ML20211H397

From kanterella
Jump to navigation Jump to search
Proposed Tech Specs Relocating Info from Current TS to UFSAR Section 17.2
ML20211H397
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 07/06/1990
From:
IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:
Shared Package
ML20211H372 List:
References
NUDOCS 9710060364
Download: ML20211H397 (24)
v • d • e


Text

- -

Attachment 3 i

l l ITS Mark-up of Technical Specifications, Section 6 (Applicable Pieces)

lA 288M 8?88882; P PDR

l ha ci t C eit 'Oh h.O i

DAEC-1 l

El efVfEV aWD atDIT s i

s 1 6.5.3 Operations Coaritttee E.5.3.3 etion o The erstions Committee shall function to as se the Plant A7 Sper tendent - huclear en all matters related o nuclear safety.

6.E.1.2 Composit The Operatto Committee shall be composed of selected sittant Plant Superintenden Superintendents, Superviserr and person I from the followirg depa nts: Operations, Maintenance, Reactor P tornance, Radiatio.1 Protect n, Quality Control, and Technical Support.

The Assistant Plant erintendent-Operations and Maintenance : 1 act as the Chairman. e or more of the sceners shall be designa as Vice Chairman.

i 6.5.3.3 Alternates

  • A alternate members shall b ga ppointed in writing by the Plant -

' Sup intendent-Nuclear to serve \on a permanent basis; however, ne more than roeactivities alterr.stesatshall Commit any partitipate one tiha. as voting members in Operations) >

Amendment No. 89,736,166 6.5-1 J'JL 6 1990 i

[pgirTocsi.)v .E O

~

DAEC-1 N

6.5.1.4 h eting Frequency The Operations Consittee me' at least once per calendar month and as convened by the Operations Cosenittee Cha rean or Vice Chairman.

6.5.1.5 Quorum A uorum of the Operations Committee sha 1 consist of the chairman or Vic ,

Chai an and five members including alterna s.

6.5.1.6 sponsibilities 4

/ The operation Committee shall be responsible fort

a. Review of ) all procedures required by Specific ion 6.8, Plant Operating P edures, and changes thereto, (2) any o er proposed proceduresorelngestheretoasdeterminedbytheplantSuperintendent)

Nuclear to affect clear safety. "

Review of all proposed t ts and experiments that affect nuclear afety,

c. eview of all proposed change to the Technical Specifications.
d. Revi of all proposed changes or a ifications to plant systems or equipse that affect nuclear safety,
e. Investigatio of all violations of the Techni 1 Specifications {

including the p paration and forwarding of repo s covering evaluation and recomendation to prevent recurrence to the Vi President, Nuclear and to the Chairman o the Safety Committee.

Amendment No. 82.157,198 6.5-2

SPdiFdn g DAEC-1

' '#I'" 8f 411 Repo able Events.

,/

!9 Review of f 999ty operations to datect potential safety haza s.

- er mance of special review . Investigati 1 sis and reports there s requested by the Chat n of th Sa% t a

. Review of the Pla securgtY Plan. < /,/

d- Review of e Energency Plan, 1

k. Rev of every unplanned release of radioacti'vity to the environs for.which a

. sport to the NRC s/required. /

p/

.- }

J

}

/1. Review of changes to the Offsite Dose Assessment Manua nd changes to the .

Proces atrol Progr

/

a.

/ /l

'lteview of the fra Protection Program and' implementing procedures. '/

, ./ f -

i 6.5.1.7 thority

'j l

The O

/ p'erations Comeittee shall:

1

/ ,

a. Recommend to the Plant Superintend Nuclear written approval or disapproval i

of itemsconsidered

/

/  !

under Specification 6.5.1.6 (a) through (d) above. ,

_p h adment No, ;;;.II0,214 6.5 3

[pecs'h::.'G;e C .)

1 DAEC-1

', b. Render determination inwritingwithregardtowhethef'ornoteachitem considered under 6.5.1.6 a) through (e) above constitutes n unreviewed safety question.

