Text

License Amendment Request to Reflect Changes to Organization, Unit Staff Responsibility, Unit Staff Qualifications, Programs and Manuals, and High Radiation Area
	ML14212A502
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	07/21/2014
From:	Waldrep B; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-14-0001
	Download: ML14212A502 (61)
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10 CFR 50.90 July 2-1, 2014.

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001.

CATAWBA NUCLEAR STATION, UNITS I AND 2 DOCKET NOS.. 0,413, 50."14/ RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369,50-370 / RENEWED UCENSE NOS. NPF-9 AND NPF-17 OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3 DOCKET'NOS.60-269, 50-270,50-287/ RENEWED LICENSE NOS. DPR-38, DPR-47 AND DPR-56

SUBJECT:

LICENSE AMENDMENT REQUEST TO REFLECT CHANGES TO ORGANZAO110N, UNIT STAFF RESPONSIBILUTY, UNIT STAFF QUALFICATIONS, PROGRAMS AND MANUALS, AND HIGH RADIATION A.

.AN Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy hereby submits a request for an amendment to Technical Specifications (TSs) of the Renewed Facility Operating Licenses (FOL) for Catawba Nuclear Station (CNS), Units I and 2; McGuire Nuclear Station (MNS), Units I and 2; and Oconee Nuclear Station (ONS), Units 1, 2 and 3. Specifically, Duke Energy is requesting the Nuclear Regulatory Commission's (NRC's) approval to revise TS Sections 5.1, "Responsibility';

5.2, =Organization"; 5.3, "Unit Staff'Qualifications'; 5.6, uPrograms and Manuals; and for CNS and MNS, Section 5.7, "High Radiation Area."

The primary'proposed change described in this License Amendment Request (LAR) will update the licensed operator training requiremnents to be consistent with the National Academy for Nuclear Training (NANT) program which is based on a systematic approach to training.

Additional administrative changes are proposed in TS Sections 5.1, "Responsibility'; 5.2,

'Organization"; 5.3, "Unit Staff Qualificationsr; 5.5, uPrograms and Manuals"; and for CNS and MNS, Section 5.7, "High Radiation Area." One of the proposed administrative changes is in accordance with NRC approved Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-258-A, "Changes to Section 5.0, Administrative Controls."

The Enclosure provides a detailed evaluation of the proposed changes.

U.S. Nuclear Regulatory Commission RA-14-0001 Page 2 Attachments 1, 2 and 3 contain TS Markups for Catawba, McGuire and Oconee, respectively.

Attachments 4, 5 and 6 contain the retyped TS pages for Catawba, McGuire and Oconee, respectively.

Duke Energy requests that this proposed LAR be reviewed and approved within one year of the date of submittal, and that,120 day implementation period be granted. Revision to each station's UFSAR:ff be made in accordance with 10 CFR 50.71(e).

There are no regulatory commitments contained in this letter.

Pursuant to 10 CFR 50.91, a copy of this proposed LAR is being provided to the appropriate officials of the States of North Carolina and South Carolina.

If you have any questions concerning this letter, or require additional information, please contact Julie Olivier at 980-373-4045.

I declare under penalty of perjury that the foregoing Is true and correct. Executed on T1 J

0

Sincerel, Benjamin C. Waldrop,'V Nuclear Corporate Governance and Operations Support JL.V;

Enclosure:

Evaeuation of.the Proposed Change Attachments.:"

1. -Catawa Technical SpecIficton Marked Up Pages

2. McGulre Technical Specification Marked Up Pages

3. Oconee Technical Specification Marked Up Pages

4. Catawba Technical Specification Retyped Pages

5. McGuire Technical Specification Retyped Pages

6. Obnee Technical Specification Retyped Pages

U.S. Nuclear Regulatory Commission RA-14-0001 Page 3 xc:,

V.M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 R. Hall, Senior Project Manager (ONS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop8 81 I Rockville, MD 20852-2738 E.G. Miller, Project Manager (CNS & MNS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 GOA Rockville, MD 20852-2738 E.L. Crawe, NRC Senior Resident Inspector' Oconee Nuclear Station G.A. Hutto, III NRRC Senior Resident Inspector Gatawba Nuclear Station JiZeiledr NRC Senior Resident Inspector McGuire Nuclear Station S.E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management SC Dept. of Health and Env. Control 2600 Bull St.

Columbia, SC 29201 W.L. Cox, Ill, Section Chief Div. of Environmental Health, RP Section NC Dept. of Env. & Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission RA-14-0001 Page4.

bxc:

Chris Nolan Julie Olivier Robert Pope ELL File: (Corporate)

Jeff Robertson..

P.T. Vu KL. Crane (For MNS Licensing/Nuclear Records)

MNS Master File 801.01 - MG02DM Chris Wasik Stephen Newman Tom Ray Ed Burchfleld' Bob Guy Terry Patterson Sandy Severance Don Legrand J.E. Smith (For ONS Licensing/Nuclear Records)

ONS Master File 801.01 -- ON03DM, Randy Hart Tolani Owusu NCMPA-1 PMPA NCEMC' CNS Master File 801.01 - CN04DM T.K Pasour (For CNS Licensing/Nuclear Records)

Enclosure Evaluation of the Proposed Change RA-14-0001 Evaluation of the Proposed Change Subjoct License Amendment Request to Reflect Changes to Organization, Unit Staff Res"Oonsibility, Unit Staff Qualifications, Programs and Manual*,',adlgh Radiati~on MnaleadHih 1.0

SUMMARY

DESCRIPTION 2.0 DETAILEE DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

.4.1 Applicable Reguatory Req'uirements/Cdiera 4.2 Precedent 4.3 "No Signhfltnt Hazards Consideration Determination 4.4 Conc*luslon*'

5.Q ENVIRONMENTAL, CONSIDERATION

6.0 REFERENCES

page I Of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 1.0

SUMMARY

DESCRIPTION This evaluation sUpports a request to revise requirements in TS 5.3 that have been superseded based on licensed operator training programs being accredited by the National Academy for Nuclear Training (NANT) and promulgation of the revised 10 CFR 55, "Operators' Licenses,"

which became effective on March 25, 1987.

Additionally, this evaluation supports arequest to revise the Catawba (CNS), McOuire (MNS),

and Oconee (ONS) Administrative Controls Section of Technical Specifications (TSs) to reflect several proposed-changes to onsite and offeite staff titles. The proposed changes more accurately reflect current staff nomenclature and responsibilities, and will achieve organizational consistency within the Duke Energy fleet. The proposed changes are administrative in nature and follow Standard Technical Specifications (STS). One of the proposed administrative changes seeks to,revise the Administrative Controls Section of TSs in accordance with Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler, TSTF-258-A, "Changes to Section 5.0, Administrative Controls" (Reference 13).

2.0 OETAILED DESCRIPTION The following is a list of the proposed TS revisions, as well as the detailed description of the changes.

2.1 Technca S co(TrS§ Section

1.

i.Administrative Conts - Rso*gonbilitv" CNS,-TS 5.1, Responsibility, is revised In Afttcment I as follows:

a. The tUse of Station Manager is replaced with Plant Manager to reflect the current organization..

b. The proposed changes.replace the title of Shift Supervisor (SS) wt Control Room Supervisor (CRS). All functions of the SS contained In TS Section 5.1.2 are in the context of having the command and control of the control room. This function is owned itn the current operations organization by the CRS. Also, the proposed changes replace the title of Shift Work Manager with Shift Technical Advisor (STA),

as the Shift Work Manager position has become obsolete. The proposed changes also add the term urelief" to describe the Senior Reactor Operator (SRO) who relieves the CRS so as to emphasize that this person is temporarily relieving the CRS.

c. The proposed changes add a requirement for the STA SRO license to be active when the STA assumes the control room command function.

d. In part b of TS Section 5.1.2, "SRO duties" is replaced with "CRS duties" for clarity since the section is in the context of the Control Room Supervisor having command and control of the control room.

