ML20247D920

Proposed Tech Specs Removing Nuclear Power Group Organizational Charts

ML20247D920
Person / Time
Site:	Cooper
Issue date:	03/20/1989
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20247D918	List: ML20247D920 NLS89000036, Application for Amend to License DPR-46,revising Tech Specs to Remove Organizational Charts Per Recommendations of Generic Ltr 88-06
References
GL-88-06, GL-88-6, NUDOCS 8903310252
Download: ML20247D920 (9)

Text

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" ** - Attachment to NLS8900036 Page l'.of 7L REVISED TECHNICAL SPECIFICATIONS s

TO REMOVE NUCLEAR POWER GROUP ORGANIZATIONAL CHARTS l nL Revised Pages n

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219a 236 (deleted) 237.(deleted)-

I. INTRODUCTION On. March 22, 1988, the Nuclear Regulatory Commission (NRC) issued.

Generic Letter 88-06, " Removal of Organization Charts from Technical Specification Administrative Control Requirements." . Generic'-

Letter 88-06 recommended licensees. remove. onsite- and offsite organizational charts from their Technical Specifications: to eliminate the procedural' requirement that Technical Specifications mus t . be changed prior to instituting a corresponding nuclear'.

organization change.

Generic Letter '88-06 indicated that with appropriate changes, the.

Technical Specifications would address "the essential aspects of the organizational structure that are defined by existing onsite.and offsite organization charts." This change would obviate the.need for regulating'the organization chart itself through the Technical Specifications.

LGeneric Letter 88-06 provides guidance concerning the changes necessary to capture the essential, aspects of the onsite and offsite organization charts. Generic Letter 88-06 recommends the following items be added to the Technical Specifications to compensate for the removal.of the organizational charts:

1. Requirement to establish and control lines of authority, responsibility, and communication in other company documents

2. Requirement to designate an onsito position as responsible for overall safe operation and maintenance of the plant

3. Requirement to designate an executive position as having corporate responsibility for overall nuclear safety, and authority to take measures necessary to ensure acceptable performance of staff in maintaining plant safety

4. Requirement to designate those positions in the onsite organization requiring Senior Reactor Operator (SRO) and Reactor Operator (RO) licenses I

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5. Requirement _ to establish provisions to ensure that Quality Assurance, Health Physics, and Training Staff have sufficient organizational freedom and' freedom from operational pressures to effectively accomplish ~their organizational objectives The District agrees that addition of the first four recommended changes are appropriate and necessary to capture the essential  ;

aspects of the onsite and offsite organizational charts currently  ;

in the CNS Technical Specifications. However, it is the District's view that the organizational elements described in Item 5 above are already addressed in other appropriate programs and controlled in corresponding documents, and that the addition of this requirement would not reflect any organizational aspect currently defined by the organizational charts.in the CNS Technical Specifications.

The following section, " Description of Changes" identifies the specific changes proposed to the CNS Technical Specifications in accordance with the guidance provided by Generic Letter.88-06, and q provides the basis for why the need for incorporating the final recommendation provided in Generic Letter 88-06 (Item 5 above) is obviated as applied to the CNS Technical Specifications and existing District programs.

II. DESCRIPTION OF CHANGES  !

i In accordance with the guidance provided by Generic Letter 88-06, the District proposes changing current Section 6.1.2, "Offsite" to new Section 6.1.2, "Offsite and Onsite Organizations," r.nd adding the following preface:

"Onsite and offsite organizations shall be established for unit ,

operation and corporate management, respectively. The onsite 1 and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant."

Generic Letter 88-06 also specifies that concurrent with the removal of the organizational charts from the licensee's Technical Specifications, the following general requirements should be added:

1. Lines of authority, responsibility, and communication shall be established and defined from the highest management 1evels through intermediate levels to and including all operating organization positions. Those relationships shall 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 forms of documentation.

