ML20246L957
| ML20246L957 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/11/1989 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20246L940 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 8907190037 | |
| Download: ML20246L957 (19) | |
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ATTACHMENT 1 PEACH BOTTOM: ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATION CHANGE _ REQUEST
" Removal of Organization Charts as Recommended'by Generic
. Letter 88-06" Supporting Information for Changes - 19 pages 00b77 PNu L_.-__-_
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Docket Nos. 50-277.
M-50-278 License Nos. DPR-44 DPR-56 Philadelphia Electric Comp &ny, Licensee under facility operatingLLicenses 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.
Proposed changes to the Technical Specifications are indicated by the vertical bars in the margins of the pages contained in Attachment 2 and. listed here: iv (Unit 3 only), iva (Unit 2 only), vi, via, vii, 243, 244, 245, 245a, 246, 252, and 252a.
This application is submitted primarily as a result of Generic Letter 88-06 " Removal of Organization Charts from Technical Specification Administrative Control Requirements" which encourages' licensees to propose changes to their Technical Specifications to remove organization charts from Technical Specifications and replace them with descriptions of the organizational structure and characteristics which are important t) safety.
The proposed changes concern the Administrative Controls in Section 6.0, and do not affect any Limiting Conditions for Operation or Surveillance Requirements.
The proposed changes in this Application are grouped into two categories.
Each category of changes includes a Description of Changes, a Safety Discussion and a Significant Hazards Consideration.
Category
'A' changes involve removing the onsite and offsite organization charts from Sections 6.2.1 and l
6.2.2, respectively.
These changes are consistent with the guidance i l
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'50-278, ac 4
? License Nos. DPR-44 iDPR-56 g
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fprovided;in' Generic-Letter (GL) 88-06.-
Category
'B' changes are-miscellaneous administrative changes.- The Application concludes
'withia, common Environmental Impact Assessment and'a List of Proposed
-Changes which specifies the pagesfand paragraphs affected by'the-(,
. proposed changes'in both= categories.
Licensee. requests that the proposed; changes be effective as of:the issuance date of the license amendment.-
Description of Changes --Category
'A'
-The removal:of organization charts'is an improvement-that was proposed on a lead plant basis for the Shearon Harris plant and.
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was; endorsed by the Westinghouse Owners' Group.
The NRC approved j
l this' change for Shearon Harris.on January-27, 1988.
This change was reviewed'as part of the NRC's program for improvements in Technical-A Spec'ifications.'
The objectives of that program were-established by-I the Commission's Interim' Policy Statement on Technical' Specification Improvements.
As a result of these efforts,' Generic. Letter 88-06 was issued on. March 22, 1988 which encouraged licensees and applicants to propose changes to their Technical Specifications to remove the organization charts.
Implementing the guidance provided in GL 88-06 involves the following proposed changes:
1 1
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Docket Non. 50-277 i
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'50-278 License Nos..DPR-44 DPR-56 1.
' Add paragraph 6.1.2 which reads "The Shift Supervisor (or, during.his, absence from the control room, a designated individual) shall be responsible for-the control room command function.
A management directive to this effect, signed by the Vice President, Peach Bottom Atomic Power Station shall be reissued to'all station personnel on an annual basis."
2.
Remove the offsite organization chart shown as Figure 6.2-1.
3.
Insert the following as paragraph 6.2.1.
"Onsite and offsite organizations shall be established for unit operation and' corporate management, respectively. 'The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.
a.
Lines of authority, responsibility, and communication shall
.be established and defined for the highest management levels through i. intermediate levels to and including all operating organization positions.
These relationships shal] be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent
' -. t Docket Nos. 50-277.
2 4 50-278 License Nos.'DPR-44 DPR forms of documentation.
These requirements shall be documented in the Peach Bottom Quality Assurance Plan.
b.
The Plant Manager shall be responsible for overall unit safe. operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c.
The Vice President, Peach Bottom Atomic Power Station shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
d.
The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report.to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures."
4.
