ML20045H485
| ML20045H485 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/09/1993 |
| From: | Storz L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2157, NUDOCS 9307200273 | |
| Download: ML20045H485 (15) | |
Text
'i CENTERIOR ENERGY
' 6200 0% 1ree Boulevard Mod Ad(hess Independence OH PO Box 94061 216 447 3100 Cleveland, OH 4410ba661 Docket Number 50-346 License Number NPF-3 Serial Number 2157 July 9, 1993 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 Subj ec t :
Request for NRC Approval Pursuant to 10 CFR 50.54(a)(3)
Gentlemen:
The Toledo Edison Company is planning changes to the Davis-Besse Nuclear Power Station Unit Number 1 (DBNPS) organization. These changes are being proposed under the Company's overall efforts to continue to improve quality and vork process efficiency, and to achieve organizational consolidation and realignment.
This reorganization consists of modifying the existing five director functional arrangement to four directors with the associated realignment of activities to accommodate this new structure.
Reporting to the Vice President - Nuclear will be
- 1) the Plant Manager, responsible for operations, maintenance, radiation protection and security; 2) the Director - Engineering, responsible for design engineering, systems / performance engineering, and nuclear support;
- 3) the Director - Nuclear Assurance, responsible for quality control (including Independent Safety Engineering), quality assessment, and regulatory affairs; and 4) the Director - Nuclear Services, responsible for material management, services, planning, and training.
Activities currently being performed at the DBNPS will be maintained in the new organization.
Two of these proposed changes have been identified by Toledo Edison as reducing commitments currently contained within the DBNPS Updated Safety Analysis Report (USAR) Chapter 17.2, Quality Assurance Program for Station Operation.
Specifically, the proposed Nuclear Assurance Department (which vill replace the current Quality Assurance Department) vill have responsibility not only for quality assurance duties, but also for emergency preparedness, nuclear licensing, 151)100 gi I
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Docket Number 50-346 License Number NPF-3 t
I Serial Number 2157 Page 2 non-radiological environmental, industrial safety, independent safety
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engineering, engineering assurance and operational experience assessment duties. As a benefit of this change, the Director - Nuclear Assurance vill have additional, diverse resources to support self-assessments and oversight duties. This consolidation of duties (which are not in-line operation, radiation protection, maintenance or I
engineering duties) under a Director - Nuclear Assurance has been j
identified as a reduction in the Quality' Assurance Program commitments because the current Director - Quality Assurance position is described
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in Chapter 17.2 as free of non-quality assurance related duties.
i The second reduction in Quality Assurance Program commitments involves having Independent Safety Engineering report to the Director - Nuclear Assurance rather than directly to the Vice President - Nuclear. The Manager - Quality Control, who vill report to the Director - Nuclear
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Assurance vill have responsibility for managing Independent Safety j
Engineering. This has been identified as a reduction because Independent Safety Engineering, as currently described in Chapter 17.2, i
vill no longer report directly to the Vice President - Nuclear.
However, it vill remain independent from the functions of plant operations, maintenance, radiation protection, engineering, and j
technical support functions.
r Toledo Edison has evaluated these two proposed program reductions as j
described in the attachment to this letter and concluded that, with their implementation, the Quality Assurance Program vill continue to l
satisfy the criteria of 10 CFR Part 50, Appendix B.
It is Toledo Edison's desire to expeditiously implement these organization changes. Accordingly, Toledo Edison requests NRC review and approval of these two proposed Quality Assurance Program reductions by July 19, 1993.
Should you have any questions or require additional information, please contact Mr. Dale R. Vuokko, Manager - Nuclear Licensing (Acting), at (419) 249-2366.
Very truly yours, C [7/)
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Louis F. Storz
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Vice President - Nuclear DRV/dle Attachments cc:
J. B. Hopkins, NRC Senior Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board
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- Docket Number 50-346 License Number NPF-3 I
Serial Number 2157 Page 1 Listing of Submittal Contents Davis-Besse Unit 1 USAR-Section 17.2, Quality i
Assurance Program for Station Operation, Pages Affected By Proposed Changes Evaluation of Proposed Quality Assurance Program Reductions rj 4
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.I Docket Number 30-346-License Number!NPF-3 Serial Number 2157
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Page 1 Note The attached marked up USAR Section 17.2 includes several changes made.
j prior to the proposed change of. Quality Assurance to Nuclear Assurance.
