AECM-88-0128, Application for Amend to License NPF-29,changing Plant Staff Organization to Consolidate Certain Engineering Personnel & Functions in Nuclear Operations Site Organization.Fee Paid

Application for Amend to License NPF-29,changing Plant Staff Organization to Consolidate Certain Engineering Personnel & Functions in Nuclear Operations Site Organization.Fee Paid

ML20151F613
Person / Time
Site:	Grand Gulf
Issue date:	07/15/1988
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151F617	List: AECM-88-0128, Application for Amend to License NPF-29,changing Plant Staff Organization to Consolidate Certain Engineering Personnel & Functions in Nuclear Operations Site Organization.Fee Paid ML20151F619
References
AECM-88-0128, AECM-88-128, NUDOCS 8807270173
Download: ML20151F613 (9)

Text

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. e EYETEM ENERGY REEDLINCES, INC.

OLM9 ) KJGREY Jo vce nesow

• * *

• July 15, 1988 U. S. Nuclear Regulatory Comission Mail Station P1-137 Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Proposed Plant Staff Engineering Organization and PSRC Membership Change Proposed Amendment to the Operating License (PC0L-88/11)

AECM-88/0128 System Energy Resources, Inc. (SERI) is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License.

The proposed amendment is the result of a planned change in the plant staff organization to consolidate certain engineering personnel and functions in the Nuclear Operations site organization.

The engineering staffs in the Technical Support Group, the Plant I Modification & Construction Group Retest section and the Maintenance Group will be consolidated into a new Performance and System Engineering Department.

This new organization will provide a source of engineering expertise on plant systems, components and programs thereby eliminating duplication of engineering tasks in the site Nuclear Operations organization.

SERI by letter dated June 3, 1988 (AECM-88/0106) has requested removal of the onsite and offsite organization charts from the GGNS Unit 1 Technical Specifications pursuant to NRC Generic Letter 88-06. Those proposed changes i are pending NRC Staff approval; therefore, no changes to those Technical Specification organization charts are proposed. The planned organization change does modify the composition of the Plant Safety Review Comittee (PSRC) membership listed in Technical Specification 6.5.1.2. That change is proposed and discussed in Attachment 3 to this letter.

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AECM-88/0128 Page 2 The planned organization change is consistent with the findings and recommendations of the 1987 Institute of Nuclear Power Operations evaluation of GGNS. The planned change is unrelated and independent of the proposed Middle South Utilities, Inc. and SERI Nuclear consolidation described by SERI letter to the NRC dated July 1, 1988 (AECM-88/0130).

The proposed change involves only the Nuclear Operations organization and does not affect the existing dedicated SERI organization supporting GGNS, including the Nuclear Plant Engineering organization.

The planned organization changes ware discussed with members of NRC Region II and NRR staffs on July 13, M, and 15,1988. As discussed with NRC Staff, '.,ERI plans to request enforceinent discretion tc allow implementation of the proposed organization on July 18, 1988. The planned organization changes represent a clear improvement in the use of site 2ngineering resources and SERI feels it is advantageous to implement these improvements as soon as possible.

Enforcement discretion will enable SERI to realize the immediate benefits of the organizational changes until the proposed amendments are approved. That request will be submitted under separate cover.

In accordance with the provisions of 10 CFR 50.4, the original of the.

requested amendment is enclosed and the appropriate copies will be distributed.

Attachment 3 provides the technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee.

Based on the guidelines presented in 10 CFR 50.92, SERI has concluded that this proposed amendment involves no significant hazards considerations.

In accordance with the requirements of 10 CFR 170.21, an application fee of $150 is attached to this letter.

Your uly,

/

ODK:bms Attachments: 1. Remittance of $150 Application Fee

2. Affirmation per 10 CFR 50.30

3. GGNS PCOL-88/11 cc: (See Next Page)

J16AECM88062102 - 2

' AECM-88/0128' Page 3

.cc: Mr. T. H. Cloninge 1(w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace', Regional Administrator (w/a)

U. S.LNuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 14820 Washington, D.C. 20555 Dr. Alton B. Cobb (w/a)

State Health Officer State Board of Health Box 1700 Jackson, P4ssissippi 39205 J16AECM88062102 - 3

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BEFORE THE q UNITED STATES NUCLEAR REGULATORY COMMISSION  !

LICENSE NO. NPF-29 DOCKET N0. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, state that I.am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the

')perating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of System Energy Resources, Inc.; and that the statements made and the matters set fort therein are true and correct to the best of my knowledge, information and ef.

.\ .

STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 beforA me, a ta y Pyblic, in and for the County and State above named, this @-ay of . ;<.IM . , 1988.

(SEAL) dd/Ahn a Notary Public My comission expires: l uj com*@n E@n St4 26 M l l

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- - Attachment 3 to AECM-88/0128 A. SUBJECT

1. NL 88/08 Proposed Plant Staff Engineering Organization and PSRC Membership Change

2. Revised Technical Spec' fications:

a. Plant Safety Review Coninittee Composition, 6.5.1.2 - Page 6-7.

B. DISCUSSION

1. Presently, the engineering expertise of the plant staff organization resides in four distinct sections: Technical Engineering, Reactor Engineering, Plant Modification and Construction (PM&C), and Maintenance Engineering (I&C, Mechanical and Electrical, Planning &

Scheduling) as shown in Figure 1. With this. separation of the plant engineering expertise a clear division of responsibility does not exist. This contributes to some degree of confusion and misunderstanding, which in turn detracts from SERI's full capability to effectively and_ efficiently resolve plant problems.

