ML20234D659

Proposed Tech Specs,Reflecting Addl Organizational Changes Due to Need for Addl Mgt Staffing for Present Outage & from Expansion of long-term Mgt Function

ML20234D659
Person / Time
Site:	Rancho Seco
Issue date:	09/16/1987
From:	SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20195G423	List: ML20195G420 ML20234D659
References
TAC-60162, NUDOCS 8709220157
Download: ML20234D659 (32)

Text

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J i ' ATTACHMENT III-r RANCHO SECO TECHNICAL SPECIFICATIONS (Pages affected by Proposed Amendment No. 138, Rev. 2) .] l 1 .I (' J l j i i k i -i 8709220157 870916 G PDR ADOCK=05000312 PDR P g

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' [i RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS TABLE OF CONTENTS (Continued) Section Page 6 ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 7' 6.2 ORGANIZATION 6-1 /' 6.3 FACILITY STAFF QUALIFICATIONS 6-3 6.4 TRAINING 6-3 /, 6.5 REVIEW AND AUDIT 6-3 6.5.1 Plant Review Committee 6-3 1 6.5.2 Management Safety Review Committee 6-6 l '138> 6.5.3 Technical Review and Control 6-8 l l 6.5.4 Audits 6-9 l l 6.6 REPORTABLE OCCURRENCE ACTION 6-10 6.7 SAFETY LIMIT VIOLATION 6-11 l 6.8 PROCEDURES 6-11 6.9 . REPORTING REQUIREMENTS 6-12 1 6.10 RECORD RETENTION 6-13 6.11 RADIATION PROTECTION PROGRAM 6-14 6.12 RESPIRATORY PROTECTION PROGRAM - Deleted 6.13 HIGH RADIATION AREA 6-15 6.14 ENVIRONMENTAL QUALIFICATION 6-16 6.15 PROCESS CONTROL PROGRN4 (PCP) 6-17 6.16 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6-18 l 6.17 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS 6-19 (LIQUID, GASEOUS,-AND SOLID) 6.18 POSTACCIDENT SAMPLING 6-22 Proposed Amendment No. 138, Rev. 2 viii

g_' j'. x. 7 ' I, v :l y RANCHO SECO UNIT 1 E f TECHNICAL SPECIFICATIONS LIST OF TABLES , 3

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,' 3 Table 4.21-1 RADI0 ACTIVE LIQUID WASTE SAMPLING AND - i ' :^ _3 ANALYSIS PROGRAM i 4-70 ! '~. < 4.22-1 RADI0 ACTIVE GASE0US WASTE SAMPLING AhD ' .<j 4 4 ' ANALYSIS PROGRAM 4.26-1 MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION (LLD) 4-84 4-28-1 EXPL0SIVE GAS MIXTURE INSTRUMENTATION SURVEILLANCE REQUIREMENTS 4-88 138x 6.2-1 MINIMUM SHIFT CREW COMPOSITION 6-2 i i ? ) 4 4 1

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r m 4 i.: 3, I RANCHO SECO UNIf 1 TECHNICAL SPECIFICATIONS LIST OF FIGURES (Continued) J' ~ Figure-3.5.2-7 Core Imbalance vs. Power Level, 0 to 40 EFPD 3.5.2-8 Core Imba. lance vs. Power Level, af ter 30 EFPD j i-3.5,2-9 Core Imbalance vs. Power Level, after 300 EFPD with APSRs Withdrawn ' 3.6.2'1 Deleted l 3.5.2-11 Deleted 1 Deleted 3.5.2-12 3.5.4-1 Incore Instrumentation Specification Axial Imbalance Indication 3.5.4-2 Incore Instrumentation Specification Radial Flux Tilt. Indication l l 3.5.4-3 Incore ' Instrumentation Specification 1 3.18-1 General Layout of Site l l 4.13-1 Main Steam Inservice Inspection 1 4.13-2 Main Feedwater Inservice Inspection l 4.13-3 Main Steam Dump Inservice Inspection 138> 6.2-1 9":llD Corporate Support of Nuclear Safety to Rancho Seco 6.2-D Nuclear Organization Chart l 1 l l l r Proposed knendment No.138, Rev. 2 xii

RANCHO SECO UNIT 1 . TECHNICAL SPECIFICATIONS 138>> Administrative Controls 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 138> 6.1.1 The Chief Executive Officer (CE0), Nuclear shall be responsible for the management of the overall facility, and the Assistant General Manager (AGM), Nuclear Power Production shall be responsible to him for the operation and maintenance of the plant. They shall delegate in writing the succession to their responsibility during.their absences. 'l 6.2 ORGANIZATION 0FFSITE 6.2.1 The offsite organization for. the facility management and technical support shall be as shown on Figure 6.2-1. l l FACILITY STAFF 1 l 6.2.2 The Facility organization shall be as shown on Figure 6.2-2 and: l l a. Each on duty shift shall be composed of at least the minimum l shift crew composition shown in Table 6.2-1. I b. At least one licensed Operator shall be in the control room when fuel is in the reactor. 138> c. At least two licensed Operators, one of whom shall be senior l licensed, shall be present in the control room when the unit is l in other than cold shutdown or refueling. l d. An individual qualified in radiation protection practices and procedures shall be on site when fuel is in the reactor. e. ALL CORE ALTERATIONS after the initial fuel loading shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator limited to Fuel Handling who has no other concurrent responsibilities during this operation. f. A site Fire Brigade of at least 5 members shall be maintained onsite at all times.* The Fire Brigade shall not include 3. 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. l l

• Fire Brigade composition may be less than the minimum requirements for a l

period of time not to exceed 2 hours in order to accommodate unexpected absence provided immediate action is taken to fill the required positions. Proposed /mendment No. 138, Rev. 2 6-1 i l l l

