ML20126E742

Marked-up Proposed Tech Specs Section 5.0, Administrative Controls

ML20126E742
Person / Time
Site:	North Anna
Issue date:	02/23/1981
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20003C015	List: ML20126E732 ML20126E736 ML20126E742
References
NUDOCS 8102260461
Download: ML20126E742 (15)

Text

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l ATTACHMENT 3 PROPOSED ENVIRONMENTAL TECi'.NICAL SPECIFICATION CHANGE NORTll ANNA UNITS 1 AND 2 O

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1.0 DEFINITIONS....'............................................. 1 2.0 LIMITING CONDITIONS FOR OPERATION........................... 2-1 2.1 No n-Ra d i ol o g i c a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 -.

2.2 Radica ctive E f fl u en ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1  ;

2.2.1 Specifications for Liquid Waste Ef fluents.. .... . - 2-2 2.2.2 Specifications for Liquid' Waste Sampling and Monitoring................................ 2-3 2.2.3 Specifications for Gaseous Waste Effluents...... 2-7 2.2.4 Specifications for Gaseous Waste Sampling and Monitoring................................ 2-13 2.2.5 Specifications for Solid Waste Handling and Disposa1.................................. 2 17-3.0 ENVIRONMENTAL SURVEILLANCE.................................. 3-1 3.1 Non radiol ogical Su rvei11 ance. . . . . . . . . . . . . . . . . . . . . . . . . . . 1 3.1.1 Ab i o ti c - Aq ua t i c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 Q 3.1.2 B i o ti c Aq u a ti c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3-1 3.1. 3 Abi o ti c - Te r re s t ri al . . . . . . . . . . . . . . . . . . . . . . . . . .

3.1,4 Onsi te Me teorol ogy Moni tori ng. . . . . . . . . . . . . . . . . . 3-1 3.2 Radi ol o gi cal Envi ronmental Moni to ri ng. . . . . . . . . . . . . . . . . 3-2 4.0 SPECIAL SURVEILLANCE AND STij0Y ACTIVITIES.................. '41-5.0 ADMINISTRATIVE CONTR0LS..................................... 5-1 5.1 R e s p o n s i b i l i t y . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Organization........................................... 5-1 5.3 Review and Audit....................................... 5-1

5. 3.1 Station Nuclear Safety and Operating Comittee (SNS0C)....................................... 5-1 5.3.1.1 Function.................................... 5-1

5. 3.1. 2 Responsibility.............................. 5-1

5. 3.1. 3 Authority................................... 5-3 5.3.1.4 Records..................................... 5-3 O

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( TABLE OF CONTENTS (Cont'dl e

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5-4

5. 3. 2.1 Function.................................... 5 4 -.

5.3.2.2 Audits...................................... 54 5.3.2.3 Records..................................... 4

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5. 3. 3.1 Fu n c t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-4 . . . . '. .

5.3.3.2 Review...................................... 5-5 5.3.3.3 Responsibility.............................. 5-5 ,

5.3.3.4 Authority................................... 5-5 5.3.3.5 Records.....................................

5-5 5.4 State and Federal Permits and Certificates.. . .. . .. . . .. . , 5-5 5.5 Procedures.................................,............

5-5

5. 5 .1 Wri t ten P roc edures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5 5.5.2 Operating Procedures............................

o 5.5.3 Procedures for Environmental Surveillance - 5-6 h '

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Ra d i o l o g i c a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5.5.4 Procedures for Environmental Surveillance -

Nonradiologica1................................. 5-6 5.5.5 Quality Assurance of Program Results.............. 5-6 5.5.6 Changes in Procedures, Station Design or Operation.......................................

5-6 5.5.7 Consistency with initially Approved Programs...... 5-7 5-7 5.6 Station Reporting Requirements...........................

5-7

5. 6 .1 Routine Reports...................................

Annual Environmental Operating Report......... 5-7 5.6.1.1 5-8

5. 6.1. 2 Radioactive Ef fluent Rel eas e Report. . . . . . . . . . .

5-9 5.6.2 Nonroutine Reports................................

