Text

Revised Tech Spec Section 6.0 Re Administrative Controls
	ML20072H253
Person / Time
Site:	Callaway
Issue date:	03/23/1983
From:	; UNION ELECTRIC CO.
To:	;
Shared Package
ML20072H249	List: ML20072H245; ML20072H253;
References
	NUDOCS 8303290356
	Download: ML20072H253 (40)
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SECTION 6.0 ADMINISTRATIVE CONTROLS ,-

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ADMINISTRATIVE CONTROLS D, 6.1 RESPONSIBILITY 6.1.1 The Manager, Callaway Plant shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility-during his absence.

6.1. 2 The Shift Supervisor (or during his absence from the control room, a designated individual) shall be responsible for the control room command .

function. A management directive to this effect, signed by the Vice President-Nuclear shall be reissued to all station personnel on an annual basis.

6.2 ORGANIZATION OFFSITE -

6.2.1 The offsite organization for' unit management and technical support shall be as shown in Figure 6.2-1.

UNIT STAFF 6.2.2 The Unit organization shall be as shown in Figure 6.2-2 and,:

a. Each on duty shif t shall be composed of at least the minimum shift f-crew composition shown in Table 6.2-1; k- b. At least one licensed Operator shall be in the control rcom when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Operator shall be in the control room; '

An

^ gindivifual

th quaJkfied in r,adiation protection procedures

c. .. r hy ic: I::Pnician" shall be on site when fuel is in the /

reactor;

d. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibili' ties during this operation; ,

e. A site Fire Brigade of at least five members shall be maintained onsite at all times." The Fire Brigade shall not include the Shift Supervisor and the (2) other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency; and

f. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g., licensed Senior Operators, licensed Goerators, teelth y . ., 2 i ; '. ; ;; , i s. ' . a c., ;;ca t: n , ;nd ss,, n i..:n;n:: ;c semci 4

k gThe m altr. g in sa!;; f individual qualified in radiation protection proceduresR ;r-i;';n and Fire minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to g Brig i

accommodate unexpected aosence provided immediate action is taken to fill the.

required positions.

health physics personnel, equipment operators, and instrument technicians.

CALLAWAY - UNIT 1 6-1

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ADMINISTRATIVE CONTROLS k,;/ -

shift Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a normal 8-hour day, 40-hour week while the plant .is operating.

However, in the event that unforeseen problems require substantial.

amounts of overtime to be used, aor during extended periods of shut-down for refueling, major maintenance or major plant modifications,

,. on a temporary basis, the following guidelines shall be followed:

1) An individual should not be permitted to-work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time;

2) An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period, nor more-than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48-hour period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, all excluding shift turnover time;

3) A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift turnover time; and

4) Except during extended shutown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Emergency Duty Officer.

Any deviation from the above guidelines shall be authorized by the

/ Manager, or higher levels of management, in accordance with estab-lished 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 monthly by the Manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is_ not authori:ed.

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CALLAWAY - UNIT 1 6-2

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's i ' MINIMUM SHIFT CREW COMPOSITION SINGLE UNIT FACILITY POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION MODES 1, 2, 3 & 4 MODES 5 & 6 !

- t SS 1 1* [

SRO 1 None !

R0 2 1 l EO 2 1 :

STA 1** None SS -

Shift Supervisor with a Senior Operator license on Unit 1 SRO -

Individual with a Senior Operator license on Unit 1 R0 -

Individual with an Operator license on Unit 1 EO -

Equipment Operator STA -

Shift Technical Advisor Except for the Shift Supervisor, the Shift Crew Composition may be one less than the minimum requirements of Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift r crew members provided immediate action is taken to restore the Shift Crew

's~ Composition to within the minimum requirements of Table 6.2-1. This provision does not permit any shift crew position to be unmanned-upon shift change due to an oncoming shift crewman being late or absent.

Curing any absence of the Shift Supervisor from the control room while the unit is in MODE 1, 2, 3 or 4, an individual (other than the Shift Technical Advisor) with a valid Senior Operator license shall be designated to assume the control room command function. During any absence of the Shift Supervisor from the control room while the unit is in MODE S or 6, an individual with a valid Senior Operator or Operator license shall be designated to assume the control room command function. ,

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One SRO, either Shift Supervisor or Operating Supervisor sw The STA position may be eliminated when an SR0 on shift meets the NRC educational requirements for an STA and the Control Room design has been upgraded to NRC requirements for eliminating the STA position.

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! CALLAWAY - UNIT 1 6-5

t ADMINISTRATIVE CONTROLS .

O 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.'1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other. sources of, plant design and operating experience information, including plants of .

similar design, which may indicate areas for improving plant safety.

t COMPOSITION 6.2.3.2 The'ISEG shall be composed of at least five, dedicated, full-time .;

engineers located on site. Each shall have a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field. t RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

that these activities are

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. performed correctly and that human errors are reduced as much as practical.

AUTHORITY Ca 6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of improving plant safety to the Manager, Nuclear Safety and Emergency Preparedness and the Manager, Callaway Plant.

RECORDS 6.2.3.5 Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to the Manager, Nuclear Safety.

and Emergency Preparedness and the Manager, Callaway Plant.

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6.2.4 SHIFT TECHNICAL ADVISOR TheShiftTechnicalAdvisorNhallprovidetechnicalsupporttotheShift Supervisor in the areas of thermal hydraulics, reactor engineering and plant

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analysis with regard to the safe operation of the unit.

i t 6.3 UNIT STAFF QUALIFICATIONS l

6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978, except for the '-di:ti r 9:::::::- Supt. Health l

Physics Nr.zer who shall meet or exceed the qualifications of Regulatory Guide 1.8, l L , t e...., o Z7;. proposed Rev. 2, 2-79 "Not responsible for sign-off function.

- The STA position may be eliminated when an SRO on shif t meets the NRC educational requirements fcer an STA cad the Control Room design has been upgraded to NRC requirements for' eliminating the STA position.

CALLAWAY - UNIT 1 6-6

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ADMINISTRATIVE CONTROLS

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(. 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Superintendent of Training and shall meet or exceed the requirements and recommendations of Section 5 of ANSI /

ANS 3.1-1978 and Appendix "A" of 10 CFR Part 55'and the supplemental require-ments specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall' include familiarization with relevant -

industry operational experience identified by the ISEG.

6.5 REVIEW AND AUDIT 6.5.1 ON-SITE REVIEW CCMMITTEE (ORC)

FUNCTION 6.5.1.1 The On-Site Review Committee shall function to advise the Manager, Callaway Plant on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The On-Site Review Committee shall be composed of the:

(~j Chairman: Manager, Callaway Plant Member: Asst Mgr, Oper and Maintenance Member: Asst Mgr, Tech Services Member: Asst Mgr, Support Services Member: D.pv, 3:dicti:r 'rctcCti0n Supt., Health Physics Member: Supv Eng, Quality Assurance i

Member: Adv to Mgr, Callaway Plant l ALTERNATES l

6.5.1.3 All alternate members shall be Chairman to serve on a-temporary basiri# appointed hewever in writing no more by the than two ORC alternates shall participate as voting members in CRC activities at any one time.

