ML20076H865

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Forwards marked-up Tech Spec Section 6.0 Re Administrative Controls & Summary Listing of Items Discussed at 830812 Meeting
ML20076H865
Person / Time
Site: Callaway Ameren icon.png
Issue date: 08/31/1983
From: Schnell D
UNION ELECTRIC CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
ULNRC-656, NUDOCS 8309060229
Download: ML20076H865 (40)
v • d • e


Text

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3 as UNION ELECTRIC COM PANY 1901 GRATIOT STREET ST. LousS. MISSOURI MAILING ADDREW.:

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August 31, 1983

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Mr. Harold R.

Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Denton:

ULNRC-656 DOCKET NUMBER 50-483 CALLAWAY PLANT, UNIT 1 TECHNICAL SPECIFICATION SECTION 6.0 On August 12, 1983 a meeting was held between NRC and Union Electric personnel to discuss the administrative portion (Section 6.0) of the Callaway Plant, Unit 1 Technical Specifications.

As a result, Union Electric is resubmitting Section 6.0 based on the agreements made at the meeting.

Please find attached five copies of marked-up Section 6.0 along with a summary listing of the items discussed during the August 12 meeting.

If you have further questions on this matter, please contact us.

Very truly yours, affi

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Donald F.

Schnell Attachments DS/lw

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8309060229 830831 PDR ADOCK 05000483 A

PDR

STATE OF MISSOURI )

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SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn upon oath ~says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By

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Jl-Donald F.

Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 31st day of August 198 3.

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BARGARA J. PFAFF "

NOTARY PUBUC, STATE OF MISSOURI MY COMMISSION EXPIRES APRIL 22,1985 ST. LOU S COU*ITY.

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cc:

Glenn L. Koester Vice President Operations Kansas Gas & Electric P.O. Box 208 Wichita, Kansas 67201 Donald T. McPhee Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M.

Street, N.W.

Washington, D.C.

20036 s

Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 i

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O SECTION 6.0 ADMINISTRATIVE CONTROLS ff{ hk)O p(ggyEDf0 77 M -

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o These items were discussed and agreed to in the meeting of August 12, 1983 between Union Electric and the Nuclear Regulatory Commission:

Page No.

Sections 1.

6-1 6.2.2.c; 6.2.2.e; 6.2.2.f;

  1. footnote 2.

6-2 6.2.2.f 3.

6-5 Paragraph 1; ** footnote 4.

6-6 6.2.3.4; 6.2.3.5; 6.3.1;

    • footnote - insert A 5.

6-7

  • footnote 6.

Insert 1 - ORC 7.

6-9 6.5.1.7; deletion of insert 2 8.

6-10 Addition.of 6.5.2.1.1; 6.5.2.2; 6.5.2.6; 6.5.2.7 9.

6-12 6.5.2.10 10.

6-13 6.5.3.1.a, b, c 11.

6-14 6.5.3.f j

12.

6-16 6.8.1.1 i

13.

6-20 6.9.1.7

    • footnote Union Electric also considers the following items CLOSED which j

were left as OPEN items from August 12:

Page No.

Section Discussion 6-6 6.3.1 UE has researched the letter of 3-28-80 and has encorporated NRC wording into this section.

6-3 &

Figs. 6.2-1 &

UE.has updated these figures in this 6-4 6.2-2 submittal and considers this item closed.

TECHNICAL SPECIFICATIONS SECTION 6.0 MEETING AUGUST 12, 1983 ATTENDANCE U_E NRC E

Steve Miltenberger - Plant Mgr. -

Fred Anderson - NRC Standards Branch Callaway Robert Benedi,ct - NRC Reviewer Dan Poole - Advisor to Plant Mgr. -

Dr. Gordon Edison - NRC Project Mgr.

Callaway Dave Shafer - UE Licensing Andy Neuhalfen - Asst. Mgr. -

Operations and Mtc.

Sharon Rauba - Asst. Engr. - Compliance Al Passwater - UE Licensing i

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ADMINISTRATIVE CONTROLS

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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 coamand 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 0FFSITE 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 Th.e Unit organization shall be as shown in Figure 6.2-2 and-

a. '

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

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b.

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

In addition, while the unit is in MODE 1, 2,3or4,atleastonelicensedSeniorOp'eratgrshallbeinthe rn +he. bub Ph 2.s Oqp4ud(o%

control room; 3

Anindivgual ua)hfied in p diation protection procedures o

,,calth rhy:ics {.cchnieten-shall be on site when fuel. is, in the

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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 responsibilities during this operation; A site Fire Brigade g at least five membersN hall be maintained e.

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 d

functions; e.g., licensed Senior Operators, licensed Operators, te51th ;.hysicist;, emlisry operctor;, cc.d kcy maintcnance-p r aenel.

  1. M celth Yhysic; kI I

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I minirnum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to i

accommodate unexpected absence provided immediate action is taken to fill the required positions, gg,

'.g health physics personnel, equipment operators, and,

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m CALLAWAY - UNIT 1 6-1

F ADMINISTRATIVE CONTROLS shift dequate shift coverage shall be maintained without routine heavjf us of overtime.

The objective shall be to have cperating p onnel work normal 8-hour day, 40-hour week while the plant is rating.

Howeve in the event that unforeseen problems require s tantial amounts overtime to be used, or during extended per ds of shut-down for re ueling, major maintenance or major plant.odifications, on a temporar basis, the following guidelines sha be followed:

1)

An individua should not be permitted to ork more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, exc1 ing shift turnover tim,

2)

An individual. shou not be permi ed 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 perio, nor more an 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. ho.ur in any 7-day period, all excluding shift turnover time; 3)

A break of at least 8 urs sh uld be allowed between work periods, including s ft turnove time, and 4)

Except during e ended shutown perio

, the use of overtime should be con dered on an individual sis and not for the entire staf on a shift.

crgency Duty Officer, Any deviatia from the above guidelines shall be a horized by the

Manager, higher levels of management, in accordan with estab-lished p ocedures and with documentation of the basis r granting the deflation.

