ML20236Q914
| ML20236Q914 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/18/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20236Q898 | List: |
| References | |
| NUDOCS 8711200357 | |
| Download: ML20236Q914 (41) | |
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BEFORE-.THE Ap UNITED. STATES-NUCLEAR REGULATORY COMMISSION
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In the Matter.of.
Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY h,
APPLICATION FOR AMENDMENT OF-FACILITY OPERATING LICENSE NPF-39 1
Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company
'97'1120G357 871118~
jDR ADOCK 05000352 PDR
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1 BEFORE THE I
UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 l
I Philadelphia Electric Company, Licensee under facility operating License NPF-39, for Limerick Generating Station Unit 1, hereby requests that the Technical Specifications contained in Appendix A to the Operating License be amended to reflect organizational changes in the corporate and onsite management of Licensee's nuclear operations, engineering, maintenance and other support activities. Proposed Amendments to the Technical Specifications are indicated by the vertical l
bars in the margin of the attached pages 6-1, 6-2, 6-3, 6-4, 6-6, 6-7, 6-8, 6-9, 6-11, 6-12 and 6-13.
The proposed organizational changes include the following:
1.
Separation of nuclear engineering, maintenance, and other nuclear operations support activities from corresponding l 1
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l fossil and hydro production support activities into an 1
organizational structure dedicated primarily to nuclear i
operations support.
2.
The new nuclear organization including both nuclear I
operations and its support activities, will be headed by a Senior Vice President with nuclear responsibilities only.
3.
The Nuclear Review Board will be reconstituted to include membership of senior nuclear executives from outside the Company, and to provide a direct reporting relationship to the Senior Vice President-Nuclear and the Office of the Chief Executive.
1 4.
The organizational chain-of-command will be reduced by the removal of two reporting levels of offsite corporate i
management.
5.
A corporate office, Vice President, Limerick Generating i
Station, will be established on-site, and will be i
dedicated solely to the management of all site organizations and activities except for those organizations involved in independent corporate assessment and oversight activities and the construction of Unit 2 up to startup.
6.
The quality assurance organizations of the Electric Production Department, and of the Engineering and Research i
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Department have been merged into one corporate level-i
-quality assurance department reporting to the Senior Vice j
President.
7.
The station organizational structure will be expanded' horizontally by increasing the number of positions at both the Manager and Superintendent level, thus narrowing the scope of position responsibility at each of these levels.
8.
Except for those organizations involved in independent-corporate assessment and oversight activities, groups i
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performing on-site tasks, but currently reporting to non-station organizations will be integrated into the station organization to establish accountability to onsite i
management.
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Certain organization changes made in November, 1986 involved.
in part, the creation of a' Nuclear Operations Department headed by a 1
vice president reporting to a new position of Senior Vice President, Engineering and Production. Additionally, there is pending an Amendment Application filed on April 1, 1986, relating to onsite organization changes, which is superseded by this Application. The changes which are i
the subject of this Application are discussed against the organization
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of nuclear functione reflected in Figures 6.2.1-1 and 6.2.2-1 of the l
-Technical Specif.ications. ;
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L Licensee proposes to complete the organizational changes proposed herein within 90 days of the issuance of the License Amendment.
Discussion The proposed organizational changes are ' described in three sections: Offsite Management and Support Organization, Onsite ManagementOrganizationandPlantOperationReviewCommittee(PORC).
Each section also includes a safety assessment and a No Significant Hazards Consideration. The Application concludes with a common environmental consideration, a list of proposed changes with the affected pages noted (Appendix A) followed by the proposed Technical
' Specification page. changes.
Offsite Management and Support Organization
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The proposed Offsite Management and Support Organization is j
l shown on Technical Specification page 6-3 as Figure 6.2.1.1 Nuclear
.I Management Organization. A discussion of each position follows.
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o The new office of Senior Vice President-Nuclear consolidates nuclear operations, nuclear services, and engineering support for nuclear I
operations under one senior management office. The Senior Vice President, Nuclear reports to the Chief Operating Officer of the l-Company. The Vice President Peach Bottom Atomic Power Station, the l
i Vice President Limerick Generating Station, the Vice President, i
Nuclear Services, and the Vice President, Nuclear Engineering, newly U
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elected Corporate Officers, will report to the Senior Vice President-Nuclear.
The newly created position of General Manager -
l Nuclear Quality Assurance and the Nuclear Geview Board will report directly to the Senior Vice President-Nuclear. The Senior Vice President-Nuclear will also be the corporate officer responsible for the LGS Unit 2 Project.
