ML17221A753
| ML17221A753 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/28/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17221A752 | List: |
| References | |
| NUDOCS 8805050016 | |
| Download: ML17221A753 (10) | |
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 9 AND TO FACILITY OPERATING LICENSE NOS.
DPR-67 AND NPF-16 FLORIDA POWER
ST.
LUCIE PLANT, UNIT NOS. I AND 2 DOCKET NOS. 50-335 AND 50-389 INTRODUCTION By letter dated February 22, 1988, Florida Power and Light Company (FP&L, the licensee) submitted a request for changes to Section 6, Administrative Controls, of the St. Lucie Plant, Unit Nos.
1 and 2, Technical Specifications.
FP&L proposed deleting figures representing the offsite organizational struc-ture (Figure 6.2-1) and the onsite organizational structure (Figure 6.2-2).
FP&L proposed adding general organizational requirements, in place of the figures.
The figures will be placed in the licensee's Topical guality Assur-ance Report.
Most of the elements contained in the figures are already re-quired by regulation, other TS, the Updated Final Safety Analysis Report, or the Topical guality Assurance
- Report, as described in the evaluation below.
FP&L also proposed other changes.
The title "Vice President
- Nuclear Operations" and "Group Vice President - Nuclear Energy" are used in various locations of the Administrative Controls section of the TS.
FP&L proposed to delete these titles and use the title "Senior Vice President - Nuclear."
Titles of personnel on the Company Nuclear Review Board (CNRB) are also proposed to be changed.
Because the first proposed change (deletion of organization charts from the TS) is the most significant of those in the amendment
- request, the next several pages of this Safety Evaluation are devoted to an evaluation of this issue, with a discussion of applicable regulatory requirements, past practice, and safety considerations.
The remaining TS changes proposed by FP&L are then evaluated.
Additional inf'ormation was submitted by letter dated April 20, 1988.
The additional information did not alter, in any way, the staff's proposed no significant hazards consideration determination published in the Federal Register on March 23, 1988 (53 FR 9503).
On March 22,
- 1988, subsequent to the licensee's application, the staff issued Generic Letter 88-06 entitled "Removal of Organization Charts from Technical Specification Administrative Control Requirements."
The staff used the Generic Letter as guidance in reviewing the licensee's proposed changes.
PDR ADOCK 05000335 P
2.0 EVALUATION Section 6.0 of the licensee's TS is required to contain the details of those administrative controls necessary to assur e safe operation of the facility.
For the first proposed
- change, FPSL proposed to replace TS 6.2. 1, TS Figure 6.2-1 (the figure showing the offsite organization),
and TS Figure 6.2-2 (the figure showing the onsite organization) with more general orqanizationa l requirements.
These general requirements capture the essence of those organi-zational features depicted on the charts that are important to the NRC for ensuring that the plant will be operated safely.
FP8L stated that the proposed changes are justified because they are adminis-trative in nature and do not affect plant operation.
FPSL notes that, in addition to being required by the TS, the important organizational features depicted on the organization charts are also required or controlled by other regulatory control mechanisms.
For example, FPSL's Quality Assurance (QA)
Program for St. Lucie is required by 10 CFR 50, Appendix B, to include similar information relating to the organizational structure.
Regulatory Requirements Applicable to Organizational Structure 10 CFR 50.36, "Technical Specifications,"
which implements Section 182a. of the Atomic Energy Act, was promulgated by the Commission on Oecember 17, 1968 (33 FR 18610).
This rule delineates requirements for determining the contents of the TS.
Technical Specifications set forth the specific characteristics of the facility and the conditions for its operation that are required to pro-vide adequate protection to the health and safety of the public.
Specifically, 10 CFR 50.36 requires that:
Each license authorizing operation of a production or utilization facility of a type descr ibed in 550.21 or 550.22 will include Technical Specifications.
The Technical Specifications will be derived from the analy'ses and evaluation included in the safety analysis report, and amendments
- thereto, submitted pursuant to 50.34.
The Commission may in-clude such additional TS as the Commission finds appropriate.
