ML20044F109
| ML20044F109 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/14/1993 |
| From: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20044F106 | List: |
| References | |
| NUDOCS 9305260460 | |
| Download: ML20044F109 (23) | |
Text
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l ATI'ACIIMENT 1 i
Rancho Seco Permanently Defueled Technical Specifications PaFes Affected by Proposed License Amendment No.186, Revisions 1 Removal / Insertion Instructions Remove Insert D6-1 D6-1 D6-2 D6-2 D6-3 D6-3 D6-4 D6-4 D6-5 D6-5 D6-6 D6-6 D6-7 D6-7 D6-8 D6-8 D6-9 D6-9 D6-10 D6-10 D6-11 D6-11 D6-18 D6-18 D6-19 De ' 4 i
9305260460 930514 DR ADOCK 0500033y p
1 o
i RANCHO SECO UNIT 1 PERMANENTLY DEFUELED i
TECHNICAL SPECIFICATIONS i
D6.0 ADMINISTRATIVE CONTROLS 1
D6.I RESPONSIBILITY i
D6.1.1 The Manager, Plant Closure & Decommissioning (Plant Manager) shall be responsible -
l l
for the management of the overall facility, the operation and maintenance of the plant, and ensuring the safe storage ofirradiate d core components, and shall delegate in writing the succession of his responsibilities dming his absences.
D6.1.2 The Shift Supervisor (or a qualified, designated individual) shall be responsible for the control room command function. A management directive to that effect, signed by the Plant Manager, shall be issued to all plant personnel on an ANNUAL basis.
D6.2 ORGANIZATION D611 CORPORATE AND ON-SITE ORGANIZATIONS
(
Lorporate and on-site organizations shall be established for corporate management and facility operation respective 1y during the PERMANENTLY DEFUELED MODE. The organizations i
shall include the positions responsible for activities affecting the safe storage ofirradiated core l
components and the overall safety of the facility.
Lines of authority, responsibility, and communication shall be established and defined for a.
the highest management levels through intermediate levels to and including all operating orgamzation positio_ns. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in i"
equivalent forms of documentation. The organization and responsibilities shall be documented.in the Defueled Safety Analysis Report (DSAR).
l b.
The Plant Manager shall be resnonsible for overall unit safe operation and shall have l
r control over those on-site activities necessary for safe operation and maintenance of the plant.
The General Manager (GM), through the Assistant General Manager (AGM) and Chief c.
Operations Officer and the Deputy AGM, Operations, shall have corporate responsibility for overall safe operation of the facility and shall tak.e any measures needed to ensure 1
acceptable performance of the staffin operating, maintaining, and providing technical i
support to the facility to ensure NUCLEAR SAFETY.
d.
The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate on-site manager; howe.ver, they shall have sufficient organizational freedom to ensure their independence from operatmg pressures. The Quality organization has the authority to take any issue concerning the quality of operations at Rancho Seco to the Deputy AGM, Operations.
I Proposed Amendment No.186, Revision 1 l
D6-1
E RANCHO SECO UNIT 1
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PERM ANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)
D6.2.2 FACILITY STAFF The facility organization shall be as shown in the DSAR, and:
Each on-duty shift shall be composed of at least the minimum shift crew composition a.
shown in Table D6.2-1.
b.
At least one individual qualified a stand watch in the Control Room (a Non-Certified Shutdown Control Room Operator or a Certified Fuel Handler) shall be in the Control Room when fuel is in the spent fuel pool.
c.
An individual qualified in radiation protection practices and procedures shall be on site during fuel handling operations when fuel is in the spent fuel pool.
d.
All fuel handling operations shall be directly supervised by a Certified Fuel Handler.
e.
Administrative procedures shall be developed and implemented to limit the working hours of facility staff who perform functions important to the safe storage ofirradiated fuel asst mblies; e.g., Certified Fuel Handlers, radiation protection personnel, non-certified operators, and key maintenance personnel.
Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a normal shift schedule. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed:
a.
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 /> straight, excluding shift turnover time.
b.
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 seven day period, all excluding shift turnover time.
A break of at least eight hours should be allowed between work periods, including c.
shift turnover time.
d.