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The new office of Vice President. Nuclear Services has responsibility for activities which support the station and reports to the Senior Vice President-Nuclear. Within this new organization there are four new organizations, each with a Manager who reports to the Vice President, Nuclear Services. The four organizations are:
Nuclear Support; Nuclear Maintenance; Nuclear Training; and Nuclear Administration.
The Manager - Nuclear Support has support and oversight responsibility for licensing, fuel management, radiation protection.
. radioactive waste management, nuclear plant chemistry, emergency preparedness, nuclear plant security and the Operating Experience Assessment Program.
The Manager - Nuclear Maintenance is responsible for the supplemental craft maintenance support which serve the maintenance organization at the nuclear facilities. These activities include mobile mechanical maintenance, mobile electrical maintenance, and centralized maintenance services.
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The Manager - Nuclear Training is responsible for three branches: the Nuclear Training Section which has the responsibility for licensed, accredited and general employee training; the Barbadoes Training Center, respor.sible for crafts training for maintenance and construction workers; and the Management and Professional Development Section which is responsible for training and development programs for l
1 PE managers, supervisors, and engineers. The Manager-Huclea? i,aining j
also provides technical direction to each site Training Superintendent, l
The Manager - Nuclear Administration is responsible for coordinating and monitoring activities which support the nuclear organization including personnel administration, budget and cost control, computer applications, and nuclear records management.
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The new office of Vice President, Nuclear Engineering is responsible for management of engineering activities which support the nuclear facilities. The Vice President is assisted by the Manager-Nuclear Engineering.
The Manager - Nuclear Engineering is responsible for the following organizational units: the Engineering Division, the Project j
Management Division, the Engineering Design Division, and the Limerick Generating Station Unit 2 Construction Division.
The Manager, Engineering is responsible for engineering designs, analyses, studies assistance and expertise as required, to j
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support the safe and effective operations of the Company's nuclear units.
i The Manager, Projects is responsible for the management of engineering projects for each station to ensure that all engineering work is defined, planned, scheduled, budgeted, implemented, technically supported and evaluated in a timely and cost effective manner. The Manager, Projects interfaces with each station's Project Manager (discussed later in the Application) to coordinate the station implementation of engineering projects.
The Manager, Engineering Design is responsible for providing conceptual design support, engineering design, and drafting services to support the development and implementation of nuclear plant modifications.
The Construction Superintendent, Limerick Generating Station 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.
o The General Manager-Nuclear Quality Assurance (NQA) will report directly to the Senior Vice President-Nuclear and will be responsible for maintaining an effective Nuclear Quality Assurance j
i Program.
Previously separate Quality Assurance and Quality Control activities will be integrated into one centralized organization, the new Nuclear Quality Assurance Department. Within this centralized j
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organization are the following-organizational units: PBAPS Quality.
-LGS Quality, Quality Support, Performance Assessment, and Independent Safety Engineering. The quality control and quality ~-
assurance activities on each site-are under the direction of the site Quality Managers. The Quality Support Manager. will be responsible for quality activities applicable.to both sites. This-includes manuals-and procedures, vendor audits and surveillance, training, procurement controls, and oversight of quality activities i
of Nuclear Engineer.ing and Nuclear Services.
The HQA Department will include the Independent Safety Engineering j
Group'and the new Performance Evaluation group. The Performance Evaluation Manager will be responsible for ensuring that appropriate i
performance measurement programs are in place to monitor organizational performance and to provide independent assessment of the effectiveness of other nuclear organizations. The Independent i
k Safety Engineering Group (ISEG) Manager is-responsible' for the j
i examination of plant operating characteristics, NRC correspondence d
and reports, and other appropriate sources of plant design and operating experience information that may indicate areas for J
improving plant safety. The HQA organization also monitors and performs independent review and audits of plant activities including maintenance, modifications, and operational problems, and performs operational analyses in order to identify areas of potential safety I
concern and opportunities for improvements which will further I
enhance plant safety. These organizations report to the Senior Vice j
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1 President-Nuclear through the General Manager-Nuclear Quality _
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The'. Nuclear Review Board (NRB) will be reconstituted to include outside nuclear executives and to provide an independent review and
. audit function of technical and managerial areas. The NRB will report monthly to the Senior Vice President-Nuclear and quarterly to the office of the Chief Executive Officer.
The position of' Senior Vice President-Nuclear Power has been i
i dissolved. The nuclear responsibilities of the former Vice President.