Controls shall be included in the proced es such t

individual overtime shall be reviewed monthly by the F qager or designee to assure that excessive hours have not been ass' ned.

outine deviation from the above guidelines is not authorized.

The. omcud cM cvedime, worked b LtnN Sd rncmbs cmdg

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CALLAWAY - UNIT 1 6-2

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

la SRO 1

None RO 2

1 E0 2

1 STA 1**

None Shift Supervisor with a Senior Operator license on Unit 1 SS i

Individual with a Senior Operator license on Unit 1 SR0 R0 Individual with an Operator license on Unit 1 Equipment Operator EO STA Shift Technical Advisor

&#eept for the Shift Super'eiter,'The Shif t Cres 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift

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crew members provided immediate action is taken to restore the Shift Crew g,

Composition to within the minimum requirements of Table 6.2-1.

This provision

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

During 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 l

control room command function.

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A 0ne SRO, either Shift Supervisor or Operating Supervisor The STA pe+444en may be climinated when en SRO n shif t r. cats thc 'OC l

edeentionpl rcquirements for an STA and the Contrcl ~;cc: dc;ign h:2 iccn-g graded te NRG-req drement: fer clini n t4ag-the ST* pe itier The STA position shall be manned in modes 1 through 4 unless the N.

Shift Supervisor or the Senior Reactor Operator meet the qualifications for the STA as required by the NRC.

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ENGR, STAFF STAFF STAFF STAFF STAFF UNION E LECTRIC COMPANY CALLAWAY PLANT UNIT I TECHNICAL SPECIFICATIONS FIGURE 6.2-1 NUC1. EAR FUNCTION ORGANIZATION CHART f

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HEALTH SAFETY Q/C PHYSICISTS COORDINATOR STAFF Also Available On Aperture Card UNION ELECTRIC COMPANY CALLAWAY PLANT UNIT I TECHNICAL SPECIFICATIONS FIGURE 6.2-2 CALLAWAY PLANT OPERATING ORGANIZATION REV.O

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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. =f 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 ? years professional level experience in his g

field.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for main'taining surveillance of plant activities to provide independent verification

  • that these activities are performed correctly and that hu. nan errors are reduced as much as practical.

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-0.2.0.4 The ISEG shall make detailed recommendations for revised procedures, 3

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.[4RecordsofactivitiesperformedbytheISEGshallbeprepared, maintained, and forwarded each calendar month to the Manager, Nuclear Safety and Emergency Preparedness and the Manager, Callaway Plar.t.

6.2.4 SHIFT TECHNICAL ADVISOR The Shift Technical AdvisoF shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit.

6. 3 UNIT STAFF QUALIFICATIONS C.3.1 Escr c.ec.be. ef the cc.it 5tsf f shs ',eet or cx :cd th: min'msm-qua' 4 ' ice, tion; c f A"$1/M 2.1-10C, ex;ey. fm the h 4 h ^.

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Lg. ::m1LL rhysica ";r: : who :h;!! ncet or cxceed the qu;;ific2t;c,,2.f Regul a;a j,Gu.de 1. 5,

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( "Not responsible for sign-off function.

    • The STA position-c.ay b-c eliminated " hen an SFO en shift reetc
  • ho 'mr ad"ontional sequirementa Oro-mwST/Md-the-Control-Room-<lesigtHete-beet -umadcd t<

NaC retuiremen w-for-el-imi nat-ing -the-SU pm i t ion see. T.NWP~T A CALLAWAY - UNIT 1 6-6

f TNSERT A The STA position shall be manned in modes 1 through 4 unless the Shift Supervisor or the Senior Reactor Operator meet the qualifications for the STA as required by the NRC. i i e e I

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lus acr' B 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 Superintendent, Health Physics who shall meet or exceed the qualifications of Regu-latory Guide l'.8, September 1975, for a Radiation Protection Manager. 1 The licensed operators and senior operators shall also meet or ex-ceed the minimum qualifications of the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees. 4 + 4 I i i O e 4 l l (

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y. t. I ADMINISTRATIVE CONTROLS v t 6.4 TRAINING h-6.4.1 A retraining and replacement training program for the unit staff shall j be maintained under the direction of the Superintendent of Training and shall meet or exceed the requirements and recommendations of Section 5 of ANSI / 1; ANS 3.1-1978 and Appendix "A" of 10 CFR Part 55 and the supplemental require-3 ments specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC [t. letter to all licensees, and shall include familiarization with relevant Qt industry operational experience identified by the ISEG. 6.5 REVIEW AND AUDIT j 6.5.1 ON-SITE REVIEW COMMITTEE (ORC) 9 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: r. (; Chairman: Manager, Callaway Plant (j Member: Asst Mgr, Oper and Maintenance 3j-Member: Asst Mgr, Tech Services Member: Asst Mgr, Support Services Member: -57., "cdiatica "rctcction Supt., Health Physics Member: Supv Eng, Quality Assurance

  • Member:

Adv to Mgr, Callaway Plant ALTERNATES

6. 5.1. 3 All alternate members shall be appointed Chairman to serve on a temporary basi b wever aoin writing by the ORC serc-than two alternatc; I

-sha44-part-ic4pate-as-vot4ng-membees-in-OrtCwetivit-les-et-any-on; time. l A pos i t-ion _t0-be--abo-1-ished-when-provis4ons-of-ACfv5-4+tter--&4ed NOveoe

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,na, a Ns Mmb troy be ftrfngd u) hen 4his % ico is (do6h'Shed. R

    • Except for the alternate for the Supervising Engineer, Quality Assurance (Operations) who is appointed by the Manager, Quality Assurance.