Page 2 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 MNS - TS 5.1, Responsibility, is revised in Attachment 2 as follws:-

e. The title of Station Manager Is replaced with Plant Manager to reflect the current organization.

f. The term 'Reportability" in the header is corrected to read "Responsibility."

g. The nomenclature change from the obsolete title of Control Room SRO (CRSRO) to the CRS is made. A requirement is added for the STA SRO license to be active when the'STA assumes the control room command function.

h. In part bofTS Section 5.1.2, "SROduties" isreplacedwith CRSduties" for clarty since the section is in the context of the Control Room Supervisor having command and control of the control room.

ONS - TS 5.1, Responsibility, Is revised in Attachment 3 as follows:

I. The title of Station Manager is replaced with Plant Manager to reflect the current organization.

j.

New Section 5.1.2 Is added to the ONS TS. This is Identical to the first paragraph contained in the MNS and CNS TS with the updated staff titles of Control Room Supervisor and Shift Technical Advisor.

2.2 TS Section 5.2: "Administrative Controls - Ojnization" CNS, MNS and ONS - TS 5.21, ROnsite and Offsite Organizations" are revised in Attachments 1, 2 and 3, respectively as follows:

a. The title of Station Manager is replaced with Plant Manager to reflect the current organiation.

b. Parts c and d of Duke Energy's TSs have been modeled after Part c of Standard Technical Specifications (STS). These two parts are currently redundant in that both the Site-andGroup Vie Presidentt have corporate responsibility for overall nuclear safety. To correct this, the proposed changes delete "corporate" from Part c to denote that the corporate-responsibility is with the senior nuclear 'executive in Part d.

Next, Part d is currently outdated due to Duke Energy corporate reorganization. The proposed changes replace "Group Vice President Nuclear Generation Department" in ONS and MNS with "Chief Nuclear Officer."

Page 3 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 ONS - TS 5.2.1, "Onsite and Offsite Organizations": is revised in Attachment 3 as follows:

C.- The term "health physics" in TS 5.2.1.e is replaced with "radiation protection" to reflect the terminology currently being used and also to be consistent with other areas of ONS TS.

CNS - TS 5.2.2,-wUnit StWff Is revised in Attachment I as follows:

d. In Part f, the title of Operations Superintendent is replaced with Operations Manager, the title of Shift Operations Manager Is replaced with Assistant Operation Manager

- Shift, the tide of Shift Supervisor Is replaced with Shift Manager and the title of Assistant Shift Supervisor is replaced with Control Room Supervisor. These titles reflect the current organization,.

e. In Por g, the Shift Technical Advisor (STA), who had supported the SS, now provides advisory technical support to the Shift Manager. The Shift Work Manager is changed to STA. Also, the last sentence In Part g is changed to "In addition, the STA shall meet the qualifications specifed by the Commission Policy Statement on Engineering Expertise on Shift."

MNS., TS 5.2.2, 'Unit Staff is revised in Attachment 2 as follows:

f. In Part g, the Shift Technical Advisor (STA), who had supported the CRSRO, now provides advisory technical.support to the Shift Manager.

ONS TS 5.2.2, "Station Staff' Is revised In Attachment 3 as follows:

g.. The heading of "Station Staff is being replaced with "Unit Staff" as this is representative of the term used at ONS, as well as the term specified in MNS and CNS.TS.

h. An introductory statement, "Th unit staff organization shall include the following:" Is inserted prior to Part a. This is an administrative change and epresentativ of what is currently in STS, MNS TS and CNS TS.

I. In Part f, the title of Operations Superintendent is replaced with Operations Manager and the title of Shift Operations Manager is replaced with Assistant Operations Manager - Shift These titles reflect the current organization.

In Part g, the Shift Technical Advisor (STA), who had supported the SS, now provides advisory technical support to the Shift Manager. The Shift Work Manager is changed to STA. The last sentence is changed to "In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift."

Page 4 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 2.3 TS 5.3. "AdminltiveControis Unit Staff Qafications" CNS and MNS - TS 5.3, "Unit StWff Oualificatons" are revised in AftAchments 1 and 2 respectively as follows:

a. The notation ":" is Sdded. after."exce for clart and the phrase."the Radiation Protection Manager; who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 19765 Is itemized as number 1.

b. The following sentence is added and itemized as number 2: "The education and experience eligibility requirements for license operators shall meet or exceed the guidelines outlined by the National Academy -for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated Into applicable station training procedures." These education and experience eligibility requirements correspond to those contained in the current version of the NANT ACAD document as described in Section 2.3.1.

c. Section.5.3.2 is added as follows in accordance with TSTF traveler TSTF-258-A (Reference 13): "For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1,. peotobi the functions described in 10 CUR 50.4(m)." Adding paragraph 5.3.2 ensures that them is no.

misunderstanding when complying with IO CFR 55.4 requirments which state in part-Actively performing the functions of an operator.or senior operator means that an individual has a position on the shift crew:#tha requires the Individual to be licensed as defined in the facility's technical specificaftis, and that...."

ONS W TS 5.3, Station Staff Qualificions' is revised in Attachment 3 as foIows

d. The trms "Station Staff' and u"station staff' in 5.3 and 5.3.1 are changed to "Unit Staff" and "unit staff" respectively.. This terminology change is for consstency within the fleet...

e. The phrase Ixr the Operations Superintendent and the Shift Operations Manager." is deleted and the notation ":" sadded after "except" for clarity...

f. The title of "Operations Superintendent" is replaced with "Operations Manager" to reflect the current organization. The following sentences are itemized as number 1:

"The Operations Manager shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis."

Page 5 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001

g. The title of "Shift Operations Manager" is replaced with "Assistant Operations Manager - Shift" to reflect the current organization. The following sentences are itemized as number 2: "The Assistant Operations Manager - Shift shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training on a one-for-one time basis.'

h. The following new sentence is added and itemized as number 3: 'The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures." These education and experience eligibility requirements correspond to those contained in the current version of the NANT ACAD document as described in Section 2.3.1.

i. New'Section 5.3.2 is added as follows in accordance with TSTF traveler TSTF-25W-A (Reference 13): "For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting themrequirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).' Adding paragraph 5.3.2 ensures that there is no misunderstanding when complying with 10.CFR 55.4 requirements which state in part "Actively performing the functions of an operator or senior operator means that an individual has a position on the shift crew that requires the individual to be SidenSed as defined in the facility's technical-specifications, and that..."

2.3.1 Further ClarQft of Chanas to TS Section 5:3.1 On March 20, 1985, the NRC issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (Refereice 5), which ervdorsed the training ccreditation program developed by theInStitute for NuclearPower Operations (INPO), in association with NANT. Subsequently, in6 Generic Letter (QL) 87-07 (Reference 6) and NUREG 1262 (Reference 8), the NRC indicated it would accept a licensee's licensed operator training program if it Is accredited and based on a systems approach to training. This accreditation obviates the need'to conform to the guidance of either Regulatory Guide (RG) 1.8, Revision I (Reference 8) or ANSI N18.1-1971 (Reference 9) for licensed operators. As an alternative, the accreditation may be superseded by INPO (NANT) accreditation in accordance with the revised 10 CFR 55.31 and licensees may submit a*-r*uest to the NRC for an adrnistrative ochage to their TS to revise or delete, as appropriate, the TS requirements that have been superseded.

On January 18, 2001, the NRC issued Regulatory Issue Summary (RIS) 2001-01, "Eligibility of Operator License Applicants," (Reference 10), to familiarize licensees with the NRC's current guidelines for the qualification and training of Reactor Operator (RO)

Page 6 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 and Senior Operator (SO) license applicants. This RIS again acknowledges that a...the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that is based on a systems approach to training..." consistent with 10 CFR 55.31(e)(4), as amended on March 25,1987. The RIS further makes the following statement S... a facility licensee's training program would be considered approved by the NRC when it is accredited by the National Nuclear Accrediting Board (NNAB).n Many licensees have been implementing the education and experience guidelines endorsed by the NNAB by voluntwlly~obtaining and periodically renewing the

-accrediltation of their licensed operator training program. The current version of these guidelines Is outlined by-the NANT Document ACAD, "Guidelines for Initial Training and Qualification of Licensed Operators."

The staff has encouraged facility licensees to review their requirements and commitments with regards to RO and SO education and experience and to update their documentation (e.g., Final Safety Analysis Report Technical Specifications and training program descriptions) to enhance consistency and minimize confusion. To accomplish this, in padt, Duke-Energy is proposing changes to TS 5.3.1 to clarify education and

experiince eligibility requirements for licensed operators.

