ML20151R325
| ML20151R325 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/22/1988 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20151R307 | List: |
| References | |
| 1512, GL-88-06, GL-88-6, TAC-67906, NUDOCS 8804270295 | |
| Download: ML20151R325 (15) | |
Text
.
.-Dockot N3. 50-346 License No. NPF-3 Serial No. 1512 Enclosure APPLICATION FOR AMENDMENT TO 4'
FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Attached are requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Facility Operating License No. NPF-3.
Also included are the Safety Evaluation and Significant Hazards Consideration.
The proposed changes (submitted under cover letter Serial No. 1512) concern:
Technical Specification 6.2, Organization; Figure 6.2-1, Davis-Besse Nuclear Power Station Offsite/Onsite Organization; and Figure 6.2-2, Davis-Besse Nuclear Power Station Operations Organization.
By:
M' D. C. Shelton, Vice President, Nuclear l
l Sworn and subscribed before ne this 22nd day of April, 1988.
'Ik if /LL{_.-
~
Notary Public, State of Ohio My Commission expires b//1 N/
/
8804270295 880422 PDR ADOCK 05000346 l
P DCD
Dockst No. 50-346 License No. NPP-3 Serial No. 1512 Enclosure The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License No. NPF-3, Appendix A, Technical Specifications.
A. ' Time Required to Implement: This change is to be implemented within 45 days after issuance of the License Amendment.
B.
Reason for Change (DCR No.88-150):
Remove organization charts from Technical Specification Section 6.0 in accordance with the guidance provided in NRC Generic Letter No. 88-06:
C.
Safety Evaluation:
See attached Safety Evaluation (Attachment No. 1)
D.
Significant Hazards C; sideration:
See attached Significant Hazards Consideration (Attachment No. 2).
l
Dock 3t No. 50-346 f.icin;o Ns. NPF-3
+
S;rici No. 1512
. Attachment 1
-l Page 1 SAFETY EVALUATION INTRODUCTION The purpose of this Safety Evaluation is to review, proposed changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications. The proposed changes involve Technical Specification Section 6.0, Administrative Controls, and propose removing organization charts from the Technical Specifications in accordance with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements, dated March 22, 1988.
As discussed in Generic Letter 88-06, the removal of organization charts is a line item improvement that was proposed on a lead-plant basis for the Shearon Harris plant and was endorsed by the Vestinghouse Owners Group. This change was reviewed as part.of the NRC's program for improvements in Technical Specifications. The objectives of that program were established by the NRC's Interim Policy Statement on Technical Specification Improvements. The NRC Staff concluded in Generic Letter 88-06 that the removal of organization charts from Technical Specifications vill provide greuter flexibility for licensees to implement changes in both the onsite and offsite organizational structure, consistent with NRC policy.
REFEREfyES Generic Letter 88-06, dated March 22, 1988, Removal of Organization Charts from Technical Specification Administrative Control Requirements.
Safety Evaluation by the NRC Office of Nuclear Reactor Regulation in Amendment No. 3 te Facility Operating License No. NPF-63 for the Shearon Harris Nuclear i
Power Plant, dated January 27, 1988.
10 CFR 50.36, Technical Specifications, (which implements Section 182a of the Atomic Energy Act) Paragraph (c)(5), Administrative Controls.
10 CFR 50, Appendix B, Criterion I, Organization.
Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants.
NUREG-0800, Standard Reviev Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LVR Edition.
l l
DOCUMENTS AFFECTED l
I Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications, Section 6.0, Administrative Controls, Figure 6.2-1, Davis-Besse Hueler.r Power Station Offsite/Onsite Organization, and Figure 6.2-2, Davis-Besse Nuclear Power Station Operations Organization.
Davis-Basse Nuclear Power Station, Unit No. 1, Updated Safety Analysis Report, Section 13.1, organizational Structure.
l l
t
' Dock;t No. 50-346 6
2Licens] No. NPF-3 S:rici !!o. 1312 Page 2 SYSTEMS AND COMPONENTS AFFECTED None SAFETY FUNCTIONS AFFECTED None EFFECTS ON SAFETY The regulatory requirernents for Technical Specifications are provided in 10CFR50.36 which implements Section 182a of the Atomic Energy Act. This rule delineates requirements for determining the contents of Technical Specifications. Technical Specifications set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public. Further, requirements for administrative controls in Technical Specifications are provided in 10CFR50.36(c)(5), Administrative Controls.
This regulation states that administrative controls are the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner.
Organization charts were used as an aid in depJeting the organizational and management relationships believed to be needed to meet 10CFR50.36(c)(5), however, the regulation does not specifically require that Technical Specifications contain organization charts.
