ML20206B921

Proposed Defueled Tech Specs Stating That Characterization of Revised Review & Audit Function Remain in Plant TS Rather than Be Transferred to Plant QA Plan

ML20206B921
Person / Time
Site:	Yankee Rowe
Issue date:	04/23/1999
From:	YANKEE ATOMIC ELECTRIC CO.
To:
Shared Package
ML20206B920	List: ML20206B918 ML20206B921
References
NUDOCS 9904300123
Download: ML20206B921 (34)

Text

i ATTACHMENT I Revised Technical Specification Panes Annotated Version 6-1 6-3 6-5 through 6-17 6-19 6-21 6-22

-)

9904300123 990423 POR ADOCK 05000029.

M PDR

6.0 ADMINISTRATIVE CONTROLS Administrative controls are the written rules, orders instructions.

procedures, policies, practices, and the designation of authorities and responsibiliti.es by the management to obtain assurance of safety and quality of maintenance of a nuclear facility.

These controls shall be adhered to.

6.1 RESPONSIBILITY l

6.1.1 The Decommissioning Manager Plant-Supee4ntendent shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

6.1.2 In all matters relating to the operation of the plant and to l

these Technical Specifications, the Decommissioning Manager l

Plant-Supee4ntendent shall report to and be directly l

responsible to the. President of Managee-ef-Operat4 ens-4n-the Yankee Atomic Electric Company.

6.2 ORGANIZATION.

6.2.1 An on-site and an off-site organization shall be established for plant operation and corporate management.

The on site and off-site organization shall include the positions for activities affecting the safety of the facility.

a.

Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as

- 5ppTopriate.- iTr-tiiedorrof-organi zational charts.

These organizational charts shall, be documented in the FSAR.

b.

A single corporate officer shall have overall responsibility for plant nuclear safety.

This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining and providing technical support in the plant so that continued nuclear safety is assured.

There shall be an individual management position in the c.

j on-site organization having overall responsibility for l

safe operation of the plant; he/she shall have control l

over those on-site resources necessary for safe operation and maintenance of the plant.

YANKEE-ROWE 651 l

I C

I' l.

I I

6.0 ADMINISTRATIVE CONTROLS (Continued)

Adequate shift coverage shall be maintained without

- routine heavy use of overtime.

The objective shall be to.have operating personnel work, on the average, an l

approximate 40-hour week..However. in the event that unforeseen problems require substantial amounts of overtime to be used, or during major maintenance or major plant modifications on a temporary basis, the i

following guidelines shall be followed:

(1) An individual should not be permitted to work more l

than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

(2) An individual should not be permitted to work more l

than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24, hours in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time.

(3) A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work peri.ods. including shift turnover time.

(4) The use of overtime should be considered on an indi,vidual basis and not for the entire staff on shift.

Any deviation from the above guidelines shall be authorized by the Decommissioning Manager Plant 1

1 Supee+ntendent or his delegated. representative, or higher l

levels of management in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be reviewed l

monthly-by-the-Decommissioning Manager Plant l

Supectatendent or his delegated representative to assure l

that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

i i-

• U e

YANKEE-ROWE' 6-3' lG :.

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.3 FACILITY STAFF 00ALIFICATIONS 6.3.1 Each member of the facility management / supervisory staff shall meet or exceed the minimum qualifications of ANSI 18.1-1971 for comparable positions, except for the Radiation Protection Manager who shall also meet the minimum qualifications of Regulatory Guide 1.8. Revision 1.

p.4 TRAINING 6.4.1 A retraining and replacement training program for the facility Certified Fuel Handlers shall be conducted in accordance with an NRC approved training program.

A training program for the unit staff shall meet or exceed the

-requirements and recommendations of Section 5.5 of ANSI N18.1-1971.

6.5 REVIEW AND AUDIT 6-6 1--PLANT-OPFRAT40N-REV4FW-GOMMITTEE 1

FUNGTION 6:5-4rl-4he-Plant-Operat4en-Review-Gemm4ttee-4PORG4-sha44-funet4en-te adv4se-the-Plant-Supee4ntendent-en-all-matters-related-te-neelear safety-GOMPOSITION 6:6-4:2-lhe-PORG-sha44-be-composed-ef-a-Cha4rman-and-a-min 4 mum-ef-feue management /supeev4sery-etaff-members-whe-are-appe4ntedr-4n wefttegr-by-the-Plant-Super 4atendent:

AbTERNATFS 6:5:4:3-All-alternate-members-sha44-be-appeinted-49-we4 ting-by-the-Plant

'Supee4ntendent-te-serve-en-a-temperary-basist-hewevepr-no-mere l

then-twe-alternates-sha44-part4e4pate-49-PORG-aet4v4 ties-at-any ene-time-fee-the-purpose-ef-establish 4ng-a-querum i

YANKEE-ROWE 6-5'

r 6.0 ADMINISTRATIVE CONTROLS (Continued)

MFFT4NG-FRE0WFNGV 6+6:1-4-lhe-PORG-sha44-meet-at-least-enee-pee-salendae-month-and-as eenvened-by-the-PORG-Gha4fmaar GUORUM 6:5:1-6-A-querum-ef-the-PORG-sha44-eens4st-ef-a-maser 4ty-ef-the-members-4n Spee4ffeat4en-6-6 4rBy-49 eluding-the-Ghairman:

RESPONS4 Bib 4T4' S 1

6:5:1-6-lhe-PORG-sha44-be-eespens4ble-fee +

ar--Rev4ew-ef-14-a44-preeedures-eequ4 Fed-by-Spee444 eat 4en-6r7 and-shanges-thereter-and-24-any-ether-peepesed-preeedures er-ehanges-therete-as-determ49ed-by-the-Plant Super 4ntendent-to-affeet-nuelear-safety-l