The use of overtime should be considered on an individual basis and not for the entire stafr on a shift.
Anv deviation from the above guidelines shall be authorized by the Plant Manager or
[
y designee, 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 shall be reviewed semiannually by the Mant Manager or designee to
[
assure that excessive hours have not been assigned. Routine deviation from the above -
guidelines is not authorized.
Proposed Amendment No.186, Revisions 1 D6-2
RANCHO SECO UNIT 1 PERMANENTLY DEFUELED I
TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)
- 'l FACILITY STAFF (Continued) f.
The individual who directly supervises the Shift Supervisors shall be a Certified Fuel f
Handler.
r TABLE D6.2-1
_j MINIMUM SHIFT CREW REQUIREMENTS
- l NUMBER FOR
-t POSITION PERMANENTLY DEFUELED MODE Shift Supervisor" 1
Non-Certified Operator 1
i Minimum Total Personnel 2
1 In the event that any member of a minimum shift crew is absent or incapacitated due to illness oi injury, a qualified replacement shall be designated to report on site within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Under these circumstances, the remaining shift crew member must stay in the control room until the replacement shift crew member arrives in the control room.
The Shift Supervisor shall be a Certified Fuel Handler.
l D6.3 FACILITY STAFF OUALIFICATIONS i
Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except fer the individual assigned the function of the' l
Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
D6.4 TR AINING A training program for the unit staff shall be maintained under the direction of the Plant-Manager and meet or exceed the requirements and recommendations of ANSI N18.1-1971, Section 5.5. A retraining and replacement training program for the Certified Fuel Handlers shall be conducted in accordance with a NRC approved traming program.
Proposed Amendment No.186, Revision 1 i
D6-3
.i RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS l.
ADMINISTRATIVE CONTROLS (Continued)
D6.5 REVIEW AND AUDIT D6.5.1 PLANT REVIEW COMMITTEE (PRC)
FUNCTION D6.5.1.1 The PRC shall function to advise the Plant Manager on matters related to NUCLEAR
[
SAFETY.
COMPOSITION l
D6.5.1.2 The PRC shall be composed of a Chairman and a minimum of four members.
j MEMBERSHIP D6.5.1.3 Membership of the PRC shall be as defined below:
A list of members made up of personnel filling positions in the Nuclear Organization and a.
others who meet or exceed the minimum qualifications of ANSI N18.1-1971, Section 4.2 or 4.4, shall be developed and approved by the Deputy AGM, Operations.
l b.
A list of alternate members of the PRC shall be developed and approved by the Deputy i
AGM, Operations.
c.
The Chairman of the PRC shall be appointed by the Deputy AGM, Operations. When a l
meeting is scheduled or an emergency meeting is necessary, and the PRC Chairman will be i
absent, an alternate Chairman may be designated by the PRC Chairman or the Deputy AGM, Operations from among the PRC members in Specification D6.5.1.2.
MEETING FREOUENCY -
D6.5.1.4 The PRC shall meet at least once per calendar month or more frequently as convened by the PRC Chairman, or as directed by the Plant Manager.
t QUORUM Db.5.1.5 A Quorum of the PRC shall consist of a majority of the members in Specification D6.5.1.2 including the Chairman or alternate Chairman. No more than two alternates shall participate in PRC activities at any one time for the purpose of estabushing a quorum.
f Proposed Amendment No.186, Revision-l' D6-4 i
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RANCHO SECO UNIT 1 PERMANENTLY DEFUELED q
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TECHNICAL SPECIFICATIONS l
.t ADMINISTR ATIVE CONTROLS (Continued)
)
RESPONSIBILITIES D6.5.1.6 The PRC shall be responsible for review of:
The required safety evaluation of: (1) all procedures and programs required by a.
Specification D6.8 and changes thereto, and (2) any other proposed procedures or programs or changes thereto which are as determined by the Plant Manager to affect l
NUCLEAR SAFETY.
b.
The s tfety evaluations of proposed tests and experiments that affect NUCLEAR SAFETY.
Proposed changes to the Technical Specifications or the Possession-Only License.
l c.
d.