Organization charts do depict the reporting chain for some organizational functions that must be independent of scheduling and operating pressures.
Until 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, was adopted in 1970, organization charts were partially relied on by the NRC for assuring this function.
As stated in 10CFR50, Appendix B, Criterion I, Organization, persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Appendix B further acknowledges that the organizational structures may take I
many forms, but emphasizes that regardless of structure, the individuals l
assigned the responsibility for execution of any portion of the program shall l
have access to such levels of management as may be necessary to perform this l
function. Toledo Edison's required Quality Assurance Program specifies and depicts these organizational relationships in greater detail than currently exists in the Technical Specifications.
The practice of including organization charts in Technical Specifications was established before the advent of 10CFR50, Appendix B, and other associated guidance documents, such as Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, and NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LVR Edition.
HovcVer, a general description of the featnes required to determine safe plant operation is now mandated by Appendix B.
Docket Ns. 50-346-Liesnsa No. NPF-3 Ssriol Ns. 1512 Page 3 As discussed in Generic Letter 88-06, it has been the NRC Staf f's experience that organization charts by themselves have been of little help in ensuring that the objectives of administrative control requirements are met.
Nevertheless, because the charts are in the Technical Specifications, unnecessary processing of License Amendments has resulted.
Specific i
operational requirements exist elsewhere in the Technical Specifications that bear more directly on safety matters of concern than the organization charts.
As an example, the organizational element responsible for control room command function is identified in Technical Specification Table 6.2-1, Minimum Shift Crew Composition, which provides the requirements for minimum staffing under various operating modes. The organizational management functions for independent reviews and audits and the Station Review Board and Company Nuclear Review Board are also spe:ified in other Technical Specifications.
Therefore, many of the details shown on the onsite and offsite organization charts are not essential to the safe operation of the facility. As discussed t
in NRC Generic Letter 88-06, the staff concludes that the details can be modified while maintaining operational safety.
i Also identified in NRC Generic Letter 88-06 are the aspects of organization charts which are important to safety, are not covered by other specifications, and that must remain in the Technical Specifications.
These include:
}
1)
A requirement that lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization portions. 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 in equivalent forms of documentation; 2)
Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be needed to ensure acceptable performance of the staff in 1
operating, maintaining, and providing technical support tc the plant l
to ensure nuclear safety 3)
Designation of a management position in the onsite organization that is responsible for overall unit operation and has control over those onsite activities necessary for safe operation and maintenance of the plant; 4)
Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license; and 5)
Provisions o' sufficient organizational freedom to be independent of operational
- -ures to those individuals who perform the functions of health,,
.ss, quality assurance, and training of the operating staff.
Toledo Edison proposes meeting these aspects by adopting the Technical Specifications provided as Enclosure 2, Markup of Vestinghouse Standard Technical Specifications, to Generic Letter 88-06.
Specifically, Toledo Edison proposes removing Figure 6.2-1, Davis-Besse Nuclear Power Station
3 Dockst Ns. 50-346
'Lic;nra No. NPF-3 S;riol No. 1512 Page 4 Offsite/Onsite Organization, and Figure 6.2-2, Davis-Besse Nuclear Pover Station Operations Organization, from the Technical Specifications and adding to the Technical Specifications, the following general requirements that capture the essential aspects of the organizational structure ensuring that the plant vill be operated safely:
1)
Establishing and maintaining the lines of authority, responsibility, and communication for the highest management levels through intermediate levels to and including all operating organization positions through documentation as appropriate, (in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation) in the Updated Safety Analysis Report (USAR) and updated in accordance with 10CFR50.71(e). This requirement vill be established in Technical Specification 6.2.1.a.
USAR Section 13.1, Organization Structure, contains organization charts which are at least to the level of detail as shown on the existing Technical Specification organization charts.
USAP, Section 13.1 provides a description of the functional responsibilities of various departments and job descriptions for key staff positions.
2)
Designating the Vice President, Nuclear as the executive position responsible for overall plant nuclear safety with the authority to take such measures as may be needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. This requirement vill be established in Technical Specification 6.2.1.b; 3)
Designating in the onsite organization, the Plant Manager as the management position in the onsite organization responsible for overall facility safe operation who has control over those onsite actifities necessary for safe operation and maintenance of the plant. This requirement vill be established in Technical Specification 6.2.1.c; 4)
Designating the Assistant Plant Manager - Operations and the Operations Superintendent as the onsite Operations management positions that require a Senior Reactor Operator license. This requirement vill be established in Technical Specification 6.2.2.g; and 5)
Providing that the individuals, who train the operating staff, who carry out health physics, and who are involved it quality assurance functions, may report to an onsite manager, however, they shall have sufficient organizational freedom to ensure their independence from operating pressures. This requirement vill be established in Technical Specification 6.2.1.d.