5.6.2.1 Nonroutine Non-Radiological Environmental Operating Report............................ 59 5.6.2.2 Nonroutine Radiological Environmental Operating Reports........................... 5-10 5.6.3 Changes in Environmental Technical Specifications. 5-11 5.6.4 Changes in Permits and Certifications............. 5-11 5-11 5.7 Records Retention........................................

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AOM1f;1STP.ATIVE_ CONTROLS 5.0 Administrative controls below apply to Appendix B Part I only.

5,1 Responsibility.

The responsibility for implementing the Environmental Technical Specifications is assigned to the Manager-Nuclear Operations and Maintenance at the corporate level and to the Station Manager at the station level. The Superintendent -

Operations shall be responsible for ensuring that the station is operated in accordance with the Limiting Conditions of Operation. The Station Supervisor -

ble for the radiological environmental Health Physics surveillance shall be respons(pxecutive requirements. The Manager of Environmental Services l

shall be responsible for providing services which will fulfill the non-radiological environmental surveillance requirements.

5.2 Organi z a tion _

The relationship between the Nuclear Operations Department and the Environmental Services Department is shown in Figure 5.2-1.

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L) 5.3 0.3.1 Stati:n t;uclear safety and 0:eratine Cemittee (5:iSOC) 5.3.1.1 Function The SitSOC, as described in Section 6.5.1 of Appendix A cf this license, shall function to advis,e the Station Mana5er on r.atters related to the envircreental impact of the station. When the 5:450C is exercising its responsibility for non-radiological aspects of the ETS, the Station Biologist or his alternate shall be consulted.

5.3.1.2 Kesponsibility The 5:;50C shall be responsible fer:

a. Coordinatien of the Envirenrantal Technical Specifications with the Safety Technical Specifications (Appendix A) to avoid ccn-flicts and maintain consistency,

b. Eeview of changes to the Envircncental Tecnnical Specifications and the evaluation of the envircr. mental impact of the change.

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v c.' Review of proposed written procedures required by Sections 5.5.2.

and 5.5.3 below and changes thereto, which affect the environrental impact of the station.

d. Review of proposed changes to station systems to determine the environmental impact of the changes.

e. Investigation of all reported instances of violation of the ,,

Environmental Technical Specifications; and where the investiga-tion indicates, evaluation and formulatien of recomendations to prevent recurrence,

f. Review of environmental monitoring programs to detect potential or existing significant adverse environmental impacts that have not been' evaluated, or that are significantly greater than that evaluated by the Cemission.

5.3.1.3 Au tho ri ty.

The SNSOC shall:

a. Review the environmental evaluation of all changes described in Section 5.3.1.2 a, b and c, above. When the evaluation indicates that such activity may result in a significant adverse environ-mental impact that was not evaluated, or that is significantly greater than that evaluated by the Commission, the SNSCC shall O ensure that a written evaluation of such activities is provided to and prior approval is obtained from the Director of Nuclear Feactor Regulation for the activities,

b. If the SNSOC determines that unexpected harmful effects or evidence of irreversible damage are occurring as a result of operatien of the station, the SMSOC shall ensure that an acceptable analysis of the problem and a plan of action to eliminate or sf gnificantly reduce the harmful effects or damage is submitted to the Comission for review and approval.

c. Review written reports prepared as a ref, ult of investigations and rrviews conducted under 5.3.1.2 a, e and f. ,

5.3.1.4 Records l

l The SN50C shall maintain written minutas of each meeting and copies l

shall be provided to the Ch:im.c . :f th: Sy:t:m hel::r I:fety :nd

' -Oper+ ting Co r fste: (SyNSCC). D s cdec.c Seq EvaMic,,

and (c n(ed .

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5.3.2.1 Function The rum De S ; rd::ks % r-c.cr, Ou:lity S:paA m ave:nc:, Cp:r::kn: and 'uf ' manee shalll perform independent audits of the implementacicn Gf tN Environmental Technical ~5peci fications.

