Docket Nos. 50-266 and 50-301

Mr. C. W. Fay, Vice President Nuclear Power Department Wisconsin Electric Power Company 231 West Michigan Street, Room 308 Milwaukee, Wisconsin 53201

Dear Mr. Fay:

September 4, 1991

DISTRIBUTION: Docket Fi-rles NRC & Local PDRs PD33 Reading BBoger JZwolinski JHannon PKreutzer RSamworth OGC-OWFN DHagan GHill(8) Wanda Jones

CGrimes DBrinkman EWBrach ACRS(10) GPA/PA OC/LFMB PD33 Gray Region III, DRP

SUBJECT: AMENDMENT NOS. 128 AND 132T0 FACILITY OPERATING LICENSE NOS. DPR-24 AND DPR-27 (TACS NOS. 74344 AND 74345)

The Commission has issued the enclosed Amendment Nos. 128 and 132to Facility Operating License Nos. DPR-24 and DPR-27 for the Point Beach Nuclear Plant, Unit Nos. 1 and 2. The amendments revise the Technical Specifications in response to your application dated August 1 1989 (NRC-89-091) as supplemented by letters dated March 29, 1990 (NRC-90-028), and July 17, 1991 (NRC-91-067).

These amendments revise Technical Specification 15.6, Administrative Controls, to document changes to staff organization and to remove organization charts from the Technical Specifications.

A copy of the Safety Evaluation is also enclosed. will be included in the Commission's next biweekly

The notice of issuance Federal Register notice.

Sincerely,

Original- Signed By:

Robert B. Samworth, Sr. Project Manager Project Directorate 111-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Enclosures: 1. Amendment No. 12 8 to DPR-24 2. Amendment No. 132to DPR-27 3. Safety Evaluation

cc w/enclosures: See next page

LA:PDIII-3:DRPW PKr~etzerrPM:PDIII-3:DRPW

RSamworth/bj g / /"C-/91

PflC FILE CENTER C PY

D: P I -1 3:DRPW

DOCUMENT NAME: 74344 AND 74345 AMD

9109130050 PDR ADOCI P

910904 05000266

PDR

Pocket No• 50-266 and 50-301

Mr. C. W. Fay, Vice President Nuclear Power Department Wiscunsin Electric Power Company 231 West Michigan Street, Room 308 Milwaukee, Wisconsin 53201

Dear Mr. Fay:

September 4, 1991

DISTRIBUTION: Docket Files NRC & Local PDRs PD33 Reading BBoger JZwolinski JHannon PKreutzer RSamworth OGC-OWFN DHagan GHill(8) Wanda Jones

CGrimes DBrinkman EWBrach ACRS(10) GPA/PA OC/LFMB PD33 Gray Region III, DRP

SUBJECT: AMENDMENT NOS. 128 AND 132T0 FACILITY OPERATING LICENSE NOS. DPR-24 AND DPR-27 (TACS NOS. 74344 AND 74345)

The Commission has issued the enclosed Amendment Nos. 128 and 132to Facility Operating License Nos. DPR-24 and DPR-27 for the Point Beach Nuclear Plant, Unit Nos. I and 2. The amendments revise the Technical Specifications in response to your application dated August 1 1989 (NRC-89-091) as supplemented by letters dated March 29, 1990 (NRC-90-0281, and July 17, 1991 (NRC-91-067).

These amendments revise Technical Specification 15.6, Administrative Controls, to document changes to staff organization and to remove organization charts from the Technical Specifications.

A copy of the Safety Evaluation is also enclosed. will be included in the Commission's next biweekly

The notice of issuance Federal Register notice.

Sincerely,

QriginaJ Signed By;

Robert B. Samworth, Sr. Project Manager Project Directorate 111-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Enclosures: 1. Amendment No. 128 to DPR-24 2. Amendment No. 132 to DPR-27 3. Safety Evaluation

cc w/enclosures: See next page

LA:PDIII-3:DRPW PK.Y.etzer

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" PM:PD II1-3:DRPW RSamworth/bj g /5/1

D:P•• I-3:DRPW S15/91

DOCUMENT NAME: 74344 AND 74345 AMD

r/9 1

Mr. C. W. Fay Point Beach Nuclear Plant Wisconsin Electric Power Company Unit Nos. 1 and 2

cc:

