ML20248D650

Safety Evaluation Supporting Amend 69 to License DPR-34

ML20248D650
Person / Time
Site:	Fort Saint Vrain
Issue date:	03/31/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20248D642	List: ML20248D638 ML20248D646 ML20248D650
References
NUDOCS 8904110529
Download: ML20248D650 (4)

Text

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j, [c., UNITED STATES J w ~j NUCLEAR REGULATORY. COMMISSION r .

WASHINGTON, D. C. 20555 -

A,.g'Vf SAFETY EVALUATION BY THE.0FFICE OF. NUCLEAR. REACTOR REGULATION RELATED TO AMENDMENT W0. 69 TO FACILITY.CPERATING. LICENSE N0. DPR-34 PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN. NUCLEAR GENERATING' STATION DOCKET.ND. 50-2g

1.0 INTRODUCTION

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I By letter dated October 14, 1988, Public Service Company of Colorado j l (PSC) proposed chan J' l Specifications (TS)ges to the Fort St. Vrain (FSV) Technical I' AC 7.1.1, " Organization Acfministrative Controls", AC 7.1.2, " Plant Operaticns Review "haclear Facility Committee Safety Comittee(PORC),(Administrative Controls"and NFSC), Administrative Controls", AC 7.1.3, i AC' O.2, " Safety Limits, Administrative Centrols", these changes were proposed to accon.plish three goals:

l a. Changes were proposed to meet guidance of Generic Letter 88-06 dated March 22, 1988. The offsite Organization and Unit Staff organization charts, Figures ? 1-1 and 7.1.2, are removed and replaced by a narrative description of the offsite and onsite organizations functional requirements in TS AC 7.1.2.a. Unit staff qualification requirements are described in AC 7.1.1.4 added by'the proposed change. .

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b. Changes were proposed to TS 7.1.1 i.dding TS 7.1.1.1, " Responsibility",

to more closely meet the format of the Standard Technical Specifications.

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c. The bulk of changes proposed are to reflect a recent total l reorganization of the licensee's nuclear activities. The proposed e Technical Specification changes reflect the licensee's current organization.

k 2.0 BACXGROUND Consistent with the guidance prov!ded in the Standard Technical-M 50 Specifications, Specifications 6.2.1 and 4.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are pra ided as figures to these sections l kg (Section 7.1'at FSV). ' On a plant. specific basis, these organization i og charts have been provided by applicants and included in the TS issued-with the operating license. Subsequent restructuring of either the-se offsite or unit organizations, following the issuance of an operating >

"N " license, has required licensees to submit a license amendment for NRC

-approval to reflect the' desired changes'in these organizations. As a consequence, organizational changes have necessitated the need to-rec'iest an amenda nt'of the cperating license.

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Because of these limitations on organizational structure, the nuclear l industry has highlighted this as an area for improvement in the TS. The Shearon Harris licensee proposed charges to remove 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 organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR Part 50.

However, there were aspects of the organizational structure that are i important to ensure that the administrative control requirements of 10 CFR 50.36 would be met and that would not be retained with the removal of the organization charts. The applicable regulatory requirements are those administrative controls that are necessary to ensure safe operation of the facility. Therefore, those aspects of organization charts for Shearon Harris that were essential for conformance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organizations and (2) to i

Specification 6.2.2 to define qualification requirements of the unit l 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 i Plant that incorporated these changes to their TS. Subsequently the i 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.

Additionally, PSC has undergone a total reorganization of nuclear activities in 1988. The NRC staff was informed of organization changes as these tock place.

3.0 EVALUATION A. Generic letter 88-C6 The licensee's proposed changes to TS are in accordance with the guidance provided by Generic Letter 88-06 and addressed the items listed below.

(1) Specification AC 7.1.1 was revised to delete the references to Figures 7.1-1 and 7.1-2 that were removed from the TS.

