ML16357A141

Revision 18 to Updated Final Safety Analysis Report, Chapter 13, Conduct of Operations

ML16357A141
Person / Time
Site:	Limerick
Issue date:	09/19/2016
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
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Download: ML16357A141 (53)

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LGS UFSAR CHAPTER 13 - CONDUCT OF OPERATIONS TABLE OF CONTENTS 13.1 ORGANIZATIONAL STRUCTURE 13.1.1 Deleted 13.1.2 Operating Organization 13.1.2.1 Plant Operations Department 13.1.2.1.1 Operations Department 13.1.2.1.2 Radiation Protection Department 13.1.2.1.3 Chemistry/Radwaste Department 13.1.2.1.4 Maintenance Department 13.1.2.1.5 Work Management Department 13.1.2.2 Nuclear Security Department 13.1.2.3 Site Engineering Department 13.1.2.4 Deleted 13.1.2.5 Training Department 13.1.2.6 Regulatory Assurance Department 13.1.2.7 Human Resources Department 13.1.2.8 Organizational Effectiveness Department 13.1.3 Qualification of Nuclear Plant Personnel 13.1.3.1 Qualification Requirements 13.1.3.2 Qualifications of Plant Personnel 13.1.4 Special Projects 13.2 TRAINING 13.2.1 Plant Personnel Training Program 13.2.1.1 INPO Accredited Training Programs 13.2.1.2 Access Training 13.2.1.3 Emergency Preparedness Training 13.2.1.4 Radwaste Shipping Training 13.2.1.5 Fire Protection Training 13.2.1.6 Fire Protection Requalification Training 13.2.2 Records 13.2.3 Training Organization 13.2.3.1 See Figure 13.2-1 13.3 EMERGENCY PLANNING 13.4 REVIEW AND AUDIT 13.4.1 General 13.4.2 Onsite Review 13.4.3 Independent Review 13.4.4 Audit Program 13.4.5 Independent Safety Engineering Group CHAPTER 13 13-i REV. 18, SEPTEMBER 2016

LGS UFSAR TABLE OF CONTENTS (CONT'D) 13.5 PLANT PROCEDURES 13.5.1 Administrative Procedures 13.5.1.1 Procedure for Preparation and Control of Administrative Procedures 13.5.1.2 Procedure for Plant Operations Review Committee 13.5.1.3 Procedure for Plant and Shift Operations 13.5.1.4 Procedure for Release of Safety-Related Equipment 13.5.1.5 Procedure for Temporary Modifications 13.5.1.6 Procedure for Control of Plant Modifications 13.5.1.7 Procedure for Control of In-plant Work 13.5.1.8 Procedure for Administration of the Preventive Maintenance Program 13.5.1.9 Procedure for Administration of the Surveillance Testing Program 13.5.1.10 Procedure for Administration of Plant Records 13.5.1.11 Procedure for Procurement 13.5.1.12 Procedure for Administration of the Plant Security Program 13.5.1.13 Procedure for Preparation of Maintenance Procedures 13.5.1.14 Procedure for Preparation of Transient Response Implementation Plan Procedures 13.5.1.15 Procedure for Preparation of Emergency Plan Procedures 13.5.1.16 Procedure for Preparation of General Plant Procedures 13.5.1.17 Procedure for Preparation of System Procedures 13.5.1.18 Procedure for Preparation of Operational Transient Procedures 13.5.1.19 Procedure for Preparation of Alarm Response Cards 13.5.1.20 Procedure for Preparation of Fuel Handling Procedures 13.5.1.21 Procedure for Preparation of Health Physics Procedures 13.5.1.22 Procedure for Preparation of Chemistry Procedures 13.5.1.23 Procedure for Temporary Changes to Approved Procedures 13.5.1.24 Procedure for Preparation of Off-Normal Procedures 13.5.1.25 Procedure for Preparation of Event Procedures and Special Event Procedures 13.5.1.25.1 Procedure for the Preparation of Event Procedures 13.5.1.25.2 Procedure for the Preparation of Special Event Procedures 13.5.1.26 Procedure for Preparation of Radwaste Procedures 13.5.2 Operating and Maintenance Procedures 13.5.2.1 Control Room Operating Procedures 13.5.2.2 Control of Unit 2 Construction Activities During Unit 1 Operation 13.5.2.3 Additional Operating and Maintenance Procedures 13.5.3 Operations Technical Requirements Manual (TRM) 13.5.4 Surveillance Frequency Control Program (SFCP) 13.5.5 References 13.6 INDUSTRIAL SECURITY CHAPTER 13 13-ii REV. 18, SEPTEMBER 2016

LGS UFSAR CHAPTER 13 - CONDUCT OF OPERATIONS LIST OF TABLES TABLE TITLE 13.1-1 Plant Staffing 13.1-2 Shift Crew Composition - Minimum Requirements 13.2-1 Matrix of LGS Training Program Guidelines CHAPTER 13 13-iii REV. 18, SEPTEMBER 2016

LGS UFSAR CHAPTER 13 - CONDUCT OF OPERATIONS LIST OF FIGURES FIGURE TITLE 13.1-1 Deleted 13.1-2 Limerick Generating Station Organization Chart 13.1-3 Health Physics Organization Chart 13.1-4 Deleted 13.2-1 Training Organization 13.5-1 Definition of "At the Controls" 13.5-2 SRO Control Room Boundaries CHAPTER 13 13-iv REV. 18, SEPTEMBER 2016

LGS UFSAR CHAPTER 13 - CONDUCT OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE The Exelon Generation Company, LLC (EGC) corporate organization and its functions and responsibilities are described in Chapter 1 of the Quality Assurance Topical Report (QATR) designated as NO-AA-10, as revised.

13.1.2 OPERATING ORGANIZATION Limerick Generating Station is under the direction of the Vice President-Limerick Generating Station who is accountable to the Senior Vice President-Nuclear Operations. The Vice President-Limerick Generating Station has overall control and responsibility for the conduct of activities of all organizations at the Limerick Generating Station. All station organizations are accountable to the Vice President-Limerick Generating Station except for those organizations involved in the independent corporate assessment and oversight activities described in Chapter 17 of the UFSAR.

The Plant Manager is the Vice President's deputy and is responsible for day-to-day plant operations, maintenance and technical support. The Plant Manager assumes responsibility for all station activities in the absence or unavailability of the Vice President.

The station organization chart for Limerick Generating Station is shown in Figure 13.1-2. This figure, along with Table 13.1-2, shows the title of each position and the positions for which reactor operator and senior reactor operator licenses are required. The requirements for selection, qualification and training of Limerick Generating Station personnel are specified in Section 13.1.3, Qualification of Nuclear Plant Personnel. Table 13.1-1 shows the original schedule for filling the station operating position.

Succession of Authority The Vice President-Limerick Generating Station has overall responsibility for station activities.

The Plant Manager is the Vice President's deputy and, in that capacity, is responsible for day-to-day plant operations, maintenance and technical support. The Plant Manager assumes responsibility for all station activities in the absence or unavailability of the Vice President. If both the Vice President and the Plant Manager are unavailable, absent, or incapacitated, one of the following will be designated as responsible for all station activities: Director-Site Engineering; Director-Plant Operations; Shift Operations Superintendent; or Senior Manager-Plant Engineering.

13.1.2.1 Plant Operations Department The Plant Operations Department is under the direction of the Plant Manager who is accountable to the Vice President-Limerick Generating Station. The Plant Manager is responsible for operating and maintaining the plant safely, reliably, and efficiently. Also, the Plant Manager ensures compliance with all applicable Technical Specifications, quality assurance requirements, procedures, and federal, state, and local requirements. The following managers report directly to the Plant Manager:

Director-Plant Operations; Director-Maintenance; CHAPTER 13 13.1-1 REV. 18, SEPTEMBER 2016

LGS UFSAR Director-Work Management; Manager-Radiation Protection; and, Manager-Chemistry/Radwaste; 13.1.2.1.1 Operations Department The Operations Department is under the direction of the Director-Plant Operations who reports to the Plant Manager. The Director-Plant Operations has the following management level direct reports:

Shift Operations Superintendent Senior Manager-Operations Support/Services Manager-Reactor Engineering The Shift Operations Superintendent under the direction of the Director-Plant Operations is responsible for management oversight of shift operations including the following activities:

a. Day-to-day operating routine;

b. Investigation and resolution of abnormal or emergency operating situations;

c. Ensuring that operations are carried out in a safe, efficient manner and in strict conformance to the operating license, technical specifications, and operating procedures;

d. Close liaison with other station groups to ensure safe equipment startup and shutdown;

e. Surveillance and routine maintenance activities within his purview;

f. Ensuring that other station activities do not place the plant in an unsafe condition;

g. Evaluation of the operating history of the plant (such as equipment operating failures or operator errors) to detect changes that may improve availability, reliability, and safety in plant operation; and,

h. Shift training.

Shift Managers The Shift Operating Crews are supervised by Shift Managers who report directly to the Shift Operations Superintendent. The Shift Managers are in charge of and responsible for plant operations on their shift. They are specifically responsible for supervising and directing operating employees during a shift and ensuring that work is performed according to approved procedures. They are also responsible for coordinating maintenance activities on their shift.

Shift Managers are SRO licensed and have the authority to direct a plant shutdown or to direct the plant to any specific set of conditions commensurate with approved procedures when observations of plant equipment or conditions indicate that a nuclear safety hazard exists, or as directed by approved procedures. In this context, Shift Managers have the responsibility and authority for issuing standing or special orders.

The Shift Managers must remain aware of and in control of plant operational, maintenance, and testing activities that may affect safe operation. In the assignment of duties to the Shift CHAPTER 13 13.1-2 REV. 18, SEPTEMBER 2016

LGS UFSAR Managers, consideration is given to the need to prevent administrative duties from detracting from the primary responsibility of ensuring safe operation of the plant. The Shift Manager may concurrently function as the STA provided the individual meets the Commission Policy Statement on Engineering Expertise on Shift.

Shift Supervisors The Shift Supervisors report to the Shift Manager on their shift and assist the Shift Manager in supervising and directing the employees who operate the plant. The Shift Supervisors ascertain and remain aware of plant equipment conditions by reviewing reports and by making personal inspections. They are responsible for scheduling certain routine tests and maintenance activities. Shift Supervisors are SRO licensed and have the authority to direct a plant shutdown when observations of plant equipment or conditions indicate that a nuclear safety hazard exists, or as directed by approved procedures. A Shift Supervisor may concurrently function as the STA provided the individual meets the Commission Policy Statement on Engineering Expertise on Shift. A Shift Supervisor may serve as the fire brigade leader when not assigned as Control Room Supervisor or the STA.

Shift Technical Advisors Shift Technical Advisors (STA) report to the Shift Managers. Limerick uses either of the two options contained in Generic Letter 86-04, "Policy Statement on Engineering Expertise on Shift," for meeting the requirement for a Shift Technical Advisor (STA). These two options are as follows.

1. An STA program in accordance with the description in NUREG-0737 (Item 1.A.1.1); or

2. Combine one of the required licensed Senior Reactor Operator (SRO) positions and the STA position (i.e., dual-role SRO/STA).