All safety evaluations of proposed changes or modifications to plant systems er equipment -
1 that affect NUCLEAR SAFETY. Items which are dc ermined by a qualified reviewer as not involving an unreviewed safety question, a change of Technical Specifications, or a change in a licensing basis document need not be reviewed by the PRC.
Investipations of all violations of the Technical Specifications to determine adequacy of e.
corrective action and to detect any degrading trend.
f.
Facility operations to detect potential r.afety hazards.
1 g.
Events requiring a Licensee Event Report as deEned by 10 CFR 50.73 and NUREG-1022 to determine adequacy of corrective action and to detect any degrading trend. (See Specification D6.9.5.)
h.
Special investigations and reports thereon as requested by the Plant Manager.
i.
The Physical Security Plan and changes thereto.
j.
The Emergency Plan and changes thereto.
k.
The Fire Protection Plan Program and changes thereto.
1.
Changes to the PROCESS CONTROL PROGRAM, the OFF-SITE DOSE CALCULATION M ANU.tL and the RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM MANUAL. (See Specifications D6.13 and D6.14.)
Major changes to the Radioactive Waste Treatment Systems (Liquid, Gaseous and Solid).
m.
Review of any accidental, tuplanned, or uncontrolled release of radioactive material to the n.
environs, including the preparation and forwarding of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence. The PRC shall forward these reports to the Plant Manager and the MSRC.
Proposed i
Amendment No.186, Revision 1 D6-5 i
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PERMANENTLY DEFUELED
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TECHNICAL SPECIFICATIONS ADMINISTR ATIVE CONTROLS (Continued)
AUTHORITY D6.5.1.7 The PRC shall:
Recommend ir. writing to the Plant Manager approval or disapproval ofitems considered l
a.
under Specification D6.5.1.6.
b.
Render determinations in writing with regard to whether or not each item considered under Specifications D6.5.1.6a through e, and m above constitutes an unreviewed safety question.
F c.
Provide immediate written notiGeation to the MSRC Chairman of disagreement between i
the PRC and the Plant Manager; however, the Plant Manager shall have responsibility for l
r resolution of such disagreements pursuant to SpeciGcation D6 5.1.1.
RECORDS D6.5.1.8 Minutes of each PRC meeting, including appropriate documentation of reviews encompassed by SpeciGcation D6.5.1.6e and shall be prepared, approved, and forwarded to the 3
Plant Manager and to the MSRC Chairman within 14 days following each meeting.
l D6.5.2 MANAGEMENT SAFETY REVIEW COMMITTEE (MSRC)
FUNCTION D6.5.2.1 The MSRC shall function to provide independent review and audit of designated
)
activities in the areas of:
i a.
Facility Operation b.
Engineering / Nuclear Engineering l
i c.
Chemistry and Radiochemistry d.
Radiological Safety e.
Quality Assurance Practices COMPOSITION D6.5.2.2 The MSRC shall be composed of a Chairman and a minimum of four members. The MSRC membership shall be made up of direct reports to the Plant Manager or above as shown on the Nuclear Organization or of other personnel meeting or exceeding the minimum qualineations of ANSI /ANS 3.1-1981, Section 4.7.2.
i Proposed Amendment No.186, Revision 1 IM-6 j
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RANCHO SECO UNIT 1
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PERM ANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)
A1EMBERSHIP D6.5.2.3 The Chairman of the MSRC shall be appointed by the AGM & Chief Operations Officer. A current list of members and ahernates as described in Specifica'. ion D6.5.2.2 shall be i
developed and approved by the AGM & Chief Operations Officer and maintained by the MSRC Secretary. In the absence of the Chairman, an Alternate Chairman may be designated by the MSRC Chairman or the AGM & Chief Operations Officer. The Alternate Chairman shall be selected from among the MSRC members in Specification D6.5.2.2.
MEETING FREOUENCY t
D6.5.2.4 The MSRC shall meet at least once per calendar quarter and as convened by the MSRC Chairman or as directed by the Deputy AGM, Operations.
l OUORUM D6.5.2.5 A quorum of MSRC shall consist of a majority of the members in Specification D6.5.2.2, including the Chairman or alternate Chairman. No more than two ahernates shall participate in MSRC activities at any one time for the purpose of establishing a quorum. No more than a minority of the quorum shall have line responsibility for operation of the unit.
