ML20215H164

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Proposed Tech Specs Re Administrative Controls
ML20215H164
Person / Time
Site: Waterford Entergy icon.png
Issue date: 10/15/1986
From:
LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20215H153 List:
References
NUDOCS 8610210490
Download: ML20215H164 (31)
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Text

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-51 This is a request to revise Section 6 (Administrative Controls) of the Technical Specifications.

Existing Specifications See Attachment A Proposed Specifications See Attachment B Description The Administrative Controls Section of the Technical Specifications describes, in part, the on-site and off-site organizations for operation of Waterford 3.

The proposed changes will delete the organization charts in Figures 6.2-1 and 6.2-2 while revising specific titles to their functional equivalents.

The Nuclear Operations organization within LP&L is presently anticipating an organizational restructuring to increase the efficiency of operation.

Having nearly a full cycle of experience with an operating nuclear plant, the reorganization will complete the transition from construction to full plant operation.

In order.to reduce the burden on the NRC and LP&L in processing future Technical Specification changes due to LP&L organization changes, LP&L proposes to amend the Administrative Controls section of the Technical Specifications to reflect functional responsibilities rather than rigid organizational titles.

The primary change in Attachment B is the deletion of the organization charts in Figures 6.2-1 and 6.2-2.

The majority of the remaining changes simply provide functional titles in place of organizational titles.

For instance, the Plant Operations Review Committee (PORC) Chairman is presently required to be the Assistant Plant Manager-Nuclear (Plant Technical Services or Operations and Maintenance). The proposed change will designate the PORC Chairman as " Senior management of plant technical services, operations or maintenance".

The proposed changes introduce no reduction in commitment, involving for the most part merely a change in title designation - i.e. the existing organizational functions will continue to be performed-in accordance with the Technical Specifications.

The only exception concerns the creation of the new position of Vice President-Nuclear which reports to the Senior Vice President-Nuclear Operations. Certain of the former Senior Vice President responsibilities have been redesignated to the Vice President.

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In addition to reducing the administrative bur' den on the NRC and LP&L in processing Technical Specification changes, deletion of the organization charts is consistent with the NRC's Technical Specification Improvement Program (TSIP). The TSIP has validated the idea (raised. in ALAB-531 and

.other reviews) that Technical Specifications should be reserved for those 3

matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the' possibility of an event i

giving rise to an immediate threat to the public health and safety. Clearly, the removal of a rigid organizational structure and personnel titles while preserving all commitments and responsibilities will.have no effect on the safety status of the plant.

Additionally, including organizational structure in the Technical Specifications is unnecessary due to other controls maintained by the NRC.

For instance,'the i

Waterford 3 organization (on-site and of f-site) is discussed in detail in the QA Program description in the FSAR. 10 CFR 50.54(a)(3) requires that any change to the QA Program description that reduces commitments must receive prior NRC approval before implementation. Conformanet with this regulation ensures that 4

the organizational structure is maintained at a. level consistent with NRC re-quirements, regardless of the content of the Technical Specifications.

In summary, the proposed change:

1.

Will not affect the safe operation of W terford 3 a

-2.

Will not reduce commitments or requirements in the Technical Specifications, 3.

Will substitute functional title descriptions for actual.

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organizational titles, and

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4.

Will reduce the administrative burden on the NRC and LP&L in the future.

Safety Analysis The proposed changes described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.. Will operation of the f acility in accordance with this proposed change involve a significant increase in the probability or con-sequences of any accident previously evaluated?

. Response: No The proposed changes have no effect on the assumptions con-tained in the safety analyses..The Technical Specifications which preserve the safety analysis assumptions are likewise unaffected by the proposed changes.

Therefore the proposed changes will not result in any increase in the probability or consequences of any accident previously analyzed.

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4.

s 2.

Will operation of the ' facility -in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

i Response: No The proposed changes are administrative in nature. No plant procedure changes or physical modifications result. Therefore the proposed changes will not create the possibility. of a new or different kind of accident.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No The Waterford 3 safety margins are defined and maintained by the Technical Specifications in Sections 2-5_ which are unaffected by -

the proposed changes. Therefore, the proposed changes will not involve any reduction in a safety margin.

Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that:

(1) the. proposed change does not constitute a significant hazards consideration as defined by

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10 CFR 50.92; and (2) there is a reasonable assurance that the health and 2

safety of the public will not be endangered by the proposed change; and.(3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final En-vironmental Statement.

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ADMINISTRATIVE CONTROLS p.

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6.1 RESPONSIBILITY 6.1.1 The Plant Manager-Nuclear 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 Supervisor, or during his absence from the control room, a designated individual shall be responsible for the control room command function.

A management directive to this effect, signed by the Vice President -

Nuclear Operations, 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 in Figure 6.2-1.

UNIT STAFF 6.2.2 The unit organization shall be as shown in Figure 6.2-2 and:

a.

Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; b.

At least one licensed Operator shall be in the control room when fuel is in the reactor.

In addition, while the reactor is in MODE 1, 2, 3, or 4, 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 or performed by a licensed Operator or. licensed Senior Operator and 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 two other members of the minimum shif t crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.

  • 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.

WATERFORD - UNIT 3 6-1

ADMINISTRATIVE CONTROLS 5

UNIT STAFF (Continued) f.

Administrative procedures shall be developed and implemented to limit the working hours of individuals of the nuclear power plant operating staff who are responsible for manipulating plant controls or for adjusting on-line systems and equipment affecting plant safety which would have an immediate impact on public health and safety.

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

The objective shall be to have operating personnel work a normal 8-hour day, 40-hour week while the plant is operating.

However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:

1.

An individual shall 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 shall 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 /> shall be allowed between work periods, including shift turnover time.

4.

Except during extended shutdown periods, the use of overtime shall be considered 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, the assistant Plant Managers, the Operations Suptrintendent - Nuclear or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime will be reviewed monthly by the Station Manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

WATERFORD - UNIT 3 6-2

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E WATERFORD. UNIT 3 6-4

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TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION MODE 1, 2, 3, OR 4 MODE 5 OR 6 SS 1

1 SR0 1

None R0 2

1 A0 2

1 STA 1

None SS Shift Supervisor with a Senior Operator License SR0 -

Individual with a Senior Operator License R0 Individual with an Operator License AO Auxiliary Operator-STA Shift Technical Advisor Except for the Shift Supervisor, the shift crew composition may be one less than the minimum requirements of Table 6.2-1 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 6.2-1.

This provision dces not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent.

During any absence of the Shift Supervisor from the control room while the unit is in MODE 1, 2, 3 or 4, 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 of the Shift Supervisor from the control room while the unit is in MODE 5 or 6, an individual with a valid Senior Operator or Operator license shall be designated to assume the control room command function.

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WATERFORD - UNIT 3 6-5

1 ADMINISTRATIVE CONTROLS k'

6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) 4 FUNCTION 6.2.3.1 The ISEG 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 ISEG shall make detailed recommendations for revised procedures, equipment modifica-i tions, maintenance activities, operations activities, or other means of improving unit safety to the Engineering and Nuclear Safety Manager.

COMPOSITION j

6.2.3.2 The ISEG shall be composed of at least five, dedicated, full-time engineers located on site.

Each shall have a bachelor's degree in t

engineering or related science and at least 2 years professional level 9xperience in his field, at least 1 year of which experience shall be in the nuclear field.

RESPONSIBILITIES 6.2.3.3 The ISEG'shal1 be responsible for maintaining surveillance of unit i

activities to provide independent verification

  • that these activities l

are performed correctly and that human. errors are reduced as much as practical.

AUTHORITY 6.2.3.4 The ISEG.is an onsite independent technical review group that reports to the-Engineering and Nuclear Safety Manager.

The ISEG shall have the authority necessary to perform the functions and responsibilities as delineated above.

RECORDS 6.2.3.5 Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to the Engineering and Nuclear Safety Manager.

6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering, l

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 of instrumentation and controls in the control room.

1

  • Not responsible for sign-off function.

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. ATERf0R0 - UNIT 3 6-6 W

ADMINISTRATIVE CONTROLS IN 6.3 UNIT STAFF QUALIFICATI0a5 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 except that; a.

