ML20085E617

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Proposed Tech Specs 6.1.G & 6.1.G.1.b Re Organization, Review,Investigation & audit,6.11, Radiation Protection Program & 6.12, High Radiation Area
ML20085E617
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 10/11/1991
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20085E611 List:
References
NUDOCS 9110210071
Download: ML20085E617 (24)
v • d • e


Text

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I QUAD CITIES DPR-29 TABLE OF CONTENTS (Cont'd)

Page 3.12/4.12 FIRE PROTECTION SYSTEMS 3.12/4.12-2 A. Fire Detection Instrumentation 3.12/4.12-3 B. Fire Suppression Water System 3.12/4.12-2 C. Sprinkler Systems 3.12/4.12-4 D. CO 2 Systems 3.12/4.12-5 E. Fire Hose Station 3.12/4.12-7 F. Penetration Fire Barriers 3.12/4.12-7 G. Fire Pump Diesel Engine 3.12/4.12-E 3.12/4.u Limiting Conditions for Operation and Surveillance 3.12/4.12-1 Requirements Bases

5. 0 DESIGN FFATURES 5.0-1
6. 0 ADMINISTRATION CONTROLS 6.1-1 6.1 Organization, Review, Investigation and Audit 6.1-1
6. 2 Plant Operating Procedures 6.2-1 6.3 Reportable Event Action 6.3-1 6.4 Action to be Taken in the Event a Safety Limit is Exceeded 6.4-1 6.5 Plant Operating Records 6.5-1
6. 6 Reporting Requirements 6.6-1 6.7 Environmental Qualification 6.7-1 6.8 Offsite Dose Celculation Manual (0DCM) 6.8-1 6.9 Process Control Program (PCP) 6.9-1 6.10 Major Changes to Radioactive Waste Treatment Systems (Liquid, Gaseous, Solid) 6.10-1 N

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i QUAD-CITIES OPR-29 G.

The Review and Investigative Function and the Audit function of activ-ities affecting quality during facility operatioc shall be constituted and have the responsibilities and authorities outlined below:

1.

The Superintendent of the Offsite Review and Investigative Function '

shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS).

The Corporate Audit function shall be the respon-sibility of the Manager of QA/NS and shall be independent of operations.

The Manager of QA/NS reports directly to the Chief Executive Officer '

and has the responsibility to set Corporate Policy for both the areas of Quality Assurance and Nuclear Safety. Policy is promul-gated through a central policy committee directed by the Manager of QA/NS. The Manager of QA/NS has the responsibility for the perform-ance of periodic audits of each-nuclear station and corporate departments to determine that QA/NS policy is being carried out,

a. - Offsite Review and Investigative Function '

The Superintendent of the Offsite Review and Investigative I function shall: (1) provide directions for the review and ,

investigative function and appoint a senior participant to provide appropriate direction, (2) select each participant for this function, (3) select a complement of more than one participant who collectively possess background and qualifica-tionsinthesubjectmatterunderreviewtoprovidecomprehen-sive interdisciplinary review coverage under this function, (4) independently review and approve the findings and recom-mendations developed by personnel performing the review and investigative function,_(5) approve and report in a timel manner all findings of noncompliance with NRC requir s to the Station knanse. Vice President BWR Onar -

, Manager of QA t Vice President (AVPVQuality Programs and

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MAWAf>OL(CMC sessment,as/NS/Assistar anc the Senior t ce President-Nuclear Operations.

During periods when the Superintendent of Offsite Review and Investigative Function is unavailable, he shall designate this responsibility to an established alternate, who satisfies the formal training and experience requirements for the Su tendent of the Offsite Review and Investigative Function. perin- The responsibilities of the personnel performing this function are stated below. The Offsite Review and Investigative Function shall review:

(1) The safety evaluations for (1) changes to procedures, equipment, or systems as described in the safety analysis i

report and-(2) tests or experiments completed under the i provision of 10 CFR S0.59 to verify that such actions did i

l not constitute an unreviewed safety question. Proposed ,

changes to the Quality Assurance Program description shall be reviewed and approved by the Manager of QA/NS. l- 1 6.1-3 Amendment No. 117 z _ __ ._ , _ _ . _ _ _ _.__ _ _ _ _ _ -, - , _ _ _ . _ _

QUAD-CITIES OPR-29 (2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety ques. tion as defined in 10 CFR 50.59.

