ML20205P863
| ML20205P863 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/31/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20205P856 | List: |
| References | |
| NUDOCS 8811080332 | |
| Download: ML20205P863 (6) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 10 TO FACILITY OPERATING LICENSE NO. NPF-39 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENEPATING STATION UNIT 1 DOCKET NO. 50 352
1.0 INTRODUCTION
By letter dated November 18, 1987 Philadelphia Electric Company,(PEco or l
the licensee) reouested an amendment to Facility Operating License No.
NPF-39 for the Limerick Generating Station Unit 1.
The propnsed amendment would modify Section 6 of the facility Technical Specifications to reflect (I) a new corporate and (II) a new plant staff organizational structure, and (III) a revised composition of the Plant Operations Review Committee.
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By letter dated November 19, 1987 the licensee also submitted a similar application for the Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, l
which it also operates.
The latter application was approved by the i
Cocinission on June 72.1988 (Amendment Nos.132 and 135 to Facility Operating License Nos. OPR-44 and OPR-56).
l 2.0 EVALUATION l
I.
Offsite Management and Support Organization, Figure 6.2.1-1 1
PEco has established, eithin the corporate structure, a dedicated nuclear organization with direct management authority and responsibility over all aspects of nuclear operations, engineering, maintenance, and construction.
4 The new nuclear organization will be headed by an Executive Vice President-l Nuclear with nuclear responsibilities only.
This organization has been forced by separating nuclear engineering, maintenance and other nuclear 2
l operations support activities from corresponding fossil and hydro produc-tion support activities and reassigning these resources to the newly j
established dedicated nuclear organization.
The positions of Senior Vice President-Nuclear Power, Nuclear Production Manager, Superintendent-Nuclear Generation Division, Superintendent-Nuclear Services, and Manager-i Nuclear Plant have been abolished and the functions under these positions have been reassigned within the new organization under the Executive Vice 4
President-Nuclear.
Revision I of the Plan for Restart included a change in the title of the senior nuclear executive to Executive Vice l
President-Nuclear. The new organization is shown in revised Technical i
Specification (TS) Fiqure 6.2.1-1.
Reporting to the Executive Vice President-Nuclear are the Senior Vice President-Nuclear, Vice President-Nuclear Services, Vice President-Nuclear Engineering, General 1
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Manager-Nuclear Quality Assurance, Vice President-Limerick and Vice President-Peach Bottom.
In addition, the Nuclear Review Board (NRB) reports directly to the Executive Vice president-Nuclear.
The new office of Vice President-Nuclear Services has responsibility for nuclear service activities that support the station.
Reporting to the Vice President-Nuclear Services are the Managar-Nuclear Support, Manager-Nuclear Maintenance, Manager-Nuclear Trainino, and Manager-Nuclear Administration. The Manager-Nuclear Support is responsible for licensing, fuel manacement, radiation protection, radioactive waste management, nuclear plant chemistry, emergency preparedness, nuclear plant security and the Operating Experience Assessment program.
The Wanager-Nuclear Maintenance is responsible for the supplemental craft maintenance support which serves the maintenance organization at the nuclear facilities.
These activities include mobile mechanical maintenance, mobile electrical maintenance, and centralized maintenance services.
The Manager-Nuclear Training is responsible for two branches:
the Nuclear Training Section, which has the responsibility for licensed, accredited and general employee training; and the Barbados Training Center, responsible for crafts training for maintenance and construction workers.
The Manager-Nuclear Administration is responsible for coordinating and monitoring activities that support the nuclear organization, including personnel administration, budget and cost control, computer applications, and nuclear records management.
l The new office of Vice President-Nuclear Engineerino is responsible for l
management of engineering activities that support the nuclear facilities.
Reporting to the Vice President-Nuclear Engineering through the Manacer-Nuclear Engineering are the Manager-Engineering, Manager-Pro,iect Manage-ment, Manager-Engineering Design and the Construction Superintendent, Limerick Generating Station Unit 2.
The Manager, Engineering is responsible for engineering designs, analyses.
studies, assistance and expertise, as required, to support the safe and effective operations of the Company's nuclear units.
