ML20127N367

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Proposed Tech Specs Section D6.0,administrative Controls for Proposed Amend 186
ML20127N367
Person / Time
Site: Rancho Seco
Issue date: 01/19/1993
From:
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20127N332 List:
References
NUDOCS 9301290182
Download: ML20127N367 (21)
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RANCHO SECO UNIT 1 -

PERM ANENTLY DEFUELED TECl. lNICAL SPECIFICATIONS D6.0 ADMINISTRATIVE CONTROLS D6.1 RESPONSIBILITY D6.1.1 The Plant Closure Manaper (PCM) shall be responsible for the managsent of the - l overall facility, the operation anu maintenance of the plant, and ensuring the safe storage of .

irrudiated core co.mponents, and shall delegate in writing the succession of his responsibilities during his absences.

D6.1.2 The Shift Supervisor (or a qualified, designated individual) shall be responsible for the control room command function. A management directive to that elTect, signed by the PCM, l; shall be issued to all plant personnel on an ANNUAL basis.

D6.2 ORGANIZATION D611 CORPORATE AND ON SITE ORGANIZATIONS Corporate and on site organizations shall tr established for corporate management and facility '

operation respectively during the PERM ANENTLY DEFUELED MODE. The organizations shall include the positions responsible for activities afrecting the safe storage ofirradiated core?

components and the overall safety of the facility.

a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating _

orgamzation positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in ~

equivalent forms of documentation. The organization and responsibilities shall be documented in the Defueled Safety Analysis Report (DSAR). .ll

b. The PCM shall be msponsible for overall unit safe operation and shall have control over ,l those on site activities necessary for safe operation and maintenance of the plant,
c. The General Manager (GM), through the Assistant Genval Manager (AGM) and Chief Operations Officer and the Deputy AGM, Operations, shall have corporate responsibility l for overall safe operation of the fa'cility and shall take any measures needed to ensure acceptable _ performance of the staffin operating, maintaining, and providing technical support to the facility to ensure NUCLEAR SAFETY.
d. The individuals who train the operating stalT and those who carry out health physics functions may report to the a,propriate on site manager; however, they shall have sutricient orgamzational freedom to ensure their independence from operating pressures.
e. The Quality organization shall report to the PCM to ensure independence from operating pressures. In addition, the Quality organization has the authority to take significant issues concerning the quality of operations of Rancho Seco to the Deputy AGM,

' Ope _ rations.

Proposed

Amendment No.186 '

D6-1 d . < a . .,, -  ; . :.

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RANCHO SECO UNIT 1 .

PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continuedi D6.21 FACILITY STAFF The facility organization shall be as shown in the DSAR, and: Lll ,

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table D6.21.
b. At least one individual qualified to stand watch in the Control Room (a Non-Certified -

Shutdown Control Room Operator or a Certified Fuel Handler) shall be in the Control Room when fuel is in the spent fuel pool. ,

c. An individual qualified in radiation protection practices and procedures shall be on site during fuel handling operations when fuel is in the spent fuel pool. .
d. All fuel handling operations shall be directly supervised by a Certified Fuci dandler,
e. Administrative procedures shall be developed and im ,lemented to limit the working hours of facility staff who perform functions important to t le safe storage ofirradiated fuel assemblies; e.g., Certified Fuel Handlers, radiation protection personnel, non-certified operators, and key maintenance personnel.

Adequate shift coverage shall be maintained without routine heavy use of overtime. The' objective shall be to have operating personnel work a normal shift schedule. However, in

  • he event that unforeseen problems require substantial amounts of overtime to be used, or-Juring major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed:
a. 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,

b. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour :

period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, all excluding shift turnover time.

c. A break of at least eight hours should be allowed between work periods, including shift turnover time.
d. The use of overtime should be considered on an individual basis and not for the -

entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the PCM or designee, in l-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 semiannually by the PCM or designee to assure that e .cessive hours have not been assigned. Routine deviation from the above guidelines is not authorized.

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Proposed Amendment No.186 -

D6-2 .

