ML20236R585
| ML20236R585 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/18/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20236R552 | List: |
| References | |
| NUDOCS 8711230371 | |
| Download: ML20236R585 (47) | |
Text
_
c' BEFORE THE
' UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 l
APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 and DPR-56 l
l Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company j
i
'l 1
8711230371 871119 PDR ADOCK 05000277 p.
f..
a BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF l
l FACILITY OPERATING LICENSES DPR-44 and DPR-56 Philadelphia Electric Company, Licensee under facility operating Licenses DPR-44 and DPR-56, for Peach Bottom Atomic Power Station Unit No. 2 and Unit No. 3, respectively, hereby requests that the Technical Specifications contained in Appendix A to the Operating Licenses 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 fechnical Specifications ate indicated by the vertical bars in the margin of the attached pages 243, 244, 245, 245a, 246, 247., 248, 248a, 249, 251, 252, 252a, 253, 254, 261, 262, 266 and 267.
The proposed organizational changes include the following:
1 1.
Separation of nuclear engineering, maintenance, and other
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nuclear operations support activities from corresponding fossil and hydro production support activities into an organizational structure dedicated primarily to nuclear i
operations support.
2.
The new nuclear organization, including both nuclear operations and its support activities, will be headed by a Senior Vice President-Nuclear 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.
4.
The organizational chain-of-command will be reduced by the l
removal of two reporting levels of offsite corporate management.
5.
A corporate office, Vice President, Peach Bottom Atomic Power Station, has been established on-site, and will be-dedicated solely to the management of all site organizations and activities, except for those j
organizations involved in independent corporate assessment and oversight activities.
6.
The quality assurance organizations of the Electric Production Department and of the Engineering and Research 1
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1 e
Department have been merged into one corporate level Nuclear Quality Assurance Department reporting to the Senior Vice President.
7.
The station organizational structure will be expanded horizontally by increasing the number of positions at both i
the Manager and Superintendent level, thus narrowing the scope of position responsibility at each of these levels, l
i 8.
Except for those organizations involved in independent corporate assessment and oversight activities, all groups performing on-site activities, but currently reporting to non-station organizations will be integrated into the station organization to establish accountability to onsite management.
Certain organization changes made in November, 1986 involved, in part, the creation of a Nuclear Operations Department headed by a l
vice president reporting to a new position of Senior Vice President.
l 1
Engineering and Production, are the subject of a pending Amendment l
Application filed on August 26, 1987 and superseded by this Application.
l The changes which are the subject of this Application are discussed against the organization of nuclear functions reflected in Figures 6.2-1 and 6.2-2 of the Technical Specifications.
Licensee proposes to complete the organizational changes proposed herein within 90 days of the issuance of the License Amendment.
Discussion The proposed changes are described in four sections: Offsite i
Management and Support Organization, Onsite Management' Organization, Plant Operations Review Committee, and Miscellaneous Changes. Each i
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 J
(Appendix A) followed by the proposed Technical Specification page changes.
I.
Offsite Management and Support Organization The proposed Offsite Management and Support Organization is i
shown on Technical Specification page 244 as Figure 6.2-1, " Nuclear _
l Management Organization." A discussion of each position follows.
The new office of Senior Vice President-Nuclear consolidates nuclear j
operations, nuclear services, and engineering support for nuclear operations under one senior management office. The Senior Vice l
President-Nuclear reports to the Chief Operating Officer of the Company.
i The Vice President, Peach Bottom Atomic Power Station, the Vice j
President, Limerick Generating Station, the Vice President, Nuclear i
Services, and the Vice President, Nuclear Engineering, newly elected i
Corporate Officers, will report to the Senior Vice President-Nuclear.
The newly created position of General Manager - Nuclear Quality Assurance and the Nuclear Review Board will report directly to the Senior Vice President-Nuclear. The Senior Vice President-Nuclear will 1
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also be the corporate officer responsible for the Limerick Generating Station (LGS) Unit 2 Project.
A.
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.
1.
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.
2.
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.
3.
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, responsible for crafts j
training for maintenance and construction workers; and the !
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v Management and Professional-Development Section which is responsible for training and development programs for PE managers, supervisors, and engineers. The Manager-Nuclear Training also provides technical direction to each site Training Superintendent.
l 4.
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.
l B.
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.
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.1 1.
The Manager - Nuclear Engineering is responsible for the following organizational units: The Engineering Division, the Project Management Division, the Engineering Design Division and the Limerick Generating Station Unit 2 Construction Division.
I 1.
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.
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ii. The Manager, Project Management 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.
iii. 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.
iv.
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 j
associated with LGS Unit 2 until fuel loading.
l C.
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 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 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 at 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 of the Nuclear Engineering and Nuclear Services.
The NQA Department will include the Independent Safety Engineering Group and the new Performance Evaluation group. The Performance Evaluation Manager will be responsible for ensuring that appropriate performance measurement programs are in place to monitor organizational performance and to provide independent assessment of the effectiveness of the other-nuclear organizations. The Independent Safety Engineering Group (ISEG) Manager is responsible l
l for the examination of plant operating characteristics, NRC correspondence and reports, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety. The NQA 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 j
i concern and opportunities for improvements which will further enhance plant safety. These organizations report to the Senior Vice President-Nuclear through the General Manager, NQA.