(U CALLAWAY - UNIT 1 6-7 a - ~, _ ~ - -.,

~. _.... .I ) ADMINISTRATIVE CONTROLS MEETING FREQUENCY 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. a T 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 ej shall consist of the Chairman or his designated alternate and/four members -including Olternates. AT /54.57" CF W/MH 7"WC AMf St A47/fd'4rf,S 4 ih5PONSIBILITIES INSERT - 1 6.5.. 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 Specification 6 and cha es thereto, and (3) any other proposed procedures or c anges there as determined by the Manager,'Callaway Plant to a ect nuclear j, safety; ? j b.. Review of a 1 proposed changes, tests and experimen which may j involve an un viewed safety question as defined Section 50.59, ] 10 CFR; / J c. Review of all propo d changes to Technical pecifications or the Operating License; d. Review of all safety eva tions perfo..ed under the provision of Section 50.53(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 fety Review Board; f. Review of events requir' g 24-hour writte notification to the Commission; g. Review of reports f operating abnormalities, o viations from expected perforponce of plant equipment and of un nticipated a deficiencies ~4 the design or operation of structu , systems or components + at affect nuclear safety; h. Perform ce of special reviews, investigations or analyses and reports asrequestedbytheChairman,NuclearSafetyRevieQoard; thereo i. Re ew of the plant Security Plan and implementing procedures $gd all submit recommended changes to the Nuclear Safety Review Sca d; k j Review of the Emergency Plan and implementing procedures ar.d shall submit recommended changes to the Nuclear Safety Review Board; CALLAWAY - UNIT 1 6-8

INSERT - 1 { RESPONSIBILITIES 6.5.1.6 The On-Site Review Committee shall be responsible forfre"!e"e ef' kof a. All Administrative Procedures. lleciew of

b. A 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. sem of c. Proposed p'rocedures and changes to procedures, equipment, systems or facilities which may involve an unreviewed safety question as defined in 10 CFR 50.59 or involves a change in Technical Specifications. hAtw of d.A Proposed test or experiments which may involve an unreviewed safety question as defined in 10 CFR 50.59 or requires a gi chan,ge in Technical Specifications. %c}twoT e." Proposed changes to Technical Specifications or the Operating License. f. Investigation 5of all violations of the Technical Specifications including the forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President-Nucigar and to the Nuclear Safety Review Board. o\\cs0 at c) g. Reports of operating abnormalities, deviations from expected performance of plant equipment and of unanticipated deficiencies j. in the design or oper.ation of structures, systems or components at affect nuclear safety. v6*t$ Aty*<NEmvJ w f n A Y r $// h.l sM4-wr-it-ten-rep (ne-to-the-Gommibelon -coneern' ~ ^"^~ ^' ^'p2l$0 C s m r g .r-equi-ra 24-hour notificacien te th^ Cerirrie". itw d 1. The plant Security Plan and shall submit recommended changes to the QSRB. Rfta$ j./'The Radiological Emergency Response Plan and shall submit recommended changes to the NSRB. as k. Investigations or analysis of special subjects ace requested by the Chairman of the Nuclear Safety Review Board. iw of 1. Changes to the PROCESS CONTROL PROGRAM, and the OFFSITE DOSE CALCpLATION MANUAL. \\ uiw or Any accidental, unplanned or uncontrolled radioactive release including m. the preparation or reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwarding l of these reports to the Manager, Callaway Plant and to the Nuclear Safety Review Board. l

r: ADMINISTRATIVE CONTROLS Review of changes to the PROCESS CONTROL PROGRAM, and the OF [ OSE LCULATION MANUAL; and 1. Review of any acc 1, unplanne ncontrolled radioactive release including the pre ' n of reports covering evaluation, recommendations a ' position o corrective action to prevent recurre pnc he forwarding of these re to the Manager, ray Plant and to the Nuclear Safety Review -mm 6.5.1.7 On-Site Review Committee shall: Peinsert a. Recommen writing to the Manager, Callaway Piant approval -lhiS disapproval 'tems considered under Specifications 6. .6a. i; Sec.Wn through,d'Q, above, b. Render determinations in w ~ ing with ra d to whether or not each item considered under Specific 'o .5.1.6a. through p f above, f constitutes an unreviewed sa qu ion; and c. Provid2 written no ' cation within 24 hours the Vice President-Nuclear and uclear Safety Review Board of reement between the ORC - the Manager, Callaway Plant; however, th ' nager, (/". C ay Plant shall have responsibility for resolution o uch 3 isagreements pursuant to Specification 6.1.1 above. RECORDS 6.5.1.8 TheOn-SiteReviewCobitteeshallmaintainwrittenminutesofeach ORC meeting that, at a minimum, document the results of all ORC activities performed under the responsibility and authority provisions of these Technical Specifications. Copies shall be provided to the Vice President-Nuclear and the Nuclear Safety Review Board. 6.5.2 NUCLEAR SAFETY REVIEW E0ARD (NSRB) FUNCTION 6.5.2.1 The Nuclear Safety Review Board shall function to provide independent review and audit of designated activities in the areas of: a. Nuclear power plant operations, b. Nuclear engineering, c. Chemistry and radioche'mistry, d. Metallurgy, ? s e. Instrumentation and control, f. Radiological safety, CALLAWAY - UNIT 1 6-9

