ML20212A865

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Safety Evaluation Supporting Amend 98 to License NPF-3
ML20212A865
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 02/18/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20212A846 List:
References
TAC-63189, NUDOCS 8703030427
Download: ML20212A865 (5)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT A0.98 TO FACILITY OPERATING LICENSE NO. NPF-3 TOLEDO EDISON COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346 INTRODUCTION By letter dated July 26, 1985, Toledo Edison Company (TED or the licensee) made application for amendment to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No.1.

The change proposed a revision to the Technical Specifications (TSs) concerning the position to which the Company Nuclear Review Board (CNRB) reported, changing it from the President and Chief Operating Officer to the Senior Vice President, Nuclear. The licensee's submittal did not address the three standards of 10 CFR 50.92(c) as required by 10 CFR 50.91. Therefore, the NRC staff requested the licensee l

to do so in a letter dated November 4, 1985. The licensee responded in a letter I

dated December 5, 1985, which addressed the three standards and added an additional proposed TS change to include the new position title, Senior Vice President, Nuclear. However, the resubmittal did not include a revised Figure 6.2-1, and since the licensee planned to submit additional TS changes concerning the organization, the staff review was held in abeyance.

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On October 22, 1986, the licensee submitted an application for amendment which included the above changes and other organizational and administrative changes to bring the TSs into agreement with their existing organization.

By letter dated November 13, 1986, the licensee corrected a clerical error in the October 22, 1986, application.

The proposed changes are to: revise the reporting and advising relationship between the CNRB and the President and Chief Operating Officer and Senior Vice President, Nuclear; revise specific sections to be more consistent with the Babcock and Wilcox (B&W) Standard Technical Specifications, NUREG-0103, Revision 4 (STS); revise composition of the Station Review Boa N.(SRB) to expand the range of expertise on the SRB and to reflect recent individual and/or group responsibility, organization, and title changes; and revise organizational position titles and position responsibilities.

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. On January 22, 1986, the licensee submitted an application for amendment i

which proposed to change the duties and responsibilities of the Station Peview Board. That application also included some position title changes, j

To insure consistency within the TSs, we have included those portions of i

that application which relate to title changes in our evaluation of the October 22, 1986 application.

l The proposed changes from these two applications which are evaluated herein involve TS Sections 6.1.1, 6.2.2, 6.2.3, 6.3.1, 6.4.1, 6.5.1, 6.5.2, 6.6.1, and 6.7.1, and Figures 6.2-1 and 6.2-2.

For consistency, corresponding title changes have also been included in Sections 6.8.2 and 6.8.3.

EVALUATION The licensee, in the October 22, 1986 application, has proposed to change the reporting and advising relationship of the Company Nuclear Review Board, CNRB, as delineated in Section 6.5.2.9, from reporting to the President to reporting to the Senior Vice President.

The licensee states in their July 26, 1985 submittal that when the original TSs were issued, two Vice Presidents, one of which was the Vice President, Nuclear, were designated as members of the CNRB, and because of this, the Board reported to the President and Chief Operating Officer.

In License 1

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Amendment No. 76, dated November 5, 1984, the board membership was revised, removing the two Vice Presidents from board membership and reducing the CNRB i

from 10 to 8 and also making other title changes. The position of Senior Vice President, Nuclear, was created in a manaaement reorganization in July 1985.

This change in reporting of the CNRB is in agreement with the B&W STS (NUREG-0103, Revision 4).

The staff has reviewed the above changes and finds that these changes are administrative in nature and have no affect on safety and are, therefore, 1

acceptable.

1, Other organization title changes shown in the revised Figure 6.2-1 change the title of Station Superintendent to Plant Manager. The Assistant to the i

Vice President, Nuclear, is changed to Assistant Vice President, Nuclear; Administrative Service Vice President to Administration Senior Vice President; i'

Assistant Plant Superintendent Operations to Assictant Plant Manager, Operations; l

Assistant Station Superintendent Outage Management to General Superintendent L

Outage and Program Manaaement; the Chemist and Health Physicist to Chemistry and Health Physics General Superintendent; Technical Engineer to Technical Support Manager; Nuclear Facility Engineering Director to Engineering General l

Director; Nuclear Licensing Manager to Nuclear Licensing Director; and the Nuclear Training Manager to Nuclear Training Director.

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_ The revisions to Figure 6.2-1 also include the following new positions:

The Administrative Services Assistant Vice President and the Personnel Assistant Vice President report to the Administration

' Senior Vice President.

