ML20078M330
| ML20078M330 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/21/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-83-137, NUDOCS 8310250133 | |
| Download: ML20078M330 (52) | |
Text
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s' KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY GLENN L.
MOESTER vaCE PRES 8 DENT huCLEAR October 21, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 KMLNRC 83-137 Re.
Docket No. STN 50-482 Ret: Letter SLNRC 83-0036 dated 7/8/83 from NAPetrick, SNUPPS, to HRDenton, NRC Subj: Technical Specifications - Section 6.0
Dear Mr. Denton:
The Reference letter transmitted the administrative portion (Section 6.0) of the Wolf Creek Generating Station, Unit No.1, Technical Specifications for NRC review. As a result of dis-cussinns held with Mr. Johns Jaudon, NRC Region IV, on September 14, 1983, Kansas Gas and Electric Company is resubmitting Section 6.0 of the Technical Specifications. Transmitted herewith are five copies of Section 6.0 of the Wolf Creek Generating Station, Unit No.1, Technical Specifications for NRC review and approval.
Yours very truly, Glenn L. Koester g
Vice President - Nuclear GLK:bb cc: JHolonich (2)
WJohnson, Region IV WSchum/ASmith
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l 8310250133 031021 PDR ADOCK 05000482 l
A PDR l
201 N. Market - Wichita, Kansas - Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
n OATH OF AFF~RMATION STATE OF KANSAS
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COUNTY OF SEDGWICK )
I, Bernard Ruddick, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Engineering of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal for Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, know the contents thereof, and that all statements contained therein are true.
KANSAS GAS AND ELECTRIC COMPANY
/
ATTEST:
By u_ @ _
Bernard Ruddicli
)
Vice President - Engineering E.D. Prothro, Asst. Secretary STATE OF KANSAS
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COUNTY OF SEDGWICK )
i BE IT REMEMBERED that cn this 21st day of October, 1983
, before me,-
Evelyn L. Fry a Notary, personally appeared Bernard Ruddick, Vice President - Engineering of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed the foregoing instru-ment, and he duly acknowledged the executior of the same for and on behalf of and as the act and deed of said Corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the
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&1dateandyearabovewritten.
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fvelyr/L. Fry Notary M5.2ggy;63ifssionexpireson Auguse 1s, 1984.
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i SECTION 6.0 CHANGES WOLF CREEK ONLY The title changes in this section are the result of recent organizational changes at KG&E.
However, the responsibilities and reporting relationships i
of these positions have not changed.
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ADMINISTRATIVE CONTROLS 6.1 -RESPONSIBILITY Mager-6.1.1 The Plant Sonn.;ndent shall be responsible for overall Unit operation and shall delegate in writing the succession to this responsibility during his absence.
6.1. 2 The Supervising Operator, under the Shift Supervisor, 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:
Each on duty shift shall be composed of at least the minimum shift a.
crew composition shown in Table 6.2-1; 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, hw,.,gA.,
2, 3 or 4, at least one licensed Senior Operator shall be in the n
ihc thit h Control room; Phys.<s y~f
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- lth ohy:ic: Techaicir.# shall be on site when fuel is in the AH c.
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 bpigade of at least 5 members snall be maintained onsite e.
at all times.
The fire brigade shall not include 3 members of the l
minimum shift crew necessary for safe shutdown of the Unit and any personnel required for other essential functions during a fire emergency; and b 4 h e-at;,a gem.s hm tky sa s y*y The M lth Phy:ic: T :b-ici.vand fire brigade composition may be less than the minimum 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 accommodate unexpected absence provided immediate action is taken to fill the required positions.
WOLF CREEK - UNIT 1 6-1
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o Section 6.2.2 4
Justification -
This section has been revised to reflect the KG&E response to the' Radiological Assessment Branch Question 471.2wc.
This response is located in the Wolf Creek Generating 2 Station FSAR Addendum.
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ADMINISTRATIVE CONTROLS f.
Administrative procedures shall be developed and implemented to limit the working hours of Unit Staff who perform safety-related functions; e.g., Senior Operators, Operators, Health Physicists, Auxiliary operators, and key maintenance personnel.
Adequateshiftcoverageshallbemaintainedwithoutroutineheavyj use of overtime.
The objective shEll be to havey5perating personnel work a normal 8-hour day, 40-hour week while the plant is operating.
However, in the event that unforseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown 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 <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time; 2)
An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, all excluding shift turnover time; 3)
A break of at least eight hours should be allowed between work periods, including shift turnover time; and 4)
Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.
- R s.pM Any deviation from the above gui,delines shall be y thorize_d by the j e
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~ Plantlupo. intendent or hi; Jet /,~or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.
Controls shall be included in the procedures such that individual overtime shall be reviewed 9"
monthly by the Plant % perint;ndsat or his designee to assure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized.
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WOLF CREEK - UNIT 1 6-2
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s Section 6.2.2.f.
Justification -
The-wording proposed by the NRC'is acceptable provided some minor modifications are made.
This requirement should apply to "shif t" operating personnel.
Because of the common use of the term-
" Operations" in application to all of a Nuclear Power Plant Staff, the present wording would be ambiguous resulting in con-fusion by individuals dealing with Technical Specifications.
In the case of UCGS, the organization does not include a " deputy"
-to the Plant Manager.
This responsibility would be assigned to the individual referred to as the " Call Superintendent."
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This figure shall show the organizational structure and lines of ressonsibility for the offsite groups that provide technical and management support for the unit.
The organizational arrangement for performance and monitoring Quality Assurance activities should also be indicated.