The regulation further states that the TS wi 11 include, among other things, items in the following category:
(5)
Administrative Controls:
Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
Each licensee shall submit any reports to the Commission pursuant to approved Technical Specifications as specified in 550.4.
Past Practice Review of the organization, personnel qua lifications, education, experience,
- training, and an applicant's overall capacity to operate a plant safely has always been of concern to the NRC, and its predecessor, the AEC.
Before a plant is licensed to operate, a finding is made that the applicant's staff is capable
of operating the plant safely.
In the past, the organization charts were made TS so that changes made after operation began would require prior NRC approval.
This was done to preserve certain specific features of the licensed organiza-tion.
While the regulation does not specifically require that the TS contain organi-zation charts, the practice of including organization charts in the TS began in the late 1960s.
These charts were used as an aid in depicting the organiza-tional and management relationships thought to be needed to meet the provisions of 10 CFR 50.36(c)(5).
The practice of including organization charts in the TS has continued since.
Organization charts do depict the reporting chain for some organizational functions that must be independent of scheduling and operating pressures.
Until 10 CFR Part 50, Appendix 8, - "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"
was adopted in 1970, organiza-tion charts were partially relied on by the staff for assuring this function.
As stated in 10 CFR 50, Appendix 8, Criterion I, "Organization":
Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational
- freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Appendix 8 further acknowledges that the organizational structures may take many forms, but emphasizes that regardless of structure, the individuals assigned the responsibility for execution of any portion of the program shall have access to such levels of management as may be necessary to perform this function.
The licensee's required QA Program specifies and depicts these organizational relationships in greater detail than currently exists in the TS.
The practice of including organization charts in the TS was established before the advent of 10 CFR 50, Appendix 8, - "Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants,"
and other associated guidance docu-
- ments, such as the Regulatory Guide 1.70, "Standard Format and Content of Safe-ty Analysis Reports for Nuclear Power Plants,"
and NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants -
LWR Edition."
A general description of the features needed by the staff to make the finding that the applicant is capable of operating the plant safely are now mandated by Appendix B.
Safety Considerations The fundamental safety issue in the proposal to delete organization charts from the TS is whether there can be reasonable assurance that the organization wi 11 operate the plant safely and remain effective without requiring prior staff approval for changes reflected in organization charts.
It has been the staff's experience that organization charts by themselves have been little help to reviewers in assessing the safety significance of changes to the plant and license.
Nevertheless, because the charts are in the TS, license amendment requests have been required to effect organizational changes as simple as combining some minor functions under one organizational element shown. on the chart.
The usefulness of the charts to the staff in recent years has been minimal and the safety relevance of the charts themselves is, small.
Specific operational requirements that bear more directly on the safety matters of concern to the staff than the organization charts are required elsewhere in the TS.
For example, the organizational element responsible for control room command function is identified separately in the TS, as are the requirements for minimum staffing under various operating modes.
The organizational management functions for independent reviews and audits, unit review group and independent safety engineering
- groups, and shift technical advisor are also specified in other TS.
Thus, the organization charts themselves are not needed to support the staff's finding that the organization wi 11 operate the plant sa fe ly.
In summary, the specific details of the operating organization are not essential to the safe operation of the facility, and the staff concludes that the details can be modified in many ways while maintaining adequate opera-tional safety.
Over the years of experience with the details of operating organizations, the staff has been able to distill those organizational charac-teristics which are important to assure plant safety.
The important features of a licensee's organization (currently depicted on the TS organization charts, but not already included in other TS) necessary for the staff to find that the organization wi 11 operate the plant safely are stated below.
These amendments revise the TS to add statements incorporating these features to replace the organization charts.
Lines of authority, responsibility and communications shall be estab-lished and defined from the highest management levels through interme-diate levels to and including al'I operating organization positions.
Those relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of depart-mental responsibilities and relationships and job descriptions for key personnel positions, or in equivalent forms of documentation.
These organizational relationships will be maintained in a document such as the FSAR or gA Manual.
b.
There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety.
This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant so that continued nuclear safety is assured.
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c.
There sha 11 be an individual management position in the onsite organiza-tion having responsibilities for overall unit safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant.
d.