.The elimination of the Manager - Quality Systems occurred in October 1992 (reference: USAR Change Notice (UCN)92-081). The l
responsibilities of the Manager - Quality-Systems vere divided among the remaining Quality Assurance Sections (Quality Verification and Quality Control). This change did not reduce commitments identified in i
the Quality Assurance Program. Another change that was made eliminated the day-to-day, in-line quality review of specification and modification packages performed by the Engineering Assurance Unit (reference:
UCN 92-058). This change was approved by the NRC on-Octobo so, 1992 (Toledo Edison Log 1-2751).
These two changes are indicated in the attachment by their. respective UCN numbers.
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Docket Number 50-346 License Number NPF-3 Serial Number 2157 Page 2 17.2.1.4 Toledo Edison Nulcear Group NVcLE. AR A 55 0 RAhlCE 14 DIRECTOR
-QUAIMY-ASSURANGE--
Mue lor l1 The Director - queH+y Assurance reports to the Vice President - Nuclear and is responsible for the development, maintenance, and monitoring of the Nuclear 14 Quality Assurance Program.
The Director is also responsible for advising the Plant Manager and cognizant corporate mana g meng of the Quality Assurance Program's effectiveness. The Director - Quahyty Assurance is independent l14 from cost and scheduling considerations when opposed to safety considerations, 1
-ad-4hfree-of-nen-qheeleted--de* 1et. 4fc i:; authorir.Id-to identify quality problems; initiate, recommend. or provide solutions, through l9 designated channels; verify implementition of solutions: and verify l1 con ormance to established quality requirements. The Director -
l9 2/d'8 I # Assurance has the authority to suspend (st'op work) any activity, l14 except reactor operation, not in conformance with specified requirements 1
and/or provisions of the NQAM, Conditions adverse to quality that appear
.t o #warrant suspension of reactor operation, including startup or power g
Jation are immediately reported to the Plant Manager.
The Director aE[ty Assurance is responsible for the adequate staffing of the 14 Nki+1tyAssuranceDepartment to ensure that the, requirements of the NQAM are effectively implemented.
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MANAGER - QUALITY CONTROL 9
The Manager - Quality Control reports to the Director d 1$hAssuranceand l14 is responsible for managing the Quality Control' staff in the quality review, l1 inspection, and examination of plant structures, systems, and components 14 within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and engineering specification requiremente. This' responsibility ' includes the inspection of weldin'g to verify it meets ASME, National Board. and State of Ohio requirements in 1
addition to coordinating the activities of the Authorized Inspection Agency to ensure Code compliance. jyg g
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j-Docket Number 50-346 License Number NPF-3 Scrial Number 2157 Pale 3 insert A The Director - Nuclear Assurance is responsible for directing all phases of interaction relating to regulating agencies to ensure compliance with laws, regulations, and commitments. This responsibility also includes providing direction for the Nuclear Licensing Programs, the Emergency Preparedness Program, Environmental Compliance Program and Industrial Safety Program to ensure compliance with Federal, State and local laws, regulations and commitments.
The Director - Nuclear Assurance is also responsible for directing the activities of independent safety engineering, engineering assurance and the review of external information and plant operations assessments.
Insert B The Manager - Quality Control is also responsible for development and maintenance of the ASME Quality Assurance Manual and Quality control and pyen) selected Nuclear Assurance Department Procedures. The Manag2r - Quality UO'h)
Control is also responsible for review of all corrective action documents for close-out, review of selected site procedures and selected procurement
.9d-UM documents, review and approval of Vendor Quality Assurance Programs and 6% Cept Procedures, performance of vendor audits and surveillances, receipt iilkB5 inspections and review of vendor supplied documentation, control of the
_ approved vendor list, and Quality Control Staff training. l The Manager -
Quality Control is also responsible for providing technical expertise onsite to allow for systematic and independent assessment of plant activities by the
' independent safety engineering function. Ad.ditional responsibilities include surveillance of plant operations and maintenance activities to' provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may affect the underlying assumptions in the USAR Accident Analysis.