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RANCliO SECO UNIT 1 - 9 PERM ANENTLY DEFUELED - ,

TECIINICAl, SPECIFICATIONS ~ '

fJ2hilNISTRATIVE CONTROLS (Continued) -

FACILITY STAFF (Continued) ,

f. The individual who directly supervises the Shift Supervisors shall be a Certified Fuel; Handler. ,

TABLE D6.21 MINIMUM SillFT CREW REQUIREMENTS

  • NUMBER FOR POSITION PERMANENTLY DEFUELED hiODE Shift Supervisor ** I Non-Certified Operator ,_L Minimum Total Personnel 2
  • In the event that any member of a minimum shift crew is absent or incapacitated due to illness or injury, a qualified replacement shall be designated to report on site within 2' L

hours. Under these circumstances, the remaining shift crew member must stayin the "

l control room until the replacement shift crew member arrives in the control room.

    • The Shift Supervisor shall be a Certified Fuel Handler.

D6_ :3 FACILITY STAFF QUALIFICATIONS .

Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI  :

N18.1-1971 for comparable positions, except for the individual assigned the ftmetion of the: _ I Radiation Protection Manager, who shall meet or exceed the qualifications 01 Regulatory Guide 1.8, September 1975.

D6.4 TR AINING

' A~ training program for the unit staff shall be maintained under the direction of the PCM and I

meet or exceed the requirements and recommendations of ANSI N18.1-1971,_Section 5.5. A-

- retrainin.; and replacement training program Ibr the Certified Fuel Handlers shall be conducted L in accor(ance with a NRC approved training "rogram l' ~ Proposed L 1 Amendment No.186 l ,

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RANCllO SECO UNIT 1 -

PERM ANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTI(OLS (Cont _inued)

D6.5 REVIEW AND AUDIT D6.5.1 PLANT REVIEW COMMITTEE (PRC)

FUNCTION D6.5.1.1 The PRC shall function to advise the PCM on matters related to NUCLEAR .

SAFETY.

COMPOSrrlON {~

D6.5.1.2 The PRC shall be composed of a Chairman and a minimum of four members.

MEMIlERSHIP D6.5.1.3 Membership of the PRC shall be as defined below;

a. A list of members made up of personnel filling positions in the Nuclear Organization and others who meet or exceed the minimum qualifications of ANSI N18.1-1971,- Section 4.2 or 4.4, shall be developed and approved by the PCM. _l
b. A list of alternate members of the PRC shall be developed and approved by the PCM. l'
c. The Chairman of the PRC shall be appointed by the PCM When a meeting is scheduled .l or an emergency meeting is necessary, and the PRC Chairman will be absent, an alternate -

Chairman may be designated by the PRC Chairman or the PCM from among the PRC 1 members in Specincation D6.5.1.2 MEETING FREQUENCY D6.5.1.4 -The PRC shall meet at least once per calendar month or more frequently as convened .

by the PRC Chairman, or as directed by the PCM.

QUORUhi D6.5.1.5 A Quorum of the PRC shall consist of a majority of the members in Specification

- D6.5.1.2 including the Chairman or alternate Chairman. No more than two alternates shall- 1 participate in PRC activities a any one time for the purpose of establishing a quorum.

Proposed

- Amendment No.186 D6-4 q q

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- RANCliO SECO UNIT i PERMANENTLY DEFUELED TECliNICAL SPECIFICATIONS ,

ADMINISTRATIVE CONTROLS (Continue.d)

- RESPONS[HILITIES D6.5.1.6 The PRC shall be responsible for review of:

a. - The required safety evaluation of: (1) all procedures and programs required by Specification D6.8 and changes thereto, and (2) any other proposed procedures or programs or changes thereto which are as determined by the PCM to affect NUCLEAR l:.

SAFETY.

b. The safety evaluations of proposed tests and experiments that afTect NUCLEAR SAFETY.
c. Proposed changes to the Technical SpeciGeations or the PossessionOnly License. l'
d. All safety evaluations of proposed changes or modifications to plant systems or equipment -

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that alTect NUCLEAR SAFETY. Items which are determined ay a qualified reviewer as -

not involving an unreviewed safety question, a charige of Technical Specifications,'or a ~

change ia a licensing basis document need not be reviewed by the PRC.

e. Investigations of all violations of the Technical Specifications to determine adequacy of - ,

corrective action and to detect any degrading trend,

f. Facility operations to detect potential safety hazards.
g. Events requiring a Licensee Event Report as defined by 10 CFR 50.73 and NUREG-1022 to determine adequacy of corrective action and to detect any degrading trend.' (See

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Specification D6.9.5.)

