ML20248A838

Forwards Mod to 871230 Application for Amend to Licenses DPR-24 & DPR-27,consisting of Tech Spec Change Request 120. Amend Adds Section 15.6.1.2 to Document Changes to Staff Organization & Remove Organization Charts,Per NRC Request

ML20248A838
Person / Time
Site:	Point Beach
Issue date:	08/01/1989
From:	Abdoo R WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248A844	List: ML20248A838 ML20248A865
References
CON-NRC-89-091, CON-NRC-89-91 GL-88-06, GL-88-6, NUDOCS 8908090038
Download: ML20248A838 (7)

Text

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! ..l 4*1' Wisconsin Electnc PONER COMPANY I. 231 W Michigan, Po. Box 2046. Milwaulwe WI 53201 (414)221 2345 L NRC-89-091 August 1,'1989 l:

U.S. NUCLEAR REGULATORY COMMISSION 10 CFR 50.90 Document-Control Desk

' Mail Station P1-137

. Washington, D.C. 20555-L Gentlemen:

DOCKETS 50-266 AND 50-301 MODIFICATION TO TECHNICAL SPECIFICATION CHANGE. REQUEST 120

' STAFF ORGANIZATION CHANGES AND DELETION OF ORGANIZATION CHARTS POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated December 30, 1987, Wisconsin Electric Power Company (Licensee). submitted Technical Specification Change Request 120.

That submittal proposed modifications to Technical Specification (TS)

Section 15.6, " Administrative Controls," to document changes to the staff organization and to remove the organization charts.

Subsequently, on March 22, 1988, the NRC issued Generic Letter 88-06 to provide guidance for the removal of these organization charts from the TS. More recently, the NRC Project Manager for Point Beach has recommended that our proposed change be inodified with consideration given to the Generic Letter 88-06 guidance.

Thus, in accordance with the requirements of'10 CFR 50.59 and 50.90, Wisconsin Electric hereby submits a modification to Technical Specification Change Request 120. This proposal completely modifies the original request. The requested changes are listed below and the proposed TS pages, with changes indicated by margin bars, are attached.

1. The first change adds new section 15.6.1.2. This specifies that the duty shift superintendent (or in his absence the duty operating supervisor) has responsibility for the control room command function. This is not a change in our organization or policy; it allows this section of the TS to follow the guidelines of the Standard Technical Specifications fcr Westinghouse Pressurized Water Reactors (STS).

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U.S. NLC Document Control Desk August 1, 1989 Page 2 L '2. We propose to delete Figure 15.6.2-1, Management Organization i

Chart," Figure 15.6.2-2, " Conduct of Plant Operations," Figure 15.6.2-3, " Wisconsin Electric Power Company Offsite Management Fire Protection Organization," and Figure 15.6.2-4, " Point Beach l

Nuclear Plant Fire Protection Organization." Maintaining these organization charts in the TS has resulted in frequent license amendment requests for strictly administrative reasons.

Deletion of these organization charts will eliminate future similar' requests and provide us greater flexibility in implementing organization changes, consistent with Commission policy.

l Guidance for removing such figures has been provided in Generic l

Letter 88-06. Accordingly, we propose to revise section 15.6.2.1 and add new requirements to section 15.6.2.2 to include the' essential aspects of the organization charts not already contained elsewhere in the TS. We propose that TS 15.6.2.1 include the requirement that onsite and offsite organizations be established. This section will also designate responsibility for overall plant safe operation to the Manager and designates the Vice President-Nuclear Power as having corporate responsi-bility for overall plant nuclear safety. We have added para-

graph 'd' to this section to specify that individuals who carry l out health physics and quality assurance functions have L sufficient organizational freedom to be independent of operational pressures. We would like to point out that this is the only place where we differ from the Generic Letter gualance.

This guidance suggests that the individuals who train the operating staff also maintain sufficient freedom from operating pressures. While our Superintendent-Training does not report to the Superintendent-Operations, and thus is operationally independent of the operations group, we believe that training personnel should be excluded from this provision to permit assignment of trainees to operations for on-the-job training duties and the temporary assignment of operations staff to training functions.

Additionally, in support of removing these TS organization charts, we propose to modify section 15.6.2.2.a to include the personnel requirements for the minimum shift crew. These requirements are currently provided by the organization chart and in notes 1,3 and 4 of figure 15.6.2-2. Specification 15.6.2.2.g has also been added to require that the Superintendent-Operations held a senior reactor operator license. This requirement is now listed on Figure 15.6.2-2.

