ML20006E794
| ML20006E794 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/08/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006E791 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 9002260357 | |
| Download: ML20006E794 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION, c
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.
2 TO FACILITY OPERATING LICENSE N0. NPF-85 L
PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION, UNIT 2 l
DOCKET NO. 50-353 h
1.0 INTRODUCTION
By letter dated November 3, 1989, Philadelphia Electric Company (the L
licensee) requested an amendment to Facility Operating License No. NPF-85 Unit 2.
The proposed amendment would for the Limerick Generating Station,(TSs) in response to NRC Generic L
revise the Technical Specifications L
Letter (GL) 88-06 " Removal of Organization Charts from Technical l
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Specification Administrative Control Requirements" to: 1) remove the onsite and offsite organizational' charts from TS Section 6.2.1 and 6.2.2,.
respectively and 2) make certain miscellaneous administrative changes in.
b Section'6 of the TSs (Administrative Control) related to revisions to the corporate organization. The five proposed miscellaneous administrative
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changes would: 1) revise paragraphs in Sections 6.2 and 6.5 to reflect the new organization under the Executive Vice President-Nuclear, 2) revise L
paragraph 6.5.2.1 to indicate that the Nuclear Review Board (NRB) reports 4
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to and advises the Executive Vice President-Nuclear, 3) revise paragraph l'
'6.5.2.9.C.to indicate that NRB audit reports shall be forwarded to the H
Corporate Officer (s) responsible for the areas audited, 4)' revise y
paragraphs 6.2.3.2 and 6.2.3.4 to reflect title changes ~and the deletion
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of the corporate Independent Safety Engineering Group (ISEG) and 5) revise paragraph 6.14.2 to reflect the groups responsible for technical review of the Offsite Dose Calculation Manual.
2.0 DISCUSSION r
The same identica1 changes to the TSs which are being requested for p
Limerick, Unit 2 by the November 3, 1989 application were approved for Limerick,-Unit 1 by Amendment No. 35'to Facility Operating License No.
NPF-39 on December 19, 1989. The safety evaluation supporting Amendment No. 35 is incorporated herein by reference.
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was proposed on a lead-plant basis for the Shearon Harris plant and, hat The removal of organizational charts from the TS is an improvement t was p
endorsed by the Westinghouse Owners' Group. The NRC approved this change for Shearon Harris on January 27, 1988. This change was reviewed as part K
of the NRC's program for improvements in TS. The objectives of that program were established by the NRC's " Interim Policy Statement on TS Improvements." As a result of these efforts, NRC GL 88-06 was issued on March 22, 1988 which encouraged licensees and applicants to propose changes to their TS to remove the organizational charts form the TS and L.
9002260357 900200 PDR ADOCK 05000353 -
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" replace them with descriptiens of the organizational structure and characteristics which are important to safety. The proposed changes concern the Administrative Controls in Section 6.0, and do not affect any-Limiting Conditions for Operation or Surveillance Requirements.
The LGS Unit 1 onsite and offsite organizations are defined by organization charts included under administrative control requirements of the TS. Generic Letter (GL) 88-06 provided guidance which addresses amendments that may be proposed for removing organization charts from the TS.-
Many of the details shown on the onsite and offsite organization 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 adeouate operational safety. This experience has enabled.the staff to identify those organizational characteristics which
'are'important.to safety. The aspects of the organizational charts which
- are important to safety and which are not covered by other specifications, and must therefore remain in TS, were listed in GL 88-06.
The licensee has' proposed deleting the onsite and offsite organization charts in accordance with the guidance in GL 88-06 along with the five miscellaneous administrative changes as discussed above.
3.0 EVALUATION In the application of November 3, 1989, the licensee proposed to revise Sections 6.2.1 and 6.2.2 to delete the two organizational charts shown in figures'6.2.1-1 and 6.2.2-1.
The title for Section 6.2.1 would be changed from "Offsite Organizations" to "Offsite and Onsite Organizations." The title for Section 6.2.2 remains the same (i.e.,
"UnitStaff").
Section 6.2.1, is presently one sentence that. states that _the " unit management and technical support shall be as shown in Figure 6.2.1-1."
Section 6.2.2 presently has one sentence that states that "the unit organization.shall be as shown in Figure 2.2.2-l."
Section 6.2.2 also has six subsections, a. through f., which specify requirements on minimum shif t staffing, fire brigade size, health physics coverage and overtime restrictions; in the application of November 3, 1989, the licensee was not proposing any changes in the wording of items a, through f., in Section 6.2.2.
In accordance with the guidance in GL 88-06, the licensee proposed to define, in words, the positions and associated responsibilities of the key personnel presently shown in the organizational charts who are important to plant safety. To accomplish this, the licensee proposed to add subsections a) through d) below to Section 6.2.1:
a)
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 1
positions. These relationships shall be documented and updated, as
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. appropriate, in the form of organization charts, functional descriptions.of department responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Limerick Ouality Assurance Program.
b)
The Plant Manager shall be responsible for overall unit safe i
operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c)
The-Vice President-Limerick Generating Station shall have corporate responsibility for overall plant, nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in
. operating, maintaining, and providing technical support to the plant to ensure nuclear safety, d)
The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizati,onal freedom to ensure their independence from operating pressures.
Deletion of the organizational charts is accompanied by the addition of general administrative control requirements which describe the essential aspects of the organizational structure defined in the organizational q
charts. The additional administrative control descriptions are contained in the proposed paragraph 6.2.1.a through 6.2.1.d.
They involve _the designation of safety' responsibilities and organizational freedom of the Health Physics, Training and Quality Assurance groups. The independence of~the Quality Assurance group is further guaranteed by adherence to 10 CFR 50 Appendix B, Criterion I.
The. proposed descriptions of duties and responsibilities. meet the guidance in GL 88-06 and' adequately defines the key' corporate and. plant management positions that are presently'shown in Figure 6.2.1-1.
The proposed additions to Section 6.2.1 are acceptable.
As described in the Introduction above, the licensee requested five miscellaneous administrative changes and changes to Section 6.2.2.
As noted previously, these same changes were approved for Limerick, Unit 1 by bendment No. 35.
For the reasons discussed in our safety evaluation
'i supporting Amendment No. 35, the same changes are acceptable for Limerick, Unit 2, since both units have the same operating staff and organization.
1 In cummary, the proposed chang'es to remove t'he organizational charts from the TS'and replace them with descriptions of the organizational structure and' characteristics which are important to safety meets all the guidance in GL 88-06 and are acceptable.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment relates to changes in recordkeeping, or administrative' procedures or requirements.
Accordingly, the 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 nor environmental assessment need be.,
prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The Commission made a proposed determination that the anendment involves no significant hazards consideration which was published in the Federal-Register'(54 FR 51256) on December 13, 1989 and consulted with the commonwealth of Pennsylvania.
No public comments were received and the Commonwealth of Pennsylvania did not have any comments.
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, and (2) such activities will be conducted in compliance with the Commission's-regulations and the issuance of this amendment will not be inimical to the common defense and the security nor to the health and safety of the public.-
Principal Contributor: Richard Clark Dated: February 8, 1990:
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