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l Figure 6.2-1 0FFSITE ORGANIZATION WOLF CREEK - UNIT 1 6-3 l
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o:n TU Plant Man: ster I
C2 N
-Supt of Maint
-Supt of Operations
-Supt of Tech Supp
-Supt of Plant Supp
-Supt of Regulatory, Quality and kinin Services
-Maint Sves Supvr
-Ops Coord-Operations
-Reactor Enq Supvr
-Pire Prot. Spec.*
-Quality Control Supvr*
-Maint Ergr l-Shiit Supvr l-l<eactor L29 l-Quality Control Spec
-Warehouse Supvr
-Supervising Opr
-Chief of Security *
{-Warehouse Attd
-Reactor Operator
-IEC Supvr
-Security Ops Supvr
-Safety Specialist
-Utility Mairt Supy
-Station Operator
-tM / Spec
-Lieutenant
-Utility Mech
-Utility Helper
-l&C Tech
-Sergeant
-toctzwnt Cent Supvr
-Dldg Servieman
-Relay Tech
-Officer
-Document Cont Clerk
-Utility llelper
-Analyri: & Film Opr
-Ops Coord-Planning
-Training Supvr and Projects
-Iead Cornputer Eng l-Trainirg tag
-Administrative Supvr
-Maint Supp Super
-Ergineer/ Specialist
-Crxnp Eng/ Spec l-Training Spec l-Clerk
-Mech Super
-Surveillance Coord
-Ctunputer Tech
-Welder
-Utility llelper m
-Machinist
-Results Eng Supur 8
-Mechanic
-Site Chemist
-1<csults tag (M)
-Utility Helper l-Cnmistry Supy
-Results Eng (E)
-Electrical Super
-!!P/Ch m h ch
-Electrician
-Utility Helper
-Utility llelper
-Site Ilealth Phys.*
l-liealth Itiysics Super
-lip / Chm Tech
-Utility llelp e
- fbr hchnical Matters of an immediate nature,the respective individual reports directly to the Plant Manajer.
Figure 6.2-2 WOLF CREEK GENERATING STATION ORGANIZATION l
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'N T le 6.2-1 k
g MINIMUM SHIFT CREW COMPOSITION w SINGLE UNIT FACILITY
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POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION
, MODES 1, 2, 3 & 4 MODES 5 & 6 SS U
1 1
SRO 1
None' RO 2
1 SO 4
1 STA 1*'
Nc,ne CHM 1
None Shift Supervisor with a ior[eratorplicenseonUnit1 k
Individual with a Senior Operator license on Unit 1 Individual with an Operator license on Unit 1 R0 V
stwen
- q ipacat Cperator SO Shift Technical Advisor STA Chemistry Personnel CHM
-Ex :pt for the S!"ft Sup r"iser, 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accomodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimui 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.
During any absence of the Shift Supervisor from the control room while the Unit is in MODES 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 E0DE 5 or 6, ar individual with a l
valid Operator license (other than the Shift Technical Advisor) shall be designated to assume the control room command function.
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"The STA positica may be eliminated when an SRO en :hift :::t: the upc.
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. educational requireacnts for an STA and--the-conttel-room-design-has-been upgr:ded t: EC r;;;uirc;;nt; for clininat-itig-the ST^.-position..
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In. sert-A Shift Technical Advisor is required anytime the Shi2t Supervisor or the Supervising Operator on duty does not meet the educational requirements of a STA as defined in the October 31, 1980 letter from Darrell G.
Eisenhut, Division of Licensing, to all licensees and applicants.
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s Table 6.2-1 Justification -
UCGS has recently completed a college training program which meets or exceeds the requirements recommended in Section 6 of the INPO document " Nuclear Power Plant Shif t Technical Advisor -
Recommendations fot Position Description, Qualification, Educa-tion and Training."
This document is endorsed as guidance for STA training by NUREG-0737.
In addition, five of the seven UCGS Shif t Supervisor candidates have degrees in engineering fields or physics.
Furthermore, the requalification requirements that are set out for GTAs will be included in the SRO requalifications program.
Per UCGS SER item 13.1.3.4 "In the event of unexpected absence through sickness or vacation of the SRO who has been upgraded to the educational requirements of the STA, a similarly qualified SRO replacement or a Duty / Call Technical Advisor will be furnished for that shift.
The applicant has committed to adding this requirement to the administrative controls section of the proposed Technical Specifications.
UCGS, therefore, recommends the note should read "* Shift Technical Advisor is required anytime the Shift Supervisor or Supervising Operator on duty does not meet the educational requirements of an STA as defined in the October 31, 1980 letter from Darrell G.
Eisenhut, Division of Licensing, to all licensees and applicants."
At Wolf Creek the title " Station Operator" is used rather than
" Equipment Operator" for the position identified in Rev. 4 of NUREG-0452 as " auxiliary operator."
Since the term " equipment operator" is undefined in the UCGS organization structure and procedure and is not a commonly accepted term at UCGS, its use would Icad to confusion and misinterpretation by personnel using the Technical Specifications.
Our recommendation is to hereafter use the term " Station Operator" in all Technical Specification entries.
The intention of the first paragraph on page 6-5 would appear to ensure immediate action is taken to ensure a minimum crew com-position is restored following an unexpected absence of on-duty shift crew members.
It is inappropriate to assume that the Shift Supervisor is immune from unforeseen causes of absence.
Sudden illnesses, for example, are completely out of any control of KG&E.
Therefore, inclusion of the term "except for the Shift Supervisor" would not realistically ensure that the Shift Supervisor is present but would only result in generation of a Technical Specification violation.
As such, it is an unrealistic paperwork requirement which will not add to the safety of the public or the facility.
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ADMINISTRATIVE CONTROLS 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.
COMPOSITION 6.2.3.2 The ISEG shall be composed of at in:t fin, d:di::t:d,-fe"-t' c engi ce- 'eested er !!te.
Each eM1' 5 e e Meheler's degree 4a e ;ineer ng i
= nl:t;d ::iun ud :t in:t 2 y==iedp = f: =i = 1 i m i =p ri =:: ir. hi:
ena - cu su p t.n ed ded;m onsite gro9 v.m n minie tw}+:
u, opp c,.de.
sp aJists.
assigne.d c.yic t.
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engneers er RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification
- that these activities are performed correctly and that human errors are reduced as much as practical.
AUTHORITY 6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of iroroving plant safety to the Manager, Nuclear Safety and Emergency Preparedness and the Manager, Call w:y P knt. im d Anaye,
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6.2.4 SHIFT TECHNICAL ADVISOR when rey:c,A The Shift Technical Advisor provide technical support to the Si.!ft 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 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 R dicticr. Irctectier 53= b b 1
. = g:r who shall meet or exceed the qualifications of Regulatory Guide 18, Ph 5M September 1975.
- Not responsible for sign-off function.
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s Section 6.2'.3.2 Justification -
In Section 18.1.7.2 of the Wolf Creek FSAR Addendum, KG&E indicates that ISEG will be staffed by degreed or equivalent individuals in the following disciplines:
nuclear engineering, mechanical engineering, electrical engineering, plant chemistry, radiological controls, and nuclear operations.
