ML20136G092
| ML20136G092 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/18/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20136G070 | List: |
| References | |
| NUDOCS 8511220250 | |
| Download: ML20136G092 (17) | |
Text
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'31 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE DPR-44 & DPR-56 Edward G.
Bauer, Jr.
Eugene J. Bradley 2301 Market Street-Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 8511220250 851118 PDR ADOCK 05000277 P
PDR v
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m m J.pn r. r BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION i
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i In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE DPR-44 & DPR-56 Philadephia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station Unit No. 2 and Unit No. 3, respectively, hereby requests that the Technical Specifications contained in Appendix A of the Operating License be amended by making certain changes regarding the plant organization ~as indicated by a vertical bar in the margin'of the attached pages 243, 246, 247, 248, and 254, k
and revised organization charts on pages 244 and 245.
- Further, Licensee requests revisions to the organization chart on page 53 in Appendix B of the Operating License.
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This Amendment Application has been initiated to reflect several enhancements to the plant organization.
The proposed changes.necessiated a redraft of the plant organization chart shown on Figure 6.2-2.
Consequently, we are using this opportunity to present the organization chart in a new format and to propose several minor revisions to the chart and the composition of the onsite safety review committee.
The revisions to the Technical Specifications proposed by this Amendment Application would: (1) divide the Health Physics and Chemistry organizations into two groups, each directed by a senior level supervisor; (2) divide the organization for the conduct of plant operations under a reorganization of station upper management through two new positions:
Superintendent Operations and Superintendent Plant Services; (3) present the station organization chart in a new format; (4) add the Administration Engineer, Assistant Maintenance Engineer, Outage Planning Engineer, and ALARA-Health Physicist to the station organization chart; (5) revise licensed operator staffing requirements during periods when both units are shutdown; (6) permit certain revisions to the organization chart and onsite safety review committee composition without prior NRC approval; (7) change several titles on the the organization charts; (8) revise the composition of the onsite safety review committee; (9) incorporate several minor revisions to establish consistency with the Standard Technical Specifications and the Limerick Generating Station Technical Speci fications; (10) clarify who is authorized to approve procedures, and (11) revise the Management F
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y Organization Chart to reflect reorganization and title changes.
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A discussion of each of the proposed changes follows:
(1)
Currently, Figure 6.2-2, Organization for Conduct of Plant Operations, shows the Senior Health Pysicist as being responsible for both the Health Pnysics and Chemistry programs.
The proposed change to Figure 6.2-2 woul.' divide the organization into two groups, each directed by a senior level supervisor.
Health Physics activities would continue to be supervised by the Senior Health Physicist.
A new position of Senior Chemist would be established with the responsibility for the supervision of the radiochemistry and conventional chemistry activities.
The Plant Chemist, who formally reported to the Senior Health Physicist, would, under
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the new organization, report to the Senior Chemist.
Direction of Health Phycies and Chemistry activities by two senior level supervisors will significantly enhance C
management control over these important plant activities and improve the ef fectiveness of the organization.
The individual assigned to the new position of Senior Chemist meets the qualifications of Regulatory Guide C
.l.8, September 1975, " Personnel Selection and Training".
e (2)
Licensee proposes changing the title of " Station Supe rintendent" to " Manager - Nuclear Plant" and the creation of two positions (Superintendent - Operations, and Superintendent - Plant Services) at the ____
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g-superintendent level to handle the plant management responsibilities previously handled in a single line organization through an Assistant Superintendent to the Station Superintendent.
The proposed revisions to i
Figures 6.2-1 and 6.2-2 reflect these organizational i
changes.
The Superintendent - Operations would manage the Senior Chemist, Technical Engineer, and Operations i
Engineer.
The Superintendent - Plant Services would manage the Outage Planning Engineer, Maintenance Engineer, and Senior Health Physicist.
Reorganization l
is intended to better focus management attention on the performance of each of the primary plant organizations essential to safe and ef fective operations.
The individuals to be assigned to the positions of Superintendent - Operations, and Superintendent - Plant i
Services are the Assistant Superintendent and Technical Engineer, respectively.
Both are currently licensed and represent a combined total of more than 37 years of operating experience at the Peach Bottom facility.
The position of Manager - Nuclear Plant will be filled by the incumbent Station Superintendent.
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(3)
The organization chart in Figure 6.2-2 has been redrawn using a new format to improve clarity and depict the plant organization more accurately.
The features of the new format are as follows:,
(a)
A block format is used to enhance clarity.
(b) -Reference to " clerical", " custodial", and " stores",
personnel is removed from the chart since these disciplines are inherent to any organization.
(c)
Professional job categories such as Engineer, Technician, Physicist, Chemist, and Technical Assistant are grouped under the category of
" Staff".
The disciplines provided by these personnel are inherent to any plant organization, and reference to specific job professions is unrelated to the job functions and organizational structure depicted on the chart.
Further, these job categories do not represent plant staf f positions.
Use of the "Staf f" nomenclature would avoid the burden of processing license amendments to reflect changes in job titles and designations of academic training for these personnel.