~

c. Provide written notification within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to the Vice President, Nuclear and the Safety Committee of di greement oatween the Operations Comittee and the Plant Superintendent-Nu ear; however, the Plant 1 5 erintendent-Nuclear shall have responsibil for resolution of such disa sements pursuant to Specification 6.1.1 at.o .

i

/

  • f " 6.5.1.8 Record i .'y s

The Operations Comitt a shall maintain written minutes of each meeti and

, copies shall be provided o the Vice Present, Nuclear and the Chairman o the

Safety Cosmiittee.

6.5.2 Safety Comittee 6.5, 1 Function The Safety omittee shall function to provi independent review and audit of disignated ac vitiks in the areas of:

a. Nuclear power lant operations.
b. Nuclear Engineering. s Amendment ho.80.726198 6.5-4

_ _ _ _ . _ _ . . . _ _ _ , . _ . _ . _ _ _ _ . _ _ . _ _ . ~ _ _ _ .

spy e : ) ;c d' ," C .i

. unu-t

.>.1.*wv i a.k .*" . y;, ., .-st.c..: "* ..

.~#

" h eelstry and radisch i . .

d. Metallurgy, i

l Instrumentation and control.

f. Red logical safety. .
g. Mechanica electrical engineering.

,' 4 4

h7 h. Quality assur recticas.

4 i

1. Non-destructive testing .

Administration, 8.5.2.2 omeosition The Sr.faty C' ttaa sna11 he composed of persons have bean, appointed in wetting by the Pre ident to serve on a permanent bast and who collectively have or have access t applicable technica) and experi al exoertise in the as listed in section 5.2.1. items a through J.

G G

}5-' men nc , . n S

__ . . _ _ . . _ _ _ _ _ . _ . . _ _ . . . . _ . . _ _ _ . ~ . _-- . _ _ .

[ u; [:.y . , T3 l

.s -

~.4. :lg5,$ !Mn'$x.

. . . .: - - - k.*d**.'.&.k.%

. 2 .. I

. 7~i.I..... .

. [:f1lf.lf.$,.I.' '.I ,

arc t I C

i l

. 6.5.2.3 Alternates -

)

. \ A alterrate members shall bs appointed n writina by the President'to serve c.n a armenent basis.

6.8.2.4 sultants Consultants sha be ut11tted as determined by the Sa y Comnittee Chairman to provide expert adv e to the Safety Committee. .

  1. 6.5.2.5 Heeting Freque

%F The safety Comalttee shall me at least once par calendar quarter Ing the

, initia year of facility operat following fuel loading and at least once per 1

six s mt thereafter.

1 4 .

6.5.2.6 Ouo 1

t A quorum of the Saf y Committee shall consis of the Chairman or Vice Chairman and at 1 east four memb s with a maximum of two iternates as votine members.

4 more than a alnority the voting members shal have line responsibility r operation of tlie facili

'6.5 6 Amendment No. 9'5

fjy c. A c r1 or C.)

. 1 DAtc.) l N w

{

4 6.5.2.7 Review -_

Th Safety Co mittee shall be responsib for the re iew of: '

a. The saf ety evaluations for (1) ch6r, r M procedures, and (1) cest; o expertoonts completed under the prov ton of Section 50.19, 10 C .. to verify that such actions diti no constitute en unreviewr*.

safety estion.

I

b. Pr790 sed the es to procedures, equipment or syst s which involve l

[ /) an unreviewed fety question as defined in Section .59, 10 CFh. -

\M k-' c. Proposed tests or eriments which involve an unreviewe afety question as defined 1 Section 50.5g 10 CFR.

N '

. d. Proposed changes in Techn al Specifications or licenses.

e. Violations of applicable stat tes, codes, regulations, orders, technical specifications, licen coquirements, or of internal rocedures or instructions having clear safety H gnificince. '
f. Sign icant operating abnonnalities or ev'istions from normal and expecte erformance of plant equipment at affect nuclear safety.
g. All Reportab Events'.
h. All recognized i ications of an unanticipated ficiency in some aspect of design or peration of safety related s ctures, systems, or components.

