ML20199H343

Application for Amend to License NPF-42,revising TS 6.3 & 6.12 to Reflect Position Change within Organization

ML20199H343
Person / Time
Site:	Wolf Creek
Issue date:	01/28/1998
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199H348	List: ML20199H343 ML20199H355
References
ET-98-0005, ET-98-5, NUDOCS 9802050016
Download: ML20199H343 (9)

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W$LF CREEK NUCLEAR OPERATING CORPORATION Rchard A. Muench Vce President Engineenng January 28, 1998 ET 93-0005 A U. S.-Nuclear Regulatory Commission

i. ATTN: Document Control Desk

) Mail Station Pl-137 b Waehington, D. C. 20555 I

Reference:

WC JC Letter ET 97 9050, dated May 15, 1997, from R. A. itanch, WCNOC, to the NRC

Subject:

Dacket No. 50-402: Proposed Revision to Technical Specification Section 6.0 for Organization Change I

Gertlement This letter transmits an applicction for amendment to F " t ity ( . ting License

No. NPF-42 for Wolf Creek Generating Station (WCGS! chis license amendment request revises Technical Specification Sections 6. ar.d 6.12 to reflect a

. position change within the Wo' f Creek Nuclear OperatAng Corporation (WCNOC) a organization.

The Reference provided an application for conversion of the Current Technical

. Specifications to the Improved Technical Specifications. The requested organizational change also affects the Reference, and markups are provided in

-Attachment U to identify the change to the Improved Technical Specifications.

_ A Safety Evaluation of the proposed change is provided in Attachment I, and Attachment II provides a No Significant Hazards Consideration Determination.

Attachment III is the Environmental Impact Determination for the proposed change,-and the.mtrked-up Current Technical Specifiestion pages for this request

are provided in Attachment . IV. A marked-up Improved Technical Specifications

-page for this request is provioed in AttacLnent V.

In accordance with IC CFR 50.91, a copy of this revision to our original i application, with attachments, is oe. a provided to the designated Kansas State Offielal.

9802050016 900120 PDR ADOCK 05000482

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PO. Box 411/ Earti.9on. KS 66839 / Phone: [J16) 364-8831 t'

- An Equal Oppor. unity Employer M FMC. VET

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- ET 98-0005

- Page 2 of 2' If y6. 'have any questions concerning this matter,- picase ' contact . rrue at (316) 2e4-88U1, extension 4034, or Mr. Britt T. Mc-Kinney, at extension 4433.

Very truly yours, Nt Richar A. Muonch RAM /jad

- Attachments I- -- Safety Evaluation

'I I -- No Significant Hazards Consideration Determination III -- Environmental Impact Determination IV -- Proposed Current Technical Specification Change V -- Proposed Improved T<;nnical Specification Change cc: V. L. Cooper (KDHE), w/a W. D.1 Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a K. M. Thomas (NRC), w/a e

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< , Richard A.-Moench, of lawful age, being first' duly sworn-upon oath says~that

.helis Vice President Engineering -'of _ Wolf Creek Nuclear _ Operating: Corporation; 4

. that.he has read.the foregoing document and knows the content thereof; that he

has executed that same for and:on behalf of said Corporation with full' power

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-'and authority to do oo;-and';that-the facts therein stated are true and correct -

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.to the best of his knowledge, information and belief.

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. ,- .R. chard f.MuenctP-i Vice Prysident Enginee' ring SUBSCRIBEDandsworntobeforemethis-h Ge f. o f mapY,1998.

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' Attachment I to ET 98-0005 Page 1 of 2 4

i ATTACHMENT I SAFETY EVALUATION 4

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Attachment I to ET 98-0005 Page 2 of 2 Safety Evaluation Prorsed Change This amendment request propodes to revise Technical Specification Sections 6.3.lb and 6.12.lc to reflect an organization change. Wolf Creek Nuclear Operating Corporation (WCNOC) plan 3 to merge the positions of Superintendent Radiation Protection and Superintendent Chemistry into one new position, Manager Chemistry /Madiation Protection.

Evaluation 1ne duties of the Superintendent Radiation Protection will be merged with the duties of the Superintendent Chemistry into one new position, the Manager Chemistry / Radiation Pro'ection. Thir restructuring of the Chemistry and Radiation Protection Departments will p: ovide more effective management attention to radiation protection issues at Wolf Creek Generating Station (WCGS).

