ML20215L668

Revised Application for Amend to License NPF-3,changing Tech Specs to Reflect Administrative & Organizational Changes for Consistency W/B&W Rev 4 to NUREG-0103, Sts

ML20215L668
Person / Time
Site:	Davis Besse
Issue date:	10/22/1986
From:	Williams J TOLEDO EDISON CO.
To:
Shared Package
ML20215L662	List: ML20215L660 ML20215L668 ML20215L675
References
RTR-NUREG-0103, RTR-NUREG-103 TAC-63189, NUDOCS 8610290238
Download: ML20215L668 (10)

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APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are forty-three (43) copies of the 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. 1313 include Sections 6.1.1; 6.2.2 and Figure 6.2-1; 6.2.2 and Figure 6.2-2; 6.2.2d; 6.2.2f; 6.2.3; 6.3.1; 6.4.1; 6.5.1.1; 6.5.1.2; 6.5.1.7c; 6.5.1.8; 6.5.2.9; 6.5.2.10a-c; 6.6.1b; 6.7.lb; 6.7.1d; and 6.8.

By ,

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enior Vice Presid , Nuclear 8610290238 861022 PDR ADOCK 05000346 p PDR Sworn to and subscribed before me this 22nd day of October, 1986.

L Illbf r . lA Notary Public, State of Ohio My Commission Expires /. /

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4 Docket No. 50-346 License No. NPF-3 Serial No. 1313 October 22, 1986 Attachment The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station Unit No. 1, Operating License NPF-3, Appendix A, Technical Specifications, Sections 6.1.1; 6.2.2 and Figure 6.2-1; 6.2.2 and Figure 6.2-2; 6.2.2d; 6.2.2f; 6.2.3; 6.3.1; 6.4.1; 6.5.1.1; 6.5.1.2; 6.5.1.7c; 6.5.1.8; 6.5.2.9; 6.5.2.10a-c; 6.6.lb; 6.7.lb; 6.7.1d; and 6.8.

A. Time Required to Implement: This change is to be effective itnediately upon NRC issuance of the License Amendment.

B. Reason for change (Facility Change Request 85-0282, Revision C):

The proposed changes are to: revise the reporting and advising relationship between the Company Nuclear Review Board (CNRB) and the i

President and Chief Operating Officer and Senior Vice President, ,

Nuclear; revise specific sections to be more consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4; revise composition of the Station Review Board (SRB) to expand the range of expertise on the SRB and to reflect recent individual and/or group responsibility, organization, and title changes; and revisa organizational position titles and position responsibilities.

C. Safety Evaluation: See attached Safety Evaluation.

D. Significant Hazards Consideration: See attached Significant Hazards Consideration.

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Docket No. 50-346 License No. NPF-3 Serial No. 1313 October 22, 1986 Attachment SAFETY EVALUATION l

Section 6 to the Davis-Besse Nuclear Power Station Unit No. 1 Operating License, Appendix A, Technical Specifications, concerns administrative controls. Administrative controls are the provisions of the license relating to organization, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

PROPOSED AMENDMENT REQUEST The proposed license amendment request revises the following sections of the Davis-Besse Nuclear Power Station Unit No. 1 Operating License, Appendix A, Technical Specifications:

6.1.1 (page 6-1) - Changes title of Plant Superintendent to Plant Manager.

This is an administrative change.

6.2.2d (page 6-1) - Applies footnote "#" for consistency with Babcock and 4 Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

Footnote "**" on page 6 Deletes footnote to 6.2.2f which has expired.

. Therefore, this is an administrative change.

Footnote "#" on page 6 Revises to include individual qualified in radiation protection procedures and revises wording to be more consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, l Revision 4.

Figure 6.2 Abbreviates the offsite/onsite organization chart (entire page is revised). This change reflects title and position changes under the recent organizational change to enhance management effectiveness.