Amennment No. M 8. 157 6.5-7 APR 181999

. 5Acmc67,on c3 l t

?

CACC-1 .

Q Re p ft an fdatinyninuty'of thWperationyey l G,h:1.5 / Deletch t

i l'

i i

j.

I l

1 1

l l

i

~

l .  :

Amendment No. 05,000,213- 6.5-8 n

~

i t

4

- . , ., ,-,..w,, - - ,ym.>\, . , . . . , , -e , ,a.w,- , ne, e- , , ,,.w.... .-,--.~,,-,n

.,,m.,-<e+e-e-y, ,, g , ,..en+y, -- - - - , , ~,, -

Sari.1FI C NTu n y~, 3 DAEC-1 i

4

' l (3.5.2.9 Thority The 5 ty Connittee sha,W report to and adv e the President on those reas of responsi itity specified in Sp fication6.5.2.J.'

i 6.5.2.10 Records '

s of Safety Connitt activities shall.b6 prepared, approved, nd

/Re4 distributed as indi t'ed belews

a. Minutes each Safety Coen es meeting shall be pr red, approved, a p rwarded to the Pjotident within 14 days f owing each meeting.

Amendment No. 109,157,213 6.5-9

Src.sFKATon r. O DAEC-1

b. Reports of re (ews encompassed by Specifica (on 6.5.2.7 above',

shall be p pared, approve and forwarde to the Preside within 14 dava, allowine casol ion of the re iew.

c. lated /
y. .. oeisted

. ~.

Amendment No. M .213 6.5-10

. . . _ - . - - . - - - ~ . . - - . - --.

e oe

$p p c .' '] o' .~'t.' C. O

^

' DAtC-1

  • REPORT &tLE EVENT ACTim 4.6. ne follwing actions shall be take for REPORTA8LE EVENTS.

e

[. a. .to ,

REPORTABLE [ VENT shall be review, by the Operations Committee, and a port shall be submitted to the sa ty Comittee and the Vice President. Nuclear and

b. The Commission : 11 be. notified and a report subst ed pursuant to the requirements of tion 50.73 to 10 CFR Part 50.

8 ~w

  • h I

Amendment No. 105.136.198 6.6-1 1

l

$ @;". . G*\ C l's l W6 $~ 3 DAEC-1

'r

()LANTOPERAITNURAOCEDURS h Writtenproceduresjiny ving nucle safety, ludinfppplicablfchec ff ~ 3 lowmall beinrepa \

[11 K and fin ructio , covert areaslisja a (approv;d,ALsp,ecjdd_.Mu .ection 6.8,2Q1_1y(Icedures/all W[qmplemented) teTmmus 5)

()$V,/,o. .T.Atc:e r S-)and O'D V *"U maintainedycmcGE~r-c.

' reu swintg l 1. Nom 47 startup, operation, and., shutdown of ystems and c nonts of t f lity. /

/ 1

, 2/ Refueling operation.

3. ions to be t en to correct ecific and f essen potent 1 onents, inc ding respons to alams, malfunctions / systems or suspe_cted primary system enks, and abnormal reactivit hanges. _

{s,.),;, Q V Esofienc(and 'off-norpel con (nion ppciceducal.)

  1. ance operati which coul ave an '
5. P entive and corrective main ffect on th .uclear safet of the facil .

. Surve ance and te ng requirene of equi that could e an L of ct on the n ear safety o. hefacility.[pse 7 / De1 @

.. _~ . - .