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Pcsition to be abolished when previsions of ACRS letter dated November 17,

l 1981 are met.

- Except for the alternate for the Supervising Engineer, Quality Assurance (Operations) who is appointed by the }bnager, Quality Assurance. .

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CALLAWAY - UNIT 1 6-7 l

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ADMINISTRATIVE CONTROLS h MEETING FREOUENCY 6.5.1.4 The ORC shall meet at least once per calendar month and as convened '

by the ORC Chairman or his designated alternate.

QUORUM 6.5.1.5 The minimum quorum of the ORC necessary for the performance of the ORC responsibility-and authority provisions of these Technical Specifications - ..

shall consist of the Chairman or his designated alternate and four members including alternates.

hiSPONSIBILITIES INSERT - 1 6.5.

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The On-Site Review Committee shall be responsible for:

a. eview of: (1) all procedures required by Specification 6.8 a c nges thereto, (2) all programs required by Specifi?ation 6 and cha es thereto, and (3) any other proposed procedures or e anges there as determined by the Manager, Callaway Plant to.a#4ect nuclear s safety;

b. Review of a 1 proposed changes, tests ~ and experimen which may involve an un viewed safety question as defined

Section 50.59, +

... 10 CFR;

c. Review of all propc ed changes to Technical pecifications or the

. Operating License;

d. Review of all safety eva ations perfo .ed under the provision of Section 50.59(a)(1), 10 CF for cha es, tests and experiments;

e. Investigation of all violations the Technical Specifications including the preparation and # rding of reports covering evaluation and recommendatior to p event recurrence to the Vice President-Nuclear and to t Nuclear afety Review Board; ,

f. Review of events requir' g 24-hour writte notification to the Commission;

g. Review of reports f operating abnormalities, e<viations from expected perforr nce of plant equipment and of uhanticipated deficiencies

the design or operation of structu s, systems or components '.at affect nuclear safety;

h. Perform ce of special reviews, investigations or analys and reports thereo as requestad by the Chairman, Nuclear Safety Revies. Board; i.

Rei ew of the plant Security Plan and implementing procedures agd

. all submit recommended changes to the Nuclear Safety Review Ecc d; E j Review of the Emergency Plan and implementing procedures and shall .. .

submit recommended changes to th'e Nuclear Safety Review Board; i CALLAWAY - UNIT 1 6-8

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INSERT - 1 RESPONSIBILITIES 6.5.1.6 The On-Site Review Committee shall be responsible for reviews of:

a. All Administrative Procedures.

b. The safety evaluations for (1) procedures, (2) change to '

procedures, equipment, systems or facilities, and (3) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question.

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c. Proposed procedures and changes to procedures, equipment, systems I or facilities which may involve an unreviewed safety question as

. defined in 10 CFR 50.59 or^ involves a change in Technical-Specifications.

d. Proposed test or experiments which may involve an unreviewed safety question as defined in 10 CFR 50.59 or requires a change in Technical Specifications.

e. Proposed changes to Technical Specifications or the Operating License.

f. Investigation of all violations of the Technical Specifications including the forwarding.of reports covering evaluation and recommendations to prevent recurrence to the Vice President-Nuclear and to the Nuclear Safety Review Board.

g. Reports of operating abnormalities,-deviations from expected performanch of plant equipment and of unanticipated deficiencies in the design or operation of structures, systems or components that affect nuclear safety.

h. All written reports to the Commission, concerning events which require 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification to the Commission.

1. The plant Security Plan and shall submit recommended changes to l the NSRB. ,

j. The Radiological Emergency Response Plan and shall submit recommended I changes to the NSRB.

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k. Investigations or analysis of special subjects 49e requested by the Chairman of the Nuclear Safety Review Board.

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1. Changes to the PROCESS CONTROL PROGRAM, and the OFFSITE DOSE i CALCULATION MANUAL.

l m. Any accidental, unplanned or uncontrolled radioactive release including the preparation or reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Panager, Callaway Plant and to the Nuclear Safety Review Board.

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ADMINISTRATIVE CONTROLS p,

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Review of changes to the PROCESS CONTROL PROGRAM, and the OF '.

^LCULATION MANUAL; and

1. Review of any acc ental, unplanne ncontrolled radioactive release including the pre ""i n of reports covering evaluation, recommendations a osition o W corrective action to prevent recurrenc he forwarding of these re r ' to the Manager, y Plant and to the Nuclear Safety Review ~ d ASQ40 PITY INSERT - 2

6. 5.1. 7 .

On-Site Review Committee shall:

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a. Recommen #

writing to the Manager, Callaway Plant approval disapproval 'tems considered under Specifications 6. . 6a.

through d., above, ,

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b. Render determinations in w ing witjh ra,. d to whether or not each

._ item considered under Specifica o s o.5.1.6a. through e. above, i

constitutes an unreviewed sa 4 qu ' ion; and

c. Provide written no. cation within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ' the Vice President-Nuclear and ' .eclear Safety Review Soard of . areement between the ORC ~ the Manager, Callaway Plant; however, tn- = nager,

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Ca . way Plant shall have responsibility for resolution o' ubh isagreements pursuant to Specification 6.1.1 above.

. RECORDS N 6.5.1.8 The On-Site Review Committee shall maintain written minutes of each ORC meeting that, at a minimum, document the results of all ORC activities ]

performed under the responsibility and author:ty provisions of these Technical Specifications. Copies shall be provided to the Vice President-Nuclear and the Nuclear Safety Review Board. i l

6.5.2 NUCLEAR SAFETY REVIEW E0ARD (NSRB) -

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FUNCTION 6.5.2.1 The Nuclear Safety Review Board shall function to provide independent l l review and audit of designated activities in the areas of* '

a. Nuclear power plant operations,

b. Nuclear engineering, l c. Chemistry and radiochemistry,

d. Metallurgy, ,

._ e. Instrumentation and control,

f. Radiological safety, I CALLAWAY - UNIT 1 6-9 i i

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AUTHORITY l

6.5.1.7 The on-Site Review Committee shall: -

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a. Recommend in writing to the Manager, Callaway Plant',' approval '

or disapproval of items considered under 6.5.1.6(a) through ~

(e), (i), (j), (1), and (m) above.

b. Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a), (c), and (d) ,

above constitutes an unreviewed safety question.

c. Make recommendations to the Manager, Callaway Plant in writing that actions reviewed under 6.5.1.6 (b) above did not constitute an unreviewed safety question.

d. Provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Vice President-Nuclear and the NSRB of disagreement between the ORC and the Manager, Callaway Plant; however the Manager.-Callaway Plant shall have responsibility for resolution of such disagreements ,

pursuant to 6.1.1 above.