,Dockat No. 50-346 Lic nsa N3. NPF-3 Sirial No. 1512 Page 5 Consistent with the above Technical Specifications, Toledo Edison proposes replacing the organization charts (Figures 6.2-1 and 6.2-2) with appropriate functional descriptions of the requirements that vere depicted by the organization charts, re-titling Specification 6.2.1 as "Offsite and Onsite Organization", and re-titling Specification 6.2.2 as "Facility Staff".
Therefore, because the above conditions vill be maintained in the Technical Specifications, and the regulatory requirements of 10CFR50, Appendix B and 10CFR50.36 are met, removal of the organization charts results in no reduction in current safety requirements. These changes vill allow the NRC and Toledo Edison to better focus on issues of importance to nuclear safety.
PROPOSED AMENDMENT REQUEST DISCUSSION The proposed changes are administrative in nature and do not affect plant operation. They involve replacing onsite and offsite organization charts with general requirements that capture the essential aspects of the organizational structure ensuring that the plant vill be operated safely in accordance with the guidance provided in NRC Generic Letter 88-06.
Therefore, the implementation of these proposed changes vould:
Not increase the probability of occurrence of an accident previously evaluated in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment, or a modification to a system. The aspects important to safety, that were previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications.
The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from i
Technical Specifiestion Administrative Control Requirements (10CFR50.59(a)(2)(i)).
Not increase the consequences of an accident previously evaluated in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment, or a modification to a system. The aspects important to safety, that vere previously characterized on the l
organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirerents of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CFR50.59(a)(2)(1)).
I I
t
Dockst No. 50-346 Lic;nsa No. NPF-3 S;ricl No. 1512 Page 6 Not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the USAR because the proposed changes do not involve a test or experiment, and no station equipment is being modified. The aspects important to safety, that vere previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CFR50.59(a)(2)(i)).
Not increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because the proposed changes do not involve a test or experiment, and no station equipment is being modified. The aspects important to safety, that were previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner.
The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CFR50.59(a)(2)(i)).
Not create the possibility for an accident of a different type than any evaluated previously in USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test or experiment, or a modification to a system and do not affect any plant equipment or operation procedures which could impact the probability of an accident.
The aspects important to safety, that vere previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CF350.59(a)(2)(ii)).
Not create the possibility for a malfunction of a different type than any evaluation previously in the USAR because no station equipment is being modified by the proposed Technical Specification changes.
The proposed changes do not involve a test or experiment, or a mooification to a system which could impact the probability of a malfunction. The aspects important to safety, that vere previously characterized on the
Dockst No. 50-346
'Lic nsa No. NPF-3 S2rici No. 1512 Page 7 organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Tecnnical Specifications.
The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CFR50.59(a)(2)(ii)).
Not reduce the margin of safety as defined in the basis for any Technical Specification because the amendment does not affect any operating practices or limits nor any equipment or system important to safety. The aspects important to safety, that vere previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements (10CFR50.59(a)(2)(iii)).
CONCLUSION Based on the above, it is concluded that the proposed Technical Specification changes do not constitute an unreviewed safety question.
Dock;t No. 50-346 7,
Lic:ns] N). NPF-3 Serial No. 1512 Page 1 SIGNIFICANT HAZARDS CONSIDERATION INTRODUCTION The purpose of this License Amendment application is to review proposed changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications. The proposed changes involve Technical Specification Section 6.0, Administrative Controls, and propose removing organization charts from the Technical Specifications in accordance with the guidance provided in NRC Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements, dated March 22, 1988.
As discussed in Generic Letter 88-06, the removal of organization charts is a line item improvement that was proposed.on a lead-plant basis for the Shearon Harris plant and was endorsed by the Vestinghouse Owners Group. This change was reviewed as part of the NRC's program for improvements in Technical Specifications.
The objectives of that program were established by the NRC's Interim Policy Statement on Technical Specification Improvements. The NRC Staff concluded in Generic Letter 88-06 that the removal of organization charts from Technical Specifications vill provide greater flexibility for licensees to implement changes in both the onsite and offsite organizational structure, consistent with NRC policy.
REFERENCES Generic Letter 88-06, dated March 22, 1988, Removal of Organization Charts from Technical Specification Administrative Control Requirements.
Safety Evaluation by the NRC Offico of Nuclear Reactor Regulation in Amendment No. 3 to racility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, dated January 27, 1988.