(3) Proposed tests or experiments which involve an unreviewed safety question defined in 10 CFR 50.59.

(4) Proposed changes in Technical Specification NRC operating Itcenses.

(5) Noncompliance with NRC requirements, or of internal procedures, significance. or instructions causing nuclear safety (6) Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety as referred to it by the Onsite Review and Investigative Function.

(7) Reportable events.

(8) All recunized indications of an unanticipated deficiency.

in some aspect of design or operation of safety-related structures, systems, or components.

(9) Review and report findings and recommendations regarding all changes to the Generating Stations Emergency Plan

, prior to implementation of such change.

(10) Review and report findings and recommendations regarding i all items referred by the Technical Staff Supcc :sor Station Manager Quality Programs, and AsVice sment.President BWR Oparatio..., and V gY t b. Station Audit Function my bej M i

ion Audit Func*,i shall e the respo W 11ty or the '

GM V Quality Programs and es nt inde e nt of BWR Opera-

s. Such responsibilit delegated the0Mclear cuality)

.roarams Manage @ y Uhe huclear Quality Proarame fifHES TN6 D M Manan=d shall approve the audit l agenca and ciecklists, f.he findings and the report of each i M96HAfD CWWft audit.. Audits shall be performed in accordance with the h 5fArF M surERvistog Company Quality Assurance Program and Procedures. Audits shall

- g be performed to assure that safety-related functions are

  • g g covered within a period of 2 years or less as designated below.

Asp NM % MENT (1) Audit of the conformance of facility operation to provi-

' sions contained within the Technic.,i Specifications and appMeable license conditions at least once per year.

GM CWALITT MN g esE55ME NT.

6.1-4' en en No. 117

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QUAD-CITIES OP R- '9 (2) Audit of the adherence to p)acedures, trM ning and qualification of tha station staff .scst once per year.

(3) Audit of the results caf actions taken to correct defi-ciencies occurring in facility equipment, structures, systems, or methods of operation that offect nuclear safety at least once per 6 months.

(4) Audit of the performance of activities req, red by the Quality Assurcnce Program to meet the Criteria of Appendix "B" 10 CFR 50.

(5) Audit of the Ferility Emergency Pla, .nd implementing prot edures at least once per year.

(5' 79dit_of the Facility Secu~'ty Plan and implementing ocedurcs at least once p r year.

7; Audit onsite and offsite reviews.

() Audit the Facility Fire Protection Program and implement-ing procedures at least once per 24 months.

(9) The radiological environma.. cal monitoring progrcm and the results thereof at least once per 12 months.

(1r The OCCM anc implementing procedures at least on:e per 24 months.

(11) The PCP and implement'ng procedures for solidification of radioaccive wastt at laast once per 24 months. .

(12) Report all findin;, of noncompliance wit RC requirements and recommendations and results of ea audit to the Station Manager, Manager of QA/NS, V Quality Programs and Assessment, Vice President BWR pe tions, the Senior Vice President-Nuclear Operations, and he Chief Operating Officer.

c. Authority The Manaaer of OA/N' reptets to the Chief Executive Officer.

The Hanager of QA/NS ha. toe authority to order t.rit shutdown or request any other action which he deems necessary to avoid unsafe olant conditions.

5.1-5 Amendment No. 117 L -.

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QUAD-CITIES OPR-29 The V Quality Programs and Assessment r 23r(s to the Senior V

Vice resident-Nuclear Operations. The V 9 Quality Progran;s and Assessment has the authority to rec , end unit shutdown or QA request any other action which he dee necesst.ry te avoid unsafe plant conditions. All s p sagreements shall be reported immediately to the 3 of QA/NS and the Cilief Operating Officer. f_

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d. Records M d-(1) Reviews, audits, and recommendations snall be documented and distributed as covered in 6.1.G.1.a and 6.1.G.1.b.