Figure 6.2.2 - Revised to show the organizational structure and lines of-responsibility for the plant operations staff, including licensed person-

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nel (entire page is revised).

! 6.2.3 (page 6-4a) - Changes title of Superintendent to Plant Manager.

This is an administrative change.

6.3.1 (page 6-5) - Changes title of Radiation Protection Manager to Chemistry and Health Physics General Superintendent. This is an adminis-trative change.

J 6.4.1 (page 6-5) - Changes title of Nuclear Training Manager to Nuclear Training Director. This is a change reflective of increased responsibili-ty to increase management effectiveness.

6.5.1.1 (page 6-5) - Changes title of Station Superintendent to Plant Manager. This is an administrative change.

Dockat No. 50-346 License No. NPF-3 Serial No. 1313 October 22, 1986 Attachment 6.5.1.2 (page 6-6) - Insert "A" changes composition of the Station Review Board (SRB). This reflects changes in title of individual SRB members and changes in individual responsibility due to recent organization changes.

6.5.1.7c and 6.5.1.8 (page 6-8) - Replaces Vice President, Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organiza-tional changes.

6.5.2.9 and 6.5.2.10a, b and c (page 6-12) - Replaces President and Chief Operating Officer with Senior Vice President, Nuclear. Reflects change in renponsibility due to organizational changes and is consistent with the intent of Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

6.6.lb (page 6-12) - Replaces Vice President. Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organizational changes.

6.7.lb (page 6-13) - Changes to reflect 10CFR50.72(a) requirements to notify NRC Operations Center within one hour, which is consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

6.7.1d (page 6-13) - Replaces Vice President, Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organizational changes.

6.8 (page 6-13) - Adds "And Programs" to be consistent with Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4. Accord-ingly, this is an administrative change.

PROPOSED AMENDMENT REQUEST DISCUSSION The safety function of the Station Review Board (SRB), as described in Section 6.5.1.1, is to advise the Plant Manager on all matters related to nuclear safety. The composition of the SRB ensures that the SRB can adequately perform its safety function. The proposed change in Section 6.5.1.2 will incorporate the Toledo Edison organization and managerial title changes as identified above.

The change in SRB composition replaces three members - Lead Instrument and Control Engineer, Nuclear and Performance Engineer, and Nuclear Reliabil-ity Manager. The areas of responsibility for these three SRB members are still represented by their immediate supervisor's SRB membership. Howev-er, the three members replacing those deleted expand the overall areas of expertise represented on the SRB. The addition of the Operations Quality Assurance Manager, represents an area that was not previously present in the SRB. The other two additions, Technical Support Manager and Plant Operations Engineering Supervisor, represent diverse facets of direct plant and administrative and operations responsibility.

The SRB Chairman will be designated in writing, from among the members, by the Plant Manager, adding flexibility to this position.

Docket No. 50-346 License No. NPF-3 Serial No. 1313 October 22, 1986 Attachment Therefore, the proposed changes to the SRB are either organizational in nature, designed to expand the range of expertise on the SRB, or reflect recent individual and/or group responsibility, organizational, and title changes.

The safety function of Sections 6.5.1.8, Records, 6.5.2.9, Authority, 6.5.2.10, Records and 6.7.1, Safety Limit Violation is to provide manage-ment oversight of the minutes, audits and reviews to verify that operation of the facility is performed in a safe manner and is consistent with Company policy, approved procedures and ifcense provisions; to review important proposed changes to the facility, tests and procedures; and to verify that unusual occurrences are promptly investigated and their causes are corrected in a manner that reduces the probability of recurrence.

On July 1, 1985, a management organization change occurred at Toledo Edison in which the President and Chief Operating Officer retired and a replacement was named. At that time, the position of Senior Vice Presi-dent, Nuclear was established replacing the position of Vice President, Nuclear. Sections 6.5.1.7c, 6.5.1.8, 6.6.1b and 6.7.1d reflect this change by replacing Vice President, Nuclear with Senior Vice President, Nuclear.

