ML20151X858
| ML20151X858 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/03/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20151X806 | List: |
| References | |
| NUDOCS 8808260126 | |
| Download: ML20151X858 (5) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
.....p SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 149 TO FACILITY OPERATING LICENSE N0. NPF-1 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE, OREGON PACIFIC POWER AND LIGHT COMPANY TROJAN NUCLEAR PLANT DOCKET N0. 50-344
1.0 INTRODUCTION
By letter dated March 31, 1988 as revised June 27, 1988, Portland General Electric Company (PGE) proposed changes to the Trojan Technict.1 Specifi-cations (TS) by replacing the Offsite and Facility Organization Charts with general organizational requirements. Most of these elements are already required by regulation, other TS or the Updated Final Safety Analysis Report (UFSAR). These general requirements capture the essence of those organizational features depicted on the charts that are important to the NRC for ensuring that the plant will be operated safely. PGE's June 24, 1988 letter proposed additional enhancements to the general organization requirements in support of the removal of the organization charts, and did not affect the staff's initial determination of the roposed amendment as published in the Federal Register May 18, 1988 p(53 FR 17791).
2.0 DISCUSSION AND EVALUATION PGE stated that the proposed changes are justified because they are administrative in nature and do not affect plant operation. PGE notes that, in addition to being required by the TS, the important organizational features depicted on organization charts are also required or controlled by other regulatory control mechanisms. Chapter 13 of the Trojan UFSAR contains the detailed organizational structure and a description of the conduct of operations. This information is required by 10 CFR 550.71 to be maintained and updated annually. Moreover, Trojan's Nuclear Quality Assurance (QA) Program is required by 10 CFR 50, Appendix B, to include similar information relating to the organization structure.
PGE contends that changes to these charts have resulted in processing unnecessary amendments by both the company and the NRC; the deletion of the organization charts, therefore, would eliminate needless expend 1ture of resources for both organizations.
T08260126 880803 p/H ADOCK 03000344 PDC
Regulatory Requirements Applicable to Organizational Structure 10 CFR 950.36, "Technical Specifications," which implements Section 182a of the Atomic Energy Act, was promulgated by the Comission on_ December 17, 1968 (33 FR 18610). This rule delineates requirements for determining the contents of TS. 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. Specifically,10 CFR 650.36 requires that:
Each license authorizing operation of a production or utili-zation facility of a type described in 650.21 or 550.22 will include Technical Specifications. The Technical Specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 650.34. The Comission may include such additional TS as the Comission finds appropriate.
The regulation further states that TS will include, among other things, items in the following category:
(5) Administrative Controls: Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee l
shall submit any reports to the Comission pursuant to approved i Technical Specifications as specified in 650.4.
Past Practice Review of the organization, personnel qualifications, education, exper-ience, training, and their overall capacity to operate a plant safely has always been of concern to the NRC, and its predecessor the AEC. Before a plant is licensed to operate, a finding is made that the applicant's staff is capable of operating the plant safely. In the past, the organization I charts were included in the TS so that changes made after operation began l
l would require prior NRC approval. This was done to preserve certain l- specific features of the licensed organization.
l While the regulation does not specifically require that TS contain I organization charts, the practice of including organization charts in TS began in the late 1960s. These charts were used as an aid in depicting the organizational and management relationships thought to be needed to meettheprovisionsof10CFR650.36(c)(5). The practice of including organization charts in TS has continued since.
Organization charts do depict the reporting chain for some organizational functions that must be independent of scheduling and operating pressures.
Until 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plant and Fuel Reprocessing Plants," was adopted in 1970, organization charts were partially relied upon by the staff for assuring this function.
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As stated in 10 CFR 50, Appendix B, Criterion I, "Organization":
Such 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 organization 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. The licensee's required QA program specifies and depicts these organizational relationships in greater detail than that which currently exists in the TS.
The practice of including organization charts in the TS was established before the advent of 10 CFR 50, - Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants," 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 LWR Edition." A general description of the features needed by the staff to make the finding that the applicant is capable of operating the plant safely are now mandated by Appendix B.