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ADMINISTRATIVE CONTROLS -

g. Mechanical and electrical engineering, and l

! h. Qualityassurancepractices$ N COMPOSITION

-6.5.2.2 The NSRB shall be composed of 4he: at'least the following members:

4 Chairman: General Manager, Engineering (Nuclear) i Member 'tice Chair;;n. Manager, Nuclear Engineering -

l Member: Manager, b e'i:, A;;ure..;; Nuclear Safety and Emergency

! Member -+hmt Manager, calla. ay Plant Member: -SNUPPS Technical Director . Preparedness.\

Member: Tuel Engineer Supervising Engineer, Nuclear Fuels '

l Additional members and Vice Chairman may be appointed by the Chairman j ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the NSRB i Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in NSRB activities at any one time.

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%. CONSULTANTS .

' 6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

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. MEETING FREQUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel' loading and at least once per 6 months thereafter. -

QUORUM 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the

. NSRB review and audit functions of these Technical Specifications shalP 2/3 of the consist of the Chairman or his designated alternate and at' least door 1 SRB members including alternates. No more than a minority of the quorum shall ]

! have line responsibility-for operation of-the unit. For the purpose of a j

quorum, those considered to have line responsibility will include the Manager, ,

Callaway Plant, and personnel reporting to the Manager, Callaway Plant, !

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CALLAWAY - UNIT 1 6-10

ADMINISTRATIVE CONTROLS REVIEW }

6.5.2.7 The NSRB shall review: .

a. The safety evaluations for: (1) changes to procedures, equipment, i systems or facilities; and (2) tests or experiments completed under ;

, the provision of Section 50.59, 10 CFR, to verify that such actions l did not constitute an unreviewed safety question, ;

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b. Proposed changes to procedures, equipment, systems or facilities '

which involve an unreviewed safety question as defined in Section 50.59, 10 CFR; Proposed tests or experiments which involve an unreviewed safety

c. .

question as defined in Section 50.59, 10 CFR; -

the

d. Proposed changes to Technical Specifications or 4+ri-t-Operating License;

e. Violations of h des, regulations, orders, Technical Specifications, k license requirements, or of internal, procedures or instructions

-he.in; nu;1;;r ;;f;ty ;i;:

fic;n::; which are reportable under sections 6.9.1.10 and 6.9.1.11.

f' f. G jnificant operating abnormalities or deviations from normal and '

(, expected performance of unit equipment that affect nuclear safety; All written reports to the Commission, concerning events which required

g. 5 :nt; r;';uiri,; ^*-h;ur aritten n;tificati;n t; th; ~;a;i;;ien, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification to the Commission.

h. All recognized indications of an unanticipated deficiency in some 1 aspectofdesignofoperationofstructures, systems,orcomponents '

that could affect nuclear safety; and

i. Reports and meetings minutes of the On-Site Review Committee.

l AUDITS

6.5.2.8 Audits of unit activities shall be performed under the cogni:ance of the NSRB. These audits shall encompass:

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

b. The performance, training and cualifications of the entire unit staff at least once per 12 months;

c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at least once per 5 months;

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CALLAWAY - UNIT 1 6-11

I ADMINISTRATIVE CONTROLS f

O.. d. The performance of activities required by the Operational Quality 1

Assurance Program to meet the criteria of Appendix "B",10 CFR 50,

. at least_once per 24 months; f,, Any other area of unit operation considered appropriate by the NSRB-L ortheVicePresident-Nuclear @ K

/t. The Fire Protection programmatic controls including the implementing-procedures at least once per 24 months by qualified licensee QA personnel;

4. The fire protection equipment and program implementation at least-

~D once per 12 months utili:ing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year; '

The [adiological [nvironmentalAfanitoring hrogram and the results

)fg thereof at least once per 12 months; 4 '

fl.. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months; i fl. The PROCESS CONTROL PROGRAM and implementing procedures for processing 5 and packaging of radioactive wastes at least once per 24 months; asip

/) V The performance of. activities required by the Quality Assurance

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( ee ggrag:

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, the provisions : 1of4.1, Regulatory Ac...>...Guide 1, 'g _r' _' 107

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once per 12 monthsj M AUTHORITY t

6.5.2.9 The NSRB shall report to and advise the Vice President-Nuclear on those areas of responsibility stated in Specifications 6.5.2.7 and 6.5.2.8.

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RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed as indicated below:

a. Minutes of each NSRS meeting shall be prepared, :pprc::' and forwarded to the Vice President-Nuclear within 14 days following each meeting; The minutes shall be approved at a subseq.uent.meeti.nt.

b. Reports of reviews encompassed by Specification 6.s.7.7 above, .shall be prepared, approved ano forwarded to the Vice President-Nuclear within 14 days following completion of the review; and

c. Audit reports encompassed by Specification 6.5.2.8 above, shall be forwarded to the "':: 4 :fd:-t " r'ae e-d ' t?.c management esitions responsible for the areas audited)within 30 days after completion of tne auct; by the auciting organization.

and summarier vf audits shall be prepared and forwarded to the

[ Vice President Nuclear. ;

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CAlt.AWAY - UNIT 1 6-12

ADMINISTRATIVE CONTROLS h -

6. 5. 3 TECHNICAL REVIEW AND CCNTROL ACTIVITIES 6.5.3.1 Activities which affect nuclear safety shall be conducted as follows:

- a. Procedures required by Specification 6.8 and other procedures which .

affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved.' Each such procedure or procedure change shallbereviewedbyanindividual(group)otherthanthequalified individual (group)whichpreparedtheprocedureorprocedurechange butwhomaybefromthesameorganizationastheindividual(group) which prepared the procedure or procedure change. Procedures other than Administrative Procedures shall be approved by the appropriate Department Head as designated in writing by the Manager, Callaway Plant. The Manager, Callaway Plant shall approve Administotive yRadiological

' 7 Procedures, Security Plan implementing procedures and':: r;;ncy AP an Emergency implementing procedures. Temporary changes to procedures which do L Response not change the intent of the approved procedures shall be approve for ~

by two members of the pla innlementation.

Senior Operator license *e"gt staf f, at least documented, T ': one

d byofCC,whom

ndholds a ppre.ed by tF: "=c;;r, C:11 w y Pl:nt with'r l' dej: cf ',p' = =t:ti:n.