(2) Copies of documentation reports, and correspondence shall be kept on file at the station,

e. Procedures

-l Written administrative procedures shall be prepared and main-

' aired for the offsite reviews and investigative function 4 Jescribed in Specifications 6.1.G.1.a. Those procedures shall cover the following:

(1) Content and method of submission of presentations to the Superintendent of the Offsite Review and Investigative i Function.

(2) Use of committees and consultants. l

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(3) Review and approvcl.

(4) Detailed listing of items to be reviewed.

(5) Method of (1) appointing personnel, (2) performing reviews, investigations, (3) reporting findings and recommendations of reviews and investigations, (4) approving reports, and (5) distribt. ting reports. h D, (6) Detertt'ning satisfactory completion of action required #

based on approved findings and recommendations reported by personnel performing the review and investigative function

f. Personnel
1) The retrons, including consultants, performing the review and investigative function, in addition to the Super-intendent of the Offsite Review and Investigative Func-tion, shall have expertise in one or more of the following 6.1-6 Amendment No. 117

QUAD-CITIES OPR-29

3) Review of all proposed changes to the Technical Specificat'ons.
4) Review of all proposed changes or modifications to planc systems or equipment that affect nuclear safety.
5) Investigation of all noncompliance with NRC requirements and shall prepare and forward a report co"ering evaluation and recommendations to prevent recurrence. l
6) Review of facility operations to detect potential safety hazards.
7) Performance of !.pecial reviews and investigations and reports thereon as requested by the Su:r:rir,tendent of the i Offsite Review and Investigative Functien.
8) Review of the ation Security Plan and shall submit recommend anges to the Director of Corporate Security and the V Duality Programs GM and Assessment in lieu of the dis aution in accordance with 6.1.G.2.C(1).
9) Rev ew of the Emergency Plan and station implementing procedures and identification of recommended changes. I
10) Review of reportable events and actions taken to prevent recurrence.
11) Review of any isnplanned on site rtlease of radioactive

. material to the envi ons, including the preparation and forwarding of reports covering evaluation recommendations and disposition cf the corrective action to prevent recurrence to the Vice President BWR Operations and to the Superintendent of the Offsite Review and Investigative Function.

12) Review of changes to the PCP and 00CM, and n.ajor changes to the radwaste treatment systems.

i b. Authority The Technical Staff Supervisor is responsible to the Station Manager and shall make recommendations in a timely manner in all areas of review, investigations, and quality control phases of plant maintenance, operation, and administrative procedures relating to facility operations and shall have the authority to request the action necessary to ensure 6.1-9 Amenaient No. 117

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, l QUAD-CITIES DPR-29 compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Manager shall follow such recommendations or select a course of action that is E,.=0 conservative regarding safe operation of the facility. All such disagreements shall be reported immediately to the Vice President BUR f arations and the Superintendent of the Offsite Review and Investigative Function.

c. Records
1) Reports, reviews, investigations, and recommendations prepared and performed for specification 6.1.G.2.a shall be documented with copies to the Vice President BWR Operations the Superintendent of the Offsite Review nd Investigative Function, the Station Manager, and the VP Quality Programs and Assessment.
2) Copies of all records and documentation shall be kept on file at the station.
d. Procedures Written administrative procedures shall be prepared and maintained for conduct of the Onsite Review and Investigative function. These procedures shall include the following:
1) Content and method of submission and presentation to the Station Manager, Vice President BWR Operations, and the Superintendent of the Offsite Review and Investigative Function. l
2) Use of committees L.ien necessary.

l 3) Review and approval.

4) Detailed listing of items to be reviewed.

i 5) Procedures for administration of the quulity cont.

l activities.

6) Assigr, ment of responsibilities.
e. Personnel
1) The personnel performing the Onsite Review and Investigative Function, in addition to the Station Manager, shall consist of persons having expertise in:

a; nuclear power p' ant. techn Sgy, b) reactor operations, c) reactor engineering, I

6.1-10 Amendment No. 117

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QUAD-CITIES DPR-29 6.2 PLANT OPERATING PROCEDURES B. Madhtian r;ontrol ;Jocedures shail be maintained, made aps-4o a1T!

station persdiimrh-e red to. It.e e-stmT1 show permissible radiation ex a consistent with the requirements L.M-Ef . This radiat on eeMatp_r_ogram chall be area o meet the requirements of 10 CFR 20. N -

C. 1. Procedures for items identified in Specification 6.2. A ar,d 0.2.u d any changes to such procedures shall be reviewed and approved by the Technical Staff Supervisor, an Assistant Superintendent or the Technical Superintendent, and department head responsible for the activity performed. At least one person approving each of the above procedures shall hold a valid senior operater's license. In addition, these procedures and changes thereto must have at.J QrA -

tion by the Station Manager before being implemented. (and(,.11  !

