ML20011D761
| ML20011D761 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/01/1989 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20011D723 | List: |
| References | |
| NUDOCS 8912280376 | |
| Download: ML20011D761 (27) | |
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t TABLE OF CONTENTS i
CHAPTER 138 CONDUCT OF OPERATIONS l
13.1 ORCANIZATIONAL STRUCTURE i
13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION i
13.1.2 OPERATING ORCANIZATION RESPONSIBILITIES 13.1.3 QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL 13.1.4 PLANT ADDITIONAL SUPPORT 13.1.5 SHIFT COMPOSITION 13.1.6 OVERTIME LIMITS AND CUIDELINES j
13.2 TRs.INING 13.2.1 PLANT AND SUPPORT STAFF TRAINING PROGRANS 13.3 EMERCENCY PLANNINC 13.3.1 SITE EMERCENCY PLAN l
13.3.2 SITE EMERCENCY PLAN IMPLEMENTING PROCEDURES 4
13.4 REVIEW AND AUDIT 13.5 PLANT PROCEDURES 13.5.1 ADMINISTRATIVE PROCP.DURES 13.5.2 PLANT OPERATING PROCEDURES 13.5.3 OPERATING PROCEDURAL SAFECUARDS 13.5.4 MEASURES TO PREVENT OPERATING ERROR 13.5.5 OTHER PROCEDURES l
13.6 INDUSTRIAL SECURITY l
13.6.1 SECURITY PLAN i
L 13.6.2 SAFECUARDS CONTINCENCY PLAN 13.6.3 SUITABILITY TRAINING AND QUALIFICATION PLAN nema m@
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! O 13.1 i
ORCANIZATIONAL STRUCTURE t
13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION
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The offsite organisation for management and technical support is i
described in the " Consumers Power Company Quality Assurance Program Description for Operational Nuclear Power Plants, CPC-2A," which is
" Incorporated by Reference" as part of this Updated FHSR, as described in Chapter 17.
The offsite and onsite organization are further described in the " Big i
Rock Point Plant Technical Specifications," which is " Incorporated by I
Reference" as part of this Updated FHSR, as described in Chapter 16.
13.1.2 OPERATING ORGANIZATION RESPONSIBILITIES The Plant organization is depicted on Figure 13.1, and the following provides a general discussion of responsibilities:
The Plant Manager is responsible for overall plant safe operation and has control over those onsite activities necessary for safe operation and maintenance of the plant. He vill delegate in writing the succession to this responsibility during his absence.
p The Production & Performance Superintendent is responsible for Q
plant operation and reactor engineering. The Engineering Superintendent is responsible for mechanical / civil and electrical engineering, security an(. a new procedure development / upgrade group. The Maintenance,iuperintendent is responsible for mechanical /
electrical and instrumentation and control maintenance, material I
services and outage ;1anning and scheduling. The Chemistry / Health l
Physics Superintendent is responsible for radiation protection, I
plant chemistry, radioactive wastes and emergency planning. The l
Technical Engineer in responsible for Plant licensing interfaces.
The responsibilities of others reporting to the Plant Manager are l
self explanatory.
The Shif t Supervisor will be responsible for the shif t command function. A Management directive to this effect will be issued annually by the Vice President - Nuclear Operations.
13.1.3 QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL 4
Staff qualifications are established consistent with the intent of ANSI Standard 18.1-1971 and are described in the Plant's Administrative Procedures.
a.
Each member of the plant staff will meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions.
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b.
Either the Chemistry and Health Physics Superintendent or the i
Chemistry and Radiation Protection Supervisor will meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. For t
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 combination of the followings (a)
Formal schooling in science engineering, or (b) operational or i
technical experience / training in nuclear power.
- c. The On-Call Technical Advisor (OTA) will have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents, i
d.
Either the Production and Performance Superintendent or the Operations Supervisor will hold an SRO (Senior Reactor Operator l
License) and meet or exceed the minimum qualifications of ANSI-N18.1-1971 for the comparable position of Operations Manager.
i The individual holding an SRO will be responsible for directing the activities of licensed operators.
l 13.1.4 PLANT ADDITIONAL SUPPORT A.
To support the Plant Organization shown on Figure 13.1, personnel knowledgeable in the following areas identified in ANSI N18.7-1976/
ANS 3.2 will report at the discretion of the Plant Managers i
1.
Nuclear Power Plant Hechanical, Electrical and Electronic Systems 2.
Nuclear Engineering 3.
Chemistry and Radiochemistry.
4.
Radiation Protection (Reports to Chem /HP Superintendent)
B.
Quality Assurance / Control activities will be in accordance with Consumers Power Company's Quality Assurance Program Description for Operational Nuclear Power Plants, (CPC-2A, as revised),
(reference Chapter 17 of this Updated FHSR).
C.
The Security Force will be supervised as described in the Security Plans (reference Section 13.6 of this Updated FHSR).
D.
Fire Protection responsibilities for the Plant Fire Protection Program impimentation are as described in the BRP Fire Plan and the Fire Protection Summary - BRP Plant Manual. Refer to Section 9.5.1 of this Updated FHSR.
