements are those administrative controls that are necessary to ensure safe operation of the facility. Therefore, those aspects of organization I

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, charts for Shearon Harris which were essential for cenformance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organizations and (2) to Specification 6.2.2 to define qualification requirements of the unit staff.

By letter dated January 27, 1988, the staff issued Amendment No. 3 to Facility Operating License NFP-63 for the Shearon Harris Nuclear Power Plant that incorporated these changes to their TS. Subsequently the staff developed guidance on an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88-06 provided this guidance to all power reactors.

EVALUATION The licensee's proposed changes to its TS are in accordance with the guidance provided by Generic Letter 88-06 and address the items listed below.

(1) Specifications 6.2.1, 6.2.2, and 6.3.1, page iii, " Table of Contents," and page vii, " List of Figures," were revised to delete the references to Figures 6.0-and 6.2-2 that were removed from the TS.

(2) Functional requirements of the offsite and onsite organizations were defined and added to Specification 6.2.1, and they are consistent with the guidance provided in Generic Letter 88-06. The specification notes that implementation of these requirements is documented in the Updated Final Safety Analysis Report (FSAR).

(3) The senior reactor operator and reactor operator license qualified positions of the plant staff were added to Specification 6.2.2.

Therefore, this requirement that was identified on the organization chart for the plant staff will be retained.

(4) Consistent with requirements to document the offsite and onsite organization relationships in the form of organization charts, the licensee has confirmed that this documentation currently exists in the FSAR.

(5) The licensee has confirmed that no specifications, other than those noted in item (1) above, include references to the figures of the organization charts that are being removed form TS for their plant. Hence, this is not an applicable consideration, with regard to the need to redefine referenced requirements as a result of the removal of these figures.

On the basis of its review of the above items, the staff concludes that the licensee has provided an acceptable response to these items as addressed in the NRC guidance on removing organization charts from the administrative control requirements of the TS. Furthermore, the staff finds that these changes are consistent with the staff's generic finding on the acceptability of such changes as noted in Generic Letter 88-06. Accordingly, the staff finds the proposed changes to be acceptable.

. In addition to the changes made in accordance with Generic Letter 88-06, the licensee proposed two other changes which are related to this section of the i

TS. The first change would clarify Note 1 of Section 6.3.2 by replacing the

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words "this licensee amendment" with the words " License Amendment No.111" to clarify that the note was addressed by Amendment No.111 and not by subsequent amendments. The second proposed change would change " Training Coordinator" to

" Training Superintendent" in Specification 6.4 to correctly reflect the existing position title. Based on an analysis of the proposed change, the staff concludes that the changes are editorial in nature and would not affect the conclusions reached in the FSAR or Safety Evaluation Report. They are, therefore, acceptable.

ENVIRONMENTAL. CONSIDERATION This amendment relates to changes in recordkeeping, or administrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of this amendment.

CONCLUSION We have concluded, based on the considerations discussed above, that:

(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 activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated: September 7, 1989 PRINCIPAL CONTRIBUTORS:

T. Dunning D. LaBarge h

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