In order to permit the maximum versatility and coverage of the areas described above with the most qualified personnel, KG&E believes that it should not be limited to hiring only engineers to fill those positions.
For example, individuals with chemistry degrees, health physics degrees, or other types of degrees but with specific experience in various areas might best cover the intended disciplines.
In addition, individuals with extensive experience such as ex-shift supervisors could be used to give the ISEG group added experience.
The experience requirements in Section 6.2.3.2 have been deleted since NUREG-0737 and the Westinghouse Standard Technical Specifica-tions do not specify experience criteria.
These requirements would prohibit the hiring and training of otherwine qualified parsonnel for ISEG positions.
Section 6.2.4 Justification -
The wording specified by the NRC is acceptable provided the caveat in regards to the note to Table 6.2-1 is used.
For further information, see the change justification for Table 6.2-1.
The recommended wording would be "A Shift Technical Advisor, when required, shall provide..."
Section 6.3.1 Justification -
The title of Site Health Physicist is defined in the Radiation Protection Manual.
KG&E has identified the Site Health Physicist as the RPM and this position has the responsibility and authority as outlined in Regulatory Guide 3.8, NUREG-0654 and other applicable regulations and guides.
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ADMINISTRATIVE CONTROLS 6.4 TRAINING A retrainina and replacement training program for the unit staff shall Supe <4w-w oisk u 6.4.1 be maintained under th? dir;;tica of the Sup;rintend:nt :f Trainingrand shall meet or exceed the requirements and recommendations of Section 5 of ANSI /
and Appendix "A" of 10 CFR Part 55 and the supplemental require-ANS 3.1-1978 28, 1980 NRC ments specified in Section A and C of Enclosure 1 of the March letter to all licensees, and shall include familiarization with relevantpimi yeof-anch industry operational experience identified by the ISEG,or 6.5 REVIEW AND AUDIT 6.5.1 PLANT SAFETY REVIEW COMMITTEE (PSRC)
FUNCTION The Plant Safety Review Committee shall function to advise the Plant 6.5.1.1 Superintendent on all matters related to nuclear safety.
COMPOSITION The Plant Safety Review Committee shall be composed of the:
- 6. 5.1. 2 rwec<
Chairman:
Plant Superi..t ndent af Of *"** '
"I'" e Supervi::r SeputJead*al Oper ti n:
T :hnicci Supp:rt Super"icer Suraihdd d T"b""d Member:
Member:
.aint nen;; Sc;;rvi: r survia+dd
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Member:
Instrument and Control Supervisor Member:
Reactor Engineering Supervisor Member:
Member:
Health Physicist Member:
Chemist Results Engineering Supervisor Member:
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ALTERNATES All alternate members shall be appointed in writing by the PSRC l
6.5.1.3 l
Chairman to serve on a temporary basis; however no more than two alternates shall participate as voting members in PSRC activities at any one time.
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f A'abe :
Sep u;n 6 de.d. 4 of Tepktery, bl%t,a2 A b *iS M "
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WOLF CREFK - UNIT 1 6-7
r K-l Section 6.4.1
-Justification -
In general the NRC proposed wording is similar to that proposed by WCGS.
The less restrictive use of the words " direction of" can be used in place of our proposed wording " administration of" although KG&E prefers the latter.
In regards to the title, Rev. 4 of NUREG-0452, does not specifically incorporate the standardized title " Superintendent of Training" but allows the applicant to insert the position title.
The position title at WCGS is Training Supervisor.
The review of relevant industry operational experience at WCGS is not the responsibility of the ISEG.
Tnis function falls under the administration of the UCGS Results Engineering Group and is a total plant staff responsibility.
KG&E, therefore, recommends "or another plant group" be added to the last sentence.
(A ADMINISTRATIVE CONTROLS MEETING FREQUENCY 6.5.1.4 The PSRC shall meet at least once per calendar month and as convened by the PSRC Chairman or his designated alternate.
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QUORUM 6.5.1.5 The minimum quorum of the PSRC necessary for the performance of the PSRC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and sow members including alternates.
p, RESP 0NSIBILITIES 6.5.1.6 The Plant Safety Review Committee shall be responsible for:
a.
Review of: (1) all procedures required by Specification 6.8 and changes thereto, (2) all programs required by Specification 6.8 and changes thereto, and (3) any other proposed procedures or changes thereto as determined by the Plant k ;rir.t;ni at to affect nuclear safety; be^ 7 b.
Review of all proposed changes, tests and experiments which may involve an unreviewed safety question as defined in Section 50.59, 10 CFR; c.
Review of all proposed changes to Technical Specifications or the Operating License; d.
Review of all safety evaluations performed under the provision of Section 50.59(a)(1), 10 CFR, for changes, tests and experiments; Investigation of all violations of the Technical Specifications e.
including the preparation and forwarding of reports covering evalua-tion and recommendations to prevent recurrence to the Director, Nucleat Operations, and to the Nuclear Safety Review Committee (NSRC);
f.
Review of events requiring 24-hour writ. ten notification to the Commission; Review of reports of operating abnormalities, deviations from expected g.
performance of plant equipment and of unanticipated deficiencies in l
l the design or operation of structures, systems or components that affect nuclear safety; h.
Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman, NSRC; Review of the plant Security Plan and implementing procedures *and i.
shall submit recommended changes 4to the NSRC; MN s<m..h t'kn j.
Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the NSRC; WOLF CREEK - UNIT 1 6-8 prec ulu,es J. it be rev;med by
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Section 6.5.1.5 Justification -
The minimum quorum of-the PSRC has been increased from four to five as a result of the increased size of the Wolf Creek PSRC.
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Justification -
The review of Security Plan implomonting procedures by the complete Plant Safety Review Committee would unnecessarily disseminate the procedures to an unacceptable level'of personnel.
This could potentially minimize the value of the procedares, depending on the identity of an " insider" involved in a security incident.
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Review of changes to the PROCESS CONTROL PROGRAM, and the OFFSITE DOSE CALCULATION MANUAL; and h
accidental, unplanned, or uncontrolle 1.
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n release inc uoms t" e aration of repor
, mg evaluation, y
recommendations, and dispos corrective ACTION to prevent recurrence and ing of these re he Manager, C31,1 n and to the Nuclear Safety Review Boar.
