ML20150B058

Proposed Tech Specs Re Onsite & Offsite Organization,Nuclear Safety Review Board & Organizational Responsibilities

ML20150B058
Person / Time
Site:	Callaway
Issue date:	06/28/1988
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20150B055	List: ML20150B052 ML20150B058
References
NUDOCS 8807110246
Download: ML20150B058 (10)

Text

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Attachment 1 ULNRC-l'/98 June 28, 1988 MARKED TECHNICAL SP_ECIFICATION PAGES_

Pages: 6-1 G-8 6-9 6-10 6-12 6-14 6-15 8807110246 880628 PDR ADOCK 0500048:3 P ppc ,

AfMINISTPATIVE C0!iTR0!.5 -

6.1 Resp 0!is!BIL Ty 6.1.1 The mnager, Call;uy Plant., shall ha respqn 1D10 for nytMll in'W epe.asusa a..J al oll Messte in writing the success { ion to this responsibility during his absence.

6.1.2 The Shif t Surervisor (or during his absence from t! e control rrn, a designated individual) shall he res nsible fcr the control rc >m comano func o tion. A :r.anagement directive to this effect, signed by thePTite Presidenr.- g,.

Nuclear sh311 be reissued to ali Sution personnel on an annual basis, s

6.2 ORGA!i!ZATIO!l 6.2.1 Onsite and Offsite Organization l An onsite and offsite organization shall be established for unit operation and corporate managerant. The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear pcwer plant.

a. Lines of authority, responsibility and corm:unication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as- appropriate, in the fom of organizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or equivalent forras of documentation. These requirements shall be documented in the FSAR snd updated in accordance with 10 CFR 50.71(e).

b. The Manager, Callaway Plant shall have responsibility for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. .,,e

c. The Vice President, Nuclear shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant to

ensure nuclear safety.

d. The individusis who train the operating staff and those who carry out the health physics and quality assurar.ce functions msy report to the appropriate onsite r.inager; bcwever, they shall have sufficient organizational freedom to ensure their independence fron operating pressures.

CAlt./A'AY - U!ilT 1 6-1 Amend. ent No. 37

REVISfoy 2- --

ADMINISTRATIVE CONTROLS

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&- RESPONSIBit.ITIE S .....

6.5.1.6 The ORC shall be responsible for: ,

a. Review of all Administrative Procedures;

b. . Review of the safety evaluations for (1) procedures, (2) change to procedures, equipment, systems or faci 14 ties, and (3) tests or exper-iments completed under the provision of 10 CFR 50.59 to verify that such actions dio not constitute an unreviewed safety question; ,

Review of proposed procedures and changes to procedures, equipment, c.

systems or facilities which may involve an unreviewed safety question as defined in 10 CFR 50.59 or involves a change in Technical Specifications;

d. Revi'ew of proposed test or experiments which may involve an unreviewed

• safety question as defined in 10 CFR 50.59 or requires a change in I Technical Specifications;

e. Review of proposed changes to Technical Specifications or the Operating License; L

f. Investigation of all violations of the T cal Specifications ,

including the forwarding of reports ering e luation and recom-p mendations to prevent recurrence to the4Vice Pre ident-Nuclear and .

' to the NSR8; ggg ~

g. Review of reports of operating abno lities, d iations from expected-  ;.

performance of plant equipment and of ' ated deficiencies in --

the design or operation of rtructures, systems or components that affect nuclear safety; '

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h. Review of all REPORTABLE EVENTS;

i. Review of the plant Security Plan and shall submit recommend u ,

changes to the,NSRB; Review of the Radiological Emergency Response Plan and shall submit' J.

. recommended changes to the NSRB; i

! k. Review of changes to the PROCESS CONTR0t. P'ROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems;,

I. Review of any accidental, unplanned or. uncontrolled radioactive release including the preparation of reports covering evaluation,

'ecommendations, and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Manager, Callaway Plant and to the NSRB; .

