ML20040B227
| ML20040B227 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/19/1982 |
| From: | FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20040B219 | List: |
| References | |
| TAC-10836, NUDOCS 8201250284 | |
| Download: ML20040B227 (12) | |
Text
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
TSCRN 67, Rev. 1 ADMINISTRATIVE CONTROLS 8201250284 820119 DR ADOCK 05000304 p
i I
j i
J TECHNICAL SPECIFICATION CHANGE REQUEST N0. 67, Rev. 1 (APPENDIX A) l Delete and add the following pages in Appendix A:
s DELETE ADD 3
6-2 6-2 6-3 6-3 6-5 6-5 6-6 6-6 6-7 6-7 6-12 6-12 j
6-13 6-12a 1
6-14 6-13 1
6-14 l
a Proposed Change j
The changes proposed will alter current on-site administrative controls in j
two major areas:
(1)
The PRC composition is expanded to provide additional members from i
several plant departments.
I (2)
The procedure review process is expanded to provide an alternate review process not including the PRC in pre-implementation review of certain procedures.
l l
Reason for Proposed Change The expanded PRC will allow several improvements in our conduct of business at the plant site.
The improvements will have a positive effect on plant safety by allowing necessary review functions to go on concurrent with other activities.
These improvements include, but are not limited to:
(a)
By expanding participation in the PRC, greater specific expertise /
interest can be directed toward reviews.
(b)
By expanding number of members, it is more likely that representa-tives from all departments can participate in all meetings.
(c)
By expanding' number of members, greater continuity will exist as personnel transfer, are promoted, etc.
(.d)
By expanding number of members, general point of view, policy, etc.
is less likely to be affected by absence of particular members /
3 departments.
i i
i l
i
P i
The augmented review process will provide the following improvements:
(a)
By having clearer line responsibility, reviews are more likely to be thorough and accurate.
(b) The actual individuals working on a problem will have the most current expertise on various issues. They will also be most able to identify proper reviewers in interfacing departments.
4 (c)
The Qualified Reviewersiin each department will develop a broad understanding of the impact of various procedures on otner depart-ments.
(d)
Less PRC time will be taken up in routine activities.
1 (e)
Important management time will not be diverted from primary roles.
Safety Analysis Justifying Proposed Change Florida Power Corporation considers the preceding to have clearly underscored the benefits of the proposed change.
The following potential drawbacks were also considered:
(1)
PRC expansion could lower the level of review (less " management" invol vement).
FPC does not consider this to outweigh the benefits since a more deliberate review by roughly equally experienced personnel is superior to overburdening a relatively few key personnel.
(2)
Revised review process could lessen quality of review.
FPC considers this highly unlikely.
Superintendent level approval and 50.59 review by PRC is required to assure necessary management involvement.
By placing more responsibility on those doing " detail" work, quality is expected to improve.
I Florida Power Corporation is strongly convinced that in light of current interest in " Human Factors" the proposed change is a step toward a more efficient and thorough onsite review process.
Diversion of senior site management to review functions does not support their main function and, in fact, could divert their attention from important matters.
The ability to operate the plant in a safe manner is expected to be significantly enhanced by this change. This change
~
would not involve any unreviewed safety items.
l 1
FktbilUil FLORIDA POWER CORP.
SENIOR 9
birdluk VICE PRESIDENT d
VICt PhESIDEN!
ENGINEERING CohP08 ATE LisVlttS E. CONSTRUCTION t, GE N. COUN',E L NUCLEAR GENERAL I
l l
REVIEW C0ffi.
M#
VICL PRESIDENT
- VICE PRESIDENT ADt1INISTRATIVE NUCLEAR h
SE kVICE S OPERATIONS
-t w
VICL h.'LSIDENT ENvikUNHLNi E. NEW NUCLEAR ILCHNOLOGY PL AN T
- MANAGER I
DIRtCIOR
[N'v1HONMLl4I AL f.
DIRECIOR DIRECTOR DIRECTOR MANAGER litt451r40 f,FFAlk5 full E. SPECIAL PbHCHASING f, OUALITY PROGRAMS flUCL E AR Ll4'v iko.dltf.l AL t.
PROJECTS STORES OU AL IT Y PROGR AMs SUPPORT hEG.
