ML19327B936

Application for Amend to License NPF-85,consisting of Tech Spec Change Request 88-08,revising Tech Specs to Reflect Removal of Organizational Charts as Recommended by Generic Ltr 88-06

ML19327B936
Person / Time
Site:	Limerick
Issue date:	11/03/1989
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19327B937	List: ML19327B936 ML19327B942
References
GL-88-06, GL-88-6, NUDOCS 8911140235
Download: ML19327B936 (14)

Text

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-l 10 CrR 50.90 I

PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD, WAYNE, PA 19087 5691 i

(sis)sao.sooo q

November 3, 1989 l

Docket No. 50-353 License No. NPP-85 i

l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk f

Washington, D. C.

20555

SUBJECT:

Limerick Generating Station, Unit 2 I

Technical Specifications Change Request

Dear Sir:

Philadelphia Electric Company hereby submits Unit 2 Technical Specifications Change Request No. 88-08, in accordance with 10 CPR 50.90, requesting an amendment to the Technical Specifications (Appendix A) of Operating License No. NPP-85.

Informatior supporting this Change Request is contained in

, to this letter, and the proposed replacement pages are contained in Attachment 2.

v This submittal requests changes to the Technical Specifications to reflect the removal of organizational charts from the Technical Specifications as recommended by NRC Generic Letter 88-06, " Removal of Organization Charts from Technical i

Specification Administrative Control Requirements."

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If you have any questions regarding this matter, i

please contact us.

Very truly yours, I

Hunger)fr G. A.

Jr.

Director l

Licensing Section l

Attachments fool

' I cc W. T.

Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS T. Gerusky, Director, PA Bureau of Radiological Protection l

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Unit 2 c.

Technical Specification Chang] C.qu;3t 88-08 I

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COMMONWEALTH OF PENNSYLVANIA l

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COUNTY OF CHESTER I

D. R. Helwig, being first duly sworn, deposes and sayst l

That he is Vice President of Philadelphia Electric Company, i

the Applicant herein; that he has read the foregoing Application i

for Amendment of Pacility Operating Licenses, to remove the organizational charts and correct certain position descriptions and titles, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to i

the best of his knowledge, information and belief.

k s

Vice P dent I

l Subscribed and sworn to

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before me this3 day of 7/fvMs.1989.

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, Y W LJ Ofnt s's Notary Public E

NOTARtAL SEAL CATHERINE A.f/ENDEZ, Notary Pubile Trecyttrm Two., Chester County My Comm4ston Erpres feet 4.1M3 i

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ATTACHMENT 1 1

f LIMERICK GENERATING STATION UNIT 2 I

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Docket No. 50-353 License No. NPF-85 l

TECHNICAL SPECIFICATIONS CHANGE REQUEST l

" Removal of Organizational Charts as Recommended by l

NRC Generic Letter 88-06"

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Supporting Information for Changes - 16 pages e

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e Dockot No. 50-353

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License No. NPP-85

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I Philadelphia Electric Company (PECo), Licensee under

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facility operating License NPF-85 for Limerick Generating Station I

(LGS) Unit 2, hereby requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended.

i Proposed changes to the TS are indicated by the vertical bars in l

the margins of the pages contained in Attachment 2 and listed i

heres xxvi, 6-1, 6-2, 6-3, 6-4, 6-6, 6-9, 6-12 and 6-22.

J This Change Request is submitted primarily as a result of NRC Generic Letter (GL) 88-06, " Removal of Organization Charts l

from Technical Specification Administrative Control Requirements," which encourages licensees to propose changes to j

their TS to remove organizational charts from TS-and replace them with descriptions of the organizational structure and characteristics which are important to safety.

The proposed changes concern the Administrative Controls in TS Section 6.0, I

and do not affect any Limiting Conditions for Operation or l

Corveillance Requirements.

The proposed changes in this Change Request are grouped into two categories.

Each category of proposed changes includes a Description of Changes, a Safety l

Discussion, and information supporting a finding of no Significant Hazarda Consideration.

Category

'A' proposed changes involve removing the onsite and offsite organizational charts from TS Sections 6.2.1 and 6.2.2, respectively.

These proposed changes are consistent with the guidance provided in GL 88-06.

t Category

'B' proposed changes are miscellaneous administrative i

changes.

