ML20087K232

Proposed Amends to Proof & Review Tech Specs Re Action Statements 6.b & 19.b on Position Verification of Inaccessible Fire Suppression & Sprinkler Sys Valves,High Radiation Area & Radiological Environ Monitoring Program

ML20087K232
Person / Time
Site:	Catawba
Issue date:	03/20/1984
From:	DUKE POWER CO.
To:
Shared Package
ML20087K215	List: ML20087K213 ML20087K232
References
NUDOCS 8403260080
Download: ML20087K232 (38)

Text

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i Proposed Amendment to Unit 1 Proof and Review Technical Specification Tables 3.3-1 and 3.3-3 Concerning Action Statements 6.b and 19.b, Respectively J

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I, page 1 The proposeo amendments clarify the fact that some of the instrumentation performs dual functions for reactor trip and engineered safety features actuation.

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• , page 2 PROOF & RBEW COPY l

TABLE 3.3-I Wonunuea) i ACTION STATEMENTS (Continued)

ACTION 4 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, suspend all operations involving positive reactivity changes.

ACTION 5 - With the number of OPERABLE channels one less than the Minimum l

Channels OPERABLE requirement, verify compliance with the SHUTDOWN MARGIN requirements of Specification 3.1.1.1 or 3.1.1.2, as applicable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

ACTION 6 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

The inoperable channel is placed in the tripped condition a.

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

b.

The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing of other channels per Specification 4.3.1.lg Spesih b #Att-(

ACTION 7 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed until performance of the next required ANALOG CHANNEL OPERA-TIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACTION 8 - With less than the Minimum Number of Channels OPERABLE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> determine by observation of the associated permissive status light (s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.

ACTION 9 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, one channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.

ACTION 10 - With the number of CPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor trip breakers within the next hour.

ACTION 11 - With the number of OPERABLE channels less than the Total Number of Channels, operation may continue provided the inoperable channels are placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

CATAWBA - UNIT 1 3/4 3-6

-, page 3 PR00F & SHI COPY TABLE 3.3-3 (Continued)

TABLE NOTATIONS i

1. Trip function may be blocked in this MODE below the P-11 (Pressurizer Pressure Interlock) setpoint.

1. 1. Trip function automatically blocked above P-11 and may be blocked bblow P-11 when Safety Injection on low steam line pressure is not blocked.

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• The provisions of Specification 3.0.4 are not applicable.

ACTION STATEMENTS ACTION 14 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; however, one channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

ACTION 15 - With the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed until performance of the next required ANALOG CHANNEL OPERATIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACTION 16 - With the numDer of OPERABLE channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is met. One additional channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing per Specification 4.3.2.1.

ACTION 17 - With less than the Minimum Channels OPERABLE requirement, operation may continue provided the containment purge supply and exhaust valves are maintained closed.

ACTION 18 - With the number of OPERABLE channels one 'ess than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following.

30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

ACTION 19 - With the number of OPERABLE channels one less tnan the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed 4

provided the following conditions are satisfied:

The inoperable channel is placed in the tripped condition a.

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

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The Minimum Channels OPERABLE requirement is met; however, one b.

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additional channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for sur-veillance testing of other channels per Specification 4.3.2.1.

CATAWBA - UNIT 1 3/4 3-25 Y 3 l*b 8 **

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i Catawba Nuclear Station Unit 1 Proposed Amendment to Proof and Review Technical Specifications to Allow Changing between Operational Modes 5 and 6 with the Control Area Ventilation System Inoperable s

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., page 1 The proposed amendments would make Specification 3.0.4 not applicable in modes 5 (cold shutdown) and 6 (refueling) for the Control Area Ventilation Systems. This would allow changing between modes 5 and 6 with the systems inoperable.

The Control Area Ventilation Systems ensure that the control room remains habitable after postulated accidents. Changing between modes 5 and 6 with the system (s) inoperable is acceptable for the following reasons:

(1) Whether in mode 5 or 6, there is no significant difference in the probability of a reactor accident occurring for which the system would be required to function.

In either case, the reactor is substantially subcooled and subcritical.

(2) The fact that mode 5 is acceptably safe is clear because the ACTION section requires proceeding to mode 5 from higher modes but does not require proceeding to mode 6.

Per the ACTION section, the remaining operable system would be placed in the recirculation mode. The ACTION section also restricts positive reactivity changes with both systems inoperable and with emergency power unavailable; however, changing from mode 6 to mode 5 does not necessarily involve positive reactivity changes. Therefore, passage from mode 6 to mode 5 is acceptable.

(3) Because the reactivity and temperature limits for mode 6 are lower than for mode 5, passage into mode 6 does not place the unit in a more degraded condition. Therefore, passage from mode 5 to mode 6 is acceptable.

The wording changes to ACTION statements 3.3.3.7a & b, 3.7.6.a & b and Specification 4.7.6.e.2 describe the way in which the Catawba Control Room Ventilation System functior,s.

The proposed amendments would not involve a significant increase in the probability of an accident previously evaluated because the Control Area Ventilation System is designed to mitigate the consequences of accidents and can have no effect on cause mechanisms. The consequences of accidents previously evaluated would not be significantly increased because accidents which might occur in modes 5 or 6 would be much less severe than the design basis accidents.