5.3.2.2 Audits The following audits shall be completed:

a. The conformance'of facility eperation to provisions centained within these Environmental Technical Specifications and applica-ble license conditions at least once per 12 menths.

b. The performance, training and qualifications of the facility staff involved in ensuring and monitoring compliance with tnese Environmental Technical Specifications at least once per 12 months.

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect the environmental impact of the station at least once per 12 months.

5.3.2.3 Rec:rds Frovide a written report of the results of the audits required by i 5.3.2.2 above to the SNSOC, the 6:4SM,and the Station Manager. l SS4 Ev A E.,,u~1CeA m OM O t_ m,,3, _ s% gyga,,

5.3.3 S/ t b Mu:10:r R fe u :nd C::r: tin; Cc :-itt:: (SyNSCO) d L Am ,

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'h; syn 000 as described in .Section 6.5.2 of Appendix A of this license. l shall function to provide independent review of designated activities related to the environmental impact of the station.

5.3.3.2 Review SGC .

n: syn 500 shall review and, where necessary, ccm.ent on the results I of the reviews conducted by the SNSOC and the independent' audits con u..ductedbytheSegais;r(weQ lity hsur:ne:, Oper: tion: :nd cmag Assu w eu-a.

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seL V j h: !y':50C has the responsibility fcr ensuring that the stavon is 1 ocerated in accordance with the re:uire ents of this M:erse and applicable I;F.C regulations.

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5.3.3.4 Autho ri ty_

hrute - ScSety be.le h c.nd C d ru The SyM50C shall report to and advise the E=:utiv: M:::;e r- <--

Licen:ing :nd Qu:lity %:er:nce, who shall advise the E,veh #-

Vice e-esident-Fower on those areas relating to the environment.a1 '

impact of the s tation.

5.3.3.5 Records The SyMSOC th:1' m: int:in "-itten +ute: Of each meettng and 2 ccpy :h:1' be provi ded te the 00m-i tt:0 erbers-and-the-

-Enc uti v: " ice o re:ident4cwcr On the:: cre:: 10 ti ng to-the-en"' renment:1m i p::t of the state.

SEE KITACHED PAGE 5.4 State and Federal Fermits and Certificaty None 5.5 Frecedures 5.5.1 Written Frecedures i Cetailed written procedures, including applicable checklists a-d instructions, shall be prepared and follcwed for all activities in.:1.ed in carrying cut the Environ ental Technical S:scificatiens as da *ined i in Sections 5.5.2, 5.5.3, and 5.5.4, below. Frocedures shall inc!vde sampling, data recording and storage, instrument calibration, measure-ments and analyses, and actions to be taken when limits are acpr:eched or exceeded. Testing frequency of any alarm shall be included. These frequencies shall be determined from experience with similar instru-ments in similar environments and from nanufacturer's technical ranuals.

5.5.2 Ooeratine Procedures Plant standard cperating procedures shall include provisions, in addition 'to the procedures specified in Section 5.5.1, to ensure that all plant systems and components are operated in compliance with the 1.imiting Conditions of Operations established as part of the Environ-mental Technical Sp,ecifications.

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(_/ 5.3.3.5 Records Records of SEC activities relating to the environmental .

impact of the station shall be prepared and maintained in the SEC files and a sum =ary shall be disseminated as indicated belev each calender =onth.

1. Vice President - Nuclear Operations

2. Nuclear Power Station Managers

3. Manager - Nuclear Operations and Maintenance 4 Manager - Nuclear Technical Services

5. Manager - Quality Assurance, Operations

6. Others that the Director - Safety Evaluation and Control may designate.

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( Attachment 4 DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE NORTH ANNA POWER STATION As a result of the management reorganization of April 1,1980, changes to Section 6.0 ADMINISTRATIVE CONTROLS were required to reflect the organization of a Nuclear Operations and Maintenance Department and a Nuclear Technical Services Department. The April 1, 1980 management reorganization changes were approved for North Anna Unit No. I by the Staff and issued as Amendment No.