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS i Administrative Controls l l 6.2 ORGANIZATION FACILITY STAFF l 1 g. Administrative procedures shall be developed and implemented to l limit the working hours of facility staff who perform i l safety-related functions; e.g., senior reactor operators, 138>< reactor operators, radiation protection personnel, auxiliary -l operators, and key maintenance personnel, j Adequate shift coverage shall be maintained without routine ~ heavy use of overtime. The objective shall-be to have operating. 1 138>< personnel work a normal shift schedule while the plant is i operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance or a l major plant modifications, on a temporary basis, the following guidelines shall be followed: I l 1 a. An individual should not be permitted to' work more than 16 j hours straight, excluding shift turnover time. I i b. An individual should not be permitted to work more than 16 j hours in any 24-hour period, nor more than 24 hours in any I 48-hour period, nor more than 72 hours in any seven day I period, all excluding shift turnover time. c. A break of at least eight hours should be allowed between l work periods, including shift turnover time. l l d. Except during extended shutdown periods, the use of-l overtime should 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~ 138> the AG1, Nuclear Power Production or designee, in accordance with established procedures and with documentation of the basis for granting the deviation. Controls shall be included in the i procedures such that individual overtime shall be reviewed 1 138>< monthly by the AG4, Nuclear Power Production or designee to 1 l assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized. 1 l Proposed Amendment No. 138, Rev. 2 1 6-la ____._m._--__

.i RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative ~ Control s I i TABLE 6.2-1 138>< MINIMUM SHIFT CREW C04 POSITION

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COLD OTHER THAN l RANCHO SEC0 JOB TITLE SHUTDOWN COLD SHUTDOWN I Shift Supervisor 1-SL 1-SL i 138>< Asst. Shift Supervisor or Control Room Operator 2-L 1-SL,-2-L' l l Shift Technical Advisor 0 1-NL 138>< Minimum Personnel 3 5 l l l In the event that any member of a minimum shift crew is absent or I 138>< incapacitated due to illness or injury, a qualified replacement shall be designated to report on site within two hours. SL - NRC Senior Licensed Operator I L - NRC Licensed Operator j l l 138>< NL-NRC License Not Required i i I l 5 Proposed Amendment No. 138, Rev. 2 6-2

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RANCHO SECO UNIT 1 TECHNICAL -SPECIFICATIONS Administrative Controls 6.3 ~ FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the' unit staff shall meet or exceed the' minimum qualifications of ANSI N18.1-1971 for comparable positions, except 138+4 ' for -(1) the Manager, Radiation Protection who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and (2) the Shif t Technical Advisor dio shall have a bachelor's degree or equivalent in a scientific or engineering discipline. The STA shall receive specific training in plant design, and response and analysis of the plant for transients and accidents. 6.4 TRAINING t l 6.4.1 A retraining and replacement training program for the operating. staff 138>+ shall be maintained under the direction of the Manager, Training l and shall meet'or exceed the requirements and recommendations of l Section 5.5 of ANSI N18.1-1971 and. Appendix "A" of 10 CFR, Part 55. 1 6.4.2 A training program for the Fire Brigade shall be maintained under the-l 138++ direction of the Manager, Training and shall. meet or exceed the I requirements of Section 27 of the NFPA Code - 1975, except refresher classroom training shall be on a quarterly schedule. l 6.5 REVIEW AND AUDIT-l 6.5.1 PLANT REVIEW COMMITTEE (PRC) FUNCTION 138+ 6.5.1.1 The Plant Review Committee shall.. function to advise the AGM, Nuclear Powr Production and the Management Safety Review Committee on all + matters related to nuclear safety. I COMPOSITION l 138+ 6.5.1.2 The Plant Review Committee shall be composed of a chairman, and a minimum of six members. 4 l l l Proposed Amendment No. 138, Rev. 2 6-3 l l l l l l

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 138+ MEMBERSHIP 6.5.1.3 Membership of the PRC shall be as defined below: a. A list of members made up of personnel filling positions shown in the Nuclear Organization (Fig. 6.2-2) and others vho meet or a exceed the minimum walifications of ANSI N18.1-1971. sha'll be developed and approved by the AGM, Nuclear Powr Production. 'l b. A list of alternate members of the PRC shall be developed and i approved by the AGM, Nucleae Powr P' oduction. r c. The Chairman of the PRC shall be appointed by the AGM, Nuclear Poer Production. When a meeting ~is scheduled or an emergency-I meeting is necessary, and the PRC Chairman will be absent, an alternate Chairman may be designated by the PRC Chairman or the j AGM, Nuclear Pour Production from among the PRC members j described in Specification'5.5.1.2. 'j 4 MEETING FREQUENCY 138+ 6.5.1.4 The PRC shall meet at least once per calendar month and es convened l by the PRC Chairman, or as directed by the AGM, Nuclear Po er -{ 4 Production. QUORUM 138+ 6.5.1.5 A Quorum of the PRC shall consist'of a majority of the members listed l in Specification 6.5.1.2 including the Chairman or alternate I Chairman. No more than two alternates shall participate in PRC activities at any one time for the purpose of establishing a quorum. I 4 RESPONSIBILITIES l 138+4 6.5.1.6 The Plant Review Committee shall be responsible for review of: l a. The required safety evaluation of 1).all procedures required by I Specification 6.8 and changes thereto, and 2) any other proposed L procedures or changes thereto W1ich are as determined by the AGM, Nuclear Poer Production to affect nuclear safety. l b. The safety evaluations of all proposed tests and experiments that affect nuclear safety. I c. All proposed changes to the Technical Specifications or the l Operating License. l 138+ d. All safety evaluations of proposed changes or modifications to l l plant systems or equipment that affect nuclear safety. Items' 4 l which are determined by the qualified reviemr process as not l subject to 10CFR50.59 requirements need not be revie w d and l 4 approved by the PRC. 138+

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Investigations of all violations of the Technical Specifications to determine adequacy of corrective action and to detect any 4 degrading trend, j f. Facility operations to detect potential safety hazards. I Proposed Amendment No. 138, Rev. 2 6-4 --. --.--- - ---O

