ML20154D476

Application for Amend to License DPR-6,proposing Removal of Organization Charts from Tech Specs & Informing NRC of Onsite Organizational Changes.Fee Paid

ML20154D476
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/08/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154D479	List: ML20154D476 ML20154D482
References
GL-88-06, GL-88-6, NUDOCS 8809150290
Download: ML20154D476 (6)

Text

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'e Consumers Power Kenneth W Berry m Dsrector hwerer Lkembeg General Offtes 1H6 West Pernell Roed. Jecison, MI 49201 e (517) 7861636 September 8, 1988 Nuclear Regulatory Comission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIC ROCK POINT PLANT -

TECHNICAL SPECIFICATION CHANCE REQUEST - REMOVAL OF ORCANIZATION CHARTS Attached is a request for change to the Big Rock Point Technical Specifications. These proposed changes request removal of the organization charts from the Technical Specifications and inform the NRC of onsite organizational changes. These proposed changes are consistent with the guidance and philosophy provided by the h7C in Ceretic Letter 88-06 dated March 22, 1988. The detailed organizational information being removed is incorporated into other documents as identified in the proposed changes.

Also, changes to th'd organizational structure will contir.ue to be reported to the NRC as has been Consumers Power Company's past practice and as required by the proposed changes.

The attached Proposed Technical Specification Page Changes reficct previously submitted change requests which are still pending NRC action. Approval and issuance of these proposed changes should be coordinated with the previous proposals dated July 23, 1987 and July 5, 1988 to enauro the issued pages do not contain inadvertent omissions or errors.

I Pursuant to 10CFR170.12(c), a check in the amount of $150.00 is remitted with this application.

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Kenneth W Berry Director, Nuclear Licensing i

CC Administrator, Region III NRC i l NRC Resident Inspector - Big Rock Point V BBCr?150290 800908 f 0l IN % <

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CONSUMERS POWER COMPANY Docket 50-155 Requcst for Change to the Technical Specifications License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Facility Operating Licensa DPR-6, Docket 50 155, issued to Consumers Power Company on May 1. 1964, for the Big Rock Soint Plant be changed as described in Section I below:

I. Changes A. Revise section 6.2.1 to read as follows and delete Figure 6.2-1.

"6.2.1 0FFSITE AND ONSITE ORGANIZATIONS Onsite and offsite organizations shall be established for plant operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of Big Rock Point Plant.

a. Lines of authority, responsibility and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organisation positions. These relationships shall be document-ed, updated and reported to the NRC, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key positions, or in equivalent forms of documentation. These requirements shall be documented in the FHSR. Quality Assurance Program Description for Operational Nuclear Power Plants (CPC-2A), Nuclear Operations Department Standards (NOT.S) or Plant Administrative Procedures.

b. The Plant Manager shall be responeible for overall plant safe operation and shall have control over those onsite activities necessary for safe operation and maineenance of the plant.

c. The Vice President - Nuclear Operatians shall have corporate responsibility for overall plant nuclear safety and shall take any asasures needed to ensure acceptable performance of the staff in operatang, 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 managert however, they shall have sufficient crganizational freedom to ensure their indepen-dance from operating pressures."

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, i B. Revise section 6.2.2 to read "6.2.2 ptANT STAFF". and delete the sentence in 6.2.2 that reads "The plant organization shall be as ,

] shown in Figure 6.2-2 ands" and delete Figure 6.2-2.

C. Add new section 6.3.4 to read as follows:  ;

l' i 1 "6.3.4 An individual holding a Senior Reactor Operator license ,

shall be responsible for directing the activities of

• l licensed operators. He shall meet the other requirements of i Section 6.3.1 (as applicable to Operations Manager in  !

ANSI N18.1)." j 1

D. Revise section 6.4.1 to read as follows: I "6.4.1 A retraining and replacement training program for the plant  ;

staff shall be maintained and implemented and shall meet or j exceed..."  ;

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) E. Revise section 6.4.2 to read so follows:

a "6.4.2 A fire brigade training program shall be maintained and  !

l taplemented and shall, as practicable, meet or exceed the i requirements of Section 27 of the NFPA Code-1974 Fire

' brigade training drills shall be held at least quarterly." [

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I F. Revise the Table of Contents to show in Section 10. subsection 6.3 '

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Plant Staff Qualifications page numbers to be "106-107".

G. Changt. "... Engineering and Maintenance Superintendents..." to

• "...Msintenance Superintendert..." in the first paragraph following Sectiot 6.2.2.g(4).  :

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h. Change "Planning & Admin Services Superintendent" to "Maintenance 6 Superintendent" and "Engineering & Maintenance Superintendent" to [

"Engineering Superintendent" in Section 6.5.1.2.

i l II. Discussion 1 t i Nuclear Regulatory Cosmission Generic Letter 88-06 dated March 22. 1988

provided guidance for the removal of organisation charts from Technical  !

! Specification administrative control requirecents. These proposed changes follow the guidance of the Generic Letter and remove the organi-  ;

ration charts from Big Rock Point Technical Specifications. The changes  :

add general requirements to capture the essantial aspects of the  !

} organization structure as defined by the existing organization charts.