The Independent Safety Engineering Director reports to the Senior Vice President, Nuclear.

The Nuclear Health and Safety Director and the Inforration Management Director report to the Assistant Vice President, Nuclear.

The Assistant Plant Manager, Maintenance, reports to the Plant Manager.

The Nuclear Engineering Director, Performance Engineering Manager, Systems Engineering Director, and the Design Engineering Director report to the Engineering General Director.

In addition to title changes and the realignment of responsibilities, the reorganization changes the level of some of the positions. The following positions have moved higher in their reporting status which is considered an overall enhancement:

The Nuclear Training Director and the Nuclear Licensing Director now report directly to the Senior Vice President, Nuclear.

The Technical Support Manager and Chemistry, Health Physics General Superintendent and Assistant Plant Manager, Maintenance, now report directly to the Plant Manager.

The Shift Supervisor now reports directly to the Operations l

Superintendent.

The following positions have moved lower:

The Environmental Activities and Emergency Planning Group now report to the Nuclear Health and Safety Director, a new position that reports to the Assistant Vice President, Nuclear.

This removes the groups one step from the Senior Vice President, Nuclear, but preserves their independence from line management.

The NRC staff has reviewed the above changes and concludes that the organizational changes in most cases eliminate organizational steps to the President and enhance the position status.

In the cases where the positions were moved one step further from the President, the positions' independence from the line organization was maintained. The staff concludes that the organization shown in Figures 6.2-1 and 6.2-2 is acceptable.

,' Other organizational changes submitted include a revision to the membership of the SPB, Section 6.5.1.2, to expand the rance of expertise and to reflect changes in individual and/or group responsibilities and organization and l

position title changes of the reorganization. The SRB membership has been reduced by one member, the Plant Manager (fomerly the Station Superintendent).

Four of the eight proposed board positions are ones of equivalent expertise but with new titles, i.e., the Operations Engineer, now Plant Operations Superintendent; the Technical Engineer, now Technical Support Manager; the Chemist and Health Physicist, now Chemistry and Health Physics General 1

Superintendent; and the Assistant Station Superintendent, now is the Assistant Plant Manager, Operations. Three former SRB positions, Lead Instrument and Control Engineer, Nuclear Perfomance Engineer, and Nuclear Reliability Manager have been replaced with an Engineering Director or i

Performance Engineering Manager, an imediate supervisor of these former members with equivalent expertise. Three new positions proposed are the 1

Operations Quality Assurance Manager, Assistant Plant Manager, Maintenance, and Plant Operations Engineering Supervisor. These new positions add areas of expertise not previously present in the SRB. The proposed amendment also changes the SRB Chairman from the Assistant Station Superintendent (now Assistant Plant Manager, Operations) to one designated in writing by the Plant Manager from the SRB members.

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Although the STS example of the makeup of the SRB includes the Plant Manager l

as Chaiman, it is not important to the safety program that he be the Chairman nor even be a member of the board since the board's stated function is to advise the Plant Manager on all matters related to nuclear safety, and to i

reconnend to the Plant Manager written approval or disapproval of the reviews.

The Plant Manager continues to approve procedures and programs pertinent to the safe operation of the plant per TS Sections 6.8.1 and 6.8.2.

The proposed change also includes the requirement that the Plant Manager appoints the SRB Chairman from the designated members.

L The NRC staff concludes that these proposed changes in the SRB enhance the areas of expertise and the overall knowledge of the board and do not signi-ficantly decrease the Plant Manager's mlationship with the board; therefore, the staff finds these changes acceptable.

Other TS changes proposed in addition to the position title changes are:

Figure 6.2-1 is added to Section 6.2.2.

Section 6.2.2 footnote ** has been deleted because it is no longer required.

Section 6.2.2 footnote i has been revised to include the radiation protection individual in the two hour absence waiver and to provide wording consistent with STS.

Section 6.7.1.a wording has been revised to provide imediate reporting to the NRC Operation Center as required by 10 CFR 50.72.

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The staff has reviewed these proposed revisions and finds them to be admin-istrative changes that bring TS wording and requirements into agreement with the Commission's regulations and STS wording; therefore, the staff finds the changes acceptable.

ENVIRONMENTAL CONSIDERATION This amendment relates to changes in recordkeeping, reporting, or admin-istrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Pursuant to 10 CFP 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

CGNCLUSION We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be e.ndangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated: February 18, 1987 Principal Contributors:

K.R. Ridgway and A.W. DeAgazio i

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