ML20151S533

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Proposed Tech Spec Changes to Administrative Controls Section to Conform to Current Nuclear Organization
ML20151S533
Person / Time
Site: Pilgrim
Issue date: 08/06/1988
From:
BOSTON EDISON CO.
To:
Shared Package
ML20151S530 List:
References
NUDOCS 8808150252
Download: ML20151S533 (11)
v • d • e


Text

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,' Paae NQ1 4.0 MISCELLANEOUS RADI0 ACTIVE MATERIALS SOURCES 206k 4.1 Sealed Source Contamination 206k 4.2- Surveillance Requirements 206k 4.3 Reports 2061 4.4 Records Retention 2061 5.0 HAJOR DESIGN FEATURES 206m 5.1 ' Site Features 206m 5.2 Reactor 206m 5.3 Reactor Vessel 206m 5.4 Containment 206m 5.5 Fuel Storage 207 5.6 Seismic Design 207 6.0 ADMINISTRATIVE CONTROLS 208 6.1 Responsibility 208 6.2 Organization 208 ,

6.3 Facility Staff Qualifications 208a l l 6.4 Training 208a l 6.5 Review and Audit 212 ,

6.6 Reportable Event Action 216 j 6.7 Safety Limit Violation 217 '

6.8 Procedures 217  !

Reporting Requirements 218 l 6.9 1 6.10 Record Retention 224 6.11 Radiation Protection Program 226 ,

6.12 (Deleted) 6.13 High Radiation Area 226 ,

6.14 Fire Protection Program 227 4

Qperational Obiectives Surveillance 7.0 RADIOLOGICAL ENVIRONMENTAL HONITORING PROGRAM 8.0 229 i 7.1 Monitoring Program 8.1 229 7.2 Dose - Liquids 8.2 232 7.3 Dose - Noble Gases 8.3 233 7.4 Dose - Iodine-131, Iodine-133, 8.4 234-Radioactive Material in

,- Particulate Form, and Tritium 7.5 Total Dose 8.5 234 l

Amendment No. 25, 45, 88, 89, 95, iii 8808150252 DR 880806 ADOCK 05000293 PDC

6.0 ADHfNISTRATIVE CONTRQLS l

6.1 RESPONSIBILITY The Station Director shall be accountable for overall facility operation. In his absence, the Station Director shall designate, in writing, the individual to assume this responsibility.

6.2 ORGANIZATION A. OFFSITE The Company organization for station management and technical support shall be as shown on Figure 6.2-1. l.

B. FACILITY ,

r. ,

The Facility organization shall be as shown on Figure 6.2-2 and: l '

1. Each on duty shift shall..be composed of at least _the minimum shift crew composition shown in Table 6.2-1. l
2. When the unit is in an operational mode other than cold shutdcwn or refueling, a person holding a Senior Reactor Operator License shall be present in the control room at all times. In addition to this Senior Optrator,:a Licensed Operator or Senior Operator ..

shall be present at the controls when fuel is in the vessel.

3. At least two Licensed Operators shall be present in the control room during reactor startup, scheduled reactor shutdown and during recovery from reactor trips.  ;
4. An individual qualified in radiation protection procedures shall-  !

be on site when fuel is in the reactor. l t

5. ALL CORE ' ALTERATIONS performed while fuel is in the reactor' vessel after the initial fuel loading shall be directly ([

supervised by either a licensed Senior Reactor Operator or .L Senior Reactor Operator Limited to' Fuel Handling.who has no E, other concurrent responsibilities during this operation.

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6. A Fire Brigade of 5 members including a Fire Brigade Leader i shall be maintained on site at all times. This excludes 3  !.

E members of the minimum shift crew necessary for safe shutdown -

and any personnel required for other essential functions during -

a fire emergency.  ;

C. CHANGES TO THE ORGANIZATION i

Changes may be made to the organization without prior license }

amendment provided that the NRC is notified in writing within 30 days t l

and a revision to Section 6.2 is included in a subsequent license i amendment request.  !

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i:

Amendment No. 69, 80, 88, 208 [.

l L _ _ _ . _ _ _ .__

s 0 ADMINISTRATIVE CONTROLS l 6.3. [ACJLITY STAFF OUALIFICATIONS The qualifications with regard to educational and experience backgrounds l of the facility staff at the time of appointment to the active position- '

shall meet the requirements as. described in the American National Standards Institute N18.1-1971, "Selection and Training of Personnel for Nuclear Power Plants." In addition, the individual performing the i function of Radiation Protection Manager shall meet or exceed the l qualifications of Regulatory Guide 1.8, September,1975.

6.4 JRAJHING A retraining and replacement training program for the facility staff shall be maintained under the direction of the Nuclear Training Department Manager. The training programs for the licensed personnel shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix A of 10CFR Part 55. The training programs for the Fire Brigade shall meet or exceed the requirements of NFPA Standard No. 27-1975 "Private Fire Brigade". Fire Protection Training sessions will be held quarterly.