h. Special investigations and reports thereon as requested by the PCM.
i. The Physal Security Plan and changes thereto.
j. The Eniergency Plan and changes thereto.
k. The Fire Pro.tection Plan Program and changes thereto.-
1. Changes to the PROCESS CONTROL PROGRAM, the OFF-SITE DOSE CALCULATION MANUAL and the RADIOLOGICAL ENVIRONMENTAL . ',

MONITORING PROGRAM M ANUAL. -(See Specifications D6.13 and D6.14.)

m. Major changes to the Radioactive Waste Treatment Systenis (Liquid, Gaseous and Solid).
n. Review of any accidental, unplanned, or uncontrolled release of radioactive material to the environs, including the preparation and forwarding of reports covering evaluation, -

iecommendations,- and disposition of the corrective action to prevent recurrence. The PRC shall forward these reports to the PCM and the MSRC. l Proposed

Amendment No.186-D6-5

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RANCllO SECO UNIT 1 PERMANENTLY DEFUELED TEC1INICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)

AUTilOIUD' D6.5.1.7 The PRC shall:

a. Recommend in writing to the PCM approval or disapproval ofitems considered under l Specincation D6.5.1.6.
b. Render determinations in writing with regard to whether or not each item considered under Speci0 cations D6.5.1.6a through e, and m above constitutes an unreviewed safety :

question.

c. Provide immediate written notiGeation to the MSRC Chairman of disagreement between the PRC and the PCM; however, the PCM shall have responsibility for resolution of such -l .

disagreements pursuant to Speci0 cation D6.5.1.1.

RECORDS D6.5.1,8 Minutes of each PRC meeting, including appropriate documentation of reviews encompassed by SpeciGeation D6.5.16e and g, shall be prepared, approved, and forwarded to the PCM and to the MSRC Chairman witilin 14 days followmg each meeting. l-D6 5 2_M ANAGEMENT SAFETY REVIEW COMMITTEE (MSRC)

FUNCTION D6.5.2.1 The MSRC shall function to provide independent review and audit of designated l_

activities in the areas of:

-a. Facility Operation

b. Engineering / Nuclear Engineering
c. Chemistry and Radiochemistry l d. Radiological Safety
e. Quality Assurance Practices COMPOSITION D6.5.2.2 The MSRC shall be composed of a Chainnan and a minimum of four members. The MSRC membership shall be made up of direct reports to the PCM or above as shown on the l Nuclear Organization or of other personnel meeting or exceeding the minimum quali6 cations of

-ANSI /ANS 3.1-1981, Section 4.7.2.

l Proposed

. Amendment No.186 D6-6

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RANCHO SECO UNIT 1 PERM ANENTLY DEFUELED t

. TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued) hiEhiHERSHIE D6.5.2.3 The Chairman of the MSRC shall be appointed by the Deputy AGM, Operations. A l-current list of members and alternates as described in Specification L)6.5.2.2 shall be developed and approved by the Deputy AGM, Operations and niaintained by the MSRC Secretary. -In the l absence of the Chairman, an Alternate Chairman may be designated by the MSRC Chairman or the Deputy AGM, Operations. The Alternate Chairman shall be selected from among the l MSRC members in Specification D6.5.2.2.

hiEETING FREQUENCX D6.5.2.4 The MSRC shall meet at least once per calendar quarter and as convened by the MSRC Chairman or as directed by the Deputy AGM, Operations. l .

QUORUM D6.5.2.5 A quorum of MSRC shall consist of a majority of the members in Specification D6.5.2.2, inc;uding the Chairman or alternate Chairman. No more than two alternates shall participaw in MSRC activities at any one time for the purpose of establishing a quorum. No more tl tan a minority of the quorum shall have line responsibility for operation of the unit.

REVIEW D6.5.2.6 The MSRC shall be responsible for review of:

a. The safety evaluation for (1) changes to procedures, equipment or systems, and (2) tests or; experiments completed under the provisions of 10 CFR 50.59 to ver;fy that such actions do not constitute on unreviewed safety question.
b. Proposed changes to procedures, equipment or systems which involve an unre /iewed safety question as defined in 10 CFR 50.59.

L c. Proposed tests or experimente which involve an unreviewed safety question as defined in 10 CFR 50.59.

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d. Proposed chan es in Technical Specifications or the Possession-_Only License. l e- Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or ofinternal procedures or instructions having NUCLEAR L SAFETY significance,
f. Significant operating abnormalities or deviations from normal and expected performance of plant equipment that alTect NiICLEAR SAFETY.
g. LICENSEE EVENT REPORTS as defined by 10 CFR 50.73 and NUREG-1022.