AUTHORITY 6.5.1.7 The Plant Safety Review Committee shall:
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Recommend in writing to the Plant O p;n nt;nd;nt approval or disapproval a.
of items considered under Specification 6.5.1.6a. through d. above, b.
Render determinations in writing with regard to whether or not each item considered under Specification 6.5.1.6a. through e. above constitutes an unreviewed safety question, and c.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Director Nuclear Operations and the Nuclear Safety Review Committee of disagreement A a$ce between the PSRC and the Plant % pe. int;nd;nt; however, the Plant
% u-perint;nd:nt shall have tcsponsibility for resolution of such disagreements pursuant to Specification 6.1.1 above.
RECORDS 6.5.1.8 The Plant Safety Review Committee shall maintain written minutes of each PSRC meeting that, at a minimum, document the results of all PSRC activ-ities performed under the responsibility and authority provisions of these Technical Specifications.
Copies shall be provided to the Director, Nuclear Operations, and the Nuclear Safety Review Committee.
6.5.2 NUCLEAR SAFETY REVIEW COMMITTEE (NSRC) l FUNCTION i'
6.5.2.1 The Nuclear Safety Review Committee shall function to provide independent review and audit of designated activities in the areas of:
a.
Nuclear power plant operations, j
b.
Nuclear engineering, i
c.
Chemistry and radiochemistry, d.
Metallurgy, e.
Instrumentation and control, f.
Radiological safety, WOLF CREEK - UNIT 1 6-9 l-
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K-l Insert B Review of every unplanned onsite release of radioactive material to the environs, including the preparation and forwarding of reports covering evaluation, recommendations, and disposition of
'the corrective action to prevent recurrence to the Plant Manager and to the. Nuclear Safety Review Committee.
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Justification -
The words proposed by the NRC are not included in Rev. 4 of NUREG-0452 and appear to have come from the Callaway Technical Specifications.
The wording proposed by KG&E are the appropriate words for the WCGS Technical Specifications.
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Mechanical and electrical engineering, and
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Quality assurance practices.
COMPOSITION 6.5.2.2 The NSRC shall be composed of the:
Chairman:
Manager Nuclear Services, KG&E Member ; ',' ice Chair;;n.
Manager Nuclear Plant Engineering, KG&E Member:
Quality Assurance Coordinator, KG&E Member Director Nuclear Operations, KG&E Member:
Manager Licensing, KG&E Member:
Vice President-Engineering, KG&E Member:
Manager Safety Engin ring 90cteu ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the NSRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in NSRC activities at any one time.
CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the NSRC Chairman to provide expert advice to the NSRC.
MEETING FREQUENCY 6.5.2.5 The NSRC 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 NSRC necessary for the performance of the NSRC review and audit functions of these Technical Specifications shall consist of the Chairman or his designated alternate and at least four NSRC members including alternates.
No more than a minority of the quorum shall have line responsibility for operation of the Unit.
WOLF CREEK - UNIT 1 6-10 e
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K-l Specification 6.5.2.2 Justification -
There -are no standard technical specification requirements for an NSRC Vice-Chairman, therefore, this has been deleted from the specification.
A recent KG&E reorganization changed the title Manager Safety Engineering to Manager Nuclear Safety.
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g-l ADMINISTRATIVE CONTROLS
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The performance of activities required by the Operational Qualit Assurance Program to meet the criteria of Appendix "B", 10 CF
.O, Se._
1 east once per 24 months; few 4-
- 1, Any er area of Unit operatio considered appropriat y the NSi}B A
or the e President-Nuclear @
dL The fire pro ction programmatic controls inclu ' g the implementing procedures at st once per 24 months by qu fied licensee QA personnel; J.
The fire protection eq ~ ment and pro implementation at least U
once per 12 months utiliz either qualified offsite licensee fire protection engineer or o
ide independent fire protection consultant.
An outside indep t fire protection consultant shall be used at least every thir ear; A.
The Radiological Enviro ental Monitor 1 Program and the results f
thereof at least onc er 12 months; k
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The ODCM and imp enting procedures at least e per 24 months;
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The PROCESS TROL PROGRAM and implementing proce es for processing i
and packa g of radioactive vastes at least once per months; causa The p ormance of activities required by the Quality Assu ce Prpgram to meet the provisions of Regulatory Guide 1.21, ~.c.. : gg g/
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":.i:fr 1, 'pr" 1r5, at least once per 12 mon AUTHORITY 6.5.2.9 The NSRC shall report to and advise the Vice President-Nuclear on those areas of responsibility specified in Specifications 6.5.2.7 and 6.5.2.8.
RECORDS 6.5.2.10 Records of NSRC activities shall be prepared, approved and distributed as indicated below; a.
f each NSRC meeting shall be prepared, ap; roved and f h.
to the Vice t-Nuclear within 14 days foi meeting;
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e, b.
Reports of reviews encompas 1 ication 6.5.2.7 above, shall be prepared n forwarded to resident-Nuclear ays following completion of the review; an Audit reports encompassed by Specification 6.5.2.8 above, shall be c.
forwarded to the Vice President-Nuclear and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.
en WOLF CREEK - UNIT 1 6-12
K -l
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INSERT A d.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B",
10 CFR 50, at least once per 24 months.
e.
The Emergency Plan and implementing procedures at least once per 12 months.
f.
The Security Plan and implementing procedures at least once per 12 months.
g.
Any other area of unit operation considered appropriate by the NSRC or the Vice President-Nuclear.
h.
The Fire Protection Program and implementing procedures at least once per 24 months.
i.
An independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
j.
An inspection and audit of the fire protection and loss prevention program to be performed by an outside qualified fire consultant at intervals no greater than 3 years.
k.
The radiological environmental monitoring program and the results thereof at least once per 12 months.
1.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
m.
The PROCESS CONTROL PROGRAM and implementing procedures for solidification of radioactive waste at least once per 24 months.
n.
The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977 at least once per 12 months.
K-l s
Insert B a.-
Minutes of each NSRC meeting shall be prepared, reviewed by participating members and forwarded to the Vice President -
Nuclear within 14 days'following each meeting.
b.
Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, reviewed by participating members and forwarded to the Vice President - Nuclear within 14 days following completion of the review.