Remove the-first sentence in paragraph 6.2.2 which reads "The facility organization shall be shown on Figure 6.2-2 and:", and 4 i E __ _ ___ _ _ _ _ _ _ _ _ _. _ - _ _ _. _ _.. _
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- Dock;;t Nos. 50-277
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i50-278
replace'it.with:"The. facility organization.shall be subject to the-'following:".
c 5.
Remove the.onsite' organization chart shown as Figure'6.2-2
,(Sheets 1'and 2).
K-
- 6.. Add Table 6.2.1 to'show the minimum shift crew composition.
.This-information-was ineluded in-Figure'6.2-2 which is' proposed-
.to be deleted.-
'7. : Delete.the reference to Figure 6.2-2 in paragraph 6.2.2.a and' replace it-with a' reference to Table.6.2.1..
n -:7 8.>' Add paragraph 6.2.2.g-which reads "In addition to'the requirements of 6 2.2.a, the following-shall hold a senior reactor operator license:.1) Plant Manager or. Superintendent-Operations, 2) Assistant' Superintendent-Operations and 3)
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Superintendent-Technical or Engineer-Systems."
This information was included in Figure 6.2-2 which is proposed to be deleted.
9.- Revise the Table of Contents pages iv (Unit 3 only), iva (Unit 2 only), vi, via and vii to reflect deletion of Figures 6.2-1 and 6.2-2 and the addition of Table 6.2.1.
The proposed pages via 1 I J
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YU Dockat Non.250-277 Ho
_ 278 5
and vil delete _ duplicate' entries-of' Tables listed on proposed
-pageTvi.
Safety Discussion -- Category ' A' 1
Deletion.of the charts is accompanied by theladdition.of general administrative control requirements which describe the essential aspects of.the organizational. structure! defined in the
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Organization charts.
The additional administrative contr'ol descriptions'arelcontainedLin the proposed paragraph 6.2.1.a through' d.
They involve the designation;of safety responsibilities _and.
organizational freedom of the health physics, training and_ quality assurance. groups..The independence of the qualityLassurance-group is further guaranteed by adherence to 10'CFR 50 Appendix B, Criterion I.
Removing'the organization charts from the Technical Specifications will have a positive impact on safety by permitting a licensee to implement changes to its organizational structure without prior NRC approval provided that the change meets the general administrative controls and organizational objectives specified in proposed paragraph 6.2.1.
Consequently, enhancements to the organizational structure, as well as minor administrative changes-such as position title revisions, can be implemented promptly upon identification of the need for the change.
Safety is ;
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w Dockst No3.L50-277' is 50-278 License Nos. DPR-44 DPR-56 further enhanced tur providing clear and concise definitions of responsibility for.the Shift. Supervisor, Plant Manager and Vice President, Peach Bottom Atomic-Power Station in the proposed paragraphs 6.1.2, 6.2.1.b and 6.2.1.c, respectively.
Removing the charts will not affect compliance with any NRC' regulations.
Title 10 CFR Section 50.36(c)(5) requires that provisions relating to organization and management, procedures, record keeping, review and audit, and reporting.necessary toLassure operation of the facility-in a safe manner be included in the facility Technical Specifications.
However, no particular requirements areLestablished for the format or content of these.
administrative control technical specifications.
Removing the charts.from the Technical Specifications and replacing them with the proposed descriptive language will' assure that organizational commitments continue to be defined and controlled.
The Peach Bottom Quality Assurance Plan contains detailed organization charts and associated descriptions of
. individual and group responsibilities as they apply to the operation and support of the facility.
Appendix B to 10 CFR 50 and 50.54(a)(3) govern changes to the organization as described in the Quality Assurance Plan.
The enforceability of this requirement is further. enhanced by the proposed paragraph 6.2.1.a.
Additionally, i l
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 10 CFR 50.34(b)(6) requires that the organizational structure, along with responsibilities and authorities, be included in the Final Safety Analysis Report.
