ML20238A006

Application for Amend to License NPF-3,revising Tech Spec Section 6.0 Re Administrative Controls to Provide Functionally Accurate Depiction of Executive Reporting Relationship of Nuclear Program

ML20238A006
Person / Time
Site:	Davis Besse
Issue date:	08/31/1987
From:	Shelton D TOLEDO EDISON CO.
To:
Shared Package
ML20237L753	List: ML20237L752 ML20238A006 ML20238A064
References
1411, NUDOCS 8709090092
Download: ML20238A006 (9)

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Docket No. 50-346 License No. NPF-3 Serial No. 1411 Enclosure APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Attached are requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Facility Operating License No. NPF-3. Also included are the Safety Evaluation end Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1411)

. concern Section 6.0, Administrative Controls:

Figure 6.2-1, Davis-Besse Nuclear Power Station Offsite/Onsite Organization; Specification 6.3, Facility Staff Qualifications; Specification 6.5, Review and Audit; Specification 6.6, Reportable Event Action; and Specification 6.7, Safety Limit Violation. -

By (ik bw Yk Vice President, Nuclear Sworn to and subscribed before me this 31st day of August, 1987.

IbdS0a 1V Notary Public, State of Ohio b.,, , ,_

My commission expires // /

G709090092 970831 T PDR ADOCK 05000346i P PDR ,

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Docket No.-'50-346 License'Wo. NPF-3 Serial No. 1411' Enclosure The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit 3 , 1 Operating License No. NPF-3, Appendix A Technical Specifications, Section 6.0.

A. Time Required to Implement: This change is to be effective immed-lately upon issuance of the License Amendment.

B. Reason for Change (Facility Change Request 87-0126): Revise Technical Specification Section 6.0, Administrative Controls, to include u;cnt position title changes, and reflect recent organization changes.

C. Safety Evaluation: See attached Safety Evaluation (Attachment 1).

D. Significant Hazards Consideration: See attached Significant flazards Consideration (Attachment 2).

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Docket'No. 50-346 License No. NPF-3 Serial No. 1411 3

Attachment 1 Page 1 SAFETY EVALUATION INTRODUCTION The purpose of this Safety Evaluation is to review proposed changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix-A Technical Specifications. The proposed changes involve revising the Technical Specifications to reflect recent organization, position, and title changes in Figure 6.2-1, Davis-Besse Nuclear Power Station Offsite/Onsite Organization and 'in Section 6.0, Administrative Controls.

PROPOSED AMENDMENT REQUEST DISCUSSION As discussed below, the proposed License Amendment Request revises the following sections of the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A Technical Specifications.

l Figure 6.2-1 (page 6-2) - Revise figure to: 1) Add the position of Chairman and Chief Executive Officer; 2) Include the title change of President and Chief Operating Officer to President, and include the j revised reporting requirements for the President. The President reports directly to the Chairman and Chief Executive Officer; 3) Add the position of Executive Vice President. The Finance and Administration Vice President and the Vice President, Nuclear report directly to the Executive Vice

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President, instead of to'the President and Chief Operating Officer; 4)

Include the following title changes: Administration Senior Vice President to Finance and Administration Vice President; Senior Vice President, Nuclear to Vice President, Nuclear; and Performance Engineering Manager to Performance Engineering Director; 5) Delete the Technical Support Depart-ment from Figure 6.2-1 to reflect the revised reporting requirements.

The Technical Support Department reports directly to the General Superin-tendent, Outage and Program Management, instead of to the Plant Manager;

6) Delete the Plant Services Department from Figure 6.2-1 to reflect the revised reporting requirements. The Plant Services Department reports directly to the Maintenance PJanning Snoerintendent instead of to the Plant Manager. The Maintenance Planning Superintendent reports directly to the General Superintendent, Cutage and Program Management; and 7)

-Separate the Chemistry and Health Physics Department into the Chemistry Department and the Radiological Controls Department. The Chemistry Super-intendent reports directly to the Plant Manager. The Radiological Controls Superintendent reports directly to the Plant Manager. All the changes are administrative in nature.