Electric Production Department, will be divided among three vice president. positions: Vice President, Nuclear Services, Vice President, Limerick Generating Station and Vice President, Peach Bottom Atomic
- Power Station. The nuclear related responsibilities of the former Manager, Nuclear Production and the former Superintendent, Nuclear Generation Division will be divided among the Vice President, Peach Bottom Atomic Power Station, the Vice President, Limerick Generating Station, the Vice President, Nuclear Services, and the General Manager-Nuclear Quality Assurance Department. The nuclear responsibilities of the former Superintendent, Nuclear Services and those positions reporting to him will be assigned to the Vice President, Nuclear i
I Services.
4 The responsibilities of the former Vice President, Engineering and Research Department will be divided among the Vice President, Nuclear Engineering, General Manager-Nuclear Quality Assurance _ _ _
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L4 Department, the Vice President, Engineering and Production and the site Vice Presidents. The Vice President, Nuclear Engineering is responsible for engineering activities in support of the nuclear facilities.
Responsibility for the non-nuclear engineering activities are removed from the nuclear management organization and placed under the Vice President, Engineering and Production. The nuclear related l
responsibilities of the former Mechanical-Engineering Division and the former Electrical Engineering Division are assigned to the new Manager-Engineering. Certain responsibilities of the Research and Testing Division and the Construction Division related to onsite activities are assigned to the vice presidents of each nuclear plant.
i The proposed. organizational changes discussed above are inter-related changes with the common objective of creating a unified, exclusively nuclear organizational structure to better manage the licensee's nuclear facilities. The propor,ed changes are considered i
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under a single safety assessment and a single evaluation for No s
Significant Hazards Consideration. The Safety Assessment for the proposed changes follows with an evaluation of each of the three standards as set forth in 10 CFR Section 50.92 to support the conclusion that the changes do not involve Significant Hazards Considerations.
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Safety Assessment
'A separate nuclear organization within the corporate structure, i
as described above, with no responsibilities for fossil and hydro I
operations, will define more precisely both corporate and managerial l
nuclear responsibility, improve intra-organizational communications
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horizontally and vertically, contribute to the development of a more I
distinctly nuclear culture and improve nuclear expertise, and raise the organizational " safety consciousness" level.
The addition of outside expertise to the Nuclear Review Board and the elevation of its reporting level to the Office of the Senior i
i Vice President-Nuclear and the office of the Chief Executive will serve to strengthen the expertise of the Board and ensure its direct access to I
the highest corporate-management level.
l The combining of engineering and operational Quality Assurance functions into a similar Quality Assurance Organization under one i
manager, reporting to the Senior Vice President-Nuclear will provide for a more coordinated Quality Assurance operation resulting in early j
identification, evaluation and resolution of potential safety concerns.
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The organizational changas will not affect plant hardware, plant design, plant system operation or plant system operating i
procedures. Required levels of technical competence will be maintained j
i subsequent to the change. The changes will concentrate personnel i
i attention on the multi-disciplines required for the safe operation and
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support of the nuclear units. The proposed organization changes will
3 provide for' increased management involvement, control, accountability i
and effectiveness, and will enhance operating safety at Limerick l
Generating Station..
l Significant Hazards Consideration Determination i
(1) The proposed char;;es to the offsite organization do not involve'a significant increase in the probability or consequences'of any accident previously evaluated.
The proposed changes to the offsite organization will strengthen and consolidate nuclear management and its support functions.
1 The specific changes are described previously in this Application. The i
i changes will'not' decrease the overall qualification or experience levels j
relative to the current offsite organization. Personnel who previously I
had both nuclear and non-nuclear responsibilities will concentrate on
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providing nuclear support and service.
The proposed organization changes will have no adverse effect on Licensee's capability to respond to an accident as described in the Limerick Generating Station Emergency Plan. The new personnel will not assume' emergency response duties until they are appropriately trained.
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The personnel who are currently trained in emergency preparedness will respond in accordance with the Limerick Emergency Plan, should they be activated, until the personnel in the proposed organization have been trained.
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j Limerick FSAR Chapter 15 has been reviewed to determine the effect the proposed offsite organization changes will have on previously evaluated accidents. The proposed offsite organization will have no adverse effect on the probability or consequences of any previously evaluated accidents.
The proposed reorganization will separate the non-nuclear activities from the nuclear activities and will concentrate attention on the safe operation and support of the Licensee nuclear units. No 1
changes in plant hardware, plant design, plant system operation or plant 1
system operating procedures will result from the proposed changes; for these reasons, the proposed changes to the offsite organization do not involve an increase in the probability or consequences of any accident previously evaluated.
l (2) The proposed changes to the offsite organization do not create the possibility of a new or different kind of accident from any previously evaluated.
i For reasons previously discussed in criterion (1) the proposed I
changes will enhance the offsite organization and will have no adverse impact on plant hardware, plant design, plant system operation or plant system operating procedures.
j Consequently, the proposed changes will not create the possibility of a new or different kind of accident from any previously
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evaluated.