REVIEW D6.5.2.6 The MSRC shall be responsible for uview of:
The safety evaluation for (1) changes to procedures, equipment or systems, and (2) tests or a.
experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute on unreviewed safety question.
b.
Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as delined in 10 CFR 50.59.
Proposed tests or experiments which involve an unreviewed safety question as defined in c.
d.
Proposed changes in Technical Specifications or the Possession-Only License.
l Violations of applicable statutes, codes, regulations, orders, Technical Specifications, e.
license requirements, or ofinternal procedures or instructions having NUCLEAR SAFETY significance.
l I
f.
Significant operating abnormalities or devutions from normal and expected performance of plant equipment that afrect NUCLEAR SAFETY.
g.
LICENSEE EVENT REPORTS as defined by 10 CFR 50.73 und NUREG 1022.
Proposed Amendment :4o.186, Revision 1 D6-7 l
RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTR ATIVE CONTROLS (Continued) t REVIEW (Continued) h.
Any indication of an identified signincant deGeiency in the design or operation of safety-related structures, systems, or components.
i.
Reports and meeting minutes of the PRC.
J.
Any facility activity brought to the attention of the MSRC by the District's executive management which may be indicative of conditions adverse to NUCLEAR SAFETY.
k.
T1e MSRC shall provide oversight review of:
The District Quality Program, including the Audit Program content,
+
implemeitation and audit reports, The Radi sactive Waste Control Program, and Effectiveness of the LICENSEE EVENT REPORT Program per Specification
+
D6.6.
l
.t AUTHORITY D6.5.2.7 The MSRC shall:
I Report to and advise the Deputy AGM, Operations of those areas of responsibility l.
a.
specified in Specification D6.5.2.6.
b.
Recommend to the Deputy AGM, Operations other areas of facility operation for which l-the MSRC has determined the need for additional auditing per Specification D6.5.4g.
Advise the Deputy AGM, Operations of the need for independent auditing of facility l
c.
operations.
RECORDS
+
e D6.5.2.8 Minutes of each MSRC meeting and separate documentation of reviews encompassed
-l by Specifications 6.5.2.6d through h shall be prepared, approved, and forwarded to the Deputy AGM, Opemtions within 14 days following each meeting.
f Proposed Amendment No.186, Revision 1 l
D6-8 1
+
RANCHO SECO UNIT 1 j
PERMANENTLY DEFUELED l
TECHNICAL SPECIFICATIONS i
ADMINISTRATIVE CONTROLS (Continued) i D6.5.3 TECHNICAL REVIEW AND CONTROL l
Activities which affect NUCLEAR SAFETY shall be conducted as follows:
j Procedures, plans, manuals, and programs required by Specification D6.8 and other a.
procedures, plans, manuals, and programs which affect plant NUCLEAR SAFETY, and changes thereto, shall be prepared, reviewed and approved. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual (s) other than the preparer, but viho may be from the same organization as the preparer of the procedure, plan, manual and program or change thereto. Programs, plans, manuals, and procedures other than plant administrative pracedures will be approved as delineated in writing by the Plant Manager, but not lower than a direct report to the Plant Manager.
l Such procedures, plans, manuals and programs shall be reviewed periodically in accordance with administrative procedures.
The Plant Manager will approve plant administrative procedures, Security Plan l
Implementing Procedures and Emergency Plan Implementing Procedures.
Approval of temporary procedure changes which clearly do not change the intent of the approved procedure can be made by two members of the plant management staff, at least one of whom is a Certified Fuel Handler. The change shall be documented, reviewed and approved by the procedure's approval authority within 14 days ofimplementation.
b.
Proposed changes or modifications to plant systems or equipment that affect NUCLEAR SAFETY shall be reviewed by an individual (s) other than the individual (s) who designed the modification. but who may be from the same organization as the individual (s) who designed the modifications. Such modifications shall be approved by the Plant Manager r
or his designee as delineated in writing, but not lower than a direct report to the Plant I
Manager.