Note 2 of this figure is replaced by new specification 15.6.2.1.d. Thus, the essential aspects of figures 15.6.2-1 and 15.6.2-2 will remain in the TS. Finally, FSAR Figures 12.2-1 and 12.2-2 provide the onsite and offsite organizations. These figures are identical to TS figures 15.6.2-1 and 15.6.2-2 which we are proposing to remove.

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U.S. NRC Document Control Desk August 1, 1989 l .Page 3 Regarding TS: figures 15.6.2-3 and 15.6.2-4, we are consistent i with the STS since the essential elements for fire brigade I organization are contained in TS 15.6.2.2.f. Also, the PBNP Administrative Control Policies and Procedures Manual, Chapter 1.7.5, describes the fire protection organization and contains the fire protection and fire brigade organization charts.

These four organization charts are maintained in other procedures and we will retain in the TS the essential aspects of.

these organization charts. In addition, this proposal is in keeping with the NRC Interim Policy Statement on Technical Specifications delineated in 52 FR 3788 and follows the guidelines of Generic Letter 88-06. Thus, we believe that removal of the organization charts is appropriate and justified.

3. Technical Specification 15.6.2.2.d requires that an individual qualified in radiation protection procedures be on site when fuel is in either reactor. This requirement was previously fulfilled by ensuring that a member of the operations group on-duty shift was qualified in radiation protection procedures.

We now maintain 24-hour on-site coverage by a qualified individual from the health physics group to fulfill this requirement. We propose to allow this position to be temporarily unfilled for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to accommodate this individual's ur ected absence provided immediate action is taken to repla. this individual. Unexpected absences in the operating shift crew and the fire brigade are treated in the I same manner. Since this 2-hour allowance would apply in three different instances, we propose to slightly modify the footnote on page 15.6.2-3 and reference this footnote in sections  !

15.6.2.2.a, 15.6.2.2.d and 15.6.2.2.f so that it applies in all three cases.

4. Sections 15.6.3.2 and 15.6.3.3 provide the qualifications required for the senior person in the health physics organization. With the creation of the Superintendent-Health [w L

Physics position, we have revised both sections to require that the Superintendent-Health Physics meet these qualifications.

5. Technical Specification 15.5.5.2 has been modified to reflect the following changes to the Manager's Supervisory Staff:

a. Two new positions, General Superintendent-Maintenance and General Superintendent-Operations have replaced the single position of General Superintendent.

b. The title of the Superintendent-Maintenance & Construction is changed to Superintendent-Maintenance.

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U.S. NRC Document Control Desk August 1, 1989 j Page 4

c. The title of the Superintendent-Reactor Engineering has been changed to Superintendent-Technical Services. The original position of Superintendent-Technical Services was an unnecessary administrative tier in the plant organization and no longer exists.  ;

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d. The position of Superintendent-Chemistry & Health Physics has been replaced by two positions, Superintendent-Chemistry and Superintendent-Health Physics. As part of this change, the Radiochemist position was eliminated and the Superintendent-Health Physics was created to become the senior person in the health physics organization. Thus, the Superintendent-Health Physics replaces the Health Physicist .'

and the Superintendent-Chemistry replaces the Radiochemist on the Manager's Supervisory Staff.

e. The position of Superintendent-Engineering, Quality, &

Rc'11atory Services was eliminated during the plant staff 10 -ganization.

6. Technical Specification 15.6.5.1.5 requires that "a quorum of the MSS shall consist of the Chairman or his designated i alternate and four members including alternates." Our proposed change increases the required number to the chairman and five members. This will serve to enhance the proper execution of staff functions by providing a broader review base.

7. Regarding specification 15.6.5.2.5 we propose to remove the unnecessary requirement that the OSRC "... meet at least once per quarter during the initial year of facility operation following fuel loading..." since this portion of the requirement is no longer applicable. The OSRC will still be required to meet at least twice per year at approximately six-month intervals. We propose to delete a similar portion of 15.6.2.2.e which reads

"...after the initial fuel loading..."