6.3.1 (page 6-5) - Change Chemistry and Health Physics General Superinten-dent to Radiological Controls Superintendent. This change reflects the separation of the Chemistry and Health Physics Department and is consistent with Regulatory Guide 1.8, September 1975. This is an administrative change

Docket No. 50-346 License No. NPF-3  :

Serial No. 1411 Attachment 1 Page 2 i-6.5.1.2 (page 6-6) - Change Station Review Board member from Chemistry - 1 and Health Physics General Superintendent to Radiological Controls Super-intendent. This change reflects the separation of the Chemistry and Health Physics Department. This is an administrative change.

6.5.1.2 (page 6-6) - Delete "or Performance Engineering Manager". This j position has been elevated to Performance Engineering Director, which is included as an Engineering Director. This is an administrative change.

6.5.1.2 (page 6-6) - Change Station Review Board member from Operations Quality Assurance Manager to Engineering Assurance Supervisor. This change reflects the current position title. This is an administrative change.

6.5.1.6.e (page 6-7) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.1.7.c (page 6-8) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.1.8 (page 6-8) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.2 (page 6-9) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.9 (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.10.a (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.10.b (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.10.c (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.6.1.b (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change. ,

6.7.1.b (page 6-13) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.7.1.d (page 6-13) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

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Docket No. 50-346 License No. NPF-3 Serial No. 1411 Attachment 1 Page 3 DISCUSSION OF UNREVIEWED SAFETY QUESTION The proposed changes are administrative. Therefore, the implementation of these proposed changes would not:

Increase the probability of occurrence of an accident previously evaluated in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment, or a modification to a system. The proposed changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated (10CFR50.59(a)(2)(i)).

Increase the consequences of an accident previously evaluated in the USAR 3 because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment, or a modification to a system. The proposed changes are administrative in nature and do not increase the consequences of an accident previously evaluated (10CFR50.59(a)(2)(i)).

Increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the USAR because the proposed changes do not involve a test or experiment, and no station equipment is being modified. The proposed changes are administrative in nature and do not increase the probability of occurrence of a malfunction of equipment important to safety (10CFR50.59(a)(2)(i)).

Increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because the proposed changes do not involve a test or experiment, and no station equipment is being modified. The proposed changes are administrative in nature and do not increase the consequences of a malfunction of eqripment important to safety (10CFR50.59(a)(2)(i)).

Create the possibility for an accident of a different type than any evaluated previously in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test or experiment, or a ,

modification to a system and do not affect any plant equipment or oper-ation procedures which could impact the probability of an accident. The proposed changes are administrative in nature and involve no accident scenario. On raatters related to nuclear safety, all accidents are bounded by previous analyses and no new accidents are involved (10CFR50.59(a)(2)(ii)).

Create the possibility for a malfunction of a different type than any evaluated previously in the USAR because no station equipment is being modified by the proposed Technical Specification changes. The proposed changes do not involve a test or experiment, or a modification to a

Docket No. 50-346 License No. NPF-3 Serial No. 1411 Attachment 1 Page 4 system and do not affect any plant equipment or operational procedures which could impact the probability of a malfunction. The changes are ' j administrative in nature and involve no malfunction scenario (10CFR50,59(a)(2)(ii)).

Reduce the margin of safety as defined in the basis for any Technical Specification because the amendment does not affect any operating practices or limits nor any equipment or system important to safety. The proposed changes are administrative in nature and will not reduce the margin of safety (10CFR50.59(c)(2)(iii)).

CONCLUSION Based on the above, it is concluded that the proposed Technical c-Specification changes do not constitute an unreviewed safety question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1411 Attachment 2 Page 1-SIGNIFICANT HAZARDS CONSIDERATION INTRODUCTION The purpose of this Significant Hazards Consideration is to review proposed changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A Technical Specifications. The proposed changes involve revising the Technical Specifications to reflect recent organization, position, and title changes in Figure 6.2-1, Davis-Besse Nuclear Power Station Offsite/Onsite Organization and in Section 6.0, Administrative Controls.

PROPOSED AMENDMENT REQUEST DISCUSSION As discussed below, the proposed License Amendment Request revises the following sections of the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A Technical Specifications.