RANCHO SEC0 UNIT!11 I t ' TECHNICAL SPECIFICATIONS-- Administrative Controls RESPONSIBI'LITIES: (C'ontinued) 138> .g. All events requiring a Licensee-Event. Report as defined by ' 10CFR50.73 and NUREG-1022 to' determine _ adequacy of-corrective 4 action and to detect any degrading trend.. h. Special investigations and' reports thereon as requested by 138>< the AGM, Nuclear Power Production. 138> 1. The Plant Security. Pla'n and changes thereto.. j. The Emergency Plan and changes thereto. k. Changes to the Process' Control Program and the Offsite Dose -Calculation Manual. (See Specifications 6.15 and 6.16.') l '1. Major changes to the Radioactive Waste Treatment Systems (Liquid, Gaseous-and Solid), and all_.information required by.. Specification 4 6.17. 1 AUTHORITY 6.5.1.7 The Plant Review Committee'shall: 138>< a. Recommend in writing to the AGM, Nuclear Power Production j approval or disapproval ofditems considered 'under 6.5.1.6(a) q through (d) above. b. Render determinations in ' writing with regard to whether or not each item considered under 6.5.1.6(a)'through (e) above-1 constitutes an unreviewed: safety l question. c. Provide immediate written notification to the Chairman' of the-Management Safety Review Committee.of ' disagreement between the 138> PRC and the AGM, Nuclear Power Production; however, the AGM, Nuclear Power Production shall have responsibility for resolution of such disagreements pursuant to 6.5.1.1'above. i RECORDS 138> 6.5.1.8 Records of the PRC activities shall be prepared, approved and distributed as indicated below: ~ l-a. Minutes.of each PRC meeting, including appropriate documentation [ of reviews encompassed by Specification 6.5.1.6e and g, shall be L prepared, approved, and forwarded to the AGM, Nuclear Power" l Production and to the Chairman, Management Safety Review l Committee within fourteen (14) days following each meeting. 3 l' Proposed Amendment No. 138, Rev. 2 6-5, o

RANCHO'SECO UNIT 1 TECHNICAL SPECIFICATIONS I ~ l Administrative Controls 6.5.2 Management Safety Review Committee (MSRC) \\ FUNCTION 1 l 6.5.2.1 The Management Safety Review Committee shall function to provide independent review and audit of designated activities in the areas of: l l a. nuclear power plant operations i b. nuclear engineering l c. chemistry and radiochemistry 1 i d. metallurgy j u e. instrumentation and control l f. radiological safety j g. mechanical and electrical engineering h. quality assurance practices l COMPOSITION l 138> 6.5.2.2 The MSRC shall be composed of a chainnan and a minimum of eight members. The MSRC membership shall be made up of manager. levels or above as shown on the Nuclear Organization (Fig. 6.2-2) or of other personnel meeting or exceeding the minimum qualifications of ANSI /ANS l 3.1-1981, Section 4.7.2. MEMBERSHIP 6.5.2.3 The Chairman of the MSRC shall be appointed by the CEO, Nuclear. A current list of members and alternates as described in Specification 6.5.2.2 shall be developed and approved by the CEO, Nuclear and maintained by the MSRC Secretary. In the absence of the Chairman, an Alternate Chairman may be designated by the MSRC Chairman or the CEO, Nuclear. The Alternate Chairman shall be selected from among the MSRC members described in Specification 6.5.2.2. l 1 Proposed Amendment No.138, Rev. 2 6-6 a

i RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.5.2.4 MEETING FREQUENCY 138> The MSRC shall meet at least once per calendar quarter and as. convened by the MSRC Chairman or as directed by the CEO, Nuclear. QUORUM 138> 6.5.2.5 A quorum of MSRC shall consist of a majority of the members listed in Specification 6.5.2.2, including the chairman or alternate chairman. No more than two alternates shall participate in MSRC activities.at any one time for the purpose of establishing a quorum. REVIEW 138> 6.5.2.6 The MSRC shall be responsible for review of: I a. The safety evaluation for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provisions of Section 50.59, 10 CFR, to verify that such actions do not constitute on unreviewed safety question. b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10 CFR. c. Proposed tests or experiments which involve an unreviewed safety j question as defined in Section 50.59, 10 CFR. l I d. Proposed changes in Technical Specifications. or the Operating I

License, e.

Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance. f. Significant operating abnormalities or deviations from normel f and expected performance of plant equipment that affect nuclear l safety. g. Any indication of an identified significant deficiency in the design or operation of safety-related structures, sys.tems, or 3 components. l i i Proposed Amendment No.138, Rev. 2 I 'j 6-7 i t ) a

RANCHO SECO UN d 1 7 TECHNICAL SPECIFICATIONS Administrative Controls 138> h.- Reports and meeting minutes of the Plant Review committee. i. Any facility activity brought-to the attention of the MSRC by the District's executive management which _may be indicative of conditions adverse to nuclear safety. J. The MSRC shall provide oversight review of: The District Quality Program, including cognizance of the Audit Program content and implementation, and audit reports. The Radioactive Waste Control Program. ) i Effectiveness of the Licensee Event Report Program per ) Specification 6.6.1. j 1 138> AUTHORITY l l 6.5.2.7 The Management Safety Review Committee shall: a. Report to and advise the CEO, Nuclear of those areas of responsibility specified in Specification 6.5.2.6. I l l b. Recommend to the CEO, Nuclear, c'her areas of facility l operation for which the MSRC has detennined the need for additional' auditing per Specification 6.5.4. 9 c. Advise the CEO, Nuclear, of the need for independent auditing of facility operations. I I RECORDS l 138>< 6.5.2.8 Records of MSRC activities shall be prepared, approved, and distributed as indicated below: 138> a. Minutes of each MSRC meeting and separate documentation of reviews encompassed by Specifications 6.5.2.6d,e,f and g shall be prepared, approved, and forwarded to the Chief Executive Officer, Nuclear within fourteen (14) days following each meeting. 138> 6.5.3 TECHNICAL REVIEW AND CONTROL Activities which affect nuclear safety shall be conducted as follows: a. Procedures required by Technical Specification 6.8 and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved. Each such l procedure or procedure change shall be reviewed'by an i individual (s) other than the preparer, but who may be from the same organization as the individual (s) that prepared the procedure or procedure change. Procedures other than plant I administrative procedures will be approved as delineated in writing by the AGM, Nuclear Power Production, but not lower than the department manager level. Such procedures shall be reviewed periodically in accordance with administrative procedures. Proposed Amendment No. 138, Rev. 2 6-8