This Change Request concludes with information supporting an Environmental Assessment which is common to both i

catagories of proposed changes, and a List of Proposed Changes which specifies the pages and paragraphs affected by the proposed changes in both categories.

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We request that the proposed changes be effective as of the issuance date of the license amendment.

Description of Proposed Changes - Category

'A' i

The removal of organizationt ? charts from the TS is an improvement that was proposed on a lead plant basis for the Shearon Harris plant and was endorsed by the Westinghouse Owners Group.

The NRC approved this change for Shearon Harris on January 27, 1988.

This change was reviewed as part of the NRC's program for improvements in TS.

The objectives of that program were established by the NRC's " Interim Policy Statement on TS Improvements."

As a result of these efforts, NRC GL 88-06 was issued on March 22, 1988 which encouraged licensees and applicants to propose changes to their TS to remove the organizational charts from the TS.

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Dockst No. 50-353

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License No. NPF-85 i

Implementing the guidance provided in GL 88e06 involves the following proposed changes.

l 1.

Insert the following as TS paragraph 6.2.1:

f "6.2.1 OPPSITE AND ONSITE ORGANIEATION Onsite and offsite organizations shall be established for f

unit operation and corporate management, respectively.

The onsite and offsite organizations shall include the positions l

for activities affecting the safety of the nuclear power plant.

t 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 organizational positions.

These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements shall be documented in the Limerick Generating Station Quality Assurance Program.

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b.

The Plant Manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

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The Vice President, Limerick Generating Station shall l

have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, l

maintaining, and providing technical support to the plant to ensure nuclear safety.

d.

The individuals who train the operating staff and those s

l who carry out health physics and quality assurance funct.lons may report to the appropriate onsite manager; l

however, they shall have sufficient organizational l

freedom to ensure their independence from operating pressures."

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l Dockot N3. 50-353 i

i License No. NPF-85 2.

Remove the first sentence in paragraph 6.2.2 which reads "The

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unit organization shall be as shown on Figure 6.2.2-1 ands" as recommended by GL 88-06.

Add TS paragraph 6.2.2.g as

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recommended in GL 88-06 to designate the positions in the onsite organization that require a senior reactor operator (SRO) license.

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3.

Remove the " Nuclear Management Organizational" chart shown as Figure 6.2.1-1.

4.

Remove the " Organization for Conduct of Plant Operations" chart shown as Figure 6.2.2-1.

j S.

Revise the " Table of Contents" page xxvi to reflect deletion of Figures 6.2.1-1 and 6.2.2-1 and the changes to paragraph 1

6.2.1.

Safety Discussion - Category

'A' t

Deletion of the organizational charts is accompanied by i

the addition of general administrative control requirements which l

describe the essential aspects of the organizational structure defined in the organizational charts.

The additional administrative control descriptions are contained in the proposed paragraphs 6.2.1.a through 6.2.1.d and 6.2.2.g.

They involve the designation of safety responsibilities and organizational freedom of the Health Physics, Training, and Quality Assurance groups.

The independence of the Quality Assurance group is further guaranteed by adherence to 10 CFR 50 Appendix B, Criterion I.

Removing the organizational charts from the TS will have a positive impact on safety by permitting us to promptly implement changes to our organizational structure without prior NRC approval provided that the change meets the general administrative controls and organizational objectives specified i

in proposed TS paragraphs 6.2.1. and 6.2.2.

Consequently, enhancements to the organizational structure, as well as minor administrative changes such as position title revisions, can be 1

implemented promptly upon identification of the need for the i

change.

Safety is further enhanced by providing clear and concise definitions of responsibility for the Plant Manager and Vice President, LGS in the proposed TS paragraphs 6.2.1.b and 6.2.1.c, respectively.

i Removing the organizational charts from the TS will not affect compliance with any NRC regulations.

10 CFR Section ;

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Dockot No. 50-353 i

l License No. NPF-85 i

50.36(c)(5) requires that provisions relating to organization and management, procedures, record keeping, review and audit, and l

reporting necessary to assure operation of the facility in a safe j

manner be included in the facility TS.

However, no particular requirements are established for the format or content of these administrative control TS.

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Removing the organizational charts from the TS and replacing them with the proposed descriptive language will assure that organizational commitments continue to be defined and controlled.