)

br--Review-ef-al4-preposed-tests-and-expee4ments-that-affest l

nue4 ear-safetyr ar--Rev4ew-ef-a44-proposed-ehanges-te-the-feehn4eal l

Spee4f4eatiens-er-L4eenser dr--Review-ef-all-preposed-shanges-ee-mediffeat4 ens-te-plant systems-ee-equ4pment-that-affeet-nueleaf-safety; l

l er--Invest 4 atien-of-a44-v4elattens-ef-the-Teehn4eal 9

i' Spee+f4ea64 ens-4nelud4ng-the-prepaeat4en-and-ferward499 l

ef-reperts-eevering-evaluat4en-and-feeemmendat4 ens-te

. prevent-Feeurrenee-to-the-Deeemm4ssiening-Hanager-ef Operat4 ens-3nd-to-the-Ghairman-ef-the-Nuelear-Safety J

Aud46-and-Rev4ew-Gemm4tteer f---Rev4ew-ef-a44-REPORTABEE-EVENTS ge--Rev4ew-of-fas444ty-sperat4 ens-te-deteet-petent4al-nuelear j

safety-hazards i

h---Feefermanee-ef-speefal-rev4ewsr-4nvest49at4 ens-ef analys+s-and-repeets-thereen-as-feguested-by-the-Ghairman ef-the-Nueleaf-Safety-Audit-and-Revtew-Gemm4tteer 47--Review-ef-the-94 ant-Defueled-Seeue4ty-Plan-and 4mplementing-pFeeedures-and-ehanges-thereter dr--Rev4ew-ef-the-Defueled-Emergeney-Plan-and-4mplement4eg presedures-and-shanges-thereter i

YANKEE-ROWE-6-6

r-1 l

6.0 ADMINISTRATIVE CONTROLS (Continued) kr--Rev4ew-ef-every-unplanned-en-s4te-release-of-radieaet4ve l

material-to-the-env4rens-ineluding-preparatien-of-reports eevering-evaluat4enr-resemmendat4 ens-and-disposit4en-of the-eerreet4ve-astien-to-prevent-reeurrenee-and-the ferWarding-ef-these-reperts-le-the-Plant-Superintendent l

and-to-the-Nue4 ear-Audit-and-Review-Gemm4ttee-l 4r--Rev4ew-ef-ehanges-te-the-PROGESS-GON4R06-PROGRAM-and-the l

Off-S14E-00SE-GALGUbA440N-MANUAb-1 mr--Rev4ew-ef-ehanges-to-the-fire-Preteetion-Program AUTHOR 4TV 6:5:1 7-The-PORG-sha44+

ar--Resemmend-to-the-Plant-Superintendentr-wr4tten-approval er-d4sapproval-et-4tems-eensidered-under-6 6:1-6fa) through-fd+-abover br--Render-determinat4 ens-in-writing-w4th-regard-te-whether ee-not-each-4 tem-eens4dered-under-6:5:1 6fa4-threugh-fe) i abeve-eenst4 tut-es-an-oneeviewed-safety-question e r--P r e v 4 d e-w r it ten-n e t 4 f + e a t 4 e n-wi t h 4 n-24-h eu rs-t o-t he Deeemmissien4ng-Hanager-ef-Operatiens-of-disagreement between-the-PORG-and-the-Plant-Superintendent +-heweverv the-Plant-Superintendent-shall-have-respons4bi44ty-for l

resolution-ef-sush-disagreements-pursuant-te-6:4rl-abover i

REGORDS l

6:5-4-8-The-PORG-sha44-ma49tain-we4tten-minutes-ef-eaeh-meeting-and-esp 4es shall-be-provided-te-the-Geeemmiss4en469-Manager-ef-Operattens-and l

ehairman-ef-the-Nuelear-Safety-Aud4t-and-Rev4ew-Gemmitteer l

l YANKEE-ROWE 6-7 t.

V l-l 6.0 ' ADMINISTRATIVE CONTROLS (Continued)

I l

6-5-2-N WGI-E A R-S A FET V-A H94T-A N9-R F V 4 F W-GOMMITT F E l

FUNGTION l

6:5:2 1-lhe-Nuelear-Safety-Aud4t-and-Rev4ew-fNSAR4-Gemm4ttee-shall funet4en-to-prev 4de-4ndependent-rev4ew-and-aud4t-of-a44-aspeets-ef plant-safety --Adequaey-ef-th4s-rev4ew-and-audit-4s-assured-by-the eress-seet4en-ef-d4se4p44nes-required-of-the-Gemmittee-membersh4p i

as-deser4 bed-49-Seet4en-6:6:2 GOMPOS4440N 6 6:2:2-lhe-NSAR-Gemm4ttee-sha44-be-eempesed-ef-a-Ghairman-and-a-min 4 mum ef-feur-members-whe-are-appe4nted-by-the-Desemmiss4en499-Managee ef-Operat4 ens:--NSAR-Gemm4ttee-members-shall-net-be-members-of-the plant-staff 00Al-4F4 GAT 40N 6:6:2:3-Hembersh4p-te-the-NSAR-Gemm4ttee-requires-that-an-4ediv4 dual-meet ene-ef-the-belew-aeadem4e-and/se-exper4enee-requirements +

ar--Beeheler-Degree-of-equ4 valent -plus-f4ve-46+-years-total expertenee-in-the-belew-listed-dise4p44nes-br--Nine-494-years-tetal-exper4enee-in-the-belew-44sted dise4p44nes+

fa4----Nuelear-Power-Plant-leshnelegy (b4----Fae444ty--Operat4 ens fe4 Powee-Plant-Design (d 4--

Eng4neering/Nueleae--Engineer 4ag fe4 Rad 4atien-Safety f f) --

Safety-Analys4s f g 4---i n s t r u m e n t a t 4 e n-a nd-G e n t r el th)