Amendment No. 41, 46, 69, 88, 208a

J E

B Chief Executive Officer g

o. -

Senior Vice President -

i

" Nuclear Nuclear Safety Review ard Audit Committee Emergency Preparedness QuaHty Assurance Vice President - Station Director Nuclear Engineering Department Manager Department Manager

! (Offsite) (Onsite)

Operations Review Committee i (Onsite) l l

_ Nuclear Nuclear l

Management Engineering l l l Department Planning & Outage Nuclear Training Services Plant Support Plant Manager Department Managar Department Department Department (Onsite) Manager Manager (Offsite) Manager Manager (Onsite) (Offsite)

(Offsite) (Onsite)

Boston Edison Company Organization for Management and Technical Support of Pilgrim Station ao Figure 6.2-1

  1. ,.A#= y e yAemere 3 g e-.

e A +

B

  • Station Director g

3 o .-

3 Operations Review Committee

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g .

h -

Planning & Outage NuclearTraining Plant Support Plant Manager Department Manager Department Manager Department Manager Modification & Major _

Operations Training

-Fire Protection Division Manager Plant Maintenance _

Section Manager Section Manager Maintenance Section Manager

- Radiological Section Manager Technical Section Manager TechnicalTraining

- Rann% & Outage _

1 (SRO)

Services Section Manager Section Manager

-Radiation Protection Manager P t Operations essmem & Sp Security Section Manager _

r Section Manager

-Chief Operating Engineer (SRO)

Facilities Section Manager , huclear Watch Engincors (SRO)

- Ln ., opororons supervisors (sno)

Luoci.., pion,no,ao,op,,,o,,(no) RO- Licensed Reactor Operator Materials Management Section Manager SRO - Licensed Senior Reactor Operator

-Chemistry Division Manager 1

rations Support Division Manager The Radiation Protection Manager has hift Technical Advisors direct access to the Station Director.

m Pilgrim Station Organization e Fiaure 6.2-2

6 REM EH ANQ AUDIT y

A. OPERATIONS REVIEW COMMITTEE (ORC)

-1. FUNCTION The ORC shall function to advise the Station Director on all matters related to safety.

2. COMPOSITION The ORC shall be composed of the Technical Section Manager, who shall serve as ORC Chairman, and at least six members, who shall be appointed in writing by the Station Director from senior experienced onsite individuals representin;.! nach of the

.following disciplines: plant operations, plant maintenance, plant technical, reactor engineering, ~ radiation protection,'and chemistry.

3. ALTERNATES Alternates shall be appointed in citing by the Station Director l

to serve on a temporary basis.

4. ME'ETING FRE00 ENC The ORC shall meet at least once per calendar month and as convened by the ORC Chairman.
5. OUORUM A quorum of the ORC shall consist of the Chairman or designated alternate and a majority of members / designated alternatesi however, no more than two alternates shall be allowed to meet quorum requirements.
6. RESPONSIBILITIES The ORC'shall be responsible for:

x

a. Review of 1) all procedures required by Specification 6.8 and changes thereto, 2) any other proposed procedures or changes thereto that affect nuclear safety. 3
b. Review all proposed tests and experiments that affect nuclear safety,
c. Review of all proposed changes to the Technical Specifications.
d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

Amendment No. 46, 69, 88, 212

6.5.A.6 RESPONSI8RITIES (Continued) l

e. Review of facility operations to detect potential safety hazards.
f. Review of the Station Security Plan and implementing procedures and changes to the plan and procedures.
g. Review of the Emergency Plan and implementing procedures and changes to the plan and procedures.
h. Performance of special reviews and investigations and reports thereon z.s requested by the Nuclear Safety Review and Audit Ccamittee (NSRAC) Chairman.
1. Investigation of all violations of the Technical Specifications and shall prepare and forward a report covering evaluation and recommendations to prevent recurrence to the Station Director, the NSRAC Chairman, and the Senior Vice President - Nuclear.
j. Review the Station Fire Protection Plan and implementing procedures and changes to the plan and procedures.

The ORC Chairman may appoint subcommittees composed of personnel who are not members of ORC to perform staff work necessary to the efficient functioning of ORC.

7. AUTHORITY
a. Recommend in writing to the Station Director the approval l t or disapproval of items considerad under 6.5.A.6(a) through (d) above,
b. Render determinations in writing with regard to whether or not each item considered under 6.5.A.6(a) through (d) above constitutes an unreviewed safety question.
c. Provide immediate written notification to the Station Director, the Nuclear Safety Review and Audit Committee, and the Senior Vice President - Nuclear of disagreement between the ORC Members and the ORC Chairman. The Station Director shall have responsibility for resolution of such disagreements.-
8. RECORDS The ORC shall maintain written minutes of each meeting and copies -

shall be forwarded to the Station Director and the NSRAC Chairman.