Section 13 of the Peach Bottom Updated Final Safety Analysis Report (UFSAR) contains the important organizational. features currently depicted on Figures 6.2-1 and 6.2-2.
This information is required by 10 CFR 50.71(e) to be maintained 7
and updated annually.
Thus, even in the absence of tha organization charts from the Technical Specifications, there remains assurance that onsite and offsite organizations will be established and maintained to assure operation of the facility in a safe manner.
The proposed Category
'A' changes are considered to be administrative.
The management positions requiring an NRC license do not change nor does the shift crew composition.
In fact, the shift crew composition as shown on proposed Table 6.2.1 exceeds the requirements of 10 CPR S0.54(m) for non-licensed operators by two.
Further, the proposed Category
'A' changes do not increase or decrease the qualification, experience or training requirements or onsite or offsite nuclear personnel.
Significant Hazards Consideration - Category
'A' (1)
The proposed Category
'A' changes do not involve a significant increase in the probability or consequences of any accident previously evaluated. - _ _ - _ - _ _ _ _ _ _ _ -
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Docket Nos. 50-277-c-
50-278 i
License Nos. DPR-44 DPR-56 Removing the organization charts from the Technical Specifications and replacing them with more general language does not affect. plant operation.
The proposed changes do not increase or decrease the qualification, experience or training requirements of onsite or offsite nuclear personnel.
Addit *onally, the proposed changes do not affect the shift crew composition or the' facility management positions requiring an NRC license.
The Peach Bottom Quality Assurance Plan contains detailed organization charts and associated descriptions of individual and group responsibilities as they apply to the operation and support.of the Peach Bottom facility.
Appendix B to 10 CPR 50 and 10 CFR 50.54(a)(3) govern changes to the organization as described in the Quality Assurance Plan.
10 CPR 50.34(b)(6) requires that the organizational structure also be included in the Final Safety Analysis Report.
Section 13 of the Updated Final Safety Analysis Report provides a description of the organization and detailed organization charts.
As required by 10 CFR 50.71(e), this information must be maintained and updated annually.
Based on this review, it is concluded that the proposed Category
'A' changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.
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Docket Nos. S0-277~
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50-278:
License Nos. DPR-44 DPR-56 (2)
The proposed CategoryA' changes'do not create the o
possibility of a new or diffe' rent kind of accident-from any previously evaluated.
,j The proposed changes are administrative'in nature, and do y
notiinvolve'any physical alterations of plant configurations.or changes ~to-setpoints,.or operating parameters.. It'is therefore concluded that: removing the organization: charts from the' Technical' Specifications does not create the possibility of a new or different kind.of; accident from any previously evaluated.
(3)
The proposed Categcry
'A' changes do not result in a significant reduction in the margin of safety.
-Removing the organization charts from the Technical Specifications enhances the margin of safety by permitting an organizational change lwithout prior NRC approval provided that the objectives of proposed paragraph 6.2.1 are met, thereby allowing a more timely response to situations where the appropriate action is a
. prompt organizational change.
Safety is further enhanced by providing clear and concise definitions of responsibility for the
. Shift Supervisor, Plant Manager and Vice Priesident, Peach Bottom ~
Atotaic Power Station..___z
Docket Nos. 50-277 50-278
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License Mos. DPR-44 DPR-56 i
l Further, the proposed changes include additional administrative controls which capture the essential aspects of the material being removed such that the associated requirements will continue to be met.
Based on this review, it is concluded that the proposed Category
'A' changes do not result in a significant reduction in the margin of safety, but improve the margin of safety.
Description of Changes - Category
'B' The following administrative changes are proposed:
2.
r.evir;e paragraph 6.5.1.2 to replace the Technical Engineer with the Engineer-Systems as a member of the Plant Operations Review Committee (PORC).
2.
Revise paragraph 6.5.2.9 to indicate that the Nuclear Review Board (NRB) reports to and advises only the Executive Vice President-Nuclear and not the Office of the Chief Executive.
J 3.