Further, the ACTION requirements provide for appropriate measures to compensate for the system inoperability (such as placing the remaining operable system in recirculation and suspending core alterations and positive reactivity changes).

The proposed amendments would not create the possibility of a new or different kind of accident than previously evaluated. The Control Area Venti.lation System cannot cause an accident to occur.

Safety margins are not significantly reduced by the proposed amendments because the design basis accidents' involve i

initial conditions more severe than those conditions (modes'5 and 6) for which the proposed amendments would apply.

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PLANT SYSTEMS

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=. h t. s. w us: 1 3/4.7.6 CONTROLROOMAREAVENTILATION$ men LIMITING CONDITION FOR OPERATION 3.7.6 Two independent Control Room Area Ventilation Systems shall be OPERABLE.

APPLICABILITY:

ALL MODES ACTION:

MODES 1, 2, 3 and 4:

With one Control Room Area Ventilation System inoperable, restore the inoperable system to OPERABLE status within 7 days or be-in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

With one Control Room Area Ventilation System inoperable, restore a.

the inoperable system to OPERABLE status within 7 days or initiate C

and maintain operation of the remaining OPERABLE Control Room Area Ventilation System ' S}ldtOog' We' Htf4?!Hers and cluec=l ads Q

b.

With both Control Room Area Venti ation Systems inoperable, or with direck bw Or k

the OPERABLE Control Room Area Ventilation System, required to be 4s>

% SEP5 OUtrs (an OPERABLE emergency power source,, suspend all operatio

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not capable of being powered by cherceci adsorbers CORE ALTERATIONS or positive reactivity changes.

C. % provisions of Qecihdien 3.0 4 are d ap(licable.

SURVEILLANCE RE0VIREMENTS 4.7.6 Each Control Room Area Ventilation System shall be demonstrated OPERABLE:

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At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room i

air temperature is less than or equal to 80*F; b.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal t

adsorbers and verifying that the system operates for at least l

10 continuous hours with the heaters operating; 1

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CATAWBA - UNIT 1 3/4 7-13 l

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l. 6 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

At least once per 18 months or (1) after any structural maintenance c.

on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1)

Verifying that the cleanup system satisfiss the in place penetration and bypass leakage testing acceptance criteria of less than 1% and uses the test procedure guidance in Regulatory Position C.S.a. C.S.c, and C.S.d of Regulatory Guide 1.52, Revi-sions 2, March 1978, and the sytem flow rate is 6000 cfm 2 10%;

2)

Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon ; ample obtained in accor-dance with Regulatory Position C.6.b of Regulatory Guide 1.52 Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978, for a methyl iodide penetration of less than 1%; and 3)

Verifying a system flow rate of 6000 cfm + 10% during system operation when tested in accordance with ANSI N510-1975.

d.

Af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying,

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within 31 days af ter removal, that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1%;

At least once per 18 months by:

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Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 6000 cfm 2 10%;

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Verifying that on a Loss-of-Offsite Power, or High Radition-Air Intake, or Smoke Density-High test signal, the system automati cally n -: ^__.._ _ '.'__ _ --' " ^'

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with flow thro gh the HEPA filters and charcoal adsorber banks; Aracieentai-3)

Verifying that t e system maintains the control room at a positive pressure cf greater than or equal to 1/8 inch Water Gauge relative to the outside atmosphere during system operation; 4)

Verifying that the heaters dissipate 25 1 2.5 kW when tested in accordance with ANSI N510-1975; and 5)

Verifying that on a High Chlorine / Toxic Gas test signal, the system automatically isolates the affected intake from outside air with recirculating flow through the HEPA filters and char- -

coal adsorbers banks within 10 seconds.

CATAWBA - UNIT 1 3/4 7-14

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-,73ae4 PR00F & REV!BY COPY TABLE 3.3-6 (Continueo) a TABLE NOTATIONS With fuel in the fuel storage pool areas.

With irradiated fuel in the fuel storage pool areas.

Must satisfy the requirements of Specification 3.11.2.1.

ACTION STATEMENTS ACTION 26 - With less than the Minimum Channels OPERABLE requirement, operation may continue-provided the containment purge and exhaust valves are maintained closed.

ACTION 27 - With the number of operable channels one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the ct#echd Control Room Ventilation System C'-i+ 4 "- g_._t_.

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NtikiW4GUe arc LA redmlahl ACTION 23 - With less than the Minimum Channels OPERABLE requirement, opera E bY tion may continue for up to 30 days provided an appropriate Oc U portable continuous monitor with the same Alarm Setpoint is Cl{ers and provided in the fuel storage pool area.

Restore the inoperable charcoal monitors to OPERABLE status within 30 days or suspend all afgo,4ers, operations involving fuel movement in the fuel building.

ACTION 29 - Must satisfy the ACTION requirement for Specification 3.4.6.1.

ACTION 30 - With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, operation may continue provided the Fuel Handling Ventilation Exhaust System is operating and discharging through the HEPA filters and charcoal adsorbers.

Otherwise, suspend all operations involving fuel movement in the fuel building.

ACTION 31 - With the number of OPERABLE channels less than the Minimum Channe OPERABLE requirement, operation may continue provided the Auxiliary Building Ventilation System is operating and discharging through the HEPA filter and charcoal adsorbe.s.