3 This will be met through the addition of new Section 6.1.2.A to the CNS Technical Specifications. The District has reviewed and approved a change to the CNS Updated Safety Analysis Report (USAR) which upgrades the operating organization

Attachment to NLS8900036 Page 3 of 7 1

description by : incorporating the Nuclear Power Group (NPG) onsite and offsite organizational charts and departmental descriptions of responsibilities. The affected USAR pages reflecting this change were submitted . to the NRC by letter dated January 13, 1989. This change will be reflected in the next annual 10 CFR 50.71(e) USAR revision due to be submitted on or before July 22, 1989.

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2. - Designation of a management position in the onsite organization that is responsible for overall unit operation and has control over those onsite activities necessary for safe operation and maintenance of the plant.

This will be met through the addition of new Section 6.1.2.B to the CNS Technical Specifications. Section 6.1.2.B will designate the Division Manager of Nuclear Operations as responsible for these activities.

3. Designation of an executive position that has corporate responsibility for overall plant nuclear safety and authority to take such measures as may be needed to ensure acceptable performance of staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

This will be met through the addition of new Section 6.1.2.C to the CNS Technical Specifications. Section 6.1.2.C will designate the Nuclear Power Group Manager as responsible for these activities.

4. Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license. l This will be met through the addition of new Section 6.1.3.H to- the CNS Technical Specifications. The Operations Supervisor, Shif t Supervisor, and Control Room Supervisor shall hold SRO licenses while Unit Operators shall hold RO licenses.

With the inclusion of the above changes, Figure 6.1.1, "NPPD Nuclear Power Group Organization Chart" (page 236) and Figure 6.1.2, "NPPD Cooper Nuclear Station Organization Chart" (page 237), and references l thereto are deleted.

Generic Letter 88-06 also recommends that the following requirement l be added to the licensee's Technical Specifications to compensate for the removal of the organizational charts. j

" Provisions of sufficient organizational freedom to be independent of operational pressures to those individuals who perform the functions of health physics, quality assurance, and training of the operating staff."

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It isLthe' District's' view that theJabove need not be incorporated ,

into the CNS Technical Specifications becaus'e:

'o. Provisions of organizational-freedom are assured by -means .of

.the. District's Quality Assurance Program for Operation,(and-L controlled by means, of the CNS Quality . Assurance Program for l . Operation Policy  ; Document .in accordance. with-

10 CFR' 50.54.(a)(3),-

'o The " provisions of organizational freedom" referred to are not

. currently reflected in'the organizational charts in the CNS Technical Specifications, and therefore, . the addition of thisi

' requirement is not necessary to maintain an essential aspect' of.the organizational charts currently in the CNS Technical

> - . Specifications.

The . CNS : Quality Assurance Program .for Operation Policy Document '

(Appendix:D of the Updated Safety Analysis Report). states, in the Corporate Policy statement:

" Dis'trict personnel shall have the organizational! freedom to identify concerns and propose corrective and preventive action .

necessary to enhance the District's nuclear program."

This policy' pertains to, among others, Training, Health Physics, and Quality Assurance ' personnel, and is- assured through the

-implementation of the QA Instructions and Plans.

'The QA Policy. Document, in Section 3.2.3 states further:

"The Division Manager of Quality Assurance and Staff shall have-the necessary organizational- freedom and access- within Columbus G.O. and Cooper . Nuclear Station' to institute the

-necessary. Quality Assurance requirements, identify problems, and pursue prompt corrective action.... . In addition, the' Division Manager of Quality Assurance shall have a direct line of communication with the President and C.E.O."-

.Through the institution and maintenance of these policies, the

-District's Quality Assurance, Health Physics and Training Staff is assured the organizational freedom and independence from operating pressures to ensure effectiveness of their respective programs.

Through the QA Program revision control process conducted in .

accordance with the requirements of 10 CFR 50.54(a)(3), NRC cognizance of the status of the District's QA Program is maintained.

Therefore, provisions for the independence and freedom from operational pressures are adequately provided and maintained for its Nuclear Staff through existing means.