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i 13.1.5 SHIFT COMPOSITION In order to ensure safe and well organized day to day operations, the minimum shift complem nt will be as follows:
TABLE 13-1 MINIMUM SHIFT CREW COMPOSITION Position Number of Individuals Required To Fill Position Power Refueling Shutdown or Operation Operation Cold Shutdown SS 1
1 1
RO 2
1 1
i A0 2
2 1
SS - Shift Supervisor with a Senior Operators License RO - Individual with a Reactor Operators License AO - Auxiliary Operator The Shift Crew Composition may be one less than the minimum requirements of Table 13-1 for a period of time not to exceed 2-hours.in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements of Table 13-1.
This provision Oi does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent. An on-call Technical Advisor is required and must be able to arrive on-site within one hour.
During any absence of the Shift Supervisor from the control room during power operation an individual with a Reactor Operators License will be designated to assume the control room command function.
Each on-duty shift will be composed of at least the minimum shift a.
crew composition shown in Table 13-1.
b.
At least one licensed Operator will be in the control room when fuel is in the reactor.
c.
At least two licensed Operators will be present in the control room during reactor start-up (to a power level 3 5 percent),
scheduled reactor shutdown and dudng recovery from reactor trips.
d.
An individual qualified in radiation protection procedures will be on site when fuel is in the reactor.
Radiation Protection coverage 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.
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All core alterations, af ter the initial fuel loading, will either f
e.
be performed by a licensed Reactor Operator under the general supervision of a Senior Reactor Operator or a nonlicensed Operator directly supervised by a licensed Senior Reactor Operator (or Senior Operator Limited to Fuel Handling) who has no other concurrent responsibilities during this operation.
f.
Fire Brigade composition and requirements are described in Section 9.5.1.4 of this Updated FHSR. The Fire Brigade will not include 2 members of the minimum shift crew t.ecessary for safe t
shutdown of the plant and any personnel required for other i
essential functions during a fire emergency.
g.
The minimum refueling crew during refueling operations will be four men. There will be a licensed operator in the control room at all times, and the Shift Supervisor will be in charge.
13.1.6 OVERTIME LIMITS AND CUIDELINES Administrative procedures will in be effect to limit the working hours of plant staff who perform safety-related operation functions; ie, senior reactor operators, reactor operators, auxiliary operators, health physicists and key maintenance personnel.
Adequate shif t coverage will be maintained without routine heavy use l
of overtime. However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines will be followed:
1.
An individual should rot 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.
2.
An individual should 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 7-day period, all excluding shift turnover time.
3.
A break, including shift turnover time, of at least eight hours should be allowed after continuous work periods of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> duration.
4.
Except during' extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.
Deviation from the above guidelines will be authorized by the Plant Manager or his alternate (Production and Performance or Maintenance Superintendents), or higher levels of Management, in accordance with established procedures and with documentation of the basis for granting the deviation.
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Controls will be included in the procedures such that individual overtime vill be reviewed monthly by the Plant Manager or his designee to assure that excessive hours have not been assigned.
Routine deviations from the above guidelines are not authorized.
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M11189-0428A-BX01 l
,s Plant Menager Quality Public Human Assurance Affairs Resources Director Director Director QA Plant Review Superintendent Committee (PRC) (1)
Plant (2)
QC Safety Supervisor Coortfinator Engineering Maintenance Production and Chemistry /Mealth Superintendent Superintendent Performence Physics Superintendent Superiw;endent
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-qTA Supeh,1sion Technical Admin Instrument Reactor Operations On-Call Engineer Supervisor and Control Engineer Supervisor Technical Supervisor (3)
Advisors
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Notes: (1) On-site Review Organization - For shift s
Radiation Protection Details. Refer to Technical supervisors (3] - ~ ~ - - - - - - - - -
- Technician (4)
Specifications.
l (2) Responsible For Plant Fire Protection Reactor Operators (5)
Program Auml11ery Operatorsi (3) Senior Reactor Operator (4) On-Shift h feel Is In Reactor (5) Licensed Reactor Operators FIGURE 13.1 PLANT ORGANIZATION 13.1-6 MI1189-0428A-BI01
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I 13.2 TRAINING
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A retraining and replacement training program for the plant staff is maintained to meet or exceed the requirements and reconsnendations set forth in Section 5.5 " Retraining and Replacement Training" of the American Nuclear Society, American National Standards Institute (AHSI) " Standard for Selection and Training of Personnel for Nuclear Power Plants," ANSI N18.1-1971 and Title 10 - Energy, Code of Federal Regulations (CFR), Part $$ - Operators' Licenses.
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Training programs have been established and maintained to ensure operating and support ort anization personnel possess the appropriate t
knowledge, experience, and proficiency essential to the safe and efficient operation of the Big Rock Point Nuclear Plant.
13.2.1 PLANT AND SUPPORT STAFF TRAINING PROGRANS Fire Brigade Training is addressed in Section 9.5.1.4 of this Updated FHSR.
Emergency Plan Training is addressed in the Site Emergency Plan which is incorporated by reference in Section 13.3 of this Updated FHSR.
Quality Assurance Training is addressed in the Consumers Power O
Company Quality Assurance Program Description (QAPD) for Operational-Nuclear Power Plants (CPC-2A). The QAPD is incorporated by reference in Chapter 17 of this Updated FHSR. The QAPD provides information on the training, qualification,-retraining, reevaluation, recertification e
and requalification for Quality Assurance related functions.
Security Guard Training te addressed in the " Plat.s" described in Section 13.6 of this Updated FHSR.