The LGS Quality Assurance Program, Chapter 17 of the i

LGS Final Safety Analysis Report (PSAR) contains detailed organizational charts and associated descriptions of individual and group responsibilities as they apply to the operation and i

support of the facility.

Appendix B to 10 CPR 50 and 10 CPR l

50.54(a)(3) govern changes to the organization as described in j

the Quality Assurance Program.

The enforceability of this requirement is further onhanced by the proposed TS paragraph 6.2.1.a.

Additionally, 10 CPR 50.34(b)(6) requires that the organizational structure, along with responsibilities and l

authorities, be included in the FSAR.

Chapters 13 and 17 of the LGS FSAR contain the important organizational features currently

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depicted on Figures 6.2.1-1 and 6.2.2-1.

This information is required by 10 CPR 50.71(e) to be maintained and updated annually.

Thus, even in the absence of the organizational charts from the TS, the onsite and offsite organizations will be

. established and maintained to assure operation of the facility in l

a safe manner.

Information Supporting a Finding of No Significant Bazards Consideration - Category

'A' (1)

The proposed Category

'A' changes do not involve a significant increase in the probability or i

consequences of any accident previously evaluated.

Removing the organizational charts from the TS and replacing them with more general language does not affect plant operation.

The proposed changes do not increase or decrease the qualification, experience, or training requirements of onsite or offsite nuclear personnel.

Additionally, the proposed changes do not affect the shift crew composition or the facility management positions requiring an NRC license.

The LGS Quality Assurance Program contains detailed organizational charts and associated descriptions of individual and group responsibilities as they apply to the operation and support of the LGS facility.

Appendir B to 10 CPR 50 and 10 CFR.

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Dock 0t No. 50-353 License No. NPF-85 l

50.54(a)(3) govern changes to the organization as described in i

the Quality Assurance Program.

10 CFR 50.34(b)(6) requires that j

the organizational structure also be included in the FSAR.

l Chapters 13 and 17 of the FSAR provide a description of the i

organization and detailed organizational charts.

As required by 10 CFR 50.71(e), this information must be maintained and updated annually.

Based on this review, we have concluded that the proposed Category

'A' changes do not involve a significant increase in the probability or consequences of any accident previously eva.1vated.

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(2)

The proposed Category

'A' changes do not create the l

possibility of a new or different kind of accident

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from any previously evaluated..

i The proposed changes are administrative in nature, and 4

do not involve any physical alterations of plant configurations i

or changes to setpoints, or operating parameters.

We have therefore concluded that removing the organizational charts from the TS does not create the possibility of a new or different kind of accident from any previously evaluated.

j (3)

The proposed Category

'A' changes do not result in l

a significant reduction in the margin of safety.

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Removing the organizational charts from the TS enhances the margin of safety by permitting an organizational change i

without prior NRC approval provided that the objectives of proposed TS paragraphs 6.2.1 and 6.2.2 are met, thereby allowing l

a more timely response to situations where the appropriate action is a prompt organizational change.

Safety is maintained by providing clear and concise definitions of responsibility for the Shift Supervisor, Plant Manager and Vice President-Limerick Generating Station.

Further, the proposed changes include additional administrative controls which capture the essential aspects of I

the material being removed such that the associated requirements l

will continue to be met.

Based on this review, we have concluded 1

that the proposed Category

'A' changes do not result in a i

significant reduction in the margin of safety, but improve the i

margin of safety.

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Dockot No. 50-353 License No. N?P-85 L

Description of Changes - Category

'B' The following admir.istrative changes are proposed.

1.

Revise paragraph 6.5.2.1 to indicate that the l

Nuclear Review Board (NRB) reports to and advises

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only the Executive Vice President-Nuclear and not the Office of the Chief Executive.

f 2.

Revise paragraph 6.5.2.9.c to indicate that NRB audit reports shall be forwarded to the Corporate l

Officer (s) responsible for the areas audited t

instead of the Executive Vice President-Nuclear.

3.

Revise paragraph G.2.3.2 and 6.2.3.4 to reflect l

title changes and the deletion of the corporate i

Independent Safety Engineering Group (ISBG).

i 4.