If the second option is selected, the STA position may be filled by the on-shift Shift Manager, a Shift Supervisor, or any SRO provided the individual meets the Commission Policy Statement on Engineering Expertise on Shift. The STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Plant Operators (Plant Reactor/Reactor Operators)

Plant Operators are Licensed Reactor Operators (RO) classified as either Plant Reactor Operators or Reactor Operators and report to the Shift Supervisors on their shift. They are responsible for manipulating station controls as necessary to match load demands, respond to process changes, and take immediate operator action as necessary to bring the plant into and/or maintain the plant in a safe condition during abnormal or emergency conditions. They keep the Shift Supervisor informed of plant activities related to operations. Plant Reactor Operators and Reactor Operators have the authority to shut down the plant when observations of plant equipment or conditions indicate that a nuclear safety hazard exists or as directed by approved procedures.

CHAPTER 13 13.1-3 REV. 18, SEPTEMBER 2016

LGS UFSAR Equipment Operators Equipment Operators report to the Shift Supervisor and perform routine duties outside the control room as necessary for continuous, safe plant operation. They are available to Shift Supervisors for additional work assignments that may arise from time to time. They assist in plant startup, shutdown, surveillance, and emergency response as directed by the Plant Reactor Operator, Reactor Operator, and/or shift supervision.

Operating Shift Crew The position titles, applicable operator licensing requirements, and minimum number of personnel for each shift are described in Table 13.1-2 for the various combinations of units in either the operating or cold shutdown mode. Operating shift coverage is provided 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week.

Fire Brigade The Limerick Generating Station fire brigade consists of at least 5 members and is maintained onsite at all times. The fire brigade shall not include the Shift Manager, the Shift Technical Advisor, nor the two other members of the minimum shift crew necessary for safe shutdown of the unit and personnel required for other essential functions during a fire emergency. The fire brigade composition may be less than the minimum requirements for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to accommodate unexpected absence, provided that immediate action is taken to fill the required positions. The brigade leader and at least 2 brigade members will have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability. The brigade leader will be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader is evidenced by possession of an operator's license, or equivalent knowledge of plant safety-related systems.

The qualification of fire brigade members will include an annual physical examination to determine their ability to perform strenuous fire fighting activities. The responsibilities of the fire brigade include:

a. Responding to fire alarms with appropriate equipment and protective clothing;

b. Advising the Interim Emergency Director or Emergency Director as to the need for assistance from the plant staff or from offsite fire fighting groups; and,

c. Coordinating the actions of offsite fire fighting groups if onsite assistance is requested.

Operations Support Section The Manager-Operations Support Section reports to the Senior Manager - Operations Support/Services and is responsible for supporting the daytime shift organization by relieving operators and shift management of some of their administrative burdens and ensuring effective coordination of operations programs and projects.

Operations Support personnel are responsible for fire brigade training, drills, maintenance of qualifications, testing, issuance of impairments, and maintenance of fire brigade equipment.

CHAPTER 13 13.1-4 REV. 18, SEPTEMBER 2016

LGS UFSAR The Operations Support Section is responsible for Operations procedures, plant labeling, Operations commitment tracking, business planning, scheduling, timekeeping, and reviewing operating experience reports that may be directed to the plant by various industry groups and regulatory agencies to determine the impact on Operations Section programs and practices.

Operations Services Section The Manager-Operations Services Section reports to the Senior Manager - Operations Support/Services and is responsible for clearance and tagging coordination, and work coordination.

Reactor Engineering Section The Manager-Reactor Engineering reports to the Director-Plant Operations and is responsible for the implementation of in-core fuel management, reactivity management, Special Nuclear Material (SNM) accounting, and support of day-to-day operations.

13.1.2.1.2 Radiation Protection Department The Manager-Radiation Protection reports to the Plant Manager and fills the position of the radiation protection manager as described in Regulatory Guide 8.8 (1978). Reporting to the Manager-Radiation Protection are: Health Physics Supervisors; Manager - Radiological Engineering; Manager - Tech. Support; and Contamination Control Supervisor.

Figure 13.1-3 shows the site Health Physics organization. In the absence of the Manager-Radiation Protection, a person temporarily filling this position will be qualified in accordance with the guidance specified in Regulatory Guide 1.8 (1975) and NUREG/CR-5569, "Health Physics Positions Data Base." The Manager - Radiation Protection is responsible for implementing the radiation protection program and the ALARA program functions described in Regulatory Guide 8.8 (Rev 3-1977) and Regulatory Guide 8.10 (1977), as follows:

a. Developing and implementing an effective radiation exposure control and measurement program in consonance with the ALARA program;

b. Ensuring that exposure measurement and control programs are periodically reviewed and that appropriate revisions and corrective actions are taken when the results of these programs indicate that such actions are needed to conform to the radiation protection program;

c. Preparing and reviewing procedures for implementing the Radiation Protection program;

d. Ensuring that the resources needed to implement the Radiation Protection program are available and used;

e. Participating in reviews, including design and procedure reviews at the PORC level, of facilities, activities, and equipment that can affect potential radiation exposures; CHAPTER 13 13.1-5 REV. 18, SEPTEMBER 2016

LGS UFSAR

f. Ensuring that radiation, surface contamination, and airborne activity surveys are performed and the resulting data reviewed to identify locations, operations, and conditions that have the potential for causing significant exposures and appropriate means for reducing such exposures are developed;

g. Participating in the development of training programs related to the Radiation Protection program to ensure that personnel are aware of licensee management's commitment to ALARA and are instructed in ways of reducing exposures that are related to work in radiation areas or that involve radioactive materials;

h. Supervising the radiation surveillance program and the collection, analysis, and evaluation of data from radiological surveys and from personnel exposures and doses, including the use of the RWP data;

i. Supervising and training of the radiation protection staff;

j. Providing appropriate data and information related to the Radiation Protection program and results to keep management informed about the program; and

k. Implementation of the Industrial Safety Program.

l. Performance of housekeeping (including decontamination operations) in radiological areas and industrial areas of the site.

m. Managing the shipment of radioactive material.

13.1.2.1.3 Chemistry/Radwaste Department The Manager-Chemistry/Radwaste reports to the Plant Manager and is responsible for implementation of the Plant Chemistry, Radwaste, and Environmental and Controlled Materials programs including:

a. Developing and implementing procedures and practices for chemistry and radiochemistry control and for performing appropriate analyses;

b. Advising management when establishing operating methods to minimize plant radiation levels and radwaste production and to improve plant water quality;

c. Advising management of trends in plant chemistry data;

d. Managing the Chemistry Program to ensure that high quality sampling and analysis capability is present;

e. Managing Radwaste processing; and

f. Managing the Environmental and Controlled Materials Program.

Reporting to the Manager-Chemistry/Radwaste are the Chemistry Programs Supervisor, Radwaste/Environmental Supervisor, Operational Chemistry Supervisor, and Technical Support CHAPTER 13 13.1-6 REV. 18, SEPTEMBER 2016

LGS UFSAR Specialist. These managers/supervisors are responsible for implementing the routine chemistry programs in the plant, supervising personnel who collect and analyze plant samples, daily interface with Operations, troubleshooting of chemistry anomalies, processing radioactive waste, and managing the Environmental and Controlled Materials Program.

13.1.2.1.4 Maintenance Department The Maintenance Department is under the direction of the Director-Maintenance who reports to the Plant Manager. The Director-Maintenance is responsible for the safe, effective and efficient performance of maintenance of plant equipment, instruments and controls in accordance with applicable regulations, policies and procedures. The Maintenance Department consists of Mechanical/Electrical Maintenance, Instrument and Controls Maintenance, Maintenance Support, CMO, and Maintenance Planning.

Mechanical/Electrical Maintenance Mechanical/Electrical Maintenance is supervised by the Manager-Mechanical/Electrical Maintenance who reports to the Director-Maintenance. The Manager-Mechanical/Electrical Maintenance is responsible for the assignment, supervision, and coordination of activities performed by Mechanical/Electrical Maintenance section Craftsmen and Crafts Supervisors.

Instrument and Controls Maintenance Instrument and Controls Maintenance is supervised by the Manager-Instrument and Controls Maintenance who reports to the Director-Maintenance. The Manager-Instrument and Controls Maintenance is responsible for the calibration, surveillance testing, maintenance, record keeping, and troubleshooting of instruments and controls, portable measuring equipment and plant computers.

Maintenance Planning Maintenance Planning is supervised by the Manager-Maintenance Planning who reports to the Director-Maintenance. The Manager-Maintenance Planning is responsible for managing the planning of all plant maintenance and plant instrumentation and controls activities.

CMO CMO is supervised by the Manager-CMO who reports to the Director-Maintenance. The Manager-CMO is responsible for the Predictive Maintenance Program.

Maintenance Support Maintenance Support is supervised by the Manager-Maintenance Support who reports to the Director-Maintenance. The Manager-Maintenance Support is responsible for managing all maintenance programs, building facilities, maintenance contractor administration and the maintenance modification contractor.

13.1.2.1.5 Work Management Department The Director-Work Management reports to the Plant-Manager. The Director-Work Management is responsible for assuring that outages are effectively planned and managed; CHAPTER 13 13.1-7 REV. 18, SEPTEMBER 2016

LGS UFSAR planning, scheduling, and reporting site work activities; implementing plant modifications and materials management. The Director-Work Management is also responsible for the management of engineering projects and ensures that all engineering work is planned, scheduled, budgeted, implemented, technically supported, and evaluated in a timely and cost effective manner. Reporting to the Director are the Manager-Outages, Manager- Online Work Control, and Manager-Supply Management.

13.1.2.2 Nuclear Security Department The Manager-Nuclear Security reports to the Vice President-Limerick Generating Station and is responsible for control, maintenance and implementation of the site security program including coordinating all activities associated with site access.

13.1.2.3 Site Engineering Department The Site Engineering Division is under the direction of the Director-Site Engineering who is accountable to the Vice President-Limerick Generating Station. The Director-Site Engineering is responsible for planning, directing and coordinating onsite engineering and technical support activities in accordance with applicable regulations, policies and procedures. The Site Engineering Department is composed of the following: Plant Engineering; Design Engineering; Programs.

Plant Engineering Plant Engineering is managed by the Senior Manager-Plant Engineering, who reports to the Director-Site Engineering.

Plant Engineering is responsible for supporting all aspects of system operation and maintenance including but not limited to: maintaining a high level of system knowledge; participating in design, licensing and procedural changes; initiating improvements; reviewing system operations and maintenance; trending and monitoring system performance; and performing other system related tasks as required.

Design Engineering Design Engineering is managed by the Senior Manager-Design Engineering who reports to the Director-Site Engineering.

Design Engineering is responsible for but not limited to: supporting the Station in design changes involving hardware, software, and licensing documents; maintaining design programs; owning and maintaining design bases; and providing rapid response to emerging plant issues.

Programs Programs is managed by the Manager-Programs who reports to the Director-Site Engineering.

Programs engineers are responsible for the administering of Programs such as: In-Service Inspection, Fire Protection, Motor Operated Valves, In-Service Testing, Snubbers, Thermal Performance, and Probabilistic Safety Assessments.

13.1.2.4 Deleted CHAPTER 13 13.1-8 REV. 18, SEPTEMBER 2016

LGS UFSAR 13.1.2.5 Training Department The Training Department is directed by the Director-Training, who is accountable to the Vice President-Limerick Generating Station. The Director-Training identifies the programmatic training needs of all site personnel, ensures the effectiveness of training programs, incorporates operating experience into training, and monitors participation.