Ernest L. Blake, Jr. Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Washington, DC 20037

Mr. Gregory J. Maxfield, Manager Point Beach Nuclear Plant Wisconsin Electric Power Company 6610 Nuclear Road Two Rivers, Wisconsin 54241

Town Chairman Town of Two Creeks Route 3 Two Rivers, Wisconsin 54241

Chairman Public Service Commission

of Wisconsin Hills Farms State Office Building Madison, Wisconsin 53702

Regional Administrator, Region III U.S. Nuclear Regulatory Commission Office of Executive Director

for Operations 799 Roosevelt Road Glen Ellyn, Illinois 60137

Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, Wisconsin 54241

,Ip,$k REGI,

- J UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555

WISCONSIN ELECTRIC POWER COMPANY

DOCKET NO. 50-266

POINT BEACH NUCLEAR PLANT, UNIT NO. 1

AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 128 License No. DPR-24

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Wisconsin Electric Power Company (the licensee) dated August 1, 1989, as supplemented March 29, 1990 and July 17, 1991, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

9109130052 910904 PDR ADOC C05000266 P PDR

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-24 is hereby amended to read as follows:

B. Technical Specifications

The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 128 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective immediately upon issuance. The Technical Specifications are to be implemented within 20 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Robert B. Samworth, Sr. Project Manager Project Directorate 111-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Attachment: Changes to the Technical

Specifications

Date of issuance: September 4, 1991

;iREGU

0

UNITED STATES NUCLEAR REGULATORY COMMISSION

o WASHINGTON. D.C. 20655

WISCONSIN ELECTRIC POWER COMPANY

DOCKET NO. 50-301

POINT BEACH NUCLEAR PLANT, UNIT NO. 2

AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 132 License No. DPR-27

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Wisconsin Electric Power Company (the licensee) dated August 1, 1989, as supplemented March 29, 1990 and July 17, 1991, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-27 is hereby amended to read as follows:

B. Technical Specifications

The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 132 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective immediately upon issuance. The

Tecnnical Specifications are to be implemented within 20 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Robert B. Samworth, Sr. Project Manager Project Directorate 111-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Attachment: Changes to the Technical

Specifications

Date of issuance: September 4, 1991

ATTACHMENT TO LICENSE AMENDMENT NOS. 128 AND 132

TO FACILITY OPERATING LICENSE NOS. DPR-24 AND DPR-27

DOCKET NOS. 50-266 AND 50-301

Revise Appendix A Technical Specifications by removing the pages identified

below and inserting the enclosed pages. The revised pages are identified by

amendment number and contain marginal lires indicating the area of change.

REMOVE INSERT

15.6.1/2-1 15.6.1/2-1

15.6.2-2 15.6.2-2

15.6.2-3

15.6.2-4

Figure 15.6.2-1

Figure 15.6.2-2

Figure 15.6.2-3

Figure 15.6.2-4

15.6.3-1

15.6.3-2

15.6.4/5-1

15.6.5-2

15.6.5-5

15.6.3-1

15.6.3-2

15.6.4/5-1

15.6.5-2

15.6.5-5

15.6 ADMINISTRATIVE CONTROLS

15.6.1 RESPONSIBILITY

15.6.1.1 The Manager - Point Beach Nuclear Plant (hereinafter

referred to as the Manager) shall be responsible for

overall facility operation and shall delegate in writing

the succession to this responsibility during absences

from the Point Beach Nuclear Plant area of greater than

48 hours and where ready contact by telephone or other

means is not assured.

15.6.1.2 The Duty Shift Superintendent (or during his absence

from the control room, the Duty Operating Supervisor)

shall be responsible for the Control Room Command

function.

15.6.2 ORGANIZATION

15.6.2.1 Onsite and offsite organizations shall be established

for plant operation and corporate management,

respectively.

a. 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. These

relationships shall be documented and updated, as

appropriate, in the form of organization charts,

functional descriptions of departmental responsi

bilities and relationships, and job descriptions for

key personnel positions, or in equivalent forms of

documentation. These requirements shall be documented

in the Point Beach Nuclear Plant Final Safety.Analysis

Report, or plant procedures.

b. The Manager shall be responsible for overall plant

safe operation and shall have control over those

onsite activities necessary for safe operation and

maintenance of the plant.

