ML18051B237

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Proposed Tech Specs,Clarifying Existing Regulatory Requirements,Achieving Closer Conformance to STS & Recognizing Plant Organizational Changes
ML18051B237
Person / Time
Site: Palisades 
Issue date: 01/11/1985
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18051B235 List:
References
NUDOCS 8501160373
Download: ML18051B237 (16)


Text

Consumers Power Company Palisades Plant Docket 50-255 PROPOSED TECHNICAL SPECIFICATION PAGE CHANGES 8501160373 850111

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PAL January 11, 1985 14 pages

PALISADES ADMINISTRATIVE CONTROLS 6.1 6.1.1 6.1.2 6.2 OFFS I TE 6.2.1 PLANT STAFF 6.2.2 RESPONSIBILITY The Plant General Manager shall be responsible for overall plant operation and shall delegate in writing the succession for this responsibility during his absence.

Either the Shift Supervisor or the Shift Engineer shall be responsible for the shift command function.

A directive to this effect shall be issued annually by the Vice President - Nuclear Operations.

ORGANIZATION The off site organization for plant management and technical support shall be as shown in Figure 6.2-1.

The plant organization shall be as shown in Figure 6.2-2 and:

a.

Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b.

At least one licensed Operator shall be present in the control room at all times when fuel is in the reactor.

c.

At least one licensed Senior Operator and one licensed Operator shall be present in the control room at all times during conditions other than cold shutdown or refueling shutdown.

d.

An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor.*

e.

All core alterations, after the initial fuel loading, shall either be performed under the direct supervision of a licensed Senior Operator or Senior Operator holding a license limited to fuel handling.

During this

  • time no other responsibilities shall be assigned to this individual.
f.

A Fire Brigade of at least 5 members shall be maintained on site at all times.* The Fire Brigade shall not include 3 members of the minimum shift crew necessary for safe shutdown or any personnel required for other essential functions during a fire emergency.

  • Radiation Protection coverage and Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence provided immediate action is taken to restore the minimum requirements.

NU0182-0164A-TP05 6-1 Proposed

ADMINISTRATIVE CONTROLS 6.2.3 FUNCTION 6.2~3.l

g.

Administrative procedures shall be developed and implemented to limit the working hours of Plant staff who perform safety-related functions; ie, Licensed Senior Operators, Licensed Operators, Auxiliary Operators, Chemistry, Health Physics and key Maintenance personnel and the first-line supervision of the above listed personnel.

Adequate shift coverage shall be maintained without routine heavy use of overtime.

However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:

A.

An individual shall not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight (excluding shift turnover time).

B.

An individual shall not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period (all excluding shift turnover time).

C.

A break of at least eight hours shall be allowed between work periods (including shift turnover time).

D.

The scheduling and use of extended work shifts for an entire work group or shift complement is prohibited except during extended Plant shutdown periods.

Any deviation from the above guidelines shall be authorized by the Plant General Manager or his Alternate, or higher levels of Management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime will be reviewed monthly by the Plant General Manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety. The organization shall report to the Director - Nuclear Safety.

With the concurrence of the Director - Nuclear Safety, the ISEG may function as staff to the onsite and of fsite review organizations and provide technical support for problem resolution.

NU0182-0164A-TP05 6-la Proposed

ADMINISTRATIVE CONTROLS COMPOSITION 6.2.3.2 The ISEG shall consist of a minimum of five (S) technical personnel1 located at the Palisades Plant Site.

The ISEG may include members located at other Consumers Power Company facilities.

QUALIFICATIONS 6.2.3.3 REPORTS 6.2.3.4 6.3 6.3.1 6.3.2 6.3.3 Three of the full-time members shall each have a bachelor's degree in engineering or a related science.

One of the three shall have a minimum of five years' professional experience which includes a minimum of two years' experience in power plant operation and/or design.

Any ISEG member may be drawn upon to perform ISEG duties on a temporary basis at any nuclear plant location.

Regular reports of ISEG activities shall be submitted to the NSB.

PLANT STAFF QUALIFICATIONS Each member of the plant staff shall meet or exceed the minimum qualifica-tions of ANSI Nl8.l-1971 for comparable positions.

The Plant Health Physicist shall meet 2or exceed the qualifications of Regulatory Guide 1.8, September 1975.

The Shift Technical Advisor/Shift Engineer (STA/SE) shall have a bachelor's degree or equivalent.in a scientific or engineering discipline witp specific training in plant design and/or operations, and response and analysis of the plant for transients and accidents.

The Shift Engineer shall be a licensed Senior Operator.

1 The requirement for a minimum of five (S) technical personnel shall be effective on 2

1/1/83.

For the purpose of this section, "Equivalent," as utilized in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combina-tion of the following:

(a) Formal schooling in science or engineering, or (b) operational or technical experience/training in nuclear power.

