ML20055F355
| ML20055F355 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 07/06/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20055F354 | List: |
| References | |
| NUDOCS 9007160321 | |
| Download: ML20055F355 (4) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 166TO FACILITY OPERATING LICENSE NO. DPR-49
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IOWA ELECTRIC LIGHT AND POWER COMPANY CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 o
1.0 INTRODUCTION
By letters dated November 3,1989 and February 26, 1990, Iowa Electric LightandPowerCompany(thelicensee)proposedchangestotheDuaneArnold EnergyCenter(DAEC)TechnicalSpecifications(TS),Section6.0,
" Administrative Controls." The proposed changes would remove Figure 6.2.1, "DAEC Nuclear Plant Staffing," and replace it with revised narrative
't descriptions of the onsite and offsite organizations' functional requirements and plant staff qualifications in Sections 6.2 and 6.3.
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Guidance for these proposed changes to the TS was provided.in NRC Generic I
Letter 88-06, dated March 22, 1988. Other minor administrative changes l
were also proposed.
2.0 BACKGROUND
Consistent with the guidance provided in the Standard Technical Specifications, Specifications 6.2.1 anc 6.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are provided as figures to these sections.
On a plant-specific basis, these organization charts have been provided by applicants and included in the TS issued with the operating license.
Subsequent restructuring of either the offsite or unit organizations, following the issuance of an operating license, has required licensees to submit a license amendment for NRC approval to reflect the desired changes in these organizations.
As a consequence, organizational changes have necessitated the need to request an amendment to the operating license.
Because of these limitations on organizational structure, the nuclear industry nas highlighted this as an area for improvement in the TS. The l
Shearon Harris licensee proposed changes to remove organization charts from L
its TS under the lead-plant concept that included the endorsement of the l
proposed changes by the Westinghouse Owners Group.
In its review of the l
Shearon Harris proposal, the staff concluded that most of the essential i
elements of offsite and onsite organization charts are captured by other
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regulatory requirements, notsbly, Appendix B to 10 CFR Part 50.
- However, there were aspects of the organizational structure that are important to ensure that the administrative control requirements of 10 CFR 50.36 would be met and that would not be retained with the removal of the organization charts. The app'licable regulatory requirements are those administrative-controls that are necessary to ensure safe operation of the facility.
Therefore, those aspects of organization charts for Shearoc Harris that were essential for conformance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organizations, and (2) to Specification 6.2.2 to define qualification requirements of the unit staff.
By letter dated January 27, 1988, the staff issued Amendment No. 3 to Facility Operating License NFP-63 for the Shearon Harris Nuclear Power Plant that incorporated these changes to their TS.
Subsequently the staff developed guidance on an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88-06 provided this guidance to all power reectors.
3.0 EVALUATION The licensee's proposed changes to the DAEC TSs are in accordance with the guidance provided in NRC Generic Letter (GL) 88-06, as addressed below.
Specification 6.2.1 has been revised to delete reference to Figure 6.2-1, "DAEC Nuclear Plant Staffing," which has been removed from the TS.
Consistent with requirements to document the onsite and offsite organizational relationships, the NRC staff has confirmed that the appropriate organizational charts having an equivalent level of detail are contained in Chapters 13.1 and 17.2 of the DAEC Updated Final Safety
' Analysis Report (UFSAR).
Functional requirements for the onsite and offsite organizations are defined and included in revised Specification 6.2.1.
The wording of this revised specification is consistent with the guidance of GL 88-06. The revised specification notes that implementation of these requirements is documented in the DAEC UFSAR, which will be updated annually in accordance with10CFR50.71(e).
Section 6.3, " Plant Staff Qualifications," has been revised to update the referenced standard for personnel qualifications to ANSI /ANS-3.1-1978.
Specifications 6.3.4 and 6.3.5 have been added to require that:
(1) the Plant Superintendent-Nuclear or one of his principal alternates shall have the experience and training normally required for a Senior Reactor Operator's license examination (ANSI /ANS-3.1-1978) and, (2) the Operations Supervisor shall hold a Senior Reactor Operator's license (ANSI /ANS-3.1-1978). Therefore, these requirements identified on the deleted organizational chart will be retained.
Specification 6.2.2.2.d refers to Table 6.2-1, " Minimum Shift Crew Personnel and License Requirements," which will retain in the TS the license requirements for all
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shift crew members that were also specified in the deleted organizational chart..The position of Assistant Oper&tions Supervisor is being converted to a plant staff position. As this new position will not have line supervisory responsibility for the operations staff, it will not require an active senior reactor operator's license. The new position will be covered by the applicable requirements of ANSI /AN.5-3.1-1978.
Therefore the licenserequirementsforindividualpiantstaffpreviouslyspecIfiedin i
Figure 6.2-1 will be retained through the addition of new Specifications 6.3.4 and 6.3.5, are currently contained in lable 6.2-1, or will be eliminated due to the conversion of the Assistant Operations Supe v%r's position to a new plant staff position.
On the basis of its review of the above items, the staff WcMes tnt ita licensee's proposed changes are consistent with the NRC gu dangs af GL 88-06 for removing organizational charts from the TSs.
Acu rdin W, the staff finds the proposed changes to be acceptable.
Aou.tional administrative changes were also proposed and are adcis m below.
Specification 6.1.3 has been revised to state that the Manager, Corporate Quality Assurance, is responsible for implementation of the Quality Assurance Program at the DAEC, as opposed to the onsite Quality Control l
Supervisor, who reports to the Manager, Corporate Quality Assurance. This change is merely a clarification of the actual management oversight of this function and does not change the responsibilities of either individual. This change is therefore acceptable to the staff.
For clarification, the NRC staff has determined that the requirements for the position of Manager, Corporate Quality Assurance, are specified in ANSI /ANS-3.1-1978, section l
3.2.1 or equivalent, and the recuirements for the position of Quality Control Supervisor are specifiec in section 4.4.5 of that standard.
Specification 6.4.2 has been revised to indicate that a training program for the fire brigade shall be maintained under the direction of the l
Manager, Training, instead of the Plant Superintendent-Nuclear.
The Plant Superintendent-Nuclear retains the responsibility for directing the operatingplantfireprotectionprogram(TS6.1.2).
This change more appropriately assigns the training responsibility to the Manager, Training, anc' provides sufficient organizational separation to be independent of operational pressures, as discussed in GL 88-06. Therefore, the staff finds this change acceptable.
Specification 6.4.1 has been revised to reference the training requirements of updated standard ANSI /ANS-3.1-1978, for consistency with other changes and the DAEC Quality Assurance Manual.
Specification 6.5.1.2 has Leen revised to correct the titles of the Plant Performance Department to Reactor-Performance Department, and Assistant Plant Superintendent-Operations to Assistant Plant Superintendent-Operations and Maintenance.
Specification 6.9.3 has been revised to correct the title of Shift Supervisor Engineer to the current Operations Shift Supervisor.
These changes are primarily
4 editorial and will assure consistency with current plant documentation and terminology. Therefore, the staff finds these changes acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteriaforcategoricalexclusionsetforthin10CFR51.22(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 the amendment.
5.0 CONCLUSION
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 the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:. James R. Hall Dated: July 6, 1990 i
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