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K -l Specification 6.5.2.8 Justifications -
Items 6.5.2.8.e through 6.5.2.8.k are from Callaway's submittal not Wolf Creek's submittal.
Please use the attached Wolf Creek 1
submittal.
The_words "by qualified licensee, QA personnel" were deleted from item h (KG&E version), since at Wolf Creek the audit may be performed by ISEG or QA personnel.
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K-l Specification 6.5.2.10 Justification -
The approval mechanism for NSRC records is such that approval is provided at the next regularly scheduled NSRC meeting.
The'words 4.n the NRC draft version would require a second NSRC meeting to oe 'neld within 14 days to approve these records.
To avoid this,
use the insert words provided by KG&E.
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ADMINISTRATIVE CONTROLS 6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for REPORTABLE OCCURRENCESi 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 o
Commission shall be reviewed by the PSRC and submitted to the NSRC and the Vice President-Nuclear.
6.7 SAFETY LIMIT VIOLATION 6.7.1 The following ACTION 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The Vice President-Nuclear and the NSRC shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; b.
A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the PSRC.
This report shall describe: (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective ACTION taken to prevent recurrence; The Safety Limit Violation Report shall be submitted to the Commission, c.
the NSRC 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..
Written procedures shall be established, implemented, and maint 'ned j
covering activities referenced below:
a.
The app le procedures recommended in Append ~
A", of Regulatory f
Sec Guide 1.33, e
ion 2, February 1978, l
in w t.
c b.
Refueling operations, c.
Surveillance and test act' ' 1es ofssafety-related equipment, d.
Security Plan im
- entation, e.
Emergen an implementation, s
WOLF CREEK - UNIT 1 6-13 A
K-I 4
ADMINISTRATIVE CONTROLS f.
Fire Proti::ction Program implementation, g.
rocess Control Program implementation, N6 h.
ODC lementation, and
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Progra::: for ffluent and environmental monito 'ng, using the guidance in Fiegulatory ide 4.15, December 1977.
6.8.2 Each procedure of Speci ication 6.8.1 ve, and changes thereto, shall be reviewed prior to implementatio as set orth in Specification 6.5 above.
6.8.3 Temporary changes to procedur of Specification 6.8.1 above, may be made provided:
a.
The intent of th original procedure is not altered;
\\
b.
The chang s approved by two members of the plant management staff, at lea.
one of whom holds a Senior Operator lic'ense on the Wolf Crep (Generating Station; and N
e change is documented, reviewed by the PSRC, and ap ro'ved by the c.
/
Plant Superintendent within 14 days of implementation.
'x 6.8.4 The following programs shall be established, implemented, and maintairied:
a.
Primarv Coolant Sources Outside Containment r
A program to reduce leakage from those portions of systems outside
D containment that could contain highly radioactive fluids during a
}f3Cs
sy Re W h i d; 0 ; 7:n
_::S 7:-d;n of the containment spray,anp4em, serious transient or accident to as low as practical levels. The Sp*
darety Injectiont enemical and volume cor.troM 'n:t; C;;5 System, anoug.
"draa-r recombine e.
The proaram shall include the following:
SG o b ugu$sp,.,cass..,g, 1)
Preventive maintenance and periodic visual inspection requirements, and 2)
Integrated leak test requirements for each system at refueling cycle intervals or less.
b.
In-Plant Radiation Monitorinj A program which will ensure the capability to accurately determine i
the airborne iodine concentration in vital areas under accident j
conditions.
This program shall include the following:
l 1)
Training of personnel, l
2)
Procedures for monitoring, and 3)
Provisions for maintenance of sampling and analysis equipment.
1 WOLF CREEK - UNIT 1 6-14 l
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K-l Insert C 6.8.1 The plant shall be operated and maintained in accordance with approved procedures.
Major procedures, supported by appropriate Minor procedures (such as checkoff lists, operating instructions, data sheets, alarm responses, e tc. ) shall be provided for the following operations where these operations involve nuclear safety of the plant:
a.
The applicable procedures recommended in Appendix "A" Gf Regulatory Guide 1.33, Rev.
2, Feb. 1978 b.-
Refueling operations c.
Emergency plan implementation d.
Surveillance and Testing of safety-related equipment e.
Fire Protection Program implementation f.
Process Control Program implementation 9
Offsite Dose Calculation Manual implementation A Major Procedure is a procedure which controls ' safety-related' activities, and establishes one or more basic controls, overall responsibilities, authority assignments or administrative and operational ground rules at the WCGS.
Major Procedures are written to meet the requirements of ANSI N18.7-1976/ANS 3.2 and generally are supported by Minor Procedures which provide delineation of details such as for valve lineups, calibration procedures, operating instructions, data sheets, alarm responses, and other procedures identified as " supporting. "
Major Procedures require signature approval in all cases by the Plant Manager or a Call Superintendent in his absence.
A Minor Procedure is a procedure which controls ' safety-related' activities in support of a Major Procedure.
It addresses a specific topic or sub-topic established by its
' parent' Major Procedure, expanding on it by providing working level. instructions.
Minor Procedures are not permitted to contradict requirements contained in their governing Major Procedure.
Minor Procedures require signature approval by the Plant Manager, or a Call Superintendent in his absence, only at Revision 'O. '
I I
i 6.8.2 Approval of Procedures l
l a.
All Major procedures of the categories listed in l
6.8.1 and modifications to the intent thereof shall be reviewed by the Plant Safety Review Committee and
K -l INSERT C (cont'd) approved by the Plant Manager prior to implementation and reviewed periodically as set forth in Administrative Procedures.
b.
Minor procedures (checkoff lists, operating instructions, data sheets, alarm. responses, chemistry and analytical procedures, technical instructions, special and routine maintenance procedures, laboratory manuals, etc.) shall, prior to initial use, be approved by the PSRC or a Subcommittee thereof.
6.8.3 Changes to Procedures a.
Temporary changes to Major procedures, of the cate-gories listed in 6.8.1 which do not change the intent or generate an unroviewed safety question of the original or subsequent approved procedure, may be made provided such changes to operating procedures are approved by the Shif t Supervisor (SRO licensed) and one of the Call Superintendents.