l 1 RANCH 0'SECO UNIT 1 1 1 TECHNICAL SPECIFICATIONS Administrative Controls 138> a. (Continued) The AGM, Nuclear Power Production will approve plant I administrative procedures, Security Plan Implementing Procedures and Emergency Plan Impleraenting Procedures. l Approval of temporary procedure changes which clearly do not change the intent of the approved procedures can be made by two. i members of the plant management staff, at least one of whom l holds a Senior Reactor Operator's License. The change shall be documented, reviewed and approved by the procedures approval i authority within fourteen. (14) days of. implementation. l 4 b. Proposed changes or modifications to plant systems or equipment -I that affect nuclear safety shall. be reviewed by an l individual (s) other than the individual (s) who designed the modification, but who may be from the same organization as the .d individual (s) who designed the modifications. Such modifications shall be approved by the AGM, Nuclear Power ] Production or designee, but shall be no lower than a division i director level. l l c. Proposed tests and experiments which affect-plant nuclear i l safety and are not addressed in.the Updated Safety Analysis - l l Report shall be reviewed by an individual (s) other than the individual (s) who prepared the proposed test or'expertaent. Such tests or experiments shall be approved' by the AGM,. Nuclear Power Production or designee, but shall be no lower than a division director level. d. Events reportable pursuant to the Technical Specification 6.9 and violations of Technical Specifications shall be investigated and a report prepared which evaluates the event: and which provides recommendations to prevent recurrence. Such report shall be reviewed by the PRC and forwarded to the AGM, Nuclear Power Production, and to the Chairman, MSRC. i e. Individuals responsible for reviews performed in accordance with 6.5.3.a, 6.5.3.b and 6.5.3.c shall meet or exceed the ' qualification requirements of Section 4.4 of ANSI 18.1, 1971. Each such review shall include a determination of whether or not additional, cross-disciplinary,. review is necess'ary. If deemed necessary, such review shall be performed by the review personnel of the appropriate discipline. A list of qualified reviewers for the independent reviews described in 6.5.3a., b.,

c., above-shall be established by the AGM,. Nuclear Power Production.

Proposed Amendment No. 138, Rev. 2 6-9

RANCHO SECO UN1T 1 ] -TECHNICAL SPECIFICATIONS j Administrative Controls j AUDITS l l 6.5.4 Audits of facility activities shall be performed under the 138>< cognizance of the Director, Quality Assurance, Nuclear. These audits shall encompass: 1 a. The conformance of facility operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per year. I 138>< b. The performance, training and qualifications of the District's entire facility technical staff at least once per year. c. The result of all actions taken to correct deficiencies l occurring in facility equipment, structures, systems or methods of operation that affect nuclear safety at least once per six l 138>< months for those changes not previously audited. .I l d. The performance of all activities required by the Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per two (2) years. l l e. The Facility Emergency Plan and implementing procedures at l 1 east once per two (2) years. l f. The Facility Security Plan and. implementing procedures at least I once per two (2) years. g. Any other area of facility operation considered appropriate by 138>< the Chief Executive Officer, Nuclear. h. Compliance with fire protection' requirements and implementing l procedures at least once per two (2) years. I 1. An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection fim. j. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than three (3) years. k. The radiological environmental monitoring program and the results thereof at least once per 12 months. 1. The OFFSITE DOSE CALCULATION 14ANUAL and implementing procedures i at least once per 24 months. I m. The PROCESS CONTROL PROGRA'4 for the SOLIDIFICATION of l radioactive wastes from liquid systems at least once per 24 months. Proposed Amendment No. 136, Rev. 2

RANCH 0 SECO UNIT 1 I TECHNICAL' SPECIFICATIONS Administrative Controls 138v Audit reports of reviews encompassed by..Section 6.5.4 shall be l forwarded to the Chief Executive Officer,. Nuclear,' MSRC Chairman, l and to the management positions responsible-for the areas reviewed j within 30 days after completion. 6.6 LICENSEE EVENT REPORT ACTION j 1 138>- 6.6.1 The following actions shall be_ taken.for events which are reportable. .I as LICENSEE EVENT REPORTS: a. The Commission shall be notified. and a-report submitted-per-Specification 6.9.4., purs'u' ant.to.the requirements of Section 50.73 to 10CFR50, and i i b. Each LICENSEE EVENT REPORT shall be reviewed by the PRC and the results of this review submitted,to the ASRC. Each LICENSEE-EVENT REPORT shall be reviewed and approved by the Chief Executive Officer, Nuclear, or designee.

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q 1 i l { i i l .j l l 1 l j Proposed Amendment No. 138, Rev. 2 1 6-10a l l-c _ = _ _ _ _ _ _ _ _ _ - _ _ - _ - _

q { l* RANCHO SECO UNIT 1 i TECHNICAL SPECIFICATIONS Administrative Controls 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit.is violated: L a. The provisions of 10 CFR 50.36 (c) (1) (1) and 10 CFR 50.72 shall j be complied with. 138> b. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour. The Director, Nuclear Operations and Maintenance,- the AG4, Nuclear Power Production, and the Chairman of the MSRC shall be notified 1 within 24 hours. ) c. A Safety Limit Violation Report shall be prepared. The re ort shall be reviewed by the PRC. This report 'shall describe 1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, i and (3) corrective action.taken to prevent recurrence. 1 d. The Safety Limit Violation Report shall be submitted to the ) 138> Commission, the MSRC, and the AG4, Nuclear Power Production, l within 14 days of the violation. 1 6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented and maintained j covering the activities referenced below: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972. t b. Refueling operations. i c. Surveillance and test activities of safety related equipment. { d. Security Plan implementation. e. Emergency Plan implementation. f. Fire Protection Procedures implementation. g. Process control program implementation. I h. Offsite Dose Calculation Manual implementation. 1. Effluent and environmental quality control program. 1 138> 6.8.2 Each procedure of 6.8.1 above and changes thereto-shall be reviewed and approved as set forth in Specification 6.5. Proposed Amendment No. 138, Rev. 2 6-11