L CATAWBA - UNIT 1.

3/4 3-62

., page 5, INSTRUMENTATION I

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CHLORINE DETECTION SYSTEMS i

, LIMITING CONDITION FOR OPERATION 3.3.3.7 Two independent Chlorine Detection Systems, with their Alarm / Trip Setpoints adjusted to actuate at a chlorine concentration of less than or equal to 5 ppm, shall be OPERABLE.

APPLICABILITY:

All MODES ACTION:

With one Chlorine Detection system inoperable, restore the inoperable a.

system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate arid maintain operation of the Control Room Emergency Ventilation System ^.

f% 4 k %.e 8 EPA fu h. _r.__-rs and & ca d 4 *rbW.

w With both Chlorine Detection $yktems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> b.

initiate and maintain operation of the Control Room Emergency Ventilation System $_L4k $\\ou 4hrou *

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The provisions of Specification 3.

.4 are not applicable.

SURVELLIANCE REQUIREMENTS 4.3.3.7 Each Chlorine Detection System shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at.least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an ANALGG CHANNEL OPERATIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION at least once per 18 months.

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l CATAWBA - UNIT 1 3/4 3-69

Proposed Amendments to Catawba Unit 1 Proof and Review Technical Specification Concert:ing Verifying the Position of Inaccessible Fire Suppression and Sprinkler System Valves

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., page 1 Specifications 4.7.10.1.1.b and 4.7.10.2.a currently require verifying at least once per 31 days that fire suppression and sprinkler system valves are in their correct positions.

The proposed amendments would make these specifications not applicable to valves which are inaccessible during plant operation and would add specifications to require verifying the positions of those valves at least once per 18 months.

Each of these valves is either locked in position or electrically supervised which is consistent with the guidelines in the Standard Review Plan. Because of this and because personnel entry into lower containment is controlled to a minimum, verifying the positions of inaccessible valves every 18 months is adequate to ensure the operability of the systems.

The proposed amendments only affect surveillance frequencies and do not affect test methods, acceptance criteria, or operating conditions. There-fore, new or different kinds of accidents are not created. Also, since no changes to accident analyses or surveillance acceptance criteria are proposed, the proposed amendments will not affect a margin of safety.

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PtANT SYSTEMS SURVEILLANCE RE0VIREMENTS 4.7.10.1.1 The Fire Suppression Water System shall be demonstrated OPERABLE:

At least once per 31 days on a STAGGERED TEST BASIS by starting each a.

electric motor-driven pump and operating it for at least 15 minutes on recirculation flow, g g g ;W h; 64 b.

At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow pat is in its correct position, At least once per 6 months by performance of a system flush of the c.

, outside distrubtion loop to verify no flow blockage, d.

At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel,

,TPQ At least once per 18 months By performing a system functional test e.

4 which includes simulated automatic actuation of the system throughout its operating sequence, and:

a.

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Verifying that each automatic valve in the flow path actuates to its correct position,

b. f)

Verifying that each pump develops at least 2500 gpm at a system pressure of 144 psig, C,.5)

Cycling each valve in the flow' path that is not testable during plant operation through at least one complete cycle of full travel, and dM)

Verifying that each fire suppression pump starts (sequentially) to maintain the Fire Suppression Water System pressure greater 4

than or equal to 144 psig.

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At least once per 3 years by performing a flow test of the system in accordance with Chapter 8. Section 16 of the Fire Protection Handbook, 15th Edition, published by the National Fire Protection Association.

Verihin hat M VAlVe (manual e,.ageradel er-oAmahQ ;n 4ka L p% aked is inucessille kring t<~+ g~k is c. As came+ psai..,.

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PLANT SYSTEMS SURVEILLANCE REOUIREMENTS 4.7.10.2 Each of the above required Spray and/or Sprinkler Systems shall be demonstrated OPERABLE:

At least once per 31 days by verifying that each valve (manual, power-a.

operated, or automatic) in the flow path is in its correct p sition, g

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b.

At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel, and c.

At least once per 18 months:

1)

By performing a system functioral test which includes simulated automatic actuation of the system, and:

a)

Verifying that the automatic valves in the flow path actuate to their correct positions ~on a Fire Detection test signal, and b)

Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel.

2)

By a visual inspection of the sprinkler headers to verify their integrity; and 3)

By a visual inspection of each nozzle's spray area to verify the spray pattera is not obstructed.

Ll) by Ve.rihyin= & tach va\\ve (enas&, power-opera $ed or aubdic.) in & A p=& wL;<L rs inacess/4le Ar,ag g\\ad.paed,on u in ils cocecipihn.

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CATAWBA - UNIT 1 3/4 7-29

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1 Proposed Addition to Catawba Unit 1 Proof and Review Technical Specifications Technical Specification 6.12 - HIGH RADIATION AREA i

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Attache.ent 4, page 1 It is requested that Technical Specification 6.12 - HIGH RADIATION AREA be added to the Catawba Technical Specifications. The proposed specification is the same as the Comanche Peak specification with two minor plant specific corrections.

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., page 2 ADMINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signai" required by paragraph 20.203(c)(2) of 10 CFR Part 20, each high raqiation area, as defined in 10 CFR Part 20, in which the intensity of radiation is equal to or less than 1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as

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a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWF).