With the enclosed modification, the CNRB will report directly to the Senior Vice President Nuclear, who reports directly to the President and Chief Operating Officer. This changes the CNRB reporting requirements for Audits and Reviews (Section 6.5.2.9) and Records (Section 6.5.2.10) from the President and Chief Operating Officer to Senior Vice President, Nuclear.

This change is consistent with the intent of the Babcock and Wilcox Standard Technical Specifications, NUREC-0103, Revision 4.

DISCUSSION OF UNREVIEWED SAFETY QUESTION The proposed changes are administrative in nature, broaden the Station Review Board expertise or enhance management effectiveness of the Davis-Besse Nuclear Power Station, Unit No. 1. Implementation of these changes would not:

j 1. Increase the probability of occurrence or the consequences of an i

accident or malfunction of equipment important to safety previously l

evaluated in the safety analysis report (10CFR50.59 (2) (1)) .

l The proposed changes are either administrative, broaden the Station Review Board expertise or enhance management effectiveness and do not increase the probability or consequences of an accident previously I evaluated.

2. Create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report (10CFR50.59 (2) (ii)) .

The changes involve no accident or malfunction scenario. On matters related to nuclear safety, all accidents are bounded by previous analysis and no new accidents are involved.

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Docket No. 50-346 .

License No. NPF-3 Serial No. 1313

! October 22, 1986 Attachment

3. Reduce the margin of safety as defined in the basis for any Technical ,

Specification (10CFR50.59(2)(iii)). l The proposed changes are administrative or enhance management effec-  !

tiveness and oversight and will not reduce the nargin of safety.

I Based on the above evaluation, it is determined that this revision does

not involve an unreviewed safety question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1313 t'etober 22, 1986 Attachment Significant Hazards Consideration The proposed amendment request involves the following changes:

6.1.1 (page 6-1) - Changes title of Plant Superintendent to Plant Manager. This is an administrative change.

6.2.2d (page 6-1) - Applies footnote "#" for consistency with Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

Footnote "**" on page 6 Deletes footnote to 6.2.2f which has expired.

Therefore, this is an administrative change.

Footnote "#" on page 6 Revises to include individual qualified in radiation protection procedures and revises wording to be more consistent with the Babcock and Wilcox Standard Technical Specifications , NUREG-0103, Revision 4.

Figure 6.2 Abbreviates the offsite/onsite organization chart (entire page is revised). This change reflects title and position changes under the recent organizational change to enhance management effectiveness.

Figure 6.2.2 - Revised to show the organizational structure and lines of responsibility for the plant operatione staff, including licensed personnel (entire page is revised).

6.2.3 (page 6-4a) - Changes title of Superintendent to Plant Manager.

This is an administrative change.

6.3.1 (page 6-5) - Changes title of Radiation Protection Manager to Chemistry and Health Physics General Superintendent. This is an administrative change.

6.4.1 (page 6-5) - Changes title of Nuclear Training Manager to Nuclear Training Director. This is a change reflective of increased responsi-bility to increase management effectiveness.

6.5.1.1 (page 6-5) - Changes title of Station Superintendent to Plant Manager. This is an administrative change.

6.5.1.2 (page 6-6) - Insert "A" changes composition of the Station Review Board (SRB). This reflects changes in title of individual SRB members and changes in individual responsibility due to recent organization changes.

6.5.1.7c and 6.5.1.8 (page 6-8) - Replaces Vice President, Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organiza-tional changes.

Docket No. F3 46 License No. NFF-3 Serial No. 1313 October 22, 1986 Attachment 6.5.2.9 and 6.5.2.10a, b and c (page 6-12) - Replaces President and Chief Operating Officer with Senior Vice President, Nuclear. Reflects change in responsibility due to organizational changes and is consistent with the intent of Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

6.6.1b (page 6-12) - Replaces Vice President, Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organizational i,

changes.

l 6.7.lb (page 6-13) - Changes to reflect 10 CFR 50.72(a) requirements to

< notify NRC Operations Center within one hour, which is consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4.