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.9 REPORTING REQUIREMENTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code { of Federal Regulations, the foliowing reports shall be submitted to 1 the Director of the Regional Office of Inspection and Enforcement I unless ott erwise noted. l Startup Report 1 6.9.1.1 A summary report of plant startup and power escalation testing shall I be submitted following (1) Receipt of an operating license; (2) amendment to the license involving a planned increase in power level; 3 (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier; and (4) modifications that j may have significantly altered the nuclear, thermal or hydraulic ) performance of the plant. The report shall address each of the tests l 138x identified in the USAR and shall include a description of the measured values of the operating conditions or characteristics obtained during t the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required ir license conditions based on other commitments shall be included in this report. 6.9.1.2 Startup reports shall be submitted within (1) Ninety (90) days following completion of the startup test program; (2) Ninety (90) days following resumption or commencement of commercial power operation; or (3) Nine (9) months following initial criticality, whichever is j earliest. If the Startup Report does not cover all three events I (i.e., initial criticality, completion of startup test program and i resumption or commencement of commercial power operation), i supplementary reports shall be submitted at least every three (3) months until all three events have been completed. Proposed Amendment No. 138, Rev. 2 6-12

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.9.2.2.2 (Continued) The annual radiological environmental operating reports shall 138) include summarized and tabulated results of all radiological environmental samples taken during the report period. In the - 1 event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be j submitted as soon as possible in a supplementary report. The reports shall also include the following: a summary i description of the radiological environmental monitoring program; l including sampling methods for each sample type, size and i physical characteristics of each sample type, sample preparation l methods, analytical methods, and measuring equipment used; a map of all sampling locations keyed to a table giving distances and directions from one reactor; the result of land use censuses, and i the results of licensee participation in the Interlab Comparison Program. The annual report shall also include information related to Specification 4.29. 6.9.2.3 Semiannual Radioactive Effluent Release Report Routine radioactive effluent release reports covering the operation of the unit during the previous six months of operation shall be submitted within 60 days after January 1 and July 1 of each year. The period of the first report shall begin with the date of initial i cri ticality. 6.9.2.3.1 The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released fron; the unit as outlined in' Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," with data summarized on a quarterly basis, following the format of Appendix B thereof. The radioactive effluent release reports shall include the release of gaseous effluents during each quarter, as outlined in Regulatory Guide 1.21, with the data summarized on a quarterly basis, following the format of Appendix B thereof. A summary of j meteorological conditions during the release of gaseous effluents I will be retained on-site for two years. In addition, any changes to the Offsite Dose Calculation Manual will be submitted with the i Semiannual Radioactive Effluent Release Report. Proposed Amendment No. 138, Rev. 2 6-12b I

,l-RANCHO SECO UNIT 1 TECHNICAL-SPECIFICATIONS-Administrative Controls 6.9.2.3.1 Continued) The radioactive effluent release reports shall include an assessment j of the radiation doses from radioactive effluents to individuals due to their activities inside the site boundary during the report period. All assumptions used in making these assessments (e.g., j specific activity, exposure time, and location) shall be included in j these reportE. ] The radioactive effluent release reports sha11' include the following ) information for all unplanned releases to unrestricted areas of radioactive materials in gaseous and liquid effluents: a. A description of the event and equipment involved. b. Cause(s) for the unplanned release. c. Actions taken to prevent recurrence. ) d. Consequences of the unplanned release. l The radioactive effluent release reports shall include an assessment of radiation doses from the radioactive liquid and gaseous effluents { released from the unit'during each calendar quarter, as outline in Regulatory Guide 1.21. The releases of effluents shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the.0ffsite Dose Calculation Manual (0D04). f The radioactive effluent release reports shall include any changes to the PROCESS CONTROL PROGR44 (PCP) or (0D04) made during the reporting j period, as provided in Specifications 6.14 and 6.15. 1 MONTHLY REPORT 6.9.3 Routine reports of operating statistics, including narrative summary of operating and shutdown experience, of lifts of the Primary System ') Safety Valves or EMOVs, of major safety related maintenance, and' 1 tabulations of facility changes, tests or experiments required j pursuant to 10 CFR 50.59(b), shall be submitted on a monthly basis'.to 138x the Director of Inspection and Enforcement, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Regional Office, postmarked no later than the 15th day of each month following the calendar month covered by the report. LICENSEE ~ EVENT REPORT 6.9.4 The LICENSEE EVENT REPORTS of Specification 6.9.4.1 below, including 1 corrective actions and measures to prevent recurrence, shall be reported to the NRC as Licensee Event Reports. Supplemental reports, may be required to fully describe final resolution of occurrence. In case of corrected or supplemental reports,. a Licensee Event Report shall be completed and reference shall be made to the original report' date, pursuant to the requirements of 10 CFR 50.73. Proposed Amendment No.138, Rev. 2 1 6-12c

W RANCHO SECO UNIT l' TECHNICAL SPECIFICATIONS i Administrative Controls l f 138> 6.9.6 Environmental Reports t .1 When a change to the plant design or to the plant operation is ~ planned which would have a significant adverse ~effect on the environment or which involves an environmental matter or question i not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation..The report will include a description and evaluation of the change including a supporting benefit-cost analysis. j .2 Changes or additions to permits and certificates required by Federal, State, local and regional authorities for the protection of the environment will be reported. When. the required changes are submitted to the concerned agency for approval, they will also be submitted to the NRC for information. The submittal will j include an evaluation of the environmental impact of the change. 1 l i l Proposed Amendment No. 138, Rev. 2 6-12g m _ ____.___ _ _ _ _ _.

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.17 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS (LIQUID, GASE0US, AND SOLID) 6.17.1 Function The radioactive waste treatment system (liquid, gaseous, and solid) are those-systems described in the facility Final Safety Analysis Report or Hazards Summary Report, and amendments thereto, which are used to maintain that control over radioactive materials in gaseous. and liquid effluents and in solid waste packaged for offsite shipment required to meet the LCOs set forth in these Specifications. 6.17.2 Major changes to the radioactive waste systems (liquid, gaseous, and 138> solid) shall be made by the following method. For the purpose of this specification, " major changes' is defined in Specification 6.17.3. 138> Licensee-initiated changes: 1. The Comraission shall be informed of all changes by the inclusion of a suitable discussion of each change in the_ annual USAR update-for the period in which the changes were made. The discussion of each change shall contain: a. A summary of the. evaluation that led to the determination that the change could be made (in accordance with 10 CFR 50.59); b. Sufficient information to support the reason for the change without benefit of additional or supplemental information; c. A description of the equipment, components, and processes involved, and the interfaces with other plant systems; d. An evaluation of the change with regard to the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste if different from those previously predicted in the license application and amendments thereto; e. An evaluation of the change with regard to the expected maximum exposures to individuals at or beyond the SITE BOUNDARY and to the general population if different from those previously estimated in the license application and amendments thereto; Proposed Amendment No. 138, Rev. 2 6-19