Qua44ty-Assuranee l

YANKEE-ROWE 6-8

6.0 ADMINISTRATIVE CONTROL:i (Continued)

AbTFRNATES 6 6:2:4-A44-NSAR-Gemmittee-alternate-members-shall-be-appointed-49-writ 4ng by-the-Deessm4ssienteg-danager-ef-Operat4 ens-le-berve-en-a temperary-b'asist-hewev e rr-ne-mere-tha n-ene-al ter na t e-shall partie4pate-4n-NSAR-Gemm4tte9-astiv4t4es-at-any-ene-e4me-fer-the p u r po s e-e f-e s t a bl4 s h i n g-a-q u e t'em-GONSUETANTS 6:5:2:5-Gensultants-may-be-ut4442ed-as-determined-by-the-NSAR-Gemmittee Gha4rman-to-provide-e* pert-adviser-ehen-needed:-te-the-NSAR Gemmitteer MFFTING-FREQUFNGV 6-5-2-6-The-NSAR-Gemm4ttee-sha44-meet-at-least-enee-per-six-menthsr-+25% -

Spee4al-meetings-may-be-held-when-deemed-neeessary-by-Gempany management-er-by-the-Ghairman-ef-the-NSAR-Gemmittee-QU994M 6:5:2 7-A-NSAR-Gemm4ttee-querum-shall-eensist-ef-a-majority-ef-the-members-4n-Spee4ffeat4en-6:6:Bv27-49 eluding-the-Ghairman:-

YANKEE-ROWE 6-9

n 6.0 ADMINISTRATIVE CONTROLS (Continued)

I RFV4FW l

1 6 6 Br8-lhe-NSAR-Gemm4ttee-shall-rev4ew+

i ar--The-safety-evaluatiens-fee-14-ehanges-te-equ4pment-ee systemsr-and-24-tests-ee-expee4ments-sempleted-andee-the previs4 ens-of-10-GFR-60:59-te-vee 4fy-that-sush-aettens d4d-net-senst4tute-an-unrev4ewed-safety-quest 4en; br--Pfeposed-shanges-te-equ4pment-ee-systems-wh4eh-4avelve-an uneev4ewed-safety-quest 4en-as-def49ed-in-40-GFR-50-69:

er--Prepesed-tests-ee-expee4ments-wh4eh-4nvolve-an-unrev4ewed safety-quest 4en-as-def4ned-4n-40-GFR-50r69 dr--Preposed-shanges-te-Teehn4eal-Spee4fieattens-en-the b4eenser l

l er--V4elat40ns-of-sedes -fegulatiensv-efdefsr-Teehniedl l.

Spee4f4 eat 4 ens -44eense-Fequ4rements--ee-of-4nternal preeedures-ee-4nstreettens-hav4ag-nuelear-safety l

s4 94f4eaneer 9

i fr--S4994f4eant-eperat4ng-abnerma44t4es-ee-dev4at4 ens-feem

-l j.

normal-and-expeeted-performanee-ef-plant-equipment-that l

affeet-nueleae-safetyr-def4eed-as-Plant-Informatien i

RepeFts gr--All-REPORTABLE-EVENTSr br--Reports-and-meet 4eg-minutes-ef-the-PORGr 4---Perferm-spee4al-rev4ews-and-4evest49at4 ens-and-rendee repeets-thefeen-as-requested-by-the-Desemmissientag j

Manager-ef-Operat4 ens:

YANKEE-ROWE 6-10

7 t

l 6.0 ' ADMINISTRATIVE CONTROLS (Continued)

L AUDITS-l 6 6:2-9-Audits-ef-fae444ty-aetiv4 ties-sha44-be-performed-under-the eegn4aance-ef-the-NSAR-Gemmittee---These-audits-shall-ensempass+

l ar--The-eenfermanse-ef-fae444ty-eperation-le-peev4stens senta4ned-within-the-Teehnteal-Spee444 eat 4 ens-and app 44eable-44eense-eendit4 ens-at-4 east-enee-pee 12-monthst-+264 br--The-peeformaneer-tra4ntng-and-qua4444eattens-of-these members-of-the-fae444ty-staff-whe-have-a-direet

)

relat4ensh4p-te-eperattent-ma4ntenanse-ee-teeknisal aspeets-ef-the-plantr-at-4 east-enee-pee-42-menthsr-+25%-

l

)

er--The-eesults-of-ast4 ens-taken-to-eeeeeet-defie4ene4es eseuer4ng-4n-fae444ty-equ4pmentr-strueturesr-systems-or l

methed-of-eperat4en-that-affeet-nuelear-safety-at-4 east enee-per-6-monther +25%:

dr--The-perfermanee-ef-aet+vities-requ4eed-by-the-Operat4enal l

Qua44ty-Assuranee-Pregram-to-meet-the-eriteria-ef l

Append 4* 1B %-40-GFR-50r-at-least-ense-pee-24-monthsr

+25%:

er--The-Fae444ty-Defueled-Emergeney-Plan-and-4mplement4ng

- preeedures-at -least-enee-pef-12-monthsr-+25%:

fr--The-Fae444ty-Befueled-Seeurity-Plan-and-4mplement4ng l-peseedures-et-least-enee-pef-42-monthst-+25%:.

9 --The-Fae444ty-F4ee-Proteet4en-Pregeam-and-4mplement4ng l

preeedures-at-least-ense-per-24-menthsr-+264:

l l

hr--The-ead4elegtea4-menttering-pregram-and-the-results thereof-at-least-ense-per-42-menths;-+26%-

l

+r--The-OFF-S4TE-DOSE-GALGUEAT40N-MANUAb-and-4mplementing preeedures-at-4 east-ense-per-24-menthsr-+265:

j f---The-PROGESS-GONTR0b-PROGRAM-and-4mplement4ng-preeedures fee-process 4ag-and-packaging-ef-radteaet4ve-waste-at least-enee-per-24-months -+26%

kr--The-performanee-ef-ast4vities-affeet4eg-qua44ty-as required-by-eff4uent-and-env4venmental-men 4 teeing preeedures-at-least-enee-per-42-menther-+25%:

m YANKEE-ROWE 6-11 i

t'._

6.0 ADMINISTRATIVE CONTROLS (Continued) 1r--Any-etkee-area-ef-fac444ty-eperat4en-cons 4dered appropriate-by-the-NSAR-Gemmittee-er-the-Decomm4ssiening Ma n age r-of-Oper a t+en s--