4 CALLAWAY - UNIT 1 6-8 .

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ADMINISTRATIVE CONTROLS RESPONSIBILITIES (Continued)

m. Review of Unit operatiens to detect potential ha:ards to nuclear safety;

n. Investigations or analysis of special subjects as requested by the I Chairman of the NSRB; ~

o. Review of Unit Turbine Overspeed Protection Reliability Program and I revisions thereto; and

p. Review of the Fire Protection Program and submitting recommended changes to the NSR3..

6.5.1.7 The ORC shall: . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ .

a. Reco==end in writing to the Manager, Callaway Plant approval or

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disapproval of items considered under Specifications 6.3.1.6a.

through e., i., J., k., l., o., and p. above:

l b. Render determinations in writing with regard to whether or not each item considered under Specifications 6.5.1.6b. through e., and m., .

I above, constitutes an unreviewed safety question; and gg,3.or.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President-Nuclear and the Nuclear Safety Review Board of disagreement between .

the ORC and the Manager, Callaway Plant; however, the Manager, Callaway Plant shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1 above.

RECORDS 6.5.1.8 The ORC sh intain written minutes of each ORC meeting that, at a m' nimum, do nt the esults of all ORC activities perfonted under the responsibility rovisions o these Technical Specifications. Copies shall be Vice Presiden -Nuclear and the Nuclear Safety Review Board.

provided to

• ek Se.nter 6.5.2 NUCLEAR FETY R .4 BOARD (NSRB)

FUNCTION 6.5.2.1 The NSRB 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 en .eering, and

h. Quality assurance practic . StrA0f l

The HSRS shall report to and ady' e they ice President- uclear on those areas of responsibility stated in Spec fications 6.5.2.3 an 6.5.2.9.

l l CALLAWAY - UNIT 1 6-9 Amendment No. 30

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ADMINISTRATIVE CONTROLS COMPOSITION 6.5.2.2 The NSRB shall be composed of at least the fg11owing members:

Mea Chairman:

C:n;. 3;%

MonLicusin3 wor, Enwin...:r.; 4F ("u 1::-)-

Member: Manager, Nuclear Engineering Member: Manager, Nuclear Safety and Emergency Preparedness Member Manager, Quality Assurance Member: General Manager, Nuclear Operations l Member: Supervising Engineer, Nuclear Fuels Additional members and Vice Chairmen may be appointed by the Chairman.

ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the NSRB

' Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in NSRS activities at any one time.

CONSULTANTS 6.5.2:4 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

MEETING FREQUENCY 6.5.2.5 The NSRB shall ' meet at least once per calender quarter during the initial year of unit operation following fuel loading and at least once per 6 months thereafter.

QUALIFICATIONS 6.5.'2.6 The NSRB members shall hold a Bachelor's degree in an engineering or physical science field, or equivalent experience, and a minimum of 5 years of technical experience of which a minimum of 3 years shall be in one or more of the disciplines of Specification 6.5.2.1.

i OUORUM 6.5.2.7 The quorum of the NSRB necessary for the performance of the NSRB review and audit fun:tions of these Technical Specifications shall consist of the Chairman or his designated alternate and at least two-thirds of the NSRB members including alternates. No more than a minority of the quorum shall have line responsibility for operation of the unit. For the purpose of a quorum, thoso considered to have line responsibility will include the General Manager, Nuclear Operations, and personnel reporting to tha General Manager,

[ Nuclear Operations.

