ML20213E479
| ML20213E479 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/25/1983 |
| From: | Booher H Office of Nuclear Reactor Regulation |
| To: | Thomas C Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0605, CON-WNP-605 NUDOCS 8308080055 | |
| Download: ML20213E479 (17) | |
Text
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JUL 2 51983 MEMORANDUM FOR: Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing FROM:
Harold R. Booher, Chief Licensee Qualifications Branch Division of Human Factors Safety
SUBJECT:
REVIEW 0F PROOF AtlD REVIEW COPY OF WASHIfir; TON flUCLEAR-UtlIT 2 TECHNICAL SPECIFICATIONS We have reviewed the Proof and Review Cooy of Washington Nuclear-Unit 2 Technical Specifications in our area of responsibility as you reouested in your memorandum of July 1.1983.
Our area of responsibility by Technical Specification Section flumber is 6.1, 6.2, 6.3, 6.4, 6.5, 6.8.1, 6.8.2, and 6.8.3.
Our corrents are enclosed and noted on the marked-un copy of the cited section also enclosed.
This review was performed by Frederick R. A11enspach, extension 24904.
Original Signed by Harold R. Bocher, Chief Licensee Qualifications Branch Division of Human Factors Safety
Enclosures:
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WASHINGTON NUCLEAR-UNIT 2 Comments on Proof & Review Cocy of Technical Specifications We have reviewed subsections 6.1 through 6.5 and 6.8.1 through 6.8.3 of the Proof and Review Copy of the above noted Technical Specifica-tions and have the following comments:
1.
Figure 6.2.1-1 does not represent the current offsite organi-zational structure.
This figure needs extensive revision to reflect the current WPPSS oraanization.
2.
Figure 6.2.2-la, Unit Organization, should show at least one more level of organization under the Technical Suoerintendent, the HP/ Chemistry Manager, and the Maintenance Superintendent.
3.
Section 6.5.1.2 - The titles of some of the members of the l
Plant Organization Committee do not correspond to the titles of the plant staff shown in Figure 6.6.2-la.
4.
Section 6.5.2.2 - The composition of the Company Nuclear Safety Review Board (CNSRB) includes three members to be " appointed by the Managing Director."
In instances where the members are not designated by title, there needs to be included a statement of the minimum qualification requirements for these positions.
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6.0 ADMINISTRATIVE CONTROLS J-i 6.1 RESPONSIBILITY 6.1.1 The Plant Manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
6.1. 2 The Shift Manager (or during his absence from the control room, a designated individual) shall be responsible for the control room command func-tion. A management directive to this effect, signed by the Director of Power Generation shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION OFFSITE 6.2.1 The offsite organization for unit management and technical support shall be as shown on Figure 6.2.1-1.
UNIT STAFF 6.2.2 The unit organization shall be as shown on Figures 6.2.2-la and 6.2.2-lb, and:
Each on duty shift shall be composed of at least the minimum shift a.
crew composition shown in Table 6.2.2-1; b.
At least one licensed Operator shall be in the control room when fuel is in the reactor.
In addition, while the unit is in OPERATIONAL CONDITION 1, 2, or 3, at least one licensed Senior Operator shall be in the control room.
(
c.
A Health Physics Technician
- shall be on site when fuel is in the reactor; d.
All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation; e.
A site fire brigade of at least five members shall be maintained on site at all times".
The fire brigade shall not include the Shift Supervisor, the Shift Technical Advisor, nor the three other members of the minimun shift crew necessary for safe shutdown of the unit and any personnel trequired for other essential functions during a fire j
emergency; and.
"The Health Physics Technician and fire brigade composition may be.less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.
l WASHINGTON NUCLEAR - UNIT 2 6-1 v
PROC:& my copy ADMINISTRATIVE CONTROLS UNIT STAFF (continued) f.
Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions e.g., licensed Senior Operators, licensed Operators, health physi-cists, auxiliary operators, and key raintenance personnel.
Adequate shift coverage shall be caintained without routine heavy use of overtir:a.
The objective shall be to have operating parsonnel work a normal 8-hour diy, 40-hour week while the unit is operating.
However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shut-down for refueling, major maintenance, or major unit modifications, on a temporary basis the following guidelines shall be followed:
1.
An individual should not be permitted to work more t.'an 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-hour 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-hour 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 Except during extended shutdown periods, the use of overtime should be considerec on an individual basis and not for the entire staff on a shift.
Any deviation from the above guidelines shall be authorized by the Plant Manager or his deputy, or higher levels of management, in accordance with established procedures and with documentation of the
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basis for granting the deviation.
Controls snal; be included in the l
procedures such that individual overtime shall be reviewed monthly by the Plant Manager or his designee to assure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized.