. ./ c du Piro u n m i s Nt.t rico 'i n b pedick ti.7 ibn

~

Amendment No. M97- 214 6.8-1

SPIC.) F"W AT) Ors & ")

DAEC-1 m

el heattat af rammatWe Watti sysgp o

@ 10 Fire protection program implementation.6 anO T* preventive maintenance and periodic visual examination program to q

& Gr.S,7 ,teduce leakage from systems.outside containment that would or could (2nar d f,3- .contain highly radioactive fluids during a serious transient to as low as, l .

g ,yactical levels. This program shall also include provisions for performance of periodic systems leak tests of each system once per

@'U' KERATINS CYCLE. - '

@ p rts to ensure the cena ity to accur oly deterni the airbo 4 riodine c tration in tal areas u er accident itions, luding train of personn , procedures r monitorin nd provis s for

% enance of ling and an sis equionen . -

(427 man stive saures r sn m time f rat person (Irwet b aaatstant ith the C naian's Ju== 15. 82 colle stat- - -

& aurtin - e - =&---

cn. sr-- -

- a r____-  ; -Q mQ y o utycamammesfor nuo nu.3 efnu.nm--ggggy (1.8.2 Proc: ... ___;riosa i e.s.1 above, jnd changes thereto, shan De revi o t rations C tee as indica se in Specificatio 6.5.1.6 and app ad by 1 he Plant Super endent-Nuclear r designee prior implementatto except as provided i .8.3 belcw.

4 6.8.3 T rary minor changes o procedures descri in 6.8.1 abo which do not i ange the intent of a original proced may be made wb the concurre of $,

two members of t plant management s f, at least o of whom shall h d a j senior operato iconse. Such cha : shall be doc nted and prompt reviewed by e Operations Come tea and by the p ant Superintende -Nuclear or

/

j designee Subsequent into tion, if necess change, shall /

be in ccord with 6.8.2 a e. / y, as a permane Amendment No. ^^.:*0.!:C.;;;,l"J 6.8-2

!**, ??? .214

(fd e $ 5' "T

  • O O.0 6.10 RECOR03 RETElff!ON
  • 10.1 The following records shall be retain for at least 5 years:

/1. A ords and logs of f acility operation covering interval at each power ley .

~

/ 2. Recorets and ogs of principal maintenance activities, ins etions, and repair and replac of principal items of equipment related to uclear safety.

N Y.3 All Licensee Event Repo .

v4 Records of surveillance activi its, inspections and calibrati6ns required by these T' e chnical Specificat ns.

l

/ 5. ecords of reactor tests and experimen .

/ 6. Reco s of changes made to Operating Procco es.

/. 7 Records of adioactive shipments.

/8. Records of seal source leek test and results.

g. Records of annual phy ical, inventory verifying accountant 11ty sources on record.

6.10-1 Wndment No.105

+

[jec$ CbO" VA t

{

} DAEC-1  !

10. Records of adioactive effluent monitor setpoints a setpoint determinations 6.10,2 The following records s 11 be retained for the duration of th

! Facility Operating License.

/ 1. Record and drawing changes refle ing fact 11ty design modifications made to systems and equipment descr d in the Final Safety Analysis Report.

19

/t. Records of new and irradiated fuel inventory, uel transfers and assembly burnup histories.

/3. ecords of fact 11ty radiation and contamination survey

/4. Reco of radiation exposure for all individuals for whom monitori was required.

/5. Records of gase s and liquid radioactive material released to the \

environment.

/6. Records of transient or erational cycles for those factitty  :

components designed for a 1 ted number of transients or cycles.

Amendment No. 299,194 6.10-2

. ~ .

,% h s.{.. Q r*.'<i',L'i.,q. .

.v. .

...--.  ; .. .. Baso-1 - 't' .-

( ...,.

, , 3 f J C o 7 a >*n. ' * * > J,

.. ..p.s ,

7 nacerds of training and qualifientime f y earrest sembers of plast staff.