t b ADMINISTRATIVE CONTROLS I g. Mechanical and electrical engineering, and h. Qualityassurance?racticef k (o.5 2..l. I h NSPS skal repr-L o ard. odoise_.4he. Wce PNM-Mr on -hse cueas of respreb%y s&ded. In SgcaMons G.5. 7. 8 ctnd 65.2. 9. COMPOSITION 6.5.2.2 The NSRB shall be composed of e e.: at least the following members: j Chairman: General Manager, Engineering (Nuclear) Member Vice Chairman: Manager, Nuclear Engineering Mcmber: Manager, 9uality A35uranct Nuclear Safety and Emergency Member -fitftt Manager, Callaway Plant Preparednes Member: SNUPPS Technical-Di-rector Manager,Guc43y hsurarce. Member: Iuei [ngincer-Supervising Engineer, Nuclear Fuels Additional members and Vice Chairman may be appointed by the Chairman ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the NSRB 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. j CONSULTANTS ) 6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB. i MEETING FREQUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following f uel loading and at lezst once per 6 months thereafter. B a &.c) "b r'S, d G (LM/f/M 7%CNS hotd a. '" D 1 7./,.2 6 MMM@M7"Sgegky,p ^.- w QU0RUMQfw/.op<ww,;p uAct mz,u;n..."l, JpemS*<Amt = .a d:< 6 ' j'. s w g s2.,,,, n

6. 5. 2./IThe " mum quorum of the NSRB necessary for the performance of the NSRB review and audit functions of these Technical Specifications shalle 2/3 of the consist of the Chairman or his designated alternate and at least 6 :c lSRB members including alternates.

No more than a ninority of the quorum shall have line responsibility for operation of the unit. For the purpose of a quorum, those considered to have line responsibility will include the Manager, Callaway Plant, and personnel re' porting to the Manager, Callaway Plant. .jcwy l $Y> C,f 2.L < N ,yZ[< E .'.- O uy;s'nd.; 1 CALLAWAY - UNIT 1 6-10 t

t' ADMINISTRATIVE CONTROLS REVIEW 6.5.2.[ The NSRB shall meem-[ A/y*bg.2:6 N-ulw g ! a. The safety evaluations for: (1) changes to procedures, equipment, systems or facilities; and (2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions g did not, constitute an unreviewed safety question; b. Proposed changes to procedures, equiptnent, 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. a 4 question as defined in Section 50.59, 10 CFR; .ne-tAis .d. Proposed changes to Technical Specifications or +h+s-0perating License; Violations of [, odes, regulations, orders, Technical Specifications, k e. license requirements, or of internal procedures or instructions havingnuclearsafetysignifican'ee " ^ e=reputaMW::

- r z.;.1.i n nc c.;.1.it.

C ',3 Significant operating abnormalities or deviations from normal and f. 2 expected performance of unit equipmbat that affect nuclear safety; 3 Ean p k' s yawyf.me6542Y.ert ud&fas.-1s?ttn /& hour written a r g. Scnte rc 4. Y-2

,nslA.'-n.

f h. All recognized indications

  • of an unanticipated deficiency in some aspectofdesigno{operationofstructures, systems,orcomponents that could affect nuclear safety; and i.

Reports and meetings minutes of the On-Site Review Committee. AUDITS 6.5.2. Audits of unit activities shall be performed under the cognizance 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 lea'st once per 12 months; b. The performance, training and qualifications 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 6 months; C CALLAWAY - UNIT 1 6-11

t 6 i ADMINISTRATIVE CONTROLS O... d. The performance of activities required by the Operational Quality p Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least once per 24 months; I /, Any other area of unit operation considered appropriate by the NSRB or the Vice President-Nuclear @ K p /t. The Fire Protection programmatic controls including the implementing [ procedures at least once per 24 months by qualified licensee QA personnel; g/. The fire protection equipment and program implementation at least V once per 12 months utilizing 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; ) Kg The [adiological [nvironmental Mnitoring hrogram and the results 4 thereof at least once per 12 months; [ /4.. The OFFSITE DOSE CALCULATION MANUAL an,d implementing procedures at least once per 24 months;

g. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioact' wastes at least once 24 months ateuM; aEsD

? h4 amt d '. The performance of activi ies required by the Qual y Assurance Pr g y meet the provi:icr.: cf Regulctory Cuide l T, i.i ~ J$ v. I k g..j Mim cr d NM -t ry Cuii. 4.1, Re. o.... 1, Apri 10-'5, at least <\\ once per 12 monthsj M -AlfTll0RI"I S.5.2.,p-TheNSRBshallreporttoandadvisetheVicePresident-Nuclearon NoVED To i (3ccr. p those areas of responsibility stated in Specifications 6.5.2.Jeand 6.5.2g4 6.5.2.1.1 RECORDS 6.5.2. Records of NSRB activities shall be prepared, approved, and distributed as indicated below: Minutes of each NSRB meeting shall be prepared, O N d-and forwarded a. to the Vice President-Nuclear within 14 days following each meeting 6 The-eitm tea-sha 14-be-approved.-a t--a-subsommat.-neet44w-. b. Reports of reviews encompassed by Specification 6.5.'2.7 above, shall be prepared, approved and 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 Vic: Prc;ident "ucler 2-d t W e manager.ent o s responsible'for the areas _ auditedjwithin 30 days after completion of the audit by the aediting organization. and summaries of audits shall be prepared and forwarded to the Vice President-Nuclear. ,,},h 'y-CALLAWAY - UNIT 1 6-12