Unit 1 - Amendment No. ý,•JJ28 15.6.1/2-1 Unit 2 - Amendment No. 40,0$,132

15.6 ADMINISTRATIVE CONTROLS (Continued)

15.6.2 ORGANIZATION (Continued)

15.6.2.1 (Continued)

c. The Vice President - Nuclear Power shall have

corporate responsibility for overall plant nuclear

safety and shall take any measures needed to ensure

acceptable performance of the st.iff in operating,

maintaining, and providing technical support to the

plant to ensure nuclear safety.

d. The individuals who carry out health physics and

quality assurance functions may report to the

appropriate onsite manager; however, they shall have

sufficient organizational freedom to ensure their

independence from operating pressures.

FACILITY STAFF

15.6.2.2 Facility staffing shall be subject to the following

requirements:

a. Each on-duty shift shall normally be composed of at

least the minimum shift crew composition (for all

modes except with a unit defueled) as follows:**

1. Shift Superintendent (SRO)* - one per shift

2. Duty Technical Advisor - one per shift

3. Operating Supervisor (SRO)* - one per shift

4. Operator (RO)* - two per shift for one unit

operation

- three per shift for two unit

operation

5. Operator - two per shift for one unit operation

- three per shift for two unit operation

6. The Duty Technical Advisor is located on-site on

10 minute call to the control room.

b. At least one licensed Operator shall be in the control

room when fuel is in either reactor..

Unit 1 - Amendment No. 0;,X1,128 15.6.22 Unit 2 - Amendment No. 0,M132--

15.6 ADMINISTRATIVE CONTROLS (Continued)

15.6.2 ORGANIZATION (Continued)

FACILITY STAFF (Continued)

15.6.2.2 (Continued)

c. At least two licensed Operators shall be present in

the control room during reactor start-up, scheduled

reactor shutdown and during recovery from reactor

trips.

d. An individual qualified in radiation protection

procedures shall be on site when fuel is in either

reactor.**

e. All CORE ALTERATIONS shall be directly supervised

by either a licensed Senior Reactor Operator or

Senior Reactor Operator Limited to Fuel Handling

who has no other concurrent responsibilities during

this operation.

f. A Fire Brigade of at least 5 members shall be main

tained onsite at all times.** This excludes 3 members

of the minimum shift crew necessary for safe shutdown

of the plant and any personnel required for other

essential functions during a fire emergency.

g. The Superintendent - Operations shall hold a senior

reactor operator license.

*SRO = NRC Senior Reactor Operator License

RO = NRC Reactor Operator License

** This shift may be less than the minimum requirements for a period of time not to exceed 2 hours in order to accommodate unexpected absence of personnel, provided immediate action is taken to restore the shift makeup to within the minimum requirements.

Unit 1 - Amendment No. J;,97,128 15.6.2-3 Unit 2 - Amendment No. 4,9,132

15.6 ADMINISTRATIVE CONTROLS (Continued)

15.6.2 ORGANIZATION (Continued)

FACILITY STAFF (Continued)

15.6.2.3 Duty & Call Superintendent

a. To assist and counsel the Shift Superintendent in

case of significant operating events, a Duty & Call

Superintendent group has been established. The Duty

& Call Superintendent group shall consist of quali

fied persons designated in writing by the Manager.

b. In the event of a reportable occurrence, the Shift

Superintendent shall communicate with at least one

Duty & Call Superintendent before taking other than

the immediate on-the-spot action required. One

Duty & Call Superintendent will be assigned to be

"on call" at all times.

Unit 1 - Amendment No. 97,128 15.6.2-4 Unit 2 - Amendment No. W,132

!5.f.3 Fcilt-, Staff Qualifications

15.6.3.1 Each member of the facility staff shall meet or exceed the minimum

qualifications of ANSI N18.l-1971 for comparable positions or as clarified

in 15.6.3.2 through 15.6.3.4.