THe following training programs are " Systematic Approach to Training (SAT) based and are either certified or accredited by the Institute of Nuclear Power Operations (INPO).
13.2.1.1 Ceneral Employee Training General Employee Training (CET) will be provided to all personnel requiring unescorted access. There is an associated examination t
required for course completion. The course consist s of two modules The orientation module provides information with respect to security, plant description, procedures, and Quality Assurance / Quality Control necessary to obtain unescorted access authorization.
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The radiation saf;;ty Indoctrination module provides radiation safety familiaritation for persons requiring routine or frequent access to the Plant's protected area, who do not routinely work in radiation controlled areas as part of their normal job functionst le, clerical workers.
i A requalification course and examination is administered annually and I
is required for the renewal of unescorted access authorization.
Central Employee Training is certified to meet the intent of INPO 87-004
" Guidelines for General Employee Training" and was certified by INPO l
in April 1987.
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13.2.1.2 Basic Radiation Worker Training Basic Radiation Worker Training will be provided for persons who routinely work in " radiation controlled areas," performing operations, inspections, administrative, maintenance, or safety functions. The course provides information ont 1.
Radiation safety fundamentals.
i 2.
" Standards for Protection Against Radiation" and CPCo radiation exposure limits and controls / external exposure control O
measures.
3.
Radioactive contamination 1(mits and controls / internal exposure control measures.
4.
Radioactive materials cont.o1 methods.
5.
Radioactive waste management and control procedures.
6.
Preparation for emergencies - Worker-related informat'. n and actions.
7.
Radiation safety program description.
8.
Respiratory protection program description and NUREC-0041 -
" Manual of Respiratory Protection Against Airborne Radioactive Material," compliance.
9.
Radiation survey requirements.
Successful completion of the course requires passing a written examination and satisfactorily performing the following practical actions:
1.
Read and interpret direct reading dosimeters.
tx 2.
Properly don and remove a full set of protective clothing.
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3.
Properly enter and leave a contamination area, including whole body frisk (may be done in conjunction with donning and removing protective clothing).
4.
Demonstrate the ability to work under a Radiation Work Permit (kVP).
An annual basic radiation worker requalification course is required j
for renewal of unescorted access authorization. The requalification course requires successful completion of a written examination and practical factors, unless a waiver is granted by plant management.
Basic Radiation Worker Training is certified to meet the intent of L
INPO 87-004 " Guidelines for General Employee Training," and was certified by INPO in April 1987 as part of General Employee Training above.
13.2.1.3 Reactor Operator Training Program The Big Rock Point Operator Training Program is a comprehensive Integrated Training Program. The operator positions covered under this program include the A2xiliary Operator (AO), Control Room Operator (RO), Shift Supervisor (SRO) and the On-Call Technical Advisor (OTA). The On-Call Technical Advisor is the BRP replacement for the Shif t Technical Advisor /Shif t Engineer (SRO) and requires the Oi classroom portion of the Senior Reactor Operator and OTA task specific on-the-job training as well as portions of the requalification training of the Control Room Operator and Shif t Supervisor.
The OTA will receive specific training in plant design, at.d response and analysis cf the plant for transients and accidents.
The program was accredited by INPO on September 24, 1986.
13.2.1.4 Licensed Operator Training Program Certification The Institute of Nuclear Power Operations (INPO) certification letters dated December 18, 1985 and Sep* ember 24, 1986 Indicated that the National Nuclear Accrediting Board awarded accreditation of the following (Operator) training programs for CPCo's Big Rock Point
-Plant, (reference CPCo letter dated May 26, 1987).
Non-licensed Operator Reactor Operator Senior Reactor Operator /Shif t Supervisor t
- Now referred to as the On-Call Technical Advisor (OTA).
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This meets the training program approval specified in paragraphs 55.31(a)(4) and 55.59(c) of 10 CFR Part 55 - Operator Training, that the training programs are accredited and are " systems approach to training" based, as defined in 10 CPR 55.4.
13.2.1.5 Instrument anS Control (16C) Training Program The Big Rock Point I&C Training Program is a comprehensive Integrated Training Program. The I&C positions covered under this program include Technician Trainee, Instrument Technician, Control Technician, Nuclear Instrumentation and Control Technician, and Senior Nuclear Instrumentation and Control Technician.
The program was accredited by INPO on December 18, 1985 and September 24, 1986.
i 13.2.1.6 Hechanical and Electrical Malt:tenance Personnel Training Program The Big Rock Point Hechanical and Electrical Maintenance Training i
Program is a comprehensive, integrated training progrce.
The positions covered under this program include Combination Electrical /Hechanical llelper, Combination Electrical /Hechanical Repairworker B, Combination Electrical /Hechanical Repairworker A, Qualified Welder and Machinist.
The Maintenance Repairworker positions at Big Rock Point Nuclear O
Plant are a combination of Hechanical sr.d Electrical Tasks. This means that the repairworker positions are responsible for handling the tasks identified in the Mechanical and Electrical areas.
The program was accredited by INPO on February 24, 1988.
r 13.2.1.7 Chemistry and Health Physics Training Program l
The Big Rock Point Chemistry and llealth Physics Training Program is a i
comprehensive, integrated training program. The Chemistry and llealth Physics positions covered under this program include Technician Trainee, Chemistry / Radiation Protection Technician I, Chemistry /
Radiation Protection Technician II and Senior Chemistry / Radiation i
Protection Technician.