4 0.
The Nuclear Review Board (NRB) will be reconstituted to include outside nuclear executives and to provide an independent review and l
audit function of technical and managerial areas. The NRB 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 l
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. The responsibilities of the former Superintendent, Nuclear Services and those positions reporting to him I
will be assigned to the Vice President, Nuclear Services.
I The responsibilities of the former Vice President, Engineering l
and Research Department will be divided among the Vice President, l
l Nuclear Engineering, the General Manager-Nuclear Quality Assurance, the 1
l Vice President, Engineering and Production, and the site Vice Presidents. The Vice President, Nuclear Engineering will be responsible for engineering activities in support of the nuclear facilities.
Responsibility for the non-nuclear engineering activities will be I
removed from the nuclear management organization and placed under the Vice President, Engineering and Production. The nuclear related responsibilities of the former Mechanical Engineering Division and the l
former Electrical Engineering Divisien will be assigned to the Manager-Engineering. Certain responsibilities of the Research and Testing i
Division and the Construction Division related to onsite activities will be assigned to the vice presidents of each nuclear plant.
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 Licensee's nuclear facilities. The proposed changes are considered under a single Safety Assessment and a single evaluation for No Significant Hazards Consideration Determination.
The Safety Assessment for the proposed changes follows, with an
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evaluation for each of the three standards as set forth in 10 CFR 50.92 i
to support the conclusion that the changes do not involve any Significant Hazards Considerations.
i Safety Assessment i
A separate nuclear organization within the corporate structure as described above, with no responsibilities for fossil and hydro operations, will define more precisely both corporate and managerial nuclear responsibility, improve intra-organizational communications horizontally and vertically, contribute to the development of a more 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 Vice President-Nuclear and the Office of the Chief Executive will serve i
to strengthen the experience and expertise of the Board and ensure its direct access to the highest corporate management level.
The combining of engineering and operational Quality Assurance functions into a single Quality Assurance organization under one manager reporting to the Senior Vice President-Nuclear will provide for a more I
coordinated Quality Assurance operation resulting in early identification, evaluation and resolution of potential safety concerns.
)
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 personrel attention to the multi-disciplines required for the safe operation and i
support of the nuclear units. The proposed organizational changes will
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provide for increased management involvement, control, accountability and effectiveness, and will enhance operating safety at Peach Bottom Atomic Power Station.
1 Significant Hazards Consideration Determination 1
(1) The proposed changes to the offsite organization do not involve a significant increase in the probability or i
consequences of any accident previously evaluated.
The proposed changes to the offsite organization will strengthen and consolidate nuclear management and its support functions.
The specific changes are described previously in this Application. The changes will not decrease the overall qualification or experience levels relative to the current offsite organization. Personnel who previously had both nuclear and non-nuclear responsibilities will concentrate on providing nuclear support and service.
The proposed organization changes will have no adverse effect on the Licensee's capability to respond to an accident as described in the Peach Bottom Atomic Power Station Emergency Plan. The new personnel will not assume emergency response duties until they are properly trair.ad. The personnel who are currently trained in emergency preparedness will respond in accordance with the Peach Bottom Emergency i
Plan should they be activated until all personnel in the proposed organization have been trained.
Section 14 of the PBAPS UFSAR has been reviewed to determine the effect the proposed offsite organization changes will have on
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previously evaluated accidents. The proposed offsite organization will I
have no effect on the probability or consequences of any previously evaluated accidents.
l 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's nuclear units. No changes in plant hardware, plant design, plant system operation or plant system operating procedures will result from the proposed changes.
For these reasons, the proposed changes to the offsite organization do not involve an increcse in the probability or consequences of any accident previously evaluated.
l I
(2) The proposed changes to the offsite organization do not create the possibility of e new or different kind of accident from any previously evaluated.
For reasons previously discussed in criterion (1), the proposed changes will enhance the offsite organization and will have no adverse impact on plant hardware, plant design, plant system operation or plant system operating precedures.
Consequently, 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 offsite organization do not involve a significant reduction in a margin of safety.
For reasons previously discussed in criterion (1), the proposed changes will improve the offsite 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 organiz]: ton do not reduce the margin of safety but, in fact, enhance the margi.n of safety.
Conclusion The proposed reorganization will separate the non-nuclear activities from the nuclear activities and will concentrate attention on tne safe operation and support of the Licensee's nuclear facilities by improving control and accountability for nuclear operations and developing management systems and managerial skills. The self- ___- _
assessment capability will be strengthened within the nuclear organization by increasing upper management's involvement in nuclear operations and in timely problem solving.