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WASHINGTCN NUCLEAR - UNIT 2 6-5 I
PR00F & RNEW CO?Y TABLE 6.2.2-1 MINIMUM SHIFT CREW COMPOSITION POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION CONDITION 1, 2, or 3 CONDITION 4 or 5 SM 1
1 CRS 1
Ne-9 R0 2
1 E0 2
1 STA 1
None TABLE NOTATION SM - Shift Manager with a Senior Operator license on WNP - Unit 2.
CRS - Individual with a Senior Operator license on WNP - Unit 2.
R0 - Individual with a Operator license on WNP - Unit 2.
EO - Equipment Operator STA - Shift Technical Advisor Except for the Shift Manager, the shift crew composition may be one less than the minimum requirements of Table 6.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements of Table 6.2.2-1.
This provision does not permit any shift crew position to be unmanned upon shift change due to an oncomiag shift crewman being late or absent.
l During any absence of the Shift Manager from the control room while the l
unit is in OPERATIONAL CONDITION 1, 2 or 3, an individual (other than the Shift Technical Advisor) with a valid Senior Operator license shall be designated to assume the control room command function. During any absence l
of the Shift Manager from the control room while the unit is in OPERATIONAL CONDITION 4 or 5, an individual with a valid Senior Operator license or Operator license shall be designated to assume the control room command function.
l WASHINGTON NUCLEAR - UNIT 2 6-6 l
hf ADMINISTRATIVE CONTROLS 6.2.3 SAFETY ENGINEERING GROUP (SEG)
FUNCTION 6.2.3.1 The SEG shall function to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit. design and operating experience information, including units of similar design, which may indicate areas for improving unit safety. The SEG shall make detailed recommendations for revised procedures, equipment and modifications, maintenance activities, operations activities, or other means of improving unit safety to the Director of Safety and Security.
COMPOSITION 6.2.3.2 The SEG shall be composed of at least five, dedicated, full-time engineers, a minimum of three located on site and two at the home office.
Eacn shall have a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field, at least 1 year of which experience shall be in the nuclear field.
RESPONSIBILITIES 6.2.3.3 The SEG shall be responsible for maintaining surveillance of unit activities to provide independent verification
- that these activities are performed correctly and that human errors are reduced as much as practical.
RECOROS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, main-tained, and forwarced each calendar month to the Operational Assurance Programs Manager.
6.2.4 SHIFT TECHNICAt. ADVISOR 6.2.4.1 The Shift Technical Advisor s' hall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.
The Shift Technical Advisor shall have a bachelor's degree or equivalent in a scientific or engineering discipline and shall have received specific training in the response and analysis of the unit for transients and accidents, and in unit design and layout, including the capabilities ofStnstrumentation and controls J
in the control room.
6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI /ANS 3.1-1978 for comparable positions, except for the Health Physics / Chemistry Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifications of the supple-mental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.
=Not responsible for sign-off function.
WASHINGTON NUCLEAR - UNIT 2 6-7
ADMINISTRATIVE CONTR01.5 6.4 TRAINING 6.4.l' A retraining and replacement training program for the unit staff shall be maintained under the direction of the Training Manager, shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI /ANS 3.1-1978 and Appendix A of 10 CFR Part 55 and the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry operational experience.
6.5 REVIEW AND AUDIT
- 6. 5.1 PLANT OPERATIONS COMMITTEE (POC)
FUNCTION 6.5.1.1 The POC shall function to advise the Plant Manager on all matters related to nuclear safety.
COMPOSITION
- 6. 5.1. 2 The POC shall be composed of the:
Chairman:
Plant Manager
..,,... b Vice Chairman:
Assistant Plant Manager e-e Member:
Operations Manager 4
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Member:
Technical Manager
,0 Member:
Maintenance Manager Member:
Administrative Manager (Non-voting member)
Member:
Plant QA/QC Manager Member:
Health Physics / Chemistry Manager ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing.by the POC Chai.rman or Vice Chairman to serve on a temporary basis.
MEETING FREQUENCY 6.5.1.4 The Plant Operations Committee shall meet at least once per calendar month and as convened by the POC Chairman or his designated alternate.
QUORUM 6.5.1.5 The quorum of the POC necessary for the performance of the POC responsibility and authority provisions of these Technical Spe:ifications shall consist of the Chairman or Vi.e Chairman and four members including alternates.
No more than two alter m tes shall make up the q wrum.
WASHINGTON NUCLEAR - UNIT 2 6-8
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PROD:& RNIBV CO?Y ADMINISTRATIVE CONTROLS RESPONSIBILITIES 6.5.1.6 The POC shall be responsible for:
Review of (1) all proposed procedures required by Specification 6.8 a.
and changes thereto, (2) all proposed programs required by Specifica-tion 6.8 and changes thereto, and (3) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety; b.