8. Seeerds of in-servise inspections perform \ed puremaet to these Tee sal l poeifications.
g. res of Quality Assuramas activities regu by the On Manual with ese Lee of the records instuded la sostian 10.1.
10. Record of reviewe perfarmed ier ebanges made to sedures er equipment reviewe tests and esperiments pursuant to 10 80.59.
11. Reeerds of ings of the operations committee and safety committee.
12. Records of thewervise lives of all safety-related b) u11e and mechanical snubbere includ the date at which the servise 1 Lie ses and asseeisted installaties and latenance records.
13. Records of reemits aPamalyses required by the radielegical environmental senitoring program.
4. Records of reviews performed for changes made to the offsite D e Assessment Manual and the Prosess cent i Program.

f R 14 8

R.endment me. 199.773.728.733. 184 ,

,s.10-3 N 2 21997 . _ -

1 g ehe,47 J r [D

. s f* - 1. T h!PORTINd Rh0U!RF):!NTi p *

- + r + , r - ,

i a --- e m :;me:; +..: . 2 .. .i w.:. : ,

a4eer) i i d " IZel ;-. ^ li -, pe following 6 deme 666sd roperts

% 10 CFK 1* shal4 be subadtted'n O ;;._2.. et 1: ...-'---*--8--'

-'"in d "x ;r  ; i -- f " *n _ -- - * -- :r :rir: -- J *

.31.1 ._ heuttne - N ...

a. StartvoAssort. A summary report of plant sta and power essait an testing shall be subattted follow ' (1)

N receipt of an operating license. (2) amendment to the license involving a aned inorosse in power level. (3)

  • installation of fuel the has a different design or has been meaufactured by a dif ent fuel supplier, and (4)

R Ii nodifications that may have si ifiesntly altered the nucleer thernel, or hydraulic p ce of the plant. I The report shall address each of the tests identified in the PSAR sad shall in generst include description of the measured values of the operating conditi er character.

i les obtained during the test program and comparison of thes values with design predictions and spec ! cations.

Any to etive actions that, were required to obt in

. satisfact operation shall also be described. l seditional s ific details required in license cond ions based on other c itsents shall be included in this report 6.11 1 pay i

e Y

f,9s.'$lCa.w E. ;)

artupreportsshallbesubmittedw} (1) e0 days following completion of the startup test program, ) 90 days following sumption or commencement of commercial po r operation, or (3) months following initial criticality, wh hover is earliest.

! l R, g -

8' th' 'rt'P "*'rt d*** a't cav'r *11 thr" ' (i'-

initial er cality, completion of startup test progra and resumption or c ncement of cossnercial power operation),

supplementary repor sh'all be submitted at least every three nths

_ untti all three events ve been completed.

Occu Rs):d. onpati and A..... ! freonure Reng.t1 A tabulation on an annual basis of the I

number of station, utility and j other personnel (including i

contractors) receiving exposures p ar- th r'100 mren/yr and their

, associatedmanremexposureaccordingtoworkandjobfunctions9

~. ;

(e.g., reactor operations and surveillance, inservice inspection,

~

routine maintenance, special maintenance (describe maintenance M f waste processing, and refuelinghhkt:hhth-'Tiiall be submitted Y.httF' 50 t;: of 3r;_., each year hedoseassignmensto gTnanA ous duty functions may be estimate based'onf pocket dosimeter, A TLh or film badge measurements. Small exposures totaling 4+ : thr$

20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external sources be assigned to specific major work functions. _

brk, d B . m a ,;r-) *^

\de/ m 4T4e f T,his, tabulation supplements the requirements M ;;;.(20.2206 ] of 10 Cg Amendment No. MN.lgt, 6.11-2

,,v., . . , . . , . .m_ _ . _ . . . , ,, _m

l 7s r I 4

DISCUSSION OF CilANGES

ITS 5.0
ADMINISTRATIVE CONTROLS TECHNICAL CHANGFR - RF1 OCATIONS (continued) i
Ry CTS 6.3.4 requires either the Plant Superintendent Nuclear (i.e., the plant manager) or one of his designated principal alternates to have the experience and training nonnally required for a SRO license examination. Details of the operator

-- license requirements for these specific positions are relocated to the UFSAR and plant procedures. The guidance documents which dictate the requirements are also identified in the UFSAR. The requirements that the Operations Manager or Operations Supervisor hold an SRO license has been maintained in ITS 5.2.2.f.