The Training Department is composed of the following sections each reporting to a section Manager:

a. Operations Training Section;

b. Maintenance and Technical Training Section; 13.1.2.6 Regulatory Assurance Department The Regulatory Assurance Department is supervised by the Manager-Regulatory Assurance, who reports to the Vice President-Limerick Generating Station. The Manager-Regulatory Assurance is responsible for the following:

a. Supporting and advising the Plant Manager and all site organizations on compliance with NRC regulations and reporting requirements;

b. Reviewing operating experience reports that may be directed to the plant by various industry groups and regulatory agencies and for disseminating such reports to the appropriate personnel for review for applicability to LGS and determination of required action;

c. Coordinating regulatory and INPO interfaces and communicating with the Corporate Licensing Section;

d. Coordinating the review of plant events to determine causes and corrective actions. This includes event trend analysis, tracking status of event evaluations and corrective action, and reporting the results to management;

e. Coordinating the site commitment tracking program and closure of NRC open items; and,

f. Coordinating requests for and implementing Technical Specification amendments.

g. Coordinating the site emergency preparedness program.

13.1.2.7 Human Resources Department The Manager-Human Resources reports to the site Vice President. The Manager-Human Resources is responsible for ensuring that all human resources functional responsibilities are performed in accordance with company policies and all applicable laws, regulations, licenses, and technical requirements. The Manager-Human Resources is also responsible for directing and implementing the medical program.

CHAPTER 13 13.1-9 REV. 18, SEPTEMBER 2016

LGS UFSAR 13.1.2.8 Organizational Effectiveness Department The Manager-Organizational Effectiveness reports to the site Vice President. The Manager-Organizational Effectiveness is responsible for oversight, guidance, and support to site leadership teams through assessment, monitoring, and mentoring in the areas of corrective action program, human performance, and performance improvement programs.

13.1.3 Qualification of Nuclear Plant Personnel 13.1.3.1 Qualification Requirements The qualification requirements for the onsite plant operating staff personnel are as provided in ANSI/ANS 3.1 (1978), "Standard for Selection and Training of Personnel for Nuclear Plants" and Regulatory Guide 1.8 (Rev. 1) The medical certification of licensed reactor operators and senior reactor operators is in accordance with ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants," as endorsed by Regulatory Guide 1.134 (Rev 2).

Training programs for the unit staff shall be maintained under the direction of the site training organization. The retraining and replacement training programs for all affected positions except licensed operators shall meet or exceed the standards of ANSI/ANS 3.1-1978. The retraining and replacement training programs for licensed operators shall comply with the requirements of 10 CFR 55 and shall include familiarization with relevant industry operational experience.

The Limerick Generating Station staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions, except the Manager - Radiation Protection who shall meet or exceed the qualifications of Regulatory Guide (RG) 1.8, "Personnel Selection and Training," September 1975, and the licensed operators who shall comply only with the requirements of 10CFR55. Administrative controls exist to ensure that all personnel satisfy those requirements.

13.1.3.2 Qualifications of Plant Personnel The presently assigned plant operating staff personnel meet or exceed the minimum qualification requirements indicated in Section 13.1.3.1 and as established by administrative controls.

13.1.4 Special Projects Executive Management for each Special Project is accountable to the President and Chief Nuclear Officer. Special Projects are responsible for the investigation and performance of ventures outside of the NG. Special Projects does not directly support the operation/maintenance of NG facilities.

CHAPTER 13 13.1-10 REV. 18, SEPTEMBER 2016

LGS UFSAR Table 13.1-1 PLANT STAFFING DATE POSITION APPOINTED Station Superintendent 1975 Assistant Station Superintendent 1976 Operations Engineer 1982 Shift Superintendents 1981 Shift Supervisors 1981 Control Operators 1980 Assistant Control Operators 1980 Plant Operators 1982 Assistant Plant Operators 1982 Auxiliary Operators 1982 Technical Engineer 1979 Senior Health Physicist 1982 Physicist - Applied 1983 Physicist - Technical Support 1983 Senior Chemist 1983 Instrumentation and Controls Engineer 1981 Reactor Engineer 1982 Maintenance Engineer 1982 Training Coordinator 1980 Note: The information provided in this table is historical and does not reflect the most current operating organization titles.

CHAPTER 13 13.1-11 REV. 13, SEPTEMBER 2006

LGS UFSAR Table 13.1-2 SHIFT CREW COMPOSITION - MINIMUM REQUIREMENTS(1,2,3,4)

ONE UNIT FUELED TWO UNITS FUELED LICENSE Two Units One-Unit Operating and Two Units POSITION REQUIRED Operating Cold Shutdown Operating One-Unit Shutdown Cold Shutdown Shift Manager SRO 1 1 1 per 2 units 1 per 2 units 1 per 2 units Shift supervisor SRO 2 2 2 per 2 units 2 per 2 units 2 per 2 units Plant Reactor operator RO 1 The Plant Reactor 1 per 2 units 1 per 2 units -

operator position or the assistant position will be manned.

Reactor operator RO 1 - 1 per unit 1 per unit 1 per unit Equipment operator - 2 The equipment 3 per 2 units 3 per 2 units 3 per 2 units operator position will be manned (1)

At least one licensed RO shall be present in the control room and assigned to each reactor that contains fuel.

(2)

At least 2 licensed ROs, excluding the operator of the second unit, shall be present in the control room during reactor startup, scheduled reactor shutdown, and recovery from reactor trips.

(3)

All core alterations shall be directly supervised by either a licensed SRO or SRO Limited to Fuel Handling, who has no other concurrent responsibility during this operation.

(4)

A health physics technician shall be onsite at all times when fuel is in a reactor to ensure implementation of the radiation protection program.

CHAPTER 13 13.1-12 REV. 13, SEPTEMBER 2006

LGS UFSAR 13.2 TRAINING 13.2.1 PLANT PERSONNEL TRAINING PROGRAM The Limerick Generating Station (LGS) training program incorporates the requirements specified in 10CFR55, 10CFR50 as promulgated in the NRC Final Rule 10CFR50.120 - "Training and Qualification of Nuclear Power Plant Personnel," which became effective May 26, 1993 and the applicable provisions of the Operating Licenses, including the Technical Specifications. The LGS training program is based on a Systems Approach to Training (SAT). The training program provides qualified personnel to operate and maintain the facility in a safe manner in all modes of operation. The training program will be periodically reviewed by management for effectiveness, and will be periodically evaluated and revised, as appropriate, to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements.

Achievement of this goal is based on a philosophy of providing training developed from a systematic analysis of job requirements using job and task analysis where available. This philosophy is consistent with both Nuclear Regulatory Commission (NRC) requirements and Institute of Nuclear Power Operations (INPO) recommendations necessary for accreditation of training programs.

13.2.1.1 INPO Accredited Training Programs The following training programs have been accredited by INPO and are continually maintained based on Systems Approach to Training (SAT).

Program Date Originally Accredited

1. Non-Licensed Operator 10/30/86

2. Reactor Operator 10/30/86

3. Senior Reactor Operator 10/30/86

4. Shift Manager (formerly Shift Supervisor) 10/30/86

5. Shift Technical Advisor 10/30/86

6. Engineering Support Personnel 10/30/86

7. Licensed Operator Requalification 10/30/86

8. Maintenance Technician - Mechanical and Supervisor 10/30/86

9. Maintenance Technician - Electrical and Supervisor 10/30/86

10. Instrument and Control Technician and Supervisor 10/30/86

11. Chemistry Technician 10/30/86

12. Health Physics Technician 10/30/86 Program/Course plans describing the content and details of these programs are maintained by the Nuclear Training Section.

CHAPTER 13 13.2-1 REV. 15, SEPTEMBER 2010

LGS UFSAR 13.2.1.2 Access Training Persons employed at LGS, including temporary maintenance and service personnel, are required to successfully complete General Employee Training (GET) and Fitness for Duty Training (FFD) prior to being granted unescorted site protected area access. Retraining is required in both GET and FFD on a nominal annual basis. Training content is commensurate with job responsibilities, and complies with the requirements of:

10CFR19.12 (GET),

10CFR26 (FFD),

and the guidance specified in:

ANSI/ANS 3.1-1978 (GET),

Regulatory Guide 8.13 (GET),

Regulatory Guide 8.27 (GET),

Regulatory Guide 8.29 (GET).

General Respiratory Training (GRT) is required for personnel who may wear respiratory protective equipment as part of normal work requirements or as emergency response team members. Re-training in GRT is required on a nominal annual basis. The content and conduct of GRT complies with the recommendations specified in NUREG-0041, "Manual of Respiratory Protection Against Airborne Radio-Materials," and Regulatory Guide 1.78, Position C-13, and the criteria of ANSI Z88.2.

Program/Course Plans for GET, GRT, and FFD are maintained by the Nuclear Training Section.

These plans provide a detailed description of the Program/Course, in accordance with the provisions of Regulatory Guide 1.70.

13.2.1.3 Emergency Preparedness Training See the Emergency Plan (Ref: UFSAR 13.3) 13.2.1.4 Radwaste Shipping Training Training of personnel involved in Radwaste packing, shipping, handling, or minimization receive training appropriate to the level of the task they perform. This training complies with the guidance in NRC I.E.Bulletin 79-19. A Program/Course Plan for Radwaste Shipping Training is maintained by the Nuclear Training Section. These plans provide a detailed description of the Program/Course, in accordance with the provisions of Regulatory Guide 1.70.

13.2.1.5 Fire Protection Training The objective of fire protection training is to ensure that the shift and plant staff Fire and Damage Teams are prepared and capable of responding to fire emergencies. Leaders and members of the Fire Brigade receive initial training at the West Conshohocken Fire School. Site specific fire training is administered on a 2 year cycle. Each fire brigade member participates in at least two drills per year. Also see Section 9.5.1.5.

CHAPTER 13 13.2-2 REV. 15, SEPTEMBER 2010

LGS UFSAR The fire brigade training program will consist of an initial classroom instruction program followed by periodic classroom instruction, fire fighting practice, and fire drills as follows:

a. Instruction

1. The initial classroom instruction will include:

(a) Indoctrination of the plant fire fighting plan with specific identification of each individual's responsibilities.

(b) Identification of the type and location of fire hazards and associated types of fires that could occur in the plant.

(c) Toxic and corrosive characteristics of expected products of combustion.

(d) Identification of the location of fire fighting equipment for each fire area and familiarization with the layout of the plant, including access and egress routes to each area.

(e) Proper use of available fire fighting equipment and the correct method of fighting each type of fire. The types of fires covered should include fires in energized electrical equipment, fires in cables and cable trays, hydrogen fires, fires involving flammable and combustible liquids or hazardous process chemicals, fires resulting from construction or modifications (welding), and record file fires.

(f) Proper use of communication, lighting, ventilation, and emergency breathing equipment.

(g) Proper method for fighting fires inside buildings and confined spaces.

(h) Direction and coordination of the fire fighting activities (fire brigade leaders only).

(i) Detailed review of fire fighting strategies and procedures.

(j) Review of the latest plant modifications that affect the fire fighting equipment or the fire fighting plans.

Items (i) and (j) may be deleted from training of no more than two of the non-operations personnel who may be assigned to the fire brigade

2. Instruction will be provided by qualified individuals who are knowledgeable, experienced, and suitably trained in fighting the types of fires that could occur in the plant and in using the types of equipment available in the plant.

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3. Instruction will be provided to all fire brigade members and fire brigade leaders.

4. Regular planned meetings will be held at least every 3 months for all brigade members to review changes in the fire protection program and other subjects as necessary.