Although the individuals who train the operating staff and those who carry out the health physics and quality assurance functions may report to the appropriate manager on site, they shall have sufficient organiza-tional freedom to be independent from operating pressures.
e.
Senior Reactor Operator (SRO) and Reactor Operator (RO) licenses shall continue to be required for the positions so indicated on the current TS organization charts.
f.
Other TS which reference the current organization charts shall be revised to reference the appropriate functional responsibility or position.
The proposed changes (TS 6.2. 1.a.
through e.) incorporate these features.
The significant aspects of the changes are further discussed as follows.
In regard to proposed TS 6.2. l.a.
(a. above),
the licensee proposes the same words and will place the offsite and onsite organization charts in the St. Lucie Plant Topical guality Assurance Report.
This report is a licensee-controlled document and cannot be changed unilaterally if the contained com-mitments would be reduced.
The governing regulation is 10 CFR 50.54(a)(3).
Proposed TS 6.2. l.b. through e. contain the same recommended requirements as b.
through d. above.
In regard to b.
and c. above, the Senior Vice President-Nuclear is specified as the responsible offsite executive and the Plant Mana-ger is specified as the responsible onsite manager.
In connection with e.
above (SRO/RO licenses),
the licensee proposed a
TS to continue to require the Operations Supervisor to hold an SRO license.
The licensee's letter of'pril 20, 1988 clarified the request to continue the requirement that the Operations Supervisor hold an SRO license.
This does not affect the substance of the amendments as noticed nor the staff's proposed no significant hazards consideration determination.
Lastly, the licensee proposed changes to the TS to implement recommendation
- f. above.
Based upon the above. discussion, the staff concludes that the removal of the organization charts from the TS will not prevent the licensee from meeting the standards of 10 CFR 50.36 and the underlying statutory requirements.
Moreover, the deletion of the unnecessary detail of organization charts will save resources for both the NRC and the licensee and will allow the staff to focus on issues of importance 'to the plant's safety.
The proposed changes are acceptable.
The licensee proposed to delete the titles "Vice President - Nuclear Operations" and "Group Vice President - Nuclear Energy" and replace these titles with the title "Senior Vice President
- Nuclear."
These titles are located in various places in Section 6 of the TS.
The change was requested because of an upcoming reorganization.
The title "Group Vice President
- Nuclear Energy" will become "Senior Vice President
- Nuclear."
This proposed change is acceptable, since a person on the vice president level will continue to be responsible for these activities.
In the February 22, 1988 application, the licensee initially proposed to identify the management officers by general terminology.
However, after discussions with the NRC staff, the licensee by letter dated April 20, 1988 modified the request to identify the Senior Vice President-Nuclear and the Plant Manager-Nuclear by their titles in accordance with the recommendations of GL 88-06.
This change merely adds clarity to the more general terminology used in the February 22, 1988 request and does not affect the substance of the amendments as noticed nor the staff's proposed no significant hazards consideration determination.
The licensee proposed three title changes to the membership of the CNRB.
The licensee stated that there will be no changes in collective talents on the CNRB and that the quality and scope of independent review wi 11 be maintained.
The titles also need to be changed because of an upcoming offsite organiza-tional change.
The title "Group Vice President - Nuclear Energy" will be changed to "Senior Vice President
- Nuclear."
The person occupying this position will also change.
The title "Vice President - Nuclear Oper'ations" will be changed to "Vice President
- Nuclear Energy."
The person occupying this position wi 11 not change.
The title "Senior Project Manager - Power Plant Engineering" will be deleted, and the title "Manager-Power Plant Engineering" will be added.
This will still require a senior person from Power Plant Engineering to be a member of the CNRB.
The staff agrees that the collective talents on the CNRB will not be changed and that the quality and scope of inde-pendent review will be maintained.
Therefore, the changes are acceptable.
ENVIRONMENTAL CONSIDERATION These amendments relate to changes in recordkeeping, or administrative proce-dures and requirements.
The Commission has previously published a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding.
Accordingly, these amend-ments 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 these amendments.
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CONCLUSION Ne have 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, and (2) such activities wi 11 be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Oate:
Apri:1 28, 1938 Prince al Contributor:
E. Tourigny
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