AECM-87-0151, Application for Amend to License NPF-29,consisting of Proposed Change to OL PCOL-87/08,providing Two Manager Sys to QA Organization.Description of Changes Encl.Fee Paid
| ML20236H079 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/31/1987 |
| From: | Kingsley O SYSTEM ENERGY RESOURCES, INC. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236H081 | List: |
| References | |
| AECM-87-0151, AECM-87-151, NUDOCS 8708050055 | |
| Download: ML20236H079 (9) | |
Text
l SYSTEM ENERGY RESOURCES, INC.
Omp D KynEv,JR vce nesmo July 31, 1987 ;
Nuc e c w anons i
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i Attention: Document Control Desk Gentlemen: !
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 )
License No. NPF-29 t SERI Organizational Changes Proposed Amendment to the Operating License (PCOL-87/08)
System Energy Resources, Inc. (SERI) is submitting by this letter a proposed amendment to the Grand Gulf Operating License. This amendment contains primarily administrative changes to the Offsite Organization and were discussed informally with your staff on July 30, 1987. The proposed changes to the present Quality Assurance Organization will provide a two manager system that will have a clear separation of the department's in-line functions of nondestructive examination, inspection, review and deficiency control from the independent oversight functions of audits, procurement quality, support and observations / assessments. The proposed change to the projects area under the Site Director will provide a more equal distribution of workload and a more effective management chain of command for plant projects. Other changes i involve title changes to more accurately reflect present level of responsibility. As done with previous changes to the organization, SERI plans to implement these proposed changes upon submittal of this letter.
In accordance with the provisions of 10 CFR 50.4 and 50.30, the signed original of the requested amendment is enclosed and the appropriate copies will be distributed. The attachment provides the technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee and the Safety '
raview Committee. ,
Based on the guidelines presented in 10 CFR 50.92, SERI has concluded that this proposed amendment involves no significant hazards considerations.
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385 SNP i00
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. AECM-87/0151 Page 2 In accordance with the requirements of 10 CFR 170.21, an application fee of $150 is attached to this letter.
Your, uly, i
I lj ODK:bms Attachments: 1. Remittance of $150 Application Fe l
- 2. Affirmation per 10 CFR 50.30 7
- 3. GGNS PCOL-87/08 cc: Mr. T. H. Cloninger (w/a)
Mr. R. B. MMehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o) !
Mr. R. C. Butcher (w/a)
Dr. J. Nelson Grace, Regional Administrator (w/a)
U. S. Nuclear Regulatory Commission Region II ,
101 Marietta St., N. W., Suite 2900 J Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)
Office of Nuclear Ructor Regulation 1
U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Dr. Alton B. Cobb (w/a)
State Health Officer State Board of Health Box 1700 Jackson, Mississippi 39205 I
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0. NPF-29 DOCKET N0. 50-416 IN THE MATTER OF 1
MISSISSIPPI POWER & LIGHT COMPANY j and j SYSTEM ENERGY RESOURCES, INC. .q and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION
.I, 0. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi' Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this j application as Vice President, Nuclear Operations of System Energy. Resources, Inc.; and that the statements made and the matters set for erein are true and correct to the best of my knowledge, information and f.
"O. W.' Kin 1 STATE OF MISSISSIPPI COUNTY OF HINDS Public, in and for the County and State above named, this g day ofSUBSCRIBED ro AND
, 1987. SWORN T0 be (SEAL)
. 4Al- n k My commission expires:
Ny Commissbu Expires Sep. 21, 1937, J16AECM87673101~-'4
3 SERI ORGANIZATION CHANGES Proposed changes are presented in two parts as I. QA Changes and II. Projects and Operations Analysis Changes.
I. QA-87/01 Quality Assurance Department Organization Chnges
SUBJECT:
Technical Specification Figure 6.2.1-1, Offsite Organization, Section 6.5.1.2, Plant Safety Review Committee Composition, and Section 6.5.2.2 Safety Review Conmittee Composition; pages 6-3, 6-7 and 6-9.