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II. Onsite Management Organization The onsite organization restructuring will be coordinated with changes made to the offsite organization. These changes will provide increased management involvement and effectiveness and improve control
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and accountability. The proposed Onsite Organization is shown on pages
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245 and 245a as Figure 6.2-2 " Organization for Conduct of Plant Operations". A discussion of each proposed position follows. Table I
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presents the additions and deletions to the onsite organization chart.
The new office of Vice President. Peach Bottom Atomic Power Station will have overall control and responsibility for the conduct of activities of all organizations at the Peach Bottom site, will be j
located onsite, and will report to the Senior Vice President-Nuclear.
The station organizations will be accountable to the Vice President, Peach Bottom Atomic Power Station, except for those organizations involved in independent corporate assessment and oversight activities.
I l
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 l
Engineering. The activities of these support organizations that may
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impact plant operation.or design are performed only through coordination with and appropriate approval of the station organization, l
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A.
The new Plant Manager position will replace the Manager, Nuclear Plant position. The Plant Manager will report directly to the Vice President, Peach Bottom Atomic Power Station. The Plant Manager will be responsible for activities previously assigned to the Manager, Nuclear Plant as described in PBAPS UFSAR Section 13.2.2.2 except for the administrative duties for outages, planning, modifications, personnel and security, which will be assigned to the proposed Project and Support Managers.
The Plant Manager will be responsible for operating the plant safely, reliably, and efficiently in accordance with all applicable requirements. The Plant Manager will serve as PBAPS Emergency Director, in accordance with the PBAPS-Emergency Plan. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 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 report to the Plant Manager. The Superintendent-l Operations will be responsible for management oversight of shift operations. The Superintendent-Operations 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 N18.1-1971 paragraph 4.2.1 Plant Manager. Either the Plant Manager or the
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Superintendent-0perations shall hold a Senior Reactor q
1 Operator' license.
l a.
The new Assistant Superintendent-0perations position will replace the Operations Engineer position shown in Technical Specification Figure N 6.2-2.
The Assistant Superintendent-0perations will be responsible for the day to day operations of the station, and.will be assigned 1
the responsibilities currently performed by the Operations Engineer as described in PBAPS UFSAR Section 13.2.2.5.
This position will assist the Superintendent-0perations in the administration of the shift operations and operations support organizations. The Assistant Superintendent-Operations will report to the Superintendent-Operations and will hold a Senior Reactor Operator license. The requirements of this l
position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.2.2 Operations Manager.
1.
The new Shift Manager position will report to the Assistant Superintendent-0perations. The Shift Manager will be assigned the duties of the former Shift Superintendent, and the shift management duties of the former Operations Engineer. The Shift Manager position will be established to provide a higher.
i level of management authority on'each shift. Each l
Shift Manager will. manage the operations of the plant on his assigned shift by directing and integrating the activities of the operating and operating support l
groups to assure proper performance of duties necessary for safe and efficient operation. The Shift Manager position will be independent of the shift progression sequence.
It is expected that incumbents will be rotated to and from other management positions. Placing this manager on shift will prevent isolation of management from the operators, and will provide the needed management' development and career path opportunities for-professional Operations personnel. Tha positions will be filled by individuals who have a Senior i
Reactor Operator license, bachelor's degree in relevant disciplines, and identified leadership skills. These requirements ensure that shift management has in-depth technical knowledge of plant operations and systems and has the required leadership and managerial ability. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.3.1 Supervisors Requiring AEC Licenses.
ii. The new Operations Support Engineer position will report to the Assistant Superintendent-0perations.
This position will be assigned the technical support l
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. responsibilities of the former Operations Engineer, thus relieving operators of some of their administrative functions. The position of Engineer-Operations Support will require a bachelor's degree in a relevant discipline. The requirements of this
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I position meet or exceed the qualification
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I requirements of ANSI N18.1-1971 paragraph 4.3.2 l
Supervisors Not Requiring AEC Licenses.
iii. The Shift Technical Advisor _ position remains as I
described in the existing Technical Specifications except for reporting to the Shift Manager rather than the former Operations Engineer.
l iv. The Shift Supervisor position remains unchanged except for reporting to the Shift Manager. The Shift Supervisor is responsible for assisting the Shift l
l Manager in-supervising and directing the employees who operate the plant. The requirements of this position meet or exceed the qualification
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requirements of ANSI N18.1-1971 paragraph 4.3.1 Supervisors Requiring AEC' Licenses.
1 1
v.
The titles Control Operatcr and Assistant Control Operator will be changed to Reactor Operator, and will report to the Shift Supervisor. Consistent with the current Technical Specifications Figure 6.2-2, i
there will be three Reactor Operators; one assigned l
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i
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l to each unit, plus one with responsibilities for both units. This will be a purely administrative change in position title, not affecting any position qualifications or responsibilities. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.5.1 Operators.
vi. The number of non-licensed operators assigned duties outside the control room, as depicted on the current organization chart (Figure 6.2-2), will be increased from three to five per shift. This change will establish a minimum shift complement of non-licensed operators that exceeds the regulatory requirements by two, and will enhance the capability of shift 1
personnel to perform the equipment control-i manipulations and surveillance necessary for safe i
plant operations during both routine and transient conditions.