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l-6-10 Amendment No. 16 F CALLAWAY - UNIT 1

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I REVISloy

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AUDITS (Cuntinued) .

d. The perfnrmance uf activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, at least unce per 24 months;

e. The Fire Protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel;

f. The fire protection equipment and program implementation at least once per 12 months utilizing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year;

g. The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months;

h. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at .-

least once per 24 months; ,

i. The PROCESS CONTROL PROGRAM.and implementing procedures for processing l and packaging of radioactive wastes at least once per 24 months;  ;

,/ j . The performance of activities required by the Quality Assurance  ;

, Program for effluent and environmental monitoring, at least once per 12 months; and

k. Any . er of unit operation considered appropriate by the NSRB k o

the4.Vice r ident-Nuclear. /*- 7))

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RECORDS h 6.5.2.10 Records of NSRB activities shall be prepared, approved, and distributad- '

as indicated below: -

a. Min RB meeting shall be prepared, approved and forwarded to hetVice Presid nt-Nuclear within 14 da h meet

$snior

b. Rep rts of revie encompassed by Spec cation 6. 2.8 above, shall -

be p ared roved and forwarded thegVice President-Nudear - -

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within 1 days following completion of the review; and .

"" re orts encompassed by:Specificati 6.5.2.9 above, shall be fo rded he management positions respons e the areas audited and suegaries of audits shall be prepared and forwarded to S e,n'

• f the Vice Prtsident-Nuclear within 30 days after completion of the -

l audit by the aud ting organi,2ation. ,

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6-12 CALLAWAY - UNIT 1 .

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1 ACTIVITIES (Continued)

d. Individuals responsible for reviews performed in accordance with -

Specifications 6.5.3.la., 6.5.3.lb., and 6.5.3.1c., shall be mem-bers of the management staff previously designated by the Manager, Operations Support. Each such review shall include a deter'nination of whether or not additional, cross-disciplinary, review is neces-sary. If deemed necessary, such review shall be performed by quali-fied personnel of the appropriate discipline;

e. Each review shall include a deterainatfor of whether or not an unreviewed safety question is involved. Pursuant to Section 50.59, 10 CFR, NRC approval of itams involving uareviewed safety questions shall be obtained prior to the Manager, Ca11 awry Plant, approval for implementation; and

f. The Plant Security Plan and Radiological Emergency Response Plan, and implementing procedures, shall be reviewed at least once per 12 months. Reconsended changes to the implementing procedures shall be approved in accordance with 6.5.3.1.a. Recommended changes j to the Plans shall be reviewed pursu, int to the requirements of Spect-fications 6.5.1.6 and 6.5.2.8 and approved by the Manager, Callaway .

Plant. NRC approval shall be obtained as appropriate. .

. RECOR05 l

6.5.3.2 Records of the above activities shall be provided to the Manager, Callaway Plant, ORC and/or NSRB as necessary for required reviews.

6.6 REPORTABLE EVENT ACTION 6.6.1 The 'following actions shall be taken for REPORTA8LE EVENTS:

, a. The Commission shall be notified and a report submitted pursuant to the requirement f etion 50.73 of 10 CFR Part 50, and l

b. Each REPORT LE EVENT shall b reviewed by the ORC and submitted to l the ice Presiden -Nuclear.

the NSRB ani 6.7 SAFETY LIMIT VIOMTION 6.7.1 The following ac -hell se taken in the eve ty Limit is violated:

a. The NRC Operations Center shall be notifyed by telephone as s on as possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The ce President-Nhclear and the NSRB shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; gg l b. A Safety Limit Violation Report shall be p ared. The report shall I be reviewed by the ORC. This report shall desu  : (1) plicable circumstances preceding the violation; (2) effects o e violation upon facility components, systems or structures; and (3) corrective l

' action taken to prevent recurrenew; CALLAWAY - UNIT 1 6-14 Amendment No. 16

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ADMINISTPATIVE CONTROLS SAFETY LIMIT VIOLATION (Continued)

c. The Safety Limit Violatio eport shall be submitted to the Cvrnission, the NSRS and the4 Vi ce Presi nt-Nuclear within 14 days ~

of the violation; and Saw

d. Critical operation of th unit shall ot be resumed until authorized by the Commission.

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

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a. The applicable procedures reconcended in Appendix A of Regulatory - --.