DISCUSSION: SERI plans to revise the Offsite Organization as shown on the attached mark up Figure 6.2.1-1. The organization changes proposed in this submittal were discussed with members of your staff on July 15, 1987. SERI plans to implement these changes upon submittal of this letter. These organizational changes are proposed to accomplish the following goals:
o Increase the effectiveness of QA's interface with other departments. The proposed two manager system provides for clear separation of the department's in-line functions of nondestructive examination, inspection, review and deficiency control from the independent oversight functions of audits, procurement quality, support and observations /
assessments.
o Increase the effectiveness of QA's internal operations.
- Consolidates previously separated audit functions under one manager.
- More evenly distributes work load and responsibilities between managers.
- Enhances the departmental team building process.
o Re-emphasizes SERI's transition from compliance based to performance based evaluations.
The proposed changes to the Offsite Organization chart, Figure 6.2.1-1, and Sections 6.5.1.2 and 6.5.2.2 are as follows:
- 1) Change the present position of Director, Quality Assurance to Director, Quality Programs on Figure 6.2.1-1 and Section 6.5.2.2.
- 2) Change the present position of Manager, Nuclear Site QA to Manager, Quality Services on Figure 6.2.1-1 and Section 6.5.1.2.
- 3) Change the present position of Manager, Audits QA to Manager, Quality Systems on Figure 6.2.1-1..
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- 4) Delete the present position of Manager, Programs QA from Figure 6.2.1-1.
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i JUSTIFICATION: The proposed organization changes will strengthen and increase the effectiveness of the SERI Quality Assurance department. The separation of the in-line and independent functions will facilitate the transition of SERI's focus from compliance orientation to the much broader scope of <
performance and effectiveness. This separation further allows for aggressive problem investigation and solution without compromising the independence role. Consolidation ,
of areas with similar responsibilities will create a more effective organizational structure.
- 1) The present Manager, Nuclear Site QA is responsible for providing in-line functions of inspection, non-destructive examination and nonconformance document i reviews, as well as the independent function-of implementation audits.
The proposed change to the organization will change -1 the title of Manager, Nuclear Site _ QA to Manager, Quality Services. This change will add the respons-ibility for in-line functional procedure reviews currently under the Manager, Programs QA.
Currently, the Manager, Nuclear Site QA reports directly to the Director, Quality Assurance and is a voting member of the Plant Safety Review Committee.
These relationships will be unchanged. i
- 2) The present Manager, Audits QA is responsible for the independent functions of program audits, vendor audits and evaluations, and procurement related activities.
The proposed change to the organization will change the title of Manager, Audits QA to Manager, Quality Systems. This change will transfer from the Manager, Site QA the responsibility for implementation audits and consolidate it with the programs audit function under the new Manager, Quality Systems. A new functional area of observations / assessments.is being developed under this manager to emulate the NRC's Safety System Functional Inspection approach.
Additionally, the business support functions of budgeting, computerization, administration and trending methodologies, are being transferred from the Manager, Programs QA to the new position of Manager, Quality Systems.
J Currently, the Manager, Audits QA reports directly to the Director, Quality Assurance. This relationship will be unchanged.
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- 3) The proposed change to the organization will delete j the position of Manager, Programs QA. The functions' I currently being performed under this position are ;
being absorbed under the two manager positions as previously described.
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- 4) The proposed title change from Director, Quality l Assurance to Director, Quality Programs and the ]
deletion of the word " assurance" from other titles is !
to further emphasize SERI's commitment to total j quality, not merely compliance as connotated by
" assurance". {
l SIGNIFICANT HAZARDS CONSIDERATION: j These changes are primarily administrative in nature. The individuals assigned to the newly created positions'will meet the relevant qualification requirements specified in UFSAR Chapter 13. ;
SERI has evaluated the proposed changes and considers them j not to involve a significant hazards consideration for the following reasons:
(1) The prcposed changes will not significantly increase l the probability or consequences of an accident previously )
evaluated, because the changes are administrative in i nature. The proposed changes to the quality assurance organization will not delete any functions currently performed by the quality assurance organization but I will consolidate certain functions in order to increase I the effectiveness of the departments internal operation.