Figure 6.2-1 (page 6-2) - Revise figure to: 1) Add the position of Chairman and Chief Executive Officer; 2) Include the title change of President and Chief Operating Officer to President, and include the revised reporting requirements for the President. The President reports directly to the Chairman and Chief Executive Officer; 3) Add the position of Executive Vice President. The Finance and Administration Vice President and the Vice President, Nuclear report directly to the Executive Vice President, instead of to the President and Chief Operating Officer; 4)

Include the following title changes: Administration Senior Vice President to Finance and Administration Vice President; Senior Vice President, Nuclear to Vice President, Nuclear; and Performance Engineering Manager to Performance Engineering Director; 5) Delete the Technical Support Depart-ment from Figure 6.2-1 to reflect the revised reporting requirements.

The Technical Support Department reports directly to the General Superin- j tendent, Outage and Program Management, instead of to the Plant Manager; '

6) Delete the Plant Services Department. from Figure 6.2-1 to reflect the revised reporting requirements. The Plant Services Department reports directly to the Maintenance Planning Superintendent instead of to the Plant Manager. The Maintenance Planning Superintendent reports directly to the General Superintendent, Outage and Progran Management; and 7)

Separate the Chemistry and Health Physics Department into the Chemistry Department and the Radiological Controls Department. The Chemistry Super-intendent reports directly to the Plant Manager. The Radiological Controls  ;

Superintendent reports directly to the Plant Manager. All the changes are administrative in nature. ,

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6.3.1 (page 6-5) - Change Chemistry and Health Physics General Superinten- )

dent to Radiological Controls Superintendent. This change reflects the separation of the Chemistry and Health Physics Department and is consistent with Regulatory Guide 1.8, September 1975. This is an administrative change.

Docket No. 50-346 License No. NPF-3 Serial No. 1411 Attachment 2 Page 2 1

6.5.1.2 (page 6-6) - Change Station Review Board member from Chemistry and Health Physics General Superintendent to Radiological Controls Super-intendent. This change reflects the separation of the Chemistry and Health Physics Department. This is an administrative change.

6.5.1.2 (page 6-6) - Delete "or Performance Engineering Manager". This position has been elevated to Performance Engineering Director, which is included as an Engineering Director. This is an administrative change.

6.5.1.2 (page 6-6) - Change Station Review Board member fram Operations Quality Assurance Manager to Engineering Assurance Supervisor. This change reflects the current position title. This is an administrative change.

6.5.1.6.e (page 6-7) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

l 6.5.1.7.c (page 6-8) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.1.8 (page 6-8) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.2 (page 6-9) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.9 (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.10.a (page 6-12) - Change title of Senior Vice President, Nuclear to l Vice President, Nuclear. This is an administrative change.

6.5.2.10.b (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.5.2.10.c (page 6-12) - Change title of Senior Vice President, Nuclear to Vice Fresident, Nuclear. This is an administrative change.

6.6.1.b (page 6-12) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.7.1.b (page 6-13) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

6.7.1.d (page 6-13) - Change title of Senior Vice President, Nuclear to Vice President, Nuclear. This is an administrative change.

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Docket No.~50-346 License No. NPF-3 Serial No. 1411 Attachment 2 6 Page 3 SIGNIFICANT HAZARDS CONSIDERATION The proposed changes do not involve a significant hazards consideration )

because the operation of the Davis-Besse Nuclear Power Station, Unit No. 1 in accordance with these changes would not:

j Involve a significant increase in the probability or consequences of an accident previously evaluated because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment or a modification to a system. The proposed changes are administrative in nature and do not increase the probability or consequences of an accident previously evaluated (10CFR50.92(c)(1)).

Create the possibility of a new or different kind of accident from any accident previously evaluated because the accident conditions and assumptions are not affected by the proposed Technical Specification changes. The proposed changes do not involve a test, experiment or a modification to a system and do not affect any plant equipment or operational procedures which could impact the probability of an accident.

The proposed changes are administrative in nature and involve no accident scenario. On matters related to nuclear safety, all accidents are bounded by previous analysis and no new accidents are involved )

(10CFR50.92(c)(2)).

Involve a significant reduction in a margin of safety because the amend-ment does not affect any operating practicer or limits nor does it affect any equipment or system important to safety. The proposed changes are administrative in nature and will not reduce the margin of safety (10CFR50.92(c)(3)).

CONCLUSION On the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.

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