For changes to procedures which may involve a change in intent of the approved, procedures, the persen authorized above to approve the t

(- procedure shall approve the change prior to implementatioh;

b. Proposed changes or modifications to plant nuclear safety-related structures, systems and components shall be reviewed as designated by the Manager, Callaway Plant. Each such modification shall be reviewedbyanindividual[ group)otherthanthequalifiedindividual/

(group)which designed the ihodification, but who may be from the same organizationastheindividual(group)whichdesignedthemodifica-tions. Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved prior to implementation by the Manager, Callaway Plant; '

Proposed tests and experiments which affect plant nuclear safety and I ,

c.

I are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Each such test or experiment shall be reviewed by an individual [ group)other thanthequalifiedindividual[ group)wnichpreparedtheproposedtest or experiment. Proposed test and experiments shall be approved before implementation by the Manager, Callaway Plant; These temporary changes are subsequently approved by the original approval authority.

.a CALLAWAY - UNIT 1 6-13

i ADMINISTRATIVE CONTROLS

~

d. Individuals responsible for reviews performed in accordance with Specifications 6.5.3.la, 6.5.3.lb,t .5.3.1c.6 ,and C.:.2.'.J shall be- .

members of the plant management staf f previously designated by the '

Manager, Callaway Plant. Each such review shall include a deter- [

mination of whether or not additional, cross-disciplinary, review is t necessary. If deemed necessary, such review shall be performed by qualified personnel of the appropriate discipline;

e. Each review shall include a determination of whether or not an unreviewed safety question is involved. Pursuant to Section 50.59, 10 CFR, NRC approval of items involving unreviewed safety question shall be obtained prior to Manager, Callaway Plant approval for .

implementation; I

f. '

t Security Plan.and Emergency Plan, and imolema '--

procedures, s a.. .- 4ewed at i months. Recom-

" . .pproTiif3sl* c c; ger Callaway Plant, and W nacer, mended changes sh= ,

+

_-1..'. o the Vice President-Nuclear an .. . '7-

~

Changes to the PROCESS CONTROL PROGRAM, OFFSITE DOSE CALCULATION

,! and radioactive waste treatment systems shall be re # by >

a quali ' individual / group and approved by the M -

r, Callaway i Plant; and

.I h. Every unplanned onsite relea radioactive material to the

envirnns including th . aration a. # rwarding of reports covering evaluation, re ... ncations and disposition he corrective action to prev - ecurrence to the Vice President-Nuclea -

to the NSRB be reviewed by a qualified individual / group.

RECORDS l

l 6.5.3.2 Records of the above activities shall be pro"ided to the Manager, Callaway Plant, ORC and/or NSR8 as necessary for required reviews.

. I

f. The Plant Security Plan and Radiological Emergency Response Plan and ,,

implementing procedures, shall be reviewed at least once per 12 months.

r Recommended changes to the implementing procedures shall be approved l by the Manager, Callaway Plant. Recommended changes to the Plans shall be reviewed pursuant to the requirements of sections 6.5.1.6 ,

and 6.5.2.7 and approved by the Manager, Callaway Plant. NRC approval I l shall be obtained as appropriate.

l i

v.

CALLAWAY - UNIT 1 6-14 l I

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^

ADMINISTRATIVE CONTROLS

. w 6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for REPORTABLE OCCURRENCES:

a. The Commission shall be notified and/or a report submitted pursuant to the requirements of Specification 6.9, and .

b. Each REPORTABLE OCCURRENCE requiring 24-hour notification to,the Commission shall be reviewed by the ORC and submitted to the NSRB and the Vice President-Nuclear.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Vice President-Nuclear and the NSRB shall be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ;

b. A Safety _ Limit Violation Report shall be prepared. The report shall be reviewed by the ORC. This report shall describe: (.1) applicable .

.. circumstances preceding the violation; (2) effects of the violation 1 upon facility components, systems or structures; and (3) corrective

'.. action taken to prevent recurrence;

c. The Safety Limit Violation Report shall be submitted to the Commission, the NSRB and the Vice President-Nuclear within 14 days of the violation; and

d. Critical operation of the unit shall not be resumed until authorized by the Commission.

! 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained

!- covering the activities referenced below: t

a. The applicable procedures recommended in Appendix "A", of Regulatory Guide 1.33, Revision 2, February 1978,

b. Refueling operations,

c. Surveillance and test activities of safety-related equipment,

! d. Security Plan implementation, ,

Radiological Emergency Response

e. C;crgc.;j Plan implementation, f

l k'.

CALLAWAY - UNIT 1 6-15 t

i

i s.

ADMINISTRATIVE CONTROLS bs. . -

f. Fire Protection Program implementation,

g. PROCESS CONTROL PROGRAM implementation,

h. OFFSITE DOSE CALCULATION MANUAL implementation, and

. i. M#

using the guidance cs Program for effluent in Reguletory Guide and ':;:'_,

environmental h"':'r ', :..wmonitoring,V,

t 'N"

=d .% . a w. ,, : _ i d ; 4. ;, i.e . . L. 1, 'g " ::7 &@ / 9 7 7.

t 6.8.2 Each procedure and administrative policy'of Specification 6.8.1 above, and changes thereto, including temporary changes shall be reviewed prior to

~

implementation as set forth in Specification 6.5 above. -

6.8.3 The plant Administrative Procedures and changes thereto shall be reviewed in accordance with Specification 6.5.1.6 and approved in accordance with~

Specification 6.5.3.1. The associated implementing procedures and changes thereto shall be reviewed and approved in accordance with Specification 6.5.3.1.

6.8.4 The following programs shall be established, implemented, and maintained: j

a. Primary Coolant Sources Outside Containment

,.. A program to reduce leakage from those portions of systems outside h

[ containment that could contain highly radioactive fluids during a s .. serious transient or accident to as low as practical levels. The systems include the recirculation portion of: the Containment $ pray, System k f;ty Inj;;ti;n, ;heri;si sad ,; h::.e c ..t. I,'oA;T: CAS d: LOU? i SYSTCi, ad hydr;;;cn re;;.-tiner3. The program shall include the ;

following:

1) Preventive maintenance and periodic visual inspection requirements, and .

2) Integrated leak test requirements for each system at refueling cycle intervals or less. - f

b. In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shal' include the following:

1) Training of personnel,

2) Procedures for monitoring, and

3) Provisions for maintenance of sampling and analysis equipment. .

the Safety Injection System, the Residual Heat Removal System, s and the Chemical and Volume Control System.

i i

CALLAWAY - UNIT 1 6-16

., .. . ,s -

ADMINISTRATIVE CONTROLS

~

c. Secondary Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shall include:

1) Identification of a sampling schedule for the critical variables and control points for these variables,

2) Identification of the procedures used to measure the values of '

the critical variables, -

3) Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage,

4) Procedures for the recording and management of data,

5) Procedures defining corrective action for all off-control point chemistry conditions, and l

6) A procedure identifying: (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action.