Individuals qualified in radiation protection procedures (e.g., Health Physics Technician) or personnel con-tinuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. 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 radiation monitoring device which continuously indicates the a.

radiation dose rate in the area, or 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 estab-lished and personnel have been made knowledgeable of them, or An individual qualified in radiation protection procedures with a c.

radiation dose rate monitoring device, who is responsible for pro-viding positive control over the activities within the area and shall perform pericdic radiation surveillance at the frequency specified by thehjg,.ggi p,g:@ntheRWP.

6.12.2 In addition to the requirements of Specification 6.12.1, areas acces-sible to personnel with radiation levels greater than 1000 mR/h at 45 cm (13 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Qm is.e O r on duty and/or 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 areas and the maximum allow-able stay time for individuals in that area.

In lieu of the stay time specif-ication of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation pro-tection procedures to provide positive exposure control over the activities being performed within the area.

For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing,

light shall be activ)(ated as a warning device.

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Proposed Amendment.to Catawba Unit 1 Proof and-Review Technical Specification 6.2.2.f Concerning the Unit Staff J

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., page 1 The Catawba operating personnel will be working 12-hour shifts with a four shift rotation. Under this schedule adequate shift coverage will be maintained without routine heavy use of overtime.

The tenn " deputy" is not used to describe any position in the Catawba organization. The Station Manager's " designee" is the person charged with the duties of the Manager in the Manager's absence.

Also, a new Figure 6.2-2 " UNIT ORGANIZATION" is provided which shows the organization that will be in place at Catawba at the time of fuel load.

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,,page2 PR00f & REV!EW COPY C,

ADMINISTRATIVE CONTROL UNIT STAFF (Continued) f.

Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions (e.g., licensed Senior Operators, licensed Operators, health physicists, auxiliary operators, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy pag;nd use of overtime.

The objective shall be to have operating personnel work la --- ' ^ E. __m 40-hour week while the unit is operating.

Howev e, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shut-down for refueling, major maintenance, or major plant modification, 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 7-day period, all excluding shift turnover time.

3.

A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including shift turnover time.

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.

deQnst Any deviation from the (above guidelines shall be authorized by the Station Manager or his,;" ; C, 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

. monthly by the Station Manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

L l

I CATAWBA - UNIT 1 6-2

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M UNIT ORGANIZATION CATAWBA NUCLEAR STATION Figure 6.2-2 4-

4 i

.i Proposed Amendment to Catawba Unit 1 Proof and Review Technical Specification Tables 3.12-1, 3.12-2 and 4.12-1 Concerning the Radiological Environmental Monitoring Program i

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L, page 1 y

The proposed changes are intended to clarify some ambiguous areas and to remove soma specifications'which do not apply to Catana.

~

"I-131 analysis weekly" is changed to " weekly gamma isotopic.(rdjng In Table 3.12-1, item 2 several changes are proposed. The wo "

r The term I-131 analysis implies a lo9-level 'I-131 analysit.js being performed when the test actually being performed is a gamma? isotopic analysis; the change therefore clarifies the t)pe of test being performed.

Also, the) wording " Gross beta radioactiyity analysis following filter change (8 ; and gamma isotopic analysisl'1 of c9mp9sjte (by-location) quarterly" is changed to " weekly gamma isotopic.l M 1."

Since gamma isotopic analysis is required for filters with high gross beta ~ activity and since gamma isotopic analysis provides much more information than does gross beta analysis, a change is necessary to replace'the weekly gross beta analysis with a weekly gamma isotopic analysis. The above change necessitates the change of Table notation (3) of Table '3.12-1 to read, " Airborne particulate sample filters shall becheld for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling, to allow foi radon and-thoron daughter decay, before gamma isotopic analysis is performed," since gross beta analysis would no longer be required.

m The next cnange proposed is to delete item 3b of Table 3.12-1 which calls for quarterly ground water samples from one or two sources when groundwater is likely to be affected by radioactive effluent releases.

The Catawba FSAR shows that groundwater is not likely to be affected, since any radioactivity released to the groundwater will reach Lake Wylie only after a delay of at least 40 years.

It will not travel to any offsite locations as groundwater because groundwater flows toward the lake.

FSAR paragraph 2.4.14 concludes:

"With the exception of the Technical Specifications describing remedial action required in the event of a rise in groundwater as described in Section 2.4.13.5, the hydrologic design bases developed in the preceding sections do not necessitate technical specifications or emergency procedures to ensure,. safety-related plant functions.

In the event of an accidental radioactive release, industries and municipalities that utilize Lake Wylie and the Catawba River downstream as a water supply are notified of possible-contamination."

The above change also necessitates the dhietion of tabic notation (7),

Table 3.12-1.

~

In item 3c of Table 3.12-1 the wording "I-131 analysis" is to be changed-to " low-level I-131 analysis." The change specifies the type of test required for drinking water samples. The same wording change is applied-to item 4 of Table 3.12-1.

i, page 2 In item 4b of Table 3.12-1 the wording, "One sample of each commercially and recreationally important species" and "One sample of same species" are changed to "One sample each of a predatory species, a bottom feeder, and a forage spccies." This change is justified in the attached memo from the Duke Power Environmental Laboratory.