The Radiation Protection Superintendent shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, September 1975.

b.

Personnel in the Health Physics, Chemistry and Radwaste Departments shall meet or exceed the minimum qualifications of ANSI N18.1-1971.

c.

The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifications of the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.

d.

Personnel in the Plant Quality Department, and other staff personnel who peform inspection, examination, and testing functions, shall meet or exceed the minimum qualifications of Regulatory Guide 1.58, Rev.1, September 1980.

(Endorses ANSI N45.2.6-1978) 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit aff shall i

be maintained under the direction of the Training Manager-Nuclear nd shall meet or exceed the requirements and recommendations of Section

.2 of ANSI 3.1-1978 and Appendix A of 10 CFR Part 55 and the supplem I require-ments 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 REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager-Nuclear on all matters related to nuclear safety.

COMPOSITION i

6.5.1.2 The PORC shall be composed of the:

Chairman:

Assistant Plant Manager-Nuclear (Plant Technical Services or Operations and Maintenance)

Vice Chairman:

Technical Support Superintendent-Nuclear Member:

Maintenance Superintendent-Nuclear Member:

Operations Superintendent-Nuclear Member:

Radiation Protection Superintendent-Nuclear Member:

Quality Control Manager-Nuclear NATERFORD - UNIT 3 6-7 l

ADMINISTRATIVE CONTROLS s

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ALTERNATES 6.5.1.3 The PORC is chaired by one of the Assistant Plant Managers and, in their absence, the Technical Support Superintendent acts as Chairman.

If all three are absent, the Plant Manager-Nuclear will appoint a temporary Chairman.

All other alternate members shall.be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM 6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and three members, including alternates.

RESPONSIBILITIES 6.5.1.6 The PORC shall be responsible for the belnw listed activities.

The PORC may delegate the performance of reviews but will maintain cognizance over and responsibility for them.

Review of (1) all procedures required by Specification 6.8 and changes a.

thereto, (2) all programs required by. Specification 6.8 and changes thereto, and (3) any other proposed procedures or changes thereto as determined by the Plant Manager-Nuclear to affect nuclear safety.

b.

Review of all proposed tests and experiments that affect nuclear safety.

Review of all proposed changes to Appendix "A" Technical Specifications.

c.

d.

Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety.

Review of investigations of all violations of the Technical e.

Specifications including the preparatioa and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Plant Manager-Nuclear and to the Safety Review Committee.

f.

Review of all REPORTABLE EVENTS.

WATERFORD - UNIT 3 6-8

ADMINISTRATIVE CONTROLS f

N RESPONSIBILITIES (Continued) 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-Nuclear or the Safety Review Committee.

i.

Review of the Security Plan and implementing procedures and submittal of recommended changes to the Safety Review Committee.

j.

Review of the Emergency Plan and implementing procedures and submittal of recommended changes to the Safety Review Committee.

k.

Review and documentation of judgment concerning prolonged operation in bypass, channel trip, and/or repair of defective protection channels of process variables placed in bypass since the last PORC meeting.

1.

Review of proposed modifications to the CPC addressable constants based on information obtained through the Plant Computer-CPC data link.

However, the CPC Type I and Type II addressable constants shall be maintained within the limits specified in Table 2.2-2 of Specification 2.2.2.

m.

Review of any accidental, unplanned or uncontrolled radioactive release including reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President, Nuclear Operations and to the Safety Review Committee.

n.

Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL, and major changes to radwaste treatment systems.

AUTHORITY 6.5.1.7 The PORC shall:

a.

Recommend in writing to the Plant Manager-Nuclear, prior to implementation except as provided in Specification 6.8.3, approval or disapproval of items considered under Specification 6.5.1.6a.

through d. and 1.

b.

Render determinations in writing, prior to implementation except as provided in Specific'ation 6.8.3, with regard to whether or not each item considered under Specification 6.5.1.6a. through e. constitutes an unreviewed safety question.

c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Vice President-Nuclear Operations and the Safety Review Committee of disagreements between the PORC and the Plant Manager-Nuclear; however, the Plant Manager-Nuclear shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.