(, d. Post-accident Samoling A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident-conditions. The program shall inclade the following:

l

1) Training of personnel,

2) Procedures for samp1.ing and analysis, and

3) Provisions for maintenance of sampling and analysis equipment. .

I l

, CALLAWAY - UNIT 1 6-17

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' ADMINISTRATIVE CONTROLS f-

6.9 REPORTING REOUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES l

6.9.1 In addition to the applicable reporting requirements of Title 10, Code I of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the NRC Regional Office unless otherwise noted.

STARTUP REPORT 6.9.1.1 A' summary. report of plant STARTUP.and power escalation testing shal.1 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 aidifferent fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. n 6.9.1.2 The STARTUP /eport shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operat~ing (

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 required in license conditions based on other commitments shall be included in this report. .

)

6.9.1.3 STARTUP ports shall be submitted within: (1) 90 days following .K -

. completion of the :ARTUP test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest.- IftheSTARTUPAeportdoesnotcoverall X

\. three~ events (i.e., initial criticality, completion of STARTUP test program, and ;

resumption or commencement of commercial operation) supplementary reports shall be submitted at least every 3 months until all three events have been completed. ,

ANNUAL REPORTS 1 6.9.1.4 Annualftportscoveringtheactivitiesoftheun'itas'describedbelow -.X for the previous calendar year shall be submitted prier 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 on an annual basis 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,2 e.g., reactor operations and 1

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% of the individual total dose need-not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external sources should be assigned to specific major work functions.

I g b. C;cumcr.tati:r ;f 11' ch: ::r.;;; t; the pre;;;ri;er pc,ar c;scnad ,

, y r:li f c:'<:: W J/:' cc.d :afec., .2:.es. j dinis taculation supplements the requirements of s20.407 of.10 CFR Part 20. !

CALLAWAY - UNIT 1 6-18 g..

Ri~__

ADMINISTRATIVE CONTROLS

('h s.. 1 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT * -

[

6.9.1.6 Routine Radiological Environmental Operating Reports covering the L i

operation of the unit during the previous calendar year shall be submitted prior '

to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following initial criticality.

The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, ipcluding a compar-ison with preoperational studies, with operational controls as appropriate, and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of land use censuses required by Specification 3.12.2.

The Annual Radiological Environmental Operating Reports shall include the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursue.nt to the locations speci-fied in the Table and Figures in the ODCM, as well as summarized aid tabulated (

results of these analyses and measurements in the format of the ta. ole in the f Radiological Assessment Branch Technical Position, Revision 1, November 1979. (

In the event that some individual results are not available for inclusion with 6s the report, the report shall be submitted noting and explaining the reasons for

~

the missing results. The missing data shall be submitted as soon as possible ,

in a supplementary report. ;

The reports shall also include the following: a summary description of the j radiological environmental monitoring program; at least two legible maps ** -

covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of licensee participation in f the Interlaboratory Comparison Program, required by Specification 3.12.3; discussion of all deviations from the sampling schedule of Table 3.12-1; and discussion of all analyses in which the LLD required by Table 4.12-1 was not achievable.

)

}

"A single submittal may be made for a multiple unit station.

- 0ne map shall cover stations near the site boundary; a second shall include the more distant stations. .

f '

(. .

CALLAWAY - UNIT 1 6-19

.h. , _ ._.

p

(

ADMINISTRATIVE CONTROLS SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT

6.9.1.7 Routine Radioactive Effluent Release Reports covering the operation -

of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year. .The period of the first report shall begin with the date of initial criticality.

The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released 7 from the unit as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases:of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report to be submitted within 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the '

form of joint frequency distributions of wind speed, wind direction, and )

atmospheric stability." This sat.e report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This same report

', shall also include an assessment of the radiation _ doses from radioactive-

. C,,./ liquid and gaseous effluents to MEMSERS OF THE:PUBLIC due to their activities e inside the SITE BOUNDARY (Figures-5.1-3 and 5.1-4) during the report period.

All assumptions used in making these assessments, i.e. , specific activity, exposure time and location, shall be included in these reports. The~meteoro- ,

logical conditions cencurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses. The assessment of

. radiation doses shall be perfcrmed in.accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

The Radioactive Effluent Release Report to be submitted 60 days after January 1 -

of each year shall also include an assessment of radiation doses to the likely

(. most exposed MEMBER OF THE PUBLIC from Reactor releases and other nearby uranium l fuel cycle sources, including doses from primary effluent pathways and direct

(~ radiation, for the previous calendar year to show conformance with 40 CFR

( Part 190, " Environmental Radiation Protection Standards for Nuclear Power

( *A single submittal may be made for a multiple unit station. The submittal should combine tnose sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify

, the releases of radioactive material from each unit.

l- **In lieu of submission with the first half year Radioactive Effluent Release ,

(. Report, the licensee has the option of retaining this summary of requirec !

l - /~ meteorological data on site in a file that shall be provided to the NRC

' Q upon request. .

CALLAWAY - UNIT 1 6-20

ADMINISTRATIVE CONTROLS O

Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev.1, L October 1977.

The Radioactive Effluent Release Reports shall include the following information for each class of solid waste (as defined by 10 CFR Part 61) shipped offsite during the report period: ~

j

a. Container volume,

b. Total Curie quantity (specify whether determined by measurement or estimate),

c. Principal radionuclides (specify whether determined by measurement or estimate),

d. Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms),

e. Type of container (e.g., LSA, Type A, Type B. Large Quantity), and '

f. Solidification agent or absorbent (e.g. , cement, urea formaldehyde).

, The Radioactive Effluent Release Reports shall include a list and description

(--~

of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

. The Radioactive Effluent Release Reports shal'1 include any changes made during-4 the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE 3

OOSE CALCULATION MANUAL (00CM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land use census pursuant to Specification 3.12.2.

MONTHLY OPERATING REPORT Pressurizer Reactor Coolant System 6.9.1.8 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or safety valves, shall be submitted on a monthly basis to the Director, Office of Resource Management }

U.S. Nuclear Regulatory Ccemission, Washington, D.C. 20555, with a copy to the -

NRC Regional Office, no later than the 15th of each month following the calendar month covered by the report.

J REPORTABLE OCCURRENCES

~

6.9.1.9 The REPCRTABLE OCCURRENCES of Specifications 5.9.1.10 and 6.9.1.11 below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC. Supplemental reports may be required to fully cescribe

- final resolution of occurrence. In case of corrected or supplemental reports, a licensee event report shall be completed and reference shall be made to the

{ '> original report date.

