ML20246H010
| ML20246H010 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 04/26/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246G998 | List: |
| References | |
| NUDOCS 8905150327 | |
| Download: ML20246H010 (4) | |
Text
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SAFETY EVALUATI0t: EY THE OFFICE OF NUCLEAR REACTOR REGULATION SUFF0F. TING Af'ENDMENT NO.117 TO FACILITY OPERATIhG LICENSE NO. DPR-29 AMENDMENT NO. 213 TO FACILITY OPERATING LICENSE NO. DPR-30 AMENDMENT NO.105 TO FE0 VISIONAL OPERATING LICENSE NO. DRP-19 AMEhDMEhT N0.100 TO FACILITY OFERATING LICENSE NO. DPR-25 COMl10NWEALTH EDISON COMPANY OUAD CITIES huCLEAR PO'r!ER STATION, UNITS 1 AND 2 DEESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET N05. 50-254/265/237 AND 249 1.0 ihTRODUCT10N By letters cated FeLruary 17 and 21,1989 ar.d March 20, 1985, Commonwealth Eoison Company (CECO, the licensee) proposed to remove Figure 6.1-1, Corporate Organi:r. tion, and Figure 6.1-2, Station Orger.12ation, from Section 6 of the Technical. Specifications (TS) ir, accordance with the guidence of Generic Letter 88-06. As part of this proposeo change, TS Section 6.1 woulo be revised to reft:rence the CECO Quality Assurance Manual and Management Plan as respor.sible docun;ents for nointaining said organization charts and descriptions.
Further nre, Ceco has proposed to revise many of the station (on-site) and corporate (of f-site) position titles, responsibilities, and lines of authority in order to support a major reorganization of their company. The proposed revistor.s also included recognition that the Rac/ Chem department has been split into two separate entities.
2.0 BACKGROUND
I Typically onsite and offsite organizations are defined by organization charts includeo under administrative control requirements of the TS. This requires a license ainendment to change the organization charts before the licensee may is:plement changes in the organizational structure. The guidance provided in G:neric Letter 88-00 (dated March 22,1988) addresses amendments that may be proposed for reinoving organization charts from the administrative control requireinents of the TS. This will permit a licenseo to implement changes to the structure of the offsite or onsite organizations without first having to cbtain NRC approval through the issuance of a license amendment ~to' update l
organization charts in TS. GL 88-06 requires that the Final Safety Analysis Report (FSAR), Quality Assurance (QA) Flan, or other appropriate document contain organization charts with at least the same level of detail as those which are proposeo to be removeo.
8905150327 890426 PDR ADOCK 05000237 P
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-2 Removal of organization charts is a line item improvement that was proposed on a lead-plant basis f or the Shearon Harris plant and was endorsea by the Westinghouse Owners Group. This change was reviewed as part of the NRC's program for improvements in TS. The objectives of that program were established i
by the Commission's Interim Folicy Statement on Technical Specification Improvements.
The staff concluded that removal of organization charts from TS will provide greater flexibility for licensees to implement changes in both the onsite and offsite organizational structure, consistent with Connission policy.
In acc1 tion to CECO's intent to delete organization charts, the licensee proposed to revise significant aspects of TS Section 6.
This revision would reflect change in the CECO organization and update station and corporate position titles, description, responsibilities, and lines of authority. The purpose of the orgar.ization change was to improve cosaunication channels and eliminate reduncant levels of management.
3.0 EVALUATION Regulatory reactrements fcr establishing administrative controls in TS are prescribec by 10 CFR 50.36. This regulation states that administrative controls are provisions related to organization and management necessary to ensure operation of the f acility in a safe manner. Although, 10 CFR 50.36 requires administrative controls be in the TS, it does not mandate organization charts.
It has been the staff's experience that organization charts by themselves have been of little help in ensuring that the objectives of administrative control requirements are met. Specific operational requirements are required elsewhere in TS that bear more directly on operational safety than organization charts. As examples, the organizational elsment responsible for the control room connand function is identified separately in the Quad Cities and Dresden TS, as are the requirements for minimum staffing under various operating conditions. The organizational u nagement functions for independent reviews and audits, unit review and I
independent safety engineering groups, and shift technical advisors are also specified in other subsections of Section 6 of the Quad Cities and Dresden TS.