2.4.

TB Section 5.5..Administratve Controls - Proorams and Manuals" CNS, MNS and ONS - TS 5.5.1, "Ofisite Dose Calculation Manual (ODCM)" are revised in Attachments 1, 2 and 3, respectively as follows:

a., The title of Station Manager-is replaced with Plant Manager to reflect the current organizattion.

b. Part b currently states that 'Licensee initiated changes to the ODCM: Shall become effective after theapproval of the Station Manager,..." The phrase 'or Radiation Protection Mariager" is added after Station. (Plant) Manager to be consistent with Duke Energy Carolinas Topical Report, Quality Assurance Program, Duke-I-A 2.5 TS Section 5.7. "Administrative Controls - High Radiation &0a0 CNS - TS 5.7.2, 'High Radiation Area" is revised In Attachment I as follows:

a. The title of Shift Supervisor is replaced with Shift Manager to reflect the current organization. The high radiation area door lock keys were under the administrative control of athe Shift Supervisor on duty or radiation protection personnel." This phrase Is changed to 'the Shift Manager, Radiation Protection Manager, or radiation protection personnel."

Page 7 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 MNS - TS 5.7.2, "High. Radiation Area' is revised In Attachment 2 as follows:

b. The title of Operations Shift Manager is replaced with Shift Manager to reflect the.

current organization.

3.0 TECHNICAL EVALUATION

Licensed operator qualifications and training can have an indirect impact on accidents previously evaluated. However, the NRC considered this impact during the rulemaidng process, and by promulgation of the revised 10 CFR 55 rule, determined that any such Impact remains acceptable when licensees have an accredited licensed operator.training program which is based on a systems approach to training. The NRC has concluded in References 11 and 12 that the standards and guidelines provided by INPO (NANT) in their training accreditati program are equivalent to those put forth or endorsed by the NRC. Therefore, maintaining a NANT accredited, systems based licensed operator training program IK equivalent to maintaining an NRC approved licensedoperator training program that conforms to applicable NRC Regulatory Guides or NRC endorsed industry standards.

The licensed operator qualifications and training program will continue to comply with the requirements of 10 CFR 55. The Duke Energy licensed operator training programs are accredited by NANT and are based on a systems approach.to training. Since the proposed Technical Specification (TS) changes are administrative In nature, they do not affect plant design, hardware, system operation or procedures.

Based on the discussion above,.fth proposed TS changes are consistent with 10 CFR 55 and do, not adversely impact nuclear safety or plant operations..

These changes are proposed in consideration of the guidance set forth in Regulatory Issue Summary (RIS) 2001-01, 'Eligibility of Operator License Applicants' which encourages licensees to update their documentation (including TSs) to current operator education and experience requirements. RIS. 2001-01 indicates that such a change to update:the plant licensing basis for eligibility: requirements:of operator.license applicants would be.oonsidered administrative in nature. Therefore, the aforementioned proposed changes to the T*s are acceptable.

A technical evaluation I unnecessary for the remaining changes -ince they are administrative changes only. In order to clarify these changes are non-technical in nature, detailed Justification of the more intricate changes to take place for each TS section is provided.below..

Sections 5.1, "Responsibility,' 5.2, "Vnit:Staff,' and 5.7, "High Radiation. Area,"' of the Administrative Controls section of CNS TSsrefer to a Shift Supervisor (SS) position. Section 5.1 and 5.2 of the MNS TSs refer to a Control Room Senior Reactor Operator (CRSRO) position. Section 5.2 of the ONS TSs refer to the same SS position that is in CNS TSs. Duke Energy proposes to replace references to the SS and CRSRO positions with the Control Room Supervisor in Section 5.1.2 and with the Shift Manager in Sections 5.2.2 and 5.7.2. The Control Page 8 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 Room Supervisor has responsibility for the control room command function within Section 5.1.2, while the Shift Manager Is to be advised by the Shift Technical Advisor (STA) within Section 5.2.2. MNS TS is currently the exception to the SS terminology, as during a previous MNS LAR Shift Supervisor was changed to CRSRO in Sections 5.1.2 and 5.2.2. Also, ONS does not have TS Section 5.7.2; therefore, changes are not applicable. These changes are proposed to reflect current operations shift nomenclature and responsibilities.

Section 5.1.2 of the CNS and MNS TSs currently state that the Shift Work Manager (CNS) or STA (MNS) shall be allowed to assume the control room command function and serve as the Senior Reactor Operator (SRO) In the control room on occasion when there is a need for both the SS and the SRO to be absent from the control room in MODE 1, 2, 3 or 4 provided, among other things, that the SS is available to return to the control room within 10 minutes. It is proposed to insert the words "the relief' immediately before "SRO" to clarify that this person is only temporarily relieving the SRO. It Is also proposed to replace the SS position In Section 5.1.2(a) of the CNS TSs with the phrase "CRS or the relief SRO." In Section 5.1.2(a) of the MNS TSs it is proposed to replace the CRSRO position with the CRS position.

Additionally, Sections 5.1.2 of the CNS TSs and Section 5.2.2 of the CNS and ONS TSs refer to a Shift Work Manager position. Duke Energy proposes to replace references to this obsolete position with the STA. An added requirement for the STA, only when he or she assumes the control room command functions, is that the STA's SRO license must be active.

Definitions in 10 CFR 55.4 state: "Actively performing the functions of an operator or senior

[reactor] operator means that an individual has a position on the shift crew that requires the individual to be licensed as defined in the facility's technical specifications, and that...." Duke Energy proposes to add paragraph 5.3.2 to ensure that there is no misunderstanding when complying with 10 CFR 55.4 requirements.. This proposed change Is consistent with NRC approved TSTF-258-A (Reference.13).

Currently in section 5.5.1, changes associated with Offsite Dose Calculation Manual (ODCM) require only the Station Manager's (Plant Manager's) approval. Duke Energy proposes this section be revised to require Plant Manager's or Radiation Protection Manager's approval for ODCM changes to be consistent with Duke Energy Carolinas Topical Report, Quality Assurance Program Duke-I-A. -

i Section 5.7, "High Radiation Area," of the CNS TS currently refers to the Shift Supervisor position in paragraph 5.7.2 and the MNS TS currently refers to the Operations Shi Manager in the same paragraph number. CNS and MNS propose to replace the references to those positions with the Shift Manager. The substitution of the Shift Manager for SS is essentially an administrative change since the Shift Manager has sufficient authority to maintain control over the high radiation area keys. For section 5.7.2 of the MNS TS, only a simple nomenclature change from Operations Shift Manager to Shift Manager is being proposed.

The proposed staff title changes are In names only. The actual functions of these individuals are not being altered. The changes are consistent with the guidance of Standard Technical Page 9 of 15

Enclosure Evalation of the Proposed Change RA-14-0001 Specifications (References 2 and 3) and do not adversely impact the minimum staffing levels required by Technical Specifications.

The proposed changes continue to ensure that no individual is assigned functions that will result in conflicting roles during design basis, fire, security or other events.

4.0 REGUHATORY EVALUATION 4.1 Agooicg*

u~alyor Reoui0MMnts/rbtri 10 CFR 55.4 defines systems approach to training to mean a training program that includes the following five elements:

.1. Systematic analysis of the jobs to be performed.

2. Learning objectives derived from the analysis which describes desired performance after training.

3. Training design and Implemetation based on the learning objectives.

4. Evaluation of trainee mastery of the objectives during training.

'5. Evaluation and revision of the training based on the performance of trained I ' personnel In the job setting.

The Duke Energy licensed operator training programs are accredited by NANT and are based on a systems approach to training. The licensed operator qualifications and training program will continue to comply with the requirements of 10 CFR 55.

10 CFR 55.31(a)(4) specifies in part that the Commission may accept certification that the applicant has successfully completed a Commission-approved training program that Is based on a system approach to training and that uses a simulation facility acceptable to the Commission under 10 CFR 55.45(b). RIS 2001-001 indicated that the NRC may accept a licenseme's licensed operator training program if it is accredited and based on a systems approach to training.