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k (3) The proposed changes to the offsite organization do not i
involve a significant reduction in a margin of safety.
j For reasons previously discussed in criterion (1) the proposed changes will improve the organization and will have no impact on plant hardware, plant design, plant systems,. plant system operation or plant operating procedures. Therefore, the proposed changes to the offsite organization will not reduce the margin of safety, and in fact enhance
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the margin of safety.
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i Conclusion I
1 The proposed reorganization will separate the non-nuclear activities from the nuclear activities and will concentrate attention on 4
the safe operation-and support of the Licensee's nuclear facilities by j
improving control and accountability for nuclear operations and developing management systems and managerial skills. The self-h assessment capability will be strengthened within the nuclear organization by increasing both upper management's involvement in nuclear operations and in timely problem solving.
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Onsite Management Organization I
i The onsite organization restructuring will be coordinated with changes made to the offsite organization. These changes provide increased management involvement and effectiveness and improve control and accountability. The proposed onsite orgar.ization is shown on page f
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6-4 as Figure 6.2.2.1 Organization for Conduct of Plant Operations. A discussion of each position follows. Table I presents the additions and deletions to the onsite organization chart.
I. "The new' office of Vice President, Limerick Generating Station has overall control and responsibility for the conduct of activities of all organizations at the Limerick site, is located onsite, and reports to the Senior Vice President-Nuclear. The station organizations are accountable to the Vice President. Limerick Generating Station except for those organizations involved in independent corporate assessment and oversight activities'and the construction of Limerick Generating Station Unit 2 up to start-up.
Administrative and technical support services are provided by the-organizations described in this Application,under the direction of the Vice President, Nuclear Services and the Vice President, Nuclear Engineering. The activities of these support organizations that may impact plant operation or design are performed only through 4
coordination with and approval of the station organization, j
A.
The new Plant Manager position will replace the Station Superintendent position. The Plant Manager will report directly to the Vice President, Limerick Generating Station. The Plant Manager will be responsible for activities previously assigned to the Station Superintendent as described in LGS FSAR Section 13.1 except for the administrative duties for a) outages, planning, modifications, personnel and security, which - _ _ _ _ _ _ _ _ _ _ - -
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have been assigned to.the projects and support managers, and b) LGS Unit 2 Startup.which will be-assigned to the i
Unit-2 Startup Manager. The Plant Manager will be y
responsible for operating the plant safely, reliably, and efficiently in accordance with all applicable requirements. The Plant Manager will serve as Limerick Emergency Director, in accordance with the Limerick Emergency Plan. The requirements of this position meet or exceed the qualification requirements of ANSJ/ANS-3.1-1978 paragraph 4.2.1 Plant Manager. The Plant Manager or the Superintendent-0perations will be required to hold a Senior ' Reactor Operator license.
1.
'The new Superintendent-0perations position will v.
y report to the the Plant Manager. The Superintendent-Operations is responsible for management oversight of shift operations. 'The Superintendent-0perations will serve as the Chairman of the Plant Operations Review Committee (PORC). The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.1 Plant Manager.
b Either the Plant Manager or the Superintendent-Operations shall hold a Senior Reactor Operator
- license, i
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The new Assistant Superintendent-0perations s
position-will replace the 0perations. Engineer position shown in Technical Specification Figure
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The Assistant Superintendent-Operations dill be responsible for the' day to
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day operations of the Station, 'and will tie i
assigned: the responsibilities currently
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. performed by the Operations Engineer as l
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' described in FSAR Section 13.1. This position H
will assist the Superintendent-0perations in the l
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administration of the shift operations and operations support organizations. The Assistant l
o-1 Superintendent-0perations will report to the Supe?intendent-0perations and hold a Senior
,i Reactor Operator license. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.2 Operations Manager.
1 -1.. The Shift Superintendent position will remain as described in the existing Technical i
Specifications except'for reporting to the Superintendent-0perations through the Assistant l
Superintendent Operations. The requirements of i
this position meet or exceed the qualification s
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requirements'of~ ANSI /ANS-3.1-1978 paragraph 4.3.1-Supervisor Requiring NRC License.
