ML20136J002
| ML20136J002 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/14/1985 |
| From: | MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20136H999 | List: |
| References | |
| TAC-60158, NUDOCS 8511250255 | |
| Download: ML20136J002 (20) | |
Text
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.i Attcchment 1 to AECM-85/0360 Page 1
SUBJECT:
NLS-85/14 and 85/15 and OLCR-NLS-85/06 Technical Specifications 6.1.2, 6.2.3.4, 6.5.2.2, 6.5.2.6, 6.5.2.8.g, 6.5.2.9, 6.5.2.10a & b & c. 6.5.3.lb & e, 6.6.lb, 6.7.la & c, and Figure 6.2.1-1; pages 6-1, 6-3, 6-6, 6-9, 6-10, 6-11, 6-12, 6-13, 6-14.
Facility Operating License NPF-29, page 9.
DESCRIPTION Revisions to the subject Administrative Controls Technical 0F CHANGES:
Specifications are proposed to reflect proposed changes in the GGNS Nuclear Production Department (NPD) Offsite Organization chart (Figure 6.2.1-1).
MP&L discussed the organization
. changes in this submittal with members of your staff on October 24, 1985 and plans to implement these changes, with the exceptions stated below, upon submittal of this letter. The positions of Site Director, GGNS; Manager, GGNS Unit-1 Projects; and Manager, Plant Modification and Construction will be instituted following completion of the present plant outage. These organization changes are proposed to accomplish the following goals:
Consolidate the Support Activities within NPD into one organization.
Provide a more effective management chain of command for NPD support functions.
s Greater management emphasis on engineering support.
On the plant site, provide a higher level of management direction and involvement in plant operations.
Provide a closer tie to the plant organization for design change interface activities by placing these activities under the nuclear operations chain of command.
Implement a project management concept in the nuclear operations organization to effect the following:
Relieve some of the interface burden between plant staff and other organizations to effect project completions.
Allow plant staff to concentrate more time and effort on plant operations by transferring project implementation to a project management group.
Provide the ability to solve problems related to proposed or ongoing projects and thus be able to deliver a product that will better fit the needs of plant staff.
Provide a closer tie and a more expeditious path to top level management for plant operations.
\\
J19ATTC85102901 - 1
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Att:chment 1 to AECM-85/0360 Page 2 Provide a better definition of Outage Section responsibilities as this section is moved into the nuclear operations organization under the Manager, Plant Modification and Construction.
The proposed changes to the Offsite Organization chart, Figure 6.2.1-1, are as follows:
1)
The position Senior Vice President, Nuclear will be eliminated. The President and Chief Operating Officer will assume responsibility for providing the top level direction of the activities associated with GGNS.
2)
The present Vice President, Nuclear Operations will report directly to the President and Chief Operating Officer.
3)
The newly created position Site Director, GGNS and the present Director, Nuclear Licensing and Safety report directly to the Vice President, Nuclear Operations.
4)
The newly created position Manager, GGNS Unit-1 Projects and the present GGNS General Manager report directly to the Site Director, CGNS.
5)
The newly created position Manager, Plant Modification and Construction reports to the Manager, GGNS Unit-1 Projects. This position was created from the present Manager, Plant Outages position.
6)
The newly created position Vice President, Nuclear Engineering and Support will report directly to the President and Chief Operating Officer.
7)
The present position Manager, Nuclear Plant Engineering is being changed to Director, Nuclear Plant Engineering and c
will report to the Vice President, Nuclear Engineering and Support along with the present positions of Manager, Unit 2 Construction; Director, Nuclear Support; and Director.
Quality Assurance.
8)
The Director, Quality Assurance will report directly to the Vice President, Nuclear Engineering and Support, with a communication path to the President and Chief Operating Officer to ensure corporate guidance on Quality Assurance policy matters and to provide a direct escalation path.
9)
The newly created position of Manager, Nuclear Services and Fuels reports to the Director, Nuclear Support and was created by combining the positions of Manager, Nuclear Services and Manager, Nucient Fuels.
J19ATTC85102901 - 2
c Attcchment 1 to AECM-85/0360 Page 3 The proposed changes to the subject technical specifications other than Figure 6.2.1-1 are as follows:
1) 6.1.2, 6.2.3.4, 6.5.2.8g, 6.5.2.9, 6.5.2.10a & b & c.
6.6.lb, 6.7.la & c - Change the title Senior Vice President, Nuclear to Vice President, Nuclear Operations.
