ML20207D517
| ML20207D517 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/02/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207D514 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 8808150375 | |
| Download: ML20207D517 (3) | |
Text
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,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 115 TO FACILITY OPERATING LICENSE N0. NPF-3 TOLED0 EDIS0N COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET N0. 50-346
1.0 INTRODUCTION
By letter dated April 22, 1988, the Toledo Edison Company (TED), the licensee, proposed changes to Technical Specifications (TS's) Sections 6.2.1, Offsite L0rganization], and 6.2.2, Facility Staff [0rganization]. The proposed changes would delete Figures 6.2-1 and 6.2-2 which show the onsite and offsite organi-zational structure and operations organization and add specific requirements relating to organizational structure to TS Sections 6.2.1 and 6.2.2.
Guidance for these proposed changes to the TS was provided to licensees and applicants by Generic Letter 88-06 dated March 22, 1988.
2.0 BACKGROUND
Consistent with the guidance provided in the Standard Technical Specifications, Specifications 6.2.1 and 6.2.2 of the ;.iministrative control requirements have referenced offsite and unit (onsite) organization charts that are p6ovided 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 onsite organization following issuance of the operating license has required licensees to submit an application for license amendment and NRC approval of any desired changes to these organizations.
The nuclear industry has highlighted this as an area for improvement in the TS. The Shearon Harris licensee proposed changes to remove organization charts from its TS under the lead-plant concept that included the endorsement of the proposed chargos by the Westinghouse Owners Group.
In its review of the Shearon Harris proposal, the staff concluded that most of the essential elements of offsite and onsite organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR Part 50. However, there are aspects of the organizational structure that a:
.mportant to ensure eso015037D$$$$$$46 PDR ADOCK pgy P
' that the administrative control requirements of 10 CFR 50.36 would be met but which would not be retained with the removal of the organization charts.
The applicable regulatory requirements are those administrative controls that are necessary to ensure safe operation of the facility. Therefore, those aspects of organization charts for Shearon 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.
On 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. Subsequently, the staff developed guidance for an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88-06 provided this guidance to all licensees and applicants.
3.0 EVALUATION The Toledo Edison Co. has proposed changes to its TS which are in accordance-with the guidance provided by Generic Letter 88-06 and has addressed the items listed below.
(1) Specifications 6.2.1 and 6.2.2 would be revised to delete the references to Figures 6.2-1 and 6.2-1 and the figures would be removed from the TS.
(2) Functional requirements of the offsite and onsite organizations, consistent with the guidance provided in Generic Letter 88-06, would be defined and added to Technical Specification 6.2.1.
The specification would note aise that implementation of these requirements is documented in the Updated Safety Analysis Report (USAR) and updated in accordance with10CFR50.71(e).
(3) The organization chart for the unit staff does not stipulate senior reactor operator or reactor operator license qualified positions. Hence, this is not an applicable consideration related to the removal of the organization charts from the TS for Davis-Besse.
(4) Consistent with requirements to document the offsite and onsite organization relationships in the form of organization charts, Toledo Edison Co. has added this documentation in the USAR.
Based on review of the above items, the staff concludes that the Toledo Edison Co. has provided an acceptable application with respect to the NRC guidance for removing organization charts from the administrative control requirements of the TS.
Furthermore, the staff firds that these changes are consistent
, with the staff's generic finding on the acceptability of such changes as noted in Generic Letter 88-06.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets 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 or environmental assess-ment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the comon
. defense and security or to the health and safety of the public.
Principal Contributor: Albert W. De Agazio Dated: August 2, 1988
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