The Manager, Project Management is responsible for the management of Engineering projects for each station to ensure that all engineering work is defined, planned, schedu'ed, budgeted, implemented, technically l
supported and evaluated in a timely and cost effective manner. The Manager, Projects interfaces with each station'tt Project Manager to coordinate the station implementation of engineering projects.
The Manager Engineering Design is responsible for providing conceptual design support, engineering design, and draftino services to support the development and implementation of nuclear plant modifications.
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5 The Construction Superintendent, Limerick Generatina Station (LGS) Unit 2 is responsible for planning, scheduling, coordinating, directing and controlling the safety, quality, timeliness and cost effectiveness of all work associated with LGS Unit 2 until fuel loading.
The office of General Manager-Nuclear Quality Assurance (NOA) will be responsible for maintaining an effective Nuclear Quality Assurance Program.
Reporting to the General Manager-Nuclear Quality Assurance are the Manager-Peach Bottom Atomic Power Stat' ion Quality, Manager-Limerick Ouality, Manager-Quality Support, Manager-Performance Assessment and Manager-Independent Safety Engineering Group.
The quality control and quality assurance practices c' each site are under the direction of the respective site Managers-Quality.
The Quality Support Manager will be responsible for quality activities common to both sites.
This includes manuals and procedures, vendor audits and surveillance, training, procurement controls, and oversight of Quality activities of Nuclear Engineering and Nuclear Services.
The Performance Assessment Manager will be responsible for ensuring that J
appropriate performance measurement programs are in place to monitor oroanizational performance and to provide independent assessment of the effectiveness of the other nuclear organizations.
The Independent Safety Engineering Group (ISEG) Manager is responsable for the examination of plant operating characteristics, NRC correspont.ence and reports, and other appropriate sources of plant design and noerating experience information that may indicate potential areas for imr, roving plant safety. The Manager-ISEG reports to the Executive Vice r resident-
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Nuclear through the General Manager-NQA.
The staff reviewed the reporting relationship of the ISEG to the corporate organization with respect to whether adequate paths are provided by the organizational structure for identification of ISEG conclusions to the i
appropriate corporate management and with respect to whether the ISEG has sufficient independence from the corporate QA functional organization.
An assessment of the purposes of the five groups in NQA indicates that three of the groups, PBAPS Quality LGS Quality and Quality Support Perform functions related to ensuring compliance with regulatory requirements including 10 CFR Part 50, Appendix B.
The other two groups ISEG and i
Perfonnance Assessment, provide independent assessments and oversight of operations.
The NQA organization has thus been expanded beyond being concerned only with classical quality assurance activities. The staff concludes that these aspects of the organizational structure, which include:
(a) the independence of the ISEG from the classical quality l
assurance groups under the General Manager-NQA, (b) the Manager, ISEG reporting to the General Manager-NQA, and (c) the General Manager-NOA's i
roles as a member of the senior management team reporting directly to the i
Executive Vice-President-Nuclear and as a member of the NRR are e
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, consistent with the staff's guidance regarding the reporting of ISEG activities to a high level corporate official located offsite who is not in the power production management chain.
The Nuclear Review Board (NRB) is responsible for providing independent review and audit of technical and managerial areas.
Its composition is being revised to include outside nuclear executives.
We have reviewed the requested changes and found them acceptable as they meet the acceptance criteria of the appropriate parts of Section 13.1.1 of NUPEG-0800, the Standard Review Plan.
II. Onsite Management Organization TS Figure 6.2.2-1 PEco has established a new office of Vice President-Limerick Generating Station which will have overall control for the conduct of activities of all organizations at the Limerick site. The Vice President-Limerick is located at the Limerick site.
PECo has reassigned previous functions and added new functions under a Plant Manager, Support Manager, Project Manager, Unit 2 Startup Manager and Superintendent-Training, who all report directly to the Vice President-Limerick.
The Plant Manager will be responsible for operating the plant safely, reliably, and efficiently in accordance with all applicable requirements.
Reporting to the Plant Manager are the Superintendent Plant Services.
l Superintendent-Maintenance / Instrumentation and Controls Superintendent Technical, and Superintendent Operations.
