ML17284A515
| ML17284A515 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/08/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17284A514 | List: |
| References | |
| NUDOCS 8809160182 | |
| Download: ML17284A515 (6) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 63 TO FACILITY OPERATING LICENSE NO. NPF-21 WASHINGTON PUBLIC POWER SUPPLY SYSTEM WPPSS NUCLEAR PROJECT N0.2 DOCKET NO. 50-397 1.0
2.0 INTRODUCTION
By letter dated April 21,
- 1987, Washington Public Power Supply System proposed to modify the "Administrative Controls" section of the Technical Specifications for Nuclear Plant No. 2.
The proposed amendment involves changes of position titles and changes in responsibilities of designated positions.
The licensee also asked to remove from the organizat'ion charts in the Technical Specifications certain positions which they believe represent unnecessary level of detail.
On March 22, 1988 NRC issued Generic Letter 88-06 encouraging licensees to propose removal of organization charts from the Technical Specifications.
On May 10, 1988 the licensee submitted a revision to the April 21, 1987 amendment application.
In the May 10, 1988 letter the licensee requested that the organization charts in Figures 6.2. 1-1, 6.2.2-la, and 6.2.2-lb be removed in accordance with the generic letter.
EVALUATION The position of Technical Director (Technical Specifications Section 6.8.2) has been eliminated.
This position was a support position which reported directly to the Managing Director.
This support is now provided by the Deputy Managing Director and the other supporting Directors.
The position title, Support Services Director (page 6-14),
has been changed to Support Services Manager to provide consistency throughout the Supply System.
No deletion of support to WNP-2 or change of personnel is represented in this change.
On page 6-1 a change is made to clarify that it is the shift manager rather than the shift super visor who is prohibited from belonging to the site fire brigade.
The staff finds that these above changes meet the criteria of Section 13.1 of NUREG-0800 and do not delete any support for WNP-2.
They therefore are acceptable.
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f The proposal to remove the organization charts from the Technical Specifi-cations is consistent with the staff recommendation in the Generic Letter 88-06.
In the generic letter the staff examined the regulatory require-ments of 10 CFR 50.36 for the administrative controls to be included in Technical Specifications.
The regulation states that administrative controls are the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner.
It has been the staff 's experience that organization charts by themselves have been of little help in ensuring that the objectives of administrative control requirements are met.
Specific operational requirements are included elsewhere in the Technical Specification that bear more directly on operational safety than organization charts.
As examples, the organizational element responsible for the control room command function is identified separately in Technical Specifications, as are the r equire-ments for minimum staffing under various operating conditions.
The organizational management functions for independent reviews and audits, unit review, independent safety engineering
- groups, and shift technical advisors are also specified in other Technical Specifications.
In summary, many of the details shown on the onsite and offsite organiza-tion charts are not essential to the safe operation of the facility. Over the years, the staff experience with changes in the details of operating organizations has shown that organization charts can be modified in many ways while maintaining adequate operational safety.
This experience has enabled the staff to identify those organizational characteristics that are important to safety.'he staff finds that the only aspects of organi-zation charts that are important to safety and not covered by other specifications (thus must remain in the Technical Specifications) are those conditions listed below:
(I)
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 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.
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Provisions 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.
Since the proposed amendment included the above conditions in the Technical Specifications, removal of the organization charts represents no reduction in current plant safety.
These changes will simply allow'the licensee to implement changes in their organization structure without obtaining NRC approval.
The proposed amendment requires that the licensee must ensure that the organizational information described in (1) above is incorporated in the F ina 1 Sa fety Ana lys i s Report.
The qualifications for certain positions are currently designated by organization charts as requiring a
These requirements are added to the Technical Specifications by this amendment.
The index has been revised to reflect the removal of organizational charts.
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves changes to administrative procedures and reporting requirements.
Accordingly, this amendment meets 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 this amendment.
4.0 CONTACT WITH STATE OFFICIAL 5.0 The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Re ister (52 FR 34021) on September 9,
1987.
On July 13, 1988, Ge omm>ssson published a second proposed determination following the May 10, 1988 letter (53 FR 26535).
The staff consulted with the State of Washington.
No public comments were received, and the State of Washington did not have any comment.
CONCLUSION We 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 will be conducted in compliance with the Commission's regula-tions and the issuance of this amendment wi 11 not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
Fred Allenspach Dated:
September 8'," 1988
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