The program was accredited by INPO on February 25, 1988.
13.2.1.8 Technical Training Program The technical training program provides the comprehensive training necessary for both experienced and newly assigned management, engineering, supervisory and technical personnel to provide safe, i
efficient and effective support of Consumers Power Company's nuclear
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power plant operations.
The program was accredited by INPO on February 25, 1988.
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13.3 EMERCENCY PLANNING 13.3.1 SITE EMERGENCY PLAN A Big Rock Point Plant Site Emergency Plan has been developed and implemented to meet the standards of 10 CFR 50.47 Emergency Plans and the requirements of 10 CFR 50.54(q) (as a condition of the License) along with 10 CFR 50 Appendix "E" - Emergency Planning and Preparation for Production and Utilization Facilities.
The Big Rock Point Site Emergency Plan was developed using the criteria provided in NUREG-0654, FEMA-REP-1, Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," except where specific exemptions have been taken.
The " Big Rock Paint Plant Manual - Volume 9 - Site Emergency Plan,"
as revised, is incorporated by reference as a part of this Updated FHSR.
The Site Emergency Plan is revised on a schedule separate ! rom this Updated FHSR, and changes to the Plan are submitted in accordance with 10 CPR 50.54(q) and 10 CPR 50.4.
13.3.2 Site Emergency Plan Implementing Procedures Detailed implementing procedures for the BRP Site Emergency Plan have been developed, impicmented and maintained to meet the requirements of 10 CPR 50 Appendix "E".
The "BRP Plant Manual, Volume 9A - Site Emergency Plan Implementing 4
Procedures" are not considered part of this Updeted FHSR. The
" Implementing Procedures" and changes thereto are submitted to the i
Commission as specified in 10 CFR $0 #ppendix "E",Section V and 10 CFR 50.4.
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13.4 REVIEW AND AUDIT 4
Provisions for conducting reviews and audits of activities affecting plant safety have been established. Review and audits of operating i
phase activities that are related to nuclear cafety are delineated in the Big Rock Point Facilit.y Operating License, License Number DPR-6, j
Appendix "A" Technical Specifiertion. These activities are further addressed in Consumers Power Company Quality Assurance Program Description (QAPD) for Operational Nuclear Power Plants - CPC-2A.
i These documents are incorporated by reference in Chapter 16 and 17 of this Updated FUSR and the review and audit functions contained in the Technical Specifications and CPC-2A will not be repeated in this l
Updated FHSR.
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13.5 PLANT PROCEDURES 13.5.1 ADMINISTRATIVE PROCEDURES l
13.5.1.1 Conformance With Regulatory Cuide 1.33 - Quality Assurance Program Reauirements (Operation)
CPCo complies with the regulatory position of Regulatory Culde 1.33
- (2/78, Revision 2) as modified by the exceptions stated in the Qaality Assurance Program Description (QAPD) for Operational Nuclear Power Plants (CPC-2A). The QAPD provides Policy and Implementation requirements for Instructions, Procedures and Drawings, and will not be repeated in this Updated FHSR. The following provides general and specific information on Administrative Controls in addition to or supplementing that specified in CPC-2A.
13.5.1.2 Administrative Control Requirements and Standards The duties and responsibilities for each operating position will be clearly set down in writing.
Decision-making authority will be defined for the various operating position levels and reservations of decision-making authority specified.
Minimum standards will be established for the performance of various operational programs.
All repetitive operations such as startup, shutdown, and routine maintenance will be carried out according to normal operating procedures. Specific procedures will be prepared as necessary for non-routine operations.
13.5.1.3 Hessures To Be Taken Following Incidents To prevent or limit adverse consequences following incidents, it will be standard proce< lure tot a.
Investigate all such incidents.
b.
Suspend any unsafe operation pending an investigation.
Establish any additional procedures necessary to prevent c.
recurrences.
Notification will be made to the NRC as required by the Facility Operating License or by 10 CFR Part 20.
13.5.1.4 Administrative Procedural Controls All procedures and procedure revisions are to be approved by the Plant Manager prior to use.
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The Department Head approves all working level procedures prior to their issuance.
The Plant Review Committee (PRC) will review all procedures and j
revisions to those procedures that affect nuclear safety to ensure.
that an unreviewed safety question does not exist.
This body will l
make recommendations to the Plant Manager as to whether the proc.edure should be approved.
l The Quality Assurance Department will review nuclear safety-related procedures prior to their issuance for usage as described in the QA Program Description (CPC-2A).
Plant procedures will be filed in the Plant's document control center for periods of time consistent with guidance given in the QA Program Description (CPC-2A).
13.5.2 PLANT OPERATINC PROCEDURES
.i This section describes the Big Rock Point plant operating procedures, which include procedural operating safeguards to be established, p
the plans for pre-operational testing and initial startup of the
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reactor system, the procedures for normal operation, and the plans for handling emergency situations which may arise in the operation of the plant.
13.5.2.1 Basic Operatina Principles The basic operating principles for the plant are as follows:
Before being placed into regular service, the plant vill be subjected to appropriate individual component and systems tests, and an initial operation program.
Operation and control of the reactor and most of the process equipment is to be centralized in the control room, which is located in the turbine building. Thn control room is' equipped with a main control console, with corresponding instrument panel, for control of the generator, turbine, nuclear steam supply system, 3
reactor control systems, reactor plant auxiliary systems, and the electrical system. The control room is shielded so that it is tenable in event of a maximum credible accident.
