ML20247H681
| ML20247H681 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/19/1989 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20247H675 | List: |
| References | |
| GL-88-06, GL-88-6, JPTS-88-015, JPTS-88-15, NUDOCS 8905310290 | |
| Download: ML20247H681 (14) | |
Text
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e.
ATTACHMENT 7 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING REMOVAL OF ORGANIZATION CHARTS (JPTS-88-015)
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New York Power Authority l
JAMES A.
FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 8905310290 890519 PDR ADOCK 05000333 PDC
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..s o TABLE OF CONTENTS (cont'd)'
h.'
Pace b'
D.-
Emergency, Service. Water System 240 2#
E..
Intake Deicing Heaters
'242 3.12'
. Fire' Protection' Systems' 244a 5.0 Design Features 245'
[
,.5.1 Site; 245 4
5.2:
Reactor 245.
5.3.
.245 u
5.4 Containment' 245' O
5.5.
Fuel' Storage 245 p
'5.6 Seismic Design 246 6.0 Administrative Controls 247 6'.1 '
Responsibility 247 6.2
-Organization 247 6.2.1
~ Facility Management and Technical Support.
247 6.2.2 Plant Staff 247a 6.3 Plant Staff Qualifications 248 i
6.4 Retraining and Replacement Training 248' 6.5 Review and Audit 248 6.5.1 Plant. Operating keview Committee (PORC) 248a-6.5.2
' Safety Raview Committee (SRC) 250 6.6 Reportable Event Action 253
'6.7-Safety Limit Violation 253 6.8 Procedures 253 6.9 Reporting Requirements 254a 6.10 Record Retention 254g 6.11 Radiation Protection Program 255 6.12
' Industrial Security Program 258~
6 13 Emergency Plan 258 6.14 Fire Protection Program 258 6.15.
' Environmental Qualification 258a
' Amendment'No. /,. )(, )(, g, g,,93', 60 111
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LTST OF FIGURES Figure 71tle hgg
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3.1-1 Manual Flow Control 47a 3.1 Operating Limit MCPR versus 47b 4.1-1 Graphic Aid in tb" Selection of an Adequate Interval Between Tests 48 4.2-1 Test Interval vs. Probability of System Unavailability 87 3.4-1 Sodium Pentaborate Solution 34.7 B-10 Atom % Enriched Volume-Concentration Requirements 110
'3.4-2 Saturation Temperature of Enriched Sodium Pentaborate Solution 111 3.5-1 Thermal Power and Core Flow Limits of Specifications 3.5.J.1 and 3.5.J.2 134 3.5-6 (Deleted) 135d 3.5-7 (Deletea) 135e 3.5-8 (Deleted).
135f 3.5-9 MAPLHGR Versus Planar Average Exposure Reload 4, P8DRB284L 135g 3.5-10 MAPLHGR Versus Planar Average Exposure Reloads 4 & 5, P8DRB299 135h 3.5-11 MAPLHGR Versus Planar Average Exposure Reload 6, BP8DRB299 1351 3.6-1 Reactor Vessel Pressure-Temperature Limits 163 0
4.6-1
' Chloride Stress Corrosion Test Results at 500 F 164 6.1-1 (Deleted) 259 6.2-1 (Deleted) 260 Amendment No. }4', W,,W, 94', }E, }d, )Hi, }Hf, Mr.1-1-f l
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6.0
' ADMINISTRATIVE CONTROIS l-Administrative Controls are the means by which plant operations are subject to management control. Measures specified in this section provide for the assignment of responsibilities, plant organization, staffing qualifications and related requirements, -
review and audit mechanisms, procedural controls and reporting requirements. Each of these measures are necessary to ensure safe and efficient facility operation.
' 6.1 RESPONSIBILITY The Resider.t Manager is responsible for safe operation of the plant. During periods when the Resident Manager is unavailable, the Superintendent of Power will assume his responsibilities. In the event both are unavailable, the Resident Manager may delegate this responsibility to other qualified supervisory personnel. The Resident Manager reports direcay to the Executive Vice President - Nuclear Generation.
6.2 '.
Organization 6.2.1 Facility Management and Technical Support
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Onsite and offsite organizations shall be established for plant operation and corporate management, respectively. The onsite and offsite organizations shall include the positions' for activities that affect the safety of the nuclear power plant.