NU0182-0164A-TPOS 6-lb Proposed

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CONSUMERS POWER COMPANY OFFSITE ORGANIZATION PRESIDENT I

EXECUTIVE EXECUTIVE VICE PRESIDENT VICE PRESIDENT I

I VICE PRESIDENT VICE PRESIDENT GENERAL SERVICES NUCLEAR OPERATIONS I

DIRECTOR OF PROPERTY PROTECTION..

  • I I

l EXECUTIVE PALISADES OTHER DIRECTOR SERVICES NUCLEAR GENERAL ASSURANCE*

MANAGER I

Ii I

I PALISADES QA DIRECTOR DIRECTOR QA DIRECTOR SUPERINTENDENT NUCLEAR SAFETY..

QA SUPPORT BIG ROCK POINT

  • NSB CHAIRMAN
    • NSB VICE CHAIRMAN AND SECRETARY

I PLANT I

SUPERINTENDENT BIG ROCK POINT i

Proposed

NUCLEAR ASSURANCE OFF SITE I

QA DIRECTOR I

PLANT OPERATIONS MANAGER (c)

I PLANT OPERATIONS SUPERINTENDENT(c)

I I

I SHIFT SHIFT CONSUMERS POWER COMPANY PLANT ORGANIZATION PLANT GENERAL MANAGER (a)

I E

1~GINEERING AND MAINTENANCE MANAGER SUPERVISORS ENGINEERS SOL SOL

~ PLANT REVIEW COMMITTEE

! TECHNICAL DIRECTOR I I

RADIOLOGICAL SERVICES MANAGER I

HEAL TH PHYSICS SUPT ---(b)

A.

To support the above Plant organization, individuals knowledgeable in the following areas identified in ANSI Nl8.7-1976/ ANS 3.2 will report at the discretion of the Plant General Manager:

l.

Nuclear Power Plant Mechanical, Electrical and Electronic Systems

2.

Nuclear Engineering

3.

Chemistry and Radiochemistry

4.

Radiation Protection (Reports to Health Physics Superintendent)

A single individual may be qualified and perform in more than one discipline.

(a)Responsible for the Plant Fire Pro.tection Program implementation.

(b)A Radiation Safety Manager (RPM as defined in Regulatory Guide 1.8) shall be desig-nated by the Plant General Manager and shall be either the Radiological Services Manager, the Health Physics Superintendent or a Radiation Safety Supervisor.

The Radiation Safety Manager shall have direct access to the Plant General Manager in the matters of radiation safety.

(c)Either the Plant Operations Manager or the Plant Operations Superintendent will hold an SOL and meet the other requirements of 6.3.1 of these Technical Specifications (as applicable to Operations Manager in ANSI N18.l).

The individuai holding an SOL shall be responsible for directing the activities of licensed operators.

(SOL - Senior Operator License)

NU0182-0164A-TP05 Figure 6.2-2 6-3 Proposed

Figure 6.2- -2 (Contd)

B.

The Security Force will be supervised as described in the Plant Security Plan.

C.

Quality Assurance/Control activities will be in accordance with Consumers Power Company's Quality Assurance Program Description for Operational Nuclear Power Plants (CPC2A, as revised).

OC1184-0009A-NL02 6-3a Proposed

ADMINISTRATIVE CONTROLS POSITION SS/SE SRO/SE RO AO STA Radiation Safety Technician Chemistry Technician Security Table 6.2-1 MINIMUM SHIFT CREW COMPOSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION Power Operation, Hot Standby and Hot Shutdown l**

l**

2 2

l**

1 1

As stated in Security Plan Cold Shutdown and Refueling Shutdown*

1 None 1

2 None 1

1 As stated in Security Plan SS SRO/SE -

SRO RO Shift Supervisor with a Senior Operator License Shift Engineer with a Senior Operator License Individual with a Senior Operator License Licensed Reactor Controls Operator AO Auxiliary Operator I

Except for the Shift Supervisor, the Shift Crew Composition may be one less than the I

minimum requirements of Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order I to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements:

of Table 6.2-1.

This provision does not permit any shift crew position to.be unmanned I upon shift change due to an oncoming shift crewman being late or absent.

I

  • Does not include additional personnel required when core alterations are being conducted.

See Section 6.2.2.e.

    • There shall be two individuals with Senior Operator licenses on shift. If the Shift Engineering is on shift, the STA is not required.