AUTHOR 4TV 6:6 2r40---

The-NSAR-Gemm4ttee-sha44-repert-te-and-adv4se-the Deeemmissioning-Hanagee-ef-Operat4 ens-en-these-areas-ef respons4b444ty-spee4+4ed-4n-Seetten-6:5:2 8-and-6:5:2-9:

RECORDS 6:6:2:44 M4nutes-of-eash-NSAR-Gemm4ttee-meeting-shall-be-prepared-and forwarded-to-the-Deeomm4ssion4ng-Manager-of-Operat4 ens-and eaeh-member-ef-the-Gemmittee-for-review-with+n-20-work 4ag days-fe44 ewing-each-meeting --The-meet 4ng-minutes-sha44 j

4eeluder-where-app 44eabler-reports-ef-rev4ews-eneempassed-by j

t Seetten-6:6:2-8+-and-reports-ef-aud4ts-eneempassed-by i

Seet4en-6 6:2-9 --4he-review-of-the-minutes-shall-be l

esmpleted-w4 thin-60-days-of-the-date-ef-their-distribution:

l 6.5.1 Independent Safety Review j

i l

An Independent Safety Review shall be a thorough review conducted l

by one or more qualified Independent Safety Reviewers.

Persons I

l performing these reviews shall be knowledgeable in the subject 3

l area being reviewed.

Independent Safety Reviews must be completed l

prior to implementation of proposed activities.

I

[

a.

Independent Safety Reviewers shall be individuals without l

direct responsibility for the performance of the activities l

under review; these reviewers may be from the same l

functionally cognizant organization as the individual or l

group performing the original work.

l l

b.

Independent Safety Reviewers shall have at least 5 years of l

professional experience and either a Bachelor's Degree in l

Engineering or the Physical Sciences or shall have equivalent l

qualifications in accordance with ANSI 18.1-1971.

The l

Decommissioning Manager (or a designee) shall document the l

appointment of Independent Safety Reviewers.

I l

c.

The following subjects shall be independently reviewed by a l

qualified Independent Safety Reviewer:

I l

1.

safety evaluations for changes in the facility as l

described in the Final Safety Analysis Report (FSAR).

l Changes in procedures as described in the FSAR, and tests l

or experiments not described in the FSAR to verify that I

l Such actions do not involve a change to the Technical YANKEE-ROWE 6-12

6.0 ADMINISTRATIVE CONTROLS (Continued) l Specifications or will not involve an unreviewed safety l

question as defined in 10CFR50.59:

l l

2.

proposed changes to the programs required by Technical l

Specification 6.7. to verify that such changes do not j

l involve a change to the Technical Specifications and will l

not involve an unreviewed safety question as defined in l

10CFR50.59: and l

l 3.

proposed changes to the Technical Specification Bases.

l l

6.5.2 Independent Review and Audit Committee (IRAC) l l

The IRAC is responsible for reviewing. auditing, and advising the j

l l

President of Yankee Atomic Electric Company (or a designee) on l

matters related to the safe storage of irradiated fuel.

This l

l review and audit function is independent of line organization l

responsibilities.

I l

a.

The IRAC shall include a minimum of five members.

Alternates l

l may be substituted for regular members.

The licensee shall l

designate in writiag the chairman, the members, and l

alternates for the IRAC.

The chairman shall not have j

i l

management responsibilities for, or report to, the line l

organizations responsible for operation or maintenance of the l

fuel storage facility.

I l

b.

The IRAC shall collectively have experience and knowledge in l

the following functional areas:

l l

1.

fuel handling and storage (including the potential for l

criticality).

l 2.

chemistry and radiochemistry..

l 3.

engineering.

l 4

radiation protection, and l

S.

quality assurance.

I j

c.

The IRAC shall hold at least one meeting per quarter.

l l

d.

A quorum shall consist of three regular members or their duly l

appointed alternates, Those members representing the line l

organizations responsible for the operation and maintenance l

of the facility shall not constitute a majority of the l

quorum.

At least one member of the quorum shall be the l

chairman or the chairman's designated alternate.

I l

e.

As a minimum, the IRAC shall perform the following functions:

I l

1.

advise the Decommissioning Manager (or a designee) on all l

matters related to safe storage of irradiated fuel:

YANKEE-ROWE 6-13

l i

6.0 ADMINISTRATIVE CONTROLS (Continued) l 2.

advise the management of the audited organization and the l

Decommissioning Manager (or a designee) of audit results l

as they relate to safe storage of irradiated fuel:

l l

3.

recommend to the management of the audited organization.

l and its management. any corrective action to improve the l

l safe storage of irradiated fuel; and l

l 4.

notify the President of Yankee Atomic Electric Company of l

any safety significant disagreement between the IRAC and l

the Decommissioning Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l l

f.

The IRAC shall be responsible for reviewing:

l l

1.

the safety evaluations for procedures, and changes l

thereto completed under the provisions of 10 CFR 50.59 l

to verify that such actions do not involve an unreviewed l

safety question as defined in 10 CFR 50.59.

This review j

may be completed after implementation of the affected l

procedure:

l l

2.

changes to structures, systems, or components important l

to the safe storage of irradiated fuel to verify that j

such changes do not involve an unreviewed safety question l

as defined in 10 CFR 50.59.

This review may be completed l

after implementation of the change:

I l

3.

tests or experiments involving the safe storage of l

irradiated fuel to verify that such tests or experiments l

do not involve an unreviewed safety question as defined l

in 10 CFR 50.59.

This review may be completed after l

performance of the test or experiment:

I j

4.

proposed changes to the YNPS Technical Specifications or j

the license; 1

i l

5.

violations of codes. regulations, orders, license l

requirements. or internal procedures / instructions having j

l nuclear safety significance:

l^

l 6.

indications of unanticipated deficiencies in any aspect l

of design or operation of structures, systems or l

components that could affect safe storage of irradiated l

fuel:

l l

7.

significant accidental, unplanned, or uncontrolled l

l radioactive releases including corrective action (s) to l

prevent recurrence:

YANKEE-ROWE 6-14

6.0. ADMINISTRATIVE CONTROLS (Continued) m l

8.

significant operating abnormalities or deviations from l

normal and expected performance of equipment that affect j

safe storage of irradiated fuel:

l l

9.

the performance of the corrective action system: and I

l

10. internal and external experience information related to l

the safe storage of irradiated fuel that may indicate l

areas for improving facility safety.

l l

Reports or records of these reviews shall be forwarded to the l

Decommissioning Manager within 30 days after completion of l

the review.

l l

g.