The Support Manager will be responsible for procedures, records manage-ment, budget, cost control and ensuring the effectiveness of the site security program.
Reporting to the Support Manager will be the Administrative, Personnel and Security staffs.
i The Project Manager will be responsible 'or outage, modification, and l
planning activities.
Reporting to the Project Manager will be a Superintendent-Outages. Superintendent-Planning, Scheduling, and Reporting, and a Superintendent-Modifications.
l The Superintendent-Training will be responsible to identify the program-i matic training needs of site personnel, to ensure the effectiveness of l
training programs, and to incorporate operating experience into training t
and to monitor participation.
The Superintendent Plant Services will be responsible for management of chemistry, health physics, and radwaste activities. Reporting to the Superintendent will be the Senior Chemist, Senior Health Physicist, and the Radwaste Engineer.
The Superintendent-Maintensnce/ Instrumentation and Controls will be resporsible for the coordinetion of all maintenance and instrumentation f
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, and controls activities. Reportirg to the Superintendent-Maintenance / Instrumentation and Controls will be the Assistant Superintendent-Instrumentation and Controls, and the Assistant Superintendent-Maintenance.
The Superintendent-Technical will be responsible for technical support groups, including regulatory matters.
Reporting to the Superintendent-Technical will be a Technical Engineer responsible for modifications testing, reactor engineering and plant performance, and the process computer; and a Regulatory Engineer responsible for regulatory and INP0 interfaces, the LER program and comitment tracking.
The Superintendent-Operations will be responsible for management oversight of shift operations.
Reporting directly to the Superintendent-0perations are an Assistant Superintendent-Operations and an Operations Support Engineer.
Reporting to the Assistant Superintendent-Operations are the six Shift Superintendents and the six Shift Technical Advisors.
The Shift Superintendents manage the operations of the plant on their assigned shifts.
Either the Plant Manager or the Superintendent of Operations shall hold an SRO license.
The present Superintendent has an SR0 Ifeense and the new Plant Manager has completed the Limerick Station SRO Certification Program and the INP0 Senior Nuclear Plant Mangers Program. The Assistant Superintendent-Operations and the Shift Superintendents are required to have SRO licenses. Although not required, the Operations Support Engineer also holds an SRO license.
PEco has also made numerous revisions to Section 6 to reflect title changes in the revised organization along with minor editorial changes.
Title changes have been made in Sections 6.1, 6.2.2, 6.2.3, 6.4, 6.5, 6.6, 6.7 and 6.8 to reflect the new titles.
We have reviewed the requested changes and found them acceptable as they meet the acceptance criteria of the appropriate parts of Section 4
13.1.2-13.1.3 of NUREG-0800.
III. Plant Operations Review Comittee (PORC) Section 6.5.1 PECo has revised the composition of the PORC because of the revised plant organization.
The revised PORC membership is the Superintendent-Operations as Chairman, Superintendent-Technical, Superintendent-Maintenance / Instrumentation and Controls, Superintendent-Plant Services.
Assistant Superintendent-Operations, Maintenance Engineer, Technical Engineer, Regulatory Engineer and a Shift Superintendent.
In addition, the name of the comittee has been changed from Plant Operation Review Comittee to Plant Operations Review Comittee.
We have reviewed these changes and find them acceptable as they meet the acceptance criteria of the appropriate part of Section 13.4 of NUREG-0800, the Standard Review Plan.
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3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve a change to recordkeeping, reporting or administrative procedures or requirements. Accordingly, the amendments e
meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of the amendments.
l 4.0 CONCLUSTON The Comission has made a proposed detennination that the amendment involves no significant hazards consideration which was published in the Federal Reaister (52 FR 48f89) on December 23, 1987 and consulted with the r
State of Pennsylvania. No public comments were received and the State of Pennsylvania did not have any comments.
The staff has concluded, based on the considerations discussed above.
l 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
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(2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the j
comon defense and the security nor to the health and safety of the public.
Principal Contributor:
R. J. Clark Dated:
October 31, 1988