15.6.3.2 Except as provided in 15.6.3.3, the Superintendent - Health Physics

shall meet.the following requirements:

a. The individual shall have a bachelor's degree or the equivalent in a science or engineering subject, including some formal training in radiation protection. For purposes of this paragraph, "equivalent" is as follows:

(1) Four years of formal schooling in science or engineering; or

(2) Four years of applied radiation protection experience at a nuclear facility; or

(3) Four years of operational or technical experience or

training in nuclear power; or

(4) Any combination of the above totalling four years.

b. Except as provided in d., below, the individual shall have at least five years of professional experience in applied radiation protection. A master's degree in a related field is equivalent to one year of experience and a doctor's degree in a related field is equivalent to two years of experience.

c. Except as provided in d., below, at least three of the five years of experience shall be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power plants.

d. If the individual has a bachelor's degree specifically in health physics, radiological healf), or radiation protection, at least three years of professiu,.al experience is required; if the individual has a master's or a doctor's degree specifically in health physics, radiological health, or radiation protection, at least two years of professional experience is required. This experience shall be in applied radiation protection in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power plants.

15.6.3-1 Unit 1 - Amendment No. , 0 U,128 Unit 2 - Amendment Nlo. , UA, 12

15.6.3.3 In the event the position of Superintendent - Health Physics is

vacated and the proposed replacement does not meet all the qualifica

tions of 15.6.3.2, but is determined to be otherwise well qualified,

the concurrence of NRC shall be sought in approving the qualification

of that individual.

15.6.3.4 The Duty Technical Advisor shall have a bachelor's degree or

equivalent in a scientific or engineering discipline with specific

training in plant design and response and analysis of the plant for

transients and accidents. The Duty Technical Advisor shall also

receive training in plant design and layout including the capabil

ities of instrumentation and controls in the control room.

Unit 1 - Amendment No. R,710,128 15.6.3-2 Unit 2 - Amendment No. RM,132

I

15.6.4 TRAINING

15.6.4.1 A retraining and replacement training program for the facility

staff shall be maintained under the direction of the Super

intendent - Training and shall meet or exceed the requirements

and recommendations of Section 5.5 of ANSI N18.1-1971 and

10 CFR Part 55.

15.6.4.2 A training program for the Fire Brigade shall meet or exceed

the requirements of Section 27 of the NFPA Code-1976, except

that the meeting frequency may be quarterly.

15.6.5 REVIEW AND AUDIT

15.6.5.1 Manager's Supervisory Staff

15.6.5.1.1 The Manager's Supervisory Staff (MSS) shall func

tion to advise the Manager on all matters related

to nuclear safety.

15.6.5.1.2

15.6.5.1.3

The Manager's Supervisory Staff shall be

selected from the following:

Chairman: Manager - Point Beach Nuclear Plant Member: General Superintendent - Maintenance Member: General Superintendent - Operations Member: Superintendent - Operations Member: Superintendent - Maintenance Member: Superintendent - Technical Services Member: Superintendent - Training Member: Superintendent - Chemistry Member: Superintendent - Health Physics Member: Superintendent - Instrumentation &

Control

Alternate members may be appointed by the MSS

Chairman to serve on a temporary basis; however,

no more than two alternates shall vote in MSS at

any one time. Such appointment shall be in writing.

Unit 1 - Amendment No. 4,•J,17,,123 15.6.4/5-1 Unit 2 - Amendment No. •,,7•,•7,132

I

15.6.5 REVIEW AND AUDIT (Continued)

15.6.5.1 Manager's Supervisory Staff (Continued)

15.6.5.1.4 The MSS shall meet at least once per calendar

month and as convened by the MSS Chairman.

15.6.5.1.5 A quorum of the MSS shall consist of the Chairman

or his designated alternate and five members

including alternates.

15.6.5.1.6 The MSS shall have the following duties:

a. Review procedures as required by these Technical Specifications. Review other procedures

or changes thereto which affect nuclear safety as determined by the Manager.

b. Review all proposed tests and experiments related to nuclear safety and the results

thereof when applicable.

c. Review all proposed changes to Technical

Specifications.

d. Review all proposed changes or modifications to plant systems or equipment where changes affect nuclear safety.

e. Periodically review plant operations for

nuclear safety hazards.

f. Investigate violations or suspected violations of Technical Specifications, such investigations to include reports, evaluations and recommendations.

g. Perform special reviews, investigations or prepare reports thereon as requested by the Chairman of the Off-Site Review Committee.

15.6.5-2 Unit 1 - Amendment No. $0, $2V 128 Unit 2 - Amendment No. $0, AO, W32

15.6.5.2.5 The OSRC shall meet at least twice per year at approximately six

month intervals.