..... ~. y t 1 ADMINISTRATIVE CONTROLS 6.5.3 TECHNICAL REVIEW AND CONTROL 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 chnsoe shall be reviewed by aff* individual (group)other than the diualified) individual (group)whichpreparedtheprocedureorprocedurechange butwhomaybefromthesameorganizationastheindividual(group) which prepared the procedure or procedure change. Proceddres other than Administrative Procedures shall be approved by the appropriate i Department Head as designated in writing by the Manager, Callaway i Plant. The Manager, Callaway Plant shall approve Administrativ_c,,yRadiologica5 Procedures, Security Plan implementing procedures and$mcrgency-AP an Emergenq implementing procedures. Temporary changes to procedures which do L Responsq not change the intent of the approved procedures shall be approveg for l by two members of the p,1 aft staff, at least one of whom holds a Qi lementats n Senior Operator licensee documented, rc.icued by CRC, and approved by the Manager, Calicway Picat within it dcy; cf impicmcat+t-iere For changes to procedures which may involve a change in intent of {>} the approved, procedures, the person, authorized above to approve the g procedure shall approve *.he change prior to taplementation; 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 reviewed by a/frindividual(group)other than the Qualified) individual / h (group)which designed the ihadification, but who may be from the same organizationastheindividual(group)whichdesignedthemodifica-tions. Proposed modifications to plant nuclear safety-related structures, systems and ccmpcnents shall be approved prior to implementation by the Manager, Callaway Plant; c. Proposed tests and experiments which affect plant nuclear safety and 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 aff., individual [ group)other than the {ualifiebindividual(group)yhich prepared the proposed test or experiment. Proposed test and experiments shall be approved before implementation by the Manager, Callaway Plant; These temporary changes,Jhall be,. ac aubacquc al; approved by the original approval authorityf wHhin 30 cbya. k CALLAWAY - UNIT 1 6-13

aO.

f..

ADMINISTRATIVE CONTROLS } } $n Individuals responsible for reviews performed in accordance with d. Specifications 6.5.3.la, 6.5.3.lb r6.5.3.lc,,and C.L.3.1d shall be g members of the plant management staff previously designated by the Manager, Callaway Plant. Each such review shall include a deter-N i mination of whether or not additional, cross-disciplinary, review is j. necessary. If deemed necessary, such review shall be performed by qualified personnel of the appropriate discipline; a ( e. Each rev.iew shall-include a determination of whether or not an -unreviewed safety question is involved. Pursuant to Section 50.59, w 10 CFR, NRC approval of items involving unreviewed safety question j$ shall be obtained prior to Manager, Callaway Plant approval for i implementation; 1 E

f. %'

t Security Plan and Emergency Plan, and impleriant#7 j procedures, s ewed at leW anse per.tz months. Recem-4 mended change ps shov-anager, Callaway Plant, and h..- transriLiedTo the Vice President-Nuclear an ChangestothePROCESSCONTROLPROGRAk,0FFSITE00SECALCULATION L and radioactive waste treatment systems shall be re # by a quali ' individual / group and approved by the M , Callaway Plant; and p h. Every unplanned onsite releas radioactive material to the ^ environs including th aration a orwarding of reports covering h' evaluation, re . ndations and dis' position he corrective action to prev ecurrence to the Vice President-Nuclea to the NSRB g be reviewed b7 a qualified individual / group. ? 2'j RECORDS 1 6.5.3.2 Records of the above activities shall be provided to the Manager, Callaway Plant, ORC and/or NSRB as necessary for required reviews. f. The Plant Security Plan and Radiological Emergency Response Plan and i impicmenting procedures, shall be reviewed at least once per 12 months. l~ Recommended changes to the implementing procedures shall be approved j by the Manager, Callaway Plant. Recoccended changes to the Plans l shall be reviewed pursuant to the requirements of sections 6.5.1.6 i and6.5.2.J$andapprovedbytheManager,CallawayPlant. NRC approval shall be obtained as appropriate. I CALLAWAY - UNIT 1 6-14 .,--..m~ =-y

f! ' ADMINISTRATIVE CONTROLS O 6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for REPORTABLE OCCURRENCES: 1 a. The Commission shall be notified and/or a report submitted pursuant to the requirements of Specification 6.S, and i y? 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 hour. The Vice President-Nuclear and the NSRB shall be notified within 24 hours; b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the ORC. T_his report shall describe: (1) applicable circumstances preceding the violatica; (2) effects of the violation (' u' upon facility components, systems or structures; and (3) corrective action taken to prevent. recurrence;. c. The Safety Limit Violation Report c' hall be submitted to the Commission, the NSRB and the Vice President-Nuclear within 14 days of the violation; and [j 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: 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. E.:crgcacy Plan implementation, f Q_-. CALLAWAY - UNIT 1 6-15 u

g, = ADMINISTRATIVE CONTROLS O f. Fire Protection Program implementation, f ] g. PROCESS CONTROL PROGRAM implementation, 1 h. OFFSITE DOSE CALCULATION MANUAL implementation, and ( M_.., 4 " *" N 0 1.

ing the -guidance in 9:gelctery Cuidc 1.21, %"4r Program for efflue y

t tien 1, Junu 1374,c -4 s ^ nd :luguietcry Cui de 4.1, Re.< n ;u..1, ?g ril 1075.&c h / 9 ??. 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 impleinenting 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: a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a V serious transient or accident to as low as practical levels. The systems include the recirculation portion of: the Containment $prayx ystem s Safety Injection, chsaicsi sad vcibae cent.ci, 'n'ASTE GAS HOLDUP- -S"STOi, and hydrc;;cn reccabiners. The program shall include the following: 1) Preventive maintenance and periodic visual inspection requirements, and 2) Integrated leak test requirements for each syst'em at refueling cycle intervals or less. b. In-Plant Radiation Monitorino A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shcil include the following: 1) Training of personnel, 2) Procedures for monitoring, and 3) Provisions for maintenance of sampling and analysis equipment. ^ 1 the Safety Injection System, the Residual Heat Removal System, / and the Chemical and Volume Control System. l l l CALLAWAY - UNIT 1 6-16 l t