TECH I T ONS i 6.17.2 (Continued) 138> f. A comparison of the predicted releases of radioactive materials in liquid and gaseous effluents and in solid waste to the actual releases following performance of the change for the period in which the changes were made; g. An estimate of the exposure to plant operating personnel as a result of the changes; and h. Documentation of the fact that the change was reviewed and found acceptable by the PRC. 2. The Change shall become effective upon review and acceptance by 138> the PRC, and approved by the AG4, Nuclear Power Production per Specification 6.5.3b. } 6.17.3 Background and definition of what constitutes " major changes" to j radioactive waste systems (liquid, gaseous, and solid). l A.

Background

l 1. 10 CFR Part 50, Section 50.34a(a) requires that each application'to construct a nuclear power reactor provide a description of the equipment installed to maintain control over radioactive material in gaseous and liquid effluents produced during normal reactor operations, including operational occurrences. 2. 10 CFR Part 50, Section 50.34a (b) (2) requires that each application to construct a nuclear power reactor provide an l l estimate of the quantity of radionuclides expected to be l released annually to unrestricted areas in liquid and j i gaseous effluents produced during normal reactor operations. l l l 3. 10 CFR Part 50, Section 50.34a (b) (3) requires that each l l application to construct a nuclear power reactor provide a l description of the provisions for packaging, storage, and l shipment offsite of solid waste containing radioactive materials resulting from treatment of_ gaseous and liquid effluents and from other sources. 4. 10 CFR Part 50, Section 50.34a (c) requires that each l application to operate a nuclear power reactor shall include 1 (1) a description of the equipment and procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems, and (2) a revised estimate of the information required in (b)(2) if the expected releases and exposures differ significantly from the estimate submitted in the construction permit. Proposed Amendment No. 138, Rev. 2 6-20

ATTACHMENT IV FACILITY CHANGE SAFETY ANALYSIS PAGE 1 0F 6 PROPOSED AMENDMENT NO 138, REY. 2 DESCRIPTION: Proposed Amendment No.138 was originally submitted to the NRC for approval on Oct. 18, 1985. Subsequently, it was superseded by the submittal of Proposed Amendment No.138, Rev.1, dated Aug. 13, 1986 This Proposed Amendment No. 138 revision incorporates changes to the Sacramento Municipal Utility District Rancho Seco Nuclear Plant and corporate office organization which were made by the District subsequent to the submittal of revision 1. The proposed changes to Section 6.0, ADMINISTRATIVE CONTROLS, of the Technical Specifications include: 1) Add Sections 6.5.3 (Technical Review and Control) and 6.5.4 (Audits) to Table of Contents, page viii. 2) The title for Table 5.2-1 (and in Table of Contents, page x) - changed to " Minimum Shift Crew Composition." This title is in accord with Standard Technical Specifications. 3) The title for Figure 6.2-1 (and in Table of Contents List of Figures, page xii) - changed to "SMUD Corporate Support of Nuclear Safety To Rancho Seco." Additionally, the title for Figure 6.2-2 (and in Table of Contents of Figures, page xii) - changed to " Nuclear Organization Chart." Position titles in both figures changed to reflect revised organization. 4) Position and group titles are changed or added throughout the document to agree with those shown in Figures 6.2-1 and 6.2-2. The title changes are considered more descriptive of the management function. 5) The responsibility for the overall management of the facility as stated in Section 6.1.1, is changed from Manager of Nuclear Operations to Chief Executive Officer, Nuclear. The Assistant General Manager, Nuclear Power Production is responsible for the operation and maintenance of the plant. 6) The staff individual's qualifications identified in Specification 6.2.2.d. is expanded to include radiation protection practices. In Specification 6.2.2.g., the term " health physicist" is changed to " radiation protection personnel." 7) Section 6.2.2.g. - the individual authorized to allow deviation from stated shift coverage guidelines is changed to the AGM, Nuclear Power Production, or his/her designee. l l 8) Table 6.2-1, Shift Crew Personnel and Licensing Requirements - revised to be in accord with 10 CFR 50.54(m)(2)(i). Additionally, Section 6.2.2.c. l requires two licensed operators to be in the Control Room when the reactor is in other than cold shutdown or refueling. Removed equipment operator requirements from Table 6-2.1.

l n I O ATTACHMENT IV (CONT.) FACILITY CHANGE SAFETY ANALYSIS PAGE 2 0F 6 l PROPOSED AMENDMENT NO. 138, REY. 2 j 1 DESCRIPTION: (Cont.) 9) Figure 6.2-1, SMUD Nuclear Safety Organization Chart - retitled to "SMUD I Corporate Support of Nuclear Safety to Rancho Seco." Corporate { organizations which do not provide routine nuclear safety support of the plant are deleted from the chart. l

10) Figure 6.2-2, Muclear Organization Chart - amended to show the revised i

I and new positio..s and organization titles. Shif t crew personnel and I license requirements are deleted from Figure 6.2-2. Added footnote to l designate license-required position.

11) Specification 6.5.1, Plant Review Committee (PRC) - revised to reflect the currently proposed charter. The function of the PRC (Section 6.5.1.1) is revised to show that the PRC advises the AGM, Nuclear Power Production and the MSRC on matters related to nuclear safety. The 4

composition of the PRC consists of personnel who meet or exceed the I qualifications of ANSI N18.1-1971. The responsibilities are amended to specify a review of procedures' safety evaluations rather than actual procedures. A similar change is made with respect to proposed plant l l changes and modifications. Specification 6.5.1.3 addresses PRC j membership and the selection of an alternate chairman in the absence of the chairman. Section 6.5.1.5 addresses the limitation on alternates for i establishing a quorum. PRC to report to AGM, Nuclear Power Production.