Shift crew composition is outlined in Section 13.1 of this Updated FilSR.
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Operators may perform certain operating functions at control panels and stations outside of the control room but only at the direction of or with prior knowledge of the licensed operator in the control room.
Startup, normal shutdown, and all other repetitive operations will be performed in accordance with specific procedures.
Maintenance of most facilities outside the shielded area may be undertaken by contact methods and without over-all plant shutdown when such work can be accomplished without exceeding permissible radiation exposure limits.
Surveillance tests and routine preventive maintenance of protective devices and critical operating equipment will be done in accordance with established schedules.
With some exceptions, the reactor enclosure and turbine building areas are habitable during normal operation. Radiation monitorirs by fixed or portable instrumentation will be provided for initial entry to all controlled radiation areas.
All personnel leaving controlled radiation areas, and all equipment being removed from such areas, will be surveyed to an extent adequate for control of contamination.
Irradiated fuel is to be changed by semi-remote methods, ie, by operators using long grappling poles through water and a lead shielded transfer cask. The water serves as both shielding and coolant for the irradiated fuel. To assure the protection of the environs against the effects of an ccident, reactor containment integrity provisions will be in effect during all times that it is physically-possible for the reactor to bc made critical, or whenever the reactor system is pressurized.
Operation of the radiaactive waste handling system will be such as to assure that the disposal of radioactive materials will not result in the exposure of any persons on or off the plant site to radiation in excess of permissible limits. These operations will be performed in accordance with NRC regalations (10 CPR Part 20).
Most liquid wastes are handled in discrete betches to facilitate control. Most gaseous and airborne wastes are continuously monitored and discharged from a high stack to facilitate atmospheric diffusion.
Caseous wastes from the disebarge of non condensibles from the main condenser will be subjected to a time delay to allow the decay of short lived radioisotopes.
Solid wastes are stored in underground tanks or vaults.
All incidents, unsafe acts, and excessive exposures to radiation will be investigated to effect procedures to prevent recurrence.
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In the event of sty situation which may compromise the safety of continued operation, it will be required procedure to shut the plant down and to take other planned emergency action to protect equipment and the health and safety of workers and the public.
i 13.5.2.2 Description of Operating Procedures The Operations procedures are divided or grouped into six areas as f
follows; details on each of these areas are provided in subsequent i
sectionst a.
00P - General Plant Operating Procedures provide instructions for integrated operation of the Plant during Plant start-up operation and complete shutdown of the Plant.
b.
SOP - Plant System Operating Procedurc; provide instructions f or energizing, filling, venting, draining, start.ing-up, shutting down, changing modes of operation, and other instructions appropriate for the operation of Plant systems.
c.
AJP - Alarm Procedures - correcting abnormal alarm conditions -
provides a description of all annunciators, their respective sensor designations, the trip setting which is associated with the alarm, along with the corrective action which is expected O
of the Operator. Memorization of Operator actions is not required.
d.
ONP - Of f-Normal Pr *:edures provide Operator instructions for
_ placing the Plant in a stable condition.
Immediate action steps will be memorized.
e.
EMP - Emergency Procedures provides Operator with instructiuns for correcting emergency conditions.
Immediate action steps will be memorized.
f.
E0P - Emergency Operating Procedures provide Operator with instructions, in flow chart form, for correcting certain types of emergency conditions not covered by EMPs. Entry conditions to E0Ps will be memorized.
13.5.2.3 ceneral operatina Procedures General Operating Procedures shall inclede procedures to control equipment, to maintain personnel and reactor safety, and to avoid l
unauthorized operation of equipment. Operating procedures shall include:
13.5.2.3.1 Start-up Procedures i
Start-up procedures to provide for starting the reactor from hot er cold conditions, establishing power operation with tne generator synchronized to the line and recover from reactor trips.
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O 13.5.2.3.2 cold Start-up Af ter Extended Shutdown procedures are in place to ensure that all plant systems and instrumentation necessary for safe operation are operacional and ready for service.
(a) To ensure that the overall plant is in a state of readiness, a start-up checklist shall be followed prior to beginning the actual start-up so that applicable equipment and systems shall be in condition for start-up. Containment sphere integrity provisions shall be in effect.
l (b) To ensure that the checksheets are correctly accomplished and documented a review will be performed by the Shift Supervisor i
prior to plant st.irtup.
(c) To ensure that the reactor reactivity control is in a state of readiness, each control rod shall be exercised and scrammed as a check of the control rod hydraulic system and the reactor safety system. A coupling verification check shall be included prior to or during start-up.
(d) To ensure that the out of core neutron monitoring instrumentation is functioning properly and actually monitoring neutron multiplication the source range monitor shall indicate a Q
minimuni of three counts per second with a signal-to-noise ratio of 3 to 1.
This will be accomplished by withdrawing the proportional counter to a region of lower flux and observing the reduction in count rate.
In the event that neutron source strength is insufficient to produce the required count rate, special approved procedures will be developed to utilize incore instrumentation for making the initial critical approach with the reactor head removed.
l A similar special procedure for less than 3 counts per second as outlined in the Technical Specifications may be necessary for reactor st art-up.
(e) To ensure that adequate neutron multiplication and reactor power level monitoring is carried out throughout the entire plant startup, critical approaches will be monitored using source range monitors. The startup rate will be restricted to demonstrate that the wide range neutron power level monitors overlap the readings of the source range monitor prior to the source range monitors becoming saturated.