5. Periodic refresher training sessions will be held to repeat the classroom instruction program for all brigade members over a 2 year period. These sessions may be concurrent with the regular planned meetings.

b. Practice Practice sessions will be held on the proper method of fighting the various types of fires that could occur in a nuclear power plant. These sessions will provide brigade members with experience in actual fire extinguishment and the use of emergency breathing apparatus under strenuous conditions encountered in fire fighting.

These practice sessions will be provided at least once per year for each fire brigade member.

c. Drills

1. Fire brigade drills will be performed in the plant so that the fire brigade can practice as a team. In addition to in-plant drills, an offsite facility enables drills to include the use of the live fire conditions. These elements plus the use of breathing apparatus and full protective clothing create actual conditions that would be encountered during a real plant fire emergency.

Additional drills, including backshift unannounced drills are conducted in plant areas throughout the year.

2. Drills will be performed at regular intervals not to exceed 3 months. Each fire brigade member should participate in each drill, but must participate in at least two drills per year.

A sufficient number of these drills, but not less than one for each shift fire brigade per year, will be unannounced to determine the fire fighting readiness of the plant fire brigade, brigade leader, and fire protection systems and equipment. Persons planning and authorizing an unannounced drill will ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun.

Unannounced drills will not be scheduled closer than 4 weeks.

At least one drill per year will be performed on a "back shift" for each shift fire brigade.

3. The drills will be preplanned to establish the training objectives of the drill and will be critiqued to determine how well the training objectives have been met.

CHAPTER 13 13.2-4 REV. 15, SEPTEMBER 2010

LGS UFSAR Unannounced drills will be planned and critiqued by members of the management staff responsible for plant safety and fire protection.

Performance deficiencies of a fire brigade or of individual fire brigade members will be remedied by scheduling additional training for the brigade or members. Unsatisfactory drill performance will be followed by a repeat drill within 30 days.

4. At 3 year intervals, a randomly selected unannounced drill will be critiqued by qualified individuals independent of the plant staff. A copy of the written report from such individuals will be available for NRC review.

5. Drills will, as a minimum, include the following:

(a) Assessment of fire alarm effectiveness, time required to notify and assemble the fire brigade, and selection, placement, and use of equipment and fire fighting strategies.

(b) Assessment of each brigade member's knowledge of their role in the fire fighting strategy for the area assumed to contain the fire.

Assessment of the brigade member's conformance with established plant fire fighting procedures and use of fire fighting equipment, including self-contained emergency breathing apparatus, communication equipment, and ventilation equipment, to the extent practicable.

(c) Simulated use of fire fighting equipment required to cope with the situation and type of fire selected for the drill. The area and type of fire chosen for the drill should differ from those used in the previous drill so that brigade members are trained in fighting fires in various plant areas. The situation selected should simulate the size and arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, to obtain equipment, and organize for the fire, assuming the loss of automatic suppression capability.

(d) Assessment of the brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.

d. Records Individual records of training provided to each fire brigade member, including drill critiques, will be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training will be available for NRC review. Retraining or broadened training for fire fighting within buildings will be scheduled for all those brigade members whose performance records show deficiencies.

13.2.1.6 Fire Protection Requalification Training CHAPTER 13 13.2-5 REV. 15, SEPTEMBER 2010

LGS UFSAR Leaders and members of the Fire Brigade receive annual refresher training at the West Conshohocken Fire School. Site specific fire training is administered on a 2 year cycle. Each fire brigade member participates in at least two drills per year.

All diesel operations and operational maintenance activities at LGS are performed by operations personnel as described in Section 13.1.2. The licensee includes diesel generator training in the INPO accredited programs for operations personnel and supervision, tailored to the specific job classifications, based upon task analyses. This training, originally drawn from manufacturers recommendations, is equivalent to vendor training. Operations personnel perform diesel generator activities in accordance with approved operating and test procedures.

Activities beyond the responsibilities assigned to operating personnel are referred to plant technical personnel and/or maintenance personnel. Maintenance personnel may be members of the onsite or offsite organization. The licensee provides a variety of INPO accredited maintenance training classes to ensure the availability of qualified maintenance technicians and supervisors. Maintenance activities are performed under supervision appropriately qualified and experienced on the type of diesel generators at Limerick. Maintenance supervision is responsible for the assignment of personnel properly qualified for the task. Qualified personnel, qualified and experienced Maintenance supervision, use of approved procedures, and technical expertise of manufacturers service representatives provides competency equivalent to vendor training so that diesel generator reliability is maintained.

13.2.2 Records The plant training organization is responsible for maintaining training records for the plant staff.

Records for the plant staff shall be sufficient to show qualification for the position held. As applicable for the training course, records include copies of written examinations and answers, lecture attendance records, results of evaluations, and records of additional remedial training. All quality records indicating pertinent, formalized training of the plant staff shall be entered into the Nuclear Records Management System for proper maintenance and recall, by the plant nuclear training section.

13.2.3 Training Organization 13.2.3.1 See Figure 13.2-1 CHAPTER 13 13.2-6 REV. 15, SEPTEMBER 2010

LGS UFSAR Table 13.2-1 Matrix of LGS Training Program Guidelines Intentionally Left Blank (See Section 13.2.1)

CHAPTER 13 13.2-7 REV. 13, SEPTEMBER 2006

LGS UFSAR 13.3 EMERGENCY PLANNING The Exelon Standardized Radiological Emergency Plan (EP-AA-1000) for the LGS has been submitted as a separate document.

CHAPTER 13 13.3-1 REV. 13, SEPTEMBER 2006

LGS UFSAR 13.4 REVIEW AND AUDIT 13.4.1 GENERAL The licensee shall establish and implement review and audit functions to ensure that activities important to safety are properly accomplished in accordance with company policies and rules, approved operating procedures, and operating license provisions during the operations phase. As fully described below, these functions are as provided in ANSI N18.7 (1976)/ANS 3.2, paragraphs 4.1 through 4.5, as modified by Regulatory Guide 1.33 (Rev 2), positions C.3, C.4, and C.5.a, and ensure implementation of 10CFR50.59 with regard to proposed changes, tests, and experiments.

The review and audit functions will be implemented in accordance with the provisions of the Quality Assurance Topical Report (QATR) and are described in the QATR.

13.4.2 ONSITE REVIEW The Plant Operations Review Committee (PORC) satisfies a portion of the independent review program requirement described in ANSI N187 (1976) / ANS 3.2, Section 4.3, "Independent Review Program". A comprehensive description of the PORC function is located in Exelon Procedure LS-AA-106, "Plant Operations Review Committee". Exelon process description NO-AA-10, "Standard Quality Assurance Topical Report (QATR)," also includes a description of PORC functions. PORC performs independent reviews of activities that have the potential to affect nuclear safety and advises the plant manager regarding approval or disapproval of these activities.

13.4.3 INDEPENDENT REVIEW The information from this section has been relocated to the Quality Assurance Topical Report (QATR).

13.4.4 ASSESSMENT PROGRAM The information from this section has been relocated to the Quality Assurance Topical Report (QATR).

The QATR describes how the Quality Assurance Program is to be functionally implemented with due regard to the safety and health of the public and the personnel on site. The LGS Quality Assurance Program as described by the QATR is incorporated herein by reference.

13.4.5 INDEPENDENT TECHNICAL REVIEW FUNCTION The information from this section has been relocated to the Quality Assurance Topical Report (QATR).

CHAPTER 13 13.4-1 REV. 13, SEPTEMBER 2006

LGS UFSAR 13.5 PLANT PROCEDURES Safety-related activities performed by the plant staff shall be governed by written and approved procedures of a type appropriate to the circumstances and activity, and shall be carried out in accordance with those procedures. Where appropriate for determining that important activities have been satisfactorily accomplished, quantitative or qualitative acceptance criteria shall be included. The licensee utilizes the operating experience gained at PBAPS Units 2 & 3 (BWR units similar to LGS) in the development of the procedures.

As fully described below, the licensee has implemented ANSI N18.7 (1976)/ ANS 3.2, Section 5 as modified by NRC Regulatory Guide 1.33 (Rev 2), paragraphs C.1 and C.5.b through C.5.j, as these documents apply to operating staff activities, in the preparation, content, and control of procedures. Programmatic controls are in place to assure that procedures are maintained current. These controls take the place of, and eliminate the need for, scheduled periodic reviews and revisions.

Sections 13.5.1.1 through 13.5.1.27 describe administrative procedures. Many of these sections describe how various procedure types (such as maintenance procedures or preventive maintenance procedures) are developed and controlled, whereas other sections describe an administrative process (such as purchasing).

It is planned that most administrative and operating procedures will be in effect at least six months prior to fuel loading of Unit 1. The procedures will be implemented with sufficient lead time to ensure that operating personnel can become familiar with them. The licensee recognizes the benefits of using the preoperational testing phase to demonstrate the adequacy of operating procedures and, where practicable, this will be accomplished.

The following paragraphs describe the types of procedures to be employed by station operating personnel in the conduct of safety-related activities. These procedures are normally prepared by the station operating staff. However, organizations providing technical support and consultants may assist in procedure development. The procedures and revisions thereto are reviewed by Station Qualified Reviewers (SQRs) who are approved and designated as such by the PORC Chairman to perform such reviews for specific classes of procedures. The SQRs determine in writing if a cross-disciplinary review is required by the appropriate personnel prior to approval.

Procedures or revisions thereto are approved by responsible Superintendents who are designated as such for specific classes of procedures by administrative procedures. PORC reviews administrative procedures and those procedures or revisions thereto requiring a 10 CFR 50.59 evaluation be performed. The Plant Manager or his designated alternate approves administrative procedures, emergency plan implementing procedures, security plan implementing procedures, and any procedure or revision thereto requiring a 10 CFR 50.59 evaluation be performed.

13.5.1 ADMINISTRATIVE PROCEDURES Administrative procedures generally include those that establish station management policy, those that control activities that involve interfaces among disciplines or groups supporting plant operations, and those that establish criteria for procedures and activities implemented by the plant staff and support organizations. Administrative procedures shall be prepared in sufficient detail so that tasks are performed in a consistent, efficient manner and to ensure that the necessary reviews and approvals are performed.

CHAPTER 13 13.5-1 REV. 15, SEPTEMBER 2010

LGS UFSAR The following paragraphs describe the administrative procedures expected to be employed. The numbers of procedures and their specific content may be altered as the procedures are developed and experience is gained in their implementation.

13.5.1.1 Procedure for Preparation and Control of Administrative Procedures This procedure shall provide the measures to control and coordinate the preparation, review, approval, and issuance of administrative procedures. This procedure shall require that administrative procedures be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used. The format and content of administrative procedures shall be defined as:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications or procedures as applicable.

d. Prerequisites when there are independent actions or procedures that must be completed prior to using the procedure.

e. Procedure section. The procedure shall provide the steps needed to perform the task in the degree of detail necessary to ensure correct, efficient performance without direct supervision or undue reliance on memory. This section may also provide criteria statements to be implemented by other procedures.

Administrative procedures are written to provide direction for the efficient administration of plant business and reflect the station management philosophy and to implement corporate policies regarding these functions.

13.5.1.2 Procedure for Plant Operations Review Committee This procedure shall define the requirements of membership, meeting frequency, quorum, responsibilities, authority, and records for the PORC in implementation of technical specification provisions. The PORC shall review significant conditions adverse to plant safety to ensure that the cause of the condition is identified, that corrective action is taken and documented, and that appropriate subjects are referred to the Nuclear Review Board.

