ML20249B688
| ML20249B688 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/11/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20249B687 | List: |
| References | |
| NUDOCS 9806240057 | |
| Download: ML20249B688 (4) | |
Text
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'4 UNITED STATES p
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NUCLEAR REGULATORY COMMISSION "o
WASHINGTON, D.C. 3000H001
%, * * '***p SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.128 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO.126 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323
1.0 INTRODUCTION
By application dated April 13,1998, as supplemented by [[letter::DCL-98-066, Suppl to LAR 98-04 to Licenses DPR-80 & DPR-82,replacing Requirement for Operations Manager to Hold SRO License W/ Allowance,Operations Middle Manager Hold SRO License & Responsible for Directing Work of Shift Personnel|letter dated May 1,1998]], Pacific Gas 4
and Electric Company (PG&E or the licensee) requested changes to the Technical Specifications (Appendix A to Facility Operating License Nos. DPR-80 and DPR-82) for the Diablo Canyon Nuclear Power Plant, Units 1 and 2. The proposed changes change the combined Technical Specifications (TS) for the Diablo Canyon Nuclear Power Plant (DCPP),
Units 1 and 2 to revise TS 6.2.2, Plant Staff and TS 6.3, Plant Staff Qualification. The proposed change to TS 6.2.2g revises the title of the Operations Manager to Operations Director, amends the requirement for that position to hold a senior reactor operator (SRO) license, and adds the position of Operations Middle Manager. The submittal also proposed changes to TS 6.3, taking exception to ANSI /ANS 3.1 -1978 for the Operations Director.
The May 1,1998, supplemental letter provided additional clarifying information and did not change the initial no significant hazards consideration determination or expand the scope of the original Federal Register notice, publishod on May 6,1998 (63 FR 25116) 1 2.0 EVALUATION The staff evaluated the licensee's submittal of April 10,1998, the relevant criteria in NUREG-0800, " Standard Review Plan," Section 13.1.1, " Management and Technical Support Organization," and Section 13.1.2-13.1.3, " Operating Organization" and the applicable American National Standards Institute (ANSI) standards.
I The licensee proposed to revisa their commitment to the ANSI requirements contained in TS 6.3 by adding an exception for the position of Operations Director. PG&E's commitment to ANSI N18.1-1971 requires the Operations Manager (fulfilled by the position of Operations Director at DCPP) to hold an SRO license at the time of appointment to the active position.
i This exception would allow the Operations Director, in lieu of meeting the N18.1 requirement of holding an SRO license, to (1) hold an SRO license at the time of appointment, (2) have held a 9806240057 990611 PDR ADOCK 05000275 P
... license at a pressurized water reactor, or (3) be certified for equivalent SRO knowledge. This approach is supported by ANSl/ANS 3.1-1987 and 3.1-1993, *American National Standard for Selection, Qualification, and Training of Personnel for Nuclear Power Plants," which allow individuals to be appointed to the position of Operations Manager based on the options proposed by PG&E for TS 6.3. The 1987 and 1993 standards further state that if the
' Operations Manager does not hold an SRO license then the Operations Middle Manager shall hold an SRO license.
l The licensee proposed a concurrent chance to TS 6.2.2g to support the revision to TS 6.3. In
- their submittal, the licensee described a proposed change to the operating organization that establishes a position in the direct chain-of-command of the Operations organization. The licensee has described the position as "similar to the Operations Middle Manager position described in ANSI /ANS 3.1-1993, Section 4.3." The licensee further described the position as off-shift and requiring an SRO license. The April 10,1998, submittal contained draft
- organizational charts showing the reporting relationships that will exist with the implementation of the proposed changes. The position of Operations Middle Manager will report directly to the Operations Director and will have the on-shift shift supervisors as direct reports.
Part 50.54(1) of 10 CFR requires that the individuals designated by a licensee to direct the licensed activities of licensed operators shall be licensed as a senior operator. The licensee stated in its submittal that the proposed change continues to meet this requirement by ensuring i
the Operations management personnel directing the activities of licensed operators maintain the appropriate qualification.
The staff concludes that TS 6.2.2g, requiring that either the Operations Director or the Operations Middle Manager hold a DCPP SRO license is consistent with the requirements of 10 CFR 50.54(1) and ensures that a licensed off-shift senior operator will direct the licensed activities of the licensed operators. Further, requiring an ANSI /ANS qualified and licensed i
Operations Middle Manager when the Operations Director does not hold a DCPP SRO license is consistent with the requirements of ANSI N18.1 1971 and ensures there is site-specific detailed relevant technical and systems knowledge in a senior operations management position.
In the [[letter::DCL-98-066, Suppl to LAR 98-04 to Licenses DPR-80 & DPR-82,replacing Requirement for Operations Manager to Hold SRO License W/ Allowance,Operations Middle Manager Hold SRO License & Responsible for Directing Work of Shift Personnel|May 1,1998, letter]], the licensee proposed amended wording for TS 6.2.2g to clearly establish that the Operations Middle Manager position will be filled by a single individual.
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Further, by using the term " Operations Middle Manager," a term used in the ANSI standard, to reference the position which must hold the license, the licensee provided an adequate description for identifying that position within the organization regardless of the title assigned by the licensee.
The staff concludes that the proposed modifications to the Diablo Canyon Power Plant TS
- 6.2.2g and TS 6.3 modifying the commitment to ANSI N18.1-1971 for the Operations Manager,
' is consistent with and meets the intent of the relevant review criteria and is, therefore, acceptable, I
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3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
These amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categoncal exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
l 5.0 -
PUBLIC COMMENTS l
' In response to the initial notice of this proposed amendment published in the Federal Register on May 6,1998, the Commission received a letter from a member of the public about this proposed change to the TSs. The individual requested that the NRC reject the proposed amendment for the following reasons: deleting the requirement to have the Operations Section Director be a holder of an SRO license would undermine credibility and compatency of the position; assigning an individual to the job with an SRO license from a different pressurized
{
water reactor (PWR) design does not meet NRC licensing criteria; having a middle manager with 1
an SRO license reporting to the Operations Section Director insulates the Director's accountability; the amendment request is not in accordance with applicable American National Standards Institute (ANSI) standards; and the proposed structure is not in the interest of public health and safety. Although the comments were not directly related to the no significant hazards determination, the staff has decided to address the comments.
The credibility and competency of a particular position is based on the performance of the assigned individual which is addressed by inspections and other evaluations performed by the Commission and is beyond the scope of the evaluation of this license amendment. Having held an SRO applicable to another PWR design is an acceptable attemative for appointment to the position of the Operations Section Director (ANSI title Operations Manager) under ANSI 3.1, 1993, Section 4.2.2, "Special Requirements." The middle manager position and its organizational relationships to the Operations Section Director and the Shift Supervisors is consistent with ANSI standards and is consistent with the requirements of 10 CFR 50.54(l).
Accountability of the operations middle manager position is a performance issue also outside the scope of the evaluation of this amendment.- As discussed above in this safety evaluation, the staff has determined that the specific changes proposed by the licensee are indeed consistent with ANSI standards. The comment that the proposed structure is not in the interest of public health and safety is not supported by the staff review, as reflected in Section 2.0 above.
The staff has considered the comments received from this' individual and finds that they do not change its no significant hazards determination, its safety finding, and its conclusion that the proposed TSs change is acceptable.
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6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the l
common defense and security or to the health and safety of the public.
1 Principal Contributor: M. Biamonte. NRR Date: June 11, 1998 1-
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