ML20151C260

Application for Amend to License NPF-57,revising Section 6, Administrative Controls by Deleting Figures 6.2.1-1 & 6.2.2-1 & Replacing W/More General Organizational Requirements.Fee Paid

ML20151C260
Person / Time
Site:	Hope Creek
Issue date:	07/12/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151C263	List: ML20151C260 ML20151C278
References
GL-88-06, GL-88-6, NLR-N88094, NUDOCS 8807210290
Download: ML20151C260 (8)

Text

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. Pubhc Service Electric and Gas Company StIven E. Miltenberger Public Service Electric and Gas Cornpany P.O. Box 236, Hancocks Bridge NJ 08038 609 339-4199 vec Prescem au chef Neea o*ccr July 12, 1988 NLR-N88094 e ,

United States Nuclear Regulatory Commissio,n Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby submits a request to amend Appendir. A of Facility Operating License No.

NPF-57 in accordance with 10CFR50.90. This amendment request revises Section 6, Administrative Controls, by deleting Figure 6.2.1-1 and 6.2.2-1 and replacing th.<m with more general organizational requirements. This change is consistent with Generic Letter 88-06. Additional changes to Section 6 are submitted to reflect management title changes and the current special report submittal requirements.

It has been deterained that the proposed amendment does not involve a sign'licant hazards consideration pursuant to 10CFR50.92. I description of the amendment request and the basis for a no significant hazards consideration determination is p rovided. in Attachment 1. The proposed revised technical specif'. cation changes are shown in Attachment 2.

The proposed changes contained in this amendment request are administrative in nature in that they do not affect the operation of the plant nor do they change the intent of the existing Technical Specifications. In addition, similar license amendments were obtained by Carolina Power & Light Company for Shearon Harris and by Florida Power & Light Company for Turkey Point and St. Lucie. Since this proposed amendment is purely administrative and since NRC has provided guidance for processing it via Generic Letter 88-06, specialized technical review should not be required for approval of this request. Therefore, PSE&G believes that the proposed amendment can be classified as a Category 2 change in accordance with the new NRC Amendment Re ey/

Procedure.

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Document Control Desk 2 7/12/88 t PSE&G has evaluated this request pursuant to 10C"R170.21 and  !

determined that a license amendment application fee is required.

A check for $150.00 is enclosed in payment of this fee. In

. accordance with 10CFR50.91(b)(1), a copy of this amendment-

) request has been sent to the State of New Jersey.

Pursuant to 10CFR50.4(b)(2)(ii), this submittal includes one.(1) signed original and thirty-seven (37) copies. Should you have any questions regarding this submittal, please do not hesitate to contact us.

Sincerely,

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Enclosure / Attachments ,

Affidavit l

C Mr. W. T. Russell, Administrator USNRC Regior I

, Mr. G. W. Rivenbark USNRC Licensing Project Manager Mr. G. W. Meyer USNRC Senior Resident Inspector Mr. D. M. Scott, Chief Bureau of Nuclear En(ineering Department of Enviror. mental Protection 380 Scotch Road i 1 Trenton, NJ 08628 l

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Reft LCR 88-04 STATE OF NEW JERSEY )

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COUNTY OF SALEM )

Steven E. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Of ficer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated July 12, 1988 , concerning Docket No. 50-354 for Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

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f Subscribed and Sworn to before me this /8Vd day of d/>Iu/ , 1988

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Notary Publid of New Jersey VANITA M. MARSHALL NOTARY PUBLIC OF NEW JERSEY My Commission expires on g g_-1..t.. r ni,.i sano s 1ons i

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ATTACHMENT 1 CHANGES TO FAOILITY OPERATING LICENSE HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 LCR 88-04 I. Description of the Changes The proposed amendment to the Hope Creek Generating Station Technical Specifications (TS) makes several changes to Section  :

6.0, Administrative Controls. The first change involves the deletion of Figures 6.2.1-1 and 6.2.2-1, showing the of fsite and onsite organizations, replacing them with more general require- i ments which capture the essential aspects of the organizational structure. Technical Specification Section 6.1.1 and 6.1.2 have been supplemented to include these more general organizational  ;

requirements in accordance with Generic Letter 88-06 dated March 22, 1988.  ;

l The second change replaces the reference to the Vice President - )

Nuclear, contained in TS 6.1.2, with a more generic title, senior i corporate nuclear officer. For consistency, TS 6. 5.1. 6( f ) ,

6. 5.1. 5(m) , 6.5.1.8(b), 6.5.1.9, 6.5.2.4.3(g), 6.5.2.4.4(b), 1 6.5.2.6, 6.6.l(b), 6.7.1(a), and 6. 7. l ( c ) have also had the i title, Vice President - Nuclear, replaced with the title, senior corporate nuclear officer. This change is necessary because the title Vice President - Nuclear has been changed to Vice President I and Chief Nuclear Officer and the Technical Specifications, as j currently structured, should reflect this change. However, this I amendment request proposes to replace the specific title, Vice President - Nuclear with a more generic title, senior corporate nuclear officer. We believe that this change will alleviate the need to process future amendment requests to reflect title changes for the Vice President and Chief Nuclear Officer.