WATERFORD - UNIT 3 6-9 l

ADMINISTRATIVE CONTROLS RECORDS

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f' 6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility and authority provisions of these technical specifications.

Copies shall be provided to the Senior Vice President-Nuclear Operations and the Safety Review Committee.

6.5.2 SAFETY REVIEW COMMITTEE (SRC)

FUNCTION 6.5.2.1 The SRC shall function to provide independent review and audit of designated activities in the areas of:

a.

Nuclear power plant operations, b.

Nuclear engineering, c.

Chemistry and radiochemistry, d.

Metallurgy, e.

Instrumentation and control, f.

Radiological safety, g.

Mechanical and electrical engineering and

- s h.

Quality assurance practices.

COMPOSITION 6.5.2.2 The SRC shall be composed of at least five members, including the Chairman.

Members of the SRC may be from within the LP&L organization or from organizations external to LP&L.

The qualifications of members selected for the SRC shall be in accordance with Section 4.7 of ANSI /ANS 3.1-1978.

ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the SRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SRC activities at any one time.

CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the SRC Chairman to provide expert advice to the SRC.

t WATERFORD - UNIT 3 6-10

ADMINISTRATIVE CONTROLS b.

MEETING FREQUENCY 6.5.2.5 The SRC 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 SRC necessary for the performance of the review and audit function of these technical specifications shall consist of a minimum of five members or of not less than a majority of the composition of members in Specification 6.5.2.2, whichever is greater.

No more than a minority of the members shall have line responsibility for operation ~ of the plant.

REVIEW 6.5.2.7 The SRC shall be responsible for the review of:

a.

The safety evaluations for (1) changes to procedures, equipment, or 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 unreviewed safety question as defined in 10 CFR 50.59; Proposed tests or experiments which involve an unreviewed safety c.

question 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.

All REPORTABLE EVENTS; 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 PORC.

WATERFORD - UNIT 3 6-11

ADMINISTRATIVE CONTROLS (mj 4

AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the SRC.

These audits shall encompass:

a.

The conformance of unit operation to provisions contained within the Technical Specification:; 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.

c.

The results of actions taken to correct deficiencies occurring in 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.

e.

Any other area of unit operation considered appropriate by the SRC or the Vice President-Nuclear Operations.

f.

The fire protection programmatic controls including the implementing T

procedures at least once per 24 months by qualified licensee QA personnel.

g.

The fire protection equipment and program implementation at least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection con-sultant.

An outside independent fire protection consultant shall be used at least every third year.

h.

The Primary Coolant Sources Outside Containment Program at least once per 24 months.

i.

The In-Plant Radiation Monitoring Program at least once per 24 months.

j.

The Secondary Water Chamistry Program at least once per 24 months.

k.

The Post-Accident Sampling Program at least once per 24 months.

1.

The Basemat Monitoring Program at least once per 24 months.

m.

The radiological environmental monitoring program and the results thereof at least once per 12 months.

n.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

o.

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

WATERFORD - UNIT 3 6-12

v ADMINISTRATIVE CONTROLS s.

IS[

AUDITS (Continued) p.

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

1 AUTHORITY 6.5.2.9 The SRC shall report to and advise the Senior Vice President-Nuclear Operations on those areas of responsibility specified in Specifications 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of SRC activities shall be prepared, approved, and distributed as indicated below:

Minutes of each SRC meeting shall be prepared, approved, and a.

forwarded to the Senior Vice President-Nuclear Operations within 14 days following each meeting.

b.

Reports of reviews encompassed by Specification 6.5.2.7 shall be prepared, approved, and forwarded to the Senior Vice President-Nuclear Operations within 14 days following completion of the review.

t Audit reports encompassed by Specification 6.5.2.8 shall be forwarded c.

to the Senior Vice President-Nuclear Operations 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 EVENT ACTION 6.6.1 The following actions shall be taken for REPORTA8LE EVENTS:

The Commission shall be notified and a report submitted pursuant a.

to the requirements of Section 50.73 to 10 CFR Part 50, and b.