The IRAC's audit responsibilities shall encompass:

l l

1.

conformance of irradiated fuel storage to provisions l

contained within the YNPS Technical specifications and l

applicable license conditions:

l l

2.

the training and qualifications of facility staff:

l l

3.

implementation of all programs required by YNPS Technical l

Specification 6.7.

l l

4.

actions taken to correct deficiencies occurring in l

structures, systems, components, or methods of operation l

that affect safe storage of irradiated fuel; I

l 5.

facility operations, modifications, maintenance, and l

Surveillance related to the safe storage of irradiated l

fuel to verify independently that these activities are l

performed safely and correctly: and l

J 6.

other activities and documents as requested by the l

Decommissioning Manager (or a designee).

l l

Reports of records of these audits, including any l

recommendations for improving the safe storage of irradiated l

fuel, shall be forwarded to the Decommissioning Manager (or a l

designee) within 30 days after completion of the audit.

I l

6.5.3 Records l

l Written records of reviews and audits shall be maintained.

As a

.l minimum, these records shall include:

l l

a.

Results of the activities conducted under the provisions of l

Specifications 6.5.1 and 6.5.2:

YANKEE-ROWE 6-15

6.0 ADMINISTRATIVE CONTROLS (Continued) l b.

Recommendations to the management of the audited l

organization; I

l c.

An assessment of the safety significance of review or audit l

findings:

l l

d.

Documentation of reviews conducted under Specification l

6.5.1.c: and l

l e.

Determination of whether each item considered under l

Specifications 6.5.2.f.1 through 6.5.2.f.3 involves an l

unreviewed safety question as defined in 10CFR50.59.

YANKEE-ROWE 6-16

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a.

The Commission shall be notified and a report submitted pursuant to the requirements of 10 CFR 50.73. and l

b.

Each REPORTABLE EVENT shall be reviewed by the an l

Independent Safety Reviewer PORG and the results of this l

review shall be submitted to the Independent Review and l

Audit Committee (IRAC) and the Decommissioning Manager l

NSAR-Gemmittee-and-the-Manager-ef-Operat4 ens.

6.7 PROCEDURES AND PROGRAMS 6.7.1 Written procedures shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of Sections 5.2 through 5.2.9 and 5.3 of ANSI N18.7-1972 and Appendix "A" of Regulatory Guide 1.33.

Revision 2. except as provided in 6.7.2 and 6.7.3 below.

The written procedures shall also cover the activities relating to:

I a.

Fire Protection Program implementation.

I b.

PROCESS CONTROL PROGRAM implementation.

l c.

OFF-SITE DOSE CALCULATION MANUAL implementation.

d.

Quality Assurance Program for effluent and environmental l

l monitoring, using the guidance in Reguletory Guice 1.21.

l Revision 1. June 1974 and Regulatory Guide 4.1, Revision 1. April 1975.

6.7.2 Each procedure ani edministrative policy of 6.7.1 above. and l

changes thereto, shall be reviewed by the an Independent l

Safety Reviewer Plant-0perattens-Rev4ew-Gemmittee and l

approved by the Decommissioning Manager Plant-Superintendent j

prior to implementation and reviewed periodically as set forth in administrative procedures.

j i

6.7.3 Preeedures-that-have-been-develepeu-as-a-resu4t-of-ekanges j

l deftned-4n-40-GFR-60:59fa4424-sha44-be-independently-rev4ewed l

te-verify-that-the-4mplementing-ast4 ens-de-net-senstitute-an l

unrev4ewed-safety-questten --4hese-reviews-sha44-be-performed l

by-Nuelear-Serv 4ee-04v4sion-persennel-hav4no-qua44fteat4 ens l

at-4 east-equ4 valent-to-these-spee4ffed-fer-NSAR-Gemmittee l

membersh4p-4n-the-Vankee-Decommiss4ening-Qua44ty-Assuranee l

Program-fV90AP+r--6 5-2-3--4he-preeedores-sha44-be-appreved l

by-the-Deeemmiss4en4eg-Hanager-ef-Operat4 ens YANKEE-ROWE 6-17

IU I

l l

6.0 ADMINISTRATIVE CONTROLS (Continued) l,

6. 7. 4' Temporary; changes'to procedures of 6.7.1 above may be made provided:

a.

The intent of the original procedure is not altered.

b.

The change is approved by two members of the-plant management staff, at least one of whom is a Certified fuel Handler.

l c.

The change'is documented -eev4ewed-by-PORG and approved l

by the Decommissioning Manager Plant-Supee4atendent L

within 14 days of implementation.

I 6.7. 5 The following programs shall'be established, implemented. and l

maintained:

a.

Radioactive Effluent Controls Proaram

.A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable.

E The program (1) shall be contained in the ODCH. (2) shall be implemented by cperating procedures, and (3) shall l

include remedial actions to be taken whenever the program limits are exceeded.

The program shall include the t

following elements:

i 1)

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation.

l i

including surveillance tests and setpoint I

determination in accordance with the methodology j

- in the ODCH:

1 2)

Limitations on the concentrations of radioactive L

material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 CFR. Part 20.

Appendix B. Table 11. Column 2:

3)

Monitoring, sampling. and analysis of radioactive l

liquid and gaseous effluents in accordance with l

l 10 CFR 20.106 and with the methodology and parameters in the ODCM; 4)

Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials ia liquid effluents released l

YANKEE-ROWE 6-14 I

r 6.0 ADMINISTRATIVE CONTROLS (Continued) 6.9.2 (continued) i f.

Records of transient or operational cycles for the

}

Reactor Pressure Vessel.

g.

Records of training and qualification for current members of the plant staff.

h.