NU0182-0164A-TP05 6-4 Proposed

ADMINISTRATIVE CONTROLS 6.4 6.4.1 6.4.2 6.S 6.S.1 FUNCTION 6.S.1.1 COMPOSITION 6.S.1.2 Chairman:

Member:

Member:

Member:

Member:

Member:

Member:

Member:

Member:

Member:

Member:

ALTERNATES 6.S.1.3 TRAINING A retraining and replacement training program for the plant staff shall be maintained under the direction of the Director of Nuclear Operations Training, and shall meet or exceed the requirements and recommendations of Section S.S of ANSI NlB.1-1971 and Appendix "A" of 10 CFR Part SS.

The Director of Property Protection is responsible for the development, revision, approval and implementation of the Fire Brigade training program.

This training shall, as practicable, meet or exceed the requirements of Section 27 of the NFPA Code-197S.

Fire Brigade training drills shall be held at least quarterly.

REVIEW AND AUDIT PLANT REVIEW COMMITTEE (PRC)

The Plant Review Committee (PRC) shall function to advise the Plant General Manager on all matters related to nuclear safety.

The PRC shall be composed of:

Plant General.Manager or Designated Alternate Engineering and Maintenance (E/M) Manager or Plant Projects Superintendent Plant Operations Manager or Plant Operations Superintendent Radiological Services Manager or Health Physics Superintendent or Staff Health Physicist Mechanical E/M Superintendent Electrical E/M Superintendent Instrumentation and Control E/M Superintendent Reactor Engineering Superintendent or Reactor Engineer Shift Supervisor or Shift Engineer Chemistry and Radwaste Superintendent or Chemical Engineer Supervisory, Senior or General Engineer Alternate members of the PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis.

However, no more than two alter-nates shall participate as a voting member at any one time in PRC activities.

NU0182-0164A-TPOS 6-S Proposed

ADMINISTRATIVE CONTROLS 6.5.1.4 6.5.1.5 6.5.1.6 MEETING FREQUENCY The PRC shall meet at least once per calendar month with special meetings as required.

QUORUM A quorum of the PRC shall consist of the Chairman and four members (including alternates).

RESPONSIBILITIES The PRC shall be responsible for:

a.

Review of:

(1) all procedures required by Specification 6.8 and changes thereto and (2) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety.

b.

Review of all proposed tests and experiments that affect nuclear safety.

c.

Review of all proposed changes to Appendix "A" Technical Specifications.

d.

Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

e.

Investigation of all violations of the Technical Specifications.

(A report shall be prepared covering evaluation and recommendations to prevent recurrence and forwarded to the Vice President - Nuclear Operations and to the Director - Nuclear Safety.)

f.

Review of plant operations to detect potential nuclear safety hazards.

g.

Performance of special reviews and investigations and reports thereof as requested by the Plant General Manager or Chairman of NSB.

h.

Review of the Site Emergency Plan and implementing procedures.

i.

Review of all reportable events as defined in Section 1.4.

PRC review may be performed through a routing of the item subject to the requirements of Specification 6.5.1.7.

NU0182-0164A-TP05 6-5a Proposed

ADMINISTRATIVE CONTROLS 6.5.2 NUCLEAR SAFETY BOARD (NSB)

RESPONSIBILITIES 6.5.2.1 FUNCTION 6.5.2.2 The Nuclear Safety Board (NSB) is responsible for maintaining a continuing examination of nuclear safety-related Corporate and plant activities and defining opportunities for policy changes related to improved nuclear safety performance.

The NSB shall operate in accordance with a written charter, approved by the Vice President - Nuclear Operations, which designates the membership, authority, and rules for conducting the meetings.

The NSB shall function to provide a review of designated activities in the areas specified in Specification 6.5.2.3.

NU0182-0164A-TP05 6-6a Proposed

ADMINISTRATIVE CONTROLS COMPOSITION 6.5.2.3 The NSB shall consist of members appointed by the Vice President - Nuclear Operations.

NSB shall be chaired by the Executive Director of Nuclear Assurance, the Vice Chairman or a duly appointed alternate.

The Director -

Nuclear Safety, shall be the Vice Chairman and Secretary.

Collectively, personnel appointed for NSB shall be competent to conduct reviews in the following areas:

a.

Nuclear Power Plant Operations

b.

Nuclear Engineering

c.

~hemistry and Radiochemistry

d.

Metallurgy

e.

Instrumentation and Control

f.

Radiological Safety

g.

Mechanical and Electrical Engineering

h.

Quality Assurance Practices An individual appointed to NSB may possess expertise in more than one of the above specialties.

These individuals should, in general, have had profes-sional experience in their specialty at or above the Senior Engineer level.

ALTERNATE MEMBERS 6.5.2.4 CONSULTANTS 6.5.2.5 Alternate members may be appointed in writing by the Vice President -

Nuclear Operations to act in place of members during any legitimate and unavoidable absences.

The qualifications of alternate members shall be similar to those of members.

Consultants shall be utilized as determined by the NSB Chairman or Vice Chairman to provide expert advice to the NSB.