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1 Docket Number 50-346 p_3 ticense Number NPF-3 Serial Number 2157 Page 4 9
AssessmenY 8
MANAGER - OUALITY V"n!"ICATM N 4
9 Aue nM Asse sehent-J)uclear The Manager - Quality Ver4[4ee+1em reports directly t the Director - Guelliy l14 Assurance and is responsible for managing the Quality eification staff in the performance of internal and selected external OA audits, and for QA 8
surveillanceofstationoperations.}InsertC
-MANAGER W ALITY SYST""S-9 eDi[ector Quali[
l14 The Manager Quali System repor[ dire y to b0 j Assurance nd is sponsib > for pervi. ng th -Quali i Syst ms Sta Og \\ Activit s vit the 0 ity S stem M ager'* area resp sibil y inc de g
p qy the d elop and r 1sion -
the I clear nd AS Qual y Ass ance M nuals an ualit ssuran Depar. ment Pr cedur, Int -depa ment cedur Revie,
9 r.rrecti Action ocumep Closur, Qua ty Ase rance epartm t Trai ing, cualit rendh and Apalysis, endor dits/ urveil) nces, eview d App val of V idor 0 ty As drance P ograms rocedres,mpfntaini the proved Ve dor Receip-Inspe ion, Ve Supp ed Docpmentatp Rev
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17.2-5 REV 14 7/91
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Docket Number 50-346-License Number NPF-3 Serial Number 2157
.i Page 5 Insert C The Manager - Quality Assessment is also responsible for development and maintenance of-the Nuclear Quality Assurance Manual, and Quality Assessment and 3
5 selected Nuclear Assurance Department Procedures. Also the responsibility for
' 4g0 review of inter-department procedures, selected site procedures and selected vendor quality assurance programs and procedures. The Hanager - Quality Assessment is also responsible for the development,-maintenance-and q)'tt4 implementation of the trending and analysis program and Quality Assessment staff _
& {p3 training.] The Manager - Quality Assessment is also responsible for the
)(b independent assessment of engineering activities and products, and review and evaluation of plant chemistry and radiochemistry issues. The Manager - Quality Assessment is also responsible for the review of all external information received in support of improved performance and reliability and for plant operations assessments.
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Insert D Manager - Regulatory Affairs The Manager - Regulatory Affairs reports to the Director - Nuclear Assurance and-is responsible for directing and coordinating the activities related to licensing and interfacing with the NRC, and other regulatory enforcement agencies, including determination of reportability. The Manager - Regulatory Affairs is also responsible for the implementation of the non-radiological environmental compliance program ()ncluding mixed (hazardous and radiologically contaminated) vaste in conjunction with the Manager - Radiation Protection],
Industrial llealth and Safety program and technical support functions for corrective actions and resolutions of plant deficiencies and deviations. The Manager - Regulatory Affairs is also responsible for planning, development, supervision, and coordination of all emergency planning and preparedness activities in the Nuclear Group and corporate support organizations. This responsibility includes maintaining the Emergency Plan in a current status and managing the interaction between the Emergency Preparedness Section and Federal, State and local government officials.
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Docket Number 50-346 License Number NPF-3 Serial Number 2157 Page.6 D-B DIRECTOR - DB EliGINEERING l9 r
The Director - DB Engineering report s directly to the Vice President -
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. Nuclear, and is responsible for all engineering activity in support of design control, plant modifications, and system performance requirements 1
for the Davis-Besse Nuclear Power Station.
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As ranc Dip 6cto -lDB ngine ring odd is espon ible or ma dging he ipdepen ent afi revi of ocure ent c cumen,, en neer g spe ific Gons and 14 pla modi cati s, en neer ng dep rtme self asses ent etiv les, hj re ew a eval ation f p1 it che stry and r ioch ist issu s, dkg e ginee ing a port ervi s suc as d ign oces contr 1, b' get 6g admin) trat n, pr cedur. cont 1 an admi tratlon, ejt'ginep ing aini g, 9 0 and gendor docum t pr cessi
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HANAGER - NUCLEAR ENGINEERING l10 The Manager - Nuclear Engineering reports to the Director - DB Engineering 9
and is responsible for managing and coordinating department function relating to reliability and risk assessment, nuclear reactor analysis,
. nuclear safety analysis, simulator engineering, reactor engineering, fuel performance and design, reactor refueling', core physics testing, and 14 installation, improvements and maintenance of computer monitoring and computer aided engineering systems.