2. Work and instruction type procedures which implement approved maintenance or modification procedures shall be approved and authorized by the Maintenance Assistance Superintendent where the l written authority has been provided by the Station Manager. The '

" Maintenance Modification Procedure" utilized for safety related work shall be so approved only if procedures referenced in the

" Maintenance Modification Procedure " have been approved as

( required by 5.2.A. Proceures which do not fall within the requirement of J.2. A or 4-e-81 may be approved by the Department Heads, pf b D. Temporary changes to procedures 6.2. A (iM's.2.Babovel manbe made provided:

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1. The intent of the origiAl-ove r' re is not altered.
2. The change is approved -y two members of the plant management stef;, a; least one of Com holds a Senior Reactor Operator's license on the unit affected.
3. The change is documented, reviewed on the On-Site Review and Investigative Function, and approved by the Station Manager within 14 days of implementation.

E. Drills of the emergency procedures described in Specification 6.2.A shall be conducted in accordance with the GSEP manual. t i

I 6.2-2 Amendment No. 11'.~

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DPR-29 6_dLRADIAll0R_ER01EC110!LEROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and thall be approved,  ;

maintained, and adhered to for all operations involving personnel radiation "

exposure.

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I 6.11 - 1 Proposed ',c.idnent ,

Zal.D/862/42

Quad-Cities OPR-29 6J 2_HIGH .RADI AT10N_ AREA l

6.12.1 In lieu of the " control device" or " alarm signal" required by pacagraph 20.203(c)(2) of 10CFR Pari 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 (RHP)*. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area,
b. A radiation monitoring device which continuously integrates the radiation dose ate in the area and alarms when a preset integrated done is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
c. A health physics quallfled individual (i.e., qualified in radiation protection procedures) with a radiatien dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall peiform periodic radiation surseillance at the frequency specified by Health Physics 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 mejor portion of the body could re:eive in one hour 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 thc Shift foreman on duty and/or the health physics supervision. 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.

Fcr individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in one nour a dose in excess of 1000 mrem ** that are locatej within large areas, such as the containment, wnere 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 RHP, continuous surveillance, direct or remote (such as use of closed circuit TV cameras), may be made by personnel qualified in radiation protection procedures to provide positiv? exposure ccatrol over the activities within the area, Health physics personnel or personnel escorted by health physics personnel shall be exempi from the RWP issuance requirements during the performance of their assigned radiation protection duties, provided they are otherwise followlog plant radiation protection procedures for entry into high radiation areas.

    • Measurement made at 30 cm (11.8 '.n) from the source of radioactivity.

6.12 - 1 Proposed Amendment l 7NLDiG !/43

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QUAD CITIES DPR-30 TABLE OF CONTENTS (Cont'd)

Page 3.12/4.12 Limiting Conditions for Operations and Surveillance Requirements Bases 3.12/4.12-6 5.0 DESIGN FEATURES 5.0-1 6.0 ADMINISTRAT'VE CONTROLS 6.1-1 6.1 Organizatien, Review, Investigation, and Audit 6.1-1 6.2- Plant Operation Procedures 6.2-1 6.3 Action to be Taken in the Event of a Reportable Occurrence in Plant Operation 6.3-1 16.4 Action to be Taken in the Event a Safety Limit is Exceeded 6.4-1 6.b- Plant _ Operating Records 6.5-1 6.6 Reporting Requirements 6.6-1 6.7 Environmental-Qualification 6.7-1 6,8 Offsite Dose Calculation Manual (OD".M) 6.8-1 6.9 Process Control Program (PCP) _

6.9-1 6.10 Major Changes to Radioactive Haste Tieatment Systems (Liqtid, Gaseous, Solid) 6.10-1 6.11 Radiation Protection Program 6.11-1 6.12 High itadiation Area 6.12-1 Zht.0/1261/1 tv Amendment No.

