ML17279B032

Augmented Application for Amend to License NPF-21,deleting Organization Charts from Tech Specs & Adding Text to Tech Spec Sections 6.2.1 & 6.2.2.Fee Paid

ML17279B032
Person / Time
Site:	Columbia
Issue date:	05/10/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML17279B034	List: ML17279B032 ML17279B035
References
GL-88-06, GL-88-6, GO2-88-112, TAC-65232, NUDOCS 8805180357
Download: ML17279B032 (7)

Text

tl AC CELERLTED D1S%1BUTJON DEMONSTRI'10N SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:8805180357 DOC.DATE: 88/05/10 NOTARIZED: NO DOCKET '0 FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION .

SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Augmented application for amend to License NPF-21,deleting ltr text.

TITLE:

NOTES:

OR organization charts 6 including proposed gen'eric DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR Submittal: General Distribution

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Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 May 10, 1988 G02-88-112 Docket No. 50-397 U. ST Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF-21, RE(}UEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS.

SECTION 6 SUPPLEMENTAL INFORMATION

Reference:

1. Letter G02-87-140, G. C. Sorensen (SS) to NRC, same subject, dated April 21, 1987

2. Generic Letter 88-06, "Removal of Organization Charts from Technical Specification Administrative Control Requirements," dated Mar ch 22, 1988 Reference 1 requested amendment to organizational charts and text of Section 6 of the lNP-2 Technical Specifications to reflect administrative changes. Reference 2 promoted and provided guidance for the removal of organizational charts from the Technical Specifications and the addition of text to Sections 6.2. 1 and 6.2.2 to capture the essential aspects of the removed organization char ts. In light of the request presently before the staff and the guidance of the Generic Letter, the Supply System hereby requests that Reference 1 be augmented (as attached) to delete the organization charts and include the proposed Generic Letter text (as applicable to HNP-2). Additionally, due to recent changes in the equality Assur ance organization, the change requested in Reference 1 (page 6-8) from gA to ()A/gC manager is hereby withdrawn. No change of support to 'HNP-2 is repr esented in this withdrawn request but rather a reflection of increased management attention to and separation of the gA/gC functions.

Furthermore, page 6-1, Section 6.2.2.e identifies the Shift Supervisor as not a member of the Fire Brigade. For purposes of clarity, the position should be identified as the Shift Manager. Again, no change of support is represented by this change but only an administrative change for clarification.

'llith incorporation of this supplemental information, the Supply System's commitment to maintaining a management structure that contributes to and governs the safe operation and maintenance of NNP-2 is not diminished.

This change provides greater flexibility towards ensuring that the above commitment is maintained. 10 CFR 50.36c(5) specifies the contents of the administrative controls section of the technical specifications and removal of the organization charts does not contravene guidance therein.

Equivalent organization charts currently exist and will be maintained in Chapter 13 of the HNP-2 FSAR and per 10 CFR 50.71 changes will be reported annually with the update of the FSAR.

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Page 2 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS, SECTION 6 SUPPLEMENTAL INFORMATION The Supply System has evaluated the augmented material per 10 CFR 50.92 and provides the following in support of a finding for no significant hazards consideration.

1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because no physical modification of the plant or equipment is involved. Removal of the organization charts does not alter compliance of the WNP-2 Technical Specifications to 10 CFR 50.36.

The added text ensures that the essential 'aspects for responsibility, authority and communication with regard to safe operation of the plant remain clear and evident. The organization charts will continue to be maintained in the WNP-2 FSAR with changes reviewed per 10 CFR 50.59 and reported through annual updates as required by 10 CFR 50.71. Therefore, for the above reasons, the probability or consequences of accidents previously evaluated will not be adversely affected.

2) The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated because as discussed, no physical changes to the plant or equipment are involved and the added text ensures the responsibility, authority, and communication for safe plant operation are not changed and remain clear and evident. Hence, no possibility for a new or different kind of accident from any previously evaluated is represented in the proposed change.

3) The proposed changes do not involve a significant reduction in a margin of safety because the revision in no way alters the Supply System's commitment to maintaining a management structure that contributes to the safe operation and maintenance of WNP-2. The added text ensures clarity of responsibility, authority, and communication remains in the Technical Specifications. Since no physical change to the plant or equipment is involved and responsibility for safety is not diminished, no significant reduction in a margin of safety is presented in this change.

As discussed above, the Supply System considers that this augmented information does not represent a significant hazar ds consideration, nor is there a potential for any effluents that may be released offsite, nor does it involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in '10 CFR 51.22(c)(9) and therefore, per 10 CFR 51.22(b), an environmental assessment of the change is not required.

Page 3 RE()VEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS. SECTION 6 SUPPLEMENTAL INFORMATION This augmented information has been reviewed and approved by the WNP-2 Plant Operation Committee (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB).

Although submitted as supplemental information to Reference 1, an application fee per 10 CFR 170.21 of one hundred fifty dollars ($ 150.00) accompanies this request. In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.

Should you have any questions, please contact Mr. P. L. Powell, Manager, WNP-2 Licensing.

Very truly yours, G. C. orensen, Manager Regulatory Programs lw Attachments cc: C Eschels EFSEC JB Martin - NRC RV NS Reynolds BCP8R RB Samworth - NRC DL Williams - BPA NRC Site Inspector - 901A

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