To ensure that control rod reactivity worth are maintained within limits such that accidental reactivity insertion do not jeopardize fuel integrity, control rod withdrawal sequences will be specified and rod worth according!y limited.
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l (f) To ensure reactor pressure vessel metal ductility and structural integrity, the power shall be adjusted once criticality is i
reached to maintain a teactor vessel temperature rise rate not to exceed 100'F per hour.
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(g) To ensure that a reactor primary heat sink is available, the i
turbine shaf t sealing system shall be placed in service as soon as sufficient steam pressure is available (approximately 150 psig) and the condenser shall be evacuated with the mechanical vacuum pump and the air ejector will be placed in service.
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(h) To ensure that the reactor is operated with automatic pressure control the mode of turbine control will normally be via the Initial Pressure Regulator. Reactor Pressure should be controlled j
at or near the nominal 1335 psig to ensure that the operational pressure setpoints of the high pressure alarm, scram, emergency condenser actuation and steam drum relief valves are appropriately i
close to the normal controlling pressure of the reactor.
(i) To ensure that the desired power distribution is maintained in the reactor core, a control rod drive withdrawal pattern will be developed by the Reactor Engineering group. Neutron flux distribution and flux and power peaking factors will be periodically and routinely verified by neutron monitoring flux wire irradiations and analysis.
I1 In-core neutron monitors are provided in 24 axial and radial locations in core however they are not associated with the reactor protection system.
13.5.2.3.3 Hot Startup Whenever the plant has been shutdown for a period of tim with the reactor vessel and auxiliaries remaining pressurized, a hot start-up l
procedure shall be followed to return the plant to service. This procedure will be essentially independent of the cause of shutdown at.suming that the cause is recognized and any nonstandard conditions have been corrected. The reactor instrumentation shall be reset and a hot start-up checklist shall be completed prior to the withdrawal of control rods.
A coupling integrity check shall be made in accordance with Section 4.7.2.8 of this Updated FHSR and the Technical Specifications.
The start-up shall then ' proceed in accordance with Technical. Specifications sections for the normal cold start-up procedure outlined therein.
Appropriate portions of the master checklist'used for the cold startup will be designated as applicable for the hot startup.
OO 13.5-6 MI1189-0429A-BX01
13.5.2.3.4 Shutdown Procedures Shutdown procedures to guide operations during and following controlled reactor shutdown or reactor trips, and to establish or maintain hot standby or cold shutdown conditions.
For extended shutdowns the following precautions will be in place.
To ensure that systematic control is traintained on the reactor and its primary heat sink as well as the turbine generator, reactor power shall be reduced by manipulation of the control rods, and the main generator load shall be decreased simultaneously.
The turbine-generator shall be separated from the system.
To ensure that the reactor is in a cold shutdown condition all control rods shall be inserted.
To ensure the reactor vessel metal remains ductible and free of excessive thermal stress, the removal of reactor decay heat and the reduction of reactor pressure shall be accomplished by controlling reactor steam flow. The rate of cooling of the reactor vessel shall not be allowed to exceed 100*F per hour. Any two temperature measuring points on the reactor or any two on the steam drum are not to be allowed to exceed a differential temperature of 2 150*F.
To ensure a means of reactor decay heat removal, tie reactor shutdown cooling system shall be placed in operation phenever reactor pressure drops below a pressure sufficient to raaintain turbine seals. This system will complete the cooline; of the reactor water to 125'F.
To ensure continuous monitoring of the reactor power level, a minimum of one source range monitor chcnnel and one power range monitor channel shall be left in operation. All instrumentation pertaining to control of activity release : hall be lef t in operation.
13.5.2.3.5 Power Operation and Load Changina Procedures Power operation and load changing procedures provide for steady-state power operation and load chemps, including response to unanticipated load changes, use of control rods, chemical shim, coolant flow control or any other system available for long-or short-term control of reactivity, making deliberate load changes, responding to unanticipated load changes, and adjusting operating parametcrs.
For normal power operation the turbine initial pressure regulator will maintain the reactor pressure at its normal value by operating the turbine admission valves. The turbine load will be established by the reactor control rod positions. The principal functions of the operating personnel during this period will be the maintenance of a continuous watch in the control room for prompt attention to 13.5-7 Mill 89-0429A-BX01
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any annunciated alarms, the adjustment of the control rod pattern to accommodate changes in reactivity and to maintain the desired power distribution, and the evaluation of abnormal conditions and the initiation of corrective action as required.
13.5.2.3.6 System operatina Procedures Systea Operating Procedures shall describe the operation of the plant including providing instruction to energize, fill, vent, drain, startup, shutdown, changing modes of system operation and other instructions appropriate for the operation of systems related
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to the safety of the plant.
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13.5.2.3.7 Alarm and Response Procedures Alarm and Response Procedures shall provide the operator with required actions to be taken when an abnormality in a plant system is annunciated.
13.5.'2.3.8 Off-Normal Procedures Off-Wormal Operating Procedures shall provide for operation during potential emergency conditions. They shall identify potential emergency conditions and shall include the steps to cope with the O
emergency so that the trained operators will know in advance the expected course of events that will identify an emergency and the immediate actions to be taken.
Since emergencies may not follow anticipated patterns, the procedures should provide sufficient flexibility to accommodate variations.