2) 6.5.2.2 - Add Site Director, GCNS and Vice President, Nuclear Engineering and Support as members of the SRC.
Delete the Advisor to the Vice President Nuclear Operations from the SRC.
3) 6.5.2.6 - Increase the SRC quorum from 6 to 7.
4) 6.5.3.1.b - In the first sentence, change the title GCNS Ceneral Manager to Site Director, CGNS.
5) 6.5.3.1.e - In the first sentence, delete the phrase "be members of the plant staff who" and add the Site Director, CGNS as having equal responsibility for designating applicable reviews.
The change to Facility Operating License NPF-29 in the deletion of License Condition 2.C(28) concerning the Advisor to the Vice President, Nuclear Operations.
JUSTIFICATION: The changes in the Offsite Organization will strengthen the Nuclear Production Department. The changes will ensure that maximum effort and maximum productivity are obtained to provide safe, reliable, and economical electric service to the public.
The changes to the Offsite Organization chart, Figure 6.2.1-1, are justified as follows:
1)
The President and Chief operating Officer of HP&L has the ultimato responsibility for providing top level direction of all activities associated with the safe and reliable operation of GCNS. lie will provide direct control of all CGNS activities through the Vice President, Nuclear Operations and the Vice President, Nuclear Engineering and Support. As indicated by the dotted line on Figure 6.2.1-1, guidance with regard to corporate quality assurance policy and a direct escalation path for the Director, Quality Assuranco is provided. The present position of Senior Vice President Nuclear is eliminated with this change since the President and Chief Operating Officer will assume the responsibility for providing top level direction of the activities associated with GGNS.
This change will provide a higher level of direct management involvement in GCNS activities than with the present organization.
J19ATTC85102901 - 3
Attcchment I to AECM-85/0360 Page 4 f
2)
The Vice President, Nuclear Operations will report directly to the President and Chief Operating Officer thus providing a direct path to top management.
3)
The Site Director, CGNS answers directly to the Vice President, Nuclear Operations and has direct responsibility for the CCNS Ceneral Manager and the Manager, CCNS Unit-1 Projects. The Site Director, CCNS will provide a higher level of management at the CCNS site for solving problems and interfacing with other organisations.
For plant operations, he will also provide closer ties with and a more expeditious path to upper management.
t 4)
The Manager, CCNS Unit-1 Projects reports directly to the Site Director CCNS and is responutble for modification costs and schedules, for project management direction, and for coordination with the Director, Nuclear Plant Engineering; the Manager, plant Hodification and Construction; and the CGNS Ceneral Manager. lie is also responsible for providing administrative direction to the Manager, Plant Hodification and Construction for the implementation and testing of design changes and plant modifications except during plant outages. During plant I
outages the Manager, Plant Hodification and Construction reports to an outage manager who reports to the CCNS Ceneral Manager. The establishment of the Projects group under the Site Director, CGNS will provide a smoother interface with plant staff in order to accomplish necessary design changes, plant modifications or other projects.
This group will help to froc up plant staff resources and allow plant staff to concentrate on plant operation.
5)
The Manager, Plant Hodification and Construction will consolidate activities asnociated with major design changes and plant modifications at the site into one organisation and thus, centralise control and coordination of these activities. This position is responsible for review, implementation, and pont-change testing of major design changen and plant modifications. This position was created from the present Manager, Plant Outages position and reports to the Hanager, CCNS Unit =1 Projecta exceps during plant outages as described above.
6)
The position Vice Prentdent, Nuclear Engineering and Support was created from the present position of Director, Nuclear Engineering and Construction. This new position places more emphasis on the enginenring and support functions required to support the operation of CCNS Unit I and less emphasis on the construction of CCNS Unit 2.
This new emphasin is shown by placing the birector, Nuclear flupporti the Director, Nuclear Plant Engineeringt and the Director, Quality Assurance in a direct reporting path to the Vice president, Nuclear Engineering and Support. This organisation will provide a more effective management chain of command for NpD support functions.
Ji9ATTC85102901 - 4
Att:chment I to AECM-85/0360 Page 5 7)
The present title Manager Nuclear Plant Engineering is changed to Director, Nuclear Plant Engineering. This change is administrative in nature in that all present responsibilities are being retained. However, the new position of Director, Nuclear Plant Fngineering will report to a higher level of management and will be able to focus this higher level of management on engineering problem resolutions.
8)
In the present offsite organization the Director, Quality Assurance reports directly to the Senior Vice President.
Nuclear.