Revise paragraph 6.5.2.10.c to indicate that NRB audit reports shall oe forwarded to the Corporate Officer (s) responsible for the areas audited instead of the Executive Vice President-Nuclear.
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License Nos. DPR-44 l-DPR-56 l
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1 Safety Discussion - Category
'B' Change Request (1) is proposed to reflect a change to the 1
organization under the Superintendent-Technical.
The Regulatory 4
Engineer and the Technical Engineer are currently described as reporting to the Superintendent-Technical.
Licensee proposes to eliminate the position of Technical Engineer and divide the duties-1 between the proposed Engineer-Systems and the proposed Engineer-I Technical Support.
The Engineer-Systems will be responsible t'or reactor systems and balance of plant systems.
The Engineer-Technical Support will be responsible for reactor, project and test engineers.
Licensee proposes that the Technical Engineer be replar.ed by the Engineer-Systems on the PORC.
The Engineer-Technical Support will be represented on the PORC by the Superintendent-Technical.
As required by proposed specification 6.2.2.g, either the Superintendent-Technical or the Engineer-Systems will hold a Senior Reactor Operator license, thereby ensuring the level of plant operations expertise of the PORC.
Change Request (2) is proposed to reflect the formation of the Nuclear Committee of the Board (NCB).
The function of NCB is to I
advise and assist the Board of Directors in the proper and complete discharge of its responsibilities for oversight of the Company's nuclear operations.
As discussed in Section 4.1 of Revision 1 to l
Section 1 of the Plan for Restart of Peach Bottom Atomic Power
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50-278
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License Nos. DPR-44 DPR-56 1
. Station, the Chairman of the NRB will meet directly with the Chairman of the NCB, and will meet directly with the NCD at.least once annually.
The Office of the Chief Executive will be made aware i
of NRB activities by both the Executive Vice President-Nuclear.and I
the Board of Directors.
The Executive Vice President-Nuclear repor'ts directly to-the Office of the Chief Executive and, in l
accordance with Technical Specification 6.5.2.9, receives reports and advice from the NRB.
The Board of Directors receives reports
'from the NRB through the'NCB.
It is therefore concluded that having the NCB and the Executive Vice President-Nuclear available to advise the Office of the Chief Executive will assure sufficient corporate
' management involvement in nuclear plant safety.
Change Request (3) is proposed to assign a more appropriate level of corporate management as the recipient (s) of NRB audit reports.
Licensee. proposes that the audit reports be forwarded to Corporate Officer (s) responsible for the areas audited rather than
.to the Pxecutive Vice President-Nuclear.
The Corporate Officer (s) have a closer proximity to the sources of problems and therefore can take prompt corrective actions.
This proposed change will not lessen the awareness of the Executive Vice President-Nuclear.
If l'
NRB audit findings are not satisfactorily addressed by the Corporate Officer (s), the NRB may inform the Executive Vice President-Nuclear through its normal cominunication channel as defined in Technical Specification 6.5.2.9. _ _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _
Docket Nos. 50-277.
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50-278 License Nos. DPR-44 DPR-56 Significant. Hazards Consideration - Category.'B' An example (Example i) provided by the Commission of a change involving no significant hazards consideration, as stated in 51 FR 7751 is " purely administrative change to the Technical fuecifications".
The Change Requests contained in Category
'C' conform to this example and do not constitute a significant hazards consideration in that:
(1)
The proposed Category
'B' miscellaneous changes do not i
involve a significant increase in the probability or consequences of an accident previously evaluated.
Replacing the Technical Engineer with the Engineer-Systems on the PORC will not decrease the effectiveness of the PORC.
As required by proposed specification 6.2.2.g, either the Superintendent-Technical or the Engineer-Systems will hold a Senior Reactor Operator license, thereby ensuring the level of plant operations expertise of the PORC.
Sufficient corporate management involvement in nuclear plant safety will be maintained with the elimination of the direct reporting requirement of the NRB to the Office of the Chief Executive.