Further, the non-licensed operators currently titled l
Plant Operator, Assistant Plant Operator, and Auxiliary Operator will be depicted on the organization chart under the generic title of Operators. This will be purely a change in nomenclature and will not affect the qualifications l'
or responsibilities of the non-licensed operators.
The change would avoid the administrative burdens associated with processing license amendment applications if changes in position titles occur,in the future.
vii. The new Operations Support Superintendent position will report to the Operations Support Engineer.
Qualifications for this position will require a Senior Reactor Operator license background, although a current license will not be required. This position will also require experience at a shift superintendent / shift supervisor level. His role will require a high degree of involvement in work planning schedules for the shift, since he will be responsible for training and administrative matters for the Shift Supervisors. The Operations Support Superintendent and the organization that he will direct will provide administrative and technical support to the Shift Manager. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.3.2 Supervisors Not Requiring AEC Licenses.
viii. The Utility Shift Managers will report to the Operations Support Engineer. This position will be established for Shift Managers'who are not scheduled for shift duty, and will be filled only when the j
shift schedule permits the assignment of Shift 1
Managers to this position.. Utility. Shift Managers 4
will perform various administrative and technical tasks such as personnel evaluations, procedure reviews, planning and scheduling, and attending i
safety review committee meetings.' The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.3.1 Supervisors Requiring'AEC Licenses.
j l
ix. The new Blocking Coordinator position will report to the Operations Support Superintendent. The Blocking Coordinator and his staff will develop blocking permits for taking systems out of service to accommodate work such as testing, maintenance and modifications. The Blocking Coordinator will have a high school diploma or equivalent, and a minimum of four years of nuclear power operation experience.
The Blocking Coordinator position will provide the q
l option of using Shift Supervisors for periods of two to three months (to provide rotational opportunities 1
from operating shift work), after which they will j
return to normal operating shift duty. This option l
will be implemented when additional Shift Supervisors are available. The requirements of this position l
meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.3.2 Supervisors Nat Requiring AEC Licenses. l l
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d a
x.
The Electrical Supervisor position will report to the j
Operations Support Superintendent. This position will be responsible for coordination of maintenance i
and surveillance testing of electrical equipment to support operations. Qualifications for this position
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include a Senior Reactor Operator license background although a current license will not be required. The 1
requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 j
paragraph 4.3.2 Supervisors Not Requiring AEC Licenses.
xi. The titility Shift Operators will report to the Operations Support Superintendent. These will be l
l operators who are not scheduled for shift duty. The J
f Utility Stift Operators will assist with the equipment Llocking, shift scheduling, procedure i
review and other shift support activities. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 i
paragraph 4.5.1 Operators.
2.
The new Superintendent-Technical position will report to the Plant Manager. This position will be responsible for the technical support groups, including regulatory matters. The requirements of this position meet or exceed the qualification l
requirements of ANSI N18.1-1971 paragraph 4.2.4 Technical J u__
a.
Manager. Either the Superintendent-Technical or the Technical j
Engineer will hold a Senior Reactor Operator License.
1 1.
.The Technical Engineer position-will report to the i
Superintendent-Technical instead of the Station J
1 Superintendent. The responsibilities will include modification testing, reactor engineering and plant performance, and the process computer. The instrumentation and controls activities will no longer be assigned to the Technical Engineer. The
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requirements of this position meet or exceed the l
qualification requirements of ANSI N18.1-1971 1
paragraph 4.2.4 Technical Manager.
l ii. The new Regulatory Engineer position will report to j
the' Superintendent-Technical. The Regulatory.
Engineer will be responsible for regulatory and INP0 interfaces, the LER piogram and commitment management / tracking. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.6.1 Engineer in Charge-Technical Support.
I 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 will improve site specific' control of previously separate groups. The requirements of this position meet or exceed the qualification I
requirements of ANSI N18.1-1971 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 N18.1-1971 paragraph 4.2.3 Maintenance Manager.
i.
The Maintenance Engineer position remair.s unchanged except for reporting to the Assistant Superintendent-Maintenance. The Maintenance Engineer is responsible l
i for implementation of the electrical and mechanical corrective and preventative maintenance programs in
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the plant. The requirements of this position meet or l
exceed the qualification requirements of ANSI N18.1-l 1971 paragraph 4.2.3 Maintenance Manager.
l ii. Supervisor-Maintenance will report to the Assistant Superintendent-Maintenance. Responsibilities include directing the activities of the crafts involved in performing maintenance activities. The requirements of this position meet or exceed the qualification of requirements of ANSI N18.1-1971 paragraph 4.3.2, Supervisors Not Requiring AEC Licenses.
1 b.
The new Assistant Superintendent-Instrumentation and i
Controls position will report to the Superintendent-l Maintenance / Instrumentation and Controls. This j
assistant superintendent will be responsible for managing all instrumentation and controls activities in the plant. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.2.4 Technical Manager.
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1 i.