Proposed Amendment No.186 L - D6-7 p

.RANCilO SECO UNIT 1 -

PERMANENTLY DEFUELED t TECilNICAL SPECIFICATIONS

- ADMINISTRATIVE CONTROLS (Continued) , ,

REVIEW (Continued) hi Any indication of an identined signincant denciency in the design or operation of safety-related structures, systems, or components.

i. Reports and meeting minutes of the PRC.

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j. Any facility activity brought to. the attention of the MSRC by the District's executive -

management which may be indicative of conditions adverse to NUCLEAR SAFETY.

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k. The MSRC shall provide oversight review of:

- The District Quality Program, including the Atidit Program content, implementation and audit reports,

- The Radioactive Waste Control Program, and

- Eirectiveness of the LICENSEE EVENT REPORT Program per SpeciGcation D6.6.

AUTIIORITY i

D6.5.2.7 The MSRC shall:

a. Report to and advise the Deputy AGM, Operations of those areas of responsibility 'l' specined in Specification D6.5.2.6.
b. Recommend to the Deputy AGM, Operations other areas of facility operation for which .. -l the MSRC has determined the need for additional auditing per SpeciGcation' D6.5.4g.
c. Advise the_ Deputy AGM, Operations of the. need for independent auditing of facility I operations.

RECOR DS D6.5.2.8 Minutes of each MSRC meeting and separate documentation of reviews encompassed by SpeciGcations 6.5.2.6d through h shall be prepared, approved, and forwarded to the Deputy-AGM, Operations within 14 days following each meeting.

4 Proposed L - Amendment No.186

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O RANCilO SECO UNIT 1 PERM ANENTLY DEFUELED TECilNICAL SPECIFICATIONS q A_ DMINISTRATIVE CONTI(OLS (Continued)

D6.5.3 TEGjNICAlaliyjEUND CONTROL-

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Activities which affect NUCLEAR SAFETY shall be conducted as follows:

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a. Procedures, plans, manuals, and programs required by Specincation D6.8 and other procedures, plans, manuals, and programs which affect plant NUCLEAR SAFETY, and -

changes thereto, shall be prepared, reviewed and appromd. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual (s) oth than the preparer, but who may be from the same organization as the preparer of the' procedure, plan, manual and program or change thereto. Programs, plans, manuals, and procedures other than plant administrative procedures will be approved as delineated in writing by the PCM, but not lower than a direct report to the PCM. Such procedures, l plans, manuals and programs shall be reviewed periodically in accordance with ,

administrative proceduret.

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The PCM will approve plant administrative procedures, Security Plan implementing -  :

Procedures and Emergency Plan Implementing Procedures. ,

Approval of temporary procedure changes which clearly do not change the intent of the approved procedure can be made by two members of the plant management stafr, at least one of whom is a Certined Fuel llandler. The change shall be documented, reviewed and approved by the procedure's approval authority within 14 days ofimplementation;

b. Proposed changes or modiGeations to plant systems or equipment tha_t alTect NUCLEAR SAFETY shall be reviewed by an individual (s) other than the individual (s) who designed the modincation, but who may be from the same organization as the individual (s) who designed the modincations. Such modiGcations shall be approved by the PCM or his-designec as delineated in writing, but not lower than a direct report to the PCM.
c. Proposed tests and experiments which afTect plant NUCLEAR SAFETY and are not addressed in the DSAR shall be reviewed by an individual (s) other than the individual (s) -l-.

who prepared the proposed test or experiment. Such tests or experiments shall be approved by the PCM or his designee as delineated in writing, but not lower than a direct L report to the PCM. ,

d. Individuals responsible for reviews performed in accordance with Specification D6.5.3a, b' and c shall meet or exceed the qualineation requirements of Section 4.4 of ANSI N;3.1 1971. Each such review shall include a determination of whether or not additional, -

l cross-disciplinary review is necessaty. 'If daemed necessary, such a review shall be performed by the review persontrA of the appropriate disc.ipline. A list of qualiGed reviewers for the independent reviews described in D6.5.3a, b and c above shall be established by the PCM.

