ML20195D375

Application for Amends to Licenses DPR-53 & DPR-69,removing Organization Charts from Tech Specs,Per Generic Ltr 88-06 & Clarifying Position Title Descriptions.Fee Paid

ML20195D375
Person / Time
Site:	Calvert Cliffs
Issue date:	06/13/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20195D380	List: ML20195D375 ML20195D388
References
GL-88-06, GL-88-6, NUDOCS 8806230105
Download: ML20195D375 (6)

Text

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D ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE MARYLAND 21203 JOSEPH A.TIERNAN vict PassiDENT NucttAm ENamGf June 13,1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Reauest for Amendment

REFERENCES:

(a) Letter from Mr. J. A. Tiernan (BG&E) to NRC Document Control Desk, dated March 15, 1988, same subject (b) Letter from Mr. F. J. Miraglia (NRC) to All Power Reactor Licensees and Applicants, dated March 22, 1988, "Removal of Organization Charts from Technical Specification Administrative Control Requirements (Generic Letter 88-06)"

Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating f License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos.1 & 2, respectively, with the submittal of the proposed changes to the Technical Specifications.

CIIANGE NO.1 (BG&E FCR 88-80)

Change pages 6-1, 6-6, 6-7, 6-8, 6-13, 6-14 and 6-22 of Unit I and Unit 2 Technical Specifications as shown on the marked-up pages attached to this transmittal.

[ Qq DISCUSSION Mao O

.o The proposed change will revise the title of the positions Marager-Nuclear Operations

$n and General Supervisor-Operations to be Manager-Calvert Cliffs Nuclear Power Plant and CO O General Supervisor-Nuclear Operations, respectively. This change is merely an admin-ny istrative change to the position titles and therefore, does not change the plant 38 organization or its present duties and responsibilities, op

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Document Control Desk June 13,1988 Page 2 ,

l The title of Manager-Nuclear Operations is being changed to clarify the responsi-bilities of the position. The position's function and requirements within the organization are not being changed as a result of this request. The title of General Supervisor-Nuclear Operations is being revised to reflect BG&E corporate policy.

Justification i

The proposed changes to the job titles will clarify the responsibilities and authority  !

of the positions within the Nuclear Energy Division. These changes do n21 revise or j alter the function or responsibilities, l

l i DETERMINATION OF SIGNIFICANT llAZARDS '

This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of i the facility in accordance with the proposed amendment would not: 1 l

(i) involve a significant increase in the probability or consequences l of an accident previously evaluated; or Justification:

No modification to the facility or our operational philosophy will be made by this proposed change. This change is administrative in nature, and therefore, does not affect those accidents evaluated in the Final Safety Analysis Report (FSAR),

(ii) create the possibility of a new or different type of accident from any accident previously evaluated; or

, Justification:

i No new or different kinds of accidentt from those previously evaluated in l the FSAR are created by this change. This change is administrative in nature, and therefore, does not create new or different conditions than those already evaluated by the FSAR.

(iii) involve a significant reduction in a margin of safety.

jsjtification:

The proposed change revises only the titles of the Manager-Nuclear

, Operations and General Supervisor-Operations, The responsibilities of these positions, as described by both the Technical Specifications and the

FSAR, will remain the same. The change does not affect the plant organiza-tion or its responsibilities as discussed in the FSAR. Therefore, safety is not effected.

_ _ , _ . - . _ _ _ - _ _ , _ _ , _ _ - . -- . - _ _ - - - - - . . = , , - . _ . - - . -

Document Control Desk June 13,1988 Page 3 CHANGE NO. 2 (BG&E FCR 88-80)

Change pages XV, 6-1, 6-2 and 6-3 of Unit I and Unit 2 Technical Specifications as shown on the marked-up pages attached to this transmittal.

DISCUSSION The proposed change removes the onsite and offsite organization charts from the l Technical Specifications. Additional general requirements that capture the essential l aspects of the organizational structure are added to the administrative controls. The I removal of the organization charts will provide greater flexibility for us to implement changes in both the onsite and offsite organizational structure. We believe this is consistent with Commission policy.

l l This change supplements CHANGE NO.1 in that we assume for purposes of argument that I the requested title changes have been approved. The marked-up pages are combined to l simplify the change and to reflect both requested changes.

This proposal also would delete the organization chart proposed in Reference (a), I CHANGE NO.1, but would not change the intent of that Request for Amendment. We still l desire to add the position of Assistant General Supervisor-Operations (AGS-0) to our l organization structure. In addition, we want to remove the senior reactor operator l l (SRO) license requirement for the General Supervisor-Operations and impose that l training requirement on the AGS-O instead. Those proposed changes are described in I

Reference (a) in detail. They are not reflected in this change because this request would exceed the limitations of Reference (b) which requires that any amendment request i must reflect the existing Technical Specifications. Therefore, this change supplements Reference (a).