Records of inservice inspections performed pursuant to Technical Specifications.

i.

Records of Quality Assurance activities required by the OA manual.

j.

Records of reviews performed for changes made to i

procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k.

Records of Independent Safety Reviews meetings-ef-the l

p0RG-and-NSAR-and the IRAC meetings, and Records of the l

Plant Operational Review Committee (PORC) and the Nuclear l

Safety Audit and Review Committee (NSARC). the review and l

audit functions which preceded the Independent Safety j

l Review function and IRAC.

1.

Records for Environmental Qualification.

m.

Records of analysis required by the Radiological Environmental Monitoring Program.

n.

Records of the service lives of all snubbers, including the date at which the service life commences and associated installation and maintenance records.

o.

Records of reviews performed for changes made to the OFF-SITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

6.10 RADIATION PROTECTION PROGRAM 6.10.1 Procedures for personnel radiation protection shall be prepared consistent with requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposures.

YANKEE-ROWE 6-19

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.12 PROCESS CONTROL PROGRAM (PCP) 6.12.1 Changes to the PCP:

)

a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.9.2.0.

This documentation shall contain:

1)

Sufficient information to support the change j

together with the ap.aropriate analyses or evaluation justify'ing the change (s), and 2)

A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of federal, state, or other applicable regulations.

I b.

Shall become effective after review and acceptance by the i

l PORG an Independent. Safety Reviewer and the approval of l

the Decommissioning Manager.-Plant-Super 4ntendent-j 4

1 i

Y NKEE-RdWE

'6-21' t

r 6.0 ADMINISTRATIVE CONTROLS (Continued) i 6.13 0FF-SITE DOSF CALCULATION MANUAL (ODCM) 6.13.1 Changes to the ODCM:

l a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.9.2.0.

This documentation shall contain:

1)

Sufficient information to support the change to! ether with the appropriate analyses or ev;1uation justifying the change (s), and 2)

A determination that the change will maintain the level of the radioactive effluent control required by 10 CFR 20.106. 40 CFR 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b.

Shall become effective after review and acceptance by l

the-p0RG-an Independent Safety Reviewer and the approval l

Of the Plant-Super 4ntendent-Decommissioning Manager, c.

Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of I

or concurrent with the Annual Radioactive Ef fluent Release Report for the period of the report in which any change to the ODCM was made.

Each change shall be identified by markings in the margin of the affected pages, clearly indicating the. area of the page that was changed, and shall indicate the date (e.g.. month / year) the change was implemented.

YANKEE-ROWE 6-22 Amendment No. 151 l

t

p.

t i

ATTACHMENT II J

l Revised Technical Snecification Panes 6-1 6-3 6-5 through 6-14 6-19 6-21 6-22 i

1 l

l

6.0 ADMINISTRATIVE CONTROLS Administrative controls are the written rules, orders, instructions, procedures, policies, practices and the designation of authorities and responsibilities by the management to obtain assurance of safety and quality of maintenance of a nuclear facility.

These controls shall be adhered to.

6.1 RESPONSIBillTY l

6.1.1 The Decommissioning Manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

4 6.1.2 In all matters relating to the operation of the plant and to l

these Technical Specifications, the Decommissioning Manager shall report to and be directly responsible to the President of Yankee Atomic Electric Company.

6.2 ORGANIZATION An on-site and an off-site organization shall be established 6.2.1 for plant operation an'd corporate management.

The on-site and off-site organization shall' include the positions for activities affecting the safety of the facility.

a.

Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate. levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate in the form of organizational charts.

These organizational charts shall be documented in the i

fSAR b.

A single corporate officer shall have overall responsibility for plant nuclear safety.

This individual shall take any measures needed to ensure acceptable performance of the staff in operating.

maintaining and providing technical support in the plant so that continued nuclear safety is assured.

c.

There shall be an individual management position in the on-site organization having overall responsibility for safe operation of the pl

, he/she shall have, control over those on-site re rces necessary for safe oppration and ma ntenance of the plant.

. YANKEE ROWE 61 i-L

6.0 ADMINISiRATIVE CONTROLS (Continued)

Adequate shift coverage shall be maintained without routine heavy use of overtime.

The objective shall be to have operating personnel work. on the average, an approximate 40-hour week.

However in the event that L

unforeseen problems require substantial amounts of

- overtime to be used. or during major maintenance or major plant modifications, on a temporary basis. the following guidelines shall be followed:

(1) An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

(2)

An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time.

(3)

A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including shift turnover time.

(4) The use of overtime should be' considered on an individual basis and not for the entire staff on

~

shift.

Any deviation from the above. guidelines shall be l

authorized by the Decommissioning Manager or his delegated representative, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

l Controls shall be reviewed monthly by the Decommissioning l

Manager or his delegated. representative to assure th.at_

excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

i 1

i

~

YANKEE'-ROWE 6-3 i

l r

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.3 FACitITY STAFF'00AllFICAT10NS i

6.3.1 Each member of the facility management / supervisory staff shall meet or exceed the minimum qualifications of ANSI 18.1-1971 for comparable positions, except for the l

Radiation Protection Manager who shall also meet the minimum qualifications of Regulatory Guide 1.8. Revision 1.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility Certified Fuel Handlers shall be conducted in accordance with an NRC approved training program.

A training program for the unit staff shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.

6.5 REVIEW AND AUDIT l

l 6.5.1 Independent Safety Review I

l An Independent Safety Review shall be a thorough review conducted l

by one or more qualified Independent Safety Reviewers.

Persons l

performing these reviews shall be knowledgeable in the subject l

j area being reviewed.

Independent Safety Reviews must be completed l

prior to implementation of proposed activities.

i I

l a.

Independent Safety Reviewers shall be individuals without I

l direct responsibility for the performance of the activities l

under review: these reviewers may be from the same l

functionally cognizant organization as the individual or l

group performing the original work.

l l

b.

Independent Safety Reviewers shall have at least 5 years of l

professional experience and either a Bachelor's Degree in l

Engineering or the Physical Sciences or shall have equivalent l

qualifications in accordance with ANSI 18.1-1971.