13.5.1.3 Procedure for Plant and Shift Operations This procedure shall define the responsibilities and authority of plant operating personnel, including:

a. Prohibition against manipulation of the reactor controls by personnel who are not licensed reactor operators or senior reactor operators. Trainees may manipulate controls under the direct supervision of a licensed operator.

b. Requirement that apparatus and mechanisms that may affect the reactivity or power level of the reactor only be manipulated with the knowledge and consent of the licensed reactor operator or senior reactor operator present at the controls.

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c. Requirement for a licensed reactor operator or senior reactor operator to be present at the controls at all times when fuel is in the reactor.

d. Reactor operator's responsibility and authority for shutting down the reactor when he determines that the safety of the reactor is in jeopardy, when operating parameters exceed reactor protection setpoints and automatic shutdown does not occur, or when there is doubt as to whether safe conditions exist.

e. Responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or unscheduled or unexplained power change.

f. Senior reactor operator's responsibility for directing the licensed activities of the reactor operator and to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power change.

g. Responsibility to respond conservatively to instrument indications including the case in which the credibility of the indication is in doubt.

h. Responsibility to adhere to the technical specifications and the provisions of the operating license.

i. Responsibility to review routine operating information to ensure safe operation.

j. Functional relationship of the STA to the operating shift.

This procedure shall also provide instructions to plant staff and operating personnel in areas of general and continuing applicability to plant management such as:

a. The necessity to adhere to plant procedures and to refer directly to procedures for complex or extensive jobs where reliance on memory cannot be trusted, such as reactor startup, tasks that are infrequently performed, and complex tasks that must be performed in a specific order.

b. The responsibility of plant personnel to take action, in the event of an emergency not covered by approved procedures, so as to minimize personnel injury and damage to the facility, and to protect public health and safety.

c. Personnel conduct.

d. Availability on call of plant staff and operating personnel.

e. Preparation of plant logs and records.

f. Requirements for shift turnover.

g. Definition of "at the controls" (Figure 13.5-1).

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h. Recording data or completing documentation as tasks are performed when such data or documentation of tasks is required.

i. Definition of SRO control room boundaries (Figure 13.5-2).

13.5.1.4 Procedure for Release of Safety-Related Equipment This procedure shall implement the licensees standard requirements for blocking and tagging equipment and shall establish criteria for this function such as:

a. Designation of personnel authorized to release equipment or systems for maintenance and the method of documenting such authorization.

b. Aspects to be considered in releasing equipment such as: how long equipment may be out of service; potential for degradation of protection when one subsystem of a redundant safety system has been removed from service; equipment and personnel safety.

c. Aspects to be considered in returning equipment to service such as removal of jumpers and test signals and return of valves, breakers, or switches to proper positions.

This procedure shall provide for identification of released equipment and for controls, such as blocking/locking or tagging, to maintain personnel and reactor safety and to avoid unauthorized operation of the equipment. The procedure shall provide for independent verification, where appropriate, to ensure that the blocking and tagging methods have been implemented correctly.

The functional acceptability of equipment shall be verified and documented as equipment is returned to service.

Operating personnel will ensure that when any part of a redundant safety system is removed from service, the portion remaining in service is operable and in surveillance as required in the Technical Specifications. An administrative procedure, which governs when equipment is returned to service, requires Shift Management to review all Work Orders and testing pertaining to the safety system being returned to service. Shift Management will ascertain if additional testing is required and consider the consequences of returning equipment to service.

13.5.1.5 Procedure for Temporary Modifications This procedure shall provide controls for temporary modifications such as electrical jumpers, lifted electrical leads, and bypass lines. The requirements shall include independent verification of the intent/need for the installation, consideration of the need to revise applicable procedures, and a logging system to indicate current status of the temporary modification.

13.5.1.6 Procedure for Control of Plant Modifications This procedure shall provide the controls for administration, design and design review, and preplanning of plant modifications so that modifications are performed in a manner to ensure quality as specified in the original or approved modification design. The procedure shall provide for consideration and specification of appropriate inspections and tests to develop a suitable level of confidence that the modification has been properly installed. Activities that ensure the quality of CHAPTER 13 13.5-4 REV. 15, SEPTEMBER 2010

LGS UFSAR the modification shall be performed in accordance with documented drawings or instructions appropriate to the circumstances, that conform to the specified design requirements, and that provide for documentation of activities where appropriate. Skills normally possessed by trained craft personnel may not require detailed step-by-step delineations in a written procedure. As part of the modification process, consideration shall be given to the need for revising applicable procedures.

The procedure for control of plant modifications shall require that the status of inspections and tests performed on items be indicated by use of stamps, tags, labels, routing cards, procedural sign-offs, or other suitable means that provide traceability between the record and the item(s).

Also, where necessary to preclude inadvertent bypassing of inspections and tests, the procedure shall require that the item(s) that have satisfactorily passed required inspections and tests be identified. This procedure shall require that the following aspects of housekeeping and cleanliness control be considered in the development of instructions for the modification:

a. Housekeeping provisions shall recognize the special requirements involved with radiation zones and control areas.

b. Only proper materials, equipment, processes, and procedures may be used to ensure that the quality of plant equipment is not degraded.

c. Where necessary, special instructions for housekeeping and cleaning operations shall be provided and used.

d. Where needed to prevent contamination of safety systems with foreign materials, personnel and/or materials access control shall be established and a cleanliness inspection shall be performed immediately prior to closure. The inspection results shall be documented.

The procedure for control of plant modification shall require that appropriate inspections be established and implemented for modifications in accordance with the following criteria:

a. Inspections, examinations, measurements, or tests shall be specified and performed for each work activity where necessary to ensure quality.

b. Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected. Inspection of certain activities (such as work functions associated with normal plant operations, routine maintenance, and certain technical services routinely assigned to the onsite operating organization) may be conducted by shift or plant staff supervisory personnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct of the work.

c. Modification work similar to construction phase work shall be subject to inspections similar to those performed in the construction phase.

d. Inspections shall be performed in accordance with approved written instructions or procedures that contain or reference the requirements, acceptance limits, and responsibilities for the inspection.

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e. When specific hold points are required, they shall be indicated in appropriate documents.

f. When inspection techniques require specialized qualifications, inspection personnel shall meet the specified requirements for the technique involved.

g. If inspection is impossible or disadvantageous, indirect control by monitoring process methods, equipment, and personnel shall be provided. Both inspection and process monitoring shall be provided when control is inadequate without both.

h. Inspection instructions or procedures shall include or reference requirements for evaluation of inspection results when the nature of the results indicates that such an evaluation is needed to determine if the plant can be operated safely.

Evaluation beyond that given by inspection-level personnel shall not normally be required for go/no-go and pass/fail type inspections.

i. Inspectors, data recorders, and those evaluating inspection results shall be identified and the records shall reflect implementation of the inspections and actions completed or planned to correct noted deficiencies.

The procedure for control of plant modifications shall require that special processes be identified and accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria, or other special requirements. The procedure shall require that special processes be accomplished by qualified personnel using qualified procedures and equipment as provided in the specified requirements for the activity.

The procedure for control of plant modifications shall require that modifications be tested to demonstrate that they will perform satisfactorily in service and that such testing be performed in accordance with written test procedures or instructions that incorporate or reference the requirements and acceptance limits contained in the applicable design documents. Such testing shall confirm that modifications and associated procedure changes, if any, produce expected results.

13.5.1.7 Procedure for Control of In-plant Work This procedure shall provide the controls needed to coordinate, approve, and implement in-plant work. The controls provided shall include:

a. Planning and coordination of maintenance and modification work so as not to compromise plant safety, including the consequences of concurrent or sequential maintenance and modification activities, the need to provide operable equipment to support the operating mode of the plant, and the need to remain within license limits. Such planning shall also include evaluation of use of special processes, equipment, and materials in regard to potential hazards to personnel and equipment.

b. A method to ensure that conditions adverse to plant safety (such as failures, malfunctions, deficiencies, deviations, defective plant equipment, abnormal occurrences and nonconformances related to plant equipment) shall be identified and corrected through corrective maintenance.

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c. A method to maintain or coordinate maintenance of the identification and traceability of materials, parts, and components as it is established in the storeroom to provide insurance that only correct and accepted items are used and installed.

d. Obtaining the necessary permits, such as blocking and tagging of equipment and radiation work permits that specify radiation protection measures, monitoring, and protective clothing.

e. Review of repetitive malfunctions to determine the cause and corrective measures.

This activity can include referral to Engineering for evaluation, determination of repair or replacement parts, and associated design, testing, and installation requirements.

13.5.1.8 Procedure for Administration of the Preventive Maintenance Program This procedure shall establish the administrative requirements for the preventive maintenance program so that preventive maintenance is preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Preventive maintenance shall include those routine actions needed to ensure that plant equipment (including special tools) continues to operate properly by detection or prevention of actual or impending failures or substandard performance. The aspects of preventive maintenance that shall be addressed in this procedure include:

a. Establishment of the frequency and schedule for preventive maintenance actions.

b. Records of completion of preventive maintenance actions.

c. Preparation, approval, and control of written procedures, documented instructions, or drawings that are appropriate to the circumstances for the performance of preventive maintenance actions. The written procedures, documented instructions or drawings shall conform to the design requirements, and provide for documentation of activities where appropriate. Skills normally possessed by trained craft personnel may not require detailed step-by-step delineations in a written procedure. Preventive maintenance procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

This procedure shall establish the format and content of preventive maintenance procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications, vendor documents, and drawings as appropriate to ensure the required quality of the work.

d. Prerequisites, including those independent actions or procedures that must exist prior to use of the preventive maintenance procedure. Prerequisites applicable only to certain sections of the procedure shall be so identified.

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e. Precautions to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation. Routine precautions that a trained craftsman is expected to take, such as normal electrical safety methods, shall not be required to be stated.

f. Procedure section. The procedure shall provide the steps needed to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision and in consideration of the skills normally possessed by trained craft personnel. Precautions and reference documents important to specific steps in the procedure shall be identified or included at those steps. This section shall also provide instructions for performing and documenting the results of required inspections and tests and provides the necessary acceptance criteria. When appropriate, checkoff lists shall be included in or appended to preventive maintenance procedures.

g. Return-to-normal. This section shall contain instructions as to the mode or condition in which the equipment is to be placed after completion of the preventive maintenance action.

Maintenance and preventive maintenance procedures are proven to be correct through their use.

Because they are written for specific equipment, they are not subject to intersystem changes that may affect other procedure types, such as general plant procedures.

Maintenance and preventive maintenance procedures are reviewed when equipment modifications are made through the controlled modification program at the station. In addition, when indicated by the review of NRC Bulletins, Circulars and Notices, INPO documents and industry documents, the procedures are revised if necessary on a case-by-case basis.

To ensure feedback, preventive maintenance procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures.

13.5.1.9 Procedure for Administration of the Surveillance Testing Program This procedure shall establish the administrative requirements and responsibilities for the surveillance testing program so that such testing is preplanned and performed in accordance with written procedures and drawings appropriate to the circumstances, and in accordance with the technical specification requirements. Included in this program shall be the safety-related instruments and control devices and special equipment as defined in the technical specifications.

The aspects of surveillance testing that shall be addressed in this procedure include:

a. Establishment of calibration intervals and methods for installed safety-related instruments and control devices as defined in the technical specifications.

b. Requirements for the calibration of measuring and test equipment at specified intervals or prior to use to ensure the necessary accuracy of equipment and requirements for use of measuring and test equipment of the proper type and range.