10 CFR 50.36, Technical Specifications, (which implements Section 182a of the Atomic Energy Act) Paragraph (c)(5), Administrative Controls.
10 CFR 50, Appendix B, Criterion I, Organization.
(
Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Peports for Nuclear Power Plants.
NUREG-0800, Standard Reviev Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LVR Edition.
DOCUMENTS AFFECTED Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications, Section 6.0, Administrative Controls, Figure 6.2-1, Davis-Besse Nuclear Power Station Offsite/Onsite Organization, and Figure 6.2-2, Davis-Besse Nuclear Power Station Operations Organization.
l
' Docket No. 50-346 Licens] NJ. NPF-3 Serial No. 1512 Page 2 Davis-Besse Nuclear Power Station, Unit No. 1, Updated Safety Analysis Report, Section 13.1, Organizational Structure.
SYSTEMS AND C0h'PONENTS AFFECTED None SAFETY FUNCTIONS,_AFFECTED None EFFECTS ON SAFETY The regulatory requirements for Technical Specifications are provided in 10CFR50.36 which implements Section 182a of the Atomic Energy Act. This rule delineates requirements for determining the contents of Technical Specifications. Technical Specifications set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public.
Further, requirements for administrative controls in Technical Specifications are provided in 10CFR50.36(c)(5), Administrative Controls.
This regulation states that administrative controls are the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner. Organization charts vere used as an aid in depicting the organizational and management relationships believed to be needed to meet 10CFR50.36(c)(5), however, the regulation does not specifically require that Technical Specifications contain organization charts.
Organization charts do depict the reporting chain for some organizational functions that must be independent of scheduling and operating pressures.
Until 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, was adopted in 1970, organization charts vere partially relied on by the NRC for assuring this function.
As stated in 10CFR50, Appendix B, Criterion I, Organization, persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Appendix B further acknowledges that the organizational structures may take many forms, but emphasizes that regardless of structure, the individuals assigned the responsibility for execution of any portion of the program shall have access to such levels of management as may be necessary to perform this function. Toledo Edison's required Quality Assurance Program specifies and depicts these organizational relationships in greater detail than currently exists in the Technical Specifications.
The practice of including organization charts in Technical Specifications was established before the advent of 10CFR50, App 9ndix B, and other associated guidance documents, such as Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, and NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LVR Edition.
However, a general description of the features required to determine safe plant operation is now mandated by Appendix B.
Dock 3t N3. 50-346 Licensa No. NPF-3 Serial No. 1512 Page 3 As discussed in Generic Letter 88-06, it has been the NRC Staff's experience that organization charts by themselves have been of little help in ensuring that the objectives of administrative control requirements are met.
Nevertheless, because the charts are in the Technical Specifications, unnecessary processing of License Amendments has resulted.
Specific operational requirements exist elsewhere in the Technical Specifications that bear more directly on safety matters of concern than the organization charts.
As an example, the organizational element responsible for control room command function is identified in Technical Specification Table 6.2-1, Minimum Shift Crew Composition, which provides the requirements for minimum staffing under various operating modes. The organizational management functions for independent reviews and audits and the Station Reviev Board and Company Nuclear Reviev Board are also specified in other Technical Specifications.
Therefore, many of the details shown on the onsite and offsite organization charts are not essential to the safe operation of the facility.
As discussed in NRC Generic Letter 88-06, the staff concludes that the details can be modified while maintaining operational safety.
Also identified in NRC Generic Letter 88-06 are the aspects of organization charts which are important to safety, are not covered by other specifications, and that must remain in the Technical Specifications. These include:
1)
A requirement that lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization portions. Those relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilit.ies and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation:
2)
Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; 3)
Designation of a management position in the onsite organization that is responsible for overall unit operation and has control over those i
onsite activities necessary for safe operation and maintenance of the plant; 4)
Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license; and l
5)
Provisions of sufficient organizational freedom to be independent of l
operational pressures to those individuals who perform the functions of health physics, quality assurance, and training of the operating staff.
Toledo Edison proposes meeting these aspects by adopting the Technical Specifications provided as Enclosure 2, Markup of Vestinghouse Standard Technical Specifications, to Generic Letter 88-06.
Specifically, Toledo Edison proposes removing Figure 6.2-1, Davis-Besse Nuclear Power Station l
Dockot No. 50-346 Liccns3 No. NPF-3 Serial No. 1512 Page 4 Offsite/Onsite Organization, and Figure 6.2-2, Davis-Besse Nuclear Power Station Operations Organization, from the Technical Specifications and adding to the Technical Specifications, the following general requirements that capture the essential aspects of the organizational structure ensuring that the plant vill be operated safely:
1)
Establishing and maintaining the lines of authority, responsibility, and communication for the highest management levels through intermediate levels to and including all operating organization positions through documentation as appropriate, (in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation) in the Updated Safety Analysis Report (USAR) and updated in accordance with 10CFR50.71(e). This requirement vill be established in Technical Specification 6.2.1.a.