The l

l Decommissioning Manager (or a designce) shall document the l

appointment of Independent Safety Reviewers.

)

I l

c.

The following subjects shall be independently reviewed by a l

qualified Independent Safety Reviewer:

I l

l 1.

safety evaluations for changes in the facility as I

described in the Final Safety Analysis Report (FSAR).

l changes in procedures as described in the FSAR, and tests l'

or experiments not described in the FSAR to verify that l

such actions do not' involve a change to the Technical YANKEE-ROWE 6-5 I

F 6.0 ADMINISTRATIVE CONTROLS (Continued) l Specifications or will not involve an unreviewed safety l

question as defined in 10CFR50.59:

l l

2.

proposed changes to the programs required by Technical l

Specification 6.7. to verify that such changes do not l

involve a change to the Technical Specifications and will l

not involve an unreviewed safety question as defined in l

10CFR50.59: and I

l 3.

proposed changes to the Technical Specification Bases.

l l

6.5.2 Independent Review and Audit Committee (IRAC) l l

The IRAC is responsible for reviewing. auditing, and advising the l

President of Yankee Atomic Electric Company (or a designee) on j

matters related to the safe storage of irradiated fuel.

This l

review and audit function is independent of line organization l

responsibilities.

I l

a.

The IRAC shall include a minimum of five members.

Alternates l

may be substituted for regular members.

The licensee shall l

designate in' writing the chairman, the members, and I

alternates for the IRAC.

The chairman shall not have j

l managerent responsibilities for, or report to, the line

(

l organizations responsible for operation or maintenance of the l

fuel storage facility..

l l

b.

The IRAC shall collectively have experience and knowledge in l

the following functional areas:

l l

l 1.

fuel handling and storage (including the potential for l

l criticality).

l 2.

chemistry and radiochemistry, j

3.

engineering.

l 4.

radiation protection, and i

5.

quality assurance.

]

I l

c.

The IRAC shall hold at least one meeting per quarter.

I l

d.

A quorum shall consist of three regular members or their duly I

appointed alternates.

Those members representing the line l

organizations responsible for the operation and maintenance 1

of the facility shall not constitute a majority of the l

quorum.

At least one member of the quorum shall be the l

chairman or the chairman's designated alternate.

I l

e.

As a minimum, the IRAC shall perform the following functions:

l l

1.

advise the Decommissioning Manager (or a designee) on all l

matters related to safe storage of irradiated fuel:

YANKEE-ROWE 6-6

6.0 ADMINISTRATIVE CONTROLS (Continued)

-.h"M l

2.

advise the management of the audited organization and the l

Decommissioning Manager (or a designee) of audit results l

as they relate to safe storage of irradiated fuel; l

l 3.

recommend to the management of the audited organization.

l and its management, any corrective action to improve the

-l safe storage of irradiated fuel: and l

l 4.

notify the President of Yankee Atomic Electric Company of l

any safety significant disagreement between the IRAC and l

the Decommissioning Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l l

f.

The IRAC shall be responsible for reviewing:

I l

1.

the safety evaluations for procedures, and changes l

thereto, completed under the provisions of 10 CFR 50.59 l

to verify that such acti')ns do not involve an unreviewed j

safety question as defined in 10 CFR 50.59.

This review l

may be completed af ter implementation of the affected l

procedure:

I l

2.

changes to structures, systems, or components important l

l to the safe storage of irradiated fuel to verify that l

l such changes do not involve an unreviewed safety question l

as defined in 10 ffR 50.59.

This review may be completed l

l after implementation of the change; j

I I

l 3.

tests or experiments involving the safe storoge of l

l irradiated fuel to verify that such tests or experiments l

l do not involve an unreviewed safety question as defined l

in 10 CFR 50.59.

This review may be completed after l

performance of the test or experiment:

l l

4.

proposed changes to the YNPS Technical Specifications or l

the license; I

l 5.

violations of codes, regulations, orders, license I

l requ,rements, or internal procedures / instructions having l

nuclear safety significance:

l l

6.

indications of unanticipated deficiencies in any aspect l

of design or operation of structures, systems, or l

components that could affect safe storage of irradiated l

fuel:

l l

7.

significant accidental, unplanned. or uncontrolled l

radioactive releases, including corrective action (s) to l

prevent recurrence:

YANKEE-ROWE 6-7

F l

l 6.0 ADMINISTRATIVE CONTROLS (Continued)

_l 8.

significant operating abnormalities or deviations from l

normal and expected performance of equipment that affect l

safe storage of irradiated fuel; I

l 9.

the performance of the corrective action system; and I

l

10. internal and external experience information related to l

the safe storage of irradiated fuel that may indicate l

areas for improving f acility safety.

l l

Reports or records of these reviews shall be forwarded to the l

Decommission.ng Manager within 30 days after completion of l

the review.

l l

g.

The IRAC's audit responsibilities shall encompass:

I

\\

l 1.

conformance of irradiated fuel storage to provisions l

contained within the YNPS Technical specifications and l

l applicable license conditions:

l l

2.

the training and qualifications of facility staff:

I l

l 3.

implementation of all programs required by YNPS Technical l

l Specification 6.7.

l l

l 4.

actions taken to correctddeficiencies occurring in l

structures, systems, components or methods of operation l

that affect safe storage of irradiated fuel; I

l S.

facility operations, modifications. maintenance, and l

Surveillance related to the safe storage of irradiated l

fuel to verify independently that these activities are l

l performed safely and correctly: and l

l l

l 6.

other activities and documents as requested by the l

Decommissioning Manager (or a designee).

l l

Reports of records of these audits, including any l

recommendations for improving the safe storage of irradiated l

fuel, shall be forwarded to the Decommissioning Manager (or a j

designee) within 30 days after completion of the audit.

l l

6.5.3 Records l

l Written records of reviews and audits shall be maintained.

As a j

minimum, these records shall include:

l l

a.

Results of the activities conducted under the provisions of l

Specifications 6.5.1 and 6.5.2; YANKEE-ROWE 6-8

6.0 ADMINISTRATIVE CONTROLS (Continued) l l

b.