Amendment No. 29, 46, 69, 88, 213

,' 6.5.B.8 AUDXTS (Continued) l
c. The results of all actions required by deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per six months.
d. The performance of all activities required by the Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per two years.
e. The Emergency Plan and implementing procedures at least once per two years.
f. The Station Security Plan and implementing procedures at least once per two years,
g. Any other area of facility operation considered appropriate by the NSRAC or the Senior Vice President - Nuclear.
h. The Fire Protection Program and implementing procedures at least once per two years.
9. AUTHORITY The NSRAC shall report to and advise the Senior Vice President -

Nuclear on those areas of responsibility specified in Section 6.5.B.7 and 6.5.B.8.

10. RECORDS Records of NSRAC activities shall be prepared, approved and distributed as indicated below:
a. Minutes of each NSRAC meeting shall be prepared, approved and forwarded to the Senior Vice President - Nuclear, NSRAC members, ,

and others the Chairman may designate,

b. Reports of reviews encompassed by Section 6.5.B.7.e, f, g and h above, shall be prepared, approved and forwarded to the Senior Vice President - Nuclear, with a copy to the Station Director within 21 days following the completion of the review.
c. Audit reports encompassed by Section 6.5.B.8 above shall be forwarded to the Senior Vice President - Nuclear and to the management positions responsible for the areas audited within 30 days after completion of the audit.

6.6 REPORTABLE EVENT ACTION The following actions shall be taken for each reportable event:

A. The Commission shall be notified and/or a report submitted pursuant to the reauirements of either 10 CFR 50.72 or 10 CFR 50.73.

B. Each Reportable Event Report submitted to the Commission shall be reviewed by the ORC and submitted to the NSRAC Chairman and the Station Director.

Amendment No. 46, 69, 74, 28, 104, 216

6.7 SAFETY LIMIT VIOLATION The following actions shall be taken in the event a Safety Limit is violated:

A. The provisions of 10 CFR 50.36(c) (1) (i) shall be complied with immediately. -

B. The Safety Limit Violation shall be reported to the Commission within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 10CFR50.36(c)(6) and 50.72, and to the Station Director l and the NSRAC Chairman immediately.

C. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the ORC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective' action taken to prevent recurrence.

D. The Safety Limit Violation Report shall te submitted to the Commission within 30 days in accordance with 10CFR50.36(c)(7) and 50.73 and to the NSRAC Chairman and the Station Director. l 6.8 PROCEDURES A. Hritten' procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7 - 1972 and Appendix "A" of USNRC Regulatory Guide 1.33, except as provided in 6.8.B and 6.8.C below.

B. Each procedure of 6.8.A above, and changes thereto, shall be reviewed by the ORC and approved by the responsible department manager prior to l implementation. These procedures shall be reviewed periodically as set forth in administrative procedures.

HQJTI: ORC review and approvcl of procedures for vendors / contractors, who have a QA Program approved by Boston Edison Company, is not required for work performed at the vendor / contractor facility. ,

C. Temporary changes to procedures o N .A above may be made provided: ,

1. The intent of the original procedure is not altered. ,
2. t members of the plant management The change is approved by 'wo staff, at least one of whom holds a Senior Reactor Operator's license on the unit affected.
3. The change is documented, subsequently reviewed by the ORC within 7 days of implementation, and approved by the responsible department nanager.

o D. Written procedures to implement the Fire Protection Program shall be established, implemented and maintained.

Amendment No. 29, 30, 46, 74, 88, 217

I

, 6.10.B RECORD RETENTION (Continued)

6. Records of gaseous and liquid radioactive material released to the environs.
7. Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles.
8. Records of training and qualification for current members of the plant staff.
9. Records of in-service inspections performed pursuant to these Technical Specifications.
10. Records of Quality Assurance activities required by the QA Manual.
11. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to i

10 CFR 50.59.

12. Records of meetings of the ORC and the NSRAC.
13. Records for Environmental Qualification.

6.I1 RADIATION ' PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. ,

i 6.12 (Deleted) ,

6.13 HIGH RADIATION AREA (0PTIONAL) j 6.13.1 In lieu of the "control device" or "alarm signal" required by  ;

paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit *. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following: ,

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RHP issuance requirements during the performance of this assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

Amendment No. 20, 45, 95, 226

p l

a 6.13.1 HIGH RADIATION AREA (Cpntinued)

b. A radiation monitoring device which continuously integrates the j radiation dose rate in the area and alarms when a preset l >

l integrated dose is received. Entry into such areas with this.

monitoring device may be made after the dose rate level in the  ;

I area has been established and. personnel have been made knowledgeable of them. l

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the freqJency specified by the Radiation Protection Manager in the Radiation Work Permit. l 6.13.2 The requirements of 6.13.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr. In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Nuclear Watch Engineer on duty and/or the Radiction Protection Manager.

6.14 FIRE PROTECTION PROGRAM The following inspections and audits _shall be performed:

1. An independent fire protection inspection and audit shall be performed annually utilizing either qualified off-site licensee personnel or an outside' fire protection firm.
2. An inspection and audit by an outside qualified fire consultant shall be performed at intervals no greater than 3 years.

i 227 Amendment No. 20, 45,

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