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-QUAD-CITIES DPR-30 G. The Review'and Investigative function and the Atedit function of-activities affecting quality during facility operations shall be '

-constituted and have the responsibilities and authoritles outlined i below: ,

L The Superintender.t of the _Offsite Review and Investigative 4 Function shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS). 'The Corporate Audit function

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shall be the responsibility of the_ M' iger or' Quality Assurance / Nuclear Safety (QA/NS) and shall be independent of operations.

The Manager-of QA/NS reports directly to the Chief Executive Officer-'and-has the responsibility-to set Corporate Policy for "beth'the= areas of Quality Assurance and Nuclear Safety. Policy is promulgated through a central policy _ committee directed by the Manager of QA/NS The Manager of QA/NS has the responsibility for.

the performance of periodic audits of each nuclear station and corporate departments to determine that QA/NS policy is being carried out.

a. Offsite Review and Investigative function. '

The Superintendent of the Offsite Review and Investigative Function shall: (1) provide directions for the review and investigative function and appoint a senior participant to -

provide appropriate direction, (2) select each participant for:thi3 function, (3) select a complement of more than one .

participant who collectively possess background and-qualifications in the subject matter under review-to provide comprehensive interdisciplinary review coverage under this-function ,(4_) , independently revie9 and approve the' findings and recommendations developed by personnel per_ forming the review and investigative function, (5) approve and report in a tirely. manner all findings of noncompilance with-NRC u . requirements to-the Station Manager, Vice President BWR ,

Operations, Manager QA/NS, General Manager (GM)-Quality l Programs and Assessment, and the Senict Vice President of Nuclear Operations. During periods-when the Superintendent e

of Offsite Review and Investigative function is unavailable, p 'he shall designate this responsibility to an estabilshed alternate,_who satisfies the formal training and exoerlence

[i- requirements'for the Superintend 9 of the O'fsite Review and Investigative-Function. The re pos ibilities of the personnel performing this funccwn are stated below. -The-L :Offsite Review and Investigative function:shall review:

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1513B 6.1-3 Amendment No.

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QUAD-CITIES DPR-30

1) The safety evaluations for (1) changes to procedures, equipment, or systems as described in the safety analysis report and (2) tests or experiments completed under the provisions of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question. Proposed changes to the Quality Assurance Program description sha:1 be reviewed and approved by the Manager of QA/NS.
2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.
3) Proposed tests or experiments which involve an unreviewed safety question defined in 10 CFR 50.59.
4) Proposed changes in Technical Specification NRC operating licenses.
5) Noncompliance with NRC requirements, or of internal procedures, or instructions causing nuclear safety

-significance.

6) Significant operating abnormalities or deviations from normal and e=pected performance of plant. equipment that affect nuclear safety as referred to it by the Onsite Review and_ Investigative Function.
7) Reportable events.
8) All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components.
9) Review and report findings and recommendations regarding-all changes to the Generating Stations Emergency Plan prior to implementation of such change.
10) Review-and report find!ngs and recommendations regarding all items referred by the Technical Staff Supervisor, Station Manager, Vice President BNR Operations, and GM Quality Programs and Assessment.
b. Station Audit function The Station Audit function shall be the responsibility of the GM Quality Programs and Assessment independent of BWR Operations.

Such responsibility may be delegated by the GM Quality Programs end Assessment.

6.1-4 Amendment No.

ZNLD/862/64

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QUAD-CITIES DPR-30 Elther the above, or designated corporate staff or g supervision approved by GH Quality Programs and Assessment j shall approve the audit agenda and rhetkilsts, the findings and the report of each audit. Audits shall be performed in accordance with the Company Quality Assurance Program and Procedures. Aualts shall be performed to assure that safety-related functions are covered within a period of 2 years or less as designated below.

1) Audit of the conformance of facillty operation to provisions contained within the Technical Specifications and applicable license conditions at least once i.er year.
2) Audit of the adherence to procedures, training and qualification of the station staff at least once per year.
3) Audit of the results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or methods of operation that affect nuclear safety at least once per 6 months.
4) Audit of the performance of activities required by the.