NSB members are not restricted as to sources of technical input and may call for separate investigation from any competent source.

MEETING FREQUENCY 6.5.2.6 NSB shall meet at least once per calendar quarter during the initial year of facility operation following fuel loading and at least once every six months thereafter.

NU0182-0164A-TP05 6-7 Proposed

ADMINISTRATIVE CONTROLS QUORUM 6.5.2.7 6.5.2.8 REVIEW 6.5.2.8.1 AUDITS 6.5.2.8.2 A quorum of NSB shall consist of the Chairman and four (4) members.

(The Vice Chairman may be a voting member when not acting in the capacity of Chairman.)

No more than a minority of the quorum shall have line responsi-bility for operation of the facility. Jt is the responsibility of the Chairman to ensure that the quorum convened for a meeting contains appro-priately qualified members or has at its disposal consultants sufficient to carry out the review functions required by the meeting agenda.

RESPONSIBILITIES NSB shall be responsible for the review of:

a.

Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

b.

All reportable events and other violations (of applicable statutes, codes, regulations, orders, Technical Specifications, license require-ments or of internal procedures or instructions) having nuclear safety significance.

c.

Issues of safety significance identified by the Plant General Manager, the NSB Chairman, Director - Nuclear Safety or the PRC.

d.

Proposed changes in.the operating license or Appendix "A" Technical Specifications.

e.

The results of actions taken to correct deficiencies identified by the audit program specified in Specifications 6.5.2.8.2 and 6.5.2.8.3 at least once every six months.

f.

Safety evaluations for changes to procedures, equipment, or systems and tests or experiments completed under the pr~visions of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.

g.

Maintain cognizance of PRC activities through ISEG attendance at scheduled PRC meetings or through review of PRC meeting minutes.

Audits of operational nuclear safety-related facility activities shall be performed under the cognizance of NSB.

These audits shall encompass:

a.

The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.

b.

The performance, training and qualifications of the entire facility staff at least once per 12 months.

NU0182-0164A-TP05 6-8 Proposed

ADMINISTRATJVE CONTROLS 6.9.3.3 6.10 6.10.1 Special Reports

a.

Special reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable referenced specification:

Area Prestressing, Anchorage, Liner and Penetration Tests Primary System Surveillance Evaluation and Review Specification Reference 4.5.4 4.5.5 4.3 90 Days After Completion of the Test*

Five Years

  • A test is considered to be complete after all associated mechanical, chemical, etc., tests have been completed.
b.

Bimonthly status reports on the program to improve the reliability of the paths to prevent post-LOCA boron precipitation shall be submitted to the Division of Operating Reactors until completed.

c.

Deleted.

RECORD RETENTION In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated:

The following records shall be retained for at least five years:

a.

Records and logs of plant operation covering time interval at each power level.

b.

Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c.

Reportable Occurrences.

d. *Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

NU0182-0164A-TP05 6-26 Proposed

r.'

ADMINISTRATIVE CONTROLS

m.

Records for environmental qualifications which are covered under the provisions of Paragraph 6.14.

n.

Records of the service lives of all hydraulic and mechanical snubbers listed on Tables 3.20.1 and 3.20.2 including the date at which the service life commences and associated installation and maintenance records.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR, Part 20, and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12. 1 In lieu qf the "control device" or "alarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto 1shall be controlled by requiring issuance of a Radiation Work Permit.

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

1

a.

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

b.

A radiation monitoring device which continuously integrates the radia-tion dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after th~ dose rate level in the area has been established and personnel have been made knowledgeable of them.

Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of.their assigned radiation protection duties provided they comply with approved radiation protection procedures for entry into high radiation areas.

NU0182-0164A-TP05 6-28 Proposed

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ADMINISTRATIVE CONTROLS 6.10.2

e.

Records of changes made to the procedures required by Specification 6.8.1.

f.

Records of radioactive shipments.

g.

Records of sealed source leak tests and results.

h.

Records of annual physical inventory of all source material of record.

)

The following records shall be retained for the duration of the Plant operating license:

a.

Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b.

Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c.

Records of monthly radiation exposure for all individuals entering radiation control areas.

d.

Records of gaseous and liquid radioactive material released to the environs.

e.
f.
g.
h.
i.
j.
k.
1.

Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles.

I 1

Records of reactor tests and experiments.

1 Records of training and qualification for members of Plant Staff.

Records of inservice inspections performed pursuant to these Technical Specifications.

Records of Quality Assurance activities required by the QA Program Description.

Records of reviews performed for changes made to pr~cedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

Records of meetings of the PRC and NSB.

Records of monthly facility radiation and contamination surveys.

1 Effective as of December 31, 1984.

NU0182-0164A-TP05 6-27 Proposed