ML20247L549

Safety Evaluation Supporting Amend 68 to License DPR-22

ML20247L549
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Site:	Monticello
Issue date:	07/14/1989
From:	Office of Nuclear Reactor Regulation
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NUDOCS 8908010279
Download: ML20247L549 (6)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR P,EACTOR REGULATION RELATED TO AMENDMENT NO. 68 TO FACILITY OPERATING LICENSE NO. OPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By letter dated August 14, 1987, as supplemented and/or revised by letters dated January 4, February 10, and August 31, 1988, Northern States Power Company (NSP or the licensee) submitted a request to amend Section 6 of the Plant Technical Specifications (TSs) to delete the requirement for plant management and support staff, not assigned to an operations shift, to hold a Senior Reactor Operator (SRO) license. The August 31, 1988 letter superseded all prior submittals to modify the figures in Section 6 of the TSs, requesting instead that those figures, which depict corporate and plant organizational charts, be entirely removed from the TSs.

In lieu thereof, the licensee specified ceneral requirements that capture the essential aspects of the organizational structure depicted in the deleted figures in accordanca with the guidance provided in NRC Generic Letter 88-06, dated March 22, 1988, entitled " Removal of Organization

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Charts from Technical Specification Administrative Control Requirements." Part I of this Safety Evaluation presents our evaluation of the proposed change to relax the requirements for SR0 licenses. Part II of this Safety Evaluation addresses the proposed deletion of corporate and plant organizational charts from the TSs.

2.0 DISCUSSION AND EVALUATION 2.1 Part 1 - Delete Requirements for Plant Management / Support Staff to Hold a Current SRO License The TS changes proposed would add new Specifications 6.1.C.7 and 6.1.C.8 and revise Specification 6.1.0 to:

(a) delete the Licensed Senior Operator (LS0) requirement for the General Superintendent of Engineering and Radiation Protection.

(b) change the LSO requirement to a formerly Licensed Senior Operator requirement for the General Superintendent of Operation and add the following new subitem to Specification 6.1.D:

"...and (3) the General Superintendent of Operations who shall meet the requirements of ANSI N18.1-1971, except that NRC license requirements are as specified in Specification 6.1.C.7."

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. (c) add the requirement for at least one member of plant management holding a current SRO license to be assigned to the plant operations group on a long-term basis, and that individual will not be assigned to a rotating operations shift (long-term basis being at least two years).

(d) revise Specification 6.5.G to read:

" Temporary changes to those procedures which are required to be reviewed by the Operations Committee described in A, B, C, D, E and F wove, which do not change the intent of the original procedures, may be made with the concurrence of two members of the unit management staff, at least one of whom holds a Senior Reactor Operator license."

(Underscore is the proposed change).

New Specification 6.1.C.7 states that:

"The General Superintendent, Operations shall be formerly licensed as a Senior Reactor Operator or hold a current Senior Reactor Operator License."

New Specifications 6.1..C.8 states that:

"At least one member of plant management holding a current Senior Reactor Operator License shall be assi operations group an a lang term basis (approximately two years)gned to the plant This individual will not be assigned to a rotating shift."

With respect to changea (a) and (b), we do not require the individual filling the position of General Superintendent of Engineering and Radiation Protection to hold a SRO license. As for the General Superintendent Plant Operation, the latest revision of ANSI /ANS-3.8 (1987), which we endorse, does not require that the plant operations manager hold a current SR0 license, provided that such a license is held by an operations middle manager. Since the licensee's proposed change will require that at least one individual in the plant operations group hold a SR0 license, we find the proposed change to be consistent with ANSI /

ANS-3.1 (1987) and is therefore acceptable.

Changes (c) and (d) are also considered acceptable in that they are consistent with the requiremen's set forth in the Standard Technical Specifications, NUREG-0123.

2.2 PART II - Remove Figures Depicting Corporate And Plant Organization Charts From The T55 The licensee's August 31, 1988 application also contained a proposal to remove figures depicting corporate and plant organization charts from Section 6 of the TSs in conformance with the example set forth in Enclosure 2 of Generic Letter (G'.) 88-06.

Sectior 6 of the TSs specifies those administrative controls necessary to assure safe operation of the facility. We find that the general requirements proposed by the licensee for replacing the organization charts are justified because they are administrative in nature and consistent with the guidelines provided by the NRC in GL 88-06.

Rsculatory Requirements Applicable To Organizational Structure 10 CFR 50.36 " Technical Specifi:ations," which implements Section 182a of the Atomic Energy Act, was promulgated by the Commission on December 17, 1968 (33

. FR 18612). This rule delineates requirements for determining the contents of the TSs. The TSs set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public. Specifically, 10 CFR 50.36 requires that:

Each license authorizing operation of a production or utilization facility of a type described in 650.21 or 650.22 will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to $50.34. The Commission may include such add?tional technical specifications as the Comission finds appropriate.

The regulation further states that the TSs will include, among other things, items in the following category:

(5) Administrative controls. Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of he facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in 550.4.

Past Practice i

Review of the organization, personnel qualifications, education, experience, training, and their overall capacity to operate a plant safely has always been of concern to the NRC, and its predecessor, the AEC. Before a plant is licensed to operate, a finding is made that the applicant's staff is capable of operating the plant safely.