The Office of the Chief Executive will be made aware of - _ _ _ _ _ _ ___________________ - _ -
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56
.NRB activities by the Nuclear Committee ci the Board through the Board of Directors and by the Exectati ve Vice President-Nuclear.
Designating Corporate Officer (s) responsible for the areas audited instead of the Executive Vice President-Nuclear as the recipient (s) of NRD audit reports is a more appropriate initial level of review.
The Corporate Officers have a closer proximity to the sources of problems and therefore can take prompt corrective i
actions.
If NRB audit findings are not satisfactorily addressed by the Corporate Officer (s), the NRB may inform the Executive Vice President-Nuclear through its normal communication channel as defined in Specification 6.5.2.9.
Section 14 oi the PBAPS UPSAR 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 UPSAR are not affected by the proposed miscellaneous changes.
For this reason, as well as the reasons presented above, it is concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 (2)
The proposed Category
'B' miscellaneous changes do not create the possibility of a new or different kind of accident from any previously evaluated.
The implementation of these miscellane
.s changes will not affect the interpretation or intent of the specifications they involve (6.5.1.2, 6.5.2.9 and 6.5.2.10.c).
These changes are purely administrative and do not involve any hardware changes or plant modifications.
Therefore, these changes will not create the possibility of a new or different kind of accident from any previously evaluated.
(3)
The proposed Category
'B' miscellaneous changes do not involve a significant reduction in a margin of safety.
I The administrative nature of these changes will not impact plant systems or operation.
For this reason, as well as the reasons presented in the Safety Assessment and in response to item 1 above, it is concluded that these changes will not involve any reduction in a margin of safety.
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Es T ', y Docket Nos.-50-277 L,
50-278 o
i License Nos.'DPR-44
, e DPR-56 Environmental Impact' Assessment f
An environmental impact assessacnt is not required for the changes' proposed by this Application because the changes conform to
- the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).
The proposed changes do not involve ~any systems that have a direct relationship with the environment.
The Application involves removing the organization
-chartsifrom the Technical Specifications and miscellaneous administrative changes.- The Application involves no significant
' hazards consideration as demonstrated in the preceding section.
The Application involves no-significant change in the types or significant increase in the amounts of any effluents that may be Teleased'offsite and there will be no significant increase in individual or cumulative occupational radiation exposure.
Conclusion 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 and will not endanger the health and safety of the public.
List of Propo7sd Chinges Section Affected Proposed Changes Page iv (Unit 3)
Designate Figures 6.2-1 and 6.2-2 as deleted.
Page iva (Unit 2)
Page vi Relocate designation of Table 4.8.3.c from pages via and vii to page vi.
Add Table 6.2.1 to list.
Page via Insert "This page intentionally left b]snk" since l
all entries are on page vi.
{
.Page vii Insert "This page intentionally left blank" since all entries are on page vi.
Page 243 Paragraph 6.1.2 Add designation of Shift Supervisor as having control room command.
Paragraph 6.2.1 Change title "Offsite" to "Offsite and Onsite Organizations".
Delete existing paragraph 6.2.1 and i
add specifications 6.2.1.a through 6.2.1.d as recommended in GL 88-06.
1 Page 244 Delete Figure 6.2-1, Paragraph 6.2.2 Replace "as shown on Figure 6.2-2 and:"
with " subject to the following:".
Paragraph 6.2.2.a Replace reference to Figure 6.2-2 with a reference to Table 6.2.1.
Paragraph 6.2.2.g Add license requirements of station managers as required by GL 88-06.
Page 245 Delete Figure 6.2-2 Sheet 1
)
and add Table 6.2.1.
I Page 245a Delete Figure 6.2-2 Sheet 2 1
j Page 246 Replace the Technical Engineer Paragraph 6.5.1.2 with the Engineer-Systems as a PORC member.
Page 252 Remove the " Office of the Chief Paragraph 6.5.2.9 Executive".
Page 2$2a Replace the " Executive Vice President-Paragraph 6.5.2.10.c Nuclear" with " Corporate Officer (s)".