'111..The Operations Support Engineer position will be_
performing a staff-function.for the Superintendent-0perations. Responsibilities of the position will? include support of regulatory and licensing information needs, coordination of I
shif t training with the training organizations, j
and certain administrative functions. The individual in this position is nct required to l
hold an NRC license.
iv. -The Shift Technical Advisor position will remain
-as described in the existing Technical Specifications except for reporting to the Assistant Superintendent Operations.
2.
The new Superintendent-Technical position will report to the Plant Manager. This position will be l
responsible for the technical support groups including regulatory matters. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 i
Technical Manager. Either the Superintendent-~
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Technical or the Technical Engineer will hold a Senior Reactor Operator License. l 1
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The Technical Engineer position will report to j
the-Superintendent-Technical instead of the Station Superintendent. Responsibilities will include modification testing, reactor 1
engineering and plant performance, and the process computer. The instrumentation and i
controls activities will no longer be assigned to the Technical Engineer. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
ii. The new Regulatory Engineer position will report to the Superintendent-Technical. The Regulatory Engineer will be responsible for regulatory and INP0 interface, the LER program and commitment management / tracking. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.6.1 Engineer in Charge-Technical Support.
3.
The new Superintendent-Maintenance / Instrumentation and Controls position will report to the Plant Manager. This position will be responsible for the coordination of all plant maintenance and instrumentation and controls activities, and improved site specific control of previously separate groups.
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4' The requirements of-this position meet or-exceed the qualification requirements of AhSI/ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
a.
The new Assistant Superintendent-Maintenance position will report to the Superintendent-Maintenance / Instrumentation and Controls. This assistant superintendent will be responsible _for managing all electrical and mechanical maintenance in the plant. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1970 paragraph 4.2.3 Maintenance Manager.
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The Maintenance Engineer position remains unchanged'except for reporting to the Assistant Superintendent-Maintenance. The Maintenance Engineer is responsible for implementation of the electrical and mechanical, corrective and preventative maintenance programs in the plant. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.3 Maintenance Manager.
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.ii. The Supervi3or-Maintenance will report'to the Assistant Superintendent-Maint'enance.
Responsibilities; include directing the activities of the crafts involved-in.
performing maintenance activities. The-requirements of this position meet'or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.3.1, Supervisor Not Requiring NRC License.
b.
The new Assistant Superintendent-instrumentation and Controls position will report to the Superintendent-Maintenance / Instrumentation and Controls. :This assistant superintendent will be responsible for managing all instrumentation and controls activities in the plant. The requirements of this position meet or exceed the i
qualification requirements of ANSI /ANS-3.1-1978 4.2.4 Technical Manager.
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The Instrumentation and Controls Engineer position remains unchanged except for reporting to the Assistant Superintendent-Instrumentation and Controls. The Instrumentation and Controls Engineer is responsible for calibration, testing, surveillance, repair, maintenance and _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _
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. record keeping of in-plant.and portable-measuring and test equipment 'and plant computers. The-requirements of this-position meet or' exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager, ii. The Supervisor-Instrumentation and Controls reports to the Assistant Superintendent-Instrumentation and Controls.
Responsibilities include directing the activities of the.. technicians involved in instrumentation and control activities.
The requirements of this position meet the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.4.2 Instrumentation and Control.
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The Superintendent-Plant Services position will report to the Plant Manager and be responsible for management of Chemistry, Health Physics and Radwaste activities. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
i.
The Senior Chemist position remains unchanged except for reporting to the
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Superintendent-Plant Services. The Senior Chemist is' responsible for radiochemistry, chemical control and plant chemistry i
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programs and meets the qualifications l
described in FSAR Section.13.1. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.4.3 Chemistry and Radiochemistry Professional-Technical.
ii. The Senior Health Physicist position
-remains unchanged except for reporting to the Superintendent-Plant Services. This l
position corresponds to the Radiation Protection Manager.as described in Regulatory Guide 8.8-1977.. The requirements of this position meet.or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.4.4 Radiation Protection, Professional 1JTechnical.
iii. The new Radwaste Engineer position will l
I report to the Superintendent-Plant l
Services. The Radwaste Engineer will provide.overall direction for the operation of radwaste systems, conduct of radwaste shipping, and implementation of the - _
l-housekeeping plan (including decontamination operations) for buildings, structures and general site areas. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.3.1 Supervisor Not Requiring NRC License.
B.
