NLS89000189, Revised Proposed Change 45 to Tech Specs,Removing Organizational Charts Per Generic Ltr 88-06

Revised Proposed Change 45 to Tech Specs,Removing Organizational Charts Per Generic Ltr 88-06

ML20244B255
Person / Time
Site:	Cooper
Issue date:	06/06/1989
From:	Kuncl L NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20244B258	List: ML20244B265 NLS89000189, Revised Proposed Change 45 to Tech Specs,Removing Organizational Charts Per Generic Ltr 88-06
References
GL-88-06, GL-88-6, NLS89000189, NUDOCS 8906130045
Download: ML20244B255 (8)

Text

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. GENERAL OFFICE t

- Nebraska Public Power District " ' " "%EAfo"u"E M's^M^ """*"

w NLS89000189

. June 6, 1989 U.S. Nuclear Regulatory Commission

' Document Control. Desk Washington,LD.C. 20555 Gentlemen:

Subject:

Revision to. Proposed Change .No. 45 to Technical Specifications Removal of-Organization Charts Cooper Nuclear Station NRC Docket No. 50-298, DPR-46

Reference:

Letter from L. G. Kuncl (NPPD) to USNRC dated March 20, 1989, " Proposed-Change No. 45 to Technical' Specifications, Removal of Organization' Charts, Cooper Nuclear Station By letter dated March 20, 1989 (Reference) , . the Nebraska Public Power District (District) submitted to the NRC Proposed Change i

No. 45 to the Cooper Nuclear Station (CNS) Technical Specifications. Proposed Change No. 45 requested' removal-of the organizational charts in accordance with the guidance'of Gi.neric Letter 68-06. The District requests a revision to that prop 3 sal to more closely follow the guidance provided in Generic Letter'88-06.

The Attachment contains a description of the' proposed ebanges and this revision to our original submittal, the attendant 10- CFR 50.92 evaluation, and the Technical Specification pages revised by the removal of the organizational charts. This proposed change has-been reviewed by ' the necessary Safety Review Committees and incorporates all amendments to the CNS Facility Operating' License through Amendment 128 issued February 21,- 1989.

In addition to the signed original,.37 copies are also submitted for your use. . By copy of this letter and attachment the appropriate . State of Nebraska official is being notified in accordance with 10 CFR 50.91(b) (l') ._ Copies to the NRC Region IV

, Office and the CNS Resident Inspector are ' also being sent" in accordance with 10 CFR 50.4 (b) (2) .

gDR90613OO45 890606 b 1' p ADOCK 05000298 i PDC I L _ _ _-_ -_ _ -

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June 6, 1989 Should you have any questions or require' additional information, please contact me.

,NV . (?

L. G. E nci Nuclear Power Group Manager LGK/mjb:dar15/1(CHNG45)

Attachment cc:- H. R. Borchert Department of Health State of Nebraska NRC Regional. Office Region IV Arlington, TX NRC Resident Inspector Office Cooper Nuclear Station i

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June 6, 1989 i

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STATE OF N$'3RASKA )

)ss PLATTE COUNTY )

-i L. G. Kuncl, being first duly sworn, deposes cnd says'that he is )

an authr,rized representative of the Nebraska Public Power District, a publ!.c corporation and political subdivision of the State of Nebras'ca; that he is duly authorized to submit this request on beha32 of Nebraska Public Power District; and that the statements )

containad herein are true to the best of his knowledge and belief.  !

L. G.IKuncl 4 I 1

SubscribeA in my presence and sworn to before me-this [ h, day l of ( //Jnt0_ , 1989. -j i

COLLEEN M. KUTA NOTARY /'PUBKIC Ny Cast EE 454,1W i

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, Attachment to NLS89000189 Page 1~of'5' REVISED TECHNICAL' SPECIFICATIONS 4'

, TO REMOVE NUCLEAR POWER GROUP ORGANIZATIONAL CHARTS 1

Revised Paces.

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.219- 1

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

I. INTRODUCTION On March. 22,'1988, the Nucle'ar - Regulatory Commission' (NRC) issued..

Generic Letter 88-06 ." Removal of Organization Charts from Technical Specification Administrative Control Requirements.". LGeneric' Letter 88-06 recommended licensees remove onsite and -offsite organizational charts from their : .. Technical- Specifications to . .!

eliminate 7the procedural requirement to revise the' Technical; -j Specifications prior- to instituting a corresponding nuclear. -4 organization change.