Revise paragraph 6.14.2 by removing the Engineer-In-Charge Nuclear and Environmental Section in l

order to remove unnecessary detail concerning the technical review of the Offsite Dose Calculation Manual (ODCM).

5.

Revise paragraph 6.2.2.f by replacing the five specific titles of the superintendents who may authorize deviation from overtime guidelines with a reference to the administrative procedure that is i

used to designate which personnel are authorized to perform this function.

l Safety Discussion - Category

'B' Proposed change #1 reflects a change to the formation of l'

Nuclear Committee of the Board (NCB).

The function of NCB is to advise and assist the Board of Directors in the proper and i

l complete discharge of its responsibilities for oversight of the Company's nuclear operations.

The Chairman of the NRB will eeet directly with the Chairman of the NCB, and will meet directly with the NCB at least once annually.

The Office of the Chief l

Executive will be made aware of NRB activities by both the Executive Vice President-Nuclear and the Board of Directors.

The i

Executive Vice President-Nuclear reports directly to the Office of the Chief Executive and, in accordance with TS Section 6.5.2.9, receives reports and advice from the NRB.

The Bohrd of Directors receives reports from the NRB through the NCB.

We have therefore concluded that having the NCB and the Executive Vice President-Nuclear available to advise the Office of the Chief j !

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Dockot No. 50-353 f

License No. NPF-85 I

Executive will assure sufficient corporate management involvement in nuclear plant safety.

Proposed change $2 assigns a more appropriate level of corporate management as the recipients of NRB audit reports.

We i

propose that the audit reports be forwarded to Corporate Officers responsible for the areas audited rather than to the Executive Vice President-Nuclear.

The Corporate Officers have a closer proximity to the sources of problems and therefore can take prompt corrective actions.

This proposed change will not lessen i

the awareness of the Executive Vice President-Nuclear.

If NRB audit findings are not satisfactorily addresned by the Corporate l

Officers, the NRB may inform the Executive Vice President-Nuclear I

through its normal communication channel as defined in TS Section 6.5.2.1.

j Proposed change #3 reflects the deletion of the f

corporate ISEG.

The deletion of the corporate ISEG requitec that l

the two dedicated full time corporate ISEG engineers be transferred to the LGS ISEG group.

This chinge is reflected in paragraph 6.2.3.2.

Additionally, as a result of this change, the position of ISEG Manager is delet.ed and the LGS ISEG now reports 1

to the General Manager - Nuclear Quality Assurance, as reflected l

in TS paragraphs 6.2.3.2 and 6.2.3.4.

This change does not diminish the effectiveness of the ISEG as the ISEG Superintendent l

ultimately reports to the General Manager - Nuclear Quality i

Assurance.

Proposed change #4 deletes unnecessary detail from the I

TS.

Nevertheless, the PORC will continue to review the ODCM as required and perform the necessary safety review for LGS.

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Proposed change #5 is proposed to eliminate unnecessary i

detail from TS.

Specifically, the listing of these titles i

requires PECo to obtain prior NRC approval of a TS change when i

making ininor administrative changes to the organization, such as position title revisions.

Replacing these specific titles with an appropriate position description and along with the administrative control requirements being added to TS paragraph 6.2.1.a, maintains the same level of control of the working hours of the unit staff.

This change is consistent with the philosophy of GL 88-06.

Information Supporting a Finding of No Significant Hazards Consideration - Category

'B' An example (Example 1) provided by the NRC of a change involving no significant hazards consideration, as stated in 51 FR 7751, is " purely administrative change to the TS."

The proposed changes contained in Category

'B' conform to this.

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L Dockct No. 50-353 License No. NPP-85

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example and we have concluded that they do not constitute a f

significant hasards consideration as explained below.

I (1)

The proposed Category

'B' miscellaneous changes do f

not involve a significant increase in the probability or consequences of an accident i

previously evaluated.

i Sufficient corporate management involvement in nuclear plant safety will be maintained with the elimination of the direct reporting requirement of the NRB to the Office of the Chief Executive.

The Office of the Chief Executive will be made i

aware of NRB activities by the Nuclear Committee of the Board I

through the Board of Directors and by the Executive Vice i

President-Nuclear.

Designating Corporate Officers responsible for the areas I

audited instead of the Executive Vice President-Nuclear as the recipients of NRB audit reports is a more appropriate initial level of review.