The NRC regulatory requirements that am related to the content of the Technical Specifications (TS) are contained in Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.36. Section 50.36 requires that the TS include items in the following specific categories: (1) safety limits, limiting safety system settings, and limiting control settings (50.36(c)(1)); (2) limiting conditions for operations (50.36(c)(2)); (3) surveillance requirements (50.36(c)(3)); (4) design features (50.38(c)(4)); and (5) administrative controls (50.36(c)(5)).

Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Traveler TSTF-258-A, Revision 4, contains changes to Section 5.0, Administrative Controls that are acceptable to the NRC staff.

Page 10 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 4.2 Precedent..

The NRC has previously approved changes similar to the proposed TS changes in this License Amendment Request for many other nuclear power plants including:

1.

Millstone Nuclear Power Station, Units 2 and 3: Application dated August 9, 2001 (ADAMS Accession No. ML012320087); Supplement dated November 19, 2001 (ADAMS Accession No. ML020090148); NRC Safety Evaluation dated December 5, 2001 (ADAMS Accnsion No. ML013330628).

2.

Wolf Creek Generating Station: Application dated September27, 2001 (ADAMS Accession No. ML012750141); Supplementdated June 27,;2002 (ADAMS Accession No. ML021900439); Supplement dated September 19, 2002 (ADAMS Accession No. ML022700159); NRC Safety Evaluation dated November 26, 2002 (ADAMS Accession No. ML023030583).

3."

Braldwood Station, Units I and 2; Byron Station, Units I and 2; Clinton Power Station, Unit 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units I and 2; Oyster.Creek Nuclear Generating SttioW;.Peach Bottom Atomic Power Station, Units 2 Ondc3!Quad Cities Nuclear Power.Stati, Unhts I and 2; and Three Mile Island Nuclear Station, Unit 1: Application dated July 19, 2007 (ADAMS Accession No. ML072110212); Supplement dated July 7, 2008 (ADAMS Accession No. ML081900267);

NRC Safety Evaluation dated July 25, 2008 (ADAMS Accession Nos. ML080860670 and ML082130136).

4; The NRC has previously approved changes to MGuireTS Sections 5.1, 5.2, 5.3 and

-5.7 which updsted the responsibility, orgariztion, -unit staff qualifications and high radiation areas(Duke Energy Letter dated December 2, 2002) (ADAMS Accession No.

.ML023450240); as supplemented by Duke Energy Letter dated April 14, 2003 (ADAMS Accession No. ML031-120348); NRC Safety Evaluation dated June.6,2003 (ADAMS Accession No. ML031570491).

5.

NRC letter dated September 4,2002 (ML022200571) approved Comanche Peak Steam Electric Station (CPSES), Units I and 2 request to revise TS 5.3 to require licensed Reactor Operators (ROs) and licensed Senior Reactor Operators (SROs) to meet or exceed the minimum qualifications In RG 1.8, Revision 3, and that all other members of the staff meet or exceed minimum qualifications In RG 1.8, Revision 2,1987.

6.

NRC letter dated December 15,2005 (ML053200531) approved-Cooper Nuclear Station request to revise TS 5.3 to update the qualification standard for the shift manager, senior operator, licensed operator and shift technical engineer from RG 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 2, April 1987, to RG 1.8, Revision 3, May 2000.

Page I1 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 4.3 No Skgmificant Hazards Consrani20::

Duke Energy is requesting an amendment to Technical 'Specifications of the Renewed Facility Operating Licenses for Cetawba Nuclear Station (CNS), Units I and 2; McGuire Nuclear Station (MNS), Units I and 2; and Oconee Nuclear Station (ONS), Units 1, 2 and 3. Specifically, Duke Energy is requesting the Nuclear Regulatory Commission's approval to revise Technical Specification Sections 5.1, "Responsibility"; 5.2, "Organization"; 5.3, "Unit Staff Qualifications!;

5.5, "Programs and Manuals"; and for Catawba and McGuire; Section 5.7, "High Radiation Area." An update to the licensed operator training requirements to be consistent with the National Academy for Nuclear Training program which is based on a systems approach to training; is requested. Additional administrative changes are proposed in Technical Specification Sections 5.1, Responsibility; 5.2, Organization; 5.3, Unit Staff Qualifications; 5.5, Programs and Manuals; and for Catawba and McGuire; Section 5.7, High Radiation Area.

Duke Energy has evaluated whether or not a significant hazards consideration Is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below.

1.

Ooes the proposed amenment Involve a significant increse In t# probabinty or conseuqecsw of an accident previously evaluated?

Response: No The proposedTechnical Specification (TS) changes regarding organization, unit staff responsibility and unit staff qualifications are administrative changes to clarify the current requirements for Duke Energy's licensed operator qualifications and training program. With this change, the TSs continue to meet the current requirements of 10 CFR 55. Although licensed operator qualifications and training may have. an indirect impact on accidents previously evaluated, the NRC considered this impact during the rulemaking process,:and by promulgation of the revised I CFR 55 rule, concluded that this impact remains acceptable as long as the licensed operator training programs are certified to be accredited and are based-on a systems approach to training. The proposed TS change takes credit for the National Academy for Nuclear Training (NANT) accreditation of the licensed operator training program.

The proposed TS change regarding responsibility, organization and high radiatin area is administrative in nature to reflect the current titles and responsibilities, of station personnel and is consistent with Standard Technical Specifications (STS).

Therefore, the proposed amendment does not involve a significant increase in. the probability or consequences of an accident previously analyzed.

2.

Does the proposedt amendment create the possibNlity of. a fiw or dffferent kind of accldent from amy acidlent previously evaluated?

Response: No.

Page 12 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 The proposed TS changes are administrative changes to clarify the current requirements for Duke Energy's licensed operator qualifications and training program and to conform to the revised 10 CFR 55. Similar to the discussion above, although licensed operator qualifications and training may have an indirect Impact on the possibility of a new or different kind of accident from any accident previously evaluated, the Nuclear Regulatory Commission (NRC) considered this impact during the rulemaking process, and by promulgation of the revised rule, concluded that this impact remains acceptable as long as licensed Operator training programs are certified to be accredited and based on a systems approach to training. As previously noted, the Duke Energy licensed operator training program is accredited by NANT and Is based on a systems approach to training. The proposed TS change takes credit for the NANT accreditation of the licensed operator training program.

The proposed TS change regarding-responsibility, organization and high radiation area does not impact any plant systems that are accident initiators nor does the proposed change adversely impact any accident mitigating system. No physical changes are being made to the plant. This change is administrative in nature to reflect the current titles and responsibilities of station personnel and to be consistent with STS.

The proposed amendment does not impact plant design, hardware, system operation or procedures, and therefore does'not create the possibility of a new or different kind of accident from any previously evaluated.

3..'

DoeS the proposed anendment Involve a significant reduction In the margin of Response: No The proposed Technical Specification (TS) change regarding unit staff qualifications is an administrative change to.clarify the current requirements applicable to Duke Energy's licensed operator qualifications and training program. With this change, the TS continue to meet the current requirements of 10 CFR 55. Although licnsed:opator qualifications and training may have an indirect inpact on accidents previously evaluated, the NRC considered this Impact during the rulemaking process, and by promulgation of the revised 10 CFR 55 rule, concluded that this impact remains acceptable as long as the licensed operator training programs are certified to be accredited and are based on a systems approach to training. As noted previously, the Duke Energy licensed operator training program is accredited by NANT and is based on a systems approach to training.

The NRC has concluded per NUREG-1262, that the standards and guidelines provided by the Institute for Nuclear Power Operations' NANT are equivalent to those put forth or endorsed by the NRC. As a result, maintaining a NANT accredited, systems approach based licensed operator training program is equivalent to maintaining an NRC approved licensed operator training program. Furthermore, the NRC published Regulatory Issue Summary (RIS) 2001-001 to familiarize licensees with the NRC's current guidelines for the qualification and training of Reactor Operator and Senior Operator license applicants. This document again acknowledges Page 13 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001 that the NANT guidelines for education and experience outline acceptable methods for implementing the NRC's regulations in this area. The margin of safety is maintained by virtue of maintaining the NANT accredited licensed operator training program.