CALLAWAY - UNIT 1 6-21

1 ADMINISTRATIVE ~ CONTROLS I O -

PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP )

6.9.1.10 The types of events listed below shall be reported within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Regional Administrator of the NRC Regional Office, or his designate, no later than the first working day following the event, with a written followup report within 14 days. The written followup report shall include, as a minimum, i a completed copy of a Licensee Event Report form. Information provided on the q Licensee Event Report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances l surrounding the event. '

a. Failure of the Reactor Trip System or other systems subject to

~ Limiting Safety System Settings to initiate the required protective i function by the time a monitored parameter reaches the Setpoint I specified as the Limiting Safety System Setting in the Technical q Specifications or failure to complete the required trip function; '

b. Operation of the unit or affected systems when any parameter or i operation subject to a Limiting Condition for Operation is less conservative than the least conservative aspect of the Limiting Condition for Operation establi'shed in the Technical Specifications; r' , c. Abnormal degradation' discovered in fuel cladding, reactor coolant i C pressure boundary, or primary containment;

d. Reactivity anomalies involving disagreement with the predicted value of reactivity balance under steady-state conditions during power operation greater than or equal to 1% ak/k; a calculated reactivity balance indicating a SHUTDOWN MARGIN less conservative than specified in the Technical Specifications; short-term reactivity increases that correspond to a reactor period of less than 5 seconds or, if subcritical, an unplanned reactivity insertion of more than 0.5%

ak/k; or occurrence of any unplanned criticality;

e. Failure or malfunction of one or more components which prevents or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the SAR;

f. Personnel error or procedural inadequacy which prevents or could pre' vent, by itself, the fulfillment of the functional-requirements of systems required to cope wth accidents analyzed in the SAR;

g. Conditions arising from natural or man-made events that, as a direct result of the event require unit shutdown, operation of safety systems, or other protective measures required by Technical '

Specifications; ,

b CALLAWAY - UNIT 1 6-22 i

ADMINISTRATIVE CONTROLS O

's

h. Errors discovered in the transient or accident analyses or in the methods.used for such analyses as described in the Safety Analysis Report or in the bases for the Technical Specifications that have or could have permitted reactor operation in a manner less conservative l than assumed in the analyses;

, i. Performance of structures, systems, or components that requires 'l remedial action or corrective measures to prevent operation in a '

manner less conservative than assumed in the accident analyses in l the Safety Analysis Report or Technical Specifications bases; or t discovery during unit life of conditions not specifically considered in the Safety Analysis Report or Technical Specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition; and J. Tai'ure ;f the pressuri cr PCRV:.;r s:fcty ;;hc:.

, THIRTY DAY WRITTEN REPORTS 6.9.1.11 The types of events listed below shall be the subject of written reports to the Regional Administrator of the NRC Regional Office within 30 days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a Licensee Event Report Form. Information

\.. provided on the Licensee Event Report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.

a. Reactor Trip System or Engineered Safety Feature Instrumentation Setpoints which are found to be less conservative than those estab-lished by the Technical Specifications but which oo not prevent the fulfillment of the functional requirements of affected systems; l b. Conditions leading to operation in a degraded MODE permitted by a .

! Limiting Condition for Operation or plant shutdown required by a l

l Limiting Condition for Operationg l c. Observe inadequacies in the implementation of Administrative or l Procedural Controls which threaten to cause reduction of degree of redundancy provided in Reactor Trip Systems or Engineered Safety i Feature Systems; and l d. Abnormal degradation of systems, other than those specified in Specification 6.9.1.11c above, designed to contain radioactive material resulting from the fission process. i M A thirty day written report need not be submitted when !

i

, j LT%d equipment is removed from service, for reasons other than failure, to enter alternate or degraded modes of operation

(" consistent with the provisions of a Technical Specification.

CALLAWAY - UNIT 1 6-23

1 f.

s_e

- i 9

e. An unplanned offsite release of: ~~ l (1) core than 1 Curie o'f ra'dioactive l material in liquid ef fluents, (2) more than 150 Curies o gaseous ef fluents.

The report of an unplanned offsite release of radioactive material shall include the following information: '

1)

. A description.of the event and equipment involved,

2) Cause(s) for the unplanned release,

3) Actions taken.to prevent recurrence, and '

4) Consequences of the unplanned release. -

~

4

(:- ~ f.

Measured levels of radioactivity in an environmental sampling medium i

determined to exceed the reporting level values of Table 3.12-2 when

__ averaged over any calendar quarter sampling period.

l l

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d .73 u

. . .j 4

e.

ADMINISTRATIVE CONTROLS .

O RADIAL PEAKING FACTOR LIMIT REPORT i

- 6.9.1.12 The F xy limit for RATED THERMAL POWER (F,RTP) shall be provided.to the Regional' Administrator of the NRC Regional Office with a copy to the Director, Nuclear Reactor Regulation, Attention: Chief of the Core Performance Branch, U.S. Nuclear Regulatory Commission, Washington,-D.C., 20555, for all' core planes containing Bank _"D" control rods and all unrodded core planes at -

least 60 days prior to cycle' initial criticality. In the event that the limit would be submitted at some other time during core life, it shall be submitted 60 days prior to'the date the limit would become effective unless otherwise exempted by the Commission.

Any information needed to support F xRTP will be by request from the NRC and need not be included in this report.

SPECIAL REPORTS 6.9.2 Special Reports shall be submitted to the Regional Administrator of the NRC Regional Office within the time period specified for each report.' j 6.10 RECORD RETENTION

[/.' In addition to the applicable record retention requirements of Title 10', Code of Federal Regulations, the following records shall be retained for at least' the minimum period indicated.

6.10.1 The following records shall be retained for at least 5 years:

a.' Records and logs of unit operation covering time interval at each power level;

b. Records and logs of principal maintenance activities, inspections,

repair and replacement of principal items of equipment related to nuclear safety;

c. All REPORTABLE OCCURRENCES submitted to the Commission;

d. Records of surveillance activities; inspections and calibrations required by these Technical Specifications; i

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

f. Records of radioactive shipments.

g. Records of sealed source and fission detector leak tests and results; -

and

. - h. Records of annual physical inventory of all sealed source material of record.

CALLAWAY - UNIT 1 6-24 ,

..,' . . . .. - , . L. : .. .

. i ADMINISTRATIVE CONTROLS-6.10.2 The following records shall be retained for the duration of the Unit Operating License:

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

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

)

c. Records of radiation exposure for all individuals entering radiation control areas;

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

e. Records of transient or operational cycles for those unit components identified in Table 5.7-1;

f. Records of reactor tests and experiments;

g. Records of training and qualification for current members of the

g. unit staff; V h. Records of in-service inspections performed pursuant to these- 4 Technical Specifications;

,i . i!=;rd: :f ;u .lity A=;r=x ccti.itic: r: quired by th: OA M=u:1;

/

f 1. f. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to

' 10 CFR 50.59;

/

j . jf. Records of meetings of the ORC and the NSRB; I

k . [. Records of the service lives of all snubbers listed in Tables 3.7-4a I

) and 3.7-4b including the date at which the service life commences g

and associated installation and maintenance records;

1. p(. Records of secondary water sampling and water quality; and

}

g m. pf. Records of analysis required by the radiological environmental monitoring program that would permit evaluation of the accuracy of

,\ the analysis at a later date. This should include procedures

s effective at specified times and QA records showing that these procedures were followed.