Each REPORTA8LE EVENT shall be reviewed by the PORC and the results of this review shall be submitted to the SRC and the Senior Vice President-Nuclear Operations.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

WATERFORD - UNIT 3 6-13

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4 NPF-38-51 ATTACHMENT B 4

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ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant Manager 1.c'eer shall be responsible for overall unit I

operation and shall delegate in writing the succession to this responsibility during his absence.

- 6.1. 2 The Shift Supervisor, or during his absence from the control room, a designated individual shall be responsible for the control room command function.

A reanagement directive to this effect, signed by the Vice President -

Nuclear 0;;;ratic.,:, shall be reissued to all station personnel on an annual l

basis.

6.2 ORGANIZATION OFFSJ-T[

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The ffsit org tzati for it ma gemen and chni 1s por

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UNIT STAFF I

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  • ci;;ur: S. 2-2 cr.i a.

Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; b.

At least one licensed Operator shall be in the control room when fuel is in the reactor.

In addition, while the reactor is in MODE 1, 2, 3, or 4, 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; u

d.

All CORE ALTERATIONS shall be observed or performed by a licensed Operator or licensed Senior Operator and 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 two other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.

  • 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.

WATERFORD - UNIT 3 6-1

rn ADMINISTRATIVE CONTROLS UNIT STAFF (Continued) f.

Administrative procedures shall be developed and implemented to limit the working hours of individuals of the nuclear power plant.

operating staff who are responsible for manipulating plant controls or for adjusting on-line systems and equipment affecting plant safety which would have an immediate impact on public health and safety.

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

The objective shall be to have operating porsonnel work a normal 8-hour day, 40-hour week while.the plant is operating.

However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:

1.

An individual shall 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 shall 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 /> shall be allowed between work periods, including shift turnover time.

Except during extended shutdown periods, the use of overtime shall 4.

be considered 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, th: :::i; tant Plant Man;;;r;, th; Opc.;ticas Super *7 tend:nt "u:!::r cr 'igher 1;;;1: cf ;;n;;;;;nt, in accordance with established procedures and with documentation of the basis for Controls shall be included in the procedures granting the deviation.

such that individual overtime will be reviewed monthly by the Ct;tica PtAur l Manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized.

WATERFORD - UNIT 3 6-2

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s WATERFORD - UNIT 3 6-4

O ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION 6.2.3.1 The ISEG 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 ISEG shall make detailed recommendations for revised procedures, equipment modifica-tions, maintenance activities, operations activities, or other means of improving unit safety to the Engin;; ring and "uclear Safety ":n:ger.

l Vsc e Pres s ant a r - Huc.t.s.n n COMPOSITION 6.2.3.2 The ISEG shall be composed of at least five, dedicated, full-time engineers located on site.

Each shall have a bachelor's degree in engineering or related science and at least 2 years professional level gxperience in his field, at least 1 year of which experience shall be in the nuclear field.

RESPONSIBILITIES 6.2.3.3 The ISEG 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.

AUTHORITY cu rs o os rHE PLAAir* HAH A&G Ft E M T OC& AN iilA TION 6.2.3.4 The ISEG is an onsite independent technical review group that reports

-to-the Engitring and "uclear S fet; " n:g:.

The ISEG shall have the authority l

r necessary to perform the functions and responsibilities as delineated above.

RECORDS Records of activities performed by the ISEG shall be prepared, maintained, l 6.2.3.5 and forwarded each calendar month to the Engin;;rin;, xd Sci;;r Saf;ty "anag:r.

Va cc Pnesu be.n r-NueLe A R 6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to the Shift Supervisor 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 of-instrumentation and controls in the control room.

  • Not responsible for sign-off function.

WATERFORD - UNIT 3 6-6

0 ADMINISTRATIVE CONTROLS

[..'.

L 6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 except that:

MnWGCMcu r of RAbtA rton PeorucricM a.

The ";distica l' ret;;ti;n

rint;nd
nt shall meet or exceed the i

minimum qualifications of Regulatory Guide 1.8, September 1975.

b.

Personnel in the Health Physics, Chemistry and Radwaste Departments shall meet or exceed the minimum qualifications of ANSI N18.1-1971.

c.

The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifications of the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.