The proposed TS change regarding responsibility, organization and high radiation area is administrative in nature to reflect the current titles and responsibilities of station personnel and is consistent with STS. Systems and components are not impacted and therefore are capable of performing as designed. The performance of fission product barriers will not be impacted by this proposed change.

Therefore, the proposed changes do not involve a significant reduction In the margin of safety.

Based on the above discussion, Ouke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth In 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions Based on the considerations discussed above, (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 amendment will not be inimical to the common defense and security or to the health and sae of the public.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment does not involve a significant hazards consideration, a significant change in the types of any effluents that may be released offsite, a significant Increase in the amount of any effluents that may be released offite or a significant increase in the individual or cumulative occupational radiation exposure. Therefore, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

6.0 REFERENCES

1.

NUREG 1431, Revision 4, "Standard Technical Specifications - Westinghouse Plants,"

April, 2012.

2.

NUREG 1430, Revision 4, "Standard Technical Specifications - Babcock and Wilcox Plants," April, 2012.

3.

National Academy for Nuclear Training, ACAD 10-001, "Guidelines for Initial Training and Qualification of Licensed Operators," February, 2010.

Page 14 of 15

Enclosure Evaluation of the Proposed Change RA-14-0001

4.

National Academy for Nuclear Training, ACAD 09-001, "Guidelines for Initial Training and Qualification of Licensed Operators," January, 2009.

5.

Federal Register, 50 FR 11147, "Commission Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel," March 20, 1985.

6.

NRC Generic Letter 87-07, "information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10 CFR 55 and Conforming Amendments," March 19, 1987.

7.

NUREG 1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 Operators' Licenses," November, 1987.

8.

Regulatory Guide 1.8, Revision I-R, "Personnel Selection and Training," May, 1977.

9.

ANSI N18.1-1971, "Selection and Training of Nuclear Powr Plant Personnel, March 8, 1971."

10.

NRC Regulatory Issue Summary 2001-01, "Eligibility of Operator License Applicants,"

January 18, 2001.

11.

Regulatory Guide 1.8, Revision 3, "Qualification and Training of Personnel for Nuclear Power Plants," May 2000.

12.

TSTF-258-A, Revision 4, "Changes to Section 5.0, Administrative Controls," June 29, 1999.

Page 15 of 15

Attachmnt 1 to RA-14-OO01 Afttchmnt 1 RA-4000

.° M,

n C

.- : _ 4 ".

.y

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibilitv 5.1.1 he Manager shal be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

5.1.2 The shall be responsible for the control room command function. During any absence of the 8I-CM from the control room white the unit is in.MODE 1, 29-3; or 4, an individual (other than the Shift We* -M"e e(SIniMI AisrLIA*) with an active Senior Reactor Operator (SRO) license shall be designated to-assume the control room command function. During any absence of the 66fjfrom the control room while the unit is In MODE 5 or 6, an indMdual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

On occasion when there is a need for both the Shift 11 onf. e andt hef rjiLSRO to be absent from the control room in MODE 1, 2, 3, or 4, OewShift 1Aedu1 melsrtn STA with an active SRO li"ense on the unit shall be allowed to assume the control roonM omnmand function and sIerve as the SRO in the control room provided that

a.

the Shifts or the j.SR is available to return to~the control room within 10 minutes, jn

b.

the assumption of SROC&Lduties b.the -Shift We* Mma*ep is.

lmited to periods:not in *xcess of 15 minutes duration and a total time not to exceed I hour during any shift-and, G.

h if 011 Wor-h-P.k timn.go 0A.

0 "F'no.

k

t.

Catawba Units I and 2 5.1-1 Amendment Nos. 4746a I

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Qffsite Orgenmi.jaos Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offeite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, In organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel psitionW, or in equivalent forms of documentation. These requirements shall be documented In the UFSAR;

b.

The 8tar-mManager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant

c.

The Vice President Sf Cot_.-..-,* "

i_

. Catawba Nuclar Site. shalt have -s-pe~ae-rIsponsibility foroverall plant nuclear sfty and shall take any measureS needed to ensure acceptable performance of the staff in operatingi maintaining, and providing technical support to the plant to ensure nuclear safety;

d.

The Chief Nuclear Officer will be the Senior Nuclear Executive and have corporate-responsibility for-overall nuclear safety; and

e.

The individuals who train the operating stff, *car out rediaon protection, or perform quality assurance functions may report to the appropriate onsite manager; however, these inldividuals Shall have sufficient organizational freedom to ensure theirindepoehdene from'operatingwpsures.

5.2.2 Ui The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor Is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

(continued)

Catawba Units I and 2 5.2-1 Cataba UitsI an 2 52-1Amendment Nos. 26&1246 1

Organization 5.2 5.2 Organization 5.2.2 Uni Stff (continued)

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit Is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in tho control room.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(1) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protection Technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , In order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted.

S The Operations 6 iA dehalI hold or have held a SRO license. The WN g

OperatIonsManager-=hft-Shift Sm,and A10MhSupervisor shall hold an SRO license. The PsmpQ-Operator shall hold a Reactor Operator License.

g.

The Chift Work, I~u...L.,

,n,.

wo

,f.....,

1-thse of - Shift Technical Advisor (STA) shall provide advisory technical support to the I Shift 8t"e4*Ft.MmnU= in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, t-he Shi, AWAF, Ma....s s1hall meeo !he qu.lifiatioe, for STA celfo b

hoCm meic wienl Pcmlolll *tatmll or' Erblnc*llliillng Commission Polii-v Statement on Enaireeina Exmertise on Shift.