1.
Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to anc including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.
These requirements shall be documented in the Updated FSAR.
2.
The Resident Manager shall be responsible for overall plant operation, and shall have control over those onsite activities that are necessary for safe operation and.
maintenance of the plant.
3.
The Executive Vice President - Nuclear Generation shall take any measures i
needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
Amendment No.pf,)0, Js,Jd 247 i
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The Individuals who train the operating staff and those who carry out health
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physics and quality assurance functions may report to the appropriate ancite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.
6.2.2 Plant Staff The plant staff organization shall be as follows:
1.
Each shift crew shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; 2.
An SRO or an SRO with a Ucense limited to fuel handling shall directly supervise all Core Alterations. This person shall have no other duties during this time; 3.
A fire brigade of five (5) or more members shall be maintained on site at all times. This excludes two (2) members of the minimum shift crew necessary for safe shutdcwn and any personnel required for other essential functions during a fire emergency; 4.
In the event of illness or unexpected absence, up to two (2) hours is allowed to restore the shift crew or fire brigade to the minimum compliment; 5.
The Operations Superintendent, Assistant Operations Superintendent, Shift Supervisor and Assistant Shift Supervisor shall hold a SRO license and the Senior Nuclear Operator and the Nuclear Control Operator shall hold a RO license.
Amendment No. #, Jtf 247a i
6.3 PLANT STAFF QUALIFICATIONS 6.3.1 The minimum qualifications with regard to educational background and experience for plant staff positions shown in FSAR Figure 13.2-7 shall meet or exceed the minimum qualifications specified in ANSI N18.1-1971 for comparable positions except for the Radiological and Environmental Services Superintendent, who shall meet or exceed the qualifications specified in Regulatory Guide 1.8, September,1975.
6.3.2 The Shift Technical Advisor (STA) shall meet or exceed the minimum requirements of either Option 1 (Combined SRO/STA Position) or Option 2 (Continued use of STA Position), as defined in the Commission Policy Statement on Engineering Expertise on Shift, published in the October 28,1985 Federal Register (50 FR 436321). When invoking Option 1, the STA role may be filled by the Shift Supervisor or Assistant Shift Supervisor. (1) 6.3.3 Any deviations will be justified iv the NRC prior to an individual's filling of one of these positions.
NOTE:
(1)
The 13 individuals who hold SRO licenses, and have completed the FitzPatrick Advanced Technical Training Program prior to the issuance of License Amendment 111, shall be considered qualified as dual role SRO/ STAS.
6.4 RETRAINING AND REPLACEMENTTRAINING A training program shall be maintained under the direction of the Training Superintendent to assure overall proficiency of the plant staff organization. It shall consist of both retraining and replacement training and shall meet or exceed the minimum requirements of Section 5.5 of ANSI N18.1-1971.
The retraining program shall not exceed periods two years in length with a curriculum designed to meet or exceed the requalification requirements of 10 CFR 55, Appendix A.
In addition fire brigade training shall meet or exceed the requirements of NFPA 21-1975, except for fire brigade training sessions which shall be held at least quarterly. The effective date for implementation of fire brigade training is March 17,1978.
6.5 REVIEW AND AUDIT Two separate review groups for plant operations have been :onstituted. One of these, the Plant Operating Review Committee (PORC), is an onsite review group. The other is an independent review and audit group, The offsite Safety Review Committee (SRC).
Amendment No. X, X, FT,9(, kff 248
1 THIS PAGE INTENTIONALLY LEFT BLANK The next page is 250a 1
l Amendment No.fd, M, M,}fI 259-260
h-ATTACHMENT II SAFETY EVALUATION FOR PROPOSED TECHNICAL RPJ_CI EMOVAL-OF ORGANIZATION. CHARTS (JPTS-88-015)
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
Attachment II SAFETY EVALUATION Page 1 of 6 I.
DESCRIPTION OF THE PROPOSED CHANGES The. proposed changes to the James A.
FitzPatrick Technical specifications revise Sections 6.1, 6.2, 6.3 and 6.4 and Figures 6.1-l'and 6.2-1 on pages lii,.vii, 247, 247a, 248, 259 and 260.
The changes are as follows:
- 1. Table of Contents; Dace iii
- a. Replace the title of Section 6.2; " Plant Staff Organization" with " Organization".