2. is being consolidated into the Performance Plant staff engineering and System Engineering (P&SE) Department under a new position, the Manager P&SE. P&SE will be formed by consolidating various engineering staffs - those in Technical Engineering, Reactor Engineering, PM&C, and Maintenance Engineering. P&SE will serve as a single source of engineering expertise on plant systems. This strengthened organization will enhance the operation of Grand Gulf Nuclear Station (GGNS) by providing a focused management approach to plant engineering functions.

By consolidating the plant engineering expertise, duplication of engineering tasks within the various organizations will be essentially eliminated. Consolidating resources will mean a more effective use of engineering capabilities on site.

3. The formation of the plant staff engineering organization is independent of the proposed overall SERI consolidation described in the SERI letter (AECM-88/0130) dated July 1, 1988 and is not being done to accommodate the integration of the other nuclear facilities.

Likewise, the realignment will not affect the SERI offsite support functions including the design engineering organization, Nuclear Plant Engineering (NPE). In fact, the realignment is designed to improve the interface between NPE and plant staff in the areas of maintenance, engineering, and operations.

4. The Manager, P&SE will be responsible for activities necessary to support the operations of GGNS, Unit 1. This includes System Engineering management, Inservice Inspection Program management, Reactor Engineering management and the engineering support of maintenance and operations. The Manager, P&SE will report to the GGNS General Manager and will be assisted by the System Engineering Superintendent, the Reactor Engineering Superintendent and the Engineering Support Superintendent.

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Attachment 3 to AECM-88/0128

5. The System Engineering Superintendent will be responsible for plant staff system engineering functions. The system engineering function will-provide system engineers who have.overall system and component expertise on their assigned systems. He will be responsitle for technical activities associated with design changes, the collection, collating and evaluation of data, reliability analysis and root cause analysis. The System Engineering Superintendent will have three System Engineering Supervisors under his direction and will report to the Manager, P&SE.

6. The Engineering Support Superintendent will provide administrative support to the Manager, P&SE. He will also be responsible for those portions of programs such as Inservice Inspection, Thermal Performance Monitoring and Equipment Qualification. assigned to the plant staff. The Engineering Support Superintendent will have two supervisors, the Inservice Inspection Supervisor and Engineering Support Supervisor, under his direction and will report to the Manager, P&SE.

7. The Reactor Engineering Superintendent will be responsible for onsite core management and periodic reactor testing, in-plant nuclear materials control and accountability, and providing assistance to reactor operators during control rod pattern adjustments. The Reactor Engineering Superintendent will report to the Manager, P&SE.

8. As a part of the organizational realignment, the Technical Support Superintendent position is being deleted. The Technical Support Superintendent is currently a member of the Plant Safety Review Committee (PSRC) as indicated in Technical Specification (TS) 6.5.1.2.

Therefore, with this position being deleted the following i administrative change is proposed to TS 6.5.1.2: replace the Technical Support Superintendent with the Manager, P&SE.

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9. TS Figure 6.2.1-1 and 6.2.2-1 provide the organizational charts associated with GGNS and would require changes with this reorganization; however, a proposed TS change was submitted by SERI letter (AECM-88/0106) dated June 3,1988 that will remove these figures .from l the TS. This proposed organizational realignment has been evaluated i against the criteria of 10CFR50.59 and determined not to constitute  !

an unreviewed safety question. Also, the appropriate Updated Final l Safety Analysis Report (UFSAR) change request has been initiated to I have the UFSAR reflect the organizational changes.

C. JUSTIFICATION

1. With the new organization all the duties, responsibilities and functions being performed will now be performed in a more productive and effective manner. The new organization will allow SERI to develop a better predictive and preventive maintenance program. The P&SE staff will be composed of the engineers presently in the various plant staff engineering sections; thus all required minimum qualifications of Technical Specification 6.3.1 will continue ^.o be met. There will be a clear division of responsibility whic' 11 eliminate confusion and misunderstanding.

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Attachment'3 to AECM-88/0128

2. As a result of the elimination of the Technical' Support Superintendent position the Manager,-P&SE will be added as a member of the PSRC.

Neither the number of PSRC members nor the level of expertise will

. change. In addition, the majority of work activities previously supervised by the Technical Support Superintendent will .now be the responsibility of the Manager, P&SE. Therefore, the.same perspective brought to the PSRC by the Technical Support Superintendent will still exist when the Manager, P&SE is added to the PSRC.

D. N0 SIGNIFICANT HAZARDS CONSIDERATIONS As discussed in 10CFR50.92, the following discussions are provided to the NRC Staff in support of "no significant hazards considerations."

1. No significant increase in the probability or consequences of an accident previously evaluated results from this change.

a. This realignment of the plant staff engineering groups will have no negative effect on plant design or operation because P&SE will actively look for ways to improve the performance of specific systems and components, as well as overall plant performance. With responsibility and accountability being assigned for designated plant systems, components, and programs the knowledge of specific systems will be enhanced. The same i level of expertise applied to the PSRC review function will exist with the approval of the proposed change. Since essentially the same representation will exist there will be no loss in PSRC effectiveness,

b. Therefore, there is no increase in the probability or consequences of previously analyzed accidents due to the proposed change.

2. This change would not create the possibility of a new or different I kind of accident from any previously evaluated.

a. Since there is no loss in PSRC effectiveness, the proposed change is administrative in nature. No physical alterations of plant configuration or changes to setpoints or operating parameters are proposed. The same level and quality of PSRC review is maintained and unaltered by this proposed change. l

b. Therefore, the possibility of a new or different kind of accident from any previously evaluated is not created.

3. This change would not involve a significant reduction in the margin of safety. H

a. There will be no physical changes to the plant equipment, setpoints or operating modes as a result of the proposed change. This administrative change maintains the level and .

quality of PSRC review by maintaining essentially the same level of expertise applied to the PSRC review function.

b. Therefore, this proposed change will not involve a significant reduction in'the margin of safety.

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