17. The April 1, 1980 management reorganization changes were approved and issued with the low-power operating license for North Anna Unit No. 2 on ,

April 11, 1980. Changes were proposed to the April 1, 1980 organization changes in our license amendment request dated August 1, 1980 (Serial No. 678) to reflect the addition of an Assistant Station Manager to the Station organi-zation. The above changes were further revised by our license amendment submittal dated August 28, 1980 (Serial No. 731), which proposes the implemen-tation of an independent safety review group and the deletion of the existing System Nuclear Safety and Operating Committee. In order to provide the NRC Staff with a complete, consistent, and up-to-date package of proposed organi-zation changes, the changes outlined above have been consolidated in a " master package" for submittal to the Staff. The " master package" also reflects changes to Section 6.0 resulting from the TMI Lessons Learned Category A changes previously submitted to the Staff for review in our license amendment request dated October 15, 1980 (Serial No. 845). The " master package" is discussed below.

Technical Specifications Figure 6.2-1 has been revised to show the new structure of the offsite organization for facility management and technical support. The previous positions of Senior Vice President-Power and Vice President-Power Supply and Production Operations have been deleted from the Technical Specifications. The deleted positions have been replaced by the Executive Vice President-Power, the Senior Vice President-Power Operations, and the Vice President-Nuclear Operations. All previous references to the Senior Vice President-Power and Vice President-Power Supply and Production Operations positions have been revised to reference either the Senior Vice President-Power Operations or the Vice President-Nuclear Operations positions.

As indicated by Figure 6.2-1, the Manager-Nuclear Operations and Maintenance and the Manager-Nuclear Technical Services replace the previous position of Director-Nuclear Operations. Both eanagers will report to the Vice President-Nuclear Operations. The Manager-Nuclear Operations and Maintenance has responsibility for the supervision of the Nuclear Station Managers in the operation and maintenance of the Company's operational nuclear units. Both Nuclear Station Managers and the Director-Operation and Maintenance Services report to the Manager-Nuclear Operations and Maintenance. The Director-Opera-tion and Maintenance Services is responsible for coordinating operational and maintenance support with nuclear unit activities. The Section Supervisor-Training, the Section Supervisor-Operation and Maintenance Support, and the hgg Section Supervisor - Adminstrative Services will report to the Director-Operation and Maintenance Services.

The Manager-Nuclear Technical Services has responsibility for technical services activities required to support the Company's operational nuclear units. Reporting to the Manager-Nuclear Technical Services are the Director-Chemistry and Health Physics, the Director-Technical Analysis and Control, and the Director-Safety Evaluation and Control. The Director-Chemistry and Health Physics will provide support to the nuclear stations in the areas of chemistry and health physics. The Director-Technical Analysis and Control is responsi-ble for furnishing support for station design modifications and responses to NRC requirements. The Director-Safety Evaluation and Control, who is respon-sible for offsite safety review of nuclear power station operations, is discussed in greater detail below.

The August 28, 1980 submittal (Serial No. 731) proposed the transfer of the independent review responsibility from the existing System Nuclear Safety and Operating Committee (SyNSOC) to the Safety Evaluation and Control (SEC) staff and proposed the transfer of the System Nuclear Safety and Operating Committee audit responsibility to the Quality Assurance Department.

The Safety Evaluation and Control staff will be composed of a Director and a minimum of three staff members qualified to perform independent reviews. The ,

Director-Safety Evaluation and Control will report to the Manager-Nuclear Technical Services, who will advise the Vice P re s ident-Nuc. lea r Operations on the activities of the Safety Evaluation and Control staff. This organiza-tional structure will assure that sufficient attention is directed towards examination and evaluation of safety concerns and that management is cognizant of the results of these Safety Evaluation and Control staff reviews.

The Safety Evaluation and Control staff will provide the independent reviews of station operational activities required by ANSI N18.7-1976/ANS 3.2 (Admin-strative Controls and Quality Assurance Program for Operational Nuclear Power Plants), which are presently provided by the System Nuclear Safety and Operat-ing Committee. The advantages of this proposed change are threefold.

First, the Safety Evaluation and Control staff is composed of indivi-duals with direct nuclear experience in their respective technical disciplines. Presently, Safety Evaluation and Control staff specialists meet or exceed the criteria proposed in Technical Specification 6.1.C 2.b.