L l Where necessary, requirements have been added to appropriate  !

specifications for items which are currently not specified in the {

' Technical Specifications outside of the organization charts. In other l sections specific titles which imply a specific organizational 4 relationship have been removed, 1

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Changes A, B and C are modeled after the guidance provided in Enclo-sure 2 of the Generic Letter. In all cases company and plant cecific  ;

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titles and references have been utilized and titles which imply a l 1 specific organizational relationship have been removed. In Change A, I

any one or combination of four documents are specified to contain the  !

organizational information. To meet the guidance of the Generic Letter j that requires the removed organization detail to be included in other  !

q documents prior to removal from the Technical Specifications a '

combination of the four documents is necessary. In the long term the  !

updated THSR is intended to be the principal document for the location  ;

of this information, however, Big Rock Point currently does not have an updated THSR. Changes D and E remove apacific titles which taply a f specific organizational relationship. These changes follow the intent i of the guidance provided by the Generic Letter in that they allow  !

changes to organizational structure without obtaining prior NRC ,

approval. The functional responsibility for training is also implicitly [

included in the new section 6.2.1.

Other requirements on the current organization charts are already in other specifications, have been added as new specifications or are  :'

implicitly included in the new section 6.2.1. From Tigure 6.2-1, offsite Organization, the footnotes relating to the Nuclear Safety Board are already in section 6.5.2 and the footnote relating to the fire l protection program is implicitly included in the new section 6.2.1. l Trom Tigure 6.2-2 Plant Organization, notes A., B., C. and footnote (a)  !

are implicitly included in the new section 6.2.1. Footnote (b) has been added as new item 6.3.4 l l

Change T corrects page numbers in the Table of Contents as a result of I Changes A through E. l l

Changes G and H reflect plant organizational structure changes. Thess changes are implemented consistent with the philosophy of Generic Letter 88-06 in that the onsite orgaqization may be changed without obtaining prior NRC approval. However, titles which have been changed do appear l in other Technical Specification sections which require an amendment. l They also are intended to reflect the Cossaissionc increased awareness of l maintenance concerns as evidenced by recent policy statenert and ,

proposed rules. These organisational changes eliminate the Planning & [

Admin Services Superintendent position and splits the Engineering & ,

Maintenance Superintendent position into an Engineering Superintendent I and a Maintenance Superintendent. These changes elevate the maintenance i functions at the plant to allow incr6ased management focus on I maintenance activities. As the plant continues to age increased I emphasis on maintenance becomes more impor pnt to asJure plant I reliability and public health and safety. With respect to the Plant Review Coassittee, the discipline composition does not change. Neither the totti number nor quorum requirements of the Plant Review Cossaittee ,

are being changed. The maintenance area is represented by s single [

manager as opposed to being corbined witn the engineering area. With  ;

respect to authorization of deviation from overtime requirements, the r Production and Performance and the Maintenance Superintendents are the  ;

Plant Manager's principal assistants who deal with the majority of the overtime concerns at the plant.

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4 Other changes to be implemented include the combining of all material control, procurement and stockroom functions into one organizational group under the Maintenance Superintendent and to move security furetions under the Engineering Superintendent. As a result of the changes the Plant Manager vill have eight managers directly reporting to him. These include the Technical Engineer Production & Performance Superintendent. Engineering Superintendent. Maintenance Superintendent.

Chemistry / Health Physics Superintendent. Human Resources Director.

Public Af fairs Director and Administrative Services Supervisor. The technical Engineer is responsible for plant licensing interfaces. The Production & Performance Superintendent is responsible for plant operation and reactor engineering. The Engineering Superintendent is responsible for mechanical / civil and electrical engineering, security and a new procedure development / upgrade group. The Maintenance Superintendent is responsible for mechanical / electrical and instrumentation and control maintenance, material services and outage planning and scheduling. The Chemistry / Health Phystes Sup6rintendent is responsible for radiation protection, plant chemistry, radioactive vastes and emergency planning. The responsibilities of the remaining direct reports to the Plant Manager are self explanatory. These organizational changes have beun included in revised Plant Administrative Procedures. They have also been discussed with the Senior Resident Inspector and the Reactor Projects Branch in Region III.

III. Analysis of No Significant Hazards Consideration These proposed changes do not involve a significant increase in the probability or conaequences of an acr.ident previously evaluated because removal of the organization charts freu Technical Specifications and the organizational changes do not affect plant operation. Essenti '.

elements of the organizational structure have been retained th.augh the addition of general requirements modeled after the guidance and i philosophy provided by the NRC in Generic Letter 88-06. The organizational changes elevate the maintenance functions to allow increased management focus on maintensnce activities consistent with NRC policy and proposed rule making. These proposed changes do not eraate the possibility of a new or different kind of accident than previously evaluated because the proposed changes are administrative in nature. No aodifications to plant equipment. changes to setpoints or changes to operating limitations are being proposed. These proposed changes do not involve a significant reduction in a margin of safety as defined in Technical Specification bases because there are no bases for administrative controls. Through our Quality Assurance Program implementation and our commitment to maintain qualified personnel in all positions of responsibility and authority, it is assured ths; safety functions performed by both the onsite and offsite organirailons vill continue to be performed at a high level of competence. Therefore, these proposed changes do not involve a significant hazards consideration.

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O IV. Conclusion The Big Rock Point Plant Review Committee has reviewed this Technical Specification Change Request and has determined this change does not involve an unreviewed safety question and, therefore, involw s no significant hazards consideration. This change has also been reviewed under the cognizance of the Nuclear Safety Board. A copy of th?.s Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Opeicating License.

CONSL'MERS POWER COMPANY r

B __ C I b - ' d Originator Ne Ralph R Frfsdh Gordon L delps'. Senior Vice President' Energy Supply Senior Licensing Analyst Nuclear Licensing Dept.

Sworn and subscribed to before me this 8th day of September 1988.

M L, -> w.

Beverly'phn Avery Notary /Public Jackson County. Michigan My commission expires December 27. 1988 TSB0488-0105-NLO4

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