The people filling these positions directly control the operations of te plant; not i the Plant Superintendent Nuclear. Additionally, changes to the procedures and the UFSAR are controlled in accordance with l_0 CFR 50.59. This change will ensure that required qualifications are maintained for the Plant Superintendent.

Nudear and his designated principle alternate and, therefore, is acceptable. This change is consistent with the NUREG.  ;

R. DAEC proposes the requirements on training (CTS 6.4.1) be relocated from Technical Specifications on the basis that they are adequately addressed by other Section 5.0 administrative controls as well as regulations. ITS 5.3, Unit Staff Qualifications, provides r dequate requirements to assure an acceptable, competent operating staff. Each member of the unit staff shall meet or exceed the minimum qualifications of specific Regulatory Guides or ANSI Standards acceptable to the NRC staff. ITS 5.3 describes the details of the required qualifications. .

Additionally, ITS 5.2, Organization, details unit staff requirements. ITS 5.2.2.a ,

and ITS 5.2.2.b, and 10 CFR 50.54 describe the minimum shift crew composition and delineate which positions require an RO or SRO license. Training and requalification of those positions are as specified in 10 CFR 55.

Based upon these considerations, duplicating the provisions relating to training is not necessary to assure operation of the facility in a safe manner and may be relocated to a licensee controlled document which will be evaluated in accordance with the DAEC 10 CFR 50.59 program.

R, DAEC proposes that the review and audit functions (CTS 6.5) and Reportable Event review (CTS 6.6.1.a) requirements, be relocated from the ITS to the Quality Assurance Program on the basis that they can be adequately addressed elsewhere and that there is adequate regulatory authority to do so, Thus, the provisions are not necessary to assure safe operation of the facility, given the existence of these DAEC 12 Revision A

_ _ . . . _ _ _ _ _ _ . _ . _ _ _ _ . _ _ . . . _ _ _ _ __u_ -

DISCUSSION OF CilANGES ITS 5.0: ADMINISTRATIVE CONTROLS O TECilNICAL CllANGES - RFI OCATIONSs continued)

R, (continued) l redundant requirements. This proposal would rely on a Quality Assurance Program implementing 10 CFR 50.54 and 10 CFR 50, Appendix B, to control the I requirements. Such an approach would result in an equivalent level of regulatory authority while providing for a more appropriate change control process. The level of safety of facility operation is unaffected by the change and NRC and DAEC esources associated with processing license amendments for these Administrative Control requirements will be optimized. The following points summarize DAEC's position on removing these requirements from Technical Specifications.

Thel. Operations Committee r' eview function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority, and records are all covered in equivalent detail in ANSI N18.7-1972E These requirements are also propos:d to be covered in the QA Program. Equivalent change control is provided by 10 CFR 50.54(a).

Thel Safety Committee is also addressed, although with less detail, in ANSI N18.71972. The QA Program will include the requirements for the offsite review group. Since the offsite resiew group provides after the fact recommendations to improve activities, this organization is not necessary to assure safe operation of the facility. Based upon these considerations, duplication of these requirements in the TSs is unnecessary.

Relocating! Reportable E ent review requirements to the QA Program will ensure these requirements are appropriately maintained. Given that these reviews and submittal of results are required following the event without a specified Completion Time, the proposed relocated requirements are not necessary to assure

' operation of the facility in a safe manner. The change control process of 10 CFR 50.54(a) will provide eqitivalent change control.

DAEC 13 Revision A

_A

., a

  • DISCUSSION OF CHANGES ITS 5.0: ADMINISTRATlVE CONTROLS

, TECHNICAL CHANGFE - RP1 OCATIONS (continued)

Re- - (continued) principal operative standard in Section 182a. of the Atomic Energy Act;'.' health and safety of the public" does not apply. Based on these considerations, the lodine Monitoring Program administrative control is not necessary to assure operation of the facility in a safe manner and can be relocated from Technical Specifications to the UFSnR or other plant procedures.