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c. Requirements for performing a documented evaluation of the validity and acceptability of previous calibration activities when measuring and test equipment are found to be out of calibration. The evaluation shall cover the applicable surveillance tests from the time of the previous calibration.

d. Requirements for performing special calibrations of installed safety-related instruments and control devices when the accuracy of the equipment is questionable.

e. Requirements for recording calibration activities and suitably marking equipment to indicate calibration status.

f. Establishment of a master surveillance test schedule reflecting the status of all planned surveillance tests.

g. Responsibilities for timely performance of surveillance tests, evaluation of results, reporting completion, and maintenance of appropriate records.

h. Planning for performance of required tests so as not to compromise plant safety including the possible consequences of concurrent or sequential testing, the need to provide operable equipment to support the operating mode of the plant, and the need to remain within license limits.

i. Preparation, approval, and control of written procedures for the performance of individual surveillance tests. Surveillance test procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

This procedure shall establish the format and content of surveillance test procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability and objectives(s) of the test.

c. References, including technical specifications, drawings, and vendor documents as appropriate to ensure the required quality of the work.

d. Prerequisites including those independent actions or procedures that must be completed and plant conditions that must exist prior to use of the surveillance test procedure, and including any special conditions to be used to simulate normal or abnormal operating conditions. Prerequisites applicable to only certain sections of the procedure shall be so identified. Special equipment or calibrations required to conduct the test shall be listed.

e. Precautions to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public; or to avoid an abnormal or emergency situation. Applicable limiting conditions shall be included.

CHAPTER 13 13.5-9 REV. 15, SEPTEMBER 2010

LGS UFSAR Routine precautions that trained craftsmen or test personnel are expected to take, such as normal electrical safety methods, need not be stated.

f. Procedure section. The procedure shall provide the steps needed to perform the test in the degree of detail necessary to ensure safety and correct performance without direct supervision and in consideration of the skills normally possessed by trained craft and testing personnel. Precautions and reference documents important to specific steps in the procedure shall be identified or included at those steps. Where test steps are to be witnessed, the test sequence shall identify the hold points and shall require appropriate approval for the test to continue beyond the designated hold point. The procedure requires recording of test results, including data such as as-found and as-left information where appropriate.

Acceptance criteria for the tests shall be specified. When appropriate, checkoff lists shall be included in or appended to the surveillance test procedures.

g. Return-to-normal. This section shall contain instructions as to the mode or condition in which the equipment is to be placed after completion of the surveillance test.

This procedure shall require recording the test date, corrective actions taken (if any), identification of those performing the test, and identification of those evaluating the test results to ensure that requirements have been met.

Surveillance tests and routine tests are performed on a periodic basis; this step-by-step use of the procedure demonstrates the adequacy of the procedures. In addition, when changes in the plant Technical Specifications are received, the appropriate procedures are identified and revised.

Plant modifications, NRC Bulletins, and Information Notices also initiate procedure review and revision, if needed.

To ensure feedback, surveillance test procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures.

The surveillance test program shall include procedures for monitoring performance of plant systems to ensure that engineered safety features and emergency equipment are in the required state of readiness and that operating systems are performing properly.

The limits for significant parameters shall be identified as well as the nature and frequency of monitoring.

13.5.1.10 Procedure for Administration of Plant Records This procedure shall establish the provisions and responsibilities for retention of plant records.

Preparation of records is discussed in procedures that cover the specific activities. The responsibility for maintaining and storing records at specified location(s) shall be assigned. This procedure shall ensure that retention times are established so that applicable statutory requirements are satisfied. The significance of the event covered by the record-type and the contribution of the record to the ability to reconstruct significant events shall also be considered in establishing retention periods.

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LGS UFSAR 13.5.1.11 Procedure for Procurement This procedure shall establish the controls for activities performed by the plant operating staff in regard to procurement of safety-related equipment. This procedure shall require that procurement of safety-related equipment (including spares and replacements) be purchased to specifications and codes equivalent to those specified for original equipment or to approved alternate requirements that have been evaluated to ensure that interfaces, interchangeability, safety, fit, and function are not adversely affected or contrary to applicable regulatory or code requirements. The results of this evaluation shall be documented. The procedure shall define the requirements for preparation, review, and approval of procurement requirements and changes thereto to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure adequate quality are included or referenced.

The procedure for procurement shall define the content of procurement documents as follows:

a. To the extent necessary, the procurement document shall require suppliers of Q-listed items to provide a quality assurance program consistent with original requirements, ANSI/ASME NQA-1-1994, 10CFR50, Appendix B, or approved alternate requirements as described above. When applicable, suppliers shall be required to extend applicable requirements of the procurement documents to their suppliers and subcontractors.

b. Basic technical requirements. Required drawings, specifications, and industrial codes and standards shall be identified by titles and dates of issue in such a way as to clearly set forth the applicable documents for fabrication. Where procedural requirements apply, they shall be identified clearly and in such a way as to avoid uncertainty as to source and need. Packaging and transportation shall be required to be accomplished in a manner that will ensure that quality is not degraded and that applicable regulatory requirements are met.

c. Source inspection and audit. Provisions for access to suppliers' facilities and records for source inspection and audit shall be specified when the need for such inspection or audit is determined.

d. Documentation requirements. Necessary records to show compliance with specifications, codes, standards, and fabrication requirements shall be specified as to preparation, retention, and submittal. In addition, applicable vendor documents such as drawings, specifications, procedures, qualification records, material analyses, and inspection and test records shall be specified as to preparation, retention, and submittal.

The procedure for procurement shall contain the provisions and responsibility for receipt inspection to determine the acceptability of purchased items in regard to the procurement documents and/or receipt inspection instructions. The procedure shall provide that, where required by contract requirements, codes, or regulations, documentary evidence that items conform to procurement requirements shall be available at the plant site prior to installation or use of such items, shall be retrievable, and shall be sufficient to identify the specific requirements such as codes, standards, or specifications met by the purchased item. The documentary evidence may be records as specified in the procurement documents, or results of tests and inspections such as material analyses, source inspection, performance data, in-depth sampling, and receipt.

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LGS UFSAR This procedure provides that items not passing receipt inspection (including incomplete or incorrect documentation) shall not be considered acceptable. Affected items shall be considered inoperable and reliance shall not be placed on such items to fulfill their intended safety functions until such discrepancies are dispositioned by proper authority. The controls specified for such nonconforming items shall include:

a. Identification of nonconforming items by tagging and, where practicable, segregation.

b. Control of further processing or installation until the disposition is determined and approved.

c. Disposition of the nonconforming item as "use-as-is," repair, rework to complete or correct the item to the specified requirements, or reject (scrap). The responsibility and authority for the disposition shall be defined. Repaired and reworked items shall be reinspected in accordance with applicable procedures or instructions.

d. Documentation of the satisfactory completion of the disposition. This includes documentation verifying the acceptability of nonconforming items that are dispositioned "use-as-is" or repair, and describing the deviation and as-built condition.

e. Notification to appropriate organizations to ensure that effected drawings or records reflect as-built conditions.

The procedure for procurement shall establish requirements for identification and control of received materials, parts, and components (including partially fabricated subassemblies) to ensure that only correct and acceptable items are used and installed. The procedure shall provide for:

a. Use of physical identification (such as marking or tagging) to the maximum extent practicable. Physical separation, procedural control, or other appropriate means shall be used when physical identification is not used or not sufficient.

Identification can be on the item or on records traceable to the item.

b. Identification marking shall be clear and unambiguous, and shall employ methods and materials that will remain legible considering the handling, storage, and installation conditions expected. The marking must not affect the function of the item.

c. Markings shall be transferred to subdivided parts and shall not be obliterated or hidden by surface treatment or coatings unless other identification means are instituted.

d. When applicable codes, standards, or specifications require traceability of materials, parts, or components to specific inspection or test records, such traceability shall be provided.

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e. Identification shall relate the item to applicable drawings, specifications, procurement documents, or other pertinent technical documents.

13.5.1.12 Procedure for Administration of the Plant Security Program This procedure shall establish the administrative requirements and responsibilities for the plant security program that is developed to implement the industrial security plan and to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant. This procedure shall require that security procedures be distributed to appropriate personnel in accordance with current distribution lists, which reflect the confidentiality of security provisions, to ensure that outdated or inappropriate procedures are not used.

This procedure shall define the format and content of security procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose of the procedure.

c. Prerequisites, when needed, including those independent actions or procedures that must be completed prior to use of the security procedure.

d. References, when needed.

e. Precautions to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid abnormal or emergency conditions.

f. Procedure section. The procedure shall provide the steps needed to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision. Precautions and reference documents important to specific steps in the procedure shall be identified or included at those steps. Acceptance criteria, where appropriate, shall be specified. When appropriate, checkoff lists shall be included in or appended to the procedure.

To ensure feedback, security procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures.

13.5.1.13 Procedure for Preparation of Maintenance Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation and control of maintenance procedures that are developed to maintain safety-related equipment. Actual coordination and planning for maintenance actions shall be accomplished through the procedure for controlling in-plant work. The following aspects of maintenance work shall be addressed in this procedure:

a. The need to perform maintenance activities in a manner to ensure quality as specified in the original or approved modification design.

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b. Specification and performance of appropriate inspections and tests to attain a suitable level of confidence that the maintenance has been properly performed.

c. Activities that ensure the quality of maintenance shall be performed in accordance with documented drawings or instructions that are appropriate to the circumstances, that conform to the design requirements, and which provide for documentation of activities where appropriate. Skills normally possessed by trained craft personnel may not require detailed step-by-step delineations in a written procedure.

d. The status of inspections and tests performed on items shall be indicated by the use of stamps, tags, labels, routing cards, procedural sign-offs, or other methods that provide traceability between the record and the item(s). Also, where necessary to preclude inadvertent bypassing of inspections and tests, items that have satisfactorily passed required inspections and tests shall be identified.

e. Special control requirements for emergency maintenance that must proceed immediately to correct a degraded safety condition and for which a procedure does not exist.

This procedure shall require that the following aspects of housekeeping and cleanliness control be considered in development of maintenance procedures:

a. Housekeeping provisions must recognize the special requirements involved with radiation zones and control areas.

b. Only proper materials, equipment, processes, and procedures may be used to ensure that the quality of plant equipment is not degraded.

c. Where necessary, special instructions for housekeeping and cleaning operations shall be provided and used.

d. Where needed to prevent contamination of safety systems with foreign materials, personnel and/or materials access control shall be established and a cleanliness inspection shall be performed immediately before closure. The Inspection results shall be documented.

This procedure shall require that appropriate inspections be established and implemented for maintenance actions in accordance with the following criteria:

a. Inspections, examinations, measurements, or tests shall be specified and performed for each work activity where necessary to ensure quality.

b. Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected. Inspection of certain activities (such as work functions associated with normal plant operations, routine maintenance, and certain technical services routinely assigned to the onsite operating organization) may be conducted by shift or plant staff supervisory personnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct of the work.

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c. Inspections shall be performed in accordance with written approved instructions, drawings or procedures that contain or reference the requirements, acceptance limits, and responsibilities for the inspection.

d. When specific hold points are required, they shall be indicated in appropriate documents.

e. When inspection techniques require specialized qualifications, inspection personnel shall meet the specified requirements for the technique involved.

f. If inspection is impossible or disadvantageous, indirect control by monitoring process methods, equipment, and personnel shall be provided. Both inspection and process monitoring shall be provided when control is inadequate without both.

g. Inspection instructions or procedures shall include or reference requirements for evaluation of inspection results when the nature of the results indicates that such an evaluation is needed to determine if the plant can be operated safely.