In the past, the organization charts were included in the TSs so that the changes made after operation began would require prior NRC approval. This was done to preserve certain specific features of the licensed organization.

While the regulation does not specifically require that the TSs contain organization charts, the practice of including organization charts in the TSs began in the late 1960s. These charts were used as an aid in depicting the organizational and management relationships thought to be needed to meet the provisions of 10 CFR 50.36(c)(5). The practice of including organization charts in the TSs has continued since.

Organization charts do depict tne reporting chain for some organizational functions that must be independent of scheduling and operating pressures.

Until 10 CFR Part 50, Appendix B. " Quality Assurance Criteria for Nuclear l

Power Plants and Fuel Reprocessing Plants," was adopted in 1970, organization i

charts were partially relied on by the NRC staff for assuring this function.

As stated in 10 CFR 50, Appendix B, Criterion I, " Organization":

Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organ <zational freedom, including sufficient independence from cost and schecule when opposed to safety considerations, are provided.

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_4 10 CFR 50, Appendix B, further acknowledges that the organizational structures may take many forms, but emphasizes that regardless of structure, the individuals assigned the responsibility for execution of any portion of the t

program shall have access to Such levels of management as may be necessary to perform this function. The licensee's required QA Program specifies and depicts these organizational relationships in greater detail than currently exists in the TSs.

The practice of including organization charts in the TSs was established before

- the advent of 10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants,and Fuel Processing Plants," and other associated guidance documents, such as Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" and NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants - LWR Edition." A general description of the features needed by the staff to make the findings that the applicant is capable of operating the plant safely is not mandated by 10 CFR Part 50, Appendix B.

Safety Considerations The fundamental safety issue in the proposal to delete organization charts form the TSs is whether there can be reasonable assurance that the organization will operate the plant safely and remain effective without requiring prior staff approval for changes reflected in organization charts.

It has been the staff's experience that organization charts by themselves have been little help to reviewers in assessing the safety significance of changes to the plant and licensee. Nevertheless, because the charts are in the TSs, license amendment requests have been required to effect organizational changes as simple as combining some minor functions under one organization element shown on the chart.

The usefulness of the charts to the staff in the recent years has been minimal and the safety relevance of the charts themselves is small.

Specific operational requirements that bear more directly on the safety matter of concern to the staff than the organization charts are required elsewhere in TSs.

For examplo, the organizational element responsible for the control room ccomand function is identified separately in the TSs, as are the requirements for minimum staffing under various operating modes. The organizational management functions for independent reviews and audits, unit review group and i

independent safety engineering groups, and shift technical advisor are also specified in other TSs. Thus, the organization charts themselves are not needed to support the staff's finding that the organization will operate the plant l

safely.

In sumary, the specific details of the operating organization are not essential to the safe operaticn of the facility, and the staff concludes that the details i

I can be modified in many ways while maintaining adequate operational safety.

Over the years of experience with the details of operating organizations, the NRC staff has been able to identify those organizational characteristics which are important to assure plant safety.

The important features of a licensee's organization (currently depicted on the TS organization charts, but not already included in other TSs) necessary for

, 5-the stafi to find that the organization will operate the plant safely are stated below.

a.

Lines of authority, responsibility and cocanications shall be established and defined from the highest managtment levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships and job descriptions for key personnel positions, or in equivalent forms of documentation. These organizational relationships will be maintained in a document such as the Updated Safety Analysis Report or QA Manual.

b.

There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant so that cer.tinued nuclear safety is assured.

c.

There shall be an individual management position in the onsite organization h5ving responsibilities for overall unit safe operation which shall have control over those onsite resources necessary for safe operation and maintenance of the plant.

d.

Although the individuals who train the operating staff and those who carry out the health physics and quality assurance functions tray report to the appropriate manager on site, they shall have sufficient organizational freedom to be independent from operating prc:sures.

e.

Senior Reactor Operator (SRO) and Reactor Operator (RO) licenses shall centinue to be required for the positions so indicated on the current TS organization charts.

f.

Other TSs which reference the current organization charts shall be revised to reference the appropriate functional responsibility or position.

The proposed changes incorporate these featt Ns to replace the organization charts being deleted. 1he licensee has proposed to include the infor1 nation in iten a above in the next update of the Monticello Safety Analysis Report.

Therefore, we conclude that the removal of the organization charts from the TSs will not prevent the licensee from meeting the standards of 10 CFR 50.36

&nd the underlying statutory requirements and is therefore acceptable. Moreover, the deletion of unnecessary detail of organization charts will save resources for both the NRC and the licensee and will allow the NRC staff to focus on issues of importance to the plant's safety.

3.0 ENVIRONMENTAL CONSIDERATION

The amendment involves a change to recordkeeping, reporting or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental l

l assessment need be prepared in connection with the issuance of this l

amendment.

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, 4.0' CONCLUSION On the basis of the. considerations discussed above, we conclude that (1) there

'is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with ther Comission's regulations, and (3) the. issuance of. this amendment will not be inimical to the comon defense and security or to

' the health and safety of the public.

Principal Contributor:

F. R. Allenspach, NRR J. J. Stefano, NRR i

Dated: July 14,1989 l

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