R, DAEC proposes to relocate and address the review and approval process (CTS 6.8.2) and the temporary change process (CTS 6.8.3) for procedures as part of the QA Program, UFSAR, or appropriate procedures. This proposal is based on the existence of the following requirements which are 6uplicative of 10 CFR 50.36 in these areas and which assure operation of the facility in a safe manner. The

, requirement for procedures is mandated by 10 CFR 50 Appendix B, Criterion 11 (second sentence) and Criterion V. ANSI N18.719? ?which is an NRC staff.

endorsed document used in the development of the Qn Program, also contains specific requirements related to procedures.

ANSI N18.7197M Section 5.2.2 discusses procedure adherence. This section clearly states that procedures shall be followed, and the requirements for use of procedures shall be phscribed in writing. ANSI N18.7 197(also discusses temporary changes to procedures, and requires review and approval of procedures to be defined.

ANSI N18.7 197[ Section 5.2.15 describes the review, approval and control of procedures. The section describes the requirements for the licensee's Quality Assurance Program to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality. The section further states that each yocedure shall be reviewed and approved prior to initial use. The reviews required are also described.

~ - - ~. L ANSI N45.2 1971. Section 6 also requires the Quality Assurance Program "

to describe procedure requirements. _ _

DAEC- 15 Revision A

DISCUSSION OF CllANGES ITS 5.0: ADMINISTRATIVE CONTROLS

. TRCHNICAI CHANGFR . RRI OCATIONS (continued)

R, (continued)

DAEC will continue to implement the requirements of 10 CFR 50, Appendix II, regarding procedures without duplicating the necessity of procedure requirements in the facility Technical Specifications _ Safe operation of the plant will continue to be maintained, and therefore, the requirements for procedures and their control should not be re addressed in Technical Specifications. Duplication of the pmvisions related to procedures is not necessary to assure safe o wration of the facility. The QA Program, UFSAR or appropriate procedures ginclude adequate _ detail with respect to the administrative control of procedures related to '

activities affecting quality and nuclear safety QA Program changes will be in accordance with 10 CFR 50.54(a), with UFSAR and procedure changes being evaluated in accordance with the DAEC 10 CFR 50.59 program.

l

, Roi CTS 6.8.5 contains details that are being relocated to plant controlled documents, e

which currently implement the preventative and corrective maintenance program (CTS 6.8.1.11). CTS 6.8.1.11 contains program controls that are being placed in ITS 5.5.2 which is a program for Primary Coolant Sources Outside Containment.

The details in CTS 6.8.5 involve a once per operating cycle detailed walkdown -

inspection requirement and an additional quarterly walk down inspection. The program controls will continue to be maintained in ITS 5.5.2 and are sufficient to ensure the leakage is monitored. Changes to relocated requirements will be evaluated in accordance with the DAEC 10 CFR 50.59 pr., gram.

4 Rn CTS 6.9.2, "High Radiation Area," contains """ and ""*" footnotes that specify measurement distances from a source of radioactivity used to determine personnel dose rates, This type of detail is not retained in the ITS and can be relocated to plant controlled documents where changes to these requirements will be evaluated in accordance with the DAEC 10 CFR 50.59 program.

DAEC- 16 Revision A

4 DISCUSSION OF CilANGES ITS 5.0: ADhilNISTRATIVE CONTROLS TECIINICAL CllANGES Iml OCATIONS (continued)

Rn The details contained in CTS 6.9.4.b," Radiological Environmental Monitoring Program," are proposed to be relocated to the Offsite Dose Assessment Manual (ODAM). The program is a redundant verification of the effectiveness of the effluent monitoring program contained in the ODAM and specified in the administrative controls section of the ITS. The relocated program has no impact or effect on nuclear safety of the plant. ITS 5.5.1 for the ODAM requires the ODAM to contain these activities Changes to the ODAM will be controlled in accordance with ITS 5.5.1.c.

