Removal of Organization Charts from Technical Specification Administrative Control Requirements (Generic Letter No. 88-06)

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D.C. 20555

                               MARCH 22, 1988

TO ALL POWER REACTOR LICENSEES AND APPLICANTS 

SUBJECT:  REMOVAL OF ORGANIZATION CHARTS FROM TECHNICAL SPECIFICATION 
          ADMINISTRATIVE CONTROL REQUIREMENTS (Generic Letter 88-06) 

Typically onsite and offsite organizations are defined by organization 
charts included under administrative control requirements of the Technical 
Specification (TS). This requires the processing of a license amendment to 
change an organization chart before implementing a change in organizational 
structure. The guidance provided in this Generic Letter addresses amendments
that may be proposed for removing organization charts from the 
administrative control requirements of the TS. 

The staff has determined that with appropriate changes to these 
administrative control requirements, the onsite and offsite organization 
charts may be removed. The changes involve the addition of general 
requirements that capture the essential aspects of the organizational 
structure that are defined by existing onsite and offsite organization 
charts. Enclosure 1 provides guidance for license amendment requests to 
remove organization charts from TS. 

Enclosure 2 provides an example of this change that was made to the 
administrative control requirements of the existing Westinghouse Standard 
Technical Specifications (STS). The staff has found that this change will 
not reduce plant safety and it is generically applicable to all power 
reactors. 

The removal of organization charts is a line item improvement that was 
proposed on a lead-plant basis for the Shearon Harris plant and was endorsed
by the Westinghouse Owners Group. This change was reviewed as part of the 
NRC's program for improvements in TS. The objectives of that program were 
established by the Commission's Interim Policy Statement on Technical 
Specification Improvements. The staff concludes that the removal of 
organization charts from TS will provide greater flexibility for licensees 
to implement changes in both the onsite and offsite organizational 
structure, consistent with Commission policy. 

Licensees and applicants are encouraged to propose changes to their TS that 
are consistent with the guidance provided in Enclosure 1. Proposed license 
amendments conforming to this guidance will be reviewed and approved quickly



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by the appropriate Project Manager while those that deviate from this 
guidance will require a more detailed review. If you have any questions on 
this matter, please contact the Project Manager for your facility. 

                                   Sincerely, 


                                   Frank J. Miraglia 
                                   Associate Director for Projects 
                                   Office of Nuclear Reactor Regulation 

Enclosures:
As stated

                                                           Enclosure 1 

                GUIDANCE FOR REMOVAL OF ORGANIZATION CHARTS 
                      FROM TECHNICAL SPECIFICATIONS 

INTRODUCTION 

This enclosure provides guidance for the preparation of license amendments 
for the removal of onsite and offsite organization charts from Technical 
Specifications (TS). It involves the addition of general requirements that 
capture the essential aspects of the organizational structure that are 
defined by existing organization charts. 

This guidance was developed by the NRC staff based on its review of a lead-
plant proposal submitted on the Shearon Harris docket and endorsed by the 
Westinghouse Owners Group. The benefit of this proposal is that it would 
permit a licensee to implement changes to the structure of the offsite or 
onsite organizations without first having to obtain NRC approval through the
issuance of a license amendment to update organization charts in TS. 

DISCUSSION 

The staff examined the regulatory requirements for administrative control's 
in TS provided in 10 CFR 50.36. This regulation state's that administrative 
controls are the provisions relating to organization and management 
necessary te ensure operation of the facility in a safe manner. It has been 
the staff's experience that organization charts by themselves have been of 
little help in ensuring that the objectives of administrative control 
requirements are met. Specific operational requirements are required 
elsewhere in TS that bear more directly on operational safety than 
organization charts. As examples, the organizational element responsible for 
the control room command function is identified separately in TS, as are the 
requirements for minimum staffing under various operating conditions. The 
organizational management functions for independent reviews and audits, unit 
review and independent safety engineering groups, and shift technical 
advisors are specified in other TS. 

In summary, many of the details shown on the onsite and offsite organization
charts are not essential to the safe operation of the facility. Over the 
years, the staff experience with changes in the details of operating 
organizations has shown that organization charts can be modified in many 
ways while maintaining adequate operational safety. This experience has 
enabled the staff to distill those organizational characteristics which are 
important to safety. The staff finds that the organization charts which are 
important to safety, are not covered by other specifications, and must 
remain in TS are those conditions listed below. 

(1)  A requirement that lines of authority, responsibility, and 
     communication shall be established and defined from the highest 
     management levels through intermediate levels to and including all 
     operating organization positions. Those relationships shall be 
     documented and updated, as appropriate, in the form of organization 
     charts, functional descriptions of departmental responsibilities and 
     relationships, and job descriptions for key personnel positions, or in 
     equivalent forms of documentation. 


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(2)  Designation of an executive position that has corporate responsibility 
     for overall plant nuclear safety and authority to take such measures as
     may be needed to ensure acceptable performance of staff in operating, 
     maintaining, and providing technical support to the plant to ensure 
     nuclear safety. 

(3)  Designation of a management position in the onsite organization that is
     responsible for overall unit operation and has control over those 
     onsite activities necessary for safe operation and maintenance of the 
     plant. 

(4)  Designation of those positions in the onsite organization that require 
     a senior reactor operator (SRO) or reactor operator (RO) license. 

(5)  Provisions of sufficient organizational freedom to be independent of 
     operational pressures to those individuals who perform the functions of
     health physics, quality assurance, and training of the operating staff.

Since the above conditions will be maintained in the TS, removal of the 
organization charts represents no reduction in current safety requirements. 
These changes will simply allow licensees to implement changes in their 
organization structure without obtaining NRC approval. 

The licensee or applicant must ensure that the organizational information 
described in (1) above is incorporated in a document (Final Safety Analysis 
Report, Quality Assurance Plan, or other appropriate document) to be 
referenced in the revised TS before the amendment to remove the organization
charts is proposed. 

The qualifications for certain positions are currently designated by 
organization charts as requiring a SRO or RO license. If these requirements 
are not currently specified in TS outside of the organization charts (such 
as the minimum shift crew composition, they should be added to an 
appropriate specification. 

Finally, the plant TS should be examined for additional references to the 
organization charts. Where such references are included in administrative 
control requirements, they must be replaced by an appropriate functional 
description of the requirement that was defined by the organization charts. 

As guidance on the format of the changes discussed above, an annotated copy 
of the Standard Technical Specifications for Westinghouse plants is provided
as Enclosure 2 with (1) deleted material shown in strike out text and (2) 
additions to existing requirements shown underlined. On a plant-specific 
basis, the form of proposed changes may differ from this guidance to the 
extent that differences may exist in the titles or names of various 
positions or the enclosed example. 

SUMMARY 

The removal of the organization charts from the TS will entail the addition 
or modification of existing requirements as noted above. If the FSAR or 
Quality Assurance Plan, or other appropriate documentation does not 
currently contain organization charts to at least the level of detail as 
shown on those which are 


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proposed to be removed from the TS, the licensee or applicant should first 
complete that action which will ensure that this organization information is
included in appropriate documentation. 

Any question on this matter should be directed to the Project manager for 
your facility.