HANAGER - DESIGN ENGINEERING The Manager - Design Engineering reports to the Director - DB Engineering and is responsible for managing Davis-Besse procurement and modification engineering, and associated safety evaluations to assure safe designs and continued 14 conformance to design requirements. This includes the maintenance of design engineering drawings, specifications, and calculations. Additional responsibilities include engineering support to address non-routine technical issues reinted to the operation and maintenance of Davis-Besse.
HA'!3AGER - SYSTEMS ENGINEERING l9 The Hanager - System Engineering reports to the Director - DB Engineering 9
and is responsible for minimizing Davis-Besse forced outage and lost I
capacity by providing systems engineering services to ensure proper installation, operation, preventive maintenance, testing, and problem resolution for optimum system performance and reliability.
Additional 14 responsiblities include the formulation. Implementation,'and periodic
-assessment of the effectiveness of the fire protection program.
l9 HANAGER - PERFORMANCE ENGINEERING The Manager - Performance Engineering reports to the Director - DB Engineering l9 and is responsible for managing the activities of the Performance l14 Engineering Section to provide direct day-to-day engineering support 8
in the areas of plant thermal performance monitoring, inservice inspection 5
17.2-8 REV 14 7/91
Docket Number 50-346 License Number NPF-3 Serial Number 2157 D-B Page 7 9
DIRECTOR /TECHN LSEJdICES l9
-Nuc[ ear l9 The D ecto Tech cal Se ces rep ts to he Vic-Preside and s res sib 1 for dir ing al phase of int action r lating/to r ulati agen en to e ure com lance ith la, regula ons, d
ommit nts.
Is res neibili also eludes providin direct on for the clear raining rogram suppo the n ds of t site reonn in ccorda ce with aws, re ation, commi ents, an stand de, a a
ects y e Emer cy Pre rednes Progr Enviro ntal C plian
/Progravand In trial ety P gram to ensure ce plianc with F deral, stat nd lo
- laws, gulat ns and mmitment l9 JACER -A UCLEAR CENSI The H ager -
clear censing eports t tne Di ector Techni 1 Servi es direct dinati the a tivitie relate to and s respop ible facing w t$ g and co 1 ensing dd inte the NRC and at er reg atory d enfor ement gencies includ g determ ation of eporta.11ty.
The Ma ger - N lear 1
Licens g is a o respon ble for e impi.entati of th non-ra ologi al envi nmenta complian programfncludin mixed hazard s and r diolop cally co minate ) waste i conjunct 6n with he Ma 'ger - R diation rotecgion.-
16 ustria Health a Safety ogram d tech cai su ort fun tions or 14 correct e action and reso tions o plant eficien les and eviat ons.
l9 MANA(.ER - NUCL R TRAINI Jr Manage - Nuclear rainin report direct to the irect r - Te nical 9
Services nd is res neible or the evelop t and pieme ation f complip ce wit regul one, 9 mmit-nuclear raining p ograms
- ensur ments nd indust standy ds.
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17.2-9 REV 16 7/92 l
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Docket Number 50-346
' License Number NPF-3 Serial Number 2157
~Page.8 D-n NNAC y-I NDEPENDEfE-/JAFETY-EpG I NEERI t l9 The nager - Ind dent ty En eerin, repo 6 dire y to e Vice j
elble[rprov ng te inical pertis 9
Pre dent - Nucl. r, and i res; for.,etemati and independen ssess >nt of ant 6
c.-sitej o all d malp enance etivitip)(to p dditio respo sibilit
>s inc e surv illane of plan -
5 ctiv ties.
de in epende techni 5
oper tions ca) veri ' cation hat the-activ ies ar rfo
. corr tly an inves-5' jdgatio-ofp1 t incid ts whic may af oct th underlyngass ptions n 5
the Up Acc ent Ana, sis.
ISE artm funct ns inde andentl from 8
6 oth f Nucl Group ctivitip.
PMW NUCLEAR REVIEV BOARD The Company Nuclear Review Board (CNRB) is responsible for providing an independent reviev and audit of activities affecting quality to assure itself that Davis-Besse is being operated and maintained in compliance with the Nuclear Quality Assurance Program and the Operating License. The nature of CEB activities include the monitoring and reviev of functions 5
and problems pertaining to nuclear safety. The Chairman of the c aB is responsible for providing a O RB Charter which meets the requirements of Section 6 of the Technical Specifications.