The Instrumentation and Controls Engineer position 1
remains unchanged except for reporting to the Assistant Superintendent-Instrumentation and Controls. The Instrumentation and Controls Engineer J
is responsible for calibration,_ testing, surveillance, repair, maintenance and record keeping i
of in-plant and portable measuring and test equipment
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j and plant computers. The requirements of this position meet or e<ceed the qualification requirements of ANSI N18.1-1971 paragraph 4.2.4 1
Technical Manager.
ii. The Supervisor-Instrumentation and Controls will report 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 N18.1-1971 paragraph 4.4.2 Instrumentation and Control..
4.
The Superintendent-Plant Services position will report to
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the Plant Manager and will be responsible for management of Chemistry, Health Physics and Radwaste activities. The requirements of this position meet or exceed the qualification requirements of ANSI'N18.1-1971 paragraph 4.2.4 Technical Manager.
i.
The Senior Chemist position remains unchanged except for reporting to the Superintendent-Plant Services.
The Senior Chemist is responsible for radiochemistry, chemical control and plant chemistry programs. The requirements of this position meet or exceed the j
i qualification requirements of ANSI N18.1-1971 i
paragraph 4.4.3 Radiochemistry, Professional-Technical.
ii. The Senior Health Physicist position remains unchanged except for reporting to the Superintendent-Plant Services. This position corresponds to'the Radiation Protection Manager as described in Regulatory Guide 1.8-1975. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 paragraph 4.4.4 Radiation Protection, Professional-Technical.
iii. The new Radwaste Engineer position will report to the Superintendent-Plant Services. The Radwaste Engineer will provide overall direction for the operation of radwaste systems, conduct of radwaste shipping, and l
implementation of the 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 N18.1-1971 paragraph 4.3.2 Supervisors Not Requiring AEC Licenses.
B.
The new Project Manager position will report to the Vice i
President, Peach Bottom Atomic Power Station. The Project Manager will be responsible to assure that outages are effectively planned and managed. The Project Manager will direct the three groups responsible for outage, modification, and planning activities. Coordination and cooperation among l
l these three groups are essential for the optimum utilization of the work force doing plant outages, both planned and unplanned.
I Having all three groups report to the same manager will-enhance this coordination and cooperation. The Project Manager will
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1 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 1
responsible to establish and maintain an effective materials management system. The requirements of this position meet or l
exceed the qualification requirements of ANSI N18.1-1971 l
paragraph 4.2.4 Technical Manager.
i 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 N18.1-1971 paragraph 4.2.4 Technical Manager.
- i 2.
The new Superintendent-Planning. Scheduling and i
Reporting position will report to the Project i
1/l Manager. This position will be responsible for plant l
performance reporting and integrated planning and
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scheduling of plant activities. The planning will involve both outage and'non-outage activities including maintenance and modifications. The requirements of this position meet or exceed the qualification requirements of ANSI N18.1-1971 l
paragraph 4.2.4 Technical Manager.
l 3.
The new Superintendent-Modifications position will report to the Project Manager. The Superintendent-Modifications will be responsible for the control and j
implementation of the plant modifications program.
l The requirements of this position meet or exceed the 4
qualification requirements of ANSI N18.1-1971 paragraph 4.2.4 Technical Manager.
C.
The new Support Manager position will report to the Vice President, Peach Bottom Atomic Power Station. The Support Manager will be responsible for procedures, records management, budget, cost control and ensuring the effectiveness of the site security program. The Support Q
Manager will also be responsible for personnel.
administration.
1.
The new Administration position will report to the Support Manager. Duties will include procedure-administration, document control, records management, emergency prept. redness planning, the industrial safety program.
2.
The new Personnel position will report to the Support Manager. Personnel will be responsible for personnel administration such as payroll, benefit counseling, performance review system, industrial relations, site access coordination, and medical exams.
3.
The new Security position will report to the Support Manager. Security will be responsible for the implementation of the Peach Bottom Atomic Power Station Security Plan.
I 0.
The new Superintendent-Training position will report to the Vice President, Peach Bottom Atomic Power Station.
The Superintendent-Training will be responsible to identify the programmatic training needs of site personnel, to ensure the effectiveness of training programs, to incorporate operating experience into training and to monitor participation. The Superintendent-Training will also be responsible for. - _ _ _ _ _ _ _ _
simulator training activities. These duties were previously assigned to the former Manager-Nuclear Plant.
Safety Assessment 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 Peach Bottom Atomic Power Station.
The placement of an onsite corporate officer, Vice President, Peach Bottom Atomic Power Station will accompiish a number of objectives. First, the Vice President will be dedicated solely to the management of the Peach Bottom Atomic Power Station, focusing corporate level attention on station necessities, and fostering corporate accountability. Further, the presence of an onsite corporate officer will enhance communication between the station organizations and the highest levels of corporate management. With the Vice President's awareness af 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 will have full authority for directing, j
coordinating and controlling the work of all site organizations.
Currently, construction, field engineering, testing, and maintenance craft groups report to offsite management.
In the proposed organization these groups will be integrated into the station organization. This will improve communication and coordination among the groups and will provide accountability to the site vice president. _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _.