(2) Functional requirements of the offsite and onsite organizations were defined and added to Specification AC 7.1.1, and they are consistent with the guidance provided in Generic Letter 88-06. The specifications notes tnat implementation of these requirements are doeurented in the FSAR.

(3) The senior reactor operator and reactor operator license qualified positions of the unit staff were added to Specification AC 7.1.1.

l This requirement was identified on the organization chart for l conduct of operations and will be retained.

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7 (4) Consistent with requirements to document the offsite and onsite organization relationships;in the form of organization charts, the' ,

licensee has included this documentation;in the latest update of the FSAR.

(5) Specification AC 7.1.1 referenced the-figures for the administrative  ;

and departmental organization and the conduct of operations being : -i removed from the TS and has been revised to define the requirements 1 that were identified by. these charts.-

B. Standard Technical-Specifications (STS)

The proposed changes meet the requirements of the STS. The actual wards and format are specific to Fort St. Vrain.

C. Current Organization

' The licensee recently has undergone a. complete reorganization of nuclear activities. The new organization reflected by the proposed changes to Technical Specification meet NRC. requirements and licensee comitments.

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D. Plant Operations Review Committee (PORC)

Most of the proposed changes impacting PORC are due to title changes, uithin the Itcensee's organization. . The deletion of paragraph AC' J 7.1.2.5k, which required review of all unplanned releases of radioactive material to the environment, received considerable' staff review 'The existing and proposed events receiving PORC review include all'reporteble-  ;

events, all Technical Specification: violations, and a11' plant. operations.

Technical Specification violations and reportable events ~ establish'an .

upperbound for reviewing unplanned radioactive material: releases. . In the past, there has been no threshold below which FORC review is unnecessary.

Many unplanned releases receiving PORC review necessitated by this lack of-threshold were several orders of magnitude below planned, releases' occurring in the same time frame. This may have diverted management time from other activities impacting safe operation of the plant..

The staff concludes that maintaining an upper threshold for review of j unplanned releases while allowing the licensee to establish a lower bound threshold for review of radioactive releases does not lessen safety and' {

is' acceptable. The licensee's activities in this area are routinely inspected by NRC inspectors. The licensee has generally been conservative.in radiological protection.

E. Training The proposed changes in training reflect licensee title and organization changes. The proposed changes do'not reflect ailessening in training requirements.

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l F. Nuclear Facility Safety Comnittee'-(NFSC) -

~The proposed changes refleet licensee title and organizational changes.

The. proposed changes.specify a preliminary approval of meeting minutes by

'the Senior Vice President, Nuclear Operations within 30 days of a meeting.

followed by distribution of the minutes to members. The full committee

. votes on the. minutes at the fol!owin9 NFSC meeting. Previously each member of zthe NFSC was required to approve meeting, minutes within:30 days. -)

L The proposed changes provide an acceptable mechanism for approval of NFSC l meeting minutes.. On the basis of its review of the above items, the staff concludes that the licensee has provided;an acceptable response to-t these items as addressed in the NRC guidance on removing organization charts from the administrative control' requirements of the TS.

p Furthermore, the staff finds that these changes are consistent with the staff's generic finding'on.the acceptability of such changes noted in L Generic Letter 88-06. . Accordingly, the staf f finds the proposed , changes to be acceptable. .i 4.0 ENVIRONMENTAL' CONSIDERATION.

The amendment _ relates to changes in recordkeeping, or administrative procedures or requirements. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and thee has been no public consnent on such finding. l Accordingly, the amendment meets'the eligibility criteria-for categorical exclusionsetforthin10CFRSection51.22(c)(10).Pursuantto10CFR 51.22(b), no environmental' impact statement or environmental assessment l need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

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' The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and-(2) suchpublic i activities will be conducted in compliance with the Consnission's regulations, j and the issuance of the amendment will not be inimical to the common defense i and security or to the health and safety of the public. I I

Date: March 31, 1999 '

Principal Contributors:. Robert E. Farrell I

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