Sra

d. 4 ersonnel 4a the ol nt Quality Ocpartment, and st'.cr ;t;ff pe. 5ennel l

ho peform inspection, examination, and testing functions, shall meet or exceed the minimum qualifications of Regulatory Guide 1.58, Rev. 1, September 1980.

(Endorses ANSI N45.2.6-1978) 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit St'aff shall be maintained under the direction of the Training Manager lL;1 car,and shall l

meet or exceed the requirements and recommendations of Section 6~.2 of

~

ANSI 3.1-1978 and Appendix A of 10 CFR Part 55 and the supplem Mtfl require-ments 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 REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager IL;lec.r on all l

matters related to nuclear safety.

/NSbbT COMPOSITION 6.5.1.2 'theP0 'shal e compos d of the-

[

hairm :

Assi ant Pla Mana r-Nucle (Plant chnica rvices o Opera ons and aintena e)

Vi Chair n:

chnical pport uperint dent-Nuc ear mber:

Haintena e Sup intende -Nuclear Member-Operat ns Su _rintend t-Nuclear Memb Radi ion Pr ection perinte ent-Nuc ear Me er:

Qu ity Co rol Man er-Nucle NATERFORD - UNIT 3 6-7

.~,

a INSERT 6.5.1.2 The PORC shall be composed of a minimum of.six members which shall include the following:

Chairman:

Senior management of plant. technical services, operations or maintenance Vice Chairman:

Management of plant technical support Member:

Management of maintenance j

Member:

Manage 6ent of. operations Member:

Management of radiation protection Member:

Management knpwledgeable in quality assurance /

control i

i l

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ADMINISTRATIVE CONTROLS In Tu er Eunr 01: A a.ss nc.p. O f Tag PORC

V

&tltt2M A N AAJO Vwe 0+4tRM A N ALTERNATES--

6.5.1.3 The PORC i: 2:fr:d b :n: cf th: "::iztent P!:nt " n ger: and, in their

Ch;i n:n

!f ;?' thrc:

M :nce, th-T: hnical Supp;rt S;;;r'.t:nient :t:

Or 2: Ort.hthePlantManager1.:07 will appoint a temporary Chairman.

All other alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM 6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and three members, including alternates.

RESPONSIBILITIES 6.5.1.6 The PORC shall be responsible for the below listed activities.

The PORC may delegate the performance of reviews but will maintain cognizance over and responsibility for them.

Review of (1) all procedures required by Specification 6.8 and changes a.

thereto, (2) all programs required by Specification 6.8 and changes thereto, and (3) any other proposed procedures or changes thereto as determined by the Plant Manager Nucl r-to affect nuclear safety.

l l

b.

Review of all proposed tests and experiments that affect nuclear safety.

Review of all proposed changes to Appendix "A" Technical Specifications.

c.

d.

Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety.

1 Review of investigations of all violations of the Technical e.

Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Plant Manager Nuclear and to the Safety Review Committee.

l f.

Review of all REPORTABLE EVENTS.

l l

WATERFORD - UNIT 3 6-8

O ADMINISTRATIVE CONTROLS 7

RESPONSIBILITIES (Continued) 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 tsc?::r or l

the Safety Review Comittee.

i.

Review of the Security Plan and implementing procedures and submittal of recomended changes to the Safety Review Committee.

j.

Review of the Emergency Plan and implementing procedures and submittal of recomended changes to the Safety Review Comittee.

k.

Review and documentation of judgment concerning prolonged operation in bypass, channel trip, and/or repair of defective protection channels of process variables placed in bypass since the last PORC meeting.

1.

Review of proposed modifications to the CPC addressable constants based on information obtained through the Plant Computer-CPC data link.

However, the CPC Type I and Type II addressable constants shall be maintained within the limits specified in Table 2.2-2 of Specification 2.2.2.

m.

Review of any accidental, unplanned or uncontrolled radioactive release including reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President-Nuclear y

Operaties and to the Safety Review Comittee.

n.

Review of changes to the PROCESS CONTROL PROGRAM and the 0FFSITE 00SE CALCULATION MANUAL, and major changes to radwaste treatment systems.