Safety Consideration The fundamental safety issue in this license amendment request is whether there can be reasonable assurance that the organization will operate the plant safely and remain effective without requiring prior staff approval for changes reflected in organization charts.
l l It has been the staff's experience that organization charts by themselves have been little help to reviewers in assessing the safety significance l
of changes to the plant and license. Nevertheless, because the charts are in the TS, license amendment requests have been required to effect organizational changes as simple as combining some minor functions under one organizational element shown on the chart. The usefulness of the charts to the staff in recent years has been minimal and the safety relevance of the charts themselves is small.
Specific operational requirements that bear more directly on the safety matters of concern to the staff than the organization charts are required elsewhere in the TS. As examples, the organizational element responsible l
for control room comand function is identified separately in the TS, as are the requirements for minimum staffing under various operating modes.
The organizational management functions for independent reviews and audits, unit review group, and independent safety engineering groups, and shift technical advisor are also specified in other TS Sections. Thus, the organizational charts themselves are not needed to support the staff's finding that the organization will operate the plant safely.
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In sumary, the specific details of the operating crganization are not essential to the safe operation of the facility; the staff concludes that the details can be modified in many ways while maintaining adequate operational safety. Based on years of experience with the details of operating organizations, the staff has been able to distill those organi-zational characteristics which are important to assure plant safety.
The important featm of a licensee's organization (currently depicted on the TS organization charts, but not already included in other TS) necessary for the staff to find that the organization will operate the plant safely are stated below. This amendment revises the TS to add statements incorporating these features to replace the organization charts:
- a. Li.1es of authority, responsibility and communication shall te established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of I
organizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for i key personnel positions, or in equivalent forms of documen-tation. These requirements shall be documented in the FSAR;
- b. The Vice President Nuclear shall have corporate responsibility for overall plant nuclear safety and shall take any measures l needed to ensure acceptable performance of the staff in l
I operating, maintaining, and providing technical support to the plan,t to ensure nuclear safety; l
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- c. The Plant General Manager shall be responsible for overall I unit safe operation and shall have control over those facility activities necessary for safe operation and maintenance of i
( the plant.
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- d. The individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate facility staff managers; however, they shall have
' sufficient organizational freedom to ensure their independence from operating pressures.
- e. Although radiation protection individuals may report to a facility staff manager for matters relating to radiological l
health and safety of employees and the public, the radiation protection manager shall have direct access to the onsite individual having responsibility for overall unit management.
Radiation protection personnel shall have the authority to cease any work activity when worker safety is jeopardized, or in the event of unnecessary radiation exposures.
- f. Senior Reactor Operator (SR0) and Reactor Operator (RO) licenses shall continue to be required for the positions so indicated on the current TS organization charts.
- g. Other TS which reference the current organization charts shall be revised to reference the appropriate functional respcnsibility or position.
The proposed changes incorporate these features. Therefore, the staff l concludes that the removal of the organization charts from the TS will not prevent PGE from meeting the standards of 10 CFR $50.36 and the under-lying statutory requirements. Moreover, the deletion of unnecessary detail of organization charts will save resources for both t.he NRC and the licensee and will allow the staff to focus on issues of importance to the plant's safety.
3.0 CONTACT WITH STATE OFFICIAL The NRC staff has notified the Oregon Department of Energy of the proposed issuance of this amendment along with the proposed detennination of no significant hazards cenMderation. No coments were received.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment relates to changes in recordkeeping, reporting or administra-tive procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 950.22(c)(10). Pursuant to 10 CFR 651.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. ,
5.0 CONCLUSION
We have concluded, based on the consideration discussed above, that (1) there is reasonable assurance that the health and safety of the public l
will not be endangered by operation in the proposed manner, (2) activities
' will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public.
l PRINCIPAL CONTRIBUTOR:
1 T. Chan Dated: August 3, 1988 l
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