I~

~ ~

~

~~~hl IIg I

III_

Catawba Units I and 2 5.2-2 Amendment Nos. 2644346 I

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shah meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, excelh.

o R..*dtion-.Pvtsete

1.

Th. Radiation Protection Manaaer. who shall meet or exc"eed the oaultfle.tions of fteoulatnrv Guide 1.S. Seotamber 197S.

2.

The educaion and m e elaiobility rauirmI nts for licented ooerators shall meet or exceed the auidelines outlined by te Ntional Actemy fO Nuclear Toron issinN whamh hor beetna 10 CRa 55t31 by a~ Nuclear Rouatorv Commisio 3N1 o rm~

0CF A For the,'urmoses of 10 CFR 55*4, a lIc~nsed Senior Reactor Ocerato (SRO*

and a licensed ReActor Ocerator (ROb are those individuals who. in addition to meetino the reoulrements of TS -5;3.1. nerform the functions described in 10 CatwNba Units I and 2 5.3-1 dAmendment Nos. 4 A i114 2

5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.

5.5.1 Offsit Dose Calculation Manual (ODCM)

The 0DCM shall contain the methodology and paravme used in the calculation of offelte doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program.

Licensee initiated changes to the ODCM:

a.

Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

1.

sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

2.

a determination that the change(s) do not adversely Impact the accuracy or reliability of effluent, dose, or setpoint calculations;

b.

Shall become effective after the approval of the frjg Raiain rteton I~aae;andI

c.

Shall be submitted to the NRC In the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of-the report in which any change in the OCM wes made. Each change shall be Identified by markings in the margin of the affected pages, clearly Indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

6.5.2 Containment Lealaae Rate Testrno Proamm A program shall be established to implement the leakage rant testing of the containmentas required by 10 CFR50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:

a.

The containment visual examinations required by Regulatory Position C.3 shall be conducted 3 times every 10 years, Including during each shutdown for SR 3.6.1.1 Type A test, prior to Initiating the Type A test; and (continued)

Catawba Units I and 2 5.5-1 Amendment Nos. 26&969 I

5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, In which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., Radiation Protection Technicians) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performanoe of their assigned duties in high radiation arm with exposure rates 5 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a.

A radiation monitoring device that continuously indicates the radiation dose rate in the area.

b.

A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset Integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.

c.

An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positiv control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Manager in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels

> 1000 mrem/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Shif.......,.,

on d-.. or a*d

.ation 2ot1=i0 ggrsonnel. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels In the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued)

Catawba Units I and 2 5.7-1 Amendment Nos. 13:6 to RA-14-0001 Aftech4ord McGulro TfthtmW 3-Sp Ilflcat Marked Uip Pages'

5..1 5.0 ADMINISTRATIVE CONTROLS 5.1 ResonsibilitY 5.1.1 The S

.a-w=Manager shall be responsible for overall unit operation and shall delegate In writing the succession to this responsibility during his absence.

5.1.2 The A"-

,rW-.'Qrn 1489 I

u i shall be responsible for the control room command function. During any absence of the GR$R*= from the control room while the unit is in MODE 1, 2 3, or 4, an individual [other than the Shift Technical Advisor (STA)] with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the QR$RQQU from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room commend function.

On occasion when there is a need for both the CRSRQ and the relief SRO to be absent from the control room in MODE 1, 2, 3, or 4, th4TAW STA with an activ SRO licena on the unit shall be allowed to assume the control room command function and serve as the SRO in the control room provided that

a.

the,RSRG-QC or the relief SRO Is avai~le to return to the control room within 10 minutes,nd..

b.

the assumption of 6ROCfj*duties by the STA is limited to periods not in excess of 15 minutes duration and a total time not to exceed I hour duringtany shift-va4, i ~ ~

~~4 thSAhPn SOioesr on ONG Wnlt McGuire Units I and 2 5.1-1 Amendment Nos. 24P44 I

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onalte and Qffulte QManiions Onsite and omit. organizations shall be established for unit operation and corporate management, respectively. The onsite and offite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a.

Lines of authority, responsibility; and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibiliies and relationships, and job descriptions for key personnel positons, or in equivalent forms of documentation. These requirements shall be documented in the UFSAR;

b.

The 8tee*-LJMU anager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant; C.

The Vice Presi1 of.i..uirs Nweleo"'-

S it. M fGuiMr Nuclear Site. shall have eeuts-reponsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providingtechnical support to the plant to ensure nuclear safety;

d.

The Q--,.-

Vies..

Poe..;al..*.*-.

N.....*..

r*...*WAPWm 6"aa Offr will be the Senior Nuclear Executive and have corporate responsibility for overall nuclear safety; and

e.

The individuals who train the operating staff, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager;, however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

(continued)

McGuire Units I and 2 5.2-1 aAmendment Nos. 239Q424 I

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Stff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action Is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protection Technician shall be on site when fuel Is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted

f.

The Operations Manager shall hold or have held an SRO license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the C..-a-n_.W R."e.-M Se'....m.R.e-a*-w_ Opw GSin the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit McGuire Units I and 2 5.2-2 Amendment Nos. 23433

Unit Staff Qualifications 5.3 5.0 AD*MNISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1.1971 for comparable positions, except4he Radiaion Ammotin Man w,. Ww~ shall meet or oxased the g~Iifion of tosegIlstor f9uide 4.8, September 407&;~

The Radiation Prexcceeon Manaer. who a me or ex d tha oualiflatons of Reoulatorv Guide 18September lq75.

2.

The edcto and aimeilenca elioibilitv mlremei~nnta for licensed onerators shall t or aexced the auideline outlined by the Natinal Acadmy for Nucler Trinino (NANT. which haer been found acceotal bv the Nucear Raulaton Commission £NRC* for

.rmeetino 10 CFR 55.31 and have been inconrae into anolicable station trainiro ptncedurea.

5.3.2 For the nurose of 10 CFR 55.4. a licensd Senior Reactor O ator (SROt and a licensed Ieactor piwator (RO* at thrue Individuals who.

in addition to maetiin the reau' t of TS S.31 eom the funcions descrbed in 10 CFR 5O.S4frml...

McGuire Units I and 2 5.3-1 Amendment Nos. 2-3-494 I

5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.

5.5.1 OffsiteDe Calculati MnO CI.

Q The ODCMshall contain the methodology and parameters used in the calculation of offaite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in. the conduct of the radiological environmental monitoring program.

Licensee initiated changes to, the ODCM:

a.

Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

I.

sufficient informato to support"th changes) together with the appropriate analyses or eveluations justifying the change(s), and

2.

a determination that the change(s) do not adversely impact the accuracy or reliability of effluent, dose,. or setpoint calculations;

b.

Shell become effective after the approval of the anagerig

~em~m~

1 and;,

c.

Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any. change In the 0DCM was made.. Each.change al~be identified by markings in the margin of the affected pages, clearly indicating the area of the page that mas changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Containment LeaKaaM E

A pogram shall be esWished to Implement the leakag r testing of the conltinment as'required by 10 CFR 50,54() and 106CFR 50, Appendix J, Option B, is modified by approved exemptions. This program shall be in accordance with the guidelines contained In Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:

NEI 94-01-1995, Section 9.2.3: The first Type A test performed after the May 27, 1993 (Unit 1) and August 20,1993 (Unit 2) Type A test shall be performed no later than plant restart after the End Of Cycle 19 Refueling Outage (Unit 1) and August 19, 2008 (Unit 2), and McGuire Units I and 2 5.5-1 Amendment No. 264444 I

5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, In which the Intensity of radiation is > 100 mmm/hr but < 1000 mrem/hr at 30 cm (12 In.) from the radiation source or from any surface which the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation aea and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., Radiation Protection Technicians) or personnel continuously escorted by such individuals may be exempt from the RWP Issuance requirement during the performance of their assigned duties in high radiation areas with exposure rats

!5 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of Individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a.

A radiation monitoring device that continuously indicates the radiation dose rate In the area.

b.

A radiation monitoring device that continuously Integrates the radiation dose rate in the area and alarms when a preset integrated dose Is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area haow been established and personnel are aware of them.

c.

An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who Is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Manager in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels

> 1000 mrem/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Opi*Wetie-Shift Manager, Radiation Protection Manager, or his or her designee. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued)

McGuire Units I and 2 5.7-1 Amendment Nos. 414(46

I to RA-14-0001

Attahment 3 RA-14O Ocone.TachnkWe 6.cft 8cAV"~ Uadsd uo PAges

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The G OManager shall be responsible for overall plant operation and shall delegate in writing the succession to this responsibility during his absence.

The,06 or:his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

.1.2 The Control Room Sunanileor (CRS* shall be resonmibla for the con~trol room command functi Durin9 any absence of the CR fom the control room while the unit is in MODE 1.2. 3-or 4 an ididual fether then th Shift Technical Advso (

TA I it a

,9an o HI~

M to I~tr S

license shall be dernated to assume the control room command function. Durinn any absence of the CRS from the contro room w h unit is in MODE 5 orS. an individual with an active SRD license or Reactor QOertor license shall be desionated to I

I OCONEE UNITS 1. 2, & 3 5.0-1 Amendment Nos. 0% 30(h &

I

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 QOnste and Qfsit anizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization 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 UFSAR;

b.

The,ltaie.E-PlmnMenager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;

c.

The Vice-President; Oconee Nuclear Site, shall have ewponte responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety;-

d.

The..

.p

.W,--8F N,.

0 " IIe W

Officer will be the Senior Nuclear Executive and have corporate responsibility for overall nuclear safety; and