SERVICES MANAGER MANAGER MANAGER MANAGER POWER PLANr NUCL E AR NUCLEAR NUCLEAR MATERIAts MATERIALS ENGINEERING CONT ROL S STORES MANAGEMENT
_ _l l
l SilPERVISOR MANAGER SUPE RVISOR MATERI AL QUAL. ENG.
DUALITYAUDITS TECHNOLOGY AND SURVElLLANCE SIAFF STAFF STAFF I
I
_I MANAGER OF
$UPE WISOR
' INDICATES POSITION HAVING FIRE PROCUREMENT GUALITY PROTECTION RESPONSIBILITY.
AND SITE QA ENGINEERING FIbunt 6.2-1 UFFSIIE ORGANIZATION
Q NUCLEAR PLANT c
Q W NA GE H
- D y
T ELH. ASST. To p)
NlLLE AR F1 ANT M
MANA 4 H p
NtlC ILCH SdC5 MIRAllONS (A/QC MA I NT EteANCF
+ NOIa CHLM/HAD NLC. nDI.
SUPL RI NT LPd4 NT SUPE h l NT E PK)[NT LOMPL I ANr.E S'JCS. SUPI'.
FkOftCTION SLH v lCt h (SELIN I IY )
(SOL )
MANAGE R SUFt HI NT LM( NT W1. AGE R SUF1RINTL41NT (pg f
l CHLM/h AD N1LE AR File UNM VE L Nill.L E AN Of 'l HA T I ONS COMPL I APK.L M CHANICAL PLA NN 14, SE CtN I T Y l
FkO T EL T ION T LOf. SUFFOHT EMil*(LR4PO OFFICER
[NGI NE ER SUPE H v l SIN SUPtHvlSatS trK,l PE FR SPtCIALIST E NLil f( [R SUPT HV I S,H L__
__L __
1 IJmT H ALTm OPikATIONS COMF1 l A NLC BU I LDifC E Ml %E T. Y PLAPT CLwufLH Rt wit fHuJECT T ECHN IC AL DE O4A N ICS SLRvlCL S M D iC AL HLAL IH AND CONTHOLS
( NGI P4 E H MmGt H ADv l SUN S AUDIT:NS SUPL H v l S'J<
T ECHN IC I AN fHYSICIST SPLCI AL IS T SetCIALIST l
c" ___-_ _ _
4 a
SECtklif SHIFT QA/QC ELECTHICAL BUI LDi t HEAL TH CHEN IC AL NLLL E AR Ni.0LE AR
$HlFT SUF1RvlSm5 FHYSICS AND WASIL TECH. SPtC.
INS L Ry lC t I NSP.
SUPT Hv lSm (SOL)
SUPtHvism SUPtRvlSm S SLH v lC[ MEN SUPL H vl SUR W NAGE R COWD i> Alm SPtCI AL IS T (NDQ -
___ L__ _ _
l
_1 1
l L__
AS$1STANI ASSISTANT SHlff (A/QC ADMI NIS TRAT a vE CHEMICAL NULLEAll PLANT NUCLEAR S'LIN i l Y SHI F T SUP[R v l SINS ELFCTHICIANS T ECHN ICI ANS AND WASTE E ngl PE ER/ANA L YS1 INSE RVICE INSP Supt H v l Sm (SOL)
INSPLC TOf S PLANNER SUPLR HS m SITCIALIST SPECIALIST l
j j
(Pumps &vhSJ I t.CHN'.C AL MATERIALS ASSISTANT Nd'Lt AR
[Q3)[{
GUAHD FUFCt OPLHATm 3 SUPFUti PLANN if0 T LCHN IC I ANS F INE PHOTLCT ION
{0L)
SUPLHVISOtS COmD INA T G1 Emi PE LH SPt.CI AL IS T
- SPICIALIST A551STAN' PLANNit0 NLILEAR pj A*7p T LCHN ICI ANS MATLHIALS MOO 4F IC AT ION COmD 1 NA T 31 COLND i te T ut SPECIALIST DJCDUJ
GANIZATIt ifJ
ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable posi; ions, except for the Chemi;try and Radiation Protection Manager who shall1 meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and the Operations Technical Advisor, who shall have a Bachelor's degree, or the equivalent, in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant for transients and accidents.