(d)
The Shift Technical Advisor is correctly depicted reporting to the Operations Engineer, with as advisory responsibility to the Shift Superintendent
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and operating shift.
(4)
Licensee proposes to show the position of Administration Engineer, Outage Planning Engineer, and ALARA-Health Physicist on the organization chart.
The duties of the Administration Engineer include the administration of '
security, clerical, and selected regulatory activities.
The duties of the Outage Planning Engineer involve the planning, coordination, and management of plant outage activities.
Both positions are currently held by individuals holding an SRO license; although, this is not a requirement.
The position of ALARA-Health Physicist enhances the implementation of the Peach Bottom ALARA program.
(5)
Licensee proposes a change in the minimum licensed operator staffing requirements for the control room.
Currently, Figure 6.2-2 requires two senior licensed operators (SRO) and three licensed operators (RO) per shift at all times.
The proposed change, as stated in Note 3 on Figure 6.2-2, would reduce the requirements to one SRO and two RO's during periods when Peach Bottom Units 2 and 3 are both in the shutdown or refuel mode.
The proposed staffing requirements are consistent with the Standard Technical Specifications and the Commission's regulations (10 CFR 50.54m).
The change would permit the reassignment of these licensed personnel during a dual plant outage to support core 9
alterations and other outage activities that require I
their expertise.
(6)
Licensee proposes a change to Section 6.2.2 (page 243) that would permit certain revisions to the organization charts without prior NRC approval.
The revisions would be limited to changes that do not decrease the effectiveness of the organization.
The revisions would be reported to the NRC within 30 days, followed by a license amendment application within 4 months.
Licensee proposes a similar provision regarding changes to the composition of the PORC (page 246).
These provisions would permit minor revisions, and improvements, in the staff organization without the implementation delays inherent in the current license amendment process.
(7)
Licensee proposes changes to the organization chart on
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Figures 6.2-1, 6.2-2 and 7.1.1, and to pages 243, 246, 247, 248, and 254, to reflect the following title L
changes:
" Station Superintendent" to " Manager - Nuclear Plant", and "Results Engineer" to " Performance Engineer".
These represent only a change in nomenclature, as the responsibilities of these two positions remain unchanged.
Revised page 248 also reflects changes in titles as requested in a License l
Amendment Application dated May 29, 1984.
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l (8)
Licensee proposes revisions to the onsite safety review committee (PORC) composition depicted in specification
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6.5.1.2 (page 246) to reflect the addition of the Superintendent - Operations, Superintendent - Plant Services, Outage Planning Engineer, and Senior Chemist to the organization as previously described.
Their experience and knowledge of nuclear plant activities.
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enhance the review capabilities of the PORC.
To accommodate these additions, the positions of Assistant Superintendent, Results (Performance) Engineer, Reactor Engineer, and Instrument and Controls Engineer have been removed as primary PORC members.
The number of PORC members is not changed by this application.
With the exception of the Senior Chemist, these additions to PORC are currently SRO licensed engineers.
These four individuals fill senior plant management positions and meet the qualifications of ANSI /ANS 3.1-1978 and ANSI N18.1-1971 for comparable positions.
The revisions to PORC composition elevates the experience and knowledge of the committee membership and consequently enhances the capability of the committee to perform its required functions.
(9)
By correspondence dated March 18, 1985 (J.
F.
- Stolz, NRC, to E.
G. Bauer, Jr., PECo), the NRC suggested that the organization charts for Peach Bottom and Limerick be consistent.
Accordingly, the following revisions are proposed to the chart:
a.
Add position of Assistant Maintenance Engineer.
b.
Delete the note regarding responsibility for onsite fire protection.
In addition to establishing consistency with the organization _.
chnrt in ths Lim 2 rick Technical Spe ci fications, the chart does not appear to be the appropriate place to identify job responsibilities.
10 CFR 50.48(a) of the Commission's regulations identifies the Fire Protection Plan as the appropriate docuinent for identifying fire protection responsibilities.
The Station Superintendent, to be assigned as the Manager - Nuclear Plant, is identified as being responsibile for fire protection in the Peach Bottom Fire Protection Plan.
Further, the following revisions are proposed to establish consistency with the Standard Technical Spe ci fications,
a.
A minor revision to the meeting frequency (6.5.1.4) and quorum (6.5.1.5) speci fications t
for the onsite safety review committee (PORC) is proposed on page 247.
These revisions recognize the alternate to the PORC Chairman in accordance with the Standard Technical Spe ci fications, NUREG-0123, Revision 3.
b.
Section 6.6.1.b requires PORC review of Reportable Event Reports; however, this PORC responsibility is not identified in Section 6.5.1.6 (PORC Responsibilities).
The NRC, in
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i the Safety Evaluation for Amendment Nos. 110 and 113, issued July 17, 1985, requested that the licensee amend Section 6.5.1.6 to establish consistency with Section 6.6.1.b.
Accordingly, an addition to Section 6.5.1.6 is proposed on page 247 to reflect the review responsibility of PORC for reportable events i
required by 10 CFR 50.73.
c.