Proposed f ests and experiments which affect plant NUCLEAR SAFETY and are not c.
addressed in the DSAR shall be reviewed by an individual (s) other than the individual (s) l F
who prepared the proposed test or experiment. Such tests or experiments shall be approved by the Plant Manager or his designee as delineated in writing, but not lower than a direct report to the Plant Manager.
. c d.
Individuals responsible for reviews perfonned in accordance with Specification D6.5.3a, b and c shall meet or exceed the qualification requirements of Section 4.4 of ANSI l
N18.1-1971. Each such review shall include a determination of whether or not additional, cross-disciplinary review is necessary. If deemed necessary, such a review shall be performed by the review personnel of the appropriate discipline. A list of qualified reviewers for the independent reviews described in D6.5.3a, b and c above shall be established by the Plant Manager.
Proposed Amendment No.186, Revision 1 D6-9 r
5 i
9
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L RANCHO SECO UNIT 1 j
PERM ANENTLY DEFUELED
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L TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)
TECHNICAL REVIEW AND CONTROL (Continued)
Events reportable pursuant to Specification D6.9.5 and violations of Technical e.
Specifications shall be investigated and a report prepared which evaluates the event and which provides recommendations to prevent recurrence. Such reports shall be reviewed by the PRC and forwarded to ihe Plant Manager and the MSRC Chainnan.
l D614 AUDLTS Audits of facility activities shall be performed under the cognizance of the Quality organization supervisor. These audits shall encompass:
The conformance of facility op: ration to provisions contained within the Technical a.
Specifications and applicable license conditions at least once per year.
b.
The performance and qualifications of the entire Rancho Seco facility technical staff at least once per year.
c.
Tne result of actions taken to correct deficiencies occurring in facility equipment, structures, systems or methods of operation that affect NUCLEAR SAFETY at least once per 6 MONTHS for those changes not previously audited.
d.
The performance of activities required by the Quality Awance Program to meet the criteria of 10 CFR 50, Appendix B at least once per 2 years.
The Facility Emergency Plan and implementing procedures at least once per year.
e.
f.
The Facility Security Plan and implementing procedures at least once per year.
g.
Any other area of facility operation considered appropriate by the Plant Manager or the Deputy AGM, Operations.
h.
Compliance with fire protection requirements and implementing procedures at least once per 2 years.
]
i.
An independent fire protection and loss prevention inspection and audit shall be performed ANNUALLY using either qualified off-site licensee personnel or an outside -
fire protection firm.
. J.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire-consultant at intervals no greater than 3 years.
k.
The Radiological Environmental Monitoring Program (REMP) and the results thereof at least once per year.
I.
The ODCM and implementing procedures at least once per 2 years.
Proposed Amendment No.186, Revision 1 D6-10 I
l RANCHO SECO UNIT 1.
i PERMANENTLY DEFUELED
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TECHNICAL SPECIFICATIONS 1
ADMINISTR ATIVE CONTROLS (Continued)
.I AUDITS (Continued)
The PCP and implementing procedures for processing and packaging of radioactive m.
wastes from ligmd systems at least once per 2 years.
The performance of activities required by the Quality Assurance Program for Efiluent' n.
- Control and Environmental Monitoring at least once per year.
i Audit reports of reviews encompassed by Specification D6.5.4 shall be forwarded to the Deputy-AGM, Operations, the Plant Manager, the MSRC Chairman, and the management positions.
responsible for the areas reviewed within 30 days after completion.
D6.6 LICENSEE EVENT REPORT ACTION i
The following actions shall be taken for events which are reportable as LICENSEE EVENT
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REPORTS:
j a.
The Commission shall be notified and a report submitted per Specification D6.9.5, pursuant to the requirements of 10 CFR 20.405,50.73, and appropriate portions of 73.71 (as described in the Rancho Seco Physical Security Plan) and b.
Each LICENSEE EVENT REPORT shall be reviewed by the PRC and the results of ihis review submitted to the MSRC. Each LICENSEE EVENT REPORT shall be reviewed and approved by the Plant Manager or designee.