The new Froject Manager position will report to the Vice President, Limerick Genersting Station. The Project Manager will be responsible to assure outages are effectively planned and managed. The Project Manager will direct tha three groups responsible for outage, modification, and planning activities. Coordination and cooperation among these three groups are essential for optimum utilization of the work force during plant outages, both planned and unplanned. Having all three groups report to the same manager will enhance this coordination and cooperation. The Project Manager will interface with the Plant Manager to effectively coordinate the activities of their respective groups to help ensure safe and efficient operations.
In addition, the Project Manager will be responsible to establish and maintain an effective materials management system. The requirements of this position meet or exceed the qualification a
L requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
1.
The new Superintendent-Outages position will report to the Project Manager. The Superintendent-Outages will be responsible for providing overall outage management. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-l 3.1-1978 paragraph 4.2.4 Technical Manager.
l 2.
The new Superintendent-Planning Scheduling and l
Reporting position will report to the Project Manager. This position will be responsible for plant performance reporting and integrated planning and scheduling of plant activities. The planning will involve bMh outage and. non-outage activities including maintenance and modifications. The requirements of this position meet or exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
3.
The new Superintendent-Modifications position will report to the Project Manager. The Superintendent-Modifications will be responsible for the control and I
implementation of the plant modifications program.
1 This position requires that the individual meet or i
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exceed the qualification requirements of ANSI /ANS-3.1-1978 paragraph 4.2.4 Technical Manager.
,1 C.
The Support Manager position will report to the Vice
' President, Limerick Generating Station. The Support Manager will be responsible for' procedures, records management, buc'get, cost control and ensuring the effectiveness of the site security program. The Support Manager will also be responsible for personnel
, administration.-
1.
The Administration position will report to the Support Manager. Duties include procedure administration, document control, records management.
' emergency preparedness planning and the industrial safety program.
2.
The Personnel position will report to the Support i
Manager. Personnel will be responsible for personnel administration such as payroll, benefits counseling and coordination and monitoring of the performance review system, industrial relations, site access coordination, and medical exams.
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The new Security position will report to the Support Manager. Security will be responsible for
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4 ll implementation of the Limerick Generating Station Security Plan.
D.
-The new Unit 2 Start-Up Manager position will report to the Vice President, Limerick Generating Station. The Unit 2 Start-up Manager will.be responsible for meeting the quality, schedule and cost objectives for Unit 2 and for the successful completion of the preoperational program prior to fuel load.
-1.
The new Unit 2 Start-up Superintendent-0perations position will assist the Unit 2 Start-Up Manager.
2.
The Unit 2 Start-Up Superintendent-Support position will' assist the Unit 2 Start-Up Manager.
.E.
The new Superintendent-Training position will report to the Vice ? resident, Limerick Generating Station. The Superintendent-Training will be responsible to identify the programmatic training needs of all site personnel, to ensure the effectiveness of training programs, to incorporate operating experience into training and to monitor participation. This training position is also responsible for training activities at the site simulator.
These duties were previously assignad to the Station Superintendent. _ - _ _ _
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. Safety Assessment t
The proposed changes in the onsite organization are designed to provide more: timely and effective control of activities essential to ensure the safe and efficient operation of Limerick Generating Station.
The placement of an onsite corporate officer, Vice President, Limerick Generating Station will accomplish a number of objectives.
First, the Vice President is de'icated solely to the management of the d
Limerick Generating' Station, focusing corporate level attention on station necessities, and fostering corporate accountability. Further, the presence of an onsite corporate officer enhances communication between the station organizations and the highest levels of corporate l
management. With the Vice President's awareness of site activities and his corporate level decision making authorities, the Vice. President will be able to make informed and timely corporate decisions in response to site organizational and operational' concerns. The Vice President has L
full authority for directing, coordinating and c'ontrolling the work of
' all site organizations.
Previously, construction, field engineering, testing, and maintenance craft groups reported to offsite management.
In the new l
organization these groups are integrated into the station organization.
This improves communication and coordination among the groups and provides accountability to the site Vice President. l
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il The proposed organization also provides better functional grouping of related disciplines. The-chemistry and health physics groups, currently reporting to different individuals will report to one superintendent. Similarly, the equipment maintenance program and the instrumentation maintenance program, currently reporting to different organizations will be directed by one superintendent. Reorganization of these similar disciplines under common management improves communication and coordination among working groups. This will lead to the establishment of consistent priorities and the reduction of and timely resolution of problems.
The proposed changes to.the onsite organization involve a horizontal expansion at both the Manager and Superintendent levels. The addition of more managers establishes a separation of responsibility that better enables station management to concentrate their attention on each organizational function. The new organization eliminates various administrative responsibilities from the Plant Manager, thereby allowing more focus on daily plant activities. Similarly, several superintendents will be added to allevia!! the Superintendent-0perations of responsibilities other than plant operations. The safety significance of this expansion is that it allows operations supervision to be exclusively involved in day to day operations.