8. Technical Specification 15.6.5.2.6, " Quorum," prescribes a quorum consisting of " ...the Chairman or his designated alternate and three members. No more than a minority of the quorum shall have line responsibility for the operation of the facility." In recent years the size of the OSRC has grown to 8 members including the Chairman. We propose to change the quorum requirements to ensure that at least a majority of the members, including the chairman or his designated alternate, are present at a meeting of the OSRC. This is somewhat stronger than the current specification which under certain conditions would allow in OSRC meeting with less than a majority of the members present. Additionally this follows American National Standard N18.7-1976/AMS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" section 4.3.2.3, " Quorum."

U.S. NRC Document Control Desk August 1, 1989 l Page 5 l 9. Finally, due to recent changes in the Wisconsin Electric Power Company corporate organization, the Off-Site Review Committee reports to the Chief Executive Officer rather than the President. Specifications 15.6.5.2.2, 15.6.5.2.8, 15.6.5.2.9, and 15.6.5.2.10 have been revised to reflect this organization change. Since this change resulted from the President's promotion.to CEO, the OSRC may in the future again report to some other appropriate corporate executive, depending on organization changes. We would propose additional changes if that occurs.

As required by 10 CFR 50.91(a), we nave evaluated this change in accordance with the standards specified in 10 CFR 50.92 to determine if the proposed change constitutes a significant hazards consideration. A proposed amendment 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 from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

Regarding the first criterion, the proposed amendments are strictly administrative and do not affect physical plant operation or the procedures for operating the plant. Therefore, they cannot affect previously evaluated accidents.

Similarly, the proposed amendments do not create the possibility of a new or different kind of accident than previously evaluated, since no physical plant changes or changes to plant operating parameters or procedures are proposed.

Regarding the third criterion, the proposed amendments do not involve a reduction in a margin of safety. As discussed below, each of these proposed changes are strictly administrative in nature and the changes will enhance the management of our facility. Each paragraph below corresponds to the changes discussed above.

1. Specifying the responsibility for the control room command function is strictly an administrative addition to this specification. This is not a change in plant operation or organization and does not involve a reduction in the margin of safety.

2. Wisconsin Electric maintains in FSAR Chapter 12 the necessary organization charts. Additionally, the changes proposed in this paragraph follow the guidelines for organization chart removal, as provided in Generic Letter 88-06. These changes involve no physical plant modifications or plant operating parameters and procedures.

Thus, the margin of safety is not affected.

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3. We propose to allow up to two hours to replace the individual qualified in radiation protection procedures during his unexpected absence provided immediate action is taken to replace him. This ensures that this position is expeditiously filled while avoiding an administrative violation of Technical Specifications during an unexpected absence. Since this requirement also applies to the minimum shift crew and the fire brigade,.slightly modifying the footnote on page 15.6.2-3 to make it applicable to all three sections will streamline this part of the specification.

These changes are administrative in nature and cannot affect a margin of safety.

4. Creation of the Superintendent-Health Physics pcsition'was an organizational change made to improve the effectiveness of the Health Physics organization. Since the Superintendent-Health Physics is the senior position in the HP organization, it is appropriate to apply these qualification criteria to that position. This is an administrative change and no margin of safety is affected.

5. Similarly, the changes in this paragraph do not affect a margin of safety since they are administrative in nature and result from changes to the organization structure made to improve the effectiveness of the plant organization

6. The number of Manager's Supervisory Staff members necessary to establish a quorum is increased. This will broaden the experience base-at meetings and thus enhance the functioning of the Staff. Thus, no margin of safety is affected.

7. The portions we propose.to delete from specifications 15.6.5.2.5 and 15.6.2.2.e applied only during the first year of facility operation following fuel loading and cannot possibly be applicable now or during the future. Thus removal does not affect a margin of safety.

8. The changes proposed in this specification are an improvement since the current specifications would allow a meeting of the OSRC with less than a majority of the members present under conditions where 8 or more members are appointed. Additionally, this change follows ANS N18.7-1976 section 4.3.2.3 as mentioned earlier. Thus, no margin of safety is affected.

9. The changes in Off-Site Review Committee reporting requirements result from changes in Wisconsin Electric's Corporate organization. This is an administrative change and no margin of safety is affected.

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. Please contact us if you have'any questions concerning this request.

Very truly your:, .

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Richard A. Abdoo President Enclosure Copies to NRC Regional Administrator, Region III NRC Resident Intyector R. S. Cullen, PSCW Subscribed and sworn to before me this Id' day of (lunnit , 1989.

Notary Public, State of Wisconsin My Commission expires f-2 7- 79 .

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