AUTHORITY 6.5.1.7 The PORC shall:

a.

Recomend in writing to the Plant Manager-i;ucicar, prior to implementation except as provided in Specification 6.8.3, approval or disapproval of items considered under Specification 6.5.1.6a.

through d. and 1.

b.

Render determinations in writing, prior to implementation except as provided in Specification 6.8.3, with regard to whether or not each item considered under Specification 6.5.1.6a. through e. constitutes an unreviewed safety question.

c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Str.icr Vice President-Nuclear Oper;ti = and the Safety Review Comittee of disagreements between the PORC and the Plant Manager tiucic;r; however, the Plant Manager ??ucicar shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.

WATERFORD - UNIT 3 6-9

V Ea

. ADMINISTRATIVE CONTROLS

.I RECORDS

'"'/

6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that,'at a minimum, document the results of all PORC activities performed under the responsibility and authority provisions of these technical specifications.

Copies shall be provided to ths Sm.....

V.ss

.s; Jc..t huelea. Cps.ation; eaa l

^

the Safety Review Committee.

6.5.2 SAFETY REVIEW COMMITTEE (SRC)

FUNCTION 6.5.2.1 The SRC shall function to provide independent review and audit of designated activities in the areas of:

a.

Nuclear power plant operations, b.

Nuclear engineering, c.

Chemistry and radiochemistry, d.

Metallurgy, e.

Instrumentation and control, f.

Radiological safety, g.

Mechanical and electrical engineering and t

h.

Quality assurance practices.

COMPOSITION 6.5.2.2 The SRC shall be composed of at least five members, including the Chairman. Members of the SRC may be from within the LP&L organization or from organizations external to LP&L.

The qualifications of members selected for the SRC shall be in accordance with Section 4.7 of ANSI /ANS 3.1-1978.

ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the SRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SRC activities at any one time.

CONSULTANTS 6.5.2.4 Consultants.shall be utilized as determined by the SRC Chairman to provide expert advice to the SRC.

WATERFORD - UNIT 3 6-10

7 s

ADMINISTRATIVE CONTROLS 1

AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the SRC.

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.

c.

The results of actions taken to correct deficiencies occurring in 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.

Any other area of unit operation considered appropriate by the e.

SRC or thaVVice President-Nuclear Operations.

l SE ro o n f.

The fire protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel.

g.

The fire protection equipment and program implementation at least onc'e per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection con-sultant. An outside independent fire protection consultant shall be used at least every third year.

h.

The Primary Coolant Sources Outside Containment Program at least once per 24 months.

i.

The In-Plant Radiation Monitoring Program at least once per 24 months.

J.

The Secondary Water Chemistry Program at least once per 24 months.

k.

The Post-Accident Sampling Program at least once per 24 months.

1.

The Basemat Monitoring Program at least once per 24 months.

The radiological environmental monitoring program and the results m.

thereof at least once per 12 months.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at n.

least once per 24 months.

The PROCESS CONTROL PROGRAM and implementing procedures for o.

processing and packaging of radioactive wastes at least once per 24 months.

WATERFORD - UNIT 3 6-12

ADMINISTRATIVE CONTROLS i

-1 11 AUDITS (Continued) p.

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

AUTHORITY 6.5.2.9 The SRC shall report to and advise the Senior Vice President-Nuclear Operations en those areas of responsibility specified in Specifications 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of SRC activities shall be prepared, approved, and distributed as indicated below:

a.

Minutes of each SRC meeting shall be prepared, approved, and

. forwarded to the Senior Vice President-Nuclear Operations within 14 days following each meeting.

b.

Reports of reviews encompassed by Specification 6.5.2.7 shall be prepared, approved, and forwarded to the Senior Vice President-Nuclear Operations within 14 days following completion of the review.

c.

Audit reports encompassed by Specification 6.5.2.8 shall be forwarded to the Senior Vice President-Nuclear Operations 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 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 Section 50.73 to 10 CFR Part 50, and b.

Each REPORTABLE EVENT shall be reviewed by the PORC and the results of this review shall be submitted to the SRC and the Scr.icr Vice President-l Nuclear Ope.ations.

I 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

I L

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