Nide 1.33, Revision 2, February 1978;

., _... _.. _ 5- ie. ' arsency operating procedures . required..to- tmp1.ement the..r-equir.e -----

i mencs of NUREG-0737 and Suppl'ement 1 'to NUREG-0737 as stated in' .

Section 7.1 of Generic Letter No. 82-33;

c. Plant Security Plan implementation;

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d. Rdiological Emergency Response Plan implementation; -

e. PROCES:; CONTP.0L PR9 GRAM implementation;

f. OFFSITE'00SE CALCULATION MANUAL implementation;

g. Quality Assurance Program implementation for effluent and environ-

n. ental monitoring; .

h. Turbine Overspeed Protection Reliability Program; and

i. Fire Prote: tion Program implementation. l l 6.8.2 Each procedure and administrative policy of Specification 6.8.1 above, and changes thereto, including temporary changes shall be reviewed prior to i implementation as set forth in Specification 6.5 above.

I 6.8.3 The plant Administrative Procedures and changes thereto shall be reviewed in accordance with Specification 6.5.1.6 and approved in accordance with Specification 6.5.3.1. The associated implementing procedures and changes l thereto shall be reviewed and approved in accordance with Specification 6.5.3.1.

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

a. Reactor 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 recirculation portion of the Containment Spray System. Safety Injection System, Chemical and Volume Control System, and RHR System. The program shall include the following:

1) Preventive maintenance and periodic visual inspection requirements, and CALLAWAY - UdIT 1 6-15 Amendment No. 30 ka . . - - - - _ . , .

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't Attachment 2 U LNRC-1798 June 28, 1988 Page-1 of 1 n.

I SAFETY EVALUATION This application requests that the Callaway Technical Specification Section 6.0 be revised to reflect the following-organization changes:

(a) All references to the "Vice President, Nuclear", are changed to .the "Senior Vice President,. Nuclear";

(b) The position of General Manager, Engineering (Nuclear) is deleted from the NSRB membership; (c) he Manager, Licensing and Fuels, a current member of the NSRB, in appointed Chairman of the NSRB.

These changes do not represent a reduction of the overall experience base nor a reduction to commitments to minimum qualifications. The position of General Manager,. Engineering (Nuclear) was eliminated following a promotion of the General Manager to a position outside the Nuclear Function. Since engineering expertise is currently represented on the NSRB through the membership of the Manager, Nuclear Engineering, this membership position was simply deleted. The Manager, Licensing and Fuels, currently an appointed member of the NSRB and reporting directly to the Senior Vice President, Nuclear , has been designated as the Chairman of the NSRB, the position formerly held by the General Manager, Engineering (Nuclea r) .

Thus reporting relationships and approval responsibilities are not altered by the upgrade to Senior Vice President, Nuclear from Vice President, Nuclear. This proposed Technical Specification change does not adversely af fect or endanger the health or safety of the general public nor involve an unreviewed safety question.

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-_ . .f Attachmrnt 3 U LNRC- 1798 June 28, 1988 Page 1 of 1

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SIGNI_FICAqT JIAZRDS_ CONS,I,DERATION This amendment request revises Callaway Technical Specification Section 6.0-to reflect the organization changes

-listed in Attachment 2, Safety Evaluation. The results of the Safety Evaluation conclude that minimum. qualifications and basic organizational reporting requirements are unchanged as a result of the upgrade in management assignments. The changes are administrative in nature and do not constitute a major. revision to administrative controls.

The Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain '

examples (4 8 FR 14870) . One of the examples of actions involving.

no significant hazards consideration relates to a purely administrative change to Technical Specifications.

These requeats do not involve e significant increase in the probability or consequence of an accident or other adverse condit. ion over previous evrluations; or create the possiblitiy of a new or dif ferent kind of accident or conditions over previous evaluations; or involve a significant reduction in a margin of safety. Based on this information, the requested license amendment does not present a significant hazard.

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