For temporary changes to Major procedures under the jurisdiction of Maintenance, Instrumentation and Control, Reactor Engineering, Chemistry, or Health Physics which do not change the intent or generate an unreviewed safety question, changes may be made upon approval of the Cognizant Group Leader and a Call Superintendent.
All temporary changes to Major procedures (made by a Call Superintendent and either a Cognizant Group Leader or the Shift Supervisor) shall subsequently be reviewed by the Plant Safety Review Committee and approved by the Plant Manager within 2 weeks; except that temporary changes to Maior procedures made during a refueling outage may be reviewed and approved at any time prior to initial criticality of the reload core.
All permanent changas to Maio procedures shall be made in accordance with Step.
6.8.2.a.
b.
All temporary or permanent changes to Minor operating procedures (checkof f lists, alarm responses, data sheets, operating instructions, etc.) shall be approved by the Shif t Supervisor, and shall be subsequently reviewed and approved by the Operations PSRC Subcom-mittee.
All temporary or permanent changes to other Minor procedures under the jurisdiction of Maintenance, Instrumentation and Control, Reactor Engineering, Chemistry, or Health Physics, shall be approved by a Cognizant Group Leader and shall be subsequently reviewed and approved by the appropriate PSRC Subcommittee.
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Sections 6.8.1 through 6.8.3 Justification -
The KG&E procedures section is tailored to the concept presently approved by the NRC at the Point Beach Nuclear Plant, Units 1 and 2, Wisconsin Electric Power Co.
This concept, the concept of major and minor procedures has proven over the past 10 years to be an effective, appropriate and reliable method of establishing the proper 1cvel of control over procedures.
It is more restrictive than some recent approved Technical Specifications because it includes review of all safety-related procedures before the PSRC er a subcommittee thereof.
The area of approval of changes to procedures is also modeled after the approved Point Beach Technical Specifications and has been very offective.
The concept of license required approval for procedures not operational in nature is an imposition on the senior licensed personnel which is not in accordance with the concepts and direction of the NRC to minimize the administrative burden on the Shift Supervisor.
Section 6.8.4.a Justification -
The wording proposed by KG&E is appropriate to the WCGS design.
For instance, the hydrogen recombiners are located inside containment with no connection external to containment.
The ECCS and Nuclear Sampling System (Post-Accident Sampling System only) each provide a path for primary coolant outside containment during an accident.
i 1
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K-l e
O ADMINISTRATIVE CONTROLS c.
Secondary Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation.
This program shall includi:
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 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 l
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 include the following:
1)
Training of personnel, 2)
Procedures for sarnpling and analysis, and l '
3)
Provisions for maintenance of sampling and analysis equipment.
- 6. 9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requiremer.ts of Title 10, Code of Federal Regulations, the following reports shall se 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 shall be submitted following: (1) receipt of an Operating Licensc, (2) amendment to the license involving a planned increase in power level, (3) %stallation 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.
WOLF CREEK - UNIT 1 6-15
K-\\
O ADMINISTRATIVE CONTROLS
- 6. 9.1. 2 The STARTUP Report shall address each of the tests identified in the Final Safety Analysis Report FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications.
Any corrective ACTIONS that were required to obtain satisfactory operation shall also be described.
Any additional specific details required in license conditions based on other commitments shall be included in this report.
6.9.1.3 STARTUP Reports shall be submitted within: (1) 90 days following completion of'the STARTUP test program, (2) 90 days following resumption of commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest.
If the STARTUP Report does not cover all 1
three events (i.e., initial criticality, completion of STARTUP test program, and resumption or commencement of commercial operation) supplementary reports i
shall be submitted at least every three months until all three events have been completed.
ANNUAL REPORTS 6.9.1.4 Annual Reports covering the activities of the Unit as described below 3
for the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year following initial criticality.
6.9.1.5 Reports required on an annual basis shall include:
- a. 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 mainte-nance (describe maintenance), waste processing, and refueling. The dose l
assignments to various duty functions may be estimated based on pocket dosimeter, TLO, or film badge measurements.
Small exposures totalling iess than 20% of l
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; and b.
Documentation of 44+ unglaaned
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2This tabulation supplements the requirements of $20.407 of 10 CFR Part 20.
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WOLF CREEK - UNIT 1 6-16
K-1 Section 6.9.1.5 Justification -
The wording used_in the original WCGS proposal was taken from NUREG-0452'(Rev. 4) in an e.ffort to maintain standardized wording.
WCGS would have min'imal problems including this sentence on PORVs and safety valves provided it is reworded for clarity.
For s
example, what is a " challenge" to the above valves.
The sentence should be clarified to road." Documentation of unplanned openings or a failure to open or close when required of the pressurizer -
power-operated relief valves (PORVs) and safety valves.-
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E-t ADMINISTRATIVE CONTROLS ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING' REPORT
- 6.9.1.6 Routine Radiological Environmental Operating Reports covering.the operation of the Unit during the previous calendar year shall be submitted by prics t; May 1 of each year. The initial report shall be submitted pri:r t: by May 1 of the year following initial criticality.
c s
The Annual Radiological Environmental Operating Reports'shall include summaries, interpretations,,and an analysis of trends of the results ofithe radiological environmental surveillance activites for the report period, including a comparison 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 inc'.ude the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations <pecified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological. Assessment Branch Technical Position, Revision 1, November 1979.
In the event that soma individual results are not available for inclusion with the report, the' report shall be submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted as soo'n as possible in a supplementary report.
The reports shall also include the following:
a summary description of the 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 5% reactor; the results of licensee participation in the Interlaboratory Comparison Program, required by Specification 3.12.3; iscussion of all deviations from r.ne sampling schedule of Table 3.12 4; and discussion of all analyses in which the LLD required by Yable 4.12-1 was not achievable.
b I cc *h **5 reA> % 4o 5r3 accordanc.g.
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- A :ingi; :stmitt:? n y b; ::d: f;r : =;itip?: unit st: tion.
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- 0ne map shall cover stations near the SITE BOUNDARY; a second shall include the more distant stations.
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K-1 Section 6.9.1.6 Justification -
Changing " prior to" to "by" conforms with guidance provided in the Radiologic 6).-Assessment Branch Technical Position, Revision 1, November 1979.
Since radiological / environmental reporting will be included in the Annual Radiological / Environmental Operating Report (see the Justification of Section 6.9.17), the following words were added:
" revisions to sampling locations in accordance with Specification 3.12.2."