- b. Add Sections 6.2.1 and 6.2.2 as follows:
SECTION TITLE PAGE NUMBER 6.2.1 Facility Management and Technical Support 247 6.2.2 Plant Staff 247a 2.
List of Ficures; Dace vii Delete the following figures:
FIGURE TITLE PAGE 6.1-1 Management Organization Chart 259 6.2-1 Plant Staff Organization 260 3.
Section 6.1 " Responsibility" on Dace 247 Delete the words "as shown in Fig.
6.1-1" from the last sentence in Section 6.1.
4.
Section 6.2 " Plant Staff Organization" on pace 247 a.
Replace "6.2 Plant Staff Organization" with "6.2.2 Plant Staff" b.
Replace the first line of Section 6.2.2 "The plant staff organization shall be as shown in Figure 6.2-1 and:" with "The plant staff organization shall be as follows:".
c.
Add the following item to Section 6.2.2:
i "5.
The Operations Superintendent, Assistant Operations Superintendent, Shift Supervisor and Assistant Shift
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l Attachment II l
SAFETY EVALUATION Page 2 of 6 i
l Supervisor shall hold a SRO license and the Senior Nuclear Operator and the Nuclear Control Operator shall hold a RO license."
5.
Section 6.2 " Organization" on once 247 Add the new Section "6.2 ORGANIZATION" to page 247.
6.
Section 6.2.1 " Facility Manacement and Technical Support" on pace 247 Add the following new Section 6.2.1 to page 247:
"6.2.1 Facility Manacement and Technical Suncort Onsite and offsite organizations shall be established for plant operation and corporate management, respectively.
The onsite and offsite organizations shall include the positions for activities that affect the safety of the nuclear power plant.
1.
Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions.
These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.
These requirements shall be documented in the Updated FSAR.
- 2. The Resident Manager shall be responsible for overall plant operation, and shall have control over those onsite activities that are necessary for safe operation and maintenance of the plant.
- 3. The Executive Vice President - Nuclear Generation shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
- 4. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures."
f httachment II SAFETY EVALUATION Page 3 of 6
- 7. Section 6.3 " Plant Staff Qualifications" on Dace 248 a.
Replace the words " Fig 6.2-1" in Section 6.3.1 with "FSAR Figure 13.2-7".
b.
Replace the words "this license amendment" in Note (1) with " License Amendment 111" 8.
Section 6.4 HRetrainina and Replacement Trainina" on Daae 248 Replrce the phrase, " Training Coordinator," with the phrase,
" Training Superintendent."
-9. Ficure 6.1-1 "Manacement Orcanisation Chart" on Dace 259 Delete Figure 6.1-1 " Management Organization Chart" on page 259.
- 10. Ficure 6.2-1 " Plant Staff Organization" on Dace 260 Delete Figure 6.2-1 " Plant Staff Organization" on page 260.
II. PURPOSE OF THE PROPOSED CHANGES The proposed amendment replaces the organization charts in g
the Technical Specifications with more general organizational
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requirements.
The proposed changes will provide greater flexibility to implement changes in both onsite and offsite organization structure without the need for license amendments and will meet with the guidance of Generic Letter 88-06
" Removal of Organization Charts from Technical Specification Administrative Control Requirements".
In addition, a clarification to Note 1 of Section 6*.3.2 was included with this application to specify that Amendment 111 is the amendment on which the note was based and Section 6.4 was clarified to show the correct title of the training superintendent.
III. IMPACT OF THE PROPOSED CHANGES The content required in the Administrative Control Section of the Technical Specifications is specified in 10 CFR 50.36.c(5).
The regulation requires that the Technical Specifications contain the provisions necessary to assure the operation of the plant in a safe manner, but does not specifically require inclusion of organization charts in the Technical Specifications.
While organization changes delineate management hierarchy, the s,ecific details of the organizational structure are not
Attachment II SAFETY EVALUATION Page 4 of 6 essential for the safe operation of the plant.
Those key organizational features currently shown on the charts, which are important to safety, have been incorporated in Sections 6.2.1 and 6.2.2 of the Technical Specifications.
In accordance with Generic Letter 88-06, the key organizational features to be incorporated as general requirements include:
1)
The documentation and update of organizational information describing lines of authority, responsibility and communication in a document other than the Technical Specifications.