..w.. ~ ~ ~ l ADMINISTRATIVE CONTROLS c. Secondary Wter Chemistry c A program for monitoring of secondary water chemistry to inhib.it staain generator tube degradation. This program shall include: 1) Identification of a sampling schedule for the critical variables 1 i and control points for these variables, ~ p 2) . Identification of the procedures used to measure the values of L the critical variables, 3) Identification of process sampling points, which sh'all 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 e 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. 'l d. Post-accident Samoling ~ / r/ A program which will ensure the capability to obtain and~ analyze reactor coolant, radioactive iodines and particulates in plant = i. gaseous effluents, and centainment atmosphere samples under accident A conditions. The program shall inclJde the following: 4 1) Training of personnel, 2) . Procedures for sampi.ing and analysis, and 3) Provisions for maintenance of sampling and analysis equipment. CALLAWAY - UNIT 1 6-17 .. ~ - a.

ADMINISTRATIVE CONTROLS

6. 9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be 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 shal1 be: submitted following:

(1) receipt of an Operating License, (2) amendment to the License involving a planned increase in power level, (3) installation of' fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or_ hydraulic performance of the plant. 6.9.1.2 TheSTARTUP[4portshalladdresseachofthetestsidentifiedinthe )( FSAR and shall include a description of the measured. values of the operating conditions or characte-istics 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 tais report. 6.9.1.3 STARTUP kports shall be submitted within: -(1) 90 days following.$ completion of the STARTUP test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 conths following initial f_?) criticality, whichever is earliest. IftheSTARTUP[seportdoesnotcoverall )( u? 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 6.9.1.4 Annualftportscoveringtheactivitiesoftheunitasdescribedbelow 4 for the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year l 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 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. b. ectumentation of cil chclic ;;e3 to thc prcswricer p:wer cpcreted relicf salvc; (ICri ) cad safen v21ves. 2This tabulation supplements the requirements of $20.407 of 10 CFR Part 20. CALLAWAY - UNIT 1 6-18 -- - =~- --- -~

ik

  • M' Ne at

!) { ADMINISTRATIVE CONTROLS k. ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

  • a?

f." 6.9.1.6 Routine Radiological Environmental Operating Reports covering t'he j-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 k;, of the year following initial criticality. 2; j:' The Annoal Radiological Environmental Operating Reports shall include summaries', interpretations, and an analysis of trends of the results of the radiological i environmental surveillance ~ activities for the report period', including a compar-3 ison with preoperational studies, with operational controls as appropriate, and j with previous environmental surveillance reports, and an assessment of the 2 observed impacts of the plant operation on the environment. The reports shall 4 also include the results of land use censuses required by Specification 3.12.2. a The Annual Radiologica' Environmental Operating. Reports shall include the results of analysis of all radiological environmental samples and of all environmental j radiation measurements taken during the period pursuant to the locations speci-fied in the Table and Figures in the 00CM, as well as summarized and tabulated 4 T results of these analyses and measurements in.the format of the table in the R'adiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report snall be submitted noting and explaining the reasons' for J (),.s-1 the missing results. The missing data shall be submitted as soon as possible k~ 'in-a supplementary report. O ? The reports shall also include the following:' a summary description of the radiological environmental monitoring program; at least two legible maps ** r covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of licensee participation in v-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.

CALLAWAY - UNIT 1 6-19 c

o l ADMINISTRATIVE CONTROLS t 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 effluen'ts and solid waste released from the unit'as outlined in R'egulatory 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 same 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 (~~N shall also include an assessment of the radiation doses from radioactive (j liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE B0UNDARY (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 concurrent 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 performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM). The Radioactive Effluent Release Report to be submitted 60 days af ter 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 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 those 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 frcm each unit.

  • % 1 i e u ja -sebmbs4en-wi-t-h-thc f i rs t-hem-year td i oegt4v c F # # N e n t D e 1 e a s e

.-Repor4 the licensee has the option of retaining-th@dfrmry. of required /^ meteorological datayon site in a file that shall be provided to the NRC (., upon request. % g g g. Wo.\\ oMknMy ord Icmuetry I d h ir -Concq yeor CALLAWAY - UNIT 1 6-20

.e u ~. r. I' ADMINISTRATIVE CONTROLS Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev.1, 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: .a. Container' volume, b. Total' Curie quantity (specify whether determined by measurement or est.imate), c. Principal radionuclides (specify whether determined by measurement or estimate), d. ' Source of waste and processing employe'd (e.g., dewatere'd' spent resin, ~ compacted dry waste, evaporator bottoms), Type of container (e.g., LSA, Type A, Type B, Large Quantity), and e. f. Solidification agent or absorbent (e.g., cement, urea formaldehyde). The Radioactive Effluent. Release Reports shall include a list and description ..,3 . ] of unplanned releases from the site to UNRESTRICTED AREAS of radioactive ) materials in gaseous 'and liquid effluents made during the report.ing period. f The Radioactive' Effluent Release Reports shal'1 include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE 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 OPERATIN'G REPORT l Pressurizer Reactor Coolant System Routinereportsofoperatingstatisticsandshutd[cwnexperience, 6.9.1.8 including documentation of all challenges to the PORVs or safety valves, stiall r be submitted on a monthly basis to the Director, Office of Resource Management l U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the l NRC Regional Office, no later than the 15th of each month following the calendar month covered by the report. REPORTABLE OCCURRENCES l 6.9.1.9 The REPORTABLE OCCURRENCES of-Specifications 6.9.1.10 and 6.9.1.11 l below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC. Suppiemental reports may be required to fully describe final resolution of occurrence. In case of corrected or supplemental reports, (... i a licensee event report shall be completed ar.d reference shall be made to the i original report date. I CALLAWAY - UNIT 1 6-21 k