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

5) Audit of the facility Emergency Plan and implementing procedures at least once per year.
6) Audit of the f acility Security Plan and implementing procedures at least once per year.
7) Audit onsite and offsite reviews.
8) Audit the facility Fire Protection Program and implementing procedures at least once per 24 months.
9) The radiological environmental nonttoring program and the results thereof at least once per 12 months.
10) The OOCH and implementing procedures at least once per 24 months,
11) The PCP and implementing procedures for solidificaticn of radioactive waste at least once per 24 months.
12) Report all findings of noncompliance with NRC requirements and recommendations and results of each audit to the Station Manager, Manager of QA/NS, GM Quality Programs and Assessment, Vice President BWR Operations, the Senior Vice President-Nuclear Onerations, and the Chief Operating Officer.

1513B 6.1-5 Amendment No.

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QUAD-CITIES DIR-30

c. Authority The Manager of QA/NS reports to the Chief Executive Officer.

The Manager of QA/NS has the authority to orde,' unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions.

The GM Quality Programs and Assessment reports to the Senior Vice President-Nuclear Operations. The GM Quality Programs and Assessment has the authority to recommend unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions. All such disagreements shall be reported immediately to the Manager of QA/NS and the Chief Operating Officer,

d. Records
1) Reviews, audits, and recommendations shall be documented and distributed as covered in 6.1.G.I.a and (..l.G.l.b.
2) Copies of documentation, reports, and correspondence .

shall be kept on file at the station.

e. Procedures Written administrative procedures shall be prepared and maintained for the offsite reviews and investigative functions described in Specifications 6.1 G.I.a. Those procedures shall cover the following:
1) Content and method of submission of presentations to the Superintendent of the Offsite Review and Investigative function.
2) Use of committees and consultants.
3) Review ano approval.
4) Detailed listing of items to be reviewed.
5) Method of (1) appointing personnel, (2) performing reviews, investigations, (3) reporting findings and recommendations of reviews and investigations, (4) '

approving reports, and (5) distributing reports.

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6) Determining satisfactory completion of action required based on approved findings and recommendations reported by personnel performing the review and investigative function.

L 15138 6.1-6 Amendment No.

QUAD-CITIES DPR-30 l) Review of-(1) procedures required by Specification 6.2 and changes _thereto and (2) any other proposed procedures or changes thereto as determined by-the Station Manager <

to affect nuclear safety. -

2) Review of all proposed tests and experiments that affect nuclear safety.
3) Review of all proposed changes to the Technical Specificattens.
4) Review of all proposed changes or-modifications to plant s>>tems or equipment that affect nuclear safety. ,
5) Investigation of all noncomplia.c.e with NRC requirements and shall preparo and forward a report covering' evaluation and recer.mendations to prevent recurrence. ,
6) Review of facility operations to detect potential safety- ,

hazards.

7) . Performance _of special reviews and investigations and -

reports thereor, as requested.by the Superintendent of_the Offsite Review'and Investigative function.

8) Review of.the Station Security Plan'and shall submit -

recommended changes to the Director of-Co porate Security and the GM Ouality Programs and Assessment in lieu of- 4

-distribution in accordance with 6.1.G.2.c.(1).

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9) Review of the Emergency Plan and station implementing '

iprocedures and _ identification of recc.nmended changes.-

- 10) Review of_ reportable:evects and actions taken to prevent' recurrence.

t Lil) Review of any unplanned on-site rele'ase of-radioactive material to the environs,-including the_ preparation and

' forward 1nt of_ reports coverleg evaluation recommendAttons and_ disposition of'thc corrective action to. prevent:

c recurrence:to-the Vice President BWR Operations, and-to

, the. Superintendent of the Offsite Review and'

-_ Investigative function.

12) Review of changes to the'PCP:and_00CM, and major changes ~

n- to?the radwaste treatment' systems.

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- 1513B 6.1-9 Amendment No.