Review of all proposed tests and experiments that affect nuclear safety; c.
Review of all proposed changes to the Appendix A Technical Specifications; d.
Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety; Investigation of all violations of the Technical Specifications, e.
including the preparation and forwarding of reports covering evalua-tion and recommendations to prevent recurrence, to the Director of Power Generation and to the Corporate Nuclear Safety Review Board; f.
Review of events requiring 24-hour written notification to the Commission;
- g.
Review of unit operations to detect potential hazards to nuclear safety; h.
Performance of special reviews, investigations, or analyses and reports thereon as requested by the Plant Manager or the Corporate Nuclear Safety Review Board; i.
Review of the Security Plan and implementing procedures and submittal of recommended changes to the Corporate Nuclear Safety Review Board; and J.
Review of the Emergency Plan and implementing procedures and submittal of recommended changes to the Corporate Nuclear Safety Review Board.
k.
Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the fomarding of these reports to the Director of Power Generation and to the Corporate Nuclear Safety Review Board.
1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.
AUTHORITY
- 6. 5.1. 7 The POC shall:
Recommend in writing to the Plant Manager approval or disapproval of a.
items considered under Specification 6.5.1.6a. through d. prior to their implementation.
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ADMINISTRATI'/E CONTROLS AUTHORITY (Continued) b.
Rerder ceterminaticns in writing with regard to whether or not each item considered under Specification 6.5.1.5a. through e. constitutes an unreviewed safety question.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Director of Power c.
Generation and the Corporate Nuclear Safety Review Board of disagree-ment between the POC and the Plant Manager; however, the Plant Manager shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.
RECORDS 6.5.1.8 The POC shall maintain written minutes of each POC meeting that, at a minimum, document the rasults of all POC activities performed under the responsi-bility provisions of these Technical Specifications.
Capies shall be previoed to the Director of Power Generation and the Corporate Nuclear Safety Review Board.
6.5.2 CORPORATE NUCLEAR SAFETY REVIEW BOARD (CNSRB)
FUNCTION 6.5.2.1 The CNSR8 shall function to provide independent review and audit of designated activities in the areas of:
a.
Nuclear power plant operations, b.
Nuclear engineering, c.
Chemistry and radicchemistry, d.
Metallurgy, e.
Instrumentation and control, f.
Radiological safety, I
g.
Mechanical and electrical engineering, and h.
Quality assurance practices.
The CNSRB shall report to and advise the Managing Director on those areas of responsibility in Specifications 6.5.2.7 and 6.5.2.8.
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ADMINISTRATIVE CONTROLS h k,,,
k h,N COMPOSITION 6.5.2.2 The CNSRS shall be composed of the:
Chairman:
Nuclear Safety and Regulatory Programs Manager Alternate Chairman:
Director of Licensing and Assurance Member:
Director of Power Generation Member:
Director of Technology Member:
Project 1/4 Director / Plant Manager Member:
Project 2 Director / Plant Manager Member:
Project 3/5 Director / Plant Manager Executive Secretary:
Appointed by Managing Director
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Member at Large:
Appointed by Managing Director Member at Large:
Appointed by Managing Director j+>;eid-cr ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the CNSRB Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in CNSRB activities at any one time.
CONSULTANTS 6.5.2.4 Consultants shall. be utilized as determined by the CNSRS Committee to provide expert advice to the CNSRB.
MEETING FREQUENCY 6.5.2.5 The CNSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per 6 months thereafter.
QUORUM 6.5.2.6 The quorum of the CNSRB necessary for the performance of the CNSRB review and audit functions of these Technical Specifications shall consist of the Chairman or the alternate Chairman and at least four CNSRB memoers includ-ing alternates.
No more than a minority of the quorum shall have line respon-sibility for operation of the unit.
REVIEW 6.5.2.7 The CNSRB shall review:
The safety evaluations for (1) changes to procedures, equipment or a.
systems and (2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question; b.
Proposed changes to procedures, equipment, or systems which involve an unroviewed safety question as defined in 10 CFR 50.59; WASHINGTON NUCLEAR - UNIT 2 6-11 e,
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ADMINISTRATIVE CONTROLS REVIEW (Continued)
Proposed tests or experiments which involve an unreviewed safety ques-c.
tion as defined in 10 CFR 50.59; d.
Proposed changes to Technical Specifications or this Operating License; Violations of codes, regulations, orders, Technical Specifications, e.
license requirements, or of internal procedures or instructions having nuclear safety significance; f.
Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety; g.
Events requiring 24-hour written notification to the Commission; h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety; and i.
Reports and meeting minutes of the POC.
AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the CNSRB. These audits shall encompass:
a.
The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months; b.