In the change to the NPD Offsite Organfantion, the Director, Quality Assurance reporta directly to the Vice President, Nuclear Engineering and Support, and reports to the President and Chief Operating Officer for corporate guidance on Quality Assurance policy matters and to ensure a direct escalation path. This proposed change does not alter the independence of the Quality Assurance organization. The Director. Quality Annurance wills maintain independence from undue influences and responsibility for schedules and costs; and retain sufficient authority and organizational freedom to identify quality problems, recommend solutions, and to verify implementation of solutions.
If acceptable solutions to problems cannot be reached, he has the respcnsibility and authority, as shown by the dotted line in Figure 6.2.1-1, to escalate these matters to the President and Chief Operating Officer.
9)
The present positions of Manager, Nuclear Services and Manager Nuclear Fuela are combined into the position of Hanager, Nuclear Services and Fueln. This change is administrativo in nature in that the responsibilities of two groups are being combined to provide more centralized manageroent and a more efficient organization. The new position will report to the Director Nuclear Support as the separate groups presently report.
Other changes in the subject technical specifications include assigning those items specifically identified in the technical npecificationn as responsibilition of the Senior Vice President, Nuclonr to the Vice President, Nuclear Operations. These changen are consistent with the responsibilities of the Vice President, Nuclear Operations and assigns the appropriate level of management attention to the areas addronned. These areas are elicited in Technical Specifications 6.1.2. 6.2.3.4, 6.5.2.8.g.
6.3.2.9. 6.S.2.10a & b & c. 6.6.th, and 6.7.la & c.
The changes to Technical Specifications 6.3.2.2 and 6.S.2.6 involve adding the Site Director, CONS and the Vice President.
Nucienr Engineering and Support an SRC members deleting the Advisor to the Vice President 'suclear Operations from the SRC and increaning the SRC quorum from 6 to 7 members. Adding these enmhern to the SHC will provide broader management input, ensure all top management is involved in significant safety Ji9ATTC85102901 - 5
Attcchment 1 to AECH-85/0360 Page 6 issues, and provide valuable experience to the SRC.
Increasing the quorum from 6 to 7 members will ensure that an appropriate level of expertise is available when conducting SRC meetings and represents 2/3's of the total voting membership. The Advisor to the Vice President, Nuclear Operations is being deleted from the SRC to coincide with deletion of License Condition 2.C(28) as discussed below.
The proposed changes to Technical Specifications 6.5.3.lb & e involve allowing the position of Site Director, CGNS inntead of the present CCNS Ceneral Manager, to designate review of proposed changes or modifications to plant nuclear safety-related structures, systems, and components. The Site Director, CCNS in responsible through the Manager, CCNS Unit-1 Projects for the review of proposed changes or modifications as described in Technical Specification 6.5.3.lb.
The Site Director, GGNS can choose the appropriate subordinate review group (plant staff or projects / modification and construction) depending on the type of review required thus ensuring effective reviews by groups specializing in the areas of concern. The CGNS General Manager retains the approval authority for implementation of nuclear safety-related modifications. Since the designated reviewers may be outside of plant staff. Technical Specification 6.5.3.le is revised by deleting the reference to plant staff members. Ilowever, the qualification requirements for these reviewers remains unchanged since they must meet the requirements of Section 4.4 of ANSI 18.1. 1971.
License Condition 2.C(28) of Facility Operating License NPF-29 requires MP&L to provide an advisor to the Vice President.
Nuclear Operations until the plant has operated for at leant six months at power levels above 90% of full power. This license condition was imposed in June 1982, due to the lack of operating plant experience by corporate management.
In March 1985 HP&L filled the position Vice President, Nuclear Operations with Mr. O. D. Kingsley, Jr. who has significant, responsible operational experience.
Mr. Kingsley is a graduate of Auburn University with a B. S.
degree in Engineering Physica. lie served in various line-officer capacities in the nuclear submarine service for five years before being employed by Alabama Power Company. The following are some of the ponitions held during hin 14 year tenure there:
Senior Engineer Assintant Plant Hanager, Parley Nuclear Plant Plant Manager, Farley Nuclear Plant Ansistant Manager - Nuclear Generation Hannger Nuclear Engineering and Technical Support Director, Nuclear Plant fiupport - Southern Company Ji9ATTCH5102901 - 6
Att chment 1 to AECM-85/0360 Page 7 In addition to the commercial nuclear power experience of Mr.
O. D. Kingsley, Jr., the President and Chief Operating Officer of MP&L Mr. W. Cavanaugh, III, has extensive commercial nuclear power experience.