2)
The designation of the corporate executive official responsible for overall plant nuclear safety and authority.
j 3)
The designation of the onsite management official responsible 1
for overall unit operation and control.
4)
The designation of those onsite positions requiring a senior reactor operator (SRO) or reactor operator (RO) license.
l 5)
The provision of sufficient organizational freedom to provide independence from operational pressures for onsite quality assurance, training and health physics personnel.
The first requirement shall be satisfied through the annual update of the James A.
FitzPatrick Updated Final Safety Analysis Report (FSAR).
Section 13.2 of the FSAR contains the required organization information.
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Requirement 2 shall be satisfied by designating the Executive Vice President - Nuclear Generation as the person responsible for overall plant nuclear safety.
This information shall be incorporated in Section 6.2.1 of the Technical Specifications.
1 Requirement 3 shall be satisfied by designating the Resident j
Manager as the onsite person responsible for overall plant operation.
This information shall be incorporated in Section 6.2.1 of the Technical Specifications.
Requirement 4 shall be satisfied by designating those positions requiring a SRO license or RO license.
This information shall be incorporated in Section 6.2.2 of the Technical Specifications.
Requirement 5 shall be satisfied by the addition of the following statement to Section 6.2.1 of the Technical Specifications:
"4. The individuals who train the operating staff and those who carry out health physics and quality assurance l
functions may report to the appropriate onsite manager; however, they shall have sufficient organizational l
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1 Attachment II l
SAFETY EVALUATION Page 5 of 6 freedom to ensure their independence from operating pressures."
.The proposed changes, which incorporate the guidance provided in Generic Letter 88-06, do not affect the safe operation of the plant and permit the implementation of changes to the structure of the offsite or onsite organization without first having to-I obtain NRC approval through the issuance o,f a license amendment.
The proposed changes to Sections 6.3.2 and 6.4 are editorial f
corrections which do not affect the safe operation of the plant.
IV. EVALUATION OF SIGNIFICANT KAEARDS CONSIDERATION i
Operation of the James A. FitzPatrick Nuclear Power Plant in accordance with the proposed. amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:
l 1.
involve a significant increase in the probability or consequences of an accident previously evaluated. The deletion of the organization charts from the Technical Specifications does not affect plant operation.
The NRC will still be informed of organization changes through annual updates to the FSAR.
The Code of Federal Regulations, Title 10, Part 50. 34 (b) (6) (i) requires that the licensee's organization structure, responsibilities and authorities and personnel qualification requirements be included in the FSAR.
Chapter 13 of the James A.
FitzPatrick FSAR provides a description of the organization and organization charts to the same level of detail as currently exists in the Technical Specifications.
2.
create the possibility of a new or different kind of accident from those previously evaluated.
The proposed amendment replaces-the organization charts in the Technical Specifications with more general requirements.
The proposed amendment provides greater flexibility to implement changes in both onsite and offsite organizational structure without the need for a license amendment.
These changes cannot create the possibility of a new or different kind of accident.
3.
involve a significant reduction in the margin of safety.
The proposed change removes the onsite and offsite organization charts from the Technical Specifications and adds general requirements to Section 6.2 of the Technical Specifications that capture the essential safety aspects of the organizational structure defined by the organization charts.
These changes do not involve a reduction in the margin of safety.
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Attachmsnt II SAFETY EVALUATION Page 6 of 6 i
V.
IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of the proposed' changes will not impact the ALARA or Fire Protection Programs at FitzPatrick, nor will the changes impact the environment.
VI.' CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59.
That is, they:
- a. will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report;
- b. will not increase the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report;
- c. will not reduce the margin of safety as defined in the basis for any technical specification; and d.
involves no significant hazards consideration, as defined in 10 CFR 50.92.
VII. REFERENCES i
- 1. James A.
FitzPatrick Nuclear Power Plant Updated Final Safety-Analysis Report, Section 13.2, Revision 5, dated July 1988.
- 2. James A.
FitzPatrick Nuclear Power Plant Safety Evaluation Report, dated November 20, 1972 and Supplements.
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- 3. Generic Letter 88-06, " Removal of Organization Charts
{
from Technical Specification Administrative Control Requirements", dated March 22, 1988.
4.
Code of Federal Regulations 10 CFR 50.
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