QUORUJM

15.6.5.2.6 A quorum of the OSRC shall consist of not less than a majority of the

members or designated alternates and shall include the Chairman or his designated

alternate. No more than a minority of the quorum shall have line responsibility

for operation of the facility.

REVIEW

15.6.5.2.7 The OSRC shall review:

a) The safety evaluations for 1) changes to procedures, equipment

or systems, and 2) tests or experiments completed under the

provision of 10 CFR, Section 50.59, to verify that such

actions did not constitute an unreviewed safety question.

b) Proposed changes to procedures, equipment or systems which

involve an unreviewed safety question as defined in

10 CFR, Section 50.59.

c) Proposed tests or experiments which involve an unreviewed

safety question as defined in 10 CFR Section 50.59.

d) Proposed changes in Technical Specifications or Licenses.

e) Violations of applicable statutes, codes, regulations, orders,

Technical Specifications, license requirements, or of internal

procedures or instructions having nuclear safety significance.

f) Significant operating abnormalities or deviations from normal

and expected performance of plant equipment that affect

nuclear safety.

g) All reportable events.

15.6.5-5 Unit I - Amendment No. 79,U,7j,1,128 Unit 2 - Amendment No. Z,,093MI7,132

I ý EG",

UNITED STATES NUCLEAR REGULATORY COMMISSION

S, WASHINGTON. D.C. 2055

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. IZ2 AND 132 TO

YACILITY OPERATING LICENSE NO5. DPR-24 AND DPR-27

WISCONSIN ELECTRIC POWER COMPANY POINT BEACH NUCLEAR PLANT UNIT NOS."1 AND 2

DOCKET NOS. 50-26 AND 50-301

1.0 INTRODUCTION

By letter dated August 1, 1989 Wisconsin Electric Power Company proposed revising Technical Specification Section 15.6, ADMINISTRATIVE CONTROLS, to document changes to the staff organization and to remove the organization charts. New wording is proposed to be added to Sections 15.6.2.1 and 15.6.2.2 to include essential aspects to the organization charts not otherwise included in the Technical Specifications. Guidance for these proposed changes was provided to licensees and applicants by Generic Letter 88-06, "Removal of Organizational Charts from Technical Specification Administrative Control Requirements" (GL 88-06), on March 22, 1988.

In addition to the changes covered by the Generic Letter the licensee proposed other substantive changes to Section 15.6. Technical Specification 15.6.2.2.d, which requires the presence of an individual qualified in radiation protection when fuel is in either reactor, would be revised to allow this position to be unfilled for up to 2 hours to accommodate unexpected absences.

The proposed amendment would increase the quorum requirements for meetings of the Manager's Supervisory Staff set forth in Technical Specification 15.6.5.1.5 and the Offsite Review Committee set forth in Technical Specification 15.6.5.2.6.

Several non-substantive changes in Section 15.6 were also proposed. These relate to such organizational changes as job titles and outdated requirements.

A subsequent letter from WEPCo dated March 29, 1990 withdrew a portion of the August 1989 amendment application which would have changed the reporting of the Offsite Review Committee to the CEO instead of the President. The March 29, 1990 retraction was made because of a restructuring of the WEPCo corporate organization which occurred after August 1989 and which made the change unnecessary.

By letter dated July 17, 1991, the licensee discussed additional modifications to the wording for two of the proposed technical specification changes. The new wording does not represent substantive changes to the August 1, 1989 amendment application.

9109130054 910904 PDR ADOCK 05000266 P PDR

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2.0 EVALUATION

Consistent with guidance provided by the staff at the time of licensing, the Point Beach Nuclear Plant Technical Specifications Section 15.6 include offsite and plant organizational charts for the purpose of achieving administrative controls. Restructuring of either the offsite or the plant organizations, subsequent to the issuance of the operating licenses for the two units, has required WEPCo, as it has cther licensees, to submit an application for license amendment for NRC approval to reflect the desired organizational changes.

Because of the limitation this imposes on organizational structure, the nuclear industry highlighted this as an area for improvement in the technical specifications. The Shearon Harris licensee proposed changes to remove organization charts from its technical specifications under the lead plant concept that included the endorsement of the proposed changes by the Westinghouse Owners Group. In the course of its review of the Shearon Harris proposal, the staff concluded that most of the essential elements of offsite and onsite organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR Part 50. However, the staff found that there are aspects of the organizational structure that are important to ensure that the administrative control requirements of 10 CFR 50.36 will be met and that these aspects are included in 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 the organization charts for Shearon Harris that were essential for conformity with regulatory requirements were retained in other sections of the technical specifications.

