ML20043A345
| ML20043A345 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 05/07/1990 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20043A342 | List: |
| References | |
| NUDOCS 9005210228 | |
| Download: ML20043A345 (5) | |
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UNITED sTAtts
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NUCLEAR REGULATORY COMMISSION I
WASHING TON, D. C. N696 i
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS RELATED TO AMENDMENT NO. 24 TO FACILITY OPERATING LICENSE NO. OPR-7 l
PACIFIC GAS AND ELECTRIC COMPANY j
HUNBCLOT BAY P0WER PLANT, UNIT 3
-DOCKET NO. 50-133 l
l 1.0 JNTRODUCTION i
L By letter dated January 18,1990,(R'eferenceLAR90-01)PacificGasand Electric Cornpany (PG8E or the licensee) requested amendments to the Technical Specifications (TS) appended to facility Operating License No.
DPR-7 for tae Humboldt Bay Power Plant (HBPP)
Unit 3.
The amendments change TS Section VII, " Administrative Controls," to (1) replace figures l
VII-1 and VII-2, the organizational' charts for "Off-site Organization" and "Plent Staff Organization," respectively, with text additions that contain the essential requirements for the structure of-these i
organizations; (2) revise the title of one member of the Plant Staff.
Review Committee (PSRC) from " Senior Chemical and Radiological Engineer
- i to " Senior Radiation Protection Engineer;" (3) re Office Nuclear Plant Review and Audit Cossnittee (quire that the GeneralGON'i advise the "Vice President Nuclear Power Generation" instead of the
" President;"and(4)revisethemembershipoftheGONPRAC, i
t The deletion of the organization-charts is consistent with Generic' Letter 88-06, issued by NRC on March 22, 1988.
Similar TS changes were i
authorized for the Diablo Canyon Nuclear Power Plant, Unit Nos. I and 2, by license amendments' issued July 25,1988;;Diablo Canyon 1 and 2 are j
also PG&E facilities.
The revisions to the membership and reporting =
l relationship of the 60NPRAC were previously authorized for Diablo Canyon 1 and 2 by license amendments issued December 4, 1989. Authorization of i
l the same revisions to the GONPRAC for Humboldt Bay Unit 3 is necessary i
for consistency since the GONPRAC provides the same off-site organization oversight function for both Diablo Canyon 1 and 2 and Humboldt Bay Unit 3.
1 The NRC staff has reviewed the proposed changes and finds them acceptable. The bases for the staff's findings for each. proposed change i
l are given below.
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2.0 EVALUATION l
i The NRC staff has reviewed the TS changes proposed by the licensee and finds them acceptable, based on the following evaluation:
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A.
Removal of Licensee Organization Charts from the TS l
The content required in the Administrative Controls Section of the, Technical Specifications is specified in 10 CFR 50.36c(5).
That provision requires that the technical specifications contain provisions i
relating to organization and management procedures, recordkeeping, review-and audit, and reporting that are necessary.to assure operation of the i
facility in a safe manner.
It does not specifically require inclusion of organizational charts in the technical specifications, j
InGenericLetter(GL)88-06,"RemovalofOrganizationalChartsfrom I
Technical Specification Administrative Controls Requirements", dated March 22, 1988, the NRC has provided guidance for the removal of r
organization charts from the TS.
Generic Letter 88-06 concludes that the t
removal of organization charts from the technical specifications will provide greater flexibility for licensees to implement changes in both -
the on-site and off-site organizational structure.
t With regard'to Humboldt Bay Unit 3, the licensee states that removal of the organization ~ charts from the technical specifications will not affect plant operations.
Specific operational requirements are detailed in other technical specifications that bear'more directly on operational safety than the organization charts.
The removal of the organization charts and title changes represent'no reduction in the current safety requirements, because the following conditions are included in the technical specifications by these amendments, per the recommendations of GL 88-06:
(1) A requirement that lines of authority, responsibility, and comunication 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 l
relationships, and Job descriptions for. key personnel positions, or equivalent forms of documentation.
(2) Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to a
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 on-site organization that is responsible for overall unit operation and has control over those on-site activities necessary for safe operation and ma!ntenance of the plant.
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t (4) Designation of:those positions in the on-site organization that require a senior reactor operator or reactor operator license.