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QUAD-CITIES DPR-30

b. Authority The Technical Staff Supervisor is responsible to the Station Hanager and shall make recomm(ndations in a timely manner in all areas of review, investigations, and quality control phases of plant maintenance, operation, and administrative procedures relating to facility operations and shell have the authority to request the action nc-cessary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Hanager shall follow such recommendations or select a course of action that is more conservative regarding safe operation of-the facility. All such disagreements shall be reported immediately-to the Vice President BWR Operations and the Superintendent of the Offsite Review and Investigative Function.
c. Records
1) Reports, reviews, investigations, and recc.nmendations prepared and performed for Specification 6.1.G.2.a. shall-be documented with copies to the '! ice President BWR .

Operations, the Superintendent of the Offsite Review and Investigative Function, the Station Manager, and the GM.

Quality Programs and Assessment.

2) Copies of all records and documentation shall be kept on file at the station,
d. Procedures Written-administrative procedures shall be prepared and '

maintained for conduct of the Onsite Review and Investigative function. These procedures shall~ include the following:

1) Content and method of submission and presentation to the Station Hanager, Vice President BWR Operations, and the Superintendent of the Offsite Review and Investigative Functici..
2) Use of committees when necessary.
3) Review and approval.
4) Detailed listing of items to be retiewed.
5) Procedures for administration of the quality control activities.
6) Assignment of responsibilities.
e. Personnel 1513B 6.1-10 Amendment No.

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QUAD-CITIES DPR-30 6.2. PLANT OPERATING PROCEDURES B. DELETED C. i. Procedures for iteus identified in Specification 6.2.A and 6.11 and any changer to such procedures shall te reviewed and  !

approved by the Technical Staff Supervisor, an Assistant Superintendent or Technical Superintendent, and department head responsible for the activity performed. At least one person approving tach of the above procedures shall hold a valid senior operator's license, in addition, these

,7rocedures and changes itiereto must have authorization by the Station Manager before being implemented.

2. Work and instruction type procedures which implement approved maintenance or nodification procedures shall be approved and authorized by the Maintenance Assistant Superintendent where the written authority has been provided by the Station Hanager. The " Maintenance Modification Procedure" utilized f or safety related work shall be so approved only if

! procedures referenced in the " Maintenance Modification Procedure" have been approved as required by 6.2.A.

Procedures which do not fall within the requirement of 6.2.A  ;

or 0.11 may be approved by the Department Heads. I D. Temporary changes to procedures 6.2.A and 6.11 may be made provided: l

1. The intent of the original procedure is not altered.
2. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's license on the unit affected.
3. The change is documented, rev'4ewei on the On-Site Review and Investigate Function, and approved by the Station Manager within 14 days of implementation.

E. Drills of the emergency procedures described th Specification 6.2.A shall be conducted in accordance with the GSEP manual.

6.'-2 Amendment No.

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Quad-Cities DPR-30 6.1 LRADI All0N PROIECIION _EROGRAM 6.11.1 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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C ZNLD/862/44 6.ll - 1 Proposed Amendment

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. r a Quad-Cities DPR-30 6 tlLHIGLRADIATIOLAREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20,203(c)(2) of 10CFR Part 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 Hork Permit (RHP)*. Any individual or group of individuala, permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate it, the area,
b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been estabIlshed and personnel have been made knowledgeable of them,
c. A health physics qualified individual (i.e., qualified in radiation protecticn 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 Health Physics in the RHP.

6.12.2 In addition to the requirements of Specification 6.12.1, a.reas accessible to personnel with radiation levels such that a major portion of the body could receive in one hour 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 Foreman on duty and/or the health physics supervision. noors shall remain locked except during pe:lods of access by personnel ur$cr an approved RHP which shall specify tt.e dose rate levels in the immtJiate work area and the maximum allowable itay 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 one hour a dose in excess of 1000 mrem ** that are located within large areas, such as the 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 RHP, continuous surveillance, direct or remote (such as use af closed circuit TV cameras), may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

Health physics personnel or personnel escotted by health physics personnel shall be excmpt from the RHP issuance requirements during the performance of their assigned radiation protection outies, provided they are otherwise following plant radiation protection procedures for entry into high radiation areas.

    • Heasurement made at 30 cm (11.8 in) from the source of radioactivity.

6.12 - 1 Proposed Amendment .