Therefore, the proposed changes to the organization will not increase the probability or consequences of any accident previously evaluated because the quality i assurance function will be performed more effectively through the revised organization.
(2) The proposed changes will not create the possibility -l of a new or different accident from any accident l previously evaluated because the proposed changes will ]
not affect the managerial and administrative controls 1 utilized to assure safe operations of the plant. The quality assurance. requirements for the design, ;
construction and operation of safety related equipment i will not be affected by changes to the quality assurance organization. Therefore the proposed changes to the organization will not affect the performance of the plant as previously analyzed in the FSAR.
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(3) The proposed change viil not involve a significant reduction in the niargin of safety. The proposed .
changes to the quality assurance organization involve i only the realignment of existing function and the addition of the new functional area of observation /
assessments. These changes are intended to enhance the effectiveness of'the quality assurance organization. {
Therefore, no-safety margins are affected.by the i proposed changes.
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II. PROJECTS AND OPERATIONS ANALYSIS CHANGES-A. SUBJECT
- 1. PS-87/03 SERI Organization Changes
- 2. Affected Technical Specifications:
3 6.2.1, Offsite Organization, Page 6-1 (Figure 6.2.1-1), Page 6-9 (Section 6.5.2.2)
B. DISCUSSION The following changes are proposed:
- 1. The position of Manager, Special Projects, is being added 'to:
Figure 6.2.1-1. This position reports 'directly to the Site Director, GGNS.
- 2. The position of Manager, GGNS Unit 1 Projects (shown in Figure ;; .
6.2.1-1) is being deleted. The Manager, Plant Modification and 1 Construction'will report directly to the Site Director'at all' times.
- 3. The block in Figure 6.2.1-1 entitled " Operational Analysis Group (ISEG)" is being replaced with that entitled, " Manager, Operations Analysis Group (ISEG)." The SRC Composition Section 6.5.2.2..is revised to indicate the change in title.
C. JUSTIFICATION
- 1. The position of Manager, Special. Projects was created as a result of SERI organizational plans. The responsibilities formerly belonging to.the Manager, GGNS Unit 1 Pr'ojects-are..
being assumed by the Manager, Special Projects; the Site Director; and the Manager, Plant Modification and Construction (PM&C) as follows: . The Manager, PM&C will assume responsibility-for modification costs and^ schedules,'the Site Director will assume responsibility for providing direction to the Manager, PM&C, and the Manager, Special Projects will assume the remainder of the' responsibilities formerly assigned to-the Manager, GGNS Unit 1-Projects as described in Attachment 1 to Mississippi Power-&
Light _ Company's letter dated November 14,;1985. The proposed;"
change does not change responsibilities among those groups' ,
presently reporting to the Site' Director, but rather further
( enhances recently implemented organizational' changes incorporated into the Grand Gulf Nuclear StationL0perating License.;
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- 2. The proposed change to the.0perations. Analysis. Group further enhances recent changes to the Nuclear Plant Engineering organization. The change.in the title ofithe Principal Engineer, Operations Analysis to Manager, Operations Analysis'does not change responsibilities within the. existing engineering groups.
This. elevation in title is an enhancement by providing greater recognition of the.importance of this. position while maintaining the reporting._ relationship with the Director, Nuclear _Pla'nt:
Engineering. l' ;
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'1 D. SIGNIFICANT HAZARDS CONSIDERATION These changes are primarily administrative in nature. The individuals assigned to the newly created positions will meet the relevant qualification requirements specified in UFSAR Chapter 13. !
The proposed changei c oes not involve a significant hazards consideration because operation of Grand Gulf Unit 1 in accordance with this change i wouM not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change does not involve a change in plant hardware, plant operating procedures, or plant emergency procedures. The changes to the Offsite Organization are administrative in nature in that they more equally distribute the workload among the Site Director's staff. The changes to the Offsite Organization are administrative in nature in that they provide a more effective management chain of command for Nuclear Plant Engineering support groups.
(?) create the possibility of a new or different kind of accident from any prev 1Nsly analyzed. It has been determined that a new or different kind of accident will not be possible due to this change.