The proposed organization will also provide better functional grouping of related disciplines. The chemistry and health physics groups, currently reporting to different individuals, will report to the 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 will improve communication and coordination among working groups. This wil?
lead to the establishment of consistent priorities and the reduction 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 will establish a separation of responsibility that will better enable station management to concentrate their attention on each organizational function. The new organization will eliminate various administrative responsibilities from the Plant Manager, thereby allowing more focus on daily plant activities.
The organizational chhnges proposed under the Superintendent-Operations will establish additional supervisory positions, including implementation of the Shift Manager concept, and a division of responsibility that will enhance the management-operator interaction and focus more supervision on both control room and outside control room shift activities. The additional proposed organizational positions will provide the flexibility to accommodate periodic rotation and alternative i
career paths for shift personnel into non-shift positions. This will enhance operator morale and motivation, and improve the professionalism of the operations organization.
The proposed organization will include a Personnel position onsite. This position will provide effective and timely resolution of personnel issues. This is expected to lead to improved morale and attitudes and to establish an environment conducive to peak performance.
The proposed organization will also include a Superintendent-Training onsite who will report directly to the Vice President, Peach Bottom Atomic Power Station. This elevation of deportability is commensurate I
i with the importance of training to plant safety, and will permit the Plant Manager and his organization to focus on the key plant activities associated with the safe operation of the plant.
i The personnel who are currently trained in emergency preparedness will remain within the station organization and retain the ability to act for emergency response. New personnel will receive the appropriate training before assuming emergency response duties. This will ensure that the essential emergency response capabilities are 1
maintained in the interim and subsequently transferred to the new
{
organization in an orderly manner.
The title changes proposed to Section 6 of the Technical Specifications involve either (1) a change in nomenclature, (2) assignment of the responsibility to a person at an equivalent or higher level in the organization, or (3) reflect the redistribution of responsibilities associated with the organizational enhancements. The proposed change in paragraph 6.4.1 of the Technical Specifications involves the change of " Manager-Nuclear Plant" to " Superintendent-Training" reflects the reassignment of a station support function (personnel training) to another group under the direction of the Vice President, Peach Bottom Atomic Power Station. This will permit the Plant Manager and his organization to focus on the key plant activities associated with the safe operation of the plant.
As previously discussed, the qualifications, educational and training requirements for the positions in the proposed organization meet or exceed the requirements of ANSI N18.1-1971.
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's nuclear units. The proposed organization changes,will provide for increased management involvement, control, accountability and effectiveness, and will enhance operating safety at Peach Bottom Atomic Power Station.
l Significant Hazards Consideration Determination i
(1) The proposed changes to the onsite organization do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the onsite organization will not decrease the qualifications, the experience, nor the training requirements of those positions which had a title change, but will reflect an enhancement of management by changes in the onsite organizational structure and management positions. Qualifications of personnel will continue to meet or exceed the requirements of ANSI N18.1-1971 as described previously in this Application. These changes
~
will not decrease the effectiveness of the onsite organization or the ability of the onsite organization to respond to safety issues. The restructuring of the onsite organization will allow management to increase its attention and focus on safety issues by removing many responsibilities from the Plant Manager (formerly the Manager-Nuclear Plant) and assigning those activities to additional 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 PBAPS UFSAA Chapter 14. 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 i
create the possibility of a new or different kind of accident from any previously evaluated.
1
)
The effectiveness of the onsite organization will be enhanced by the proposed changes and no changes to the operation or configuration j
l of plant systems will result from this proposed change. The changes l
will enhance the ability of management to effectively respond to safety i
issues ac previously discussed in criterion (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.
l
l (3) The proposed changes to the onsite organization do not involve a significant reductinn in a margin of safety.
The revised PBAPS organization will 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 many disciplines required to safely operate a nuclear facility will be divided among several upper management positions which will permit more concentrated attention to those activities while establishing a direct line of accountability to the onsite Vice President and ultimately to the Chief Operating Officer. Therefore, the proposed changes as discussed do not reduce the margin of safety.
l gnclusion The Licensee has concluded that operation of the facility under 1
the proposed Technical Specifications and the organizational changes therein do not involve a significant hazards consideration.
III. Plant Operations Review Committee (PORC)
Licen:;ee proposes changes to Technical Specification Section 6.5.1, which revise the composition of the Plant Operations Review Committee (PORC), to reflect the proposed changes to the onsite organizations. Since Paragraph 6.5.1.1 defines the function of the PORC as advising "the Plant Manager on all matters related to nuclear safety". Licensee proposes removing the Plant Manager from
' u
1 f
the PORC. The proposed chairman is the Superintendent-0perations.
The proposed PORC composition would add the positions of Superintendent-Technical, Superintendent-Maintenance / Instrumentation
]
and Controls, Assistant Superintendent-0perations, Regulatory Engineer and Shift Manager. Also, removed from the PORC composition would be positions of Senior Chemist, Senior Health Physicist, and three positions deleted by the proposed organization: Shift Superintendent, Operations Engineer and Outage Planning Engineer.