6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Nuclear Plant Manager and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Nuclear Plant Training Manager and shall meet or i
exceed the requirements of Section 27 of the NFPA Code-1975, except for Fire Brigade training sessions which shall be held at least quarterly.
i 6.5 REVIEW AND AUDIT I
6.5.1 PLANT REVIEW COMMITTEE (PRC)
FUNCTION 6.5.1.1 The Plant Review Committee shall function to advise the Nuclear Plant Manager on all matters related to nuclear safety.
i COMPOSITION 6.5.1.2 The Plant Review Committee shall be composed of the:
i Chairman: Technical Service Superintendent i
Member:
Operations Superintendent i
Member:
Maintenance Superintendent l
j Member:
Nuclear Technical Services Superintendent (Security) l Member:
QA/QC Compliance Manager f
Member:
Chem / Rad Protection Manager l
Member:
Technical Support Engineer Member:
Performance Engineering Supervisor Member:
At Large (Designated by Chairman) i Member:
At Large (Designated by Chairman)
ALTERNATES l
6.5.1.3 All alternate members shall be appointed in writing by the PRC Chair-man to serve on a temporary basis; no more than two alternates shall participate as voting members in PRC activities at any one time.
l l
MEETING FREQUENCY l
i 6.5.1.4 The PRC shall meet at least once per calendar month and as convened by the PRC Chairman or his designated alternate.
i I
CRYSTAL RIVER - UNIT 3 6-5
t ADMINISTRATIVE CONTROLS
]
QUORUM i
6.5.1.5 A quorum of the PRC shall consist of the Chairman or his designated alternate and five members including alternates.
l f
RESPONSIBILITIES 6.5.1.6 The Plant Review Committee shall be responsible for:
a.
Review of 1) all procedures and changes thereto as required by Specification 6.8.2, 2) any other proposed procedures or changes thereto as determined by the Nuclear 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 the Appendix "A" Technical Specifications.
i d.
Review of all proposed changes or modifications to plant systems or equipment that affect r.aclear safety.
1 e.
Investigation of all violations of the Technical Specifications l
including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the t
Vice President, Nuclear Operations and to the Chairman of the Nuclear General Re' view Committee.
f.
Review of events requiring 24-hour written notification to the Commission.
l g.
Review of facility operations to detect potential nuclear safety l
hazards.
l I
h.
Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman of the Nuclear General Review Committee.
1 i.
Review of the Plant Security Plan and implementing procedures.
i j.
Review of the Emergency Plan and implementing procedures.
l l
l 4
e CRYSTAL RIVER - UNIT 3 6-6
i ADMINISTRATIVE CONTROLS l
4 t
AUTHORITY l
6.6.1.7 The Plant Review Committee shall:
a.
Recommend to the Nuclear Plant Manager written approval or I
disapproval of items considered under 6.5.1.6 (a) through (d) above.
b.
Render determinations in writing with regard to whether or not each item considered under 6.6.1.6 (a) through (e) above i,
corStitutes an unreviewed safety question.
j c.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President, Nuclear Operations and the Nuclear General Review Committee of disagreement between the PRC and the Nuclear Flant Manager; however, the Nuclear Plant Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above.
1 RECORDS I
i 6.6.1.8 The Plant Review Committee shall maintain written minutes of each meeting and copies shall be provided to the Vice President, Nuclear Operation's and Chairman of the Nuclear General Review Committee.
6.6.2 NUCLEAR GENERAL REVIEW COMMITTEE (NGRC) t FUNCTION l
l 6.6.2.1 The Nuclear General Review Committee shall function to provide independent review and audit of designated activities in the areas of-a.
Nuclear power plant operations
?
b.
Nuclear engineering i
c.
Chemistry and radiochemistry I
d.
Metallurgy i
t t
.e.
Instrumentation and control
[
l l
f.
Radiological safety f
i g.
Mechanical and electrical engineering i
i l
h.
Quality assurance practices 4
I r
CRYSTAL RIVER - UNIT 3 6-7
}
I r
dDMINISTRATIVECONTROLS
\\
6.7 SAFETY LIMIT VIOLATION i
l 6.7.1 The following actions shall be taken in the event a Safety Limit is L
violated:
a.