D6.7 -NOT USED-(
D6.8 PROCEDURES. PLANS. M ANUALS. AND PROGR AMS D6.8.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix "A" of Safety Guide 33, November a.
1972 b.
Irradiated Core Component Storage, Fuel Movement Operations, Decommissioning, and Decontamination I
Surveillance and test activities on equipment required for long-term safe storage of c.
irradiated core components d.
Security Plan implementation e.
Emergency Plan implementation f.
Fire Protection Program Plan implementation PCP implementation al.
ODCM implementation i.
REMP M ANUAL implementation j.
Quality Assurance Program for Effluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979
- k.
. Certificd Fuel Handler raining Program implementation T
1.
Quality Assurance Prop.' implementation.
m.
Radiation Protection Propm implementation j
Proposed Amendment No.186, Revision 1 D6-11
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RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS '
ADMINISTR ATIVE CONTROLS (Continued)
D6.12 HIGH R ADIATION AREA D6.12.1 In lieu of the " control device" or " alarm signal" required by 10 CFR 20.203(c)(2).
Each High Radiation Area in which the intensity of radiation is equal to or greater than a.
100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area, and entrance thereto shall be controlled by issuance of a i
Radiation Work Permit. Any individual or group ofindividuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates -
the radiation dose rate in the area.
b.
Each High Radiation Area in which the intensity of radiation is equal to or greater than 1,000 mrem /hr shall be subject to the provisions of SpeciGcation D6.12.la above, and, in addition, locked doors shall be provided to prevent unauthorized entry into such area.
The keys shall be maintained under the administrative control of the on duty Shift Supervisor. In lieu oflocked doors, certain areas within the Reactor Building, where no enclosure exists for the purpose oflocking. and where no enclosure can be reasonably constructed, shall be barricaded, conspicuously posted, and a conspicuous visible or ' _
l audible signal shall be activated such that an individual is made aware of the presence of 1
the High Radiation Area (>1,000 mrem /hr).
D6.13 PROCESS CONTROL PROGR AM (PCP) t D6.13.1 The required content of the PCP is deGned in SpeciGcation Dl.6.
D6.13.2 Licensee-initiated changes to the PCP:
Shall be documented and records of reviews performed shall be retained as required by a.
SpeciGcation D6.10.2.o. This documentation shall contain:
1)
SufGeient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and 2)
A determination that the change will maintain the overall conformance of the-processed waste product to existing requirements of Federal, State, or other applicable regulations.
b.
Shall become efTective after review and acceptance by the PRC and approval by the Plant Manager.
-I Proposed Amendment No.186, Revision 1-D6-18
)
1
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R ANCHO SECO UNIT 1 i
PER'.1ANENTLY DEFUELED TECHNICAL SPECIFICATIONS
. ADMINISTR ATIVE CONTROLS (Continued)
D6.14 OFF-SITE DOSE CALCULATION AND RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM MANUALS D6.14.1 The required content of the ODCM is defined in Specification Dl.7.
D6.14.2 The required content of the REMP MANUAL is defined in Dl.10.
D6.14.3 Licensee-initiated changes to the ODCM or REMP MANUAL:
Shall be documented and records of reviews performed shall be retained as required by a.
Specification D6.10.2.o. This documentation shall contain:
l)
Sumcient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and 2)
A detemlination that the change will maintain the level of radioactive emuent control required by 10 CFR 20.106,40 CFR 190,10 CFR 50.36a, and Appendix I i
to 10 CFR. 50 and not adversely impact the accuracy or reliability of emuent dose or setpoint calculations.
b.
Shall become effective after review and acceptance by the PRC and approval by the Plant Manager.
c.