Proposed Amendment No.186 :

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RANCilO SECO UNIT 1 j PERM ANENTLY DEFUELED l TECllNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)

BiCIINICAL REVIEW AND CONTROL (Continued)

c. Events reportable pursuant to Specification D6.9.5 and violations of Technical Specifications shall be investigated and a report prepared which evaluates the event and which provides recommendations to prevent recurrence. Such reports shall be reviewed by the PRC and forwarded to the PCM and the MSRC Chairman. l D6.5.4 AUDITS Audits of facility activities shall be performed under the cognizance of the Quality organization supervisor. These audits shall encompass:
a. The conformance of facility operation to provisions contained within the Technical Speci0 cations and applicable license conditions at least once per year.
b. The performance and qualifications of the entire Rancho Seco facility technical stafrat least once per year.
c. The result of actions taken to correct deGeiencies occurring in facility equipment, structures, systems or methods of operation that affect NUCLEAR SAFETY at least once per 6 MONTilS for those changes not previously audited.
d. The performance of activities required by th. Quality Assurance Program to meet the criteria of 10 CFR 50, Appendix B at least once per 2 years.
c. The Facility Emergency Plan and implementing procedures at least once per year.
f. The Facility Security Plan and implementing procedures at least once per year.
g. Any other area of facility operation considered appropriate by the PCM or the Deputy AG M, Operations, j
h. Compliance with fire prmeetion requirements and implementing procedures at least once per 2 years
i. An Independent fire protection and loss prevention inspection and audit shall b:

wrformed ANNUALLY using either qualified oft-site licensee personnel or an outside ire protection firm.

j. An inspection and audit of the fire protection and loss preventior' program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

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k. The Radiological Environmental Monitoring Program (REMP) and the results thereof at least once per year.
1. The ODCM and implementing procedures at least once per 2 years.

Proposed Amendment No.186 D6-10 l

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RANCIIO SECO UNIT 1 PERMANENTLY DEFUELED ,

TECIINICAL SPECIFICATIONS

- ADMINISTRATIVE CONTROLS-(Continued) ,

AUDITS (Continued)

m. The PCP and impicmenting procedures for processing and pac. aging of radioactive wastes from liquid ryctems at least once per 2 years.
n. The performance of activities rquired by the Quality Assurance Program for Effluent -

Control and Environmental Monitoring at least once per year.

Audit reports of reviews encompassed by Speci0 cation D6.5.4 shall be forwarded to the Deputy AGM, Operations, the PCM, the MSRC Chairman, and the management positions responsible for the areas reviewed within 30 days after completion.

D6.6 LICENSEE EVENT REPORT ACTION ';

The following actions shall be taken for events which are reportable as LICENSEE EVENT REPORTS:

a. The Commission shall be notiGed and a report submitted per SpeciGcation D6.9.5, pursuant to the requirements of 10 CFR 20.405,50.73, ano appropriate portions of 73.71 (as described in the Rancho Seco Physical Security Plan) and
b. Each LICENSEE EVENT REPORT shall be reviewed by the PRC and the results of this review submitted to the MSRC. Each LICENSEE EVENT REPORT shall be reviewed and approved by the PCM or designee.

Dft2 -NOT USED- l D6.8 PROCEDURES. PL ANS. M ANUALS. AND PROGR AMS-D6.8.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained covering the activities referenced below:

a. The apphcable procedures recommended in Appendix "A" of Safety Guide 33, November  :

1972

b. Irradiated Core Component Storage, Fuel Movement Operations, Decommissioning, and Decontamination
c. Surveillance and test activities on equipment required for long term t ue storage of irradiated core components.
d. Security Plan implementation
e. Emergency Plan implementation
f. Fire Protection Program Plan implementation 3 PCP implementation
1. ODCM implementation
i. REMP M ANUAL implementation .
j. Quality Assurance Program for Efiluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979
k. Certined Fuel Handler Training Program implementation
1. -Quality Assurance Program implementation
m. Radiation Protection Program implementation Proposed Amendment No.'186 D6-il a .

RANCHO' SECO UNIT I PERMANENTLY DEFUELED-TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)

D6:12 li[Gli RADIATION AREA

. D6.12.1 - In lieu of the " control device" or " alarm signal" required by 10 CFR 20.203(c)(2).

a. Each High Radiation Area in which the intensity of radiation is equal to or greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously posted as:

a High Radiation Area, and entrance thereto shall be controlled by issuance of a -

Radiation Work Permit. Any individual or group ofindividuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates.

the radiation dose rate in the area.

b. Each liigh Radiation -Area in which the intensity of radiation is equal to or greater than 1,000 mrem /hr shall be subject to the provisions of Specification D6.12.la above, and, in additio.n, locked doors shall be provided to prevent unauthorized entry into such area.- 7~

The keys shall be maintained under the administrative control of the on_ duty Shift Supervisor. -In lieu oflocked doors, certain areas within the Reactor Building, where no .

enclosure exists for the purpose oflocking, and where no enclosure can be reasonably _

constructed, s..all be barricaded, conspicuously posted, and a conspicuous visible or .

