ML20040H310
| ML20040H310 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/27/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20040H293 | List: |
| References | |
| NUDOCS 8202180064 | |
| Download: ML20040H310 (5) | |
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?1 UNITED STATES NUCLEAR REGULATORY COMMISSION o
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SAFETY EVALUATION AND ENVIRONMENTAL IMPACT APPRAISAL BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 46 TO FACILITY OPERATING LICENSE NO. DPR-66 DUQUENSE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY BEAVER VALLEY POWER STATION, UNIT NO. 1 DOCKET NO. 50-334 Introduction Duquesne Light Company, by letters to the NRC dated April 10,1981, as supplemented June 30 August 13, September.17 and December 22, 1981, requested changes to the Appendix A and Appendix B Technical Specifications for Beaver Valley Power Statior., Unit No.1.
These changes reflect the' establishment of a Nuclear Division within Duquesne Light. Company and include changes in the Onsite Safety Committee (OSC), the Offsite Review Ccmmittee (ORC) and the review and approval procedures for plant management.
I Discussion The licensee has proposed to modify its corporate organizational structure to consolidate its major nuclear power plant operation and support activities within a single new corporate division, the Nuclear Division, which is headed by a Vice President whose sole responsibility is for nuclear power related l
activities.
It has also proposed to modify the Beaver Valley Unit 1 plant organizational structure.
The proposed offsite organization reporting to the Vice President - Nuclear Division includes a Manager - Nuclear Operations, Manager - Nuclear Safety and Licensing, Manager - Nuclear Support Services, and Manager - Nuclear Engineering.
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The Beaver Valley Unit 1 Station Superintendent reports to the Manager -
Nuclear Operations. A new position of Superintendent - Technical Services also reports directly to the Manager - Nuclear Operations. A number of the technical support functions that are currently assigned to the Station Superintendent are assigned _to the Superintendent - Technical Services in the new organization. These include the shift technical advisors, refueling, chemistry and station engineering. The current position of Chief Nuclear Engineer has been eliminated from the proposed station organization and the Supervisor - Nuclear Station Operations reports directly to the Station Superintendent. The Instrument and Control function, which is under the Maintenance Supervisor in the current organization, has been set up under a separate Supervisor - Instrument and Control who reports directly to the Station Superintendent. The Supervisor - Maintenance retains the mechanical and electrical maintenance function but reports directly to the Station Superintendent rather than to the Chief Nuclear Engineor.
Other support functions that are under the Station Superintendent in the current organization, including radiation protection, fire protection, nuclear engineering, training, security and office and records are reorganized under the new offsite organization Managers of Nuclear Safety and Licensing, Nuclear Support Services and Nuclear Engineering and the Director, Personnel Adminis-tration.
Evaluation Our evaluation of the proposed organizational changes is basec' on review of the April 10, June 30, August 13, September 17 and Decamber 22, id81 sutmittals from the licensee and conversations with the licensee concerning the proposed changes.
It also takes account of a May 7,1981 NRC Offiue of Inspection and Enforcement - Region I letter to the licensee concerning m April 3,1981 meeting with the licensee concerning the proposed organizational changes and an April 2,1981 letter from the licensee to the NRR Office of Inspection and Enforcement - Region I on the same subject.
On the basis of our evaluation as discussed above, we have concluded that the organizational changes should enhance the ability of the licensee to manage and safely operate the Beaver Valley Power Station Unit 1 and are acceptable.
The licensee has proposed to change the membership of the Onsite Safety-Committee (OSC).
It would replace the management and supervisory personnel currently designated as members with non-supervisory personnel. It would further designate membership titles that do not identify specific individuals but instead identify a job title or type of license held.. Examples of these proposed changes are designation of a Senior Licensed Operator rather than the Operations Supervisor and a Shift Technical Advisor rather than the Technical Advisory Engineer.
