ML20246L257

Safety Evaluation Supporting Amends 118,33,142 & 36 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively

ML20246L257
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	06/26/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20246L227	List: ML20246L221 ML20246L250 ML20246L257
References
NUDOCS 8907180382
Download: ML20246L257 (4)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.118 , 33 ,142 , AND 33 TO DPR-61 DPR-21, DPR-65, AND NPF-49 CONNECTICUT YANKEE ATOMIC POWER COMPANY AND NORTHEAST FUCLEAR ENERGY COMPANY, ET AL.

HADDAM NECK PLANT AND MILLSTONE NUCLEAR POWER STATION UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-213, 245, 336 AND 423 INTRODUCTION .

By an application dated March 13, 1989 as supplemented April 28, 1989 Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) requestec changes to the Technical Specifications-(TS) for the Haddam Neck Plant and Millstone Nuclear Power ~ Station, Units 1, 2 and 3. The proposed changes would remove Figure 6.2-1, Offsite Organization, and Figure 6.2-2, facility (Unit) Organization. These figures would be replaced by reviseo TS 6.1 and 6.2.1. The revision would include a general description of offsite 'and onsite management functions, key management positions and specify that an updated documentation of lines of authority, responsibility and communication will be maintained in the Quality Assurance Topical Report.

Guidance for the proposed change;s to the TS was provided by Generic Letter >

(GL) 88-06 dated March 22, 1988. l l

The supplemental submittal provided revisions to the organizational chart in the Topical Report and a description of supervisor's duties. This information did not alter the action noticed in the Federal Register on April 19, 1989, or affect the initial determination.

DISCUSSION Typically, onsite and offsite organizational charts have been included in the Administrative Controls section of the TS. The organizational charts defined lines of authority and communication through the various management levels.

Since these charts were part of the TS, any restructuring of offsite or onsite organizations required a licensing amendment. Consequently, licensing limitations were placed on the implementation of changes in organizational structures.

As part of the staff's effort to improve TS, the issue of the inclusion of organizational charts in TS was examined. The staff was guided by the Commission's l Interim Policy Statement on TS improvements ano 10 CFR 50.36. 10 CFR 50.36 states that administrative controls are the provisions relating to organization and~ management necessary to ensure the safe operation of the facility. The staff determined that the organization-1 charts themselves did little to ensure 89071803B2 890626 r PDR ADOCK 05000213 P PNV m .

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that this regulation was met. Furthermore, the staff determined that specific operational requirements stated elsewhere in the TS would bear more directly on operational safety. On a lead-plant basis the Shearon Harris plant proposed the deletion of the organizational charts. This proposal was endorsed by the Westinghouse Owners Group and examined by the NRC staff. Subsequently, the staff determined that the regulatory requirements of 10 CFR 50.36 could be met if the Shearon Harris plant added to their TS: 1) to specification 6.2.1, definitions of functional requirements for offsite and onsite organizations, a.nd 2) to specification 6.2.2, definitions of the qualifications of the unit '

staff.

By letter dated January 27, 1908, the staff issued Amendment No. 3 to the Facility Operating License NFP-63 for the Shearon Harrit 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 organizational charts from TS. GL 88-06 provided this guidance to all power reactors.

EVALUATION CYAPCO/NNECO proposed changes to the Haddam Neck and Millst'one Units 1, 2 and 3 (hereafter referred to as "all four units") TS that are consistent with GL 88-06 GL 88-06 listed a number of conditions that must be met by the TS to allow the deletion of the organizational charts while maintaining those aspects of the organizational charts that are important to operational safety. Each of these conditions are addressed below.

1) The requirement that 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, and updated and documented in the Quality Assurance Topical Report (QA) is directly stated in the revised TS 6.2.1. This requirement is consistent in the proposed TS of all four units.

2) The designation of an executive position that has corporate responsibility for overall plant nuclear safety and has the authority to 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 is directly stated in the proposed TS 6.2.1 of all four units.

3) The designation of a management position in the onsite organization that is responsible for the overall unit safe operation and that has control over those onsite activities necessary for the safe operation and maintainance of the plant is directly stated in proposed .TS 6.2.1 of til four units.

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4) The designation of those positions in the onsite organization that require a Senior Reactor Operator License or a Reactor Operator License renmins unchanged with the revisions since those stipulations did not appear in the original organizational charts. However, the revised organizational charts that will appear in the Northeast Utilities QA Report do indicate Licensed Senior Reactor Operator positions and Licensed Reactor Operator positions. This is consistent in the proposed TS of all four units.

5) Provisions for sufficient organizational freedom to be independent from *

, operating pressures for those individuals that train the operating staff, carry out health physics and quality assurance functions is expressly stated in proposed TS 6.2.1 for each of the four units.

6) All references to the organizational charts have been deleted in the TS revisions of all four units.

7) Currently, the Northeast Utilities QA report contains only the offsite corporate managenent organizational charts. By a letter ' dated April 28, 1989, CYAPC0/NNECO provided the NRC staff with copies of the revised onsite unit organizational charts for all four units. The letter also stated that these updated onsite organizational charts will appear in the upcoming 1989 revision of the Northeast Utilities Quality Assurance Topical Report.

In adcition, CYAPC0/NNECO proposed to change the nomenclature " Unit" to

" Facility" in the Millstone Unit No. 3 plant TS. This change is consistent with the nomenclature currently found in the Haddam Neck TS and the Millstone Units 1 and 2 TS. The change is purely administrative and will provide consistency among the four Northeast Utilities plants. Furthermore, the proposed change will have no adverse impact on plant safety.

On the basis of its review, the staff concludes that the proposed changes by CYAPC0/NNECO are consistent with GL 88-c and that the conditions for the deletion of the organizational charts, as set forth in GL 88-06, have been met. Furthermore, the proposed change in nomenclature will not affect plant operation. Therefore, the staff finds that the proposed TS changes are acceptable.

ENVIRONMENTAL CONSIDERATION These amendments change administrative procedures and requirements. The staff has previously published a proposed finding that the amendments involve no significant hazards consideration and there has been no public connent on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 551.22(c)(10). Pursuant to 10 CFR 551.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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s 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 Comission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

• Dated: June 26, 1989

( Principal Contributor: G. E. Garten l

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