J audible signal shall be activated such that an individual is made aware of the presence of

the fligh Radiation' Area (>1,000 mrem /hr);

D613 FROCESS CONTROL PROGR AM (PGl-

- D6.13.1 The required content of the PCP is defined in Specification DI.6.-

D6.13.2 Licensee-initiated changes to the PCP: j i

n. Shall be documented and records of reviews performed shall be retained as required by

- Specification D6.10.2.o. This documentation shall containi

1) Sufficient information to support the change together with the appropriate analyses - 9 or evaluations justifying the change (s) and
2) A determination that the change will maintain the overall ccaformance of the processed waste product to existing requirements of Federal, State, or other applicable regulations. q e b. Shall become effective after review and acceptance by the PRC and approval by the PCM.

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Proposed

Amendment No.186 D6-18 y

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RANCHO SEEO UNIT 1 PERMANENTLY DEFUELED .

TECHNICAL SPECIFICATIONS o

ADMINISTR ATIVE CONTROLS (Continued)

D6.14 OFF-SITE DOSE CALCULATION AND RADIOLOGICAL ENVIRONMENTAL-.

h40NITORING PROGR AM 3 : \NUALS D6.14.1 The required content of the ODCM is defined in Specification Dl.7.

D6.14.2 The required content of the REMP MANUAL is defined in Dl.10.

D6.14.3 Licensee initiated changes to the ODCM or REMP MANUAL:

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a. Shall be documented and records of reviews performed shall be retained as required by Specification D6.10.2.o. This documentation shall contain:

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1) Sumcient information to support the change together with the appropriate analyses .

or evaluations justifying the change (s) and

2) A determination that the change will maintain the level of radioactive emuent control required by 10 CFR 20.106,40 CFR 190,10 CFR 50.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of emuent dose _-

or setpoint calculations.

b. Shall become elTective after review and acceptance by the PRC and approval by the PCM.
c. Shall be submitted to the Commission in the form of a complete, legible copy _of the entire L

! ODCM and/or REMP MANUAL as a part of or concurrent with the Semiannual 1 - Radioactive Emuent Release Report for the period of the report in which any change to ,

the ODCM and/or REMP MANUAL was made. Each change shall beidentified by markings in the margin of the afTected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented.

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l Proposed Amendment No.186 ._

' D6-19 l

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KEfACIIM ENI.2 Safety Analysis Report and No Significant llazards Consideration for Proposed Technical Specification No.186

.c. .

Proposed Amendment No.186 Log No.1094 Safety Analysis Report Page 1 of 4 SAFl!TY ANALYSIS REPORT Descriptio1LoflChange Proposed Amendment No.186 (PA 186) re-defines the SMUD nuclear organization that will oversee the operation of the Rancho Seco nuclear facility at -

least through the Preparation for Custodial SAFSTOR phase of the Rancho Seco decommissioning projec' The District proposes the following organizational-changes:

1. The District is deleting the Deputy AGM, Nuclear position and -

creating a new position, the Deputy AGM, Operations. The SMUD General Manager, through the AGM & Chief Operations Oflicer and the Deputy AGM, Operations, would have the ultimate corporate responsibility for the overall safe operation of the Rancho Seco nuclear facility. The new position, Deputy AGM, Operations, is taking over the direct corporate responsibilities that the Deputy AGM & Chief Operations Office. had for ensuring the overall safe operation of the Rancho Seco nuclear facility during the Permanently Defueled Mode (PDM),

2. The Management Safety Review Committcc (MSRC) will report to and advise the Deputy AGM, Operations.
3. The Plant Closure Manager (PCM) will take over the Rancho Seco site management responsibilities, previously held by the Deputy AGM, Nuclear, and be directly responsible for the overall day-to-day safe operation and maintenance of the Rancho Seco nuclear facility during the PDM.
4. The Plant Review Committee (PRC) will report to and advise the PCM.