The proposed organization will include a Personnel position onsite. This position will provide effective and timely resolution of i
l personnel issues. This is expected to lead to improved morale and attitudes and to establish an environment conducive to peak performance. i
The proposed' organization also includes a-Training position onsite who will report directly to the Vice President, Limerick Generating Station.
This elevation of deportability is commensurate with the importance of
' training to plant safety.
The personnel who are currently trained'in emergency preparedness will remain within the organization and retain the ability to act for emergency response. This will ensure that the essential emergency response capabilities are maintained in the interim and subsequently transferred to the new organization in an orderly manner.
As previously discussed the qualifications, educational and training requirements for the positions in the proposed organization meet or exceed the requirements of' ANSI /ANS-3.1-1978.
The organizational changes will not affect plant hardware, plant design, plant system operation or plant system operating procedures. Required levels of technical competence will be maintained subsequent to the change. The changes will concentrate personnel attention on the multi-disciplines required for the safe operation and support of the Licensee nuclear units. The proposed organization changes will provide for increased management involvement, control, accountability and effectiveness, and will enhance operating safety at Limerick Generating Station.
I. _ _ _ - - -. _ _. _ _ _ _ _ _ - - - - -. _ _ _.. -. -
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Significant Hazards Consideration Determination (1) The proposed changes to the onsite organization do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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The proposed changes do not decrease the qualifications, the experience, nor the training requirements of those positions which had a l
title change, but reflect an enhancement of management by changes in the onsite organizational structure and management positions.
l Qualifications of personnel continue to meet or exceed the requirements of ANSI /ANS-3.1-1978 as described previously in this application as committed in the LGS FSAR Section 17.2.A.
These changes do not decrease the effectiveness of the onsite organization or the ability of the organization to respond to safety issues. The restructuring of the onsite organization allows management to increase its attention and focus on safety issues by removing many responsibilities from the Plant Manager (formerly the Station Superintendent) and assigning those activities to other onsite Managers. Establishing an onsite elected corporate officer, and dividing authority and responsibility of the operations and support functions as previously discussed, will enhance overall safety.
Operations personnel will respond to evaluated accidents as analyzed in the Limerick Generating Station FSAR Chapter 15. The reorganization and position title changes are organizational _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
enhancements and do not involve an increase in the probability or consequences of an accident previously evaluated.
(2) The' proposed changes to the onsite organization do not create the possibility of a new or different kind of accident from any previously evaluated.
The effectiveness of the onsite organization is enhanced by the proposed changes and no changes to the operation or configuration of plant systems will result from this proposed change. The changes enhance tae ability of management to effectively respond to safety issues as previously discussed in criteria (1) of this Significant Hazards Consideration Determination. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
(3) The proposed changes to the opsite organization do not involve a significant reduction in a margin of safety.
The revised LGS organization does not change the experience and qualifications of the management positions. As previously discussed in this application, the proposed changes permit greater attention to detail by higher levels of management with direct access to an onsite elected corporate officer. The responsibilities and authority of the l
l many disciplines required to safely operate a nuclear facility are divided among several upper management positions which permit more concentrated attention to those activities while establishing a direct line of accountability to the onsite Vice President and ultimately to - _ _ _ - - _ _.
t
.c s
f.
the Chief Operating Officer. Therefore, the proposed changes, as discussed,~do not reduce the margin of safety.
Conclusion The Licensee has concluded that operation of the facility under the proposed Technical Specifications and the organizational changes therein do not involve a Significant Hazards Consideration.
Discussion of Changes to the Plant Operations Review
^ Committee-In coordination with the changes to the onsite organization, changes will occur. to the Plant Operations Review Comittee (PORC). The proposed changes affect'several members of PORC. The Superintendent-Operations will replace the Station Superintendent as Chairman. The Senior Health Physicist.will be replaced by the. Superintendent-Plant Services. The Reactor Engineer will be replaced by the Technical Engineer. The I&C Engineer will be replaced by the Superintendent-Maintenance / Instrumentation and Controls. In these areas the new representative will be a supervisor of the selected discipline.
