ML20149N039

Proposed Tech Specs Re Changes to Administrative Controls to Reflect Organizational Changes in Util & NRC

ML20149N039
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/05/1988
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20149N034	List: ML20149N033 ML20149N037 ML20149N039
References
NUDOCS 8803010022
Download: ML20149N039 (15)

Text

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Fort St. Vrain 00.

Technical Spacifications.

Amendment No.

Page 7,1-7. l Authorized deviations to the working hour guidelines shall be documented and available for Nuclear Regulatory Commission review. l

3. Training

a. A retraining ard replacement training program for the facility staff shall be maintained under the

! direction of the Nuclear Training Manager and shall meet or exceed the requirements and _ recommendations-of Section 5.5 of ANSI N18.1-1971 and Appendix "A"  ;

of 10CFR Part 55. Compliance with Section 5.5 of ANSI 18.1-1971 shall be achieved no later than six months following commencement of commercial  !

operation.

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b. A training program for the Fire Brigade shall be l maintained under the direction of the Nuclear ,

l Training Manager and shall meet - or exceed the f requirements of Section 27 of the NFPA Code-1975, I

except for Fire Brigade training / drill sessions  ;

which shall be held at least once per calendar quarter,

c. The Technical Advisors shall have a bachelor degree or equivalent in a scientific or engineering discipline with specific training in plant design i

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'9003010022 800205 PDR ADOCK 05000267

.P DCD

Fort St. Vrain 01 Technical S;acifications Amendment No.

Page 7.1- 8 and response and analysis of the plant for transients and accidents. An initial training and retraining program for the Technical Advisors shall l be maintained under the direction of the Nuclear

] Training Manager. The Technical Advisors shall also i

receive training in plant design and layout, l including the capabilities of instrumentation and controls in the Control Room.

! Specification AC 7.1.2 - Plant Operations Review Committee 1

(PORC), Administrative Controls l

l The organization, responsibilities, and authority of the PORC shall be as follows:

! 1. Membership l

The Plant Operation > Review Committee shall be composed of the following:

Chairman: Station Manager Technical / Administrative Services Manager Support Services Manager (Radiation Protection Manager)

Superintendent of Operations Superintendent of Maintenance l Superintendent of Nuclear Betterment Engineering l

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Fort St. Vrain #1 Technical Specifications Amendment No.

Page 7.1- 9 Results Engineering Supervisor l Administrative Shift Supervisor I

Superintendent of Technical Services Engineering l Nuclear Training Manager

2. Alternates An alternate chairman and alternate members, if required, shall be appointed in writing by the PORC Chairman to serve in the absence of a chairman or a member; however, no more than two alternate members

] shall participate as voting members in PORC activities at any one time.

3. Meeting Frequency The PORC shall meet at least once per calendar month and I as convened by the Chairman or his designated alterr. ate.

4. Quorum A quorum shall consist of the Chairman or alternate Chairman, and four members including alternates.

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5. Responsibilities l l

The PORC shall be responsible for:

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Fort St. Vrain #1 Technical Specifications Amendment No.

Page 7.1-10

a. Review of all procedures required by Technical l Specification 7.4(a), (b), (c) and (d) and changes thereto, and any other proposed procedure or changes to approved procedures as determined by the Station Manager to affect nuclear safety.

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b. Review of all *cposed tests and experiments that affect nuclear . uty,

c. Review of all proposed changes to the Technical Specification.e.

d. Review of all proposed changes or modifications to plar,t systems or equipment that affect nuclear safety.

e. Investigation of all violations of the Technical Specifications including the preparation and forwarding of rsports covering the evaluatio7 and l re:ammendations to prevent recurrence to the Manager, Nuclear Production and to the Chairman of the Nuclear Facility Safety Committee.

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f. Review of all Reportable Event 5.  !

g. Review of facility operations to detect potential nuclear safety hazards.

Fort St. Vrain 01 Technical Specifications Amendment No.

Page 7.1-13 e) Instrumentation and Control f) Radiological Safety g) Mechanical and Electrical Engineering h) Quality Assurance Practices

1) Other appropriate fields associated with the unique characteristics of the nuclear power plant.

2. Membership ,

The NFSC shall be composed of the following:

Chairman (As appointed - See Step 4)

Manager, Nuclear Licensing and Fuels Divi ion Manager, ?.uclear Production Division Manager, Nuclear Engineering Division Manager, Quality Assurance Division I

i hfety and Security Director j l Consultants, as required, shall be appointed in writing by l the Vice President, Nucle r Operations.