6.7.1d (page 6-13) - Replaces Vice President, Nuclear with Senior Vice President, Nuclear. Reflects change in title due to organizational changes.

6.8 (page 6-13) - Adds "And Programs" to be consistent with Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4. Accord-i ingly, this is an administrative change.

The safety function of the Station Review Board (SRB), as described in Section 6.5.1.1, is to advise the Plant Manager on all matters related to nuclear safety. The composition of the SRB ensures that the SRB can adequately perform its safety function. The proposed change in Section

6.5.1.2 will incorporate the Tolede Edison organization and managerial title changes as identified above.

The change in SRB composition replaces three members - Lead Instrument i and Control Engineer, Nuclear and Performance Engineer, and Nuclear Reliability Manager. The areas of responsibility for these three SRB

> members are still represented by their immediate supervisor's SRB membership. llowever, the three members replacing those deleted expand the overall areas of expertise represented on the SRB. The addition of the Operations Quality Assurance Manager, represents an area that was not previously present in the SRB. The other two additions, Technical Support Manager and Plant Operations Engineering Supervisor, represent diverse facets of direct plant and administrative and operations responsibility.

The SRB Chairman will be designated in writing, from among the members, by the Plant Manager, adding flexibility to this position.

Therefore, the proponed changes to the SRB are either organizational in nature, designed to expand the range of expertise on the SRB, or reflect recent individual and/or group responsibility, organizational, and title changes.

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Dockat No. 50-346 License No. NPF-3 Serial No. 1313 October 22, 1986 Attachment The safety function of Sections 6.5.1.8, Records, 6.5.2.9, Authority, 6.5.2.10, Records and 6.7.1, Safety Limit Violation is to provide manage-ment oversight of the minutes, audits and reviews to verify that operation of the facility is performed in a safe manner and is consistent with Company policy, approved procedures and license provisions; to review important proposed changes to the facility, tests and procedures; and to verify that unusual occurrences are promptly investigated and their causes are corrected in a manner that reduces the probability of recurrence.

On July 1, 1985, a management organization change occurred at Toledo Edison in which the President and Chief Operating Officer retired and a replacement was named. At that time, the position of Senior Vice Presi-dent, Nuclear was established replacing the position of Vice President, Nuclear. Sections 6.5.1.7c, 6.5.1.8, 6.6.lb and 6.7.1d reflect this change by replacing Vice President, Nuclear with Senior Vice President, Nuclear.

With the enclosed modification, the CNRB will report directly to the Senior Vice President, Nuclear, who reports directly to the President and Chief Operating Officer. This changes the CNRB reporting requirements for Audits and Reviews (Section 6.5.2.9) and Records (Section 6.5.2.10) from the President and Chief Operating Officer to Senior Vice President, Nuclear. This change is consistent with the intent of the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4 The proposed change does not involve a significant hazards consideration because operation of Davis-Besse Unit No. 1 in accordance with this change would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated (10CFR50.92(c)(1)).

The proposed changes are either administrative, broaden the Station Review Board expertise, or enhance management effectiveness and are in accordance with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4. This amendment request does not increase the probability or consequencen of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any previously evaluated (10CFR50.92(c)(2)).

It has been determined that a new or different kind of accident will not be possible due to these changes. All accidents are still bounded by previous analysis and no new accidents are involved.

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i Docket No. 50-346

! License No. NPF-3 i Serial No. 1313 October 22, 1986 Attachment

3. Involve a significant reduction in a margin of safety (10 CFR 50.92 (c) (3)) .

l The administrative changes, increase of Station Review Board e expertise, enhanced management effectiveness, and changes to make the Technical Specifications more consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4, will not reduce the margin of safety.

On the basis of the above, Toledo Edison has determined that the

amendment request does not involve a significant hazards consideration.

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