ZHLD/862/43

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&UACHMENLC EVALUATION Of SIGNIFICANT llAZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards consideratinns. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards ccasiderations if operation of the facility in accordance with the pioposed amendment would not:

1. Involve a significant incraase in the probability or consequences of an accident previously evaluated; or
2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
3. Involve a significant reduction in a margin of safety.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because:

a. Position Title Change (Section 6.1.G)

The proposed Technical Specification changes nomenclature not functionality. The intent of the proposed Technical Specification remains the same as the current Technical Specification. Thus, there is no increase in the probability or consequence of an accident previously evnluated.

b. Revision of Approval Authority (Section 6.1.G.I.b)

The croposed Technical Specification retains the overall authority for the station audit function with the same position.

The current Technical Specification delegatet the responsibility for the program. Therefore, allowing delegation of approval authority impacts the implementation not the intent of the Technical Specification. Thus, there is no intrease in the probability or consequence of an accident previously evaluated,

c. Addition of the Radiation Protection Program and High Radia '.on Area (Sections 6.11 and 6.12)

The proposed change affects administrative controls exercised to restrict access to high radiation areas by plant personnel and does riot affect plant system safety.

ZNLD/862/46

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The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because:

a. Position Title Change (Section 6.1.G)

The proposed Technical Specification introduces no new actions or components. .Therefore, it creates no new or different kind of accident f rom any accident previously evaluated,

b. Revision of Approval Authority (Section 6.1.G.I.b)

The proposed Technical Specification functions like the current Technical Specification. It differs in minor detail only.

Therefore, it creates no new or different kind of accident from any accident previously evaluated,

c. Addition of the Radiation Protection Program and High Radiation Area (Sections 6.11 and 6.12)

The proposed change affects administrative controls exercised to L restrict cccess to high radiation areas by plant personnel and does not relate to plant system safety Therefore, this change does not create the possibility of a new or different kind of accident previously evaluated.

The proposed changes do not ins'1ve a significant reduction in a margin of safety because:

a. Position Title Change (Section 6.1.G)

The proposed Technical Specification concerns nomenclature only.

Therefore it does not affect the margin of safety.

b. Revision of Approval Authority (Section 6.1.G.1,b)

Although administrative in nature, the proposed Technical Specification does cause a small decrease in the margin of safety due to the removal of one line of approval aut **v. However, the wording j for this specification is standard to le industry and does not pose a significant reduction in the mai in of safety.

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l ZNLD/e62/47 l

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c. Addition of the Radiation Protection Program and High Radiation Area (Sections 6.11 and 6.12)

The proposed change is administrative in nature and does not alter the manner in which equipment required for the safe operation of the plant is operated. There are no setpoint or operational limitations being altered or changed as a result of this revision. The changes will not affect the administrative limits in place and will not reduce the station's ability to enforce these limits. Therefore, this change has no effect on the margin of plant safety.

CONCLUSION Guidance has been provided in 51.44 FR 7744 for the application of standards to license change requests for determination of the existence of significant hazards considerations. This document provides examples of-amendments which are not likely considered to involve significant hazards considerations.

This proposed amendment does not involve a significant relaxation of the criteria used to est? bit 5 safety limits, a significant relaxation of the bases for the limiting safe / system settings or a significant relaxation of the bases for the limiting conditions for operations. The proposed changes are administrative in nature without consequence to the safety to the plant.

Therefore, based on the guidance provid?d in the Federal Register and the cilteria established in 10 CFR 50.92 (e), the proposed change does not constitute a significant hazards consideration.

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AIJ8CttMENI_D ENVIRONMENTAL. ASSESSMENT STATEMENT APPLICABILITY REVIEH Commonwealth Edison has evaluated the proposed amendment against the criteria for the identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.20. It has been determined that the proposed changes meet the criteria for a categorical exclusion as provided under 10 CFR 51.22(c)(10). This determination is based upon the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, the change is administrative in nature and does not pose a significant hazards consideration. Thers is ro change in the amount or type of releases made offsite, The change does not alter the occupancy of personnel in high radiation areas, only the method used to restrict access. Thus, there is no increase in individual or cumulative occupational radiation exposure. Therefore, the Environmental Assessment Statement is not cpplicable for these changes.

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