(As applied to HBPP, this requirement is met by designating those i
positions requiring a Certified fuel Handler because reactor f
operationisprohibited.)-
l (5) Provision of sufficient organ'izational freedom to be inde endent of
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operational pressures to those individuals who perform the functions.
l of health physics, quality assurance, and training of operating staff.
The HBPP.TS alrea(y designate those plant' staff positions requiring a Certified fuel Handler. The' remainder of the above guidelines from GL<
88-06 are met by insertion of 'the following language in the HBPP TS in
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Section VII, " Administrative Controls," under "B. Organization."
Insert to be Added to HBPP Organization TS "On-site and off-site organizations shall-be established for plant i
operation and corporate management, respectively. The on-site and' off-site organizations shall. include the positions for activities affecting the safety of the nuclear power plant.
responsibility and connunication shall.be i
Linesofauthorityfinedforthehighestmanagementlevelsthrough a.
established and de intermediate levels to and including all operating organization positions.
These relationships shall be documented and updated, as appropriate, in the form of organization charts,' functional =
c descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements.shall be documented in the-yice President, Nuclear Power Generation Department Procedures, b.
The Plant Manager shall be responsible for overall unit safe operation and shall have control over those on-site activities necessary for safe operation.and maintenance of the plant, c.
The Vice President, Nuclear Power Generation shall have corporate responsibilities for overall plant nuclear safety and shall take e
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 on-site manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures."
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.4-l As discussed above, because removal of licensee orgenfration charts from the H8PP TS meets the requirements of 10 CFR 50.36, and because these i
amendments meet the' guidelines of Generic Letter 88 06, the NRC staff
.i finds them acceptable.
3 B.
Change in. Title of Plant Staff Review Comittee Member In addition to removal of the organizational charts, these amendments i
make a change in the title of one Plant Staff Review Comittee Member, from Senior Chemical-and Radiological Engineer to Senior Radiation 1
Protection Engineer.
The TS requirements for qualifications for the person in this position remain the same.
The change in title of this Plant Staff Review.comittee (PSRC) Member is-made to more clearly reflect his primary function on the plant staff.
It.
is inconsequential in effect on the PSRC itself as it does not affect the number of members, composition or function of..the PSRC. On this basis, the NRC finds this change acceptable.
C.
Change of Individual to Whom the GONPRAC Reports' i
TS Section VII.D.2.a, " General Office Nuclear Plant Review and-Audit I
Comittee Purpose," is revised to specify that; the GONPRAC-shall report to and advise the Vice President, Nuclear Power Generation, rather than the President, on the areas of-'res l
" Review," and VII.D.2.h. " Audits."ponsibility specified in VII.D.2.g.
i The function responsibility and authority of the GONPRAC remain the same..The licensee states that this change is appropriate because the proposed GONPRAC Chairman (see 2.D, below) reports to the Vice President, Nuclear Power Generation.
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The NRC staff has reviewed this proposed change and finds it acceptable because it is consistent with the recomendations of NUREG-0800 (the StandardReviewPlan,orSRP),theStandardTechnicalSpecifications,and ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the-L Operational Phase of Nuclear Power Plants."~
t D.
Revisions to GONPRAC Membership TS Section VII.D.2.b " General Office Nuclear Plant Review and Audit Comittee Composition," would be revised to change the Chairman from Vice President, Nuclear Power Generation, to Manager, Nuclear Safety Assessment and Regulatory Affairs; change the Vice Chairman from Assistant to the Vice President. Nuclear Power Generation, to Manager, Nuclear Operations Support; delete the Director, Nuclear Administration and Support Services, as a GONPRAC member and add the i
Plant Manager, Diablo Canyon Power Plant as a GONPRAC member.
The licensee states that these changes are consistent with the PG4E 5
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i organizational changes made to consolidate and stEengthen activities j
related.to independent technical assessments of plant-safety.. The l
staff has reviewed these changes and finds them acceptable because they are consistent with the recommendations of the SRP.
e 3.0. ENVIRONMENTAL CO,NSIDERATION t
These amendments involve changes in administrative requirements.
Accordingly, these amendments meet the eligibility (criteria for i
categoricalexclusionsetforthin10CFR$1.22(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.
4.0 CONCLUSION
The NRC 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 (3) the issuance of these. amendments will-not be inimical to the' common defense and security or the health andl safety of the public.
Principal Contributor:
Dan E. Martin
.i Dated: May 7, 1990 t
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