Adding the option to report the EPA pr". gram code designation climinates duplication of effort and allows KG&E greater flexibility in its program.
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Ki ADMINISTRATIVE CONTROLS SEMIANNUAL RADIOACTIVE 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 summaiy of the quantities of radioactive liquid and gaseous effluents and solid waste released 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 quarteriy basis following the format of Appendix B thereof.
The Radioactive Effluent Release Report to be submitted 60 days after January 1 of each year shall also 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 speeo, wind direction, and atmospheric stability.** This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous a.ffluents released from the Unit or Station during the previous calendar year.
This same report shall also include an assessment of the raolation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities 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 meteorological conditions concurrent with the time of release of radicactivs 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 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 fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conforence with 40 CFR Part 190, " Environmental Radiation Protection Standards for Nuclea. 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 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 required i
l meteorological data on site in a file that shall be provided to the NRC i
upon request.
WOLF CREEK - UNIT 1 6-18 i
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K-1 ADMINISTRATIVE CONTROLS Operation." Acceptable methods for calenlating 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 of,f site during the report period:
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),
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 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 shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM and to the ODCM. as well as a listing of new locations for dose calculations and/:r crl'r:rt:nt:1
- niter #n; identified by the land use census pursuant to Specification 3.12.2.
MONTHLY OPERATING REPORT
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,, gno,4 c,,,.ny 6.9.1.8 Routine reports of ope ting statistics and shutdown experience, including documentation of allksha!!:n; : t: the PORV; or safety valves, shall be submitted on a monthly basis to the Director, Office of Resource Management, U.S. Nuclear Regulatory Commission, 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.
REPORTABLE OCCURRENCES 6 Q The REPORTABLE OCCURRENCES of Specifications G.9.1.10 and 6.
below, inel corrective ACTIONS and measures to pro en ence, shall lemental reports ma qu red to fully describe be reported to the final resolution of occurrence.
orrected or supplemental reports, a Licensee Event Report sha mplete ference shall be made to the original report d WOLF CREEK - UNIT 1 6-19
K;)
a
.s ADMINISTRATIVE CONTROLS PhMPTNOTIFICATIONWITHWRITTENFOLLOWUP
- 6. 9.
10 The types of events listed below shall be reported ~within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by tel hone and confirmed by telegraph, mailgram', or facsimile transmiss'on to the gional Administrator of the NRC Regional Office, or his design e, no later tha the first working day following the event, with a written f lowup report with'n 14 days. The written followup report shall include, a a minimum,
,a completed py of a Licensee Event Report form.
Information prov'ded on the Licensee Event seport form shall be supplemented, as needed, by a itional
.P narrative materi i to provide complete. explanation of the circum tances
~
surrounding.the' e nt..
a.
Failure of he Reactor Trip System or other syste subject to
~
' Limiting Saf y System Settings to initiate the equired protective function by th time a monitored parameter rea es the Sotpoint
.specified as th limiting Safety System Setti g in the Technical Specifications or failure to complete the r uired trip function; b'.
Operation of.the uni or affected system when any parameter or operation subject to a Limiting Conditi n for Operation is less conservative than the 1 st conservat' e aspect of the Limiting Condition for Operation e tabli'shed 'n the Technical Specifications;
.(P.3-c.
Abnormal degradation discove di. fuel cladding, reactor coolant
, pressure boundary, or primary.
tainment; Q
d.
Reactivity anomalies involvi di greement with the predicted value of reactivity balance under steady-tate conditions during power operation greater than or qual to Ak/k; a calculated reactivity balance indicating a SHU" OWN MARGIN 1 ss conservative than specified in the Technical Speci cations;.short. rm reactivity increases that correspond to a eactor period of le than 5 seconds or, if subcritical, an unp nned reactivity insert'on of more than 0.5%
Ak/k; or occurrenc of any unplanned critica 'ty;
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Failure or malf nction of one or more component., which prevents or e.
- could prevent by itself, the fulfillment of the unctional requirements of system (s) used to cope with accide s analyzed in the SAR; f.
Personn error or procedural inadequacy which prevents r could pre'ven, by itself, the fulfillment'of the functional req irements of s tems required to cope wth accidents analyzed in the R;
g.
C ditions arising from natural or man-made events that, as a irect 3
esult of the event require unit shutdown, operation of safety systems, or other protecti u measures required by Technical Specifications; C.
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l(-l ADMINISTRATIVE CONTROLS Errors discoverea in the transient or accident analyses or in the methods used for such analyses as described in the Final Safety Analysis Report or in the bases for the Technical Specification that have or could have permitted reactor operation in a mann less onservative than assumed in the analyses; i.
Pe ormance of structures, systems, or components that re uires reme ial action or corrective measures to prevent opera on in a manne less conservative than assumed in the accident nalyses in the Fin 1 Safety Analysis Report or Technical Specif
- ations bases; or disco ry during Unit life of conditions not sp ifically considered
'in the Fin 1 Safety Analysis Report or Technical
'ecifications that require rem tal action or corrective measures prevent the existence or developmen of an unsafe condition; and J.
Failure of one o more pressurizer PORVs or safety valves.
THIRTY DAY WRITTEN REPORTS II 6.9.1. E The types of events 11 ted below shal be the subject of written reports to the Regional Administr tur of the C Regional Office within 30 days of occurrence of the event.
T e writt report shall include, as a minimum, a completed copy of a Licen ee Ev nt Report form.
Information provided on the Licensee Event Report form sha supplemented, as needed, by additional narrative material to provi complete explanation of the circumstances surrounding the event.
a.
Reactor Trip System or E ineered afety Features Instrumentation Setpoints which are fo d to be le conservative than those established by the Te nical Specifi tions but which do not prevent the fulfillment of e functional regtYrements of affected systems; b.
Conditions leadi to operation in a deg ded MODE permitted by a Limiting Condit~on for Operation or plant hutdown required by a Limiting Cond' ion for Operation; c.
Observe in 'equacies in the implementation of ministrative or Procedur Controls which threaten to cause red tion of degree of redunda cy provided in Reactor Trip Systems or En ineered Safety Featur s Systems; and I
d.
Ab rmal degradation of systems other than those spec ied in S ecification 6.9.1.11c above, designed to contain radi active aterial resulting from the fission process.
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e.