Subsequent to the issuance of the Shearon Harris technical specifications, the staff issued GL 88-06 to provide guidance to all licensees on acceptable format for license amendments removing organization charts.

GL 88-06 set forth the staff position on administrative controls pertaining to organization. Essentially the generic letter identified the specific elements of utility organization which bear directly on operational safety and

thus should be included in the technical specifications, while acknowledging that the inclusion of the additional detail of the actual organization charts generates additional licensing work contributing little to safety. The generic letter concluded that the only aspects of the organization charts which are important to safety, which are not covered by other specifications, and which therefore must remain in technical specifications are those conditions listed below:

(1) A requirement that lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental

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responsibilities and relationships, and job descriptions for key personnel

positions, or in equivalent forms of documentation.

(2) Designation of an executive position that has corporate responsibility for

overall plant nuclear safety and authority to take such measures as may be

needed to ensure acceptable performance of staff in operating, maintaining,

and providing technical support to the plant to ensure nuclear safety.

(3) Designation of a management position in the onsite organization that is

responsible for overall unit operation and has control over those onsite

activities necessary for safe operation and maintenance of the plant.

(4) Designation of those positions in the onsite organization that require a

senior reactor operator (SRO) or reactor operator (RO) license.

(5) Provision of sufficient organizational freedom to be independent of

operational pressures to those individuals who perform the functions of health

physics, quality assurance, and training of the operating staff.

The generic letter found that "(s)ince the above conditions will be maintained

in the technical specifications, removal of the organization charts represents

no reduction in safety requirements. These changes will simply allow licensees

to implement changes in their organization structure without obtaining NRC

approval."

The generic letter contained two other provisos: The organizational information

described above must be incorporated in a referenceable document before the

technical specifications are revised, and, if a position requires a Senior

Reactor Operator License or a Reactor Operator License, then that requirement

must appear in the technical specifications

The generic letter provided applicants and licensees with a copy of the Standard

Technical Specifications for Westinghouse Pressurized Water Reactors (STS) revised

to illustrate the format of changes.

The licensee's letter of August 1, 1989 listed nine changes:

Change 1. A new section, 15.6.1.2., is added which specifies that the Duty

Shift Superintendent (or in his absence the Duty Operating Supervisor) shall

be responsible for the control room command function. The licensee notes

that this is not a change in its organization or policy. This information

had not been in the technical specifications previously. This specification

is included in the model STS.

Staff evaluation of Change 1. This change is not addressed in the generic

letter and thus is not covered by the conclusions in the generic letter.

However the staff believes that inclusion of the requirement strengthens the

technical specifications. As noted by the licensee, the STS include a

section designating the responsibility for the control room command.

Therefore this change is acceptable.

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Change 2. This change affects the technical specifications in a number of places:

a.) Four organization charts (Figure 15.6.2-1, "Management Organization Chart;" Figure 15.6.2-2, "Conduct of Plant Operations;" Figure 15.6.2-3, "Wisconsin Electric Power Company Offsite Management Fire Protection Organization;" and Figure 15.6.2-4, "Point Beach Nuclear Plant Fire Protection Organization") are proposed to be removed.

b.) Technical Specification 15.6.2.1 is to be revised to include the requirement that onsite and offsite organizations be established. The July 17, 1991 letter modified the proposed wording to incorporate into 15.6.2.1.a. the wording from the STS.

c.) A further revision to this section will designate responsibility for overall plant safe operation to the Manager and will designate the Vice-President Nuclear Power as having corporate responsibility for overall nuclear safety.

d.) A new paragraph d is proposed to be added to specify that individuals who carry out health physics and quality assurance functions have sufficient organizational freedom to be independent of operational pressures.

e.) Section 15.6.2.2.a is to be revised to include personnel requirements for minimum shift crew.

f.) Specification 15.6.2.2.g is to be added to require that the Superintendent-Operations hold a senior reactor operators license.

