Removal of Organization Charts from Technical Specification Administrative Control Requirements (Generic Letter No. 88-06)
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
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.
Frank J. Miraglia
Associate Director for Projects
Office of Nuclear Reactor Regulation
GUIDANCE FOR REMOVAL OF ORGANIZATION CHARTS
FROM TECHNICAL SPECIFICATIONS
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.
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
(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
(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
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.
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
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
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