In item 4c of Table 3.12-1, the wording which refers to broad leaf vegetation is changed to vegetation sampling. The change is made to avoid confusion in the definition of broad leaf vegetation. Another change made to this item is a change in the wording, " Monthly during growing season" to

" Monthly when available," reflecting the fact that crops are not always available during the growing season. Also omitted from this item are the words "and I-131" from the " Type and Frequency of Analysis" column since gamma isotopic analysis automatically includes analysis for I-131.

Table notation (6) of Table 3.12-1 is changed from, "A composite sample is one in which the quantity l

(aliquot) of liquid samples is proportional to the quantity of flowing liquid and in which the method of sampling employed results in a specimen that is l

representative of the liquid flow."

to "A composite sample is one in which the rate of which the liquid is sampled is uniform and in which the method of sampling employed results in a specimen that is representative of the time averaged concentration at the location being sampled."

The change allows for the use of a simple, reliable time average concentration sampling device instead of an unreliable and complicated flow proportional sampling device. Also, a time average sample is more representative of what is in the environment than is a flow proportional sample.

Finally, since the flow of the waters being sampled, station discharge canal and inlets to water purification facilities, is fairly constant, the data acquired would be approximately the same for both sampling devices.

The next change involves Table 3.12-2 and the reporting levels for I-131.

Since the table does not specify what type of test is being performed, it is proposed that the reporting level listed in the table be that for gamma isotopic analysis, 20 pCi/1, with the reporting level for low-level I-131 analysis being included in table notation (4). Table notation (4) is changed to read, " Reporting level for gamma isotopic analysis.

If-the calculated dose for drinking water exceeds 1 mrem /yr, low level I-131 analysis shall be perfonned and a reporting level of 2pCi/l is used." A similar change is made in Table 4.12-1, analysis LLD. The gamma isotopic analysis LLD of-15 pCi/l is listed in the table and table notation (5) used to specify the low level I-131 analysis LLD of 1 pC1/1. Another change in Table 4.12-1 is l

l the deletion of a LLD for gross beta analysis on airborne particulate or gas l

samples since this test is not perfonned on this type of sample, i

..., page 3 January 6, 1984 Memo to: File

Subject:

CNS Environnental Radiological Monitoring Tech Spec Requirements For Fish Sanpling GS-752.05 The purpose of this memorandum is to document the rationale for proposing a change to the proposed CNS Technical Specifications regarding the subject program. This proposal would change the wording of Table 3.12-1 from "One sample of each commercially and recreationally important species in vicinity of plant discharge area," to "One sample of representative gamefish, forage fish, and bottom feeders in the vicinity of the plant discharge." This change is substantiated by extensive fisheries data available on Lake Wylie, and will provide a meaningful monitoring program which will ensure the health and safety of the public.

A primary purpose of environmental radiological monitoring is to monitor all potential pathways of radiation exposure or uptake in the environment.

In fish the primary concern is from radionuclides that are incorporated into fish tissue via the food chain. Radionuclides discharged from a nuclear station are either incorporated directly into lower organisms residing in the water column (bacteria, phytoplankton, zooplankton) or settle into the bottom sediments. Once radionuclides reach the bottom sediments they may remain there or can be incorporated in the tissues of benthic invertebrates.

From either of these two pathways, discharged radionuclides may eventually be incorporated into the tissues of either sport or commercial fishes and then become available to human comsumption.

In Lake Wylie there is no documentable commercial fishery, however, there is a substantial recreational fishery based on creel survey work conducted by Duke Power Company in 1983 and 1983. A potential co=mercial fishery does exist, consisting of catfish (Ictaluridae), carp (Cyprinus carpio), and possibly quillback carpsucker (Carpiodes cyprinus) and smallmouth buffalo (Ictiobus bubalus).

There is considerable overlap with recreational fisheries, particularly with carp and catfish. Recreational fisheries consist primarily of white bass (Morone chrysops), largemouth bass (Micropterus salmoides), black and white crappies (Pomoxis nigromaculatus and P. annularis), bluegill (Lepomis macrochirus), and redear sunfish (L. microlophus). Although not directly important to recreational fisheries catches, threadfin shad (Dorosoma petenense) and gizzard shad (D.

cepedianum) are important in radionuclide pathways because they serve as forage fish for some of the most important recreational fish species. All species mentioned above can be roughly divided into three trophic levels. Predatory species (white bass, largemouth bass, and crappies) and their forage species (threadfin shad and gizzard shad) incorporate radionuclides primarily through the water column pathway since the chain goes roughly from phytoplankton/

zooplankton to forage fish to predatory fish. Although there is considerable overlap, the remaining species could be termed benthic invertebrate / detritus (sediment) feeders and would be expected to incorporate radionuclides via the l

bottom sediments.

1 4

=

4

., page 4 Memo to File January 6, 1984 Since there are basically two pathways leading to radionuclide incorporation into fish tissue, since there is considerable overlap between potential 4

commercial fisheries and recreational fisheries, and since metabolic processes among species of fish do not vary drastically, we feel that monitoring of one predatory species, one bottom feeder, and one forage species will provide

)

suf ficient information to meet the objective of the CNS Environmental Radiological

)

Monitoring Program. The use of indicator species is a commonly accepted practice

{

in pollution biology and we feel that the suggested changes in the program would provide a more cost-effective indicator of radionuclide accumulation in fish than monitoring several species from each pathway.