Staff evaluation of Change 2.a. Removal of Figure 15.6.2-1 and Figure 15.6.2-2 is consistent with the generic letter. The licensee states that Figures 15.6.2-1 and 15.6.2-2 are in the FSAR as Figures 12.2-1 and 12.2-2. This meets the intent

of the GL since changes to the FSAR are subject to the review requirements of 10 CFR 50.59.

The charts are removed and the information on the charts not already included elsewhere in the technical specifications has been added.

Removul of Figure 15.6.2-3 and Figure 15.6.2-4 is not covered by the generic letter. These two figures pertain to the fire protection organization and fire protection brigade. The licensee states that the Point Beach Nuclear Plant Administrative Control Policies and Procedures Manual, Chapter 1.7.5, describes the fire protection organization and contains the fire protection and fire brigade organization charts. Although the generic letter did not address removal of the fire protection organization charts, the same analysis is applicable. Inclusion of fire protection program elements in plant procedures provides the control afforded by inclusion in the technical specifications or in the FSAR. Technical Specification 15.6.8.1, "Plant Operating Procedures," requires that procedures be provided for fire protection implementation.

Removal of the charts from the technical specifications gives the licensee flexibility in making revisions without prior staff approval. Furthermore, the fire protection technical specifications were the subject of Generic Letter 88-12. This later generic letter provided a basis for licensees to

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remove fire protection requirements from the technical specifications and to place them into documents subject to the controls of 50.59. WEPCo has not acted in response to GL 88-12. The staff recognizes that there may be other improvements to the Point Beach technical specifications resulting from a more comprehensive response to GL 88-12. However, the staff finds the request to remove these two figures from the technical specifications acceptable.

Staff evaluation of Changes 2.b. through 2.f. These changes all add information to the technical specifications which appeared on Figures 15.6.2-1 and 15.6.2-2. They satisfy the five conditions listed in GL 88-06. Therefore they are acceptable.

Condition 5 in the GL requires that individuals who perform functions of health physics, quality assurance, and training be independent of operational pressures. Proposed new section 15.6.2.1.d provides this organizational freedom to those performing the health physics and quality assurance functions. However it does not include training staff. In its amendment application letter the licensee states that the "Superintendent-Training does not report to the SuperintendentOperations, and thus is operationally independent of the operations group." It further states its belief that "training personnel should be excluded from this provision to permit assignment of trainees to operations for on-the-job training duties and the temporary assignment of operations staff to training functions."

The organization chart in the FSAR, Figure 12.2-2, shows the SuperintendentTraining reporting to the General Superintendent-Operations. The SuperintendentOperations also reports to the General Superintendent-Operations. This organization affords only a moderate degree of independence. However, the staff concurs with the licensee's belief reflecting on the practicality of achieving total independence.

Change 3. Section 15.6.2.2.a will be revised by adding a footnote to the effect that a period of time not to exceed 2 hours can pass without the required crew composition in the on-duty shift in order to accommodate unexpected absences provided immediate action is taken to get a qualified individual onto the site.

Section 15.6.2.2.d will be revised by adding the same footnote to the effect that a period of time not to exceed 2 hours can pass without an individual qualified in radiation protection procedures on site in order to accommodate unexpected absences provir' ' immediate action is taken to get a qualified individual onto the site.

Staff evaluation of Change 3. The addition of the footnote to item 15.6.2.2.a adds information which was on Figure 15.6.2-2. This change is consistent with the guidance and intent of the generic letter and is therefore acceptable.

The addition of the footnote to item 15.6.2.2.d was not considered in the generic letter. The technical specification requires an individual qualified in radiation protection procedures to be on site when fuel is in either reactor. The footnote would allow a 2-hour grace period in which the position could be unfilled provided immediate action is taken to fill the position. This change would accommodate an unexpected absence.

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In proposing this change the licensee stated that it has made a change in its procedure for filling this position. At one time the licensee filled the position by ensuring that a member of the operations group on-duty shift was qualified in radiation protection procedures. They now maintain 24-hour coverage by the staff of the health physics group. The proposed change is consistent with the staff position as set forth in the standard Westinghouse technical specification and is therefore acceptable.

Change 4. Sections 15.6.3.2 and 15.6.3.3 are revised to make the requirements contained therein applicable to the Superintendent-Health Physics instead of the Health Physicist.