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

Technical Specifications would address athe 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.

Generic Letter 88-06 provides guidance concerning. the changes necessary to capture the essential aspects of the.onsite and offsite-organization charts. This guidanceirecommends~the following items 1 be added to the - Technical Specifications c 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 onsite' position as res'ponsible for:

overall safe operation and maintenance of'the plant' 1

3. Requirement. to designate an ' executive 1 position as . having corporate . responsibility for overall . nucle'ar tsafety. andJ

. 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 g, -

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Attachment to NLS89000189

." Page 2 of 5

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's original submittal of Proposed Change No. 45, dated March 20, 1989, set forth the. District's position that Item No. 5 above was already provided for in other company programs 'and documents, and did not need to be replicated in the CNS Technical Specifications. However, pursuant to discussions between the District and the NRC staff, rhe District has agreed to include these provisions 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.

II. DESCRIPTION OF CHANGES 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," and adding the following preface:

"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."

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

1. Lines of authority, responsibility, and communication shall-  ;

be established and defined from the highest management levels j through intermediate levels to and including all operating organization positions. Those relationships shall. be j documented and updated, as appropriate, in the form of j organization charts, functional descriptions of departmental 2 responsibilities and relationships, and job descriptions for 4 key personnel positions, or in equivalent forms of documentation.

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

! 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

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. Attachment to NLS89000189 Page 3 of 5 dated January 13, 1989. This change will bh reflected in the next annual 10 CFR 50.'71(e) USAR_ revision due to be submitted-on or before July 22, 1989.

.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 i to the CNS Technical Specifications. Section 6.1.2.C will designare the Nuclear Power Group Manager as responsible for l these activities.

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4. 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. 'j J

This will be met through the addition of new Section 6.1.2.D  !

to the CNS Technical Specifications which will incorporate the I above provisions. j 1

5. Designation of those positions in the onsite organization that .j 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, Shift Supervisor, and Control Room Supervisor shall hold SRO licenses while Unit Operators shall hold R0 licenses.

With the inclusion of the above changes, Figure 6.1.1, "NPPD Nuclear

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Power Group Organization Chert" (page 236).and Figure 6.1.2, "NPPD I Cooper Nuclear Station Organization Chart" (page 237), and references thereto are deleted.

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• ~ Attachment to NLS89000189 Page 4 of 5 llI. 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 with respect to the criteria given in 10 CFR 50.92(c). The following analysis meets these requirements.

A. Evaluation of this Ame.ndment with Respect to 10 CFR 50.92 The enclosed Technical Specification. change is judged to involve no significant hazards based on the.following:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation:

This proposed change does not involve a significant increase in the probability or consequences of an accicent 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.B and 6.1.2.C 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 l 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.

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< Attachment to NLS89000189 Page}5,of'5.

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 foria-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 fimportant to ' safety,'willD continue to be' accomplished through the employment of.

persons competent in th'e appropriate areas of expertise. ,

3.

Does the proposed amendment involve 'a significant

. reduction in the margin of safety?

EvaluatioD:

-This proposed' change does.not. represent any changes in-plant . procedure or; ha'rdware. Since this change : is -

administrative in nature, the margin of safety will not be reduced. This change f has the 'overall effect of increasing . organizational . efficiency by facilitating organizational adaptation to changing operational needs.

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

Additionally, any subsequent organizational changes will j 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 j 1

4 The Commission has provided guidance concerning the application :j of the standards for determining whether a significant hazards ,

consideration exists by. .providing certain examples I!

(48 CFR 14870). The examples include: "(i) A ' ' purely 1 administrative change...." The District = feels that this- .!

proposed change falls under this examplei Additionally,. j Generic Letter 68-06 sets forth the.NRC's position that withy ,l the addition of certain administrative requirements which ';

". . . . capture . the . nssential aspects of the organizational-  !

structure. . . ." the onsite and offsite organizational charts .

may be removed.

Therefore, the ' District - finds ' that the-

-l attached proposed change to the CNS Technical Specifications l involves no significant hazards and should be approved ~by the  !

NRC.  !

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