'l Licensee proposes that the composition of the PORC, as described in Paragraph 6.5.1.2, be as follows:
Superintendent-0perations(Chairman)
Superintendent-Technical Superintendent-Maintenance / Instrumentation and Controls Superintendent-Plant Services Assistant Superintendent-0perations (to replace the OperationsEngineer)
Maintenance Engineer Shift Manager (to replace the Shift Superintendent)
Technical Engineer Regulatory Engineer Under the proposed organization, the PORC will report the results of its investigations of Technical Specification violations (proposed Paragraph 6.5.1.6.e) to both the Plant Manager and the Vice i
President, Peach Bottom Atomic Power Station. 'The PORC will provide 1
copies of written minutes of each meeting to the Plant Manager and the Vice President Peach Bottom Atomic Power Station (proposed Paragraph 6.5.1.8).
PORC will also submit to the Plant Manager, recommended l l
E
changes to the Plant Security and Emergency Plans (proposed Paragraphs 6.5.1.6.j and 6.5.1.6.k).
In each of these paragraphs, the PORC shall submit their reports "to the NRB" rather than only to the Chairman.
a Under the proposed organization the PORC will also notify "the I
l Vice President, Peach Bottom Atomic Power Station, or in his absence, the Senior Vice President-Nuclear, and the Nuclear Review Board of disagreement between the PORC and the Plant Manager" (proposed Paragraph i
6.5.1.7.c).
Safety Assessment Removing the Plant Manager from the PORC will allow the addition of another member, without affecting the quorum, but increasing the representation of a plant discipline. The' removal of the Plant Manager from PORC recognizes the function of PORC to advise the Plant Manager. The chemistry and health physics disciplines will continue to be represented, through the Superintendent-Plant Services. Since the j
outage planning organization provides a support function that is not directly related to the control of plant operations, the removal of outage planning representation on the PORC will not compromise safety.
The Assistant Superintendent-0perations will replece the former Operations Engineer, and the Shift Manager will replace the former Shift i
Superintendent. The proposed changes to the PORC composition will increase the emphasis on the roles of maintenance and operations in the safety reviews which PORC performs, and will maintain a representation of the technical disciplines required for appropriate review of safety issues. Licensee has concluded that the proposed changes will not adversely impact plant safety. l
1)
Significant Hazards Consideration Determination (1) The proposed changes to the PORC do not involve a jLignificant increase in the probability or consequences of i
an accident previously evaluated.
The changes will not decrease the qualifications, the experience, nor the training of PORC members but reflect an enhancement in the onsite organizational structure and management positions. The changes will not impede the ability of PORC to respond to safety issues since representation of the technical disciplines required for appropriate review of safety issues will be maintained. Section 14 of the PBAPS UFSAR has been reviewed to determine the effect of the PORC composition on previously evaluated accidents. Based on this review and discussion, it is concluded that the proposed PORC composition does not involve a significant increase in the probability or consequences of an.
1 accident previously evaluated.
(2) The proposed chanaes to the PORC do not create the possibility of a new or different kind of accident from any previously evaluated.
The effectiveness of PORC will not be decreased by the proposed changes for reasons discussed above, and no changes to the operations or configuration of plant systems will result. The PORC will allow management to effectively respond to safety issues.
It is, therefore, concluded that the proposed changes do not create the possibility of a l
new or different kind of accident from any previously evaluated.
l I
i l
(3) The proposed changes to the 'PORC do not involve a significant reduction in a margin of safety, i
The PORC organization will be revised in order to accommodate proposed changes to the onsite organization and will continue to provide the proper representation of all disciplines required for proper safety reviews.
It is, therefore, concluded that these changes to the PORC will nnt result in a reduction in a margin of safety.
i IV. Miscellaneous Changes l
In an Application filed January 4.-1985, Licensee requested deletion of the prompt and 30-day reporting specification as recommended in Generic Letter 83-43, dated December 19, 1983, because these requirements have been superseded by 10 CFR 50.72 and 50.73. The Amendment was issued July 17, 1985 to delete references j
to these reporting requirements. Omitted from this Application was a reference on page 248 to a deleted paragraph. Licensee proposes to amend the current 6.5.1.6.j (page 248) to replace this reference to a r, specification (6.9.2.b (5)) deleted by the July 17, 1985 Amendment, and replace it with a reference to 10 CFR 50.72 and 50.73.
In an Application filed August 13, 1986, Licensee added an area of responsibility to the PORC. That item was added to the-existinglistonpage247asitem(h),withoutchangingthe subsequent. indices on page 248. Licensee proposes that the indices on the list of Technical Specification Paragraph 6.5.1.6 be corrected as shown.
1 4
j In an Application filed May. 29, 1984, the Operations and i
Safety Review Committee (OSR) was renamed the Nuclear Review Board-(NRB). That Application failed to amend references to the OSR on pages 261. 266 and 267. Licensee proposes to amend these pages._so that they correctly refer to the NRB.
l Licensee proposes that page 245a be added to accommodate the illustrated onsite management organization, Figure 6.2-2 on two pages.