An unplan offsite release of:
(1) more than 1 Curie if ra'd
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material in id effluents, (2) more than 150 Curies of n e gas in gaseous efflu s, or (3) more than 0.05 Curie of radi odine in gaseous effluents.
s report of an unplanned offsit elease of radioactive material sh 1 include the following in rmation:
1)
A description.of the eve and equipment 'nvolved, 2)
Cause(s) for the unplanned rele e
3)
Actions taken to prevent rec' ence, a 4)
Consequences of the un nned r'elease.
i f.
Measured levels of rad' activity in an environmental sam ing medium determined to excee he reporting level values of Table 3.
-2 when averaged over an calendar quarter sampling period.
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Justification -
4 All information concerning the Radiological Environmental Monitoring Program will be included in the Annual Radiological Environmental Operating Report to eliminate duplication of effort.
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See the justification for Section 6.9.1.5.
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. These sections have been deleted to meet the new reporting require-ments specified in 10CFR50.73..
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e ADMINISTRATIVE CONTROLS RADIAL PEAKING FACTOR LIMIT REPORT 6.9.1.kTheF limit for Rated Thermal Power (FRTP)shallbeprokidedto xy xy t'he Regional Administrator of the NRC Regional Office, with a copy to the Director, Nuclear Reactor Regulation, Attention:
Chief, Core Performance Branch, U.S. Nuclear Regulatory Commission, Washington, D.C.,
20555, for all core planes containing Bank "0" control rods and all unrodded core planes at least 60 days prior to cycle initial criticality.
In the event that the limit would be submittsd 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.
RTP Any information needed to support F will be by request from the NRC and x
need nct be included in this report.
SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Regional Ad'ministrator of the NRC Regional Office within the time period specified for each report.
6.19 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 i
the minimum period indicated.
6.10.1 The following records shall be retained for at least 5 years:
Records and logs of unit operation covering time interval at each a.
power level; l
b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipmant related to I
nuclear safety; All REPORTABLE OCCURRENCES submitted to the Commission; c.
d.
Records of surveillance activities, inspections, and calibrations f
i required by these Technical Specifications; Records of changes made to the procedures required by e.
Specification 6.8.1; f.
Records of radioactive shipments; Records of sealed source and fission detector leak tests and results; g.
and h.
Records of annual physical inventory of all sealed source material of record.
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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 materici 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
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Unit Staff; h.
Records of in-service inspections performed pursuant to these Technical Specifications; i.
Records of Quality Assurance activities required by the QA Manual; j.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59; ps y pe,
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Records of meetings of the O r and the NJRB; 1.
Records of the service lives of all snubbers listed in Tables 3.7-4a and 3.7-4b including the date at which the service life commences and associated installation and maintenance records; m.
Records of secondary water sampling and water quality; and Records of analysis required by the radiological Environmental n.
Monitoring Program.thct wculd per-f t " l= tier ef the accu *ecy of tha sneloe4e s+
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6.11 RADIATION PROTECTION PROGRAM 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.
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b Specification 6.10.2.n Justification ~-
The " accuracy of the analysis" will be verified by NRC audit functions.
If these audits show the analysis to be reliable, then only the final reports need to'be retained for the duration of the Unit Operating License.
Retention of other documentation would serve no useful purpose.
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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 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 Permit-(RWP)*. Any individual or group of individual; permitted to enter such areas shall be provided with or accompanied by one or more of the following:
A radiation monitoring device which continuously indicates the a.
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 present integrated dose is received.
Ent y into such areas with this monitoring device may be made after tne c se rate level in the area has been established and personnel have been made knowledgeable of them; and A health physics qualified individual (i.e., qualified in radiation c.
protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the RWP.
6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose greater than 1000 mrem shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Supervisor and/or Site Health Physicist.
Doors shall remain locked except during 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose in excess of 1000 mrem ** 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.
"Heaith 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 entry into high radiation areas.
- Measurement made at 18" from source of radioactivity.
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ADMINISTRATIVE CONTROLS 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implemdntation.
6.13.2 Licensee-initiated changes to the PCP:
Shall be submitted to the Commission in the Semi-annual Radioactive a.
Effluent Release Report for the period in which the change (s) was made. This submittal shall contain:
1)
Sufficiently detailed information to totally support the rationale for the change wthout 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 SRE. Pstc.
b.
Shall become effective upon review and acceptance by the PSRC.
6.14 0FFSITE 00SE CALCULATION fiANUAL (00CM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation.
6.14.2 Licensee-initiated changes to the ODCM:
Shall be submitted to the Commission in the Semi-annual Radioactive a.
' Effluent Release Report for the period in which 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 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 QSO'.RC -
b.
Shall become effective upon review and acceptance by tfie PSRC.
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s(f ADMINISTRATIVE CONTROLS 7
6.15 MAJOR CHANGES TO RADIOACTIVE GASEOUS. AND SOLIO WASTE TREATMENT S 6.15.1 Licensee-initiated major changes to the Radioactive Waste Systems (liquid, gaseous, and solid):
Shall be reported to the Commission ia the Semi-annual Radioactive a.
Effluent Release Report for the period in which the evaluation was reviewed by the g The discussion of each change shall contain:
1)
A summary of the evaluation that led tc the determination that the change could be made in accordance with 10 CFR 50.59; 2)
Sufficient detailed information to totally support the reason for the change without benefit of adcitional and supt emental information; 3)
A detailed description of the equipment, components, and processes involved and the ir.terfaces with other plant systtms.
k 4)
An evaluation of the change which shows the prEicted releases of radioactive ma orials in licuid and gaseous.ffluents and/or
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quantity of solid waste that differ from those ireviously
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predicted in the license application and amenoments thereto; 5)
An eval'ation of ae change, which shows the expected maximum u
exposures to a ME BER OF THE PUtiLIC in the UNRESTRICTED AREA and to the genert population tnat differ frca those rreviously estimated in the license application and amendments tnareto; 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 peried prior to wlien the changes are to be made; 7)
An estimate of the e>.posure to p' ant operating personnel as a result of the change. and 8)
Documentation of the fact that the change was reviewed and found acceptable by the DRC. PsRc, 2.
Shall become effective upon review and acceptance by the PSRC.
- Licensees may choose to submit the information called for in this specification as part of the annual FSAR update.
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