e.

The individuals who train the operating staff, carry out hbeolo physl~iation oteon, or perform quality assurance functions may report to the appropriate onsite manager;, however, these individuals shall have sufficient organizational freedom to ensure their Independence from operating pressures.

5.2.2 i a-a The unit staff oronizntion shall include the followina

a.

A non-licensed operator shall be onsite for each reactor containing fuel and an additional non-licensed operator shall be onsite for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

OCONEE UNITS 1, 2, & 3 5.0-2 Amendment Nos. 366,4367, &

I

Organization 5.2 5.2 Organizat.on 5.2.2 nit Staff (continued)

b.

At ieast one licensed Reactor Operator (RO) per unit shall be present in the control room when fuel Is in the reactor. In addition, while the unit is in MODE 1, 2 3,- or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protecto Technician shall be on site when fuel is In the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted.

f.

The Operations S "Peei te.or 8hift SO IsanLOperations Manager -,

shall hold an SRO license.

g.

The S-hft lck o"-....

funtio".

.-- hxd t---

of - Shift Technical Advisor (STA)T shall provide advisory technical support to the WA.. *..*ae i l6GQ nWV= in the areas of thermal hydraulics, reactor engineenng, and plant analysis with regard to the safe operation of the uni In addition, the Shift

A!9*

MAnage shall MW th4 gWIitiGti 1

mSsion "PO-i *y STAtsme me tOn MIneeuI* 6oulielns OnR Shify

.imrniBie Poiy0ameto n*neialxets nS*

OCONEE UNITS 1. 2, & 3 5.0-3 Amendment Nos.

367, &

I

Organization 5.2 5.2 Orn.nization 5.2.2 i

(continued)

.h..

e qualified manpower necessary for achieving alternate shutdown using the Standby Shutdown Facility (SSF) will be available at the plant at all times.- The manpower-necessary to operate the SSF will be exclusive of the fire brigade and the minimum operating shift that is required to be present in theoControl Room.

I Ii OCONEE UNITS 1, 2, & 3 5.0-,4 Amendment Nos. 390, 3Q,-&O8 I

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Qai taff Qualifications 5.3.1 Each member of the stWiRt staff shall meet or exceed the minimum quolifications described in Section 4 of ANSIIANS-3.1-1978, "Selection and Training of Nuclear Pamer Plant Personnel' except..

"*ONA:--

The Operations G,..-. ei.

enmdeeMa

.hall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis.

".iThe 8Oporations.Manager.%j.l shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fuffilled by academic training, or related technical training on a one-for-one time basis.

3.

The edcaion and -,nianene eliibtli.Mtauirnntt for liOenoe t

shall meet " exceed the ouidelines outlined by the National ad~emv for.Nu*

Trhadnin (NANTI. which have been found acoal by the Nuclear Raoultoev CMrimlon (NRC* for meetino 10 CFR. -S31 and have been incomoed into aoolicable station flninao,~ocedures.

For the oroeo 0CRS4 iesdSno eco nrtr~~)

n a licensed Reactor Ooerator (ROb ar those individuals who. in addition to rneetina the renuireienta of TS 5.3.1: nrfom the-functions described in 10 F

. (.

4 m.

1:

OCONEE UNITS 1, 2, & 3 5.0-5 Amendment Nos. 30, 300, &

I

Programs and Manuals 5.8 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shah be established, implemented, and maintained.

5.5.1 Ofsite Dose Ccat"ion Manual OQCM The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program.

Licensee initiated changes to the ODCM:

a.

Shall be documented and records of reviews perfOrmed shall be retained.

This documentation shall contain:

1.

sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

2.

a determination that the change(s) do not adversely impact the accuracy or reliability of effluent dose, or setpoint calculations;

b.

Shall become effective after the approval of the ShateloRwe

,Manager, Iadi at i

oMn and

c.

Shal be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shaH indicate the date (i.e., month and year) the change was implemented.

5.5.2 Containment Leaie Eft Testirm P==

A program shall establish the leakage rate testing of the Containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. The next Unit I ILRT following the December 8, 2003 test shall be performed no later than March 8, 2015. The next Unit 2 ILRT following the May 29, 2004 test shall be performed no later than December 29, 2015. The OCONEE UNITS 1, 2, & 3 5.0-7 Amendment Nos 383, &430 1

to RA-14-WOO1 Attacment 4 RA1440OO1i CatowmaTechniclko ifcto RetyW~ Page

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The Plant Manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

5.1.2 The Control Room Supervisor (CRS) shall be responsible for the control room command function. During any absence of the CRS from the control room while the unit is in MODE 1, 2, 3, or 4, an individual (other than the Shift Technical Advisor (STA)) with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the CRS from the control room while the unit Is in MODE 5 or 6,- an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

On occasion when there Is a need for both the CRS and the relief SRO to be absent from the control room in MODE 1, 2, 3, or 4, an STA with an active SRO license on the unit shall be allowed to assume the control room command function and serve as the SRO in the control room provided that:

a.

the CRS or the relief SRo is available to retum to the control room within 10 minutes, an-

b.

the assumption of CRS duties by the STA is limited to periods not in excess of 15 minutes duration and a total time not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during any shift Catawba Units I and 2 5.1-1 Amendment Nos.

I

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2. I Onsite al Offt Omanizatiomn Onsite and offeits organizationslshall be established for unit operation and corporate management, respectively. The onsite and offeite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, Intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization 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 UFSAR;

b.

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

c.

The Vice President, Catawbe Nuclear Site, shall have responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff In operating, maintaining, and providing technical support to the plant to ensure nuclear safety;

d.

The Chief Nuclear Offc will be the Senior Nuclear Exeacutiv and have corporate responsibility for overall nuclear safety; and

e.

The individuals who train the operating staff, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager, howver, thiese Individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

5.2.2 Unituf The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor Is operating in MODES 1, 2. 3, or 4.

A total of three non-licensed operators are required for the two units.

( continued)

Catawba Units I and 2 5.2-1 Amendment Nos.

I

Organization 5.2 5.2 Organization 5.2.2 Uonitjuf (continued)

b.

At last one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is In MODE 1, 2, 3,,or 4, at leat one licensed Sonfor Reactor Operator (SRO) shall be present in the control room.

I-

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and.5.2.2.e end 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protection Technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position..-

e.

Deleted.

f.

The Operations Manager shall hold or hae held a SRO license. The Assistant Operations Manager - Shit, Shift Manager, and Control Room Supervisor shell hold an SRO license. The Control Operator shall hold a Reactor Operator License.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support I to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Catawba Units I and 2 5*2-2 Amendment Nos.

I

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, except

1.

The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

2.

The education and experience eligibility requirements for licensed operators shall meet -r exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been Incorporated into applicable station training procedures.

5.3.2 For the purposes of 10 CFR 55.4, a licensed Senior Reactor Operator ($RO) and a licensed Reactor Operator (RO).are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

Catawba Units I and 2 5.3-1 Amendment Nos.

I

5.0 ADMINISTRATIVE CONTROLS 5.5 Programsand Manuals The following programs shall be established, implemented, and maintained.

5.5.1 5.5.2 Offsite Dose Cal7,lation Manual (OWCM, The ODCM shall contain the methodology and parameters used in the calculation of offeft doses resulting from radioactive gaseous and liquid effluents, in the~calculation, of gaseous and liquid effluent monitoring alarm and trip setpoints; and in the conduct of the radiological environmental monitoring program.

Ucensee initiated changes to the ODCM:

a.

Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

1.

sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

2.

a determination that the change(s) do not adversely impact the accuracy or reliability of effluent, dose, or setpolnt calculations;

b.

Shall become effective after the approval of the Plant Manager or Radiation Protection ManaeWE an&W

~

c.

Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change In the ODCM was made. Each change shalH be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was Implemented.

Cgotinment Lea~kage Rat Testina9 P=oum A program shall be established to implement the leakage rate testing of the containment as required by IQCFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be In accordance with the guidelines contained in..Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as.modified -by the following exceptions:

a.

The containment visual examinations required by Regulatory Position C.3 shall be conducted 3 times every 10 years, including during each shutdown for SR 3.6. 1.1 Type A test, prior to initiating the Type A test; and (continued)

Catawba Units I and 2 5.5-1 Amendment Nos.

I

5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, In which the intensity of radiation is > 100 mronvhr but e 1000 mrsm/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified In radiation protection procedures (e.g., Radiation Protection Technicians) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties In high radiation areas with exposure rates

< 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry Into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanie by one or more of the following:

a.

A radiation monitoring device that continuously indicates the radiation dose rate In the area.

b.

A radiation monitoring device that continuously integrates the radiation dose rate In the area and alarms when a preset Integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels In the area have been established and personnel are aware of them.

c.

An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Manager in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels

> 1000 mmm/hr at 30 cm (12 In.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Shift Manager, Radiation Protection Manager, or radiation protection personnel. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued)

Catawba Units I and 2 5.7-1 Amendment Nos.

I to RA-14-0OO1 RA-14-000 IcMui. Tochnicul Speclfltion Rotyped Pages

Responsibility I 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Resmonsibillty 5.1.1 The Plant Manager shall be responsible for overall unit operation and shall delegate In writing the succession to this responsibility during his absence 5.1.2 The Control Room Supervisor (CRS) shall be responsible for the control room command function. During any absence of the CRS from the control room while the unit Is In MODE 1, 2, 3, or 4, an individual [other than the Shift Technical Advisor (STA)] with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the CRS from the control room while the unit is in MODE 5 or 6, an Individual with an active SRO license or Reactor Operator license-shall.be designated to assume the control room command function.