12) Specification 6.5.2, Management Safety Review Committee (MSRC) - revised i

to reflect the currently proposed charter. The composition of the MSRC l (Section 6.5.2.2) consists of personnel who meet or exceed the l qualifications of ANSI /ANS 3.1-1981. Specification 6.5.2.3 addresses l l MSRC membership and the selection of an alternate chairman in the absence l of the chairman. Section 6.5.2.5 addresses the limitation on alternates for establishing a quorum. Specification 6.5.2.10, Records, is moved to j 6.5.2.8 for editorial reasons, and the forwarding of audit reports to the j Deputy General Manager-Nuclear and General Manager is deleted. Section J 6.5.2.6 is revised to show that the MSRC reviews the QA program and performs an oversight review of the QA Audit Program. This is j administratively made the responsibility of Nuclear Quality, which also v has audit responsibilities. l

13) Specification 6.5.2.8, Audits - changed to 6.5.4.

Cognizance of facility activities audits is made the responsibility of the Director, Quality l Assurance, Nuclear rather than the MSRC, as previously specified. This proposed change, placing cognizant responsibilities with the department performing the audit (Nuclear Quality) and oversight responsibilities j with the MSRC, is a more efficient balance of management responsibilities { with respect to audit coverage and performance. J (

14) Specification 6.5.3, Technical Review and Controls - added.

Section i 6.5.3 describes a new review and approval process for procedures, tests j i i i l i D

o s. .. ATTACHMENT IV (CONT.) FACILITY CHANGE SAFETY ANALYSIS' PAGE 3 0F 6 PROPOSED. AMENDMENT NO. 138, REY. 2 DESCRIPTION: (Cont.) and experiments, and plant modifications. This change' broadens the safety' review process and permits greater attention to detail in the performance of safety reviews.

15) Specification 6.6.1 on LERs - edited slightly, and 6.6.1b is revised, deleting position titles and adding the MSRC, which is made up of, or reports to, these previously-litted positions.

16) Specification 6.8.2 - modified to clarify the procedure review and approval cycle.

17) Specification 6.8.3, regarding temporary changes to the procedures listed in Specification 6.8.1 - deleted.

18) Specification 6.9.2.2.2 - deletes the reference to Table 6.9-1.

Table 6.9-1 itself was deleted from the Technical Specifications by Amendment No. 28 (4/9/79).

19) Specification 6.9.3 - changed to show the current NRC addresses to which-l-

monthly reports are submitted.

20) Specification 6.9.6, Environmental Reports, - added.to Appendix A.

This section is presently in Appendix B of Technical Specifications. ~ Proposed l Amendment 102 deletes Appendix B from the Technical Specifications. l-

21) Specification 6.17, MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS (LIQUID, GASE0US, AND SOLID) - changed to clarify the definition of l

" major changes" and explain in greater detail the method by which these. major changes shall be made to radioactive waste systems. REASON FOR CHANGE: Purpose 1 This proposed amendment revision is being submitted to update the Rancho Seco Technical Specifications to reflect the current SMUD Rancho Seco Nuclear Plant and corporate office organization. EVALUATION AND BASIS FOR SAFETY FINDINGS: Systems, Subsystems, Components Affected All of the changes to be incorporated in Proposed Amendment 138, Rev. 2 are administrative or organizational in nature and do not affect any plant safety systems.

'i e ATTACHMENT IV'(CONT.) 1 FACILITY CHANGE SAFETY. ANALYSIS PAGE 4 0F 6 j PROPOSED AMENDMENT NO.-138, REY. 2.. A Safety Functions of Affected Systems / Components No plant safety systems are involved in Proposed Amendment 138, Rev. 2. All changes to Technical Specifications incorporated by this amendment are j administrative or organizational in nature, j l Effects on Safety Functions All changes to be incorporated by Proposed Amendment 138, Rev. 2 are administrative in nature and have no effect on any plant system safety function. ) Analysis of Effects on Safety Functions Subsequent to the original submittal of Proposed Amendment 138.and the ] submittal of revision 1 to Proposed Amendment 138, there have been further organization changes made. by the District, both on site and at the corporate office. These changes have resulted in both revised and new position titles 4 and organization groups. Revision 2 to Proposed Amendment 138 consists of the changes listed in the DESCRIPTION.section of the Safety. Analysis. All of.the changes are administrative or organizational in nature, and none have an effect on the functioning of any plant safety system. Most of the listed changes are editorial in nature or reorganize the Technical Specifications into a more logical context. However, the eight items discussed below involve changes in content or stated responsibilities. Item 5 elevates the position of the person responsible. for the overall-management of Rancho Seco facility from the Manager of Nuclear Operations to the Chief Executive Officer, Nuclear. :This change upgrades the authority and ~ qualifications of the individual ~ responsible for the operation of the facility, and the health and safety of the public. Item 7 places the authority to deviate from the required staffing and shift coverage (discussed in Section 6.2.2 of Technical Specifications) in the AGM, Nuclear Power Production, or his/her designee. Once again, this position (AGM) requires a higher level of qualification and authority than the individual who is currently listed as having authority to deviate from the listed guidelines. This change will enhance the safety of the conduct of operations throughout the Rancho Seco facility. Item 8 changes Table 6.2-1, Shift Crew Personnel and Licensing Requirements. This change is a regulatory requirement which brings Rancho'Seco in accord with 10 CFR 50.54(m)(2)(1). This table specifies the control room staffing, levels (for licensed personnel and STAS only) for the reactor modes of ColdL ' Shutdown and Above Cold Shutdown. This change is an enhancement to plant safety. L