5 The descripti on of the position, under whom audits of facility.

activities are performed, is changed from the Manager, Nuclear Quality Assurance to the Quality organization supervisor. The-Quality organization supervisor will report to the PCM and have authority.to take significant quality issues to the Deputy AGM,-

Operations to ensure independence of the Quality organization function from operating pressures.

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Proposed Amendment No.186 Log No.1094 Safety Analysis Report Page 2 of 4 Dchctiption of Change (Continued)

6. Reference to the Radiation Protection Manager (RPM)is -  %

i editorially modified to clarify that the individual assigned the RPM function will meet the RPM qualification requirements specified in NRC Regulatory Guide 1.8, September 1975, as required by Rancho Seco Permanently Defueled Technical Specification (PDTS) Section D6.3, Facility Staff Qualifications.

These changes affect several sub-sections in PDTS Section D6.0, Administrative Controls.

Also, the District makes a few editorial changes to ensure:

1. The PDTS properly references the Defueled Safety Analysis Report .

(DSAR) and the Rancho Seco Possession-Only License, instead of the Updated Safety Analysis Report (USAR) and the Operating License, respectively, and

'2. The PDTS Section D6.5.1.4 (PRC Meeting Frequency) clearly states that the PRC may convene more frequently than once per month per the direction of the PRC Chairman or the PCM.

ECESOn for ChaDEC In order to establish a nuclear organization commensurate with the managerial-demands that exist for the Rancho Seco facility during the Preparation for Custodial SAFSTOR decommissioning phase, the District proposes to amend the Rancho Seco PDTS, as described above, based on the following:

1. The Rancho Seco Possession-Only License status,
2. The reduced number of credible accidents applicable to Rancho Seco during the Permanently Defueled Mode (PDM),
3. The reduced potential dose consequences that can result from the remaining credible accidents in the PDM, ,
4. The reduced level of activity at the plant during the PDM,

' Proposed Amendment No.186 Log No.1094 -

Safety Analysis Report _ Page 3 of 4 ReasonJnrDChange(Conti nued )

5. The reduced number of personnel that make up the respective departments in the Rancho Seco nuclear organization, and
6. The proposed Rancho Seco Decommissioning Plan (DP) and subsequent additional DP information submitted to the NRC.

Evaluation _andlasia.foLSafely Findings The proposed changes do not affect any systems, subsystems, or components, The changes affect administrative controls only; the Rancho Seco nuclear organization specifically.

PDTS Section D6.0 contains details of the administrative controls and organizational relationships necessary to ensure safe operation of the Rancho Seco nuclear facility during the PDM. The proposed organization and title changes reduce the District management level directly responsible for the corporate and on-site management oversight of the Rancho Seco nuclear facility.

by one management level, commensurate with the activities and safety significance associated with preparing Rancho Seco for the Custodial SAFSTOR decommissioning phase. The SMUD General Manager still has the ultimate.

corporate responsibility for the overall safe operation of Rancho Seco. The-proposed changes continue to maintain the on-site and corporate organizational relationships and controls r.ecessary to ensure the plant will be operated safely

- during the PDM,. at least through the Preparation for Custodial SAFSTOR decommissioning phase.

1 i

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q Proposed Amendment No.186 Log No.1094 Safety Analysis Report Page 4 of 4 q NO.ELGNIE1 CANT II AZ AR DS CORSIDERATION The District has reviewed the proposed changes against each of the criteria in ,

10 CFR 50.92, and, based on the discussion in the above safety analysis report, l concludes .

1

- A significant increase in the probability or consequences of an accident previously evaluated in the SAR will not be created, because the l proposed organization changes continue to capture the essence of the I management oversight features that are important to ensure overall l safe operation of the Rancho Seco nuclear facility during the PDM l l- and the Preparation for Custodial SAFSTOR decommissioning phase. l The proposed amendment will not create the possibility of a new or :i different type of accident than previously evaluated in the SAR, -(

because the changes are administrative in nature, maintain the appropriate organization relationships that will ensure safe plant in the PDM, and do not provide any new mechanisms by which an  ;

accident can occur.

  • The proposed PDTS amendment will not involve a significant l reduction in the margin of safety, because the District will continue to '

maintain the appropriate administrative controls, organizational relationships, and corporate and on-site line management responsibilities necessary to ensure Rancho Seco is operated safely .

l during the PDM.

l d

NITACllM ENT 3 Rancho Seco Nuclear Organization Resulting from PA-186 (forinformation only) 1

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