STATION REVIEV BOARD The Station Reviev Board (SRB) is responsible for the review of Plant Admin-1 istrative procedures, data, and deficiencies related to nuclear safety as 1
identified in the SRB Charter. The SRB may, as it determines necessary 7-direct investigations by Station personnel of facility activities to assure 1
that these activities have been, are being, and vill be perfo'rmed in 1
accordance with approved written procedures. Generally, the SRB is 1
concerned with the nuclear safety related aspects of facility operation and 7
coordinates its activities with Quality Assurance to satisfy the OA 1
requirements for facility operation. The Chairman of the SRB is responsi-1 ble for providing an SRB Charter which meets the requirements of Section 6 1
of the Technical Specifications.
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U Docket Number 50-346 License Number NPF-3 e
Serial Number 2157 Page 1 EVALUATION OF PROPOSED OUALITY ASSURANCE PROGRAM REDUCTIONS DESCRIPTION OF PROPOSED CHANGE The proposed changes to the Updated Safety Analysis Report -(USAR)
Chapter 17.2, Quality Assurance Program for Station Operation, are shown on the attached marked up pages.
Change Number i Under the proposed Davis-Besse Nuclear Power Station, Unit No. l' (DBNPS) reorganization, the position of Director - Nuclear Assurance (presently the position of Director - Quality Assurance) vill no longer be "... free of non Quality Assurance (0A)-related duties" as is presently stated in USAR Section 17.2.1.4 (page 17.2-4) of the Quality Assurance Program for Station Operation. Accordingly, this wording vould be removed from the OA Program (see~Section 17.2.1.4 of the attached marked up pages). The Director - Nuclear Assurance vill have the responsibilities in the following functional areas in addition to the Quality Assurance responsibilities _ presently held: independent safety engineering, operational experience assessment programs, engineering assurance, nuclear licensing, environmental, emergency preparedness, and industrial safety.
Change Number 2 Under the proposed DBNPS reorganization, the independent' safety engineering function vill be directed by the Director - Nuclear Assurance rather than the Vice President - Nuclear as is presently stated in USAR Section 17.2.1.4 (page 17.2 - lic). The Manager -
Quality Control, who vill report to the Director - Nuclear Assurance, vill have responsibility for managing the independent safety engineering function, REASON FOR CHANGE Change Numbers 1 and 2 These changes are proposed to support the Centerior Energy reorganization, which includes the DBNPS organization.
These changes are proposed to allow the Director - Nuclear Assurance to assume responsibilities for performing additional quality assurance and some non-quality assurance functions as described above.
These changes will also allow the placement of the independent safety engineering function within the Nuclear Assurance Department.
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Docket Number 50-346 License Number NPF-3 Serial Number 2157 Page 2.
EFFECT OF CHANGE ON THE DBNPS USAR CHAPTER 17.2, OUALITY ASSURANCE PROGRAM Change Number 1 The deletion of the phrase regarding the Director - Quality Assurance "and is free of non-0A related duties"_is not a requirement of 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, Criterion I, Organization. The requirements of Criterion I do not preclude persons and organizations performing quality assurance functions from performing non-quality assurance functions when such functions do not affect the safety related functions of structures, systems, and components.
The basis for concluding that the new position of Director - Nuclear Assurance, with the deletion of non-QA related duty restrictions, will
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continue to satisfy the requirements of 10 CFR 50 Appendix B follows.
Under the provisions of 10 CFR 50 Appendix B, Criterion I, persons and organizations performing quality assurance functions must have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
It also requires those persons and organizations performing quality assurance functions to report-to a management level such that the required authority and' organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
The proposed changes and USAR 17.2.0 Policy (Page 17.2-2) establish sufficient authority and organizational freedom, and sufficient independence from cost and schedule when opposed to safety considerations for the quality assurance function and continue to satisfy the provisions of 10 CFR 50 Appendix B, Criterion I.
The basis for concluding that other organizational changes regarding the new position of Director - Nuclear Assurance continue to satisfy the requirements of 10 CFR 50 Appendix B, follows. As described above, the Director - Nuclear Assurance vill be responsible for the function of engineering assurance.