To establish uniformity in the presentation of the onsite i
organization, and to limit the chart to the key station management positions, the proposed organization chart does not depict engineering positions below senior engineer. This change would also avoid the administrative burden associated with the processing of license amendments to reflect changes to the lower levels of.the station organization. For this reason, Licensee proposes to delete from Figure 6.2-2 the positions of " Performance Engineer", " Reactor Engineer", " Assistant Maintenance Engineer", " Plant Chemist",
" Physicist Applied", " Physicist Technical Support", "ALARA Health i
Physicist", and " staff". All'of the functions performed by these positions will be the responsibilities of the organization depicted i
on the proposed chart. The position of the Instrumentation and l
Controls Engineer will be elevated to_the senior: engineer level; Licensee proposes that the note on Figure 6.2-1 which refers to the administration of the Fire Protection Program be
' removed. The responsibility for_ this program, as well as other station activities essential to the safe operation of the facility.._
will be assigned to the appropriate group in the proposed organization shown on Figure 6.2-2.
This responsibility is 1
specified in the Peach Bottom Fire Protection Plan maintained in accordance with 10 CFR 50.48(a).
Licensee also proposes that the 1
note on Figure 6.2-2 be revised to accurately reflect Paragraph 6.1.1 which describes the designation of the alternate for the proposed Plant Manager.
In order to be consistent with the Standard Technical Specifications (NUREG 0123, Revision 3), Licensee proposes to amend i
the reporting requirements of Paragraph 6.7.1.
Specifically, to notify the Commission within one hour and the Plant Manager, Vice i
President, Peach Bottom Atomic Power Station and the NR8 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a Safety Limit Violation.
Finally, Licensee proposes that where PORC is spelled out, i
l that it be correctly denoted as the " Plant Operations Review Committee" rather than " Plant Operation Review Committee."
Safety Assessment These requests are purely administrative in nature, three of which resulted from oversights in previous Applications. Updating the title of the corporate safety review committee (0SR to NRB), re-numbering a list to eliminate the duplication of an index, removing a reference to a deleted paragraph specifying reporting times, correcting a note on a figure, and providing the NRB membership with reports will not adversely impact the operation or the safety of the plant. 1
Deleting first level supervisory positions and non-supervisory positions from the chart will establish a consistent fornat for the 1
)
organizational structure depicted in the License and will eliminate the presentation of the lower levels of the station organization that should not be subject to the restraints of the License. All of the functions performed by the positions proposed for the removal will be the responsibility of the organizations depicted on the proposed chart.
Their removal will permit the flexibility of reorganizing the lower level of the station organization in a timely manner in order to adapt 5
to new requirements and future needs.
Deleting the reference to the Fire Protection Program responsibility is also administrative, since the responsibility for the program is specified in the Peach Bottom Fire Protection Plan maintained in accordance with 10 CFR 50.48(a). Based on these discussions, it is concluded that these changes will not pose a safety concern.
Significant Hazards Consideration Determination (1) The proposed miscellaneous changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Section 14 of the PBAPS UFSAR has been reviewed to determine the effect of the proposed administrative changes on previously evaluated accidents.
It is concluded that the accident analyses in Section 14 of the UFSAR are not affected by the proposed miscellaneous changes. For this reason, as well as the reasons presented in the --_
f Safety Assessment, it is concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
1 (2) The proposed miscellaneous changes do not create the possibility of a new or different kind of accident from any previously evaluated.
The implementation of these miscellaneous changes will not affect the interpretation or intent of the specifications they involve.
Operating procedures and design of the plant will not be impacted, as a result of implementation. For this reason, as well as the reasons presented in the Safety Assessment, these changes will not create the possibility of a new or different kind of accident from any previously evaluated.
1 1
(3) The proposed miscellaneous changes do not involve a significant reduction in a margin of safety.
The administrative nature of these changes will not impact plant systems or operation. For this reason, as well as the reasons l
presented in the Safety Assessment, it is concluded that these changes will not involve any reduction in a margin of safety.
Environmental Considerations This proposed amendment revises the offsite and onsite organizations and 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 l l
__________-w
fhey -
dj 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 consideration involved and consequently an environmental report is not submitted.
Conclusion The proposed changes were analyzed to determine how they would affect the accident analyses contained in Section 14 of the PBAPS 3
l Updated Final Safety Analysis Report. In addition, the review of No Significant Hazards Consideration was completed.
In all cases it was f
concluded that the proposed changes will provide for increased i
management involvement, control, accountability and effectiveness, and will enhance operating safety at Peach Bottom Atomic Power Station.
The Plant Operations 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
environment consideration and will not endanger the health and safety of j
i the public.
Respectfully submitted, 1
PHILADELPHIA ELECTRIC COMPANY l
I By W N A/%
v o
8 Vice President ___ ____ __ _
i:g;{u_. Jc -
4y y.
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses 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.
L l
V O
Vice President Subscribed and sworn to before me thisif" day l
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