A revision to Section 6.8.2 is proposed to establish consistency with the Standard Technical Specifications utilized for
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preparation of the Limerick Technical Spe ci fications.
The revision would refer back to Section 6.5.1.6 to clarify that PORC is responsible for the review of procedures.
The change would permit PORC to appoint subcommittees to perform reviews or studies in areas of particular expertise.
(10) A further revision to Section 6.9.2 is proposed that would explicitly permit the P ant Manager to delegate approval authority for selected procedures to the PORC member who has primary responsibility for implementation of the procedures.
The current specification is unclear regarding the delegation of approval authority, and the proposed change would avoid interpretational problems. !
t.
As stated in the Peach Bottom administrative control procedure, a plant procedure is not considered approved unless they bear the signature of the Plant Manager or his alternate on the first page.
Considering the number of new and revised procedures, this imposes an unnecessary administrative burden on several members of the station management and may distract their attention from matters of greater importance to the safe operations of the facility.
The proposed change would permit certain procedures to be approved, following PORC review, by the senior supervision level person who is responsible for implementation of the activities controlled by the procedures.
This change would permit chemistry procedures to be approved by the Senior Chemist; health physics procedures by the Senior Health Physicist; and the system procedures by the Operations Engineer.
The approval of some procedures, such as the administrative procedures, would remain the exclusive responsibility of the Plant Manager or his designated alternate since they have primary responsibility for implementation of these procedures.
As Peach Bottom administrative procedures are revised, they will identify who is authorized to approve each category of plant procedures.
The proposed revisions do not impact the review and approval responsibilities of procedures by the PORC, and current administrative controls will continue to ensure l
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PORC approval' prior to the final signof f by the 4
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responsible PORC member.
The revision would distribute this administrative task among several members of the senior plant staf f and would expedite completing the a
approval process for needed revisions.
The proposed approval. process utilizies the PORC member who is most
~ familiar with activities governed by the procedures and their revision.
(11) In addition to the proposed changes described in items (6) and (7) above, Figure 6.2-1, Management Organization Chart is revised to depict the splitting of the Generation Division into separate Fossil / Hydro and Nuclear groups, and the formation of a Nuclear Services group.
The NRC was previously informed of this reorganization in letters dated April 4, 1983 and May 29, 1984.
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Significant Hazards Consideration Determination The organizational changes described in requests (1),
(2), (4), (8), and (11) do not involve a significant increase in the probability or consequences of an accident previously evaluated because they will enhance station management control over plant activities essential to safe and effective operations.
These changes do not create the possibility of a new or dif ferent kind of accident from any accident previously evaluated because
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they likewise enhance station management control over plant 1
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activities essential to safe and effective operations.
The changes do not involve a significant reduction in a margin of safety because they are intended to better focus management atten?: ion on the performance of each of the primary plant organizations essential to safe and ef fective operations.
Changes (3) and (7), involving a new format for the organization chart and title revisions do not involve a significant increase in the probability or consequences of an accident previously evaluated because they improve clarity or are revisions in nomenclature only.
These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because they improve clarity or are revisions in nomenclarture only.
The changes do not involve a significant reduction in a margin of safety because they improve clarity or are revisions in nomenclature only.
Change (5) regarding licensed operator staffing requirements do not involve a significant increase in the probability or consequences of an accident previously evaluated because it applies only to the shutdown or refuel mode of operation.
The change does not create the possibility of a new or dif ferent kind of accident from any accident previously evaluated because it applies only to the shutdown or refuel mode at operation.
The change does not involve a significant reduction in a margin of safety because it conforms with the Commission's regulation (10 CFR 50.54m).
9.
i Changes (6), (9), and (10) which streamline the licensing process for minor revisions and establish consistency with the Standard Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated because they would permit i
organizational and procedural improvements without the implementation delays inherent in the current license amendment process.
These changes do not create the possibility of a new or dif ferent kind of accident from any accident previously evaluated because they would permit organizational and procedural improvements without the implementation delays inherent in the i
current license amendment process.
The changes do not involve a significant reduction in a margin of safety because they permit manpower resources in both the utility and NRC to concentrate on issues of safety significance rather than the administrative burden of processing minor revisions to the Operating License.
e The Plant Operation and Review Committee and the Nuclear i
Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve an unreviewed safety question or a significant hazard consideration and will not endanger the health and safety of the 4
public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY
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~ 'sVice' tPr es ide'n t i.
COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S.
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Daltrof f, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses and knows the content.s thereof; and that the statements and matters
-set forth therein' are true and correct to the best of his knowledge, information and belief.
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i Subscribed and sworn to D
beforerethis/hday ofhYV l 0 SS M4Ma i
Notary Public PAlRICIA D. SCHOL1' w ew, nava ni.uaew ca.
gy ca== aman Expans fctuary 10,1986
CERTIFICATE OF SERVICE I certify that service of the foregoing Application was made upon the Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to Thomas R. Gerusky, Director, Bureau of Radiological Protection, P. O. Box 2063,' Harrisburg, PA 17120; all this 18th day of November,1985.
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Eugene J.yBradley Attorney for s
Philadelphia Electric Company 6
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