M 6.10.3 Records of Quality Assurance activities vill be retained as identified by the

<. 6.11 RADIATION PROTECTION PROGRAM 'Q.A. Program. ,

U Procedures for personnel radiation protect'on shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and edhered to for all operations involving personnel radiation exposure.

CALLAWAY - UNIT 1 6-25

9 j s ,

i

. s ADMINISTRATIVE CONTROLS i s i 6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area in which the.

intensity of radiation is greater than 100 mrem /hr but less'than 1000 mrem /hr shall be barricaded and conspicuously posted as a.high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation work Permi t :(RWP)*. Any individual or group of individuals permitted to enter such areas shal1 be provided with or accompanied by one or more of the following: ,

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

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated

. dose is received. Entry into such areas with this monitoring device d may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them; and

c. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is respgnsible for providing positive control over the activities

-within the area and shall perform periodic radiation surveillance at the frequency specified by -the facility M ith "hy;ici:t in the RWP.

health physics management personnel 6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels ~such that a major pertion of the body could receive in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months a_ dose greater than 1000 mrem shall be provided with locked doors to prevent unauthorized entry, and the keys shall be a shift Supervisor /

maintained under the administrative control of the Shift ~;.e. e.fon duty operating .l and/or health physics supervision. Doors shall remain locked except during supervisor periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area. For individual areas accessible to personnel with radiation levels such that a major po'rtion of the body could receive in I hour a dose in excess of 1000 mrems** that are located within ,

large areas, such as PWR containment, where no enclosure exists for purposes l of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be roped off, conspicuously posted and a flashing light shall be activated as a warning-device. In lieu of the stay time specification of the RWP, direct or remote (such as use of closed circuit TV cameras) continuous surveillance may be made by personnel 1 qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

A Health physics qualified personnel or personnel escorted by health physics -

qualified personnel shall be exempt from the RWP issuance requirement during

.the performance of their assigned radiation protection duties, provided

] they are otherwise following plant radiation protection procedures for

-b- entry into high radiation areas.

an Measurement made at 18" from source of radioactivity, j CALLAWAY - UNIT 1 6-26 i.

e A

ADMINISTRATIVE CONTROLS -

f %.

5 6.13 PROCESS CONTROL FROGRAM (PCP) l 6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Licensee initiated changes to the PCP:

a. Shall be submitted to the Commission in the Semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contcin:

1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information;

2) A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and

3) Documentation of the fact that the change has been reviewed and found acceptable by the ORC.

approval in accordance with Specifications

b. Sha'll become effective upon review and a,.c6tance b 16 CRC. 6.5.1.6 and 6.5.3.1.

,. 6.14 0FFSITE 00SE CALCULATION MANUAL (00CM) .

6.14.1 The ODCM shall be approved by the Commission prior to implementation.

I 6.14.2 Licensee initiated changes to the ODCH:

a. Shall be submitted to the Commission in the Semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made effective. This submittal shall contain:

1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information. Information submitted should consist -

of a package of those pages of the ODCM to be chenged with each page. numbered and provided with an approval and cate box, together with apprcpriate analyses or evaluations justifying the change (s);

2) A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and

3) Documentation of the fact that the change has been reviewed and found acceptable by the ORC. -

i,

b. Shall become effective upon review and ::::;t:r.:: by th: C. !

( >,- approval in accordance'with i Specifications 6.5.1.6 and 6.5.3.1. j CALLAWAY - UNIT 1 6-27

,, . . . . . s- . . -

4 4

ADMINISTRATIVE CONTROLS 6.15 MAJOR CHANGES TO RADIOACTIVE LIOUID. GASEOUS AND SOLID WASTE TREATMENT SYSTEM 5a 6.15.1. Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid):

a. Shal1 be reported to the Commission in the Semi-annual Radioactive Effluent Release Report for the period in which the_ evaluation was reviewed by the ORC. The discussion of each change shall contain:

1) A summary of the evaluation that led to the determination that.

the change could be made in accordance with 10 CFR Part 50.59;

2) Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;

3) A detailed description of the equipment, components and processez involv'ed and the interfaces with other plant systems;

4) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or

f. quantity of solid waste that differ from those previously

( predicted in the license application and amendments thereto;

5) An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto;

6) A comparison of the predicted releases of radioactive' materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are ^.o be made;

7) An estimate of the exposure to plant operating personnel as a

result of the change; and l .

8) Documentation of the fact that the change was reviewed and found acceptable by the ORC.

b. Shall become effective upon review and-acceptcr.;; by the CRC.

approval in accordance with

' Specifications 6.5.1.6 and 6.5.3.1.

Licensees may chose to submit the information called for in this specification as part of the annual FSAR update.

f s

CALLAWAY - UNIT 1 6-28 k

i Specification 6.2.2 c) Page 6-1 i 1

Justification: Placement of a job title for this generic term I would constitute a. technical violation of .

i Technical Specification in the event of a strike by bargaining unit personnel.

With our current labor contract we have a conflict with job titles in that all i Radiation / Chemistry Technicians 'are not required P to be qualified in radiation protection procedures.

Specification 6.2.2 f) Page 6-1 and 6-1 Justification: These are the personnel on shift performing i safety related functions which is consistent with Generic Letter 82-12.

i Inclusion of the word " shift" is consistent with l Generic Letter 82-12 and clarifies the intent.

l Inclusion of the words " Emergency Duty Officer" is consistent with Generic Letter 82-12 in that it substitutes for those persons designated by i

i the Plant Manager as " Deputy."

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l i

1 3

. j l i

- Justification: Bottom of>Page 6-6

(

Wording is consistent with the Callaway SER j and further follows ** of Page 6-5.

Specification 6.3.1 Page 6-6' Justification: " Superintendent,_ Health Physics" wording j 1

consistent with organizational chart. Reg. Guide 1.8 proposed Rev. 2, 2-79 is consistent with ,

Callaway FSAR Site Addendum Chapter 3, Appendix

- 1 3A.

(

Specification 6.5.1.2 Page 6-7 Justification: " Superintendent, Health Physics" wording consistent with organizational chart.

Specification 6.5.1.3 Page 6-7

- Justification: To provide independence for QA representation on the ORC.

l' Specification 6 5.1.6 a, b, c,.d and e Page 6-8 l

Justification: (1) The purpose of ORC is to advise the Manager on matters concerning Nuclear Safety. To perform the review requirements of the NRC draft, considering the volume of procedures and revisions to them would-result in a detraction from the ORC members management ]

duties. Further, the extended review l 1

i*

process makes the procedure change process appear to the worker as "more trouble than it is worth" and fosters a climate conducive to short cuts.