1 ---_w..__-._.___.. li ADMINISTRATIVE CONTROLS PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP 6.9.1.10 The types of events listed below shall be reported within 24 h'ours l+ by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Regional Administrator of the NRC 8egional 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, 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. - Failure of the Reactor Trip System or other systems subject to

' Limiting Safety System Settings to initiate the required protective p function by the time a monitored parameter reaches the'Setpoint specified as the Limiting Safety. System Setting in the Technical V Specifications or failure to complete the required trip function; b'. Operation of the unit or affected systems when any parameter or operation subject to a Limiting Condition.for Operation'is less conservative than the least conservative aspect of the Limiting Condition for Operation established in the Technical Specifications; Abnormal degradation discovered in fuel claifding, react'or coolant frq - c. gQ . 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 4 ~ that correspond to a reactor period of less than 5 seconds or, if subcr.itical, 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; s CALLAWAY - UNIT 1 6-22

K l - ADMINISTRATIVE CONTROLS

n C

h. Errors discovered in the transient or accident analyses or in the j 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 [ than assumed in the analyses; r S i.. Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservhtive than assumed in the accident analyses in the Safety Analysis Report 'or Technical Specifications bases; or discovery during unit life of conditions not specifically considered f. in the Safety Analysis Report.or Technical Specifications that i require remedial action or corrective-measures to prevent the i existence or develorment of an unsafe condition; and J.- picssurizcr P0i!Vs cr safety =hes. ....e v. ...s t THIRTY DAY WRITTEN REPORTS i 6.9.1.11 Thetypesofeventslistedbelowshallbethesubjectofwritten reports to the Regional Administrator of the NRC Regional Office within 4 30 days of occurrence of the event. -The written report shall include, as a t ( O. minimum, a completed copy of a Licensee Event Report Form. Information- \\.r' ) 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 Instrumentacion ij Setpoints which are found to be less conservative than those estab-lished by the Technical Specifications but which do not prevent the i fulfillment of the functional requirements of affected systems; b. Conditions leading to operation in a degraded MODE permitted by a Limiting Condition for Operation or plant shutdown required by a LimitingConditionforOperationg Observe inadequacies in the implementation of Administrative or c. Procedural Controls which threaten to cause reduction of degree of redundancy provided in Reactor Trip Systems or Engineered Safety Feature Sy5tems; and 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. M A thirty day written report need not be submitted when g'Yf 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. y t CALLAWAY - UNIT 1 6-23 w.... i

? h r r O R L e' n unplanned offsite release of: (1) more Shan 1 Curie o' f radioactive material in liquid effluents, (2) more than 150 Curies of noble gas

in gaseous effluents, or'(3) more than 0.05 Curie of-radiciodine in gaseous effluents.

The report of an unplanned offsite release of . radioactive material shall include the following information: . A des.cripIlon.of the~ event 'and 'equipmdnt' inv~olved,_ y 1)' s 2) Cause(s) for the unplanned release, 3) Actions taken.to prevent recurrence,'and 4) Consequences of the unplanned release. '\\ - Measured level's of radioactivity in an environmental sampling medium f.- e' f. -determined to exceed the reporting level values of Table 3.12-2 when averaged over any calendar quarter sampling period. s e i c.n ~ c _~

I o h ADMINISTRATIVE CONTROLS I RADIAL PEAKING FACTOR LIMIT REPORT RTP 6.9.1.12 The F limit for RATED THERMAL POWER (Fxy ) shall be provided to. j xy Li 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 th'e Commission. P Any information needed to support F will be by request from the NRC and g h. 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. 6.10 RECORD RETENTION , - (~. In addition to the applicable record retention requirements of Title 10, Code .i/ of Federal Regulations, the following records.shall be retained for at least ) the minimum period indicated. 6.10.1 The following records.; hall be retained for at least 5 years: a. Records and logs of unit operation covering time interval at each } power level; b. Record 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 ,- s h. Records of annual physical inventory of all scaled source material of record. CALLAWAY - UNIT 1 6-24 -. ~.. _.. _ _ _ _ _.

s . c p, i.: ADMINISTRATIVE CONTROLS 'O 6.10.2 The following records shall be retained for the duration of the Unit Operating License: Records and drawing changes reflecting unit design modifications a. made to systems and equipment described in the F.inal Safety Analysis Report; b. Records;of now and' irradiated fuel inventory, fuel transfers ~and assembly burnup histories; Records of radiation exposure for all individuals entering radiation c. control areas; , d. Records of ytseous and liquid radioactive material released to the environs; Records of transient'or operational cycles for those unit components e. 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; ~i h. Records of-in-service inspections performed pursuant to these Technical Specifications; .i. itceerd; cf Quclity,t:urance--acti.itic: rcquircd by the QA Manucl; / 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. f.

Records of meetings of the ORC and the NSRB; k. [. Records of the service lives of all snubbers listed in Tables 3.7-4a I l ) and 3.7-4b including the date at which the service life commences and associated installation and maintenance records; }

1. p(.