Specification 6.5.1.2 will be changed to reflect the new PORC composition. Specification 6.5.1.1 will be changed to "..... advise the Plant Manager..." instead of Plant Superintendent to reflect a new
' title. The new members will be as follows: - _ _ -_- - _ __- __ _
e W
'Cheirman:
Superintendent-Operations Member:
Superintendent-Technical Member:
Superintendent-Maintenance /
Instrumentation and Controls
' Member:
Superintendent Plant Services Member:
Assistant Superintendent-0perations Member:
Regulatory Engineer Member:'
Technical Engineer Member:
Shift Superintendent Member:
Maintenance Engineer Safety Assessment of PORC Changes l
The changes to the PORC are in keeping with the purpose of the proposed organizational changes. The PORC changes will maintain the qualifications, experience, and training requirements of previous members and reflect an enhancement of management due to changes in the onsite organization structure and management positions as previously described in this application. Each member meets the qualifications, experience and training requirements necessary to be a member of PORC.
The proposed changes relieve the Station Superintendent (Plant Manager) of attending PORC meetings and being involved with individual issues. This allows the Plant Manager to focus attention on those issues which affect personnel, plant and public safety as well as to focus on the efficiency of operations.
i l
L, Representation of those disciplines previously represented will
.be maintained by the new PORC' organization. This is accomplished by those changes as described previously in this application. The expertise which may be unique to an individual will still be available by direct representation as may be requested by the PORC.
Other changes to~the PORC' represent changes in member titles in coordination with the proposed onsite organization changes. As previously_ discussed, responsibilities and requirements remain the same for.these positions. Therefore, the required expertise of these members is maintained and the level of PORC review will be unchanged.
The Licensee has concluded that, the proposed changes will not adversely affect personnel, plant or public safety.
No Significant Hazards Determination for the Changes to'the Plant Operations Review Committee (1) The proposed changes to the Plant Operations Review Committee do not involve a significant increase in the l
probability or consequences nf an accident previously
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evaluated.
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Levels of operating safety are maintained or increased for those reasons discussed in the above Safety Assessment.
It is therefore concluded that the proposed changes to PORC do not involve an increase in the-probability or consequences of an accident evaluated in the LGS FSAR, Chapter 15.
(2) The proposed changes to the PORC organization do not
-create the possibility of a new or different kind of accident from any previously evaluated.
)
The effectiveness of the PORC organization is unchanged by the proposed changes and no changes to the operation or configuration of plant systems result from this proposed change. The changes to PORC are administrative and they retain the ability of management to effectively respond to safety issues. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
(3) The proposed changes to the PORC organization do not involve a significant reduction in a margin of safety.
)
The PORC organization was revised in order to accommodate
]
changes to the onsite organization and still provide proper representation. The revisions do not change, nor are they meant to change, the required level of experience and qualifications of the PORC.
Therefore the changes do not reduce the margin of safety as a result of PORC member title changes.
- -si Conclusion Based on the discussion above, operation of the facility under 1i
.the proposed Technical Specification change does not involve a Significant Hazards' Considerations.
. Environment 1' Considerations This proposed amendment revises the offsite and onsite organization charts and revises certain titles in the administrative -
section of the Technical Specifications. The Licensee has determined.
that this amendment involves no increase in the amounts and no change in the types of any effluents that may be released offsite and has also
. determined that there is no increase in the individual. or cumulative
. occupational radiation exposure. Therefore, there is no environmental consir? ration involved and consequently an environmental report is not
~
submitted.
Conclusion The proposed-changes were analyzed to determine how they would affect the accident analysis contained in the Final Safety Analysis Report.
In addition, the review of No Significant Hazards Consideration -
was completed.
In all cases it was concluded that the proposed changes will provide for increased management involvement, control, accountability and effectiveness, and will enhance operating safety at i
Limerick Generating Station.
. The Plant Operation Review Committee and'the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve unreviewed safety' questions or involve significant hazards considerations or an i
environmental consideration and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY l
By
)
ci a
Vice President
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_____________u
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says i
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
So u
o Subscribed and sworn to before me this 19 day of %4,681 ad M */ b onLfa j
J Notary Public JUDITH Y. FRANKUN Notary Public, Phefa., Phda Co.
% Comnessson Experes July 28,1991
l 1
l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Unit No. 1)
CERTIFICATE OF SERVICE j
I hereby certify that copies of the foregoing Application for Amendment of Facility Operating License NPF-39 in the above-captioned matter were servd on the following by deposit in the United States mail, first-class postage prepaid on this 18th day of November, 1987.
William T.
Russell Regional Administrator U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 E. M. Kelly Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Fulton Bank Building, 5th Floor Third 6 Locust Streets Harrisburg, PA 17120
?-
k Euge e J/ Bradley Attorney for Philadelphia Electric Company
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