This change is administrative in nature and requires individuals assigned to the newly created positions to meet qualifications specified in the UFSAR.
(3) involve a significant reduction in a margin of safety. No margins of safety are affected by the proposed change due to their administrative nature. Plant and offsite organization is strengthened and qualification res uirements for positions are retained.
Therefore, the proposed change invohes no significant hazards consideration ~. ,
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I i GRAND GULF-UNIT 1 6-3 AmeNment No.
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. I GRAND GULF - UNIT 1 6-3 Amendment No.
, o re 77/0/
ADMINISTRATIVE CONTROLS PLANT SAFETY REVIEW COMMITTEE (PSRC) (Continued)
COMPOSITION 6.5.1.2 The PSRC shall be composed of the:
Chairman: Manager, Plant Support Vice Chairman / Member: Manager, Plant Operations 4 Member: Manager, Plant Mainter.ance Member: Operations Superintendent .
Member: TechnicalSupportSuperintendegt l Member: Manager, Sckcr Sit: QA Qod 1 Se.c W e.e.5 l Member: Chemistry / Radiation Control Superintendent i Member: I&C Superintendent Member: Plant Licensing Superintendent ALTERNATES
(
6.5.1.3 All alternate members shall be appointed in writing by the GGNS General Manager to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PSRC activities at any one time.
MEETING FREQUENCY 6.5.1.4 The PSRC shall meet at least once per calendar month and as convened by the PSRC Chairman or Vice Chairman.
QUORUM 6.5.1.5 The quorum of the PSRC necessary for the performance of the PSRC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or Vice Chairman and four members including alternates. i l
RESPONSIBILITIES '
6.5.1.6 The PSRC shall be responsible for review of:
1
- a. Station administrative procedures and changes thereto.
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- b. The safety evaluations for (1) procedures, (2) changes to procedures, equipment or systems, and (3) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions l did not constitute an unreviewed safety question and all programs {
required by Specification 6.8 and changes thereto.
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- c. Proposed procedures and changes to procedures, equipment or systems which may involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
)
- d. Proposed tests or experiments which may involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- e. Proposed changes to Technical Specifications or the Operating License. l j
GPAND GULF-UNIT 1 6-7 . Amendment No. l l
1
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ADMINISTRATIVE CONTROLS 6.5.2 SAFETY REVIEW COMMITTEE (SRC)
FUNCTION 6.5.2.1 The SRC shall function to provide independent review and audit' of designated activities in the areas of:
- a. nuclear power plant operations.
b .- nuclear engineering
- c. chemistry and radiochemistry .
- d. metallurgy
- e. instrumentation and control
- f. radiological safety
- g. mechanical and electrical engineering
- h. quality assurance practices COMPOSITION 6.5.2.2 The SRC shall be composed of the:
Chairman: Vice President, Nuclear Operations hember: Vice President, Nuclear Engineering & Suppcrt .
Member: Director, Nuclear Plant Engineering Member: Site Director, GGN5 Member: Director, Quality A;ss ence Progro m s Member: Designated Representative, Middle South Services, Inc.
Member: GGNS General Manager Member: Director, Nuclear Licensing Member: Manager, Radiological and Environmental-Services ,
__ Member: ,,+eincipcl Ugi=:r,.0perations Analysis ,
Two or more additional voting members shall be consultants to System Energy Resources, Inc. consistent with the recommendations of the Advisory Committee on Reactor Safeguards letter, Mark to Palladino dated October 20, 1981.
The SRC members shall hold a Bachelor's degree in an engineering or physical science field or equivalent experience and a minimum of five years of. technical
! experience of which a minimum of three years shall be in one or more of the disciplines of 6.5.2.la through h. 'In the aggregate, the membership of the committee shall provide specific practical experience in the majority of the
-disciplines of 6.5.2.la through h.
ALTERNATES 6.5.2.3 All alternate members shall be. appointed in writing by the SRC
' Chairman to serve on a temporary bas.is;..however, no more..than two alternates shall participate as voting members in SRC activities at any one time.
' GRAND GULF-UNIT 1 6-9 Amendment No. 'j
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