Shall be submitted to the Commission in the form of a complete, legible copy of the entire 1
ODCM and/or REMP M ANUAL as a part of or concurrent with the Semiannual :
Radioactive Emuent Release Report for the period of the report in which any change to d
the ODCM and/or REMP M ANUAL was made. Each change shall be identified by~
markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented.
l l
i
'i i
Proposed Amendment No.186, Revision 1 l
D6-19 i
if ^
ATTACHM ENT_2 i
b Safety Analysis Report and No Significant Hazards Consideration for Proposed License Amendment No.186, Revision 1 P
0
Proposed License Amendment No.186, Revision 1 Log No.1094, Rev.1 Safety Analysis Report Page 1 of 5 SAFETY ANALYSIS REPORT Degription of Change Proposed License Amendment No.186, Revision 1 (PA-186, Rev.1) modifies the i
SM UD nuclear organization that will oversee the operation of the Rancho Seco nuclear facility at least through the Custodial SAFSTOR phase of the Rancho Seco decommissioning project. The District willimplement (upon NRC i
approval) the following nuclear organization and Rancho Seco Permanently l
Defueled Technical Specification (PDTS) changes:
e 1.
The District is replacing the Depaiy AGM, Nuclear position with a new position, the Manager, Plant Closure & Decommissioning (Plant Manager). The Plant Manager will take over the Rancho Seco site management responsibilities, previously held by the Deputy AGM, Nuclear, and be directly responsible for the overall day-to-day safe operation and maintenance of the Rancho Seco nuclear facility during the Permanently Defueled Mode (PDM).
2.
The District is creating a new corporate position, the Deputy AGM, Operations. The SMUD General Manager, through the AGM & Chief Operations Oflicer and the Deputy AGM, Operations, will have the ultimate corporate responsibility for the overall safe operation of the Rancho Seco nuclear facility. The new position, Deputy AGM, Operations, is taking over the direct corporate responsibilities that the AGM & Chief Operations Officer had for ensuring the overall safe operation'of the Rancho Seco nuclear facility during the PDM.
F 3.
The District proposes to combine PDTS Sections D6.2.ld and D6.2.le into one specification in accordance with the guidance contained in NRC Generic Letter 88-06, " Removal of Organization Charts from Technical Specification. Administrative Control.-
Requirements." The individuals that carry out quality assurance functions will report to the appropriate on-site manager and shall have organizational freedom to ensure their independence from operating pressures. Furthermore, the District adds a sentence to Specification D6.2.ld to clarify the relationship between the Quality
. organization supervisor and the Plant Manager and Deputy AGM, Operations, and indicate how the quality assurance functions are -
maintained independent from operating pressures.
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4 Proposed License Amendment No.186, Revision 1 Log No.1094, Rev.1 Safety Analysis Report Page 2 of 5 j
e Description of Change (Continued) 4.
The Management Safety Review Committee (MSRC) will report to and advise the new corporate position directly responsible for the Rancho Seco nuclear facility, the Deputy AGM, Operations.
5.
The Plant Review Committee (PRC) will report to and advise the new management position directly responsible for the overall day-to-day operation and maintenance of the facility, the Plant Manager. The Plant Manager will replace and take over the duties previously performed by the Deputy AGM, Nuclear.
6.
A change is made to the description of the position, under whom audits of facility activities are performed. The specific title, Manager, Nuclear Quality Assurance, is changed to the more l
generic position description, Quality organization supervisor.
7.
Reference to the Raciation Protection Manager (RPM)is editorially modified to clarify that the individual assigned the RPM function will meet the RPM qualification requirements specified in NRC Regulatory Guide 1.8, Sept mber 1975, as required by PDTS Section D6.3, Facility. Staff Qualifications.
These changes affect several sub-sections in PDTS Section D6.0, Administrative Controls.
Also, the District makes the following editorial changes:
1.
Reference in the PDTS to the Updated Safety Analysis Report (USAR) and the Operating License (OL) are changed to the Defueled Safety Analysis Report (DSAR) and the Rancho Seco Possession-Only License (POL), respectively, and 2.
A wording change is made to PDTS Section D6.5.1.4 (PRC Meeting Frequency) to ensure Specification D6.5.1.4 clearly states that the PRC may convene more frequently than once per month at the discretion of the PRC Chairman or the Plant Manager.
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b Proposed License Amendment No.186, Revision 1 Log No.1094, Rev.1 Safety Analysis Report Page 3 of 5 Reason for Change In order to establish a nuclear organization commensurate with the managerial l
demands that exist for the Rancho Seco facility during the PDM and the Custodial SAFSTOR decommissioning phase, the District proposes to amend the PDTS, as described above, based on the following:
1.