Evaluation beyond that given by inspection-level personnel is not normally required for go/no-go and pass/fail type inspections.

h. Inspectors, data recorders, and those evaluating inspection results shall be identified and the records shall reflect implementation of the inspections and actions completed or planned to correct noted deficiencies.

This procedure shall require that special processes be identified and accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria, or other special requirements. The procedure shall require that special processes be accomplished by qualified personnel using qualified procedures and equipment as provided in the specified requirements for the activity.

This procedure shall require testing to be performed as necessary to demonstrate that the item performs satisfactorily in service.

The testing shall be performed in accordance with written approved procedures or instructions that include or reference requirements and acceptance criteria defined in appropriate design documents.

This procedure shall define the format and content of maintenance procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications, vendor documents, and drawings as appropriate to ensure the required quality of the work.

d. Prerequisites, including those independent actions or procedures that must be completed and plant conditions that must exist prior to use of the maintenance CHAPTER 13 13.5-15 REV. 15, SEPTEMBER 2010

LGS UFSAR procedure. Prerequisites applicable to only certain sections of the procedure shall be so identified.

e. Precautions to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation. Routine precautions that a trained craftsman is expected to take, such as normal electrical safety methods, do not need to be stated.

f. Procedure section. The procedure shall provide the steps needed to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision, and in consideration of the skills normally possessed by trained craft personnel. Precautions and reference documents important to specific steps in the procedure shall be identified or included at those steps. This section shall also provide instructions for performing and documenting the results of required inspections and tests and provides the necessary acceptance criteria. When appropriate, checkoff lists shall be included in or appended to maintenance procedures.

g. Return-to-normal. This section shall contain instructions as to the mode or condition in which the equipment is placed after completion of the maintenance action.

Maintenance procedures will normally be prepared by members of the Nuclear Maintenance Division staff, knowledgeable in the areas which the procedures address; however, members of the station operating staff and organizations providing technical support, including consultants, may assist in procedure development.

Maintenance and preventive maintenance procedures are proven to be correct through their use.

Because they are written for specific equipment, they are not subject to intersystem changes that may affect other procedure types, such as general plant procedures.

Maintenance and preventive maintenance procedures are reviewed when equipment modifications are made through the controlled modification program at the station. In addition, when indicated by the review of NRC IE Bulletins, Circulars and Notices, INPO documents and industry documents, the procedures are revised if necessary on a case-by-case basis.

To ensure feedback, maintenance procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. Procedures shall also require that maintenance procedures be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.14 Procedure for Preparation of Transient Response Implementation Plan Procedures and Severe Accident Management Plan Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of Transient Response Implementation Plan and the Severe Accident Management Plan procedures.

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LGS UFSAR Transient Response Implementation Plan procedures are symptom oriented decision tree flow charts for operator actions based on recognition of critical symptoms and definition of actions to maintain key plant parameters within predetermined ranges. The Transient Response Implementation Plan and the Severe Accident Management Plan procedures have been developed from the BWROG EPG/SAGs.

To ensure feedback, TRIP and SAMP procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures.

Transient Response Implementation Plan and the Severe Accident Management Plan procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.15 Procedure for Preparation of Emergency Plan Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of emergency plan procedures that implement the emergency plan. This procedure shall establish the format and content of the emergency plan procedures.

Emergency plan procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.16 Procedure for Preparation of General Plant Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of general plant procedures that are written to provide integrated instructions for major plant evolutions such as plant startup or shutdown. This procedure shall establish the criteria for general plant procedures, such as:

a. Preparation of startup procedures including reactor startup from cold and hot conditions, generator synchronization, and recovery from reactor trips. These procedures shall implement the authority and responsibilities of reactor operators as defined in other administrative procedures.

b. Preparation of shutdown procedures including controlled shutdown and reactor trips to the establishment and maintenance of hot or cold shutdown conditions.

c. Preparation of procedures covering steady-state and load changing conditions and operations such as use of control rods, coolant flow control, and adjusting operating parameters.

This procedure shall establish the format and content of general plant procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications, drawings, or procedures as applicable.

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d. Prerequisites, including those independent actions or procedures that must be completed and plant conditions that must exist prior to use of the procedure.

Prerequisites applicable to only certain sections of the procedure shall be so identified. Startup procedures shall require documentation of completion of prerequisites such as confirmation that necessary instruments are operable and properly set; that necessary valves are properly aligned; that necessary procedures, tests, and calibrations have been completed; and that required approvals have been obtained. Checkoff lists can be used for the purpose of defining and documenting completion of prerequisites.

e. Precautions, where necessary to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation.

f. Procedure section. The procedure shall provide the sequence and steps needed to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision. Cautionary notes applicable to specific steps shall be identified and included. System procedures or other detailed instructions not contained in the general plant procedure shall be referenced at the applicable steps. Where appropriate, check off lists shall be included in or appended to the procedure for the purpose of assisting the operator and/or confirming completion of major steps in the proper sequence. Limitations on parameters being controlled and appropriate corrective measures to return the parameter to the proper value shall be specified where appropriate.

To ensure feedback, general plant procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. When determined necessary by the PORC, tests shall be performed to confirm that significant changes to general plant procedures produce the expected results.

General plant procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.17 Procedure for Preparation of System Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of system procedures for safety-related systems. The procedure shall require system procedures to address normally expected operations such as energizing, filling, venting, draining, starting up, shutting down, and changing modes of operation as applicable to the system. It is not the intent of these procedures to cover actions, operations, or system conditions that would be unique to a special operation, such as maintenance, and would be covered in a special procedure written at the time the operation is needed.

This procedure shall establish the format and content of system procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

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c. References including technical specifications, drawings, procedures, equipment manuals, and vendor documents as applicable.

d. Prerequisites, including those independent actions or procedures that must be completed and plant conditions that must exist prior to use of the procedure.

Prerequisites applicable to only certain sections of the procedure shall be so identified.

e. Procedure section. This section shall provide the steps to perform the various operations in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision, and in consideration of the skills possessed by trained operators. Cautionary notes applicable to specific steps shall be identified or included. Limitations on parameters being controlled and appropriate corrective measures to return the parameter to the proper value shall be specified where appropriate. Where appropriate, check off lists shall be included in or appended to the procedure.

To ensure feedback, system procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. When determined necessary by the PORC, tests shall be performed to confirm that significant changes to system procedures produce the expected results. System procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures shall be not used.

13.5.1.18 Procedure for Preparation of Operational Transient Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of operational transient procedures for the restoration of normal operating conditions following a perturbation. This procedure shall establish the format and content of operational transient procedures as follows:

a. Descriptive title, revision number, and date.

b. Entry conditions.

c. Immediate operator actions. This section shall specify immediate actions for operation of controls to restore normal operating conditions.

d. Follow-up actions.

e. Verification of automatic actions. The automatic actions that are expected to occur as a result of the condition shall be identified.

To ensure feedback, operational transient procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. Operational transient procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.19 Procedure for Preparation of Alarm Response Cards CHAPTER 13 13.5-19 REV. 15, SEPTEMBER 2010

LGS UFSAR This procedure shall establish the administrative requirements and responsibilities for the preparation of individual alarm response cards. The procedure shall provide for preparation of individual alarm response cards to which operators refer. Alarm response cards shall be maintained in the control room and shall contain the following information:

a. Identification of the alarm

b. Alarm setpoint

c. Identification of the signal source instrument

d. Automatic actions that are expected to occur

e. Operator response (immediate and long-term)

To ensure feedback, safety-related alarm response cards are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of the alarm response card.

Unique numbers have been assigned to each control room alarm based on a sequential number for each annunciator window within a specific panel. Alarm response information is retrieved by identifying the alarm number and referring to the corresponding alarm card or procedure number.

13.5.1.20 Procedure for Preparation of Fuel Handling Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of fuel handling procedures that shall specify actions for core alterations, accountability for fuel, partial or complete refueling operations, receipt and shipment of fuel, and such specific procedures for each refueling outage as necessary to accomplish the required actions in a safe, efficient manner. This procedure shall establish the format and content of fuel handling procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications, drawings, or procedures as applicable.

d. Prerequisites, including those independent actions or procedures that must be completed and plant conditions that must exist prior to use of the procedure.

Prerequisites applicable to only certain sections of the procedure shall be so identified.

e. Precautions, where necessary, to alert the individual(s) performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation.

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f. Limitations and actions. Limitations on appropriate parameters and corrective action to return the parameter to the proper value or other appropriate action shall be specified.

g. Procedure section. The procedure shall provide the needed steps and requirements to perform the refueling task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision. Cautionary notes and references applicable to specific steps shall be identified and included. Where appropriate, check off lists shall be included in or appended to the procedure for the purpose of assisting the operator and/or confirming completion of appropriate steps.

This procedure shall require documentation of final fuel and component serial numbers and locations to be developed and maintained.

To ensure feedback, fuel handling procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. Fuel handling procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.21 Procedure for Preparation of Health Physics Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of health physics procedures that implement the radiation protection program. This procedure shall require preparation of health physics procedures in the following areas:

a. Monitoring external and internal exposures of appropriate employees utilizing accepted techniques.

b. Routine radiation surveys of work areas.

c. Environmental monitoring within the scope of the operating staff responsibility.

d. Radiation monitoring of maintenance and special work activities.

e. Maintenance of records demonstrating the adequacy of measures taken to control radiation exposures of employees and other appropriate personnel.

f. Control, receipt, and shipment of radioactive material.

This procedure shall establish the format and content of health physics procedures as follows:

a. Descriptive title, revision number, and date.

b. Statement of applicability or purpose.

c. References, including technical specifications, drawings, procedures, and operating manuals as applicable.

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d. Apparatus, such as instruments or special equipment, as applicable.

e. Precautions, where necessary, to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation. Routine precautions that a trained technician is expected to take need not be listed.

f. Procedure section. The procedure shall provide the needed steps to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision. Precautions and references important to specific steps in the procedure shall be identified and included at those steps. When appropriate, check off lists shall be included in or appended to health physics procedures.

Health Physics procedures will normally be prepared by members of the LGS Services organization, knowledgeable in Health Physics; however, organizations providing technical support and consultants may assist in procedure development. These procedures will be developed in consultation with the Director of the Radiation Protection Section and his staff.

The Health Physics procedures are primarily administrative and analytic. They represent the most efficient way to administer the Health Physics program. Many are based on either the type of equipment in use in the plant or, in the case of shipping radioactive materials, they are based on regulations. When the regulations change, the Health Physics procedures would be revised if needed. If new equipment for analysis is obtained, new procedures would be written for that new equipment.

To ensure feedback, health physics procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. Health physics procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.22 Procedure for Preparation of Chemistry Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of chemistry procedures that include chemical and radiochemical control activities.

This procedure shall establish the format, content, and distribution requirements for chemistry procedures as described for health physics procedures.

13.5.1.23 Procedure for Temporary Changes to Approved Procedures This procedure shall establish the administrative requirements and responsibilities for making temporary changes to approved procedures. The procedure shall provide that temporary changes, clearly not changing the intent of the approved procedure, shall be documented and approved by two members of the plant staff knowledgeable in the area(s) affected by the procedure. At least one of these individuals shall be a shift manager or a senior licensed operator on the unit affected. Temporary changes shall be incorporated in the next procedure revision if appropriate.