Records of secondary water sampling and water quality; and i f. Records of analysis required by the radiological environmental \\ m. l \\ monitoring program that would permit evaluation of the accuracy of the analysis at a later date. This should include procedures l effective at specified times and QA records showing that these s M procedures were followed. l 6.10.3 Records of Quality Assurance activitics will be retained as identified by the fm 6.11 RADIATION PROTECTION PROGRAM Q.A. Program. ( ) V Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and ~ adhered to for all operations involving personnel radiation exposure. CALLAWAY - UNIT 1 6-25 L _- .. _ =n- = ~ - - ~"

7 U { ADMINISTRATIVE CONTROLS 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 radiat. ion area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /h'r r .t shall be barricaded and conspicuously posted as a high radiation area and t . entrance thereto shall be controlled by requiring issuance of a Radiation work ( Permit (RWP)*.~.Any individual or group of individuals permitted to enter such' areas shall. be provided with or accompanied by one or more of the following: i a. A radiation monitoring device which continuously indicates the ' radiation dose rate in the area; on ~

b., A radiati'on 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 7 .may be made after the dose rate levels in the area have been', og _. established and personnel have bean made knowledgeable of them;--and- ~ c. A health physics qualified individual (i.e., qualified in r'adiation protection procedures) with a radiation dose rate monitoring device . ho is respgnsible for providing positive control over the activities w within the area and shall perform periodic radiation surveillance at ".the frequency'specified by-thc fccilit'y "ccith Phy ;ici:t in the RWP.' f [., health physics management personnel

i. W 6.12.2'.'In' addition to the requirements of Specification 6.12.1, areas

~ accessible to. personnel with radiation levels'such that a majoi pertion of the body could receive in 1 hour a dose greater than 1000 mrem shall be provided with locked doors to prevent unauthorized entry, and the keys shall be aShift Supervisor j maintained under the administrative control of the' Shift forhan'on cuty operating and/or health physics supervision. Doors shall remain locked except during superviso: 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 portion of the body could receive in 1 hour a dose in excess of 1000 mrems** that are located within large areas, such as PWR containment, where no enclosure exists for purposes 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 qualified in radiation protection procedures to provide positive exposure control over the activities within the area. AHealth 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 I they are othemise following plant radiation protection procedures for entry into high radiation areas.

==Measurement made at 18" from source of radioactivity. CALLAWAY - UNIT 1 6-26 _n n

7- $c, ADMINISTRATIVE CONTROLS 3

f 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implementat. ion.

6.13.'2 Licensee initiated changes to the'PCP: a. Shall be submitted to the Commission in the Semi-annual Radioactive I Effluent ' Release Report for the period in which the change (s) was j made. This submittal shall contain: s 1) Sufficiently detailed information to totally support the rationale for.the change without benefit of additional or supplemental information; f 1 2) A determination that the change did not reduce the overall j 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 j found acceptable by the ORC. approval in.accordance with.Specificatfor b. Sha'11 become effective upon review and ecce3,tence b the ORC. 6.5.1.6 and 6.5.3.1< 6.14 0FFSITE DOSE CALCULATION MANUAL (0DCM) C....

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

6.14.2 Licensee initiated changes to.the ODCM: a. Shall be submitted to the Commission in the Semi annual Radioactive q Effluent Release Report for the period in which the change (s) was y 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 changed with each page numbered and provided with an approval and date box, together with appropriate 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. b. Shall become effective upon review and -eecep*amc by the 0% C,'- approval in accordance with Specifications 6.5.1.6 and 6.5.3.1. CALLAWAY - UNIT 1 6-27 w-,

i ..~. .x . i. l' ADMINISTRATIVE CONTROLS 6.15 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS ^ 3 1 6.15.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid): a. Shall 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 informath n to totally support the reason for the change without benefit.of additional or supplemental .information; 3) A detailed description of the equipment, components and processes involved 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.g quantity of solid waste ~ that differ'from those previously - (f-predicted in the license application and amendmentsLthereto;- 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 p'6pulation that differ from those previously estimated in the license application and amendments thereto; 6) A comparison of the predicted relea m of radioactive materials, i in liquid and gaseous effluents and in sclid waste, to the actual releases for the period prior to when the changes are to be made; 7) An estimate of the exposure to plant operat*ng personnel as a result of the change; and i i 8) Documentation of the fact that the change was reviewed and found acceptable by the ORC. [ b. Shall become effective upon review and scceptancc 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.

( CALLAWAY - UNIT 1 6-28 i L

r ', ~ s $$1 SON Docket No. 50-346 RO4ARD P CROUSE ve. % nt nue - License No. NPF-3 utsiasasai Serial No. 1-377 August 15, 1983 Mr. James G. Keppler, Director U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Boulevard Glen Ellyn, IL 60137

Dear Mr. Keppler:

On May 18, 1983, Toledo Edison received IE Bulletin 83-05 (Log No. 1-788): "ASME Nuclear Code Pumps and Spare Parts Manufactured by the Hayward Tyler Pump Company". The enclosed attachment provides Toledo Edison's response to this bulle-tin. Per NRC letter dated May 19, 1983 (Log No. 1-792), this attachment is considered Proprietary Information. Very truly yours, ff r RPC/CTD/jmc cc: U.S. Nuclear Regulatory Commission Document Control Desk NRC Resident Inspector l 266 g30 6 e3036oocw 05 g eor P" IAU6. 2 2 083' o Attachment Contains 4 o / ) Proprietary Information "d/ /2/( Per 10 CFR 2.790(d) - 141thhold From Public Disclosure [ A),- d h 3 p)6/0l# f THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 %d// lll}}

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