The replacement of the two supervisory positions with one management position will not change any of .he qualification requirements specified in the technical specifications. The new position of Manager Chemistry /Radiatien Protection will meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 for a Radiation Protection Manager. The new position will report to the Ple'.t Manager, as the Superintendent Chemistry and Superintendent Rao'C ion Protection currently do. This proposed change W 11 not affect any other positions. The structure of and the functions performed by the two groups under the two suoervisory positions, Chemistry Technicians and Radiation Protection Technicians, are very similar. Merging the two positions into one management position will enable WCNOC to eliminate one level of management and increase communication effectiveness between the twa g roiips , allowing both groups to work together more effectively. In addition, the individual who will be filling the new position is an experienced Radiation Protection Technician and Supervisor who meets the qualification requirements of Regulatory Guide 1.8, September 1975.

These changes are administrative in nature and will enhance the organizations.

structure of Wolf Creek Nuclecr Operat' 1 Corporation. These changes will not reduce overall organizational commitm- . Based on this discussion and the considerations presented in Attachment II, the proposed changes do not increase the probability cf occurrence or the consequences of an accident or malfunction of a different type than any previously evaluated in the safety analysis report; or reduce the margin of safety as defined in any technical specification. Therefore, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

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Attechmsnt II to ET 98-0005 Page 1 of 2.

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ATTACID4ENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION h

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. -AttachmentiII to ET 90-000$

• - -Page-2 of 2f No Significant Hazaros Consideration Determination 4

This amendrent request ' proposes to revise Technical Specification Sections-6.3.lb and L6.12. lc to ref1cet an organization change. Wolf Creek Nuclear Operating Corporation -(WCNOC) plans to merge the positions of Superintendent '

Radiation Protection and Superintendent Chemistry into one new position,

-Manager Chemistry / Radiation Protection.

Standard I - Involves A Significant Increase In The Probability -Or Consequences Of An Accident Previously Evaluattd

_ _ 'The proposed" change does not involve a significant increase in the probability

.of consequences of an accident previously evaluated. These changes involve administrative changes to the WCNOC organization.

Standard II Create The Possibility of A New Or Different Kind Of Accident From Anv Previously Evaluated.

The proposed changa does not create the possibility of a new or-different kind

, of accident from any accident previously evaluated. This change is cadministrative in nature and does not involve a change to the 3nstalled plant systems or the overall operating philosophy of Wolf Creek Generating Station.

Standard III Involve A Significant Reduction In The Margin Of Safety The proposed change does not involve a significant reduction in a margin of safety. This change does not involve any changes in overall organizati Tal commitments and will not affect qualification requirements of any unit staff personnel. A position and title change alone does not reduce the margin of safety.

Based on the above discursions it has been determined that the requested technical specification revision does not involve a .significant increase in J the~ probability or consequences of an accident or other adverse condition over previous evaluations; or involve a significant reduction in the margin of 4 safety. 3 9

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Attachment III to ET 98-0005 Page_1 of 2 ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION

AttachmentziII'to ET'98-0005 jPage 2'of'2;

..y i Environmental Impact Determination-

10 CFR 51.22(b) specifies the criteria for categorical = exclusions from the requirement : for a specific environmental asaessment per 10 CFR 51.21. - This amendment; request meets the criteria specified in 10 CFR 51.22 (c) (9) as specified-below:

m i (i)- the amendment involvss no significant hazards consideration As demonstrated in Attachment II, the proposed change does- not involve any signif' cant hazards consideration.

i (ii) there is no significant change in the types or significant

-increase in the amounts of any effirents that may be released-offsite i

)The proposed organizational chaages do not involve a change to the facility or

operating procedures which would create new types of effluents. The proposed

' changes do not involve any change in the manner of operation of any plant =

. systems -involving the generation, collection, storage or processing of

- radioactive materials or other types of effluents. Therefore, all offsite and t

i control room doses will remain within the limits of 10 CFR 100 and 10 CFR 50 Appendix A, GDC 19.

.(iii)' there'is no significant increase in. individual or cumulative <

occupational radiation exnosure

' The proposed organizational chanc,es do not involve a change to the facility or operating procedures which would create new types of effluents. The proposed changes do riot involve any change in the manner of operation of any plant -

systems involving the generation, collection, storage or processing- of radioactive n.a t e rials or other types of effluents. Implementation of the proposed changes will not involve work activities which cc tid contribate to occupational radiation exposure. Thus, these changes 'will not result in a l ~signifJeant increase .in individual or cumulative- occupational- radiation exposure.

' Based on -. the above, it is concluded' that thero will be no impact on .the environment resulting from the proposed changes and that the proposed changes-meet - the criteria ; specified in 10 CFR 51.22 for a categorical exclusion from

the - requirements of 10 CFR 51.21 relative to requiring' a specific environmentai assessment by the Commission. ,

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