The Corporate Officers have a closer proximity to the sources of problems and therefore can take prompt corrective actions.

If NRB audit findings are not satisfactorily addressed by the Corporate Officers, the NRB may inform the Executive Vice President-Nuclear through its normal communication channel as defined in TS Section 6.5.2.1.

i Chapter 15 of the LGS FSAR has been reviewed.to determine the effect of the proposed administrative changes on i

previously evaluated accidents.

We have determined that the accident analyses in Chapter 15 of the PSAR are not affected by the proposed miscellaneous changes.

For this reason, as well as the reasons presented above, we have concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

t (2)

The proposed Category

'B' miscellaneous changes do c

not create the possibility of a new or different kind of accident from any previously evaluated.

1 The implementation of these miscellaneous changes will not affect the interpretation or intent of the TS that they involve.

These changes are purely administrative and do not involve any hardware changes or plant modifications.

Therefore, these changes will not create the possibility of a new or different kind of accident from any previously evaluated...

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Dockot No. 50-353 License No. NPP-85 Y1 (3) the proposed Category _'B' miscellaneous changes do not involve a significant reduction in a margin of safety.

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The administrative nature of these changes will not impact plant systems or operation.

For this reason, as well as I

the reasons presented in the Safety Assessment and in response to item 1 above, we have concluded that these changes will not

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involve any significant reduction in a margin of safety.

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Information Supporting an Environmental Assessment i

An environmental assessment is not required for the

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changes proposed by this Change Request because the changes i

conform to the criteria for " actions eligible for categorical l

exclusion" as specified in 10 CPR 51.22(c)(9).

The proposed changes do not involve any systems that have a direct relationship with the environment.

This Change Request involves i

no significant. change in the types or significant increase in the

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amounts of any effluents that may be released offsite and there l

will be no significant increase in individual or cumulative occupational radiation exposure.

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Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and i

have concluded that they do not involve unreviewed safety questions and will not endanger the health and safety of the public.

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List of Proposed Change 1 1

f Section Affected Proposed Chang's Page xxvi Change title "Offsite" to j

(

"OFFSITE AND ONSITE ORGANIEATION."

1 Designate Figures 6.2.1-1 l

and 6.2.2-1 as deleted.

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i Renumber page 6-1 to l

6-2 for Unit Staff and make i

Unit Staff all capitals.

Page 6-1 Paragraph 6.2.1 Change title "OFFSITE" to j

"OFFSITE AND ONSITE ORGANIEATIONS."

Delete existing sentence I

6.2.1 and add specifications i

6.2.1.a through 6.2.1.d as recommended in GL 88-06.

Paragraph 6.2.2 Delete "The unit organization f

shall be as shown on Figure l

6.2.2-1 ands" (Now on page 6-2).

Delete "and" from end of 6.2.2.e (now on page 6-2).

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Paragraph 6-2 Figure 6.2.2 Revise paragraph 6.2.2.f to remove references to superintendents and add "and" to end of 6.2.2.f l

(6.2.2.f is now on Page 6-3).

l Page 6-3 Figure 6.2.1-1 Delete the Nuclear Management Organizational Chart.

Include overflow I

words from old page 6-2 for " Unit Staff".

Paragraph 6.2.2 Add 6.2.2.g as recommended in GL 88-06.

Page 6-4 Figure 6.2.2-1 Delete the Organization for Conduct of Plant Operations Chart.

Page 6-6 Paragraph 6.2.3.2 Change the word "three" i

to "five" and delete the description of qualifications for Corporate ISBG engineers.

Change

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" Independent Safety Engineering

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Manager" to " General Manager-Nuclear Quality Assurance."

Change "ISEG Supervisor" to "ISEG Superintendent".

Paragraph 6.2.3.4 Change " Independent Safety Engineering Manager" to " General Manager-Nuclear Quality Assurance".

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P g] 6-9 i

Paragraph 6.5.2.1 Remove "and the Office of the i

Chief Executive."

Page 6-12 Paragraph 6.5.2.9.c Replace " Executive Vice President

-Nuclear" with " Corporate Officer (s)"

i and delete "to the " from in front of i

management positions.

I Page 6-22 l

Paragraph 6.14.2 Delete reference to " Engineer-In-Charge, Nuclear and Environmental Section."

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