The performance, training and qualifications of the entire unit staff at least once per 12 months; The results of actions taken to correct deficiencies occurring in c.
unit equipment, structures, systems, or method of operation that affect nuclear safety, at least once per 6 months; d.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, at least once per 24 months; The fire protection programmatic controls including the implementing e.
procedures at least once per 24 months by qualified licensee QA personnel; f.
The Emergency Plan and implementing procedures at least once per 12 months per 10 CFR 50.54(t).
g.
The Security Plan and implementing procedures at least once per 12 months.
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N ADMINISTRATIVE CONTROLS AUDITS (Continued) h.
The fire protection equipment and program imolementation, at least once per 12 months utilizing eicher a cualified offsite licensee fire protection engincar(s) or an catside independent fire protection consultant. An outside independent fire protection consultant shall be utilized at least once every third year; and i.
Any other area of unit operation considered appropriate by the CNSRB or the Managing Director.
j.
The radiological. environmental monitoring program and the results thereof at least once per 12 months.
k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
1.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
The performance of activities required by the Quality Assurance m.
Program for effluent and environmental monitoring at least once per 12 months.
RECOROS 6.5.2.9 Records of CNSRB activities shall be prepared, approved, and distri-buted as indicated below:
Minutes of each CNSRB meeting shall be prepared, approved, and a.
forwarded to the Managing Director 14 days following each meeting.
b.
Reports of reviews encompassed by Specification 6.5.2.7 above, shall be prepared, approved, and forwarded to the Managing Director within 14 days following completion of the review.
Audit reports encompassed by Specification 6.5.2.8 shall be forwarded c.
to the Managing Director and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.
- 6. 6 REPORTABLE OCCURRENCE ACTION
. 6. s.1 The following actions shall be taken for REPORTABLE OCCURRENCES:
The Commission shall be notified and a report submitted pursuant a.
to the requirements of Specification 6.9, and b.
Each REPORTABLE OCCURRENCE requiring 24-hour notificaticn to the Corrsission shall be reviewed by the POC, and the results of this review shall be submitted to the CNSRB and the Director of Power Generation.
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- 6. 7 SAFETY LIMIT VIOLATION 6.7.1 The following actions snall be taken in the event a Safety Limit is violated:
The NRC Operations Center shall be notified by telephone as soon as a.
possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The Director of Power Generation and the CNSRB shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
b.
A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the POC.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit components, systems, or structures, and (3) corrective action taken to prevent recurrence.
The Safety Limit Violation Report shall be submitted to the Commission, c.-
the CNSRB, and the Director of Power Generation within 14 days of the violation.
d.
Critical operation of the unit shall not be resumed until authorized by the Commission.
6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Aapendix A of Regulatory a.
Guide 1.33, Revision 2, February 1978.
b.
The applicable procedures required to implement the requirements of NUREG-0737.
c.
Refueling operations.
d.
Surveillance and test activities of safety-related equipment, e.
Security Plan implementation.
f.
Emergency Plan implementation.
g.
Fire Protection Program implementation.
h.
PROCESS CONTROL PROGRAM implementation.
i.
OFFSITE DOSE CALCULATION MANUAL implementation.
J.
Quality Assurance Program for effluent and environmental monitoring.
6.8.2 Each procedure of Specification 6.8.1, and changes thereto, shall be reviewed by the POC and shall be approved by the Plant Manager prior to imple-j mentation and reviewed periodically as set forth in administrative procedures.
6.8.3 Temporary changes to procedures of Specification 6.8.1 may be made provided:
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PR005 & Els/ cgpy ADMINISTRATIVE CONTROLS 3
i PROCEDURES AND PROGRAMS (Continued)
The intent of the original procedure is not alteredt a.
b.
The change is approved by two members of the unit management staff, at least one of whom holds a Senior Operator license on the unit affected; and The change is documented, reviewea by the POC, and approved by the c.
Plant Manager within 14 days of implementation.
6.8.4 The following programs shall be established, implemented, and maintained:
a.
Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels.
The systems include the LPCS, HPCS, RHR, RCIC, hydrogen recombiner, process sampling, containment, and the standby gas treatment systems.
The program shall include the following:
1.
Preventive maintenance and periodic visual inspection requirements, and 2.
Integrated leak test requirements for each system at refueling cycle intervals or less.
b.
In-Plant Radiation Monitorina A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:
1.
Training of personnel, 2.
Procedures for monitoring, and 3.
Provisions for maintenance of sampling and analysis equipment.
c.
Post-accident Samoling A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous efflu-ents, and containment atmosphere samples under accident conditions.
The program shall include the following:
1.
Training of personnel, 2.
Procedures for sampling and analysis, and 3.
Provisions for maintenance of sampling and analysis equipment.
1 WASHINGTON NUCLEAR - UNIT 2 6-15
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