Staff evaluation of Change 4. This change and Change 5 were not covered directly by the generic letter and therefore are not covered by the safety review therein. However, they are covered indirectly in that these two

changes are typical of changes which the staff anticipated might be made by the licensee under 50.59 following implementation of the GL.

The licensee states that the intent of specifications 15.6.3.2 and 15.6.3.3 is that the qualifications set forth be those of the senior person in the health physics organization. The licensee has created the new position,

Superintendent-Health Physics, which is now the senior person. The creation

of the new position is a licensee action which is not subject to NRC review

and approval. The amendment of the technical specifications to indicate

this organizational change has no significant safety impact. Therefore

the staff finds the change acceptable.

Change 5. Technical Specification 15.6.5.2 is to be revised to reflect the

following changes to the Manager's Supervisory Staff:

a. Two new positions, General Superintendent-Maintenance and General

Superintendent-Operations, have replaced the single position of General

Superintendent.

b. The title of the Superintendent-Maintenance & Construction is changed to

Superintendent-Maintenance.

c. The title of the Superi-tendent-Reactor Engineering has changed to

Superintendent-Technical Services.

d. The position of Superintendent-Chemistry & Health Physics has been replaced

with two positions, Superintendent-Chemistry and Superintendent-Health Physics.

The positions of Radiochemist and Health Physics are eliminated from the Manager's Supervisory Staff.

e. The Position of Superintendent-Engineering, Quality & Regulatory Services,

has been eliminated and is to be removed from the listing of Manger's Supervisory Staff.

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Staff evaluation of Change 5. The licensee has made five organizational changes which in turn necessitate the changes to the technical specifications. The organizational changes are not subject to NRC review and approval. The corresponding revision of the technical specifications to reflect the organizational changes in the composition of the Manager's Supervisory Staff has no significant safety impact. Therefore the staff finds the changes acceptable.

Change 6. Technical Specification 15.6.5.1.5 is to be revised to show that the quorum of the MSS shall include five members instead of four.

Staff evaluation of Change 6. The amendment increases the number of members of the Manager's Supervisory Staff who must be present at meeting to take actions. The licensee states that this increase "will serve to enhance the proper execution of staff functions by providing a broader review base." The staff concurs that this is a positive effect. Therefore this change is acceptable.

Change 7. Editorial changes are to be made to Technical Specifications 15.6.5.2.5 and 15.6.2.2.e, deleting obsolete clauses specifying actions to be taken for the operating cycle following the initial fuel loadings.

Staff evaluation of Change 7. The amendment removes requirements which were only effective during the initial cycle of operation. This is an administrative change of no safety significance. Therefore, the change is acceptable.

Change 8. Technical Specification 15.6.5.2.6 shall be changed to say that a quorum of the offsite review committee shall consist of not less than a majority of the members or alternates. The quorum is currently specified to be a number which is less than the majority.

Staff evaluation of Change 8. The amendment changes the definition of a quorum for the offsite review committee. In the existing technical specification the Chairman or his designated alternate and three members would have to be present. As amended, a majority of members including the Chairman or his designated alternate would have to be present. At the present time the OSRC consists of 8 members including the Chairman. Thus, for the present time at

least, this would strengthen the requirement. The licensee also states that the

proposed amendment follows American NWional Standards Institute N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear

Power Plants" section 4.3.2.3, "Quorum." The licensee is committed to the ANSI

standard and by meeting the ANSI standard has been complying with the current technical specification. The staff finds the wording of the ANSI reference acceptable and therefore the change is acceptable.

Change 9. Several changes were proposed specifying reporting to the WEPCo Chief Executive Officer rather than to the President. These proposed changes were withdrawn by the supplemental letter dated March 29, 1990.

Staff evaluation of Change 9. As note above, the ninth proposed change was withdrawn by letter dated March 29, 1990.

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The changes which are made in accordance with the generic letter are consistent with the requirements of the generic letter and are acceptable. The changes which are not covered by the generic letter have been reviewed and have been found to have no safety significance.

3.0 STATE CONSULTATION

In accordance with the Comnmission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

These amendments relate to changes in recordkeeping, reporting, or administrative

procedures ur requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant

to 10 CFR 51.22(b) no environmental impact statement or environmental assessment

need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The staff has 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, (2) such activities

will he conducted in compliance with the Commission'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.

Principal Contributor: Robert Samworth

Date: September 4, 1991