Procedures that cover actions for manipulation of controls to prevent accidents or lessen their consequences should be based on a general sequence of observations and actions.
When immediate operator actions are required to prevent or mitigate the consequences of a serious condition, the procedures shall require those actions be implemented promptly (according to the time constraints identified in the procedure).
Of f-Normal procedures may contain supplemental background information to further aid operators in taking proper actions.
Itowever, this information shall be separated from the procedural actions. The actions required shall be based on a conservative course of action by the operating crew.
13.5.2.3.9 Fuel Handling Procedures Fuel Handling Procedures shall snecify actions for core alterations, g
accountability of fuel, partial or complete refueling operation,
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receipt and shipment of fuel, and associated measures for nuclear safety during fuc1 handling.
13.5-8 Mill 89-0429A-BX01
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U The procedure for core alterations includest a.
Continuoas monitoring of neutron flux throughout core loading i
1 b.
periodic checks to ensure suberiticality and reactivity shutdown margin c.
periodic recording of data i
d.
Audible annunciation of abnormal flux. increases e.
Evaluation of core neutron multiplication Specific procedures shall be prepared for each refueling outage.
procedures should prescribe the general preplanning for the fuel l
handling program and its associated safety measures. They should I
identify those aspects of the program for which procedures are to l
be prepared for each refueling outage.
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To ensure that a systematic and orderly evaluation of activities accompanies each refueling, detailed written procedures shall be available prior to each refueling outage.
O To ensure that all fuel moves are done in such a manner as to provide for both reactor and personnel safety, the insertion and removal of fuel bundles and channels shall be done through the top of the reactor vessel after opening reactor vessel head closures as appropriate. Water shielding shall be provided by flooding the reactor vessel and the refueling extension tank. Fuel bundles and channels shall be handled by means of a grapple, transfer cask, and crane.
(Note, the fuel shuffling winch may be utilized for fuel and channel shuffling within the reactor.)
Fuel shall be replaced according to the following sequencet (i)
Removal of selected bundles from core and transfer to spent fuel storage.
(ii) Reshuffling of remaining bundles in core as desired.
(iii) Insertion of new bundles in vacant positions as desired.
Shutdown margin verifications and suberiticality checks shall be made as required by the Technical Specifications and as discussed in Sections 4.6.1.2 and 9.1.4.3 of this Updated FHSR. Assembly replacement shall proceed as described above until the desired number of fuel assemblies have been changed.
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To ensure that the reactor neutron flux level can be continuously monitored and that protective interlock and reactivity controls are in place during each refueling, the trip devices specified in Section 9.1.4.3 of this Updated FHSR and in the Technical Specifications, shall be in service and connected to the reactor safety system during all refueling operations.
No additional instrumentation need be placed within the core lattice if the out-of-core instrumentation produces a significant response to the suberiticality check in the region to be altered.
If this criterion cannot be met, a low-level neutron detector, i
measuring neutron flux, shall be located near the region to be i
altered.
In addition, both source range monitor channels shall be in service and measuring neutron flux during all refueling operations.
To ensure that a redundant means of making the reactor core suberitical always exists during refueling operations, the liquid poison system shall be available and ready for use.
To ensure that radioactive releases are not allowed to escape to the environs, containment sphere integrity provisions shall be in effect during refueling operations.
To ensure that new fuel is in such a location that it is easily accessible to the refueling tools, new fuel will normally be stored in new fuel. storage. However, fuel may also be safely moved using pRC reviewed procedures directly from the manufacturer's shipping
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containers after the fuel has been inspected.
To ensure controlled storage and to protect personnel from exposure to radiation, long term storage of irradiated fuel and irradiated fuel channels will be underwater in the spent fuel pool.
To ensure that an adequate crew size is maintained to safely perform refueling duties, the minimum refueling crew during refueling operations shall be four men. There shall be a licensed operator in the control room at all times, and the Shift Supervisor shall be in charge.
To ensure that the safety cables on the refueling transfer cask are operational and to eliminate the potential for inadvertent dropping of the cask into the reactor vessel or the spent fuel pool, functional testing of the trip mechanism of the fuel transfer cask safety catch device shall be performed prior to commencing refueling activities.
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13.5-10 Mill 89-0429A-BX01
O 13.5.2.3.10 Emergency Operating Procedures A series of emergency operating procedures have been developed to guide the operator in dealing with emergency situations. These procedures are written in either standard paragraph form and/or flow diagram language. They are symptom based procedures that guide the operator depending on the symptoms that are indicated on the plant instrumentation.
l These procedures control and mitigate the consequences of an accident by directing the operator to take control of three major parameters on the reactor, (power, water level and pressure), along l
with three major parameters on the containment, (pressure, water level and temperature).
Emergency Action Plans for Operating Personnel Control Room Personnel Control room personne'l will be responsible for the following i
actions a.
Assure that the reactor is subcritital.
4 b.
Assure that the containment sphere is isolated and all penetration O
isolation valves are closed.
c.
Notify plant personnel d.
Notify senior member of plant management e.
Assure that cooling of the reactor has been initiated f.
Assure that cooling of the containment vessel is maintained l
g.
Collect data from radiation monitoring equipment to assure that I
such data are available for determining subsequent action.
Action By Plant Management The senior member of plant management present will be responsible
.for the following actions:
a.
Determine extent and severity of the radiological hazard b.