The prcposed requirement in Specification 6.1.C.2.b exceeds the criteria for review t.taff specialists" established in ANSI N18.1-1971/ANS 3.1-1978 (Standard For Selection and Training of Personnel for Nuclear Power Plants) and meets the present qualification position of the Commission.

Additionally, the Director -Safety Evaluation and Control exceeds the l

criteria established by ANSI N18.1-1971/ANS 3.1-1978 for the Supervisor Futu.c Safety Evaluation and Control of an independent review staff.

staff members may not meet the qualification criteria for " staff specialists" positions; however, such individuals will act he directly responsible for the independent review function of Safety Evaluation and Control.

Secondly, the independent reviews of station operational activities by '

the Safety Evaluation and Control staff will be performed on a continuous basis as part of their routine responsibilities. This is in contrast to O an intermittent or scheduled review committee approach; therefore, the Safety Evaluation and Control reviews will be responsive to station time constraints while also providing a more comprehensive review of items presently processed by the System Nuclear Safety and 01 erating Cocnittee.

. _ _ . - . - - -. -~ . -. .

h ' Finally, other Safety Evaluation and Control staff routine responsibili-ties. require continuous review of industry-wide operational experience, t

technical information, and regulatory issues. This effort should main-tain a high level - of " state-of-the-art" expertise within Safety Evalua- -

tion and ' Control regarding ~ operational activities and general industry concerns. It is anticipated that the Safety Evaluation and Control. staff will provide the majority of the expertise necessary to perform indepen-dent review activities; however, technical consultants and in-house specialists will be utilized .for special concerns when Safety Evaluation and Control review requires additional expertise.

^

As'a result of this change, safety will be enhanced by the proposed. transfer of independent review responsibilities from the System Nuclear Safety and'-  ;

Operating Committee -to the Safety Evaluation and Control staff .by upgrading  ;

the quality and timely . processing of the independent reviews - of station operational activities.

Specification 6.5.2.8 for North Anna Units . No. I and No. 2 requires the performance of audits of station activities under the' cognizance of the System Nuclear Safety and Operating Committee. As a result of this proposed change, the audit responsibilities outlined in Specification 6.5.3.1, which are pre-sently being performed under the cognizance of the System Nuclear Safety and Operating Committee by the Quality Assurance Department, will be transferred to the Quality' Assurance Department. Such a transfer will provide for appropriate organizational channels for the reporting of audit results, ensure the availability of appropriate technical expertise for the performance of these audits,' and ensure that' these audits are performed in an effective and ,

timely manner.

NRC Staff comments received relating to the acceptability of the August 28, '

1980 submittal were concerned with the sections (1) on the SEC. staff composi- l tion and qualification requirements, (2) on the SEC staff meeting requirement '

(which was omitted from the August 28, 1980 submittal), and (3) on technical items to be reviewed by SEC. In order to address these NRC concerns, proposed changes are enclosed which incorporate (1) requirements for a monthly meeting of the SEC staff, (2) requirements for an academic degree and five years technical experience to qualify as a SEC staff specialist, (3) requirements I

for the review of the Quality Assurance Department audit program, and (4) revisions to the distribution of Quality Assurance Department audit reports.

As a result of the reorganization of the Licensing' and Quality Assurance Department, the Licensing function has been transferred to Safety Evaluation and Control and the Quality Assurance organization has been restructured. The Executive Manager-Quality Assurance will be responsible for the quality assurance effort encompassing the areas of engineering, construction, ar.d l

operational activities of both the fossil and the nuclear stations. He will ,

l also be responsible for the area of corporate emergency response planning and  :

implementation. The Executive Manager-Quality Assurance will report to the l I Senior Vice President-Power Operations. The Manager-Quality Assurance, Opera-L tions will be responsible for implementing quality . assurance programs which are related to the operational activities of the fossil and nuclear power

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B O statiens. >:e wi11 revert te the Executive Meeaser-oe 11tv Assurance.