Prior to assuming his present position with MP&L in early 1984, Mr. Cavanaugh worked for Arkansas Power and Light Company for 15 years. He was employed by that company in April, 1969, and worked on the design, construction, licensing, and operation of Arkansas Nuclear One Units I and 2.
The following are some of the positions he subsequently held during his tenure there Assistant Plant Superintendent of Arkansas Nuclear One Production Project Manager of Arkansas Nuclear One Manager of Nuclear Services Assistant Director of Power Production Executive Director, Generation and Construction Vice President, Generation and Construction Senior Vice President, Energy Supply.
From April through August 1983, Mr. Cavanaugh was on loan to Louisiana Power and Light Company and served there as a Senior Vice President - Nuclear Operations with direct responsibility for Waterford 3.
He is a graduate of Tulane University with a Bachelor of Science Degree in Mechanical Engineering and served as an officer in the U. S. Naval Submarine Nuclear Program prior to employment with Arkansas Power and Light.
MP&L has had contractors fill the position of Advisor to the position of Vice President, Nuclear Operations for over three years with approximately 65 days of that time while the plant was above 90% of full power (first averaged greater than 90%
for a full day on May 12, 1985). The present advisor who is now part time desires to end these personal services at the end of 1985. MP&L requests deletion of License Condition t
2.C(28) in light of the extensive commercial nuclear power experience of its existing Vice President Nuclear Operations and its President and Chief Operating Officer. The introduction of a new contractor to fill the advisor position for the remainder of the six month time requirement after the end of 1985 would not fulfill management needs and due to the short duration of the assignment would be unlikely to provide an opportunity to obtain a suitable candidate who could provide useful input.
SIGNIFICANT HAZARDS CONSIDERATION:
The proposed changes to the NPD Offsite Organization chart are administrative in nature or are intended to increase management level attention and efficiency. These changes increase management effectiveness in the areas of Nuclear Licensing and Safety. GGNS Plant Operations, Nucient Plant Engineering.
Nuclear Support, Quality Assurance, and CGNS Unit-2 Construction by providing:
Ji9ATTC85102901 - 7
Att: chm:nt 1 to AECM-85/0360 Page 8
+
1)
The President and Chief Operating Officer as the highest direct level of management involvement in CGNS Unit i activities.
2)
A Vice President, Nuclear Operations to direct GGNS Unit-1 operation and Nuclear Licensing & Safety.
3)
A Site Director, GGNS to effectively coordinate plant operation and project work including plant design changes and modifications.
4)
A Vice President, Nuclear Engineering and Support to direct and coordinate Nuclear Plant Engineering, Nuclear Support, and Quality Assurance activities to ensure safe and reliable operation of GGNS Unit-1.
5)
A Quality Assurance group that, while directly reporting to the Vice President, Nuclear Engineering and Support, is assured independence by having a direct escalation path to the President and Chief Operating Officer.
The present responsibilities of the Senior Vice President, Nuclear addressed in Technical Specifications 6.1.2, 6.2.3.4, 6.5.2.8g, 6.5.2.9, 6.5.2.10a & b & c 6.6.lb and 6.7 la & c are being assigned to the Vice President, Nuclear Operations to ensure that these responsibilities are assigned to the appropriate level of management in the GCNS plant operations chain of command. This change ensures that appropriate management attention will be focused on the responsibilities assigned in the subject technical specifications.
The increase in size and quorum requirements of the SRC is a conservative change in that additional expertise is provided to the SRC. The quorum requirements are increased to ensure an adequate number of personnel with proper expertise are available to meet SRC functional responsibilities.
Due to the extensive commercial nuclear power experience of the Vice President, Nuclear Operations and the President and Chief Operating Officer, the advisor position to the Vice President, Nuclear Operations is no longer needed and should be deleted.
This change will not adversely af fect management determinations in the GGNS plant operations chain of command.
The proposed changes to Technical Specification 6.5.3.lb & e reflect the proposed change in the CGNS plant operation chain of command. The position of Site Director, CGNS is responsible for the GGNS General Manager and the Manager, CGNS Unit-1 Projects. This change allows the Site Director, GGNS to select the appropriate review organization, either plant staff or project staff, to review proposed changes or modifications to plant nuclear safety-related structures, systems, and components; however, approval authority is retained by the J19ATTC85102901
,8
E.