Order partial or complete evacuation of the site as required c.
Formulate and initiate appropriate course of action Notify State and local officials as appropriate d.
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e.
Notify off-site Consumers management 13.5-11 Mill 89-0429A-BX01
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Notify NRC as required by the operating license or by 10 CFR, Part 20.
13.5.3 operating Procedural Safeguards The following procedural safeguards are established to assure the operating safety of the Big Rock Point Plant.
Detailed written procedures for all normal and emergency operations which may involve nuclear safety are prepared and issued prior to startup of the plant.
Instructions for normal operations consist of detailed procedures required for the operation of systems and equipment associated with the plant.
The shift operating personnel are directed to follow the approved procedures unless deviation is required to prevent injury to personnel or damage to equipment or the environment.
Operator aids are posted in appropriate plant locations to assist the operator and administrative controls have been established for these operator aids.
O Short term directions from Plant management to the Operators are
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conveyed via Operations Memos and Daily Orders. Administrative controls have been established for these Memos and Orders.
l The emergency procedures are separated into four parts. The first part describes the symptoms, the second the automatic actions, the third t;ie immediate actions which are to be taken to shut the plant down and to place it in a safe condition. The fourth part describes the follow-up actions which are to be taken to maintain the plant in a safe condition.
It is recognized that action after placing the plant in a safe condition will be dictated largely by the circumstances existing at the time and that to this extent prepared procedures cannot cover all conditions and thus in all cases will not substitute for the responsible judgment of plant management personnel. In addition to the emergency procedures related to plant operations, procedures and precautions related to emergencies postulated for any industrial plant, such as fire, earthquake, tornado and flood, have been developed. These procedures include specific instructions as to special precautions and procedures which must be followed because of the potential presence of radioactivity.
13.5.4 Measures to Prevent Operating Error Thorough trsining of the operating staf f and systematically planned operating and maintenance procedures will combine to keep to a minimum the possibility of operator errors.
13.5-12 H11189-0429A-BX01-
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O' Each operator will be well acquainted with his specific duties and responsibilities and the action to be taken in the event of off-standard conditions. The following paragraphs discuss the design measures and administrative controls which will promote the safety of plant operation.
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13.$.$
other Procedures i
Other procedural requirements for the following categories of j
procedures are described in the QA Program Description (CPC-2A):
Equipment control procedures.
Plant radiation protection procedures.
Instrument calibration and test procedures.
Chemical-radiochemical control procedures.
Radioactive waste management procedures.
Maintenance and modification procedures.
Material control procedures.
Temporary procedures.
Surveillance test procedures.
Procedural requirements for Security procedures are addressed in the Security Plans discussed in Section 13.6 of this Updated FHSR.
Emergency Preparedness procedures are eddressed in the Site Emergency O
Plan discussed in Section 13.3 of this Updated FilSR.
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13.5-13 M11180-0429A-BX01
f 13.6 INDUSTRIAL SECURITY Consumers Power Company plans for physical protection of the Big Rock Point Nuclear Power Plant are described below. Each of these plans are a separate submittal. withheld from public disclosure pursuant to 4
10 CFR 73.21 - Requirements for Protection of Safeguards Information.
These plans are submitted, amended, revised, changed, or updated and approved on a schedule separate from this Updated FHSR.
i These plans contain " Safeguards Information" of a type specified in 10 CFR 73.21 and are not included in this Updated FHSR.
13.6.1 BIC ROCK POINT SECURITY PLAN The BRP Security Plan provides a comprehensive program of physical protection provisions to meet the requirements of 10 CFR 50(p). The Security Plan addresses vital equipment, vital areas, isolation zones, and demonstrates how CPCo complies with the requirements of 10 CFR 73 and 10 CFR 11.
Changes to the Security Plan are submitted to the NRC in accordance with 10 CPR 50.4.
These changes must be consistent with 10 CFR 50.54(p)
)
or may be amended per 10 CFR 50.90.
13.6.2 BIC ROCK POINT SAFECUARDS CONTINCENCY PLAN The BRP Safeguards Contingency Plan provides guidance to personnel in order to accomplish specific, defined objectives in the event of j
threats, thefts, or radiological sabotage relating to special nuclear material or the BRP Pl ut.
The Safeguards Contingency Plan is developed and maintained to meet the requirements of 10 CFR 73 t
Appendix "C".
Changes to the Safeguards Contingency Plan are submitted to the NRC in accordance with 10 CFR 50.4.
These changes must be consistent with the provisions of 10 CFR 50.54(p) or may be amended per 10 CFR 50.90.
13.6.3 BIC ROCK POINT SUITABILITY, TRAINING, AND QUALIFICATION PLAN The BRP Sultability, Training, and Qualification Plan provides for the selection, training, equipping, testing, and qualification of individuals who will be responsible for protecting special nuclear materials at the BRP Nuclear Power Plant. The Suitability, Training, and Qualification Plan was developed, implemented, and maintained to assure that Security Personnel effectively perform their assigned security related job duties. The Suitability, Training, and Qualification Plan addresses the General Criteria for Security Personnel pursuant to 10 CFR 73 Appendix "B".
Changes to this " Plan" are submitted to the NRC in accordance with 10 CPR 50.4.
These changes must be consistent with 10 CFR 50.4(p) or i
h may be amended per 10 CFR 50.90.
v 13.6-1
.MI1189-0423A-BX01
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