S. R. Johnson Biologist SRJ/jb cc:

W. D. Adair L. L. Olmsted P. S. Wingo Lionel Lewis J. S. Isaacson W. M. Carter j

Ron liarris R. E. Sorber T. J. Keane R. B. Hofnann J. A. Effinger R. D. Ilarrell D. J. Degan J. S. Carter

}

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TABLE 3.12-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM h

NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY e

7.,

AN0/0R SAMPLE SAMPLE LOCATIONSII)

COLLECTION FREQUENCY OF ANALYSIS

[

2.

A1 borne Radiofodine and Samples from five locations Continuous sampler oper-Radiolodine Cannister:

Particulates ation with sample collec-

12 -- :,-.- -__:',,

is,{opic,g tion weekly, or more

\\/ceg Three samples from close frequently if required by to the three SITE BOUNDARY dust loading.

Particulate Sampler:

locations, in different

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sectors, of the highest calculated annual average m___.4@9,'

ground-level D/Q;

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One sample from the m

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yy vicinity of a community co NteNy opmm Whop,c(syA having the nighest calcu-p lated annual average ground-sj level D/Q; and g$_

2 One sample from a control r

location, as for example 15 to Q

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30 km distant and in the least

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prevalent wind direction.

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Waterborne cn Surface (5)

One sample upstream Composite sample over Gamma isotopic analysisI4)

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One sample downstream 1-month period.(6) an a erly.

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TABLE 3.12-1 (Continued) 9 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM E

NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY E

AN0/0R SAMPLE SAMPLE LOCATIONS (I)

COLLECTION FREQUENCY OF ANALYSIS

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3.

Waterborne (Continued) l c.

Drinking One sample of each of one to Composite sample over I-131 analysis on each l

three of the nearest (6)

^ composite when the dose p

water supplies that could be y calculated for the con-

,n s is p r-sumpd on of Ge water affected by its discharge.

A formed; monthly com-is greater than 1 aren posite otherwise.

One sample from a control per year Comoosite I

locatinn.

g for gross beta and gamma

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~' 1 isotopic analyses t'

Qo monthly. Compor.ite for i

p tritium analysis quarterly. @

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Sediment One sample from downstrea.n area Semiannually.

h Gamma isotopic analysis from with existing or potential g

semiannually.

o Shoreline recreational value.

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Ingestion y

a.

Milk Samples from allking animals Semimonthly when Gamma isotopicI4) and in three locations within 5 km animals are on pasture;M**l I-131 analysis semi-distance having the highest monthly at other times.

^ monthly when animals dose potential.

If there ar~e are on pasture; monthly none, then one sample from at other times.

allking animals in each of

.three areas between 5 to 8 km distant where, dose gare calcu-l lated to b r

jun han 1 arem per yr.

O sample from milki nimal at a control location 15 to 30 ka distant and in the least preva-lent wind direction.

TABLE 3.12-1 (Continued)

Q RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM sf 5

NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AN0/0R SAMPLE SAMPLE LOCATIONSII)

COLLECTION FREQUENCY OF ANALYSIS _

Z 4.

Ingestion.(Continued) g O) b.

Fish and C.._ _ _A J _ _ _. __

Sample in season, or Gamma isotopic analysis Inverte-

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semiannually if they on edible portionjf.

[dischargearea.

brates

'n in vicinity of plant are not seasonal.

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areas no't influenced'by plant k

discharge.

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Food One sample of each principal At time of harvest Gamma isotopic analyses Products class of food products from on edible portion.

c, g

any area that is irrigated 4

by water in which liquid E

plant wastes have been T

One. samph eac.b ofo discharged.

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Samples of Ahmes n Morents Monthly deseny Gamma isotopic I4I

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h vegeta-hm G

analysis.

foca e p e.g.

tion grown nearest each of

,g gg;1akle.

M two different offsite loca-tions of highest predicted T-is annual average ground level '

ZI.E D/Q if milk sampling is not a

performed.

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c One sample of N Mon %!y"devonsp Gamma isotopic )am64-4th-similar baseddeaf vegeta-w' : - -

analysis.

tion grown 15 to 30 km dis-6 aga;la &.

tant in the least prevalent wind direction if milk sam-pling is not performed.

., page 8 PROOF a REVTJ COM l

TABLE 3.12-1 (Continued)

TABLE NOTATIONS (1) Specific parameters of distance and direction sector from the centerline of one reactor, and additional description where pertinent, shall be provided for each and every sample location in Table 3.12-1 in a table and figure (s) in the ODCM.

Refer to NUREG-0133, " Preparation of Radio-logical Effluent Technical Specifications for Nuclear Power Plants,"

October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to circumstances such as hazardous conditions, seasonal unavailability, and malfunction of automatic sampling equipment.

If specimens are unobtainable due to sampling equipment malfunction, effort shall be made to complete correc-tive action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.6.

It is recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time.

In these instances suitable specific alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the Radiological Environmental Monitoring Program given in the ODCM.