Director-Quality Assurance, Nuclear Operations will be responsib1e for the The implementation of quality assurance programs which are related to the opera- ,

tional activities associated with the' nuclear power stations. He will report ,

to the Manager-Quality Assurance, Operations.

The organization charts for the North Anna Environmental Technical Specifica-tions and the Appendix "A" Technical Specifications have been revised to reflect the restructuring of the Quality Assurance Department and changes to other organization titles. The previous title of Executive Manager-Licensing '

and Quality Assurance has been revised to Executive Manager-Quality Assurance.

In addition, the positions of Manager-Quality Assurance, _ Operations and Director-Quality Assurance, Nuclear Operations are shown on the organization chart; however, those positions of the Quality Assurance Department which have no direct responsibility pertaining to the operation of the nuclear stations have not been shown on the Technical Specifications organization chart or referenced in the text of the Specifications.

Technical Specification Figure 6.2-2 has been revised to show the new 'struc-ture of the North Anna Power Station organization. As explained above, the Station Manager reports to the Manager-Nuclear Operations and Maintenance.

Our July 30, 1980 submittal (Serial No. 487) proposes revising Section 6.0 to add the new position of Assistant Station Manager to the North Anna Power Station organization. The Assistant Station Manager will be directly respon--

sib 1e f or the safe operation and maintenance of the power station. He will ,

serve in a coordinating capacity to the Station Manager for the off-site  ;

oerie8 the ehsence ef the Station Mee ser, the

.O ectivities of the Statien.

Assistant Manager will act as the Station Manager. The Assistant Station Manager will also be the Vice Chairman of the Station Nuclear Safety and ,

Operating Committee (SNSOC). The Superintendent-Operations, the Superinten-  !

dent-Maintenance, and the Superintendent-Technical Services will report to the  !

Assistant Station Manager. All three of these superintendents will remain ,

members of the SNSOC.

The positions of Operating Supervisor and Auxiliary Operator have been elimi- ,

i nated from the organization chart. In addition, the position tit 1e of Assistant Control Room Operator has been revised to Control Room Operator Trainee. The positions of Maintenance Coordinator and Mechanical Supervisor  :

have been replaced on the station organization chart by the position of Supervisor-Mechanical Maintenance. Both the Maintenance Coordinator and the Mechanical Supervisor report to the Supervisor-Mechanical Maintenance. Other .

title changes made to the organization chart include the change of Supervisor- '!

Safety Engineering to Engineering Supervisor (Safety Engineering), the change of Engineering Supervisor to Engineering Supervisors to reflect the two positions of Engineering Supervisor-Performance and Tests and Engineering Supervisor-Design Changes and Projects and, the change of Training Supervisor to Supervisor-Nuclear Training. The Supervisor-Hea1th Physics position has been shif ted such that he will now report directly to the Station Manager instead of reporting to the Superintendent-Technical Services. The positions of Supervisor -Nuclea r Training and Supervisor-Administrative Services will also report to the Station Manager.

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An appraisal of the North Anna health physics program was conducted by the NRC office of Inspection and Enforcement during the period of May 5-16, 1980.

The results of this appraisal were forwarded in a letter to Mr. J. H. Ferguson dated September 15, 1980 (Serial No. 787). One of the NRC recommendations resulting from the program review is that the Supervisor-Health Physics Le added as a member of the Station Nuclear Safety and Operating Committee (SNSOC). The Supervisor-Health Physics was previously a member of the SNSOC; however, as a result of an Amendment for North Anna Unit 1, he was deleted.

In order to address this concern, the proposed change is to reinstate the Supervisor-Health Physics as a member of the SNSOC. Since many operations at the station involve the health physics group in some capacity, the addition of the Supervisor -Health Physics will improve the quality of SNSOC reviews by adequately appraising the impact of radiation safety on station activities.

The proposed Technical Specification Changes to inco rpo rate TMI-2 Lessons Learned Category A changes, which were submitted by our letter dated October 15, 1980 (Serial No. 845), are reflected in the attached pages.

These changes revised the format of the minimum shift crew manning table and incorporated revisions to the sections on training and facility staff training.

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