(2) The review process proposed assures that independent and cross disciplinary reviews are conducted by qualified personnel for quality and technical adequacy. Safety evaluations are performed and reviewed by qualified reviewers and submitted to ORC.

(3) The program as submitted meets the requirements of ANSI N-18.7 as endorsed by Regulatory Guide 1.33, Rev. 2, 2/78.

(4) ORC does review the Administrative Procedures which establish the basic management philosophy of operation to assure j

safe, legal and efficient operation.

(5) When uncertainty exists as to whether an unreviewed safety question exists in procedures, or if the procedure would require a change to the Technical Specifications, ORC review is required.

Specification 6.5.1.6 h) Page 6-8 Justification: The revised wording provides additonal clarification in that: -

a) The ORC does not review the event itself, but reports of the event, and b) There are apparently no events which require "24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months written notification" to the Commission but events which require "24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification" with information no later than the first working day.

Specification 6.5.1.6 i and j) Pages 6-8 and 6-9 Justification: These plans are reviewed by the ORC and the NSRB.

The detailed implementing procedures associated with each are prepared, independently reviewed and approved by the Manager, Callaway Plant in accordance with Specification 6.5.3.1 a).

Specification 6.5.1.6 k) Page 6-9 i

Justification: The ORC reviews the reports rather than performing the investigation.

Specification 6.5.1.7 Page 6-9 Justification: Provides consistency with the purpose of reviews to be conducted under Specification 6.5.1.6.

Specification 6.5.2.2 Page,6-10 Justification: The revised wording reflects the minimum I

membership currently on the NSRB. Also, the NSRB currently consists of. additional members to improve the diversity of experience on the board. l Specification 6.5.2.6 Page 6-10 Justification: The revised words more accurately reflect the quorum requirements for an expanded NSRB.

Specification 6.5.2.7 e) Page 6-11 l Justification: Inclusion of Specification 6.9.1.10 and Specification 6.9.1.11 to provide a more clearly j defined scope and threshold of events having nuclear safety significance. The audit program described in Specification 6.5.2.8 (below),

I provides a high degree of assurance that trends adverse to quality will be detected and I corrected. The combination of these two reasons i

meet the intent of Standard Tech. Spec. wording. l Specification 6.5.2.7 g) Page 6-11 Justification: The revised wording provides additional clarification in that:

a) The NSRB does not review the event itself, but reports of the event, and b) There are apparently no events which require "24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months written notification" to the Commission but events which require "24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification" with information no later than the first working day.

Specification 6.5.2.8 i) - Page 6-12 4

Awaiting SRETS NuReg 0472, Rev. 3 Specification 6.5.2.10 a) Page 6-12 Justification: It is nearly impossible to obtain approval of the minutes within 14 days of the meeting. Obtaining i

approval would require another meeting of the board which would in itself require approved l minutes, etc., etc. In practice, the minutes are

(

l read back to the members as they are being written during the meetings, and there are rarely discrepancies between the draft minutes and those that are ultimately approved. ,

Specification 6.5.2.10 c) Page 6-12 Justification: The quantity of reading material embodied in all the audit reports is too great to be useful to the Vice-President, Nuclear. Written summaries would be much more meaningful.

r Specification 6.5.3.1 a) Page 6-3 3 Justification: The / was replaced with parentheses to more accurately reflect the intended language, e.g.

the sentence can be read using " individual" or be read using " group."

" Emergency Plan" replaced with " Radiological Emergency Response Plan" to reflect actual name of plan and avoid confusion.

The limitation on the types of changes which can be made without a " change of intent" could be strictly interpreted. Inclusion of the words "for implementation," striking the ORC review and manager approval and adding approval by the ;

original approval authority more correctly reflects approval cycle for temporary changes to l procedures which do not change the intent of the i'

approved. procedure.

Specification 6.5.3.1 b) and c) Page 6-13 Justification: The / was replaced with parentheses to more accurately reflect the intended language, e.g.

the sentence can be read using " individual" or be read using " group." .

l

{

Specification 6.5.3.1 d) Page 6-14 Typographical error in that 6.5.3.1 d) reference was used in this specification.

Specification 6.5.3.1 f) Page 6-14 Justification: Make reviews and approvals consistent with 6.5.1.6 and 6.5.2.7. Vice President, Nuclear would only be in approval cycle if NRC approval required.

Specification 6.5.3.1 g and h) Page 6-14 Justification: Already stated in Specification 6.5.1.6 and Specification 6.5.2.7. Unnecessary duplication.

Specification 6.8.1 e) Page 6-15 l Justification: " Emergency Plan" replaced with " Radiological Emergency Response Plan" to reflect actual name of plan and avoid confusion.

Specification 6.8.1.1 Fage 6-16 i e cupi c g SRETS NuReg 0472, Rev. 3 L Specification 6.8.4 Page 6-16 Justification: NuReg 0452, Rev. 4 has broken these. programs out- .

into a new section to show that they'are different from Administrative-Pt..edures.

Specification 6.8.4 a) Page 6-16 Justification: Plant Specific equipment and systems.

Specification 6.9.1.5 b) page 6-18 Justification for deletion: Report of challenges covered in monthly report under Section 6.9.1.8.

Specificat on 6.9.1.8 Page 6-21 Justification: Plant Specific equipment and systems.

Specification 6.9.1.10 j) Page 6-23 Justification: Redundant reporting requirements since failure of either of these valves results-in entering a degraded mode which requires reporting under Specification 6.9.1.10 or Specification 6.9.1.11.

Specification 6.9.1.11 b)

Justification: The added sentence is consistent with the guidance provided by Regulatory Guide 1.16.

Stating it in the specification increases clarity and reduces confusion.

Specification 6.10.2 i) going to 6.10.3 Page 6-25 Justification: The separate Specification clearly defines a separation between five year retention periods, lifetime retention periods and variable retention periods.

Specification 6.10.2 m) Page 6-25 Awaiting SRETS NuReg 0472, Rev. 3 Specification 6.12.1 c) Page 6-26 Justification: The wording " health physics management personnel" clearly defines those UE personnel who normally specify this frequency.

Specification 6.12.2 Page 6-26 Justification: Consistent with organization chart.

Specification 6.13.2 b) Page 6-27 Justification: Change to Specification 6.5.1.6 and Specification 6.5.3.1 to be consistent with review and approval cycle.

Specification 6.14.2 b) Page 6-27 Justification: Change to Specification 6.5.1.6 and Specification 6.5.3.1 to be consistent with review and approval i

cycle. I l

1 Specification 6.15.1 b) Page 6-28 Awaiting SRETS NuReg 0472, Rev. 3. j i

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ML20072H253

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