USAR Section 13.1, Organization Structure, contains organization charts which are at least to the level of detail as shown on the existing Technical Specification organization charts.
USAR Section 13.1 provides a description of the functional responsibilities of various departments and job descriptions for key i
staff positions.
2)
Designating the Vice President, Nuclear as the executive position responsible for overall plant nuclear safety with the authority tn take such measures as may be needed to ensure acceptable performan'e of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. This requirement viil be established in Technical Specification 6.2.1.b; i
3)
Designating in the onsite organization, the Plant Manager as the management position in the onsite organization responsible for overall facility safe operation who has control over those onsite activities necessary for safe operation and maintenance of the plant. This requirement vill be established in Technical Specification 6.2.1.c; 4)
Designating the Assistant Plant Manager - Operations and the Operations Superintendent as the onsite Operations management positions that require a Senior Reactor Operator license. This requirement vill be established in Technical Specification 6.2.2.g; and 5)
Providing that the individuals, who train the operating staff, who carry out health physics, and who are involved in quality assurance functions, may report to an onsite manager, however, they shall have sufficient organizational freedom to ensure their independence from l
operating pressures. This requirement vill be established in l
Technical Specification 6.2.1.d.
l l
'Dockst No. 50-346 Licenst No. NPF-3 Serial'No. 1512 Attachmeet 2 Page 5 Consistent sith the above Technical Specifications, Toledo Edison proposes replacing the organization charts (Figures 6.2-1 and 6.2-2) with appropriate functional dessriptions of the requirements that were depicted by the organization charts, re-titling Specification 6.2.1 as "Offsite and Onsite Organization", a0d re-titling Specification 6.2.2 as "Facility Staff".
l k
Therefore, because the above conditions vill be maintained in the Technical Specifications, and the regulatory requirements of 10CFR50, Appendix B and 10CFR50.36 are met, cemoval of the organization charts results in no reduction in current safety reqeirements. These changes vill allow the NRC and Toledo Edison to better focus on issues of importance to nuclear safety.
SIGNIFICANT HAZARDS CONSIDF; RATION The commission has providei standards in 10CFR50.92(c) for determining whether a significant hazatis consideration exists. A proposed amendment to an Operating License for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would:
(1) not involve a significant increase in the probability or consequences of an accident praviously evaluated: (2) not create the possibility of a new or differe7ct kind of accident from any accident previously evaluated; or (3) not involve a significant reduction in the margin of safety.
Toledo Edison has reviewed the proyosed changes and determined that a significant hazards consideration toes not exist because the operation of the Davis-Besse Nuclear Power Station, Unit No. 1 in accordance with these changes vould:
i Not involve a significant increast in the probability or consequences of an accident previously evaluated because the accident conditions and i
assumptions are not affected by the proposed Technical Specification changes. The aspects important to safety, that vere previously l
characterized on the organization chtrts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provision celating to organization and l
management necessary to ensure operation of the facility in a safe manner, i
The proposed changes are also consistent with the guidance provided in NRC l
Generic Letter 88-06 (10CFR50.92(c)(1)).
i Not create the possibility of a new or different kind of accident from any accident previously evaluated because the accident conditions and assumptions are not affected by the proposed Technical Specificaticn
(
changes. The aspects important to safety, that vere previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspecte of the organization structure in the Technical Specifications. The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and l
L
f
Dock 3t Ns.30-346 Lie:nso Ns. NPF-3 Serial No. 1512 r
Page 6 e
10CFR50.36, by pr'oviding the provision relating to organization and management necessary to ensure operation of the facility in a safe manner.
The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-06 (10CFR50.92(c)(2)).
Not involve a significant reduction in a margin of safety because the amendment does not affect any operating practices or limits nor any equipment important to safety. The aspects important to safety, that were previously characterized on the organization charts, are being replaced with general requirements that capture the essential aspects of the organization structure in the Technical Specifications.
The proposed Technical Specifications meet the requirements of 10CFR50, Appendix B and 10CFR50.36, by providing the provision relating to organization and management necessary to ensure operation of the facility in a safe manner.
The proposed changes are also consistent with the guidance provided in NRC Generic Letter 88-96 (10CFR50.92(c)(3)).
CONCLUSION On the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.
i 1
l l