13.5.1.24 Procedure for Preparation of Off-Normal Procedures CHAPTER 13 13.5-22 REV. 15, SEPTEMBER 2010

LGS UFSAR This procedure shall establish the administrative requirements and responsibilities for the preparation of off-normal procedures that are written to specify operator actions following an operator observation of an off-normal (nontransient) condition which requires immediate action to prevent degeneration of the existing condition. This procedure shall establish the format and content of off-normal procedures as follows:

a. Descriptive title, revision number, and date.

b. Symptoms. This section shall include symptoms to aid in identifying or confirming the off-normal condition. Alarm conditions, parameter changes, and other observations shall be considered.

c. Operator actions. This section shall specify actions to be taken to identify, confirm, or correct the cause of the off-normal condition.

To ensure feedback, off-normal procedures are reviewed in accordance with performance enhancement procedures following unusual incidents that reflect adversely on the adequacy of these procedures. Off-normal procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.

13.5.1.25 Procedure for Preparation of Event Procedures and Special Event Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of event procedures and special event procedures that are written to specify operator actions following an operator observation of an event of an emergency or unusual nature.

13.5.1.25.1 Procedure for Preparation of Event Procedures This Procedure establishes the format and content of event procedures as follows:

a. Confirming indications.

b. Initial actions.

c. Follow-up actions.

13.5.1.25.2 Procedure for Preparation of Special Event Procedures This Procedure establishes the format and content of special event procedures as follows:

a. Purpose.

b. Symptoms. Symptoms shall be included to aid in the identification of the plant condition.

c. Immediate operator actions. This section shall specify action to be taken as a result of the identified condition.

d. Follow-up actions.

13.5.1.26 Procedure for Preparation of Radwaste Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of radwaste procedures. This procedure shall require administration of the station radwaste program in the following areas:

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a. Control handling, packaging, storage, and shipment of radioactive material.

b. Inspection, installation, and use of equipment used to process and package radwaste.

c. Processing and handling of radwaste using vendor equipment.

This procedure shall establish the format, content, and control of radwaste procedures.

13.5.1.27 Procedure for Fire Safe Shutdown Guides This procedure shall establish the administrative requirements and responsibilities for the preparation of fire safe shutdown procedures that are written to identify available plant instrumentation and equipment which may be relied upon in the event of a fire in a specific fire area. This procedure shall establish the format and content of fire safe shutdown guides as follows:

a. Descriptive title, revision number and date

b. Available Equipment. This section shall include a listing of protected equipment which is shown by analysis to be available following an exposure fire in a specific area.

c. Contingency Actions. This section shall specify operator actions to be taken to restore essential equipment and/or system functions which have the potential of being affected by a fire in a specific area.

13.5.2 OPERATING AND MAINTENANCE PROCEDURES 13.5.2.1 Control Room Operating Procedures Operating procedures which are primarily performed by licensed operators in the control room include general plant procedures, system procedures, operational transient procedures, off-normal procedures, alarm response cards, Transient Response Implementation Plan procedures, event procedures, special event procedures, and fire safe shutdown guides. The format and content of these classes of procedures are described in Section 13.5.1. General plant procedures and system procedures will be developed to cover the activities listed in sections 2 and 4, respectively, of appendix A to Regulatory Guide 1.33 (Rev 2). Examples of the types of activities covered by operating procedures or the anticipated procedure titles are listed below:

General Plant Procedures: Reactor startup from cold conditions; reactor startup from hot conditions; turbine-generator startup; power operation and monitoring; plant shutdown to hot standby; shutdown from hot standby to cold conditions; preparation for refueling operations.

System Procedures: Recirculation system; reactor water cleanup system; residual heat removal system; high pressure coolant injection system; core spray system; reactor core isolation cooling system; standby liquid control system; fuel pool cooling system; containment; control rod drive systems; reactor protection system; main steam system; turbine-generator; condensate and feedwater systems; circulating water system; cooling towers; cooling water systems; main generator; plant electrical systems; dc systems; diesel generators; radwaste systems; solid radwaste processing; standby gas treatment system; heating, ventilation, and air conditioning systems; fire protection systems; nuclear instrumentation.

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LGS UFSAR Operational Transient Procedures: Reactor low level; high drywell pressure; reactor high pressure; positive reactivity insertion; scram discharge volume high level; condenser low vacuum; reactor high level; recirculation pump trip; and inadvertent opening of a relief valve.

Off-Normal Procedures: Failure of a jet pump; loss of isolated phase bus cooling; air ejector discharge high radiation; offgas stack high radiation; control rod uncoupled; stuck control rod; loss of CRD regulating function; low scram air header pressure; total loss of the SRM, IRM, or APRM systems; loss of primary containment; loss of secondary containment; loss of stator cooling; main steam line high radiation; and loss of uninterruptible ac power.

Transient Response Implementation Plan Procedures: Reactor pressure vessel control; primary containment control; secondary containment control; radiation release; alternate level control; emergency blowdown; reactor pressure vessel flooding; and level/power control.

Severe Accident Management Plan Procedures: Reactor pressure vessel and primary containment flooding control; and containment and radioactivity release control.

Event procedures and Special Event Procedures: Earthquake; flood; shutdown from outside the control room; control room enclosure toxic gas; oil spills; and fire.

Licensed reactor operators and senior reactor operators are required to know the immediate operator actions in operational transient procedures, event procedures, special event procedures, and the entry condition of Transient Response Implementation Plan procedures. When entry conditions for Transient Response Implementation Plan procedures are met, operator actions are directed by the Transient Response Implementation Plan procedure as a priority over actions described in other procedures.

Fire Safe Shutdown Guides: Contingency steps to operate plant equipment.

13.5.2.2 Control of Unit 2 Construction Activities During Unit 1 Operation Refer to Section 1.2.5 13.5.2.3 Additional Operating and Maintenance Procedures In addition to operating procedures related primarily to control room operations, procedures shall be issued to control other plant activities. These procedures shall include emergency plan procedures, fuel handling procedures, chemistry procedures, health physics procedures, maintenance procedures, security procedures, surveillance test procedures, and preventive maintenance procedures. The types of activities covered by these procedures are listed below.

The format and content of these procedures are described in Section 13.5.1.

Fuel Handling Procedures: New fuel inspection; irradiated fuel inspection; installation, removal, and transfer of fuel assemblies; installation and removal of control rods; core sipping; installation and removal of source holder; installation and removal of incore detectors.

Health Physics Procedures: Radiation exposure limits; dosimetry requirements; personnel exposure records; radiation work permit; radiation control area classification; radiation/contamination surveys; decontamination; shipment of radioactive material; control and accountability of radioactive material; operation and calibration of radiation monitoring equipment; airborne radioactivity monitoring; various analytical procedures; laboratory calibration procedures.

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LGS UFSAR Security Procedures: Response to industrial security threats; civil disturbance; communications; security force duties and responsibilities; receipt control; key control; guard patrols; personnel identification; access control; vehicle traffic and parking; testing and maintenance of security systems; record keeping; visitor control.

Chemistry Procedures: Sampling reactor water; sampling reactor steam; gaseous samples; sampling condensate storage tank; various analytical procedures; control of radioactive calibration sources; laboratory calibration procedures.

Maintenance Procedures: Reactor recirculation pump seal overhaul; control rod drive repair; hydraulic control unit repair; control rod drive O-ring replacement; removal and replacement of drywell head; removal and replacement of reactor vessel head; removal and replacement of steam dryer; nuclear instrumentation removal and replacement; offgas filter maintenance; motor operator adjustment; standby liquid control explosive valve replacement.

Emergency Plan Procedures: Radiological surveys and monitoring; rescue operations; fire fighting; first aid; decontamination; personnel accountability; communications, repairs and damage control; record keeping; organization, duties.

13.5.3 OPERATIONS TECHNICAL REQUIREMENTS MANUAL (TRM)

The Technical Requirements Manual (TRM) contains the technical requirements and/or supporting information (e.g., tables and component lists) which were once contained in the LGS Technical Specifications (TS) (i.e., Appendix A of the LGS Facility Operating License). Removal of the TS and information was approved by the NRC through individual TS amendments. The TRM is intended to provide operational guidance and requirements for various plant conditions, actions, and testing similar to TS, however, these requirements are in accordance with licensing commitments. Future changes to the relocated requirements and supporting information are processed in accordance with Section 6.0 of the LGS TS, and are subject to a 10CFR50.59 Review.

The TRM is comprised of an index, the individual specification and bases. The manual is intended to provide a single location for the relocated TS items as a convenience for operations and other station personnel. The individual sections of the TRM contain the relocated licensing commitments which are subject to the provisions of 10CFR50.59 as described above.

In accordance with NEI 98-03, Revision 1 (Reference 13.5-1), as endorsed by NRC Regulatory Guide 1.181 (Reference 13.5-2), the TRM is treated in a manner consistent with procedures fully or partially described in the UFSAR, and therefore, is controlled as a procedure in accordance with the applicable established procedure process. For the purposes of 10 CFR 50.59, information presented in the TRM is considered to be information described in the UFSAR, and therefore, is to be treated at the same level as information presented in the UFSAR. (Reference 13.5-3) 13.5.4 SURVEILLANCE FREQUENCY CONTROL PROGRAM (SFCP)

The Surveillance Frequency Control Program (SFCP) was implemented as a result of NRC issuance of Amendment Nos. 186 and 147, dated September 28, 2006, to the Limerick Generating Station (LGS), Unit 1 and Unit 2, Technical Specifications (TS), respectively.

Administrative controls for the SFCP were added to the Administrative Controls section of the CHAPTER 13 13.5-26 REV. 15, SEPTEMBER 2010

LGS UFSAR LGS TS for both units, and are implemented through administrative procedures. The SFCP ensures that surveillance requirements specified in the TS are performed at intervals sufficient to assure the associated TS Limiting Conditions for Operation are met. The SFCP contains a list of frequencies of those surveillance requirements for which the frequency is controlled by the program and changes to the frequencies listed in the SFCP are made in accordance with NEI 04-01, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 0.

13.

5.5 REFERENCES

13.5-1 NEI 98-03, Guidelines for Updating Final Safety Analysis Reports, Revision 1, dated June 1999.

13.5-2 Regulatory Guide 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e), dated September 1999.

13.5-3 Letter from P. Bamford, U.S. Nuclear Regulatory Commission, to C. G. Pardee, Exelon Generating Company, LLC, Limerick Generating Station, Units 1 and 2 -

Issuance of Amendment RE: Changes to Accident Monitoring Instrumentation Technical Specifications (TAC Nos. MD5937 and MD5938), dated May 29, 2008.

CHAPTER 13 13.5-27 REV. 15, SEPTEMBER 2010

LGS UFSAR 13.6 INDUSTRIAL SECURITY A physical security plan that describes a comprehensive program of physical protection for the facility has been submitted as a separate part of the license application. The physical security plan is withheld from public disclosure pursuant to 10CFR2.790(d), "Rules of Practice."

Implementation of the plan provides protection with high assurance against successful industrial sabotage as described in 10CFR73.55(a) "General Performance Requirements."

The plan addresses the following: physical security organization, physical barriers, access requirements, detection aids, communication requirements, testing and maintenance, and response requirements. Implementation of the plan becomes effective at the time of fuel loading.

CHAPTER 13 13.6-1 REV. 13, SEPTEMBER 2006