In accordance with the guidance provided by GL 88-06, Ceco's TS amendment applications for both Quad Cities and Dresden proposed the following changes:
(1) Delete Figures 6.1-1 and 6.1-2 (Corporate and Station Organization Charts).
(2) Replace the reference to Figures 6.1-1 and 6.1-2 with a reference to
" Quality Assurance Manual or the Management Plan" in TS Section 6.1.A.1.
(3) Editorial corrections.
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, Senior reactor operator license ocelified positions, identified on the station organization chart (F1gure 6.1-2), are already specified by TS 6.1.C.
Therefore, these designations are properly retained as administrative requirements even
-after removal of the unit staff organization charts, Consistent with GL 88-06 guidance, the licensee has incorporated the offsite and onsite organization relationships and responsib111 ties into their Quality Assurance Manual or Management Plan for Nuclear Operations. This QA manual provides organization charts with at least the same level of detail as Figures 6.1-1 and 6.1-2, and also provides descriptions of functional responsibilities for positions ir. the QA and Nuclear Operations.
I On the basis of its review of the above items, the staff concludes that the licensee has provided an acceptable response to these items as addressed in the hRC guidance on removing organization charts from the administrative control requirements of the TS. Furthermore, the' staff finds that these changes are consistent with the staff's generic finding on the acceptability of such changes as noted in Generic Letter 88-06.
In addition tc celeting organization charts, changes in on-site and off-site company position titles, responsibilities, description, and lines of authority identified throughout TS Section 6 were made to reflect a major Ceco reorganization. Station and corporate positions affecting nuclear operations l
and management are being reorganized to enhance plant safety by improving i
channels of communication and authority. The NRC staff concludes that the proposeo TS amendnents retain all portions of organizational characteristics which are important to safety, and that the re-organizational changes should not adverselj impact safe operation ano management of the stations. The independence between operations and quality assurance is still. maintained.
Consequently, these amenonents are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
These amendments relate to changes in recordkeeping, or administrative procidures or requirements. The Commission has previously $ssued x proposed finding that these amendments involve no significant hazards consideration and i
thare has been no public comment on such finding. Accordingly, the amendments
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teet the eligibility criteria for categorical exclusion set farth;1e40 CFR.
51.22(c)(10). Pursuant.to10CFR51.22(b),noenvironmentaltapactstatement or environmental assessment need be prepared in connection with the issuance of these amendments, m
5.0 CONCLUSION
The staff has concluded, based on the considerations discusses b that:
1 (1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and (2) public such activities will be conducted in compliance with the Cosmission'.sarwgulations and (3) the issuance of this asendment will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributors: Thierry Ross and Byron Siegel Datsd: April 26, 1989
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April 26 1989 i
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v LA copy of the related Safety Evaluation is also enclosed. A Notice of' Issuance will be included in the Connission's biweekly Federal Register notices, g
1 Sincerely, j
/3 Thierry M. Ross, Project Panager Project Directorate III-2 I
i Division of Reactor Projects - III.
IV, Y and Special Projects
/5/
Byron L. Siegel, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV,.V and Special Projects
Enclosures:
1.
Amendment No.117 to License No. DPR-29 2.
Amendment No.113 to License No. DPR-30
'3.
Amendment No.105 to License No. DPR-19 4.
Amendment No.100 to License No. DPR-25
- 5.. Safety Evaluation cc w/ enclosures:
.See next page DISTRIBUTION Do:ket file' NRC & Local PDRs PDIII-2 r/f LLuther GHolahan MVirgilio DMuller' TRoss BSiegel OGC DHagan EJordan BGrimes 1 Meek (16)
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GPA/PA ARM /LFMB Plant fil:e DMIvTie@r PDJih PDIII-2 /
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