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JAttachmsnt to NLS8900036" Page 5 of 7L Generic Letter 88-06 also' states:

";..'with appropriate changes to these-administrative control requirements, the onsite and'offsite organizational charts may-be removed. The . changes invol'e . the addition of . general requirements. that- capture 'the essential. aspects; of the organizational structure that are defined by existing onsite and offsite organizational. charts."

The existing onsite . and offsite organizational charts in the CNS:

Technical Specifications do not now define' ' the . " organizational

' freedom to,betindependent'of operational pressures" for the Health Physics, QA, and Training Staff.1 Therefore, this requirement would.

be an extraneous addition to the Technical Specifications in the case of CNS.

4 The District recognizes the importance 'of . assuring ~ that Health Physics,~ Quality Assurance, und Training activities are carried out in an uninhibited manner. The District maintains that 'these controls are already in place and are assured through the District's-existing -

Quality Assurance Program; therefore, it is the District's view that.

-these measures need not ' be replicated in the CNS Technical Specifications.

III. SIGNIFICANT HAZARDS DETERMINATION 10 CFR,50,91(a)(1) requires that . -licensee requests for operating-license amendments be accompanied by.an evaluation of'significant hazards. posed by the issuance of the amendment. This evaluation is to be performed. witl- respect to the criteria' given in

~ 10 CFR 50.92(c). The following analysis meets'these requirements.

- A '. Evaluation of this Amendment with Respect to-10.CFR 50.92 The enclosed Technical Specification - change is judged to -

involve no significant hazart.s based on the following:

'1. Does the proposed change ircre,1ve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation:

This propot.ed change does not involve a significant increase in the probability or consequences of an I

By letter dated January 13, 1989, the District submitted an approved update to the CNS USAR to incorporate the onsite and offsite organizational charts and upgrade the organizational description. These charts clearly show the line of communication from the Division Manager of Quality Assurance to the President and C.E.O.

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, Attachmsnt to NLS8900036 Page 6 of 7 accident previously evaluated because the change is administrative in nature. Removal of the organizational charts from the CNS Technical Specifications represents a change only in the administrative control of revisions to the District's nuclear organization. As described in Section II, " Description of Changes" above,'several key organizational elements have been added to the CNS Technical Specifications. These organizational requirements have been developed in accordance with the guidance provided by Generic Letter 88-06 and capture the essential aspects of the Nuclear Power Group organization. These include the addition of Sections 6.1.2.3 and 6.1.2.0 which identify the positions responsible for overall plant safety in the Onsite and Offsite organizations respectively.

This proposed change does not effect any revision to the current nuclear organization or the plant configuration.

No changes to the Shift Complement qualifications or personnel requirements have been proposed. Further, removal of the organizational charts does not represent a' physical change to the plant, a change to any plant procedure, the institution of any test or experiment, a ' change in any safety analysis, or a change in organizational conduct of operations. This proposed change, therefore, does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?

Evaluation:

This change is administrative in nature and therefore, does not create the possibility for a new or different kind of accident from any previously evaluated. The District is not proposing any procedural, hardware, or organizational changes with this submittal. The organizational functions important to safety will continue to be accomplished through the employment of persons competent in the appropriate areas of expertise.

3. Does the proposed amendment involve a significant reduction in the margin of safety?

Evaluation:

This proposed change does not represent any changes in plant procedure or hardware. Since this change is ]

administrative in nature, the margin of safety will not (

be reduced. This change has the overall effect of f increasing organizational efficiency by facilitating 1

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.Page 7 of.7 organizational adaptation to changing operational needs.

The provisions being added to Section 6.1 of the CNS Technical Specifications will assure the essential i aspects of the operating organization will remain intact.

L Additionally, any subsequent organizational changes will constitute changes to the CNS USAR and therefore require evaluation in accordance with 10 CFR 50.59.

B. Additional Basis for Proposed No Significant Hazards Determination The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by- providing certain examples (48 CFR 14870). The examples include: "(i) A purely-administrative change...." The District feels that this i proposed change falls under this example. Additionally, Generic Letter 88-06 sets forth the NRC's position that with the addition of certain administrative requirements which

".... capture the essential aspects of the. ~ organizational

- structure...." the onsite and offsite organizational charts may be removed. Therefore, the District finds - that the attached. proposed change to tl)e CNS Technical Specifi~ cations involves no significant hazards and .should be approved by the NRC.