On occasion when there is a need for both the CRS and the relief SRO to be absent from the control room in MODE 1, 2, 3, or 4, an STA with an active SRO license on the unit shall be allowed to assume the control room.command function and serve as the SRO in the control room provided that

a.

the CRS or the relief SRO is available to return to the control room within 10 minutes, and.

b.

the assumption of CRS duties by the STA is limited to periods not in excess of I5 minutes duration and a total time not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during any shift.

McGuire Units I and 2 5.1-1 Amendment Nos. I

Organization' 5.2.-

5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Qnst sag OffitQ OragoInUa~o Onsfte and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and ofuite organizations shall include the positions for activities affcting safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, Intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of depme responilties and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shal be documented in the UFSAR;

b.

The Plant Mansge shell be responsible for ovrall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant

c.

The Vice President McGuire Nuclear Sit, shall have responsibility for overall plant nuclear safety end shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety;,

d.

The Chief Nuclear Officer will be the Senior Nuclear Executive and have corporate responsibility fof overalr nuclear safety; and

e.

The Individuals who train the operating staff, cany out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager, however, thesindividuals shall have sufficient'organizational freedom to ensure their independence from operating pressures.

(continued)

McGuire Units I and 2 5.2-1 Amendment Nos.

I

Organiztion 5.2 5.2 Organization (continued) 5.2.2 Unit The unit staff organidation shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of thre non-licehed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at lest one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(mX2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action Is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protection Technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in orter to provide for unexpected absence, provided Immediate action is taken to fill the required position.

e.

Deleted

f.

The Operations Manager shall hold or have held an SRO license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

McGuire Units I and 2 5,2-2 Amendment 1110s.

Unit Staff Qualifications 5.3 5&0 ADMINISTRATIVE CONTROLS '

5.3'Unft Staff Qualifications" 5.3.1 Each memberfof the unit staff shall meet or exceed the minimum qualifications.of ANSI-N18. 1-1971 for comparable positions, except

1.

The Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

2.

The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, In addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

McGuire Units I and 2 5.3-1 Amendment Nos. I

5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manals -

The following programs shall be established, implemented, and maintained.

5.5.1 ofst" D= galcuatoManje JOOM)

The ODCM shall contain t methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, In the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program.

Licensee Initiated changes to the ODCM:

a.

Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

1.

sufficient Information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

2.

a determination that the change(s) do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

b.

Shall become effective after the approval of the Plnt Manager or Radiation Protection Manager, and C.

Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change In the ODCM was made. Each change shall be identified by marktings in.the margin of the affected pages, clearly indicating the ovar of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Containment Leakae Rate Testino Proa'am A program shall be establiihd to implement the leakage rate testing of the containment as required by 10 CFR S0.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:.

NEI 94-01-1995, Section 9.2.3: The first Type A test performed after the May 27, 1993 (Unit 1) and August 20, 1993 (Unit 2) Type A test shall be performed no later than plant restart after the End Of Cycle 19 Refueling Outage (Unit 1) and August 19, 2008 (Unit 2), and McGuire Units I and 2 5.5-1 Amendment No. I

5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation Is > 100 mrem/hr but < 1000 mrem/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified In radiation protection procedures (e.g., Radiation Protection Technicians) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties In high radiation areas with exposure rates

< 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a.

A radiation monitoring device that continuously indicates the radiation dose rate in the area.

b.

A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry Into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.

C.

An Individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who Is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Manager in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels

> 1000 mrem/hr at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Shift Manager, Radiation Protection Manager, or his or her designee. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for Individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued)

McGuire Units I and 2 5.7-1 Amendment Nos.

I to RA-14-0001 RA-1440001

'Oconee TocMtncu epsoffiatlo Rotyed Pages

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Resvonsibility 5.1.1 The Plant Manager shall be responsible for overall plant operation and shall delegate in writing the succession to this responsibility during his absence.

The Plant Manager or hisdesignee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safeWy.

5.1.2 The Control Room Supervisor (CRS) shall-be responsible for the control room command function. During any absence of the CRS from the control room while the unit is in MODE 1,2, 3, or 4, an Individual [other than the Shift Technical Advisor (STA)] with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the CRS from the control room while the unit Is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

OCONEE UNITS 1, 2, & 3 5.0-1 Amendment Nos. I

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS, 5.2 Oranization 5.2.1 Onsite and fitte Ma on" Onsite and offalte organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant

a.

Lines of authority, rsponsibilty., and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate,,in organization 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 UFSAR;

b.

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

c.

The Vce-President Oconee Nuclear Site, shall have responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff In operating, maintaining, and providing technical support to the plant to ensure nuclear safety;

d.

The Chief Nuclear Officer will be the Senior Nuclear Executive and have corporate responsibility for overall nuclear safety; and

e.

The Individuals who train the operating staff, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager, however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be onsite for each reactor containing fuel and an additional non-licensed operator shall be onsite for each control room from which a reactor is operating In MODES 1, 2, 3, or 4.

OCONEE UNITS 1, 2, & 3 5.0-2 Amendment Nos.

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Organization 5.2 5.2 Oranization 5.2.2 Uni* Su (continued)

b.

At least one licensed Reactor Operator (RO) per unit shall be present In the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3,, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided Immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A Radiation Protection Technician shall be on site when fuel is In the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , In order to provide for unexpected absence, provided immediate action Is taken to fill the required position.

e.

Deleted.

f.

The Operations Manager or Assistant Operations Manager - Shift shall hold an SRO license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

OCONEE UNITS 1, 2, & 3 5.0-3 Amendment Nos.

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Organization 5.2 5.2 Organization 5.2.2 Unit §Wff (continued)

h.

.,The qualified manpower necessary for achieving aternate.shutdown using the Standby Shutdown Facility (SSF) will be available at the plant at all times. The manpower necessary to operate the SSF will be exclusive of the fire brigade and the minimum operting shift that is required to be present In the Control Room.

I OCONEE UNITS 1, 2, & 3 5.0-4 Amendment Nos. I

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications described in Section 4 of-ANSI/ANS-3.1-1978, "Selection and Training of Nuclear Power Plant Personnel" except:

1.

The Operations Manager shall have a minimumof eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear *tation experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one time basis.

2.

The Assistant Operations Manager - Shift shall have a minimum of eight years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of two years of the remaining five years of experience may be fulfilled by academic training, or related technical training on a one-for-one time basis.

3.

The education and experience eligibility requirements for licensed operators shall meet or exceed the guidelines outlined by the National Academy. for Nuclear Training (NANT), which have been found acceptable by the Nuclear Regulatory Commission (NRC) for meeting 10 CFR 55.31 and have been Incorporated into applicable station training procedures.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO)are those individuals who, in addition to meeting the requirements of TS 5.3.1, :perform the functions described in 10 CFR 50.54(m).

OCONEE UNITS 1, 2, & 3 5.0-5 Amendment Nos. I

Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.

5.5.1 Qffut Dose Clcultiojn Manuel (ODCM)

The ODCM shall contain the methodology and parameters used in the calculation of offeite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program.

Licensee initiated changes to the ODCMI.

a.

Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

1.

sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

2.

a determination that the change(s) do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

b.

Shall become effective after the approval of the Plant Manager or Radiation Protection Manager, and

c.

Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Containmnt Leaa Rate Testing BroMM A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. The next Unit I ILRT following the December 8, 2003 test shall be performed no later than March 8, 2015. The next Unit 2 ILRT following the May 29, 2004 test shall be performed no later than December 29, 2015. The OCONEE UNITS 1, 2, & 3 5.0-7 Amendment Nos.

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v t e Letter Sequence Request
TAC:MF4491, (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2014-07-21 [Table View]

RA-14-0001, License Amendment Request to Reflect Changes to Organization, Unit Staff Responsibility, Unit Staff Qualifications, Programs and Manuals, and High Radiation Area

Text

SUBJECT:

Enclosure:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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RA-14-0001, License Amendment Request to Reflect Changes to Organization, Unit Staff Responsibility, Unit Staff Qualifications, Programs and Manuals, and High Radiation Area

Text

SUBJECT:

Enclosure:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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