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1 Since there are a number of individuals with the titles Senior Licensed Operator and Shift Technical Advisor, these titles alone do not assure that the individuals serving as committee members will conform with the NRC guidance concerning minimum qualifications for committee members. Section 3.4 of the NRC's Standard Review Plan specifies that members of the Onsite Review Committees should meet the qualifications requried by Section 4.4 of ANSI N18.1-1971 for professional and technical personnel. We discussed this with the Itcensee and it added a membership qualifications statement in Section 6.5.1.2 of its September 17, 1981 submittal requiring that OSC members will meet the qualifications specified for professional technical personnel by Section 4.4 of ANSI N18.1-1971.
Since there can be a number of personnel with the titles identified by the proposed membership list, we were concerned that a different individual might attend each meeting and that there would be no continuity in the work performed by the Committee. At our request, the licensee added a statement in Section 6.5.1.2 of its June 30, 1981 submittal that individual members be appointed to serve at least six months. We believe that this will provide adequate continuity to the activities of the OSC.
The licensee's proposed new membership list eliminates several plant dicciplines that are included in the current membership list: training, emergency planning, fire protection and security. The proposed list also adds one new discipline:
chemistry. As a result of this, the Committee has been decreased by two members. However, we find that the technical disciplines and the number of members proposed is consistent with that currently accepted by the staff for other nuclear stations.
On the basis of our review as discussed above, we conclude that with the changes we have noted above concerning the technical qualifications and the length of appointment terms of members, the changes proposed to the Technical Specifications concerning the OSC are acceptable.
In its submittals to the NRC of March 13. April 10 and June 30,1981, the licensee has proposed changes to Section 6.5.2.2 - Composition, Section 6.5.2.8 - Audit, Seciton 6.5.2.9 - Authority and Section 6.5.2.10 - Records.
These changes align the designated membership of the Offsite Review Committee (ORC) with the structure and the job titles of the proposed reorganization.
The changes also increase the number of designated committee members by two.
The proposed new chairman of the ORC is the Manager - Nuclear Safety and Licensing. This position is one step lower in the licensee's management l
structure than the current chairman who is the General Superintendent of Power Plants. However, the proposed new chairman reports directly to the new Vice President - Nuclear Division, minutes of all ORC meetings a~re sent to the new Vice President within 14 days following each meeting, and the ORC chairman is required to forward all Committee recommendations to the new Vice President.
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. We conclude that the proposed changes to Sections 6.5.2.2, 6.5.2.8, 6.5.2.9 and 6.5.2.10 as dis'ussed above will not diminish the effectiveness of the ORC and are acceptab.e.
Section 6.8.2 of the current Beaver Valley Technical Specification requires that procedures and administrative policies and changes thereto be reviewed by the Onsite Review Committea and approved by the Plant Superintendent prior to implementation.
In its September 17, 1981 submittal, the licensee proposed that Section 6.8.2 be modified to allow procedures and administrative policies and changes thereto to be implemented following review by the Onsite Review Committee and approval by either the Plant Superintendent or the responsible Department Manager. The phrase "or responsible Department Maiiager" does not adequately describe who shall approve changes.
We believe that the Plant Superintendent should be responsible to assure that appropriate multidisciplined reviews are performed by the Onsite Review Committee and that the effect on plant safety of all proposed procedures and administrative policias or changes thereto has been appropriately considered. We believe that the Plant Superintendent should be responsible to assure that appropriate review is given to these matters by the affected plant and corporate functional organi-zations.
We also believe that the Plant Superintendent should be responsible for review and approval of the reports and recommendations developed by the reviewers an~d for forwarding them, as appropriate, to the independent review group. We recognize that in order to fulfill this responsibility, the Plant General Manager may delegate some of these activities to other specific appropriate plant staff managers. This delegation must be in writing and specific to the particular review activity being performed.
In its submittal to the NRC of December 22, 1 981, the licensee changed section 6.8.2 to require that the Plant Superintendent predesignate in writing the Department Manager or other alternate given the responsibility for the review and approval of specific subjects considered by the OSC. We conclude that the proposed revision to Section 6.8.2 is acceptable.
Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in.
any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of enviornmental impact and, pursuant to 10 CFR 551.5(d)(4),
that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
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5-Conclusion We have concluded, based on the considerations discussed above, that: (1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the i
health and safety of the public will not be endangered by operation in the proposed manner, and (3) 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 security or to the health and safety of the public.
Date: January 27, 1982 l
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