Attcchment 1 to AECM-85/0360 Page 9
)
GGNS General Manager for implementation of changes. The qualifications of the reviewing personnel still must meet or exceed qualification requirements of Section 4.4 of ANSI 18.1, 1971. This change is intended to provide review flexibility while not reducing reviewer qualification requirements.
t The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes increase management efficiency, provide a higher management level involvement in i
the direction of GGNS activities, maintain the independence of the Director, Quality Assurance, and increases the level of expertise applied to the SRC. The deletion of the advisor to the Vice President, Nuclear Operations does not adversely affect management determinations due to extensive commercial nuclear power experience in the top management positions in the CGNS plant operations chain of command.
These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because of the administrative nature of some of the changes, the inclusion of the higher management level of l
President and Chief Operating Officer in the direct chain of command, the increased management effectiveness that will be realized by the change, and the assurance that the Quality Assurance organization will maintain needed independence.
These changes do not involve a significant reduction in a margin of safety as no margin of safety is affected by these changes. The proposed changes increase management effectiveness in Nuclear Operations and in Nuclear Plant Engineering and Support. The independence of the Quality Assurance organization is maintained by providing a path (dotted line on proposed Figure 6.2.1-1) to the President and Chief Operating Officer to provide guidance with regard to corporate quality assurance policy and to enetre a direct escalation path.
Therefore, the proposed changes involve no significant hazards considerations.
Ji9ATTC85102901 - 9
5
. ' 6. 0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The GGNS General Manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
6.1.2 The Shift Superintendent or, during his absence from the Control Room, a designated individual shall be responsible.for the Control Room command function.
A management directive to this effect, signed by the Scricr Vice President, Nuclear shall be reissued to all station personnel on an annual basis.
Opem.tious 6.2 ORGANIZATION 6.2.1 0FFSITE N
The offsite organization for unit management and technical support shall be as shown on Figure 6.2.1-1.
6.2.2 UNIT STAFF The unit organization shall be as shown on Figure 6.2.2-1 and:
a.
Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2.2-1.
b.
At least one licensed Reactor Operator shall be in the control room when fuel is in the reactor.
In addition, while the reactor is in OPERATIONAL CONDITION 1, 2 or 3, at least one licensed Senior Reactor Operator shall be in the Control Room.
c.
A health physics technician
- shall be onsite when fuel is in the reactor.
d.
All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.
e.
A site Fire Brigade of at least 5 members shall be maintained onsite at all times *.
The Fire Brigade shall not include the Shift Superintendent, the STA, the two other members of the minimum shift q
crew necessary for safe shutdown of the unit, and any personnel required for other essential functions during a fire emergency.
At least one A0 shall be available to respond to non-fire-fighting a
commands from the Control Room.
- The number of health physics technicians and Fire Brigade personnel may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.,
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G FIGURE 6.2.1-1 0FFSITE ORGANIZATION 1
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C1 PRESIDENT 8
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I VICE PRESIDUT VICE PRESIDENT NUCLEAR ENCINEERING l
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I DIRECTOR MANAGER DIRECTOR DIRECTOR DIRECTOR NUCLEAR LICENSING UNIT 2 NUCLEAR PLANT NUCLEAR QUAI.1TT
& SAFETY CONSTRUCTION ENGINEERING SUPPORT ASSURANCE GCNS m
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I MANAGER CCNS MANAGER ELECTRICAL ENGINEERING MANAGER MANAGER LICENSINC MANACER PROJECTS CROUP CROUP
& ENVIROMDTAL AUDITS NUCLEAR CENERAL CCNS UNIT-1 ENGINEERING SERVICES RAD 1014CICAL QA SERVICES i
MANAGER MANAGER MANAGER MECNANICAL QUALITY MANAGER PuMT PUNT
- ENGINEERING ENGINEERING MANAGER-NUCLEAR SITE NUCLEAR
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OPERATIONS MODIFICATION CROUP CROUP WUCLEAR
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ANALYSIS MANAGER C1.
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SUPPORT (ISEC) h rt ZO QUALITY ASSURANCE POLICY MATTERS AND ESCALATION PATN FIGURE 6.2.1-1 0FFSITE ORGANIZATION
ADMINISTRATIVE CONTROLS ^
INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) (Continued)
RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of unit activities to provide independent verification
- that these activities' are performed correctly and that human errors are reduced as much as practical.
AUTHORITY 6.2.3.4 The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of improving unit safety to the k r.kr Vice President, Nuclear l
6.2.4 SHIFT TECHNICAL ADVISOR Ope d, oms 6.2.4.1 The Shift Technical Advisor shall provide technical support to the g
Shift Superintendent in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to safe operation of the unit.