Pursuant to Specificaticn 6.14, submit in the next Semiannual Radioactive Effluent

(

Release Report documentation for a change in the ODCM including a revised figure (s) and table for the ODCM reflecting the new location (s) with supporting information identifying the cause of the unavailability of samples for that pathway and justifying the selection of the new location (s) for obtaining samples.

(2) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.

For the purposes of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters.

Film badges shall not be used as dosimeters for measuring direct radia-tion.

The 40 stations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading.

Airborne particulate sample filters shall be -- / for M

(3)

-" ' - - '-*=

1.___f'i24hoursormoreaftersamplinhto'allowforradonand l

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thoron daughter decayE M g :: T.

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bJm pm. ud.pc. analpis is pr&cm=L CATAWBA - UNIT 1 3/4 12-7

, page P300F S EEl! COPY

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TABLE 3.12-1 (Continued)

TABLE NOTATIONS (Continued) l (4) Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

(5) The " upstream sample" shall be taken at a distance beyond significant influence of the discharge. The " downstream" sample shall be taken in an area beyond but near the mixing zone.

" Upstream" samples in an estuary must be taken far enough upstream to be beyond the plant influence.

Salt water shall be sampled only when the receiving water is utilized for recreational activities.

WIform ra}e d &bch Ne A composite [ sample is one in which theg ;_':

^_t, ::;-_^_; _T liquid (6) sampled isy, _, _. _ ' :..1 ^_ _ t M 7 "* 4 ;' - ' -

4"-

f'" and in which 4* g g,

the method of sampling employed results in a specimen that is represen-ggg tativeoftheg'7'"-'

In this program composite sample aliquots shall be collected at time intervals that are very short (e.g., hourly) b 'I* M," N relative to the compositing period (e.g., monthly) in order to assure l

Samfed obtaining a representative sample.

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- " ' - ' ~ ~ ~ ~ ' ' ' ' ' ' ' ' ' " ~

) The dose shall be calculated for the maximum organ and,' age group, using the methodology and parameters in the ODCM.

8

(/) If harvest occurs more than once a year, samoling shall be performed during each discrete harvest.

If harvest eccurs' continuously, sampling shall be monthly. Attention shall be paid to including samples of tuberous and root food products.

l 1

I l

CATAWBA - UNIT 1 3/4 12-8

f O

O TABLE 3.12-2 REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Eg REPORTING LEVELS e

Eq WATER AIRBORNE PARTICULATE FISH MILK F000 PRODUCTS ANALYSIS (pci/t)

OR GASES (pci/m )

(pCi/kg, wet)

(pC1/2)

(pci/kg, wet) 3 g

H-3 20,000(1) 9 Mn-54 1,000 30,000 Fe-59 400 10,000 es 3

Co-58 1,000 30,000

-n g

y Co-60 300 10,000 r2o g

.:o g

2n-65 300 20,000 rg 7

Zr-Nb-95 400 j

I-131 d' 20 0.9 3

100 Q

-c Cs-134 30 10 1,000 60 1,000 4

Cs-137 50 20 2,000 70 2,000 Ba-La-140 200

~

300 II)For drinking water samples.

This is 40 CFR Part 141 value.

If no drinking water pathway exists, a value of 30,000 pCi/t may be used.

a

D D

D

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m TABLE 4.12-1 3

DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS (1) (2)

LOWER LIMIT OF DETECTION (LLD)I3)

=

I Eq WATER AIRBORNE PARTICULATE FISH HILK FOOD PRODUCTS SEDIMENT ANALYSIS (pCi/1)

OR GASES (pC1/m )

(pCi/kg, wet) (pCi/1)

(pCi/kg, wet) (pC1/kg, dry) 3 g

Gross Beta 4

4.e>

H-3 2000*

- 72 Mn-54' 15 130

[$

ro e

Fe-59 30 260

8 E

L.m '

9-Co-58,60 15 130 mo 2

w A

N 5

Zn-65 30 260 pg.;

cn g

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~~

U Zr-Nb-95 15 E

I-131

[ LS 0.07 1

60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-La-140 15 15 "If no drinking water pathway exists, a value of 3000 pCi/l may be used.

1 u_

1 Attactpent 6, page 12 Pi100F & RETBV COPY

{

TABLE 4.12-1 (Continued)

TABLE NOTATIONS (Continued)

It should be recognized that the LLD is defined as an a_ priori (before the fact) limit representing the capebility of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

AnaTyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.6.

(4) '_ L fn 2,

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I ' x 2.

g.:.._,

2-*,

m

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LL.

3....~

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,... _.. _, _. _ n, L.... L 3epodig \\evd for 15dopic cmedysis. Yke calcEN82 dese.

m mat b J.cin63 war ace.Js i mcem /yc, \\ow-leve.l I.-131 omody sl5 Shl\\ he. fedemed an.( A repor4T limit M 2

cl/l.used.

p (5) L.L) &c. pmm i.s 6pic. analysis, If Lw-level 'Tc B1 arml s;f y

is y"Sr**A, an LD a4 L dil$ skall be used-g o

CATAWBA - UNIT 1 3/4 12-12

o Proposed Amendment to Catawba Unit 1 Prcof and Review Technical Specifications 6.5.1.4 and 6.8.1 Concerning the Administrative Control for the Environmental Radiological Monitoring Program l

l l

t l

.n

., page 1 i

The Proof and Review Technical Specifications require the Station Manager or a member of his staff to review and approve changes to procedures involving radiological environmental monitoring. Since the Duke Power Environmental Radiological Laboratory provides this service to all Duke nuclear stations, such a requirement would lead to unnecessary confusion because each Station Manager would be required to review the Environmental Radiological Laboratory's procedures.