This additional responsibility is considered to be an enhancement to the quality assurance functions described in 10 CFR 50 Appendix B, Criterion I.
The engineering assurance function was originally created at the DBNPS in order to expand the Quality-Assurance Department to include a quality engineering function.
The engineering assurance function was then moved to the Engineering Department. The proposed reorganization moves the engineering assurance function back into the Quality Assurance organization where it was initially located.
As described above, the Director - Nuclear Assurance vill have the responsibility for the nuclear licensing, environmental and industrial safety functions.
These additional responsibilities are considered non-quality assurance functions. The activities performed under these responsibilities do not affect the safety related functions of structures, systems and components.
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Docket Number 50-346 License Number NPF-3 l
Serial Number 2157 Page 3 The Director - Nuclear Assurance vill also have responsibility for the emergency preparedness function. This additional responsibility is also considered a non-quality assurance function.
The activities performed under this responsibility do not affect the safety related function of structures, systems and components.
The Director - Nuclear Assurance vill also assume the previous responsibility from performance engineering for the review of all external plant information received regarding impaired performance and reliability, and for plant operations assessments. This additional responsibility provides activities which are considered to be an enhancement of quality assurance functions described in 10 CFR 50 Appendix B, Criterion I.
Although Technical Specification (TS) 6.5.2.8 of the Operating License requires an audit of the emergency plan and implementing procedures to be performed at least once per 12 months, this audit is not required to 4
be performed under 10CFR50 Appendix B.
Toledo Edison uses the Quality 1
Assurance Program attributes to audit this area in order to provide consistent methodology of performing audits, e.g.,
utilizing vell-qualified auditors. Therefore, this TS audit requirement is not i
adversely impacted by the proposed organization change.
Change Number 2 The function of independent safety engineering is not a TS nor a 10CFR50 Appendix B requirement for the DBNPS. An independent safety engineering function was added to the DBNPS organization as a Course of Action item following the June 9, 1985 loss-of-feedvater event. This function was originally under the same director who was responsible for nuclear engineering and then later, to provide independence from engineering, moved to reporting to the Vice President - Nuclear.
Under the proposed change, the Manager - Quality control, who vill report to the Director - Nuclear Assurance vill have responsibility for the function of independent safety engineering.
The independent safety engineering function vill no longer be a separate area which reports directly to the Vice President - Nuclear as previously described. The level of independency for independent safety engineering activities is established in USAR 17.2.0, Nuclear Quality Assurance Program Policy.
To adequately fulfill assigned responsibilities of the Director -
Nuclear Assurance, the policy allows the Director - Nuclear Assurance access to the chairman, President, and Chief Executive Officer, if the need for such access exists. The organizational freedom described is considered to be sufficiently adequate for independent safety engineering activities. This additional responsibility is considered to be an enhancement of the quality assurance functions described in 10 CFR 50 Appendix B, Criterion I and is considered to be structured appropriately for the circumstances.
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Docket Number 50-346
' License Number NPF-3 a
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~ Attachment 3 Page 4 BASIS FOR CONCLUSION THAT CHANGE CONTINUES TO SATISFY THE CRITERIA 0F IO CFR 50 APPENDIX B
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Change Numbers 1 ar.d 2 The proposed organizational changes do not diminish or reduce the-effectiveness of the quality assurance functions of the quality assurance program as currently described.
The proposed organization vill continue to provide sufficient organizational freedom of the quality assurance functions and sufficient organizational freedom from cost and schedule when opposed to safety considerations.
It vill provide an independent organization to function in a strong overview capacity, by facilitating versatility in both compliance and performance-based quality assurance aspects.
It vill provide an overview function with a high level of expertise and management involvement in areas such as: quality assurance functions, overviews and assessments of engineering activities, overviews and assessment of operational activities, overviews and assessment of industry experience, assessment of and compliance with regulations, licensing-issues and commitments to regulatory agencies, environmental assessments and compliance, and industrial safety assessments and compliance.
This organizational structure is perceived to enhance the goals in providing safe and reliable operation of the plant.
As justified above, the proposed organizationai changes continue _to satisfy the requirements of 10 CFR 50 Appendix B.
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