3. Alternates Alternate members, if required, shill be appointed in writing by the Vice President, Nuclear Ortri--- however, no more tha" two alternate members sha'l participate as voting members in NFSC activitics at any one time.

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FORT ST. VRAIN NUCLEAR GENERATINS STATION .

ADMINISTRATIVE AND DEPARTMENTAL MANAGEMENT ORGANIZATION CHART Chairman and Chief Executive Officer Vice President Nucicar NFSC Operations NFSC - Nuclear Facility Safety Committee PORC - Plant Operations Review Committee

" Serves as the Radiation Protection Manager Manager Manager Manager Manager Oo. .ity Nuclear Licensing Nuclear Nuclear Ass irance and Engineering Production Division Fuels Division Division Division Nuclear Technical / 2 $" # d' Supp rt Station a.n, Training Services Manager Ad*. .'"'strative egg-Manager Manager . . Services Manager yg l 732-FNk

2. "

B PORC 0 t

FIGURE 7.1 - 1

FORT ST. VRAIN NUCLEAR GENERATING STATION CONDUCT OF OPERATIONS CHART Manager Nuclear Productu>n Division Support Station Technical /

Services Manager Administrative Manages" Services Manager l SLO.

PORC Superintendent Superintendent Superintendent Superintendent Nuclear Maintenance Operations Technical Betterrnent Services Engineering l Engineenng lsto. i m > -a vi B

Health Results Adnunistratrve Shift om Physics Engineering Shdt Supervisors *R?"

ya_m Supervisor Supervisor Supervisor

- agr lSto e e*

fiths the Station Manages or the Supennierwient of Operations U -m Y shall possessa Senior Lxense O]*na

" Serves as the Radution Protection Marajer 23 Equipment Reactor Auxiliary Technical PORC Plant Operations Review Conettee Operators Operators Tenders Advisors Q Senior Literned Operatm o

SLO LO - Licensed Operats h

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Figure 7.12

Fort St. Vrain 01 Techn' cal Specifications Amendment No.

Page 7.4-1 7.4 PROCEDURES - ADMINISTRATIVE CONTROLS Applicability Applies to admin'strttive procedures which will govern plant operations.

Objective To ensure that written procedures will be maintained to define requirements for plant operation.

Specification AC 7.4 - Procedures, Administrative Controls

a. Written procedures shall be established, implemented and maintained covering the activities referenced below:

1. The applicable procedures recommended in l Appendix A of Safety Guide 33, November, 1972.

2. Refueling operations.

3. Surveillance and test activities of safety-related equipment.

4. Security Plan implementation.

5. Emergency Plan implementation.

6. Frocess Control Program (PCP) implementation.

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Fort St. Vrain #1 Technical Specifica2ic.is Amendment No.

Page 7.4- 2

7. Offsite Dose Calculation Manual (00CM) implementation.

8. Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 1.21, Revision 1, June, 1974 and Regulatory Guide 4.1, Revision 1, April, 1975.

b. Procedures and administrative policies of a) above, and changes thereto, shall be reviewed by the PORC, I or a subcommittee thereof, and approved by the l appropriate management prior to implementation.

l Procedures shall be reviewed periodically as set forth in Administrative Procedures.

Security Plan procedures, and changes thereto, shall be reviewed by the Plant Operations Review l Committee, or a subcommittee thereof, and approved b/ the designated Plant Security Officer prior to implementation.

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c. Temporary changes to procedures of a) above may be made prc'ided: l i

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1. The intent of the original procedure is not altered.

Fort St. Vrain #1 1

Technical Specifications  :

Amendment No. [

i Page 7.4-3 l I

2. The change is approved by two members of the plant management staff, at least one of whom j holds a Senior Reactor Operators License, ,

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3. The- change .i s documented, reviewed by the l PORC, or a subcommittee thereof, and approved 4

1 by the appropriate management within 14 days  ;

j of implementation.  !

d. Procedures for personnel radiation protection shall be prepared consiste.it with the requirements of f 10 CFR Part 20, and shall be' approved, maintained, i

i and adhered to for all operations involving i

j personnel radiation exposure.

Respiratory protective equipment shall be provided  ;

in accordance with 10 CFR 20.103. . _ - I e

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Fort St. Vrain #1 Technical Specifications Amendment No.

Page 7.5-3 and survei tior :e, in-service inspectics.,

routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures totaling 'ess than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the whole body dose received from external sources shall be assigned to specific major work functions,

c. Monthly Operating Report A routine operating report covering the operation of the unit during the previous month shall be submitted prior to the fif teenth calendar day of the following month.