,e ATTACHMENT IV (CONT.) FACILITY CHANGE SAFETY ANALYSIS PAGE 5 0F 6 PROPOSED AMENDMENT NO. 138, REY. 2 Analysis of Effects on Safety Functions (Cont.) Item 11 changes Specification 6.5.1, Plant Review Committee (PRC) to reflect the overall increase in authority incorporated throughout Section 6.0 of Technical S 3ecifications. This is demonstrated in the requirement for the PRC to advise t1e AGM, Nuclear Power Production, rather than the Manager of Nuclear Operations, as is done presently. Members of the PRC shall be personnel filling positions within the Nuclear Organization shown in Fig. 6.2-2 and others, all of whom meet or exceed the minimum qualifications of ANSI N18.1-1971. The PRC Chairman shall be appointed by AGM, Nuclear Power Production. An alternate list shall also be approved by AGM, Nuclear Power Production. Item 12 changes Specification 6.5.2, Management Safety Review Committee (MSRC) to reflect the overall increase in authority incorporated throughout Section 6.0 of Technical Specifications. This is demonstrated in the proposed membership of the MSRC. Presently, the MSRC consists of supervisors or managers from the various departments at Rancho Seco; Proposed Amendment No. 138 will require MSRC membership to be made up of manager levels or above. Other personnel may also serve as MSRC members, however, they must meet or exceed the minimum qualifications of ANSI /ANS 3.1-1981. The MSRC Chairman shall be appointed by the CEO, Nuclear. The responsibility for the performance of audits of facility activities shall be under the cognizance of the Director, Quality Assurance, Nuclear instead of the MSRC. This is shown i in the new Section 6.5.4, Audits. The MSRC shall review the QA program and perform an oversight review of the QA Audit Program. This change in the QA i program requires a change to Appendix 128 of the USAR. 10 CFR 50.54(a)(3) requires a report to the NRC concerning this USAR change, and approval by the NRC before implementation. Item 14 adds Section 6.5.3, Technical Review and Controls. Section 6.5.3 iiescribes a new review and approval process for procedures, tests and experiments, plant modifications, and any plant activity which affects nuclear safety. The introduction of this rigorous review and approval by the AGM, Nuclear Power Production or his/her designated alternate (at least department manager) will enhance the safety of operations throughout the Rancho Seco facility. The section also specifies that the individuals performing the stated reviews are qualified to meet, or exceed, the requirements of Section 4.4 of ANSI 18.1, 1971. Item 20 adds a section which defines the requirements for environmental reports. This section is currently in Appendix B to Technical Specifications. Proposed Amendment 104 deletes Appendix B. This section includes requirements specifying:

1) when a report is required, 2) the contents of the report, and 3) to whom the reports are to be submitted.

Item 21 defines more clearly the method by which changes to the radioactive waste systems (liquid, gaseous, and solid) shall be made. This includes the information to be sent to the Commission discussing each change at each annual update of the USAP. \\

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J ATTACHMENT IV (CONT.)

I <', FACILITY CHANGE SAFETY ANALYSIS PAGE 6'0F 6 PROPOSED AMENDMENT NO. 138, REY. 2 h Analysis of Effects on Safety Functions (Cont.) The eight items which change the content or responsibilities in Sectior,6.0 of Technical Specifications promote and enhance the safety of the conduct of l operations throughout the facility. Summary k Proposed Amendment 138, Revision 2 makes changes to Section 6.0, i ADMINISTRATIVE CONTROLS, of Rancho Seco Technical Specifications. D)ght of the listed changes have an fmpact upon the responsibilities or authority as delineated in Section 6.0 of Technical Specifications. New positions, as 1 shown in the Proposed Amendment, are more reflective of the broader management j oversight with respect to Rancho Seco. 1 The Proposed Amendment affects USAR Section 12.2, Organization and Responsibility, and Section 12.6, Review and Audit of Operations. i Additionally, the Proposed Amendment impacts Appendix 128 (Quality Assurance 9 l Program), which requires a report on the changes to the qualf.ty assurance program to be submitted to the NRC for approval of the change prior to implementation. T 1 The Proposed Amendment increases control room, licensed operator staffing levels to meet the requirements to 10 CFR 50.54(m)(2)(i). The other changes discussed in the analysis increase the level of reporting requirements of the. a subject administrative positions and committees or are changes which arc editorial in nature. The Proposed Amendment does not increase the probability of occurrence or ] consequences of a previously evaluated accident since the levei. of authority,., of the positions or committees addressed in Section 6.0 are increased. I l 3r The probability of an accident of a different type than previously naluated ( is not created since the level of authority and responsibility of all rJ individuals making up the PRC and MSRC are increased. l l The Proposed Amedment does not reduce the margin of safety aEdefined in l Technical Specifications since all levels of oversight of conduct of 1 operations at Rancho Seco are increased. / ' / ' { 'i Therefore, the implementation of the proposed changes to Technical l 1 Specifications as listed in Proposed Amendment 138, Revisio3(2 does not introduce an Unreviewed Safety Question. l i I i t< '( v> 0 1 d-1 5 1 A

1 3 t y' ./3 . ATTACHMENT V NO SIGNIFICANT PAZARDS CONSIDERATION PAGE 1 0F 1

pu r.

Proposed Amendment No.e138 was originally submitted to the NRC for approval on i October 18, 1985. Subsequently, it was superseded by the submittal of Proposed-Amendment No. 138, Rev. I dated August 13, 1986. The present submittal, Proposed Amendment,No. 138, Rev. 2, incorporates further changes to management staffing at the lancho Seco Nuclear Generating Station and the corporate office which were made'6yjthe District subsequent to the Rev. 1 submittal. Proposed Agendment No. 139, Rev. 2 consists of many changes to Section'6, p~ Administrative Centrols, of the Rancho Seco Technical Specifications. Most of these. result in higher levels of management review and approval d responsibilities on issues affecting safe. operation and reliability of the lk i j plant. Further changes assign plant auditing responsibilities to the Quality Assurance Department, with audit report reviews being made the responsibility of the Management Safety Review Committee. ) Basically, the proposed changes increase the level of experience and' qualifications of management personnel and of members of the review committees, I i.e., the Plant Review Committee and the Management Safety Review Committee. { i The District has reviewed the proposed changes to Section 6 of.the Technical J Specifications against each of the criterion of 10 CFR 50.92, and concluded that plant operation with the above administrative changes would not: , b '(ncr' ease the probability of occurrence or consequences of a previously 1 evaluated accident, because the level of qualifications and experience of g the positions or corrittees responsible for plant safety are increased. P I 2. Create the propabHitpof an accident of a different type than previously evaluated, because the safe operation of the plant is enhances by the 1 l higher level of management qualifications and experience. 3. Significantly reduce any margin of safety, because all levels of oversight of conduct of operation at Rutho Seco are increased. / On the basis of the above, the District concludes that the proposed changes do not constitute a significant haard, or in any way endanger the health and safety of the public. 'h

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