JustificatiSn Many of the details shown on the onsite and offsite organization charts are not essential to the safe operation of the facility. However, to support removing the organization charts, we are proposing administrative controls under Section 6.2.1 on page 6-1 necessary to ensure the operation of the facility in a safe manner. This change is being submitted under the guidance of Reference (b). The organizational i characteristics described in Reference (b) which are important to safety have been included in our submittal. These are:

l (1) A requirement that lines of authority, responsibility, and communication i shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions.

l 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.

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. l Document Control Desk i June 13,1988 i Page 4 j (2) 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.

(3) 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.

(4) Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license.

(5) Provisions of sufficient organizatioaal 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.

These conditions are reflected in our proposed change.

The organizational information described in (1) above is incorporated in our FSAR. Tb FSAR currently contains organization chcrts to at least the level of detail as shown on those which we propose to remove from the Technical Specifications.

The qualifications (SRO or RO license) for the General Supervisor - Nuclear Operations, Shift Supervisor, Control Room Supervisor and Control Room Operator are designated by I organization charts in the FSAR. i l

We have examined our plant Technical Specifications for additional references to the i organization charts. No other references have been identified. l i

During our review of the organization charts, we discovered a discrepancy between tha l Technical Specifications and a chart in the FSAR. On the attached copy of page 6-3 the l discrepancy is circled. Apparently, during our last reorganization, we inadvertently indicated that Nuclear Security is responsible to the Manager - Calvert Cliffs Nuclear Power Plant. This is not true. The organization chart in our FSAR (Figure 12-3) is correct. By deleting the organization charts from the Technical Specifications, the problem will be corrected.

Other than the item discussed above, the charm in the FSAR and Technical Specifica-tions are consistent. In fact, Figure 12-2 of our FSAR shows greater detail than Figure 6.2- 1 of the Technical Specifications. There are no other inconsistencies.

We understand that this request will be reviewed and approved quickly as long as it conforms to the guidance in Reference (b). We believe our proposed amendment meets all of the Generic Letter's requirements.

Document Control Desk June 13,1988 Page 5 DETERMINATION OF SIGNIFICANT IIAZARDS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerati . ens, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated; or Justification:

No modification to the facility or our operational philosophy will be made by this proposed change. This change is administrative in nature, and therefore, does not affect those accidents evaluated in the Updated FSAR.

(ii) create the possibility of a new or different type of accident from any accident previously evaluqted; or Justification:

No new or different types of accidents from those previously evaluated in the FSAR are created by this change. Removing the organization charts from the Technical Specifications and relying on those in the FSAR still ensures appropriate controls on changes to the organization will exist due to comr.1itments referenced in the FS A R, and the 10 CFR 50.54 and 50.59 requirements.

(iii) involve a significant reduction in a margin of safety.

Justification:

This proposed change does not involve any reduction in the margin of safety. Administrative controls relating to organization and management necessary to ensure operation of the facility in a safe manner will be maintained as described in the FSAR. We are proposing a change which would ensure adequate controls over changes to the BG&E organization structure through the normal FSAR revision process, and the requirements of 10 CFR 50.54 and 50.59.

T5AR UPDATE We are currently planning a site reorganization to take effect on September 1, 1988.

As requested by members of your staff, we will perform a safety analysis for the change ,

in accordance with 10 CFR 50.59 on or before that date. This safety analysis will l include an organization chart representing the new organization in detail equivalent to '

l Figure 6.2- 2 of our current Technical Specifications. This chart will not represent or describe any organizations below the section level.

We request that the requirement for functional and job descriptions be deferred until 90 days after the reorganization takes place. This will allow our company sufficient l time to make the necessary changes and updates. l

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j Document Control Desk June 13,1988 Page 6 l

l SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Off-Site Safety Review Committees, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.

FEE DETERMINATION Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1916898 in the amount of

$150.00 to the NRC to cover the application fee for this request.

Very truly ours, akau-STATE OF MARYLAND :

TO WIT:

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I hereby c rtify that on the /.3 t/t day of b/Lc i .19 38, before me, the subscriber, a Notary Public of the State of Mar nd in and for & M7m W (8/ : u.4 k

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, personally appeared Joseph . Tiernan, being duly sworn,vand states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

WITNESS my Hand and Notarial Seal:

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My Commission Expires: /t.Iu /. /h9d  ;

(/ g D(te JAT/SRC/dtm Attachments j cc: D. A. Brune, Esquire i J. E. Silberg, Esquire 3

R. A.Capra, NRC 1

S. A. McNeil, NRC W. T. Russell, NRC D. C.Trimble, NRC T. Magette, D' '