Submittal shall be to the U. S. Nuclear l Regulatory Commission, ATTN: Document Control i Desk, Washington, D. C. 20555, with a copy to the appropriate NRC Regional Administrator.

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e ATTACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION

SIGNIFICANT HAZARDS CONSIDERATION i

f. Evaluation c

The proposed chi les to Section 7 and Figures 7.1-1 and 7.1-2  :

are evaluated in ti.) following paragraphs.  !

The pos'; tion of Suparintendent of ' Training has been l eliminated. The Nuclear Training Organization will now eport to the new position of Nuclear Training Manager who will report directly.to the Vice President of . Nuclear ,

Operations. This change is administrative only and the Training Program will continue to meet or exceed the l requirements of Section 5.5 of ANSI '18.1 - 1971 and i Appendix "A" of 10CFR55.  !

Specification AC 7.1.2.1 (PORC Membership). The prnposed changes to this section will eliminate four persons from

membership of the PORC. This action is in response to the .

NRC's request for *dditional information, NRC letter Heitner to Williams, ac*ed Decembe- 5, 1986 (G-86636). In addition to lowering cnmmittee membership from the existing 14 members to the proposed 10 members, the following steps have been tak:n to ensure that continuity. ,

of members is retained from one meeting to the next  ;

meeting: ,

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! 1. Fewer PORC meetings - one per week versus one per  ;

3 day or three per week-P

2. A training program for all PORC members (incloding alter.iates) has been instituted.

3. All PORC members (including alternates) h0ve l successfully completed the training program.

4. Only those personnel designated by name (PSC Interofft.4 Memo) are eligible to serve on the >

PORC.  :

5. 90% of all PORC meetings are chaired by the  :

Chairman.

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Specification AC 7.1.2.1 (PORC Membership). The title of l

, Shift Supervisor Administration has been changed .to )

Administrative Shift Superd or. There is no significant  !

change to the responsibilitiesi' unctions associated with this position. I I

Specification AC 7.1.2.2 (Alternates) has been revised to 1 clarify that no more than two alternate members shall participate "as voting memoers" in PORC activities at any one time. The proposed change is consistent with the'

guidance provided in the Standard Technical Specifications i (STS).

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Specification -AC 7.1.2.3 (Meeting -Frequency) has been revised to allow the "designated alternate" PORC Chairman to convene PORC meetings. The proposed change is consistent with the guidance provided in the STS.

Specification AC 7.1.2.5.a _(Responsibilities) has been revised to add Specification "7.4(d)" which was ,

inadvertently omitted in a previous Technical Specification submittal. The proposed change is consistent with procedure reviews presently performed by PORC.

4 Specification AC 7.1.3.2 (NFSC Membership) has been revised to indicate that consultants will be appointed "in writing by the Vice President, Nuclear Operations". This clarification is consistent with Specification AC 7.1.3.3 and 7.1.3.4 for appointing Alternate Members and Chairman / Alternate Chairman, respectively.

Figures 7.1-1 and 7.1-2 have been updated to reflect the above described organization and the words "Fort St.

Vrain" eliminated for consistency.

Specification AC 7.4.a.1 is revised to delete an incorrect reference to Regulatory Guide 1.33 and add Safety Guide 33, November, 1972. Regulatory Guide 1.33 did not exist in November, 1972.

Specifications AC 7.4.b and 7.4.c have been revised to allow for certain procedure reviews to be performed by the PORC, "or a subcommittee thereof", prior to the PORC review required in Specification AC 7.1.2.3.a. .This  !

); proposed change will relieve the PORC of some of the l in-depth procedure reviews and allow more time to be spent _. .

{ on other issues, thereby enhancing overall PORC continuity

while maintaining the quality of procedure reviews. The procedure will then be approved by the "appropriate management" personnel (previously, "appropriate Manager").

The PSC management structure is such that the appropriate approver may be a vice president, manager, or j superintendent. This change is for clarification only and I will have no affect on the level of review the procedure receives. l The proposed change to Specification AC 7.5.1.c (Monthly Operations Report) updates the address in accordarice with NUREG ONS, dated February 6, 1987. Reference to the Director, uffice of Inspection and Enforcement has been j eliminated to .-aflect recent USNRC organizational changes.

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II. Conclusion-Based on the above, operation of Fort St. Vrain in accordance with the proposed changes will not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this change will not create an undue. risk to o the health and safety of the public nor does it . involve any 4

significant hazards consideration. '

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