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6. ADMINISTRATIVE CONTP,0LS l 6.1 ORGANIZATION 6.1.1 Responsibility The Division Manager of Nuclear Operations shall have the over-all fulltime onsite responsibility for the safe operation of the Cooper Nuclear Station.

During periods when the Division Manager of Nuclear Operations is unavailable, he may delegate his . responsibility to one of tha managers in the Nuclear

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Operations Division.

6.1.2- Offsite and Onsite Organizations 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 from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall 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 forms of documentation.

These requirements shall be documented in the USAR.

B. The Division Manager of Nuclear Operations 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 Nuclear Power Group Manager shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable perfor.aance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

6.1.3- Plant Staff - Shift Comolement l

The shift complement at the station shall at all times meet the following <

requirements. Note: Higher grade licensed operators may take the place of '

lower grade licensed or unlicensed operators.

A. A licensed senior reactor operator (SRO) shall be present at the station at all times when there is any fuel in the reactor, i B. A licensed reactor operator shall be in the control room at all times i when there is any fuel in the reactor.

C. Two licensed reactor operators shall be in the control room during all .

startup, shutdown and other periods involving significant planned control '

rod manipulations. A licensed SRO shall either be in the Control Room or immediately available to the Control Room during such periods. '

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L.. D. ' A licensed senior reactor operator (SRO) with no other concurrent duties

'{ shall be directly in charge of any-refueling operation, or alteration 3

of the reactor core.

A licensed reactor operator (RO) with no other concurrent duties shall i be .directly in charge of operations involving .the handling of irradiated fuel other than refueling or reactor core alteration operations.

E. An . individual who has been trained and qualified in health physics techniques shall be on site at all times.that fuel is on site.

F. Minimum crew size during reactor operation shall consist of four licensed reactor operators (two of whom shall be licensed SRO) and ' three unlicensed operators. Minimum crew size during reactor cold shutdown conditions shall consist of two licensed reactor operators (one of whom shall be licensed SRO) and one unlicensed operator.

In the event .that any member of a minimum shift crew is absent or incapacitated due to illness or injury a qualified replacement shall be designated to report onsite within two hours.

G. A Fire Brigade of at least 5 members shall be maintained at all times.

This excludes the 3 members of the minimum shift crew necessary for safe shutdowns, and other personnel required for other essential functions during a fire emergency. Three fire Brigade members shall be from the Operations Department and 2 support members may be from other departments i I

inclusive of Security personnel.

1 Fire Brir,ade composition may be less than the minimum requirements for ,

a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected l absence of Fire Brigade members provided immediate action is taken to restore the Fire Brigade to within the minimum requirements.

i H. The Operations Supervisor, Shift Supervisor and Control Room Supervisor shall hold a senior reactor operator license. The Unit Operators shall hold, at a minimum, a reactor operator license.

1 6.1.4 Plant Staff - Qualifications

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i The minimum qualifications, training, replacement training, and retraininh .

'of plant personnel at the time of fuel loading or appointment to the active position shall meet the requirements as described in the American National  !

Standards Institute N-18.1- 1971, " Selection and Training of Personnel for j Nuclear Power Plants" . The Chemistry and Health Physics Supervisor shall meet  ;

or exceed the qualifications of Regulatory Guide 1.8, Sept. 1975; personnel  ;

qualification equivalency as stated in the Regulatory Guide may be proposed in selected cases. The minimum frequency of the retraining program shall be every two years. The training program shall be under the direction of the Training Manager.  !

i A. A training program for the fire brigade will be maintained under the i direction of the Training Manager and shall meet or exceed the j requirements of Section 27 of the NFPA Code 1976, except for Fire Brigade i training sessions which shall be held at least quarterly.

f The training program requirements will be provided by a qualified fire protection engineer.  ;

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