U@
.g s w 6.3 UNIT STAFF QUALIFICATIONS
.gb,, a, 6.3.1 Each member of the unit staff shall meet or exceed the minimum I' $
qualifications of ANSI N18.1-1971 for comparable positions and the supplemental J
requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 j
NRC lette M o all licensees, except for the Chemistry / Radiation Control Super-
[
intendent who shall meet or exceed the qualifications of Regulatory Guide M~
1.8, September 1975", the Shift Technical Advisor who shall meet or exceed the qualifications referred to in Section 2.2.1.b of Enclosure I of the October 30, g
1979 NRC letter to all operating nuclear power plants; and those members of the It g Independent-Safety Engineering Group used for meeting the minimum complement pM3 specified in Section 6.2.3.2, each of whom shall have a Bachelor of Science degree or be registered as a Professional Engineer and shall have at least two
.f, j years experience in their field, at least one year of which experience shall jr be in the nuclear field.
6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Training Superintendent, shall meet or exceed the requirements and' recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55 and the supplemental requi'rements specified-in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter # o all t
licensees, and shall include familiarization with relevant industry operational experience.
g 5E 6.5 REVIEW AND AUDIT g
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J 't 6.5.1 PLANT SAFETY REVIEW COMMITTEE (PSRC)
FUNCTION 6.5.1.1 The PSRC shall function to advise the GGNS General Manager on all
- matters rel ted to nuclear safety.
sNot responsible for sign-off function.
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ADMINISTRATIVE CONTROLS 6.5.2 SAFETY REVIEW COMMITTEE (SRC)
FUNCTION 6.5.2.1 The SRC shall function to provide independent review and audit of designated activities in the areas of:
a.
nuclear power plant operations b.
nuclear engineering c.
chemistry and radiochemistry d.
metallurgy e.
instrumentation and control f.
radiological safety g.
mechanical and electrical engineering h.
quality assurance practices Member:
S de. Dvector, CGNS COMPOSITION Member:
%'ce PresicLent;Nucleo r Enyneers'n3 c Support 8
6.5.2.2 The SRC shall be composed of the:
. Chairman:
Vice President, Nuclear Operations EMember: Dirator" nager, e4 Nuclear Plant Engineering
" Member:
Director, Quality Assurance Member:
Designated Representative, Middle South Services, Inc.
Member:
GGNS General Manager Member:
Director, Nuclear Licensing and Safety Member:
Manager, Radiological and Environmental Services Member:
Principal Engineer, Operations Analysis id:r *
^dvi :r to the '!!: "recident, '!::lcar ptrati:n:
l Two or more additional voting members shall be consultants to Mississippi Power and Light Company consistent with the recommendations of the Advisory Committee on Reactor Safeguards letter, Mark to Palladino dated October 20, 1981.
The SRC members shall hold a Bachelor's degree in an engineering or physical science field or equivalent experience and a minimum of five years of technical experience of which a minimum of three years shall be in one or more of the disciplines of 6.5.2.la through h.
In the aggregate, the membership of the committee shall provide specific practical experience in the majority of the disciplines of 6.5.2.la through h.
ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the SRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SRC activities at any one time.
- ' r v: ting = der GRAND GULF-UNIT 1 6-9 Ame.narnant No -
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ADMINISTRATIVE CONTROLS CONSULTANTS
-6.5.2.4 Consultants, in addition to those required in Specification 6.5.2.2, shall be utilized as determined by the SRC Chairman to provide expert advice to the SRC.
No more than three consultants shall participate as voting members in SRC activities at any one time.
MEETING FREQUENCY 6.5.2.5 The SRC shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter.
QUORUM 6.5.2.6 The quorum of the SRC necessary for the performance of the SRC review and audit functions of these Technical Specifications shall consist of the Chairman or his designated alternate and at least-6-SRC voting members including l
alternates.
No more than a minority of the quorum"shall have line responsibility for operation of the unit.
__ 7 REVIEW 6.5.2.7 The SRC shall review:
The safety evaluations for (1) changes to procedures, equipment or a.
systems and (2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify'that such actions did not constitute an unreviewed safety question.
b.
Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
Proposed tests or experiments which involve an unreviewed safety c.
question as defined in Section 50.59, 10 CFR.
d.
Proposed changes to Appendix A Technical Specifications or this Operating License.
Violations of codes, regulations, orders, Technical Specifications, e.
license requirements, or of internal procedures or instructions having nuclear safety significance.
L f.
Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.
g.