The Rancho Seco Possession-Only License status, 2.
The guidance contained in NRC Generic Letter 88-06, 3.
The reduced number of credible accidents applicable to Rancho Seco during the Permanently Defueled Mode (PDM),
4.
The reduced potential dose consequences that can result from the remaining credible accidents in the PDM, i
5.
The reduced level of activity at the plant during the PDM, 6.
The reduced number of personnel that make up the respective departments in the Rancho Seco nuclear organization, and 7.
The proposed Rancho Seco Decommissioning Plan (DP) and subsequent additional DP information submitted to the NRC.
Evaluation and Ilasis for Safety Findings The proposed changes do not alrect any systems, subsystems, or components.
.The changes affect administrative controls only; the Rancho Seco nuclear organization specifically.
PDTS Section D6.0 contains details of the administrative controls and organizational relationships necessary to ensure safe operation of the Rancho i
Seco nuclear facility during the PDM. The proposed organization and title changes add one level of management at the corporate level that is directly responsible for the corporate oversight of the Rancho Seco nuclear facility. The MSRC will report to this new corporate management position.
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r Proposed License Amendment No.186, Revision 1 Log No.1094, Rev. I Safety Analysis Report Page 4 of.5 Evaluation and Basis for Safety Findings (Contimied)
The management position title which was directly responsible for the overall day-to-day safe operation'and maintenance of the Rancho Seco nuclear facility is changed to Plant Manager, which is commensurate with the activities and safety significance associated with preparing Rancho Seco for the Custodial SAFSTOR decommissioning phase.
An enhancement, in accordance with NRC Generic Letter 88-06, and a clarification is made through combining PDTS Specifications D6.2.ld and D6.2.le and adding additional Quality organization authority descriptions to Specification D6.2.ld. The Quality organization supervisor will report to the Plant Manager (the appropriate on-site manager) and have the authority to take i
any issues concerning the quality of operations at Rancho Seco to the Deputy AGM, Operations, thereby ensuring independence of quality assurance functions from operating pressures.
The SM UD General Manager will still have the ultimate corporate responsibility for the overall safe operation of Rancho Seco. The proposed changes continue to maintain the on-site and corporate organizational relationships and controls necessary to ensure the plant will be operated safely during the PDM and at least through the Custodial SAFSTOR decommissioning phase.
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Proposed License Amendment No.186, Revision 1 Log No.1094, Rev.1 Safety Analysis Report Page 5 of 5 NO SIGNIFICANT IIA 7ARDS CONSIDER ATION The District has reviewed the proposed changes against each of the criteria in 10 CFR 50.92, and, based on the discussion in the above safety analysis report, concludes:
A significant increase in the probability or consequences of an accident previously evaluated in the S AR will not be created, because the proposed organization changes continue to provide the management oversight features that are important to ensure overall safe operation of the Rancho Seco nuclear facility during the PDM, through the Custodial SAFSTOR decommissioning phase.
The proposed amendment will not create the possibility of a new or different type of accident than previously evaluated in the SAR, because the changes are administrative in nature, maintain the appropriate organization relationships that will ensure safe plant operation in the PDM, and do not provide any new mechanisms by which an accident can occur.
The proposed PDTS amendment will not involve a significant reduction in the margin of safety, because the District will continue to maintain the appropriate administrative controls, organizational relationships, and corporate and on-site line management responsibilities necessary to ensure Rancho Seco is operated safely during the PDM.
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ATTACHM ENT 3 Rancho Seco Nuclear Organization Resulting from PA-186, Rev.1 (for information only) i i
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r RANCHO SECO NUCLEAR ORGANIZATION BOARD OF DtRECTORS GENERAL MANAGER AGM & CHIEF OPERATIONS OFFICER l
DEPUTY AGM, p
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l MANAGEMENT SAFETY REVIEW COMMITTEE y9 issues) l MANAGER, P;. ANT l
CLOSURE AND DECOMMISSIONING g
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CUAUTW PLANT REWEW PN STAFF UCENS!NG/ ADMIN COMMITTEE l