Recommendations to the management of the audited l

organization:

l l

c.

An assessment of the safety significance of review or audit l

findings:

l l

d.

Documentation of reviews conducted under Specification l

6.5.1.c: and I

l e.

Determination of whether each item considered under i

l Specifications 6.5.2.f.1 through 6.5.2.f.3 involves an l

unreviewed safety question as defined in 10CFR50.59.

I i

i YANKEE-ROWE 6-9 t

p 6.0 ADMINISTRATIVE CONTROLS (Continued) l l

Pages 6-10 through 6-12 have been deleted.

l l

l I-YANKEE-ROWE 6-10

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a.

The Commission shall be notified and a report submitted pursuant to the requirements of 10 CFR 50.73, and l

b.

Each REPORTABLE EVENT shall be reviewed by an independent l

Safety Reviewer and the results of this review shall be l

submitted to the Independent Review and Audit Committee

.l (IRAC) and the Decommissioning Manager.

6.7 PROCEDURES AND PROGRAMS 6.7.1 Written procedures shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of Sections 5.2 through 5.2.9 and 5.3 of ANSI N18.7-1972 and Appendix "A" of Regulatory Guide 1.33.

Revision 2. except as provided in 6.7.2 and 6.7.3 below.

The written procedures shall also cover the activities relating to; a.

Fire Protection Program implementation.

b.

PROCESS CONTROL PROGRAM implementation.

j c.

OFF-SITE DOSE CALCULATION MANUAL implementation, i

d.

Quality Assurance Program for effluent and environmental f

j monitoring, using the guidance in Regulatory Guide 1.21 L

Revision 1. June 1974 and Regulatory Guide 4.1.

Revision 1. April 1975.

6.7.2 Each procedure and administrative policy of 6.7.1 above, and l

changes thereto, shall be reviewed by an Independent Safety l

Reviewer and approved by the Decommissioning Manager prior to implementation and reviewed periodically as set forth in administrative procedures.

l 6.7.3 Deleted.

YANKEE-ROWE 6-13

l l-l~

6.0 ADMINISTRATIVE CONTROLS (Continued) i 6.7.4 Temporary changes to procedures of 6.7.1 above may be made l

provided:

a, The intent of the original procedure is not altered.

~

b.

The chcnge is approved by two members of the plant management staff, at least one of whom is a Certified i

Fuel Handler.

l c.

The change is documented and approved by the l

Decommissioning Manager within 14 days of implementation.

6,7.5 The following programs shall be established, implemented, and maintained:

}

8.

Radioactive Effluent Controls Program j

l A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for i

maintaining the doses to MEMBERS OF THE PUBLIC from l -

radioactive effluents as low as reasonably achievable.

The program (1) shall be contained in the ODCM. (2) shall l

be implemented by operating procedures, and (3) shall l

include remedial actions to be taken whenever the program limits are exceeded.

The program shall include the l

following elements:

l 1)

Limitations on the operability of radioactive liquid l

and gaseous monitoring instrumentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM:

l 2)

Limitations on the concentrations of-radioactive material released in liquid effluents to l

UNRESTRICTED AREAS conforming to 10 CFR. Part 20.

Appendix B. Table 11 Column 2:

3)

Monitoring, sampling, and analysis of radicactive liquid, and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODCM:

4)

Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive. materials in liquid effluents released YANKEE-R0WE 6-14 i

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.9.2 (continued) 1 f.

Records of transient or operational cycles for the Reactor Pressure Vessel.

]

I g.

Records of training and qualification for current members of the plant staff.

h.

Records of inservice inspections performed pursuant to Technical Specifications.

i Records of Quality Assurance activities required by the QA manual, j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

l k.

Records of Independent Safety Reviews and the IRAC l

meetings, and Records of the Plant Operational Review l

Committee (PORC) and the Nuclear Safety Audit and Review l

Committee (NSARC), the review and audit functions which l

preceded the Independent Safety Review function and IRAC.

1.

Records for Environmental Qualification.

m.

Records of analysis required by the Radiological Environmental Monitoring Program.

n.

Records of the service lives of all snubbers including the date at which the service life commences and i

associated installation and maintenance records.

I o.

Records of reviews performed for changes made to the 0FF-l SITE DOSE CALCULATION MANUAL and the PROCESS CONTROL j

PROGRAM.

l 6.10 RADIATION PROTECTION PROGRAM l

6.10.1 Procedures for personnel radiation protection shall be prepared consistent with requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving l

personnel radiation exposures.

YANKEE-ROWE 6 19

i A

i 6.0 ADMINISTRATIVE CONTROLS (Continued) 5.12 PROCESS CONTROL PROGRAM (PCP) 6.12.1 Changes to the PCP:

a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.9.2.o.

This documentation shall contain:

1)

Sufficient information to support the change together with the appropriate analyses or evaluation justifying the chaage(s), and 2)

A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of federal, state, or other applicable regulations.

I b.

Shall become effective after review and acceptance by an l

Independent Safety Reviewer and the approval of the l.

Decommissioning Manager.

4 e

YANKEE-ROWE 6-21 L

6.0 ADMINISTRATIVE CONTROLS (Continued) 6.13 0FF-SITE DOSE CALCULATION MANUAL (ODCM) 6.13.1 Changes to the ODCM:

a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.9.2.0.

This documentation shall contain:

1)

Sufficient information to support the change together with the appropriate analyses or evaluation justifying the change (s), and 2)

A determination that the change will maintain the level of the radioactive effluent control required by 10 CFR 20.106. 40 CFR 190, 10 CFR Su.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of effluent. dose, or l

setpoint calculations.

I l

b.

Shall become effective after review an/

ceptance by an i

l l

Independent Safety Reviewer and the ak val of the l

Decommissioning Manager.

c.

Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made.

Each change shall be identified by markings in the margin of the affected

{

pages, clearly indicating the area of the page that was

{

changed, and shall indicate the date (e.g.. month / year)

J the change was implemented.

YANKEE-ROWE 6 22 Amendment No. 151 i