All REPORTABLE EVENTS.
h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
i.
Reports and meetings minutes of-the PSRC.
j.
Written reports from audits of the ALARA program.
GRAND GULF-UNIT 1 6-10 AnserwLnsent IVO.
l l
l
. ADMINISTRATIVE CONTROLS
'F
(
AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the SRC.
These audits shall encompass:
.a.
The conformance of unit operation to provisions contained within the Appendix A Technical Specifications and applicable license conditions at least once per 12 mo'ths.
n b.
The performance, training and qualifications of the entire unit staff at least once per 12 months.
c.
The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.
d.
The performance of activities required by the Operational Quality i
Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least once per 24 months.
The Emergency Plan and implementing procedures at least once per e.
12~ months.
f.
The Security Plan and implementing procedures at least once per 12 months.
w -.
g.
Any other area of unit operatijo considered appropriate by the SRC or the k r!:r Vice President;/ Nuclear l
g OperoAiosos h.
The Fire Protection Program and implementing procedures at least once per 24 months.
1.
An' independent fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.
j.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.
k.
The radiological environmental monitoring program and the results thereof at least once per 12 months.
1.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
m.
The PROCESS CONTROL PROGRAM and. implementing procedures for solidification of radioactive wastes at least orce per 24 months.
n.
The performance of activities required by the Quality Assurance i
Program to meet the criteria of Regulatory Guide 4.15, February 1979, at least once per 12 months.
f GRAND GULF-UNIT 1 6-11
a ADMINISTRATIVE CONTROLS AUTHORITY 6.5.2.9 The SRC shall report to and advise the Senier Vic~e President, Nuclear Operatoes ! !
on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.
RECORDS 6.5.2.10 Records of SRC activities shall be prepared, ap' proved and distributed as indicated below:
Minutes of each SRC meeting shall be prepared, approved and forwarded a.
to the Scr.icr Vice President, Nuclear within 14 days following each l
4 Opera.tiews meeting.
b.
Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Senier Vice President, F
Nuclear within 1,4 days following completion of the review.
t-- opera ous Audit reports encompassed by Section 6.5.2.8 above, shall be c.
forwarded to the Senier Vice President, Nuclear #and to the, Op emdio*s l.
management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.
6.5.3 TECHNICAL REVIEW AND CONTROL ACTIVITIES 6.5.3.1 Activities which affect nuclear safety shall be conducted as follows:
Procedures required by Technical Specification 6.8 and other procedures a.
which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved.
Each such procedure or procedure change shall be reviewed by an individual / group other than the individual / group which prepared the procedure or procedure change, but who may be from the same organization as the individual / group which prepared the procedure or procedure change.
Procedures other than Administrative Procedures shall The be approved as delineated in writing by the GGNS General Manager.
GGNS General Manager shall approve administrative procedures, security implementing procedures and emergency plant implementing procedures.
Temporary approval to procedures which clearly do not change the intent of the approved procedures may be made by two members of the plant management staff, at least one of whom holds a Senior Reactor Opera-tor's License.
Temporary changes shall be reviewed by the reviewing authority within 14 days of being issued.
For changes to procedures which may involve a change in intent of the approved procedures, the person authorized above to approve the procedure shall approve the change.
Proposed changes or modifications to plant nuclear safety-related b.
structures, systems and components shall be reviewed as designated by theAGGNS Gcacrc! Mcncger.
Each such modification shall be reviewed I
$*tt Dweder by an individual / group other than the individual / group which designed J
the modification,'but who may be from the same organization as the individual / group which designed the modifications.
Implementation of proposed modifications to plant nuclear safety-related structures,
./
systems and components shall be approved by the GGNS General Manager.
GRAND GULF-UNIT 1 6-12 Amena. ment. Alo.
1
ADMINISTRATIVE CONTROLS ACTIVITIES (Continued)
~
c.
Proposed tests and experiments which affect plant nuclear safety and are not addressed in the Final Safety Analysis Report shall be reviewed by an individual / group other than the individual / group which prepared the proposed test or experiment.
d.
Events reportable pursuant to Section 50.73 to 10 CFR Part 50 shall be investigated and a report prepared which evaluates the event and which provides recommendations to prevent recurrence.
Such report shall be approved by the GGNS General Manager.
e.