1 The third and final change affects TS 6.9.2 and 6.9.3, Special Reports. This amendment proposes that Special Reports be submitted to the USNRC Document Control Desk with a copy to the Regional Administrator. This proposal is consistent with a revision to 10CFR50.4, published in Federal Register, Volume 51, Number 215, on November 6, 198 6, which to date has been imple- i mented with pen and ink changes to TS 6.9. 2 and 6. 9. 3.

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- II. Reason for the Changes The onsite and offsite organizations are defined by organization charts included in the Administrative Controls section of the Hope Creek Generating Station Technical Specifications (TS). As such, this requires that a license amendment be processed for changes in organizational structure.

The content required in the Administrative Controls section of the Technical Specifications is specified in 10CFR50.36c( 5) .

This regulation requires the Tcchnical Specifications contain the controls and provisions "...necessary to assure operation of the facility in a safe manner..." but does not specifically require the inclusion of organization charts in the Technical Specifications.

The removal of organization charts implements an improvement recommended by the NRC in Generic Letter 88-06. This change was approved by the NRC for the Shearon Harris Plant on a lead plant basis on January 27, 1988.

The NRC will continue to be informed of organizational changes through other required controls. The Code of Federal Regulations, Title 10, Part 50.3 4( b) ( 6) (i) requires that the applicants organizational structure be included in the Final Safety Analysis Report. Chapter 13 of the Hope Creek Updated Final Safety Analysis Report (UPSAR) provides a description of the organization and detailed organization charts. This chapter of the UFSAR already contains the minimum information specified in Generic Letter 88-06. In accordance with 10 CFR 50.71(e),

PSE&G submits annual updates to the UFSAR.

Changes to the organization described in the Quality Assurance Program are governed by 10CFR50, Appendix B and 10 CFR 50.54(a)(3). Any changes to the organizational structure which have the potential to decrease the effectiveness of the OA Program require prior NRC approval. The changes in titles referenced in this amendment request did not reduce the effectiveness of the OA program.

I In addition, it is PSE&G't practice to inform the NRC of major I organizational changes affecting the nuclear facilities prior to )

implementation. It is our intention to continue this practice for future changes in organizational structure.

Two other minor administrative changes are being processed with I this amendment request. The title change for the Vice President l and Chief Nuclear Officer and the deletion of the Assistant General Manager - Hope Creek Operations are administrative details that should be corrected at this time. The change to the l Special Report submittal requirements has already been processed internally, pursuant to 10 CPR 50.4, as a pen and ink change and should be incorpora ted in this amendment request in accordance with 10 CFR 50.90.

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III. Significant Hazards Analysis Consideration The standards used to arrive at a determination-that a request for amendment ir<olves no significant hazards consideration are included in thr Commission's regulations, 10CFR50.92. These regulations state that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would nots (1) involve a significant increase in the probability of consequences of an accident previously evaluated; or (2) create-the possibility of a new or different kind of accident from any &ccident previously evaluated; or (3) involve a significant-reduction in a margin of safety. Each standard is discussed as follows:

1. Operation of the facility in accordance with the proposed amendment would not involve a signficant increase in the probability or consequences of an accident previously evaluated.

The changes being proposed are administrative in nature and do not af fect assumptions contained in plant safety analyses, the physical design and/or operation of the plant, nor do they affect Technical Specifications that preserve safety analysis assumptions. For these reasons, a the proposed changes do not affect the probability or ,

consequences of accidents previously analyzed.

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The changes being proposed are purely administrative and will not lead to material procedure changes or to 1

physical modifications. In addition, there are no  ;

management changes being proposed as a result of this  !

q amendment request, rather the request is necessary to j comply with Generic Letter 88-06 and to reflect the current management organization. For these reasons, the proposed changes do not create the possibility of a new or different kind of accident.

3. The operation of the facility in accordance with the

, modified specification would not involve a significant I reduction in the margin of safety.

The changes being proposed are administrative in nature and do not relate to or modify the safety margins defined l in and maintained by the Technical Specifications.

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, 1 III. Significant Hazards Ana19 sis Consideration (cont id)

, .. - I The ch'anges discussed herein'do'not reduce the TS safety' margin since all organizational responsibilities are being adequately implemented, fall personnel in place are properly. qualified, and controlling the:

organizational details in-the UFSAR will be commensurate with-controlling them in the-TS.

Through FSE&G's strong Quality Assurance Program and our commitment to maintain only qualified personnel in-positions of responsibility, it is assured that safety-functions performed by the oneits and of fsite organizations will continue to be performed with a high level of competence.-

IV. Conclusions PSE&G concludes that this amendment request is similar to two of-the examples listed in "Amendments That Are Not Likely to Involve A Significant Hazards Consideration" (published in Federal Register Volume 51, Number 44, dated March 6, 1986). _

The removal of the organization charts and the recent title change, conform to Example e(i) and the chango in distribution of j the Special Reports required in Technical Specification Section 6.9.2 and 6.9.3 conf orm to Example e(iv) .

Based on the similarity to the examples given above and the  ;

detailed information'provided in Sections II and III of this  !

submittale PSE&G believes that the proposed changes to the Hope '

Creek Generating Station Technical Specifications do not involve a Significant Hazards Consideration.

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ATTAC190lT 2 Page No.

XXIV 6-1 (with Insert) 6-2 (with Insert) 6-3 6-4 6-8 6-9 6-11 6-12 6-13 6-14 6-15 6-20 i

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