Rn CTS 6/7.9.5 does not identify a parameter which is an initial condition assumption for a DBA or transient, identify a significant abnormal degradation of the reactor coolant pressure boundary and does not provide any mitigation of a design basis event. Therefore, CTS 6/7.9.5 did not satisfy the screening criteria of 10 CFR 50.36 as documented in the Application of Selection Criteria to DAEC Technical Specifications, and has been relocated to plant procedures. Any changes to these requirements located in plant procedures will be evaluated in accordance with the DAEC 10 CFR 50.59 program.

Rn DAEC proposes the requirements on record retention (CTS 6.10) be relocated from Technical Specifications on the basis that they yan be adequately addressed by the QA Progra'.. (10 CFR 50, AppendL B, Criterion XVII) and other sections of 10 CFR 50 that are applicable to DAEC (i.e.,10 CFR 50.71,10 CFR 50.73, etc.) and because provisions relating to record keeping, in the CTS, do not assure operation of the facility in a safe manner.

Facility operations are performed in accordance with approved written procedures. Areas include normal startup, operation and shutdown, abnonnal conditions and emergencies, refueling, safety related maintenance, surveillance and testing, and radiation control. Facility records document appropriate station operations and activities. Retention of these records provides document retrievability for review of compliance with requirements and regulations. Post-compliance review of records does not assure operation of the facility in a safe manner as activities described in these documents have already been performed.

Numerous other regulations such as 10 CFR 20, Subpart L, and 10 CFR 50.71 also require the retention of certain records related to operation of the nuclear plant.

DAEC 17 Revision A

l DISCUSSION OF CllANGES ITS 5.0: ADMINISTRATIVE CONTROLS TECIINICAL CIIANGES - RFI OCATIONS (continued)

Rn The requirement to submit a Startup Report (CTS 6.11.1.a) has been relocated l from the CTS. The report is a summary of plant stanup and pcwer escalation testing following receipt of the Operating License, increases in licensed power level, installation of nuclear fuel with a different design or manufacturer than the current fuel, and modifications that may have significantly altcud the nuclear, thermal, er hydraulle performance of the unit. The repon provided a mechanism for NRC to review the appropriateness oflicensee activities after the fact, but '

provided no regulatory authority once the report was submitted (i.e., no requirement for Commission approval). The approved 10 CFR 50, Appendix D, Quality Assurance Program and Startup Test Program provide assurance that the listed activities are adequately performed and that appropriate corrective actions, if required, are taken. >

Given that the report was required to be provided to the Commission no sooner than 90 days or 9 months following completion of the respective milestone, report completion and submittal was clearly not necessary to assure operation of Ge facility in a safe manner for the interval between completion of the startup testing and submittal of the report. Additionally, given there is no requirement for the Commission to approve the report, then the Startup Report is not necessary to assure operation of the facility in a safe manner.

Based on these eonsiderations, the Startup Report may be removed from the Technical Specifications and relocated to a licensee controlled document. Where changes are evaluated in accordance with the DAEC 10 CFR 50.59 program.

Ra This change proposes to relocate the notification and reporting requirements (CTS 6.6.1.b) for Reportable Event Action out of TS. These requirements are duplicated in 10 CFR 50.73. These requirements will be relocated to plant procedures or other licensee controlled documents. Given that these notifications and reports are required following the event, notification and report submittal is clearly not necessary to assure operation of the facility in a safe manner.

Additionally, given there is no requirement for the Commission to approve the notification or reports, these requirements are not necessary to ensure operation of the facility in a safe manner. Changes to the relocated requirements in plant

' procedurer will be evaluated in accordance with the 10 CFR 50.59 program. This change is consistent with the NUREG.

DAEC 18 Revision A

Retrieved from "https://kanterella.com/w/index.php?title=ML20211H397&oldid=3250117"