The following proposed changes to the Catawba Technical Specifications would place the responsibility for quality assurance of the environmental radiological monitoring program under the corpcrate System Health Physicist.

First, paragraph 6.5.1.4 should read,

" Individuals responsible for reviews performed in accordance with Specification 6.5.1.1, 6.5.1.2, and l

6.5.1.3 shall be members of the station supervisory staff, previously designated by the Station Manager l

to perform such reviews.

Review of environmental radiological analysis procedures shall be performed by the System Health Physicist or his staff.

Each such review shall include a determination of whether or not additional, cross-disciplinary, review is necessary.

If deemed necessary, such review shall be performed by the appropriate designated review personnel."

To make the change complete the words "and environmental" will be omitted from paragraph 6.8.1, item g which will now read:

"6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below;

a....

g.

Quality Assurance Program for effluent monitoring."

With the above changes, all quality assurance responsibilities for environmental radiological monitoring are given to the corporate System Health Physicist or his designee.

i l

l l

..o,pple2 fh hf

[

3 i

i ADMTNISTRATIVE CONTROLS U

6.5 REVIEW AND AUDIT 6.5.1 TECHNICAL REVIEW AND CONTROL ACTIVITIES 6.5.1.1 Each procedure and program required by Specification 6.8 and other procedures which affect nuclear safety, and changes thereto, shall be prepared by a qualified individual / organization.

Each such procedure, and changes thereto, shall be reviewed by an individual / group other than the individual /

group which prepared the procedure,, or changes thereto, but who may be from the same organization as the individual / group which prepared the procedure, or changes thereto.

6. 5.1. 2 Proposed changes to the Appendix A Technical Specifications shall be prepared by a qualified individual / organization.

The preparation of each proposed Technical Specification change shall be reviewed by an individual /

group other than the individual / group which prepared the proposed change, but who may be from the same organization as the individual / group which prepared the proposed change.

Proposed changes to the Technical Specifications shall be approved by the Station Manager.

6.5.1.3 Proposed modifications to unit nuclear safety-related structures, systems, and components shall be designed by a qualified individual / organization.

Each such modification shall be reviewed by an individual / group other than the

(

individual / group which designed the modification, but who may be from the same organization as the individual / group which designed the modification.

Proposed modifications to nuclear safety related structures, systems, and components shall be approved prior to implementation by the Station Mafiager; or by the Operating Superintendent, the Technical Services Superintendent, or the Main-tenance Superintendent, as previously designated by the Station Manager.~

6.5.1.4 Individuals responsible for reviews performed in accordance with Specifications 6.5.1.1, 6.5.1.2, and 6.5.1.3 shall be members of the station suoervisarv staff, previously designated oy the Station Manager to perform T

such reviews.AEach such review shall include a determination of whether or not additionaT, cross-disciplinary, review is necessary.

If deemed necessary, such review shall be performed by the appropriate designated station review personnel.

6. 5.1. 5 Proposed tests and experiments which affect station nuclear safety and are not addressed in the FSAR or Technical Specifications shall be reviewed by the Station Manager; or by.the Operating Superintendent, the Technical Services Superintendent or the Maintenance Superintendent, as previously designated by the Station Manager.

l Teviw of environmedel radiological analysis procelares skII b edor**/ h f

4he coepede fy+<m blA Physicisf or. h;3 J,,; pee, l

C CATAWBA - UNIT 1 6-7

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ADMINISTRATIVE CONTROLS i

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appenaix A of Regulatory

' Guide 1.33, Revision 2, February 1978; b.

The applicable procedures required to implement the requirements of NUREG-0737 and Supplement No. I to NUREG-0737 as stated in Generic Letter No. 82-33; c.

Security Plan implementation; d.

Emergency Plan implementation; e.

PROCESS CONTROL PROGRAM implementation;.

f.

OFFSITE DOSE CALCULATION MANUAL implementation; and g.

Quality Assurance Program for effluent end-emmenennewed monitoring.

6.8.2 Each procedure of Specification 6._8.1, and changes thereto, shall be

(

reviewed and approved by the Station Manager; or by:

(1) Operating Superin-tendent, (2) Technical Services Superintendent, or (3) Maintenace Superinten-dent, as previously designated by the Station Manager; prior to implementation and shall be reviewed periodically as set forth in administrative procedures.

6.8.3 Temporary changes to procedures of Specification 6.8.1 may be made pro-vided:

a.

The intent of the original procedure is not altered; b.

The change is approved by two members of the plant management staff, at least one of whom holds a Senior Operator license on the unit affected; and c.

The change is documented, reviewed, and approved by the Station Manager; or by:

(1) Operating Superintendent, (2) Technical Services Superintendent, or (3) Maintenance Superintendent, as previously designated by the Station Manager; within 14 days of implementation.

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

a.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels.

The

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systems include the containment spray, Safety Injection, chemical and volume control, and nuclear sampling.

The program shall include the following:

CATAW8A - UNIT 1 6-13