The facility shall be place in at least HOT STANDBY within one hour.
b.
The Safety Limit violation shall be reported to the Commission, i
the Vice President, Nuclear Operations and to the NGRC within I
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
f c.
A Safety Limit Violation Report shall be prepared.
The report i
shall be reviewed by the PRC.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures and
[
(3) corrective action taken to prevent recurrence.
d.
The Safety Limit Violation Report shall be submitted to the Commission, the NGRC and the Vice President, Nuclear Operations within 14 days of the violation.
i 6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Appendix "A" of l
Regulatory Guide 1.33, November,1972.
t b.
Refueling operations.
c.
Surveillance and test activities of safety related equipment.
i d.
Security Plan implementation.
i e.
Emergency Plan implementation.
I l
f.
Fire Protection Program implementation.
i g.
Systems Integrity Program implementation.
i i
4 h.
Iodine Monitoring Program implementation.
6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed and approved prior to implementation as follows:
j a.
The Emergency Plan, Security Plan, Fire Protection Plan and
)
implementing procedures, Administrative Instructions and those 3
test procedures associated with plant modifications shall be i
reviewed and approved by the PRC and the Nuclear Plant Manager prior to implementation.
l t
CRYSTAL RIVER - UNIT 3 6-12 j
ADMINISTRATIVE CONTROLS b.
For all other procedures, the review cycle shall consist of:
an intradepartmental review by a Qualified Reviewer,'an inter-disciplinary review by Qualified Reviewer (s) in interfacing departments, as specified in Administrative Procedures, and approval by the responsible Superintendent or Manager, as specified by Administrative Procedures.
The PRC shall then review the 10CFR 50.59 evaluation within 14 days of approval.
c.
The training and qualification of Qualified Reviewers shall be governed by Administrative Procedures, with final certification by the Nuclear Plant Manager.
Recertification will be required on a periodic basis and upon transfer between departments. As a minimum, all Qualified Reviewers shall meet the requirements of ANSI N18.1-1971, Sections 4.2, 4.3, 4.4, or 4.6, or the equivalent.
d.
Each procedure and administrative policy of 6.8.1 shall be reviewed on a periodic basis as set forth in Administrative Procedures.
i t
l l
CRYSTAL RIVER - UNIT 3 6-12a
1 ADMINISTRATIVE CONTROLS 6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:
a.
The intent of the original procedure is not altered.
b.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License.
c.
The change is documented and subsequently reviewed and approved within 14 days of implementation, in accordance with the requirements of Specification 6.8.2.
6.9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be sub-mitted to the Director of t1e Regional Office of Inspection and Enforcemert unless otherwise noted.
STARTUP REPORTS 6.9.1.1 A su. mary report of plant startup and power escalation testing will be submitted following (1) receipt of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.
6.9.1.2 The startup report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described.
Any additional specific details requested in license conditions based on other commitments shall be included in this report.
6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whi iever is earliest.
If the Startup Report does not cover all three events (i.e.,
initial criticality, completion of startup test program, and the resumption or commencement of commercial power operation), supple-mentary reports shall be submitted at least every three months until all three events have been completed.
CRYSTAL RIVER - UNIT 3 6-13
ADMINISTRATIVE CONTROLS ANNUAL REPORTS 6.9.1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year.
The initial report shall be submitted prior to March 1 of the year following initial criticality.
6.9.1.5 Reports required on an annual basis shall include:
a.
A tabulation of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem /yr and their associated man-rem exposure according to work and job functions,1 e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling.
The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD, or film badge measurements.
Small exposures totalling less than 20 percent of the individual total dose need not be accounted for.
In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.
b.
A list of the reactor vessel material surveillance capsules installed in the reactor at the end of the report period and a summary of any withdrawals or insertions of capsules during the report period.
In supplying this information, the ownership of each capsule shall be indicated and the irradiation location in the vessel of each capsule which was inserted during the report period shall be identified.
r 1
This tabulation supplements the requirements of 20.407 of 10CFR Part 20.
l l
CRYSTAL RIVER - UNIT 3 6-14 l