Individuals responsible for reviews performed in accordance with 6.5.3.1.a, 6.5.3.1.b, 6.5.3.1.c and 6.5.3.1.d shall be -^-'em c' th: p' nt :t:f' te meet or exceed the qualification requirements Sh Dm ro5 of Section.4.4 of ANSI 18.1, 1971, as previously designated by the GGNS
- P GGNS General Manager Each such review shall include a determination 3*s 9bW/of whether or not additional, cross-disciplinary review is necessary.
If deemed necessary, such review shall be performed by the review personnel of the appropriate discipline.
f.
Each review shall include a determination of whether or not an unreviewed safety question is involved.
.g.
Records of the above activit b shall be provided to the GGNS General Manager, PSRC and/or as necessary for required reviews.
- 6. 6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
a.
The Commission shall be notified pursuant to the requirements of Section 50.72 to 10 CFR Part 50, and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and b.
Each REPORTABLE EVENT shall be reviewed by the PSRC and submitted to the SRC and the Senior Vice President, Nuclear.
l 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
a.
The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour.
The Seni r Vice President, Nuclear 4and the SRC shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
[
Operatiosos b.
A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the PSRC.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit components, systems or strectures, and (3) corrective action taken te prevent recurrence.
GRAND GULF-UNIT 1 6-13 g g, l
w 1
ADMINISTRATIVE CONTROLS SAFETY LIMIT VIOLATION (Continued) c.
The Safety Limit Violation Report shall be submitted to the Commission, the SRC and the Senior Vice President, Nuclear within 14 days of the violation.
OperaboroS d.
Critical operation of the unit shall not be resumed until authorized by the Commission.
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 Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
b.
Refueling operations, c.
Surveillance and test activities of safety related equipment.
d.
Security Plan implementation.
e.
Emergency Plan implementation.
f.
Fire Protection Program implementation.
g.
PROCESS CONTROL PROGRAM implementation.
h.
OFFSITE DOSE CALCULATION MANUAL implementation.
i.
Quality Assurance' Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 4.15, February 1979.
6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed as required by 6.5, above, prior to implementation and shall be reviewed psriodically as set forth in administrative procedures.
6.8.3 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 systems include the:
1.
RCIC system outside containment containing steam or water, except the drain line to the main condenser.
2.
RHR system outside containment containing steam or water, except the line to the LRW system and headers that are isolated by
, manual valves.
3.
HPCS system.
4.
LPCS system.
5.
Hydrogen analyzers of the combustible gas control system.
GRAND GULF-UNIT 1 6-14 Amena med o'o ----
I
t r-
. 2 (b)
Final evaluations and recomendations from the TDI Owners Group Program applicable to GGNS Unit 1 and MP&L's actions yb in response to this program for the standby diesel gener-E ators shall be submitted for NRC review and approval prior 3d to startup following the first refueling outage.
$e E'E (26) Turbine Disc Integrity (Section 10.2.1, SER, SSER #1) 7*I W
P<wr to ence*a 56cM ha's 4 oF"do d s
0; ring c:ch r:fu lfag 0;t:g: MP&L shall ultrasonically inspect the bores and ketways of the low pressure turbine discs for indications of crackinf./ All unacceptable indications and their dispositions shall be reported prior to startup for the next cycle of operation. These inspections shall continue a a. e,=o how 4",.i until the potential for turbine disc cracking has been assessed and an acceptable alternate inspection schedule has been established.
l (27) CirculatingWaterSystem(Section10.4.5,SER) i MP&L shall not fill the Unit 2 circulating water system (includ-ing the natural draft cooling tower basin) until Unit I flooding concerns related to this system are resolved to the satisfaction of the NRC staff.
(28) to to Vice President (Section 13.1.1, SER, SSER #
MP&L shall provi e or more additional st members, reporting directly to a Vice Pre nt principall charge of nuclear (Dele. red) operations, who have substan rcial nuclear power plant operating management experie a who will act as advisors to the vice president on ecisions a ing safe operation of i
the plant. The a onal staff members ma rmanent employees or tracted consultants, but they sha e retained in th pi visory position until the plant has operate at 1Aast 6 months at power levels above 9M of full power.
(29) 0'perating Shift Advisor (Section 13.1.2 SER)
At least one individual on each operating shift shall have sub-stantive previous BWR operating experience, including startup and shutdown of a BWR and under conditions that one might expect to encounter during the initial startup and power escalation at the Grand Gulf plant. This individual is not required to be licensed on Grand Gulf Unit I and need not be an MP&L employee, but as a minimum shall be retained on a contra.ct basis to act as a consultant or advisor to the GGNS shift crew. Such an experienced person shall be assigned to each operating shift until the plant achieves and demonstrates full power operation.
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