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Proposed Tech Specs Re Administrative Controls for Util Organization & Independent Safety Engineering Group
	ML20246L895
Person / Time
Site:	Limerick
Issue date:	07/11/1989
From:	; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	;
Shared Package
ML20246L870	List: ML20246L864; ML20246L877; ML20246L895;
References
	NUDOCS 8907190024
	Download: ML20246L895 (11)
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t-.g ATTACHMENT'2-i l

LIMERICK-GENERATING STATION UNIT l' Ibcket No. 50-35 9

License No. NPF-39 TECHNICAL ~ SPECIFICATION CHANGES List of Attached Pages xxv1 6-l' 6-2 6-3 6-4 6-6 6-9 6-11 6-12 6-22 l

8907190024 890711' 1

PDR ADOCK 05000352 P

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4 t-INDEX t-ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RESPONSIBILITY...................................................

6-1 6.2 ORGANIZATION.....................................................

6-1 6.2.1 0ffsite......................................................

6-1 Figure 6.2.1-1 DELETED.................................

6-3 6.2.2 Unit Staff....................................................

6-1 Figure 6.2.2-1 DELETED.................................

6-4 Table 6.2.2-1 Minimum Shift Crew Composition.............................

6-5 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP Function.....................................................

6-6 Composition..................................................

6-6 Responsibilities.............................................

6-6 Records......................................................

6-6 6.2.4 SHIFT TECHNICAL ADVIS0R......................................

6-6 6.3 UNIT STAFF QUALIFICATIONS........................................

67 6.4 TRAINING.........................................................

67 6.5 REVIEW AND AUDIT 6.5.1 Plant Operations Review Committee (PORC)

Function......................................................

6-7 Composition..................................................

6-7 Alternates.....................

6-7 1

i Meeting Frequency............................................

6-7 Quorum.......................................................

6-7 Responsibilities.............................................

6-8 Records......................................................

6-9 LIMERICK - UNIT 1 xxvi m___ _ _ _ _ _ _. _. _

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,s 6.0; ADMINISTRATIVE CONTROLS

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- 6.11 RESPONSIBILITY'Y m

, 6.lil ?The Plant Manager shall be responsible for overall unit operation and shall u

- 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.

y

- A management directive to this effect, signed by the Vice President, Limerick Generating Station shall be reissued to all station personnel on an annual basis.

6.2 ORGANIZATION-6.2.1 Offsite'and Onsite Organizations-Onsite and offsite organizations shall be. established for unit operation and corporate management..respectively. The onsite and offsite organizations shall

,i include the positions.for activities affecting the safety of the nuclear power-plant.

a.

Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organizational

_ positions..These relationships shall be documented and updated, as appropriate, in the. form of organizational charts, functional

. descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. -These requirements shall be documented in the Limerick Quality Assurance Plan.

b.

The Plant Manager shall be responsible for overall unit safe operation

.and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

c. -

The Vice President, Limerick Generating Station shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d..

'The individuals who train the operating staff and those who carry cut health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

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LIMERICK - UNIT 1 6-1

. Amendment No. 10

.UNITGiAFF

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6.2.2'[Thefacility.organizationshallbesubjecttothefollowing:

L a.

Each on duty shift-shall be composed of at least the minimum shift crew composition shown in Table 6.2.2-1; b.

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

In addition, while the unit is in OPERATIONAL CONDITION 1, 2, or 3, at least one' licensed Senior Operator shall'be in the control room; c.

A Health ~ Physics Technician

shall be on site;when fuel is.in the reactor; l d. :

ALL CORC ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation;-

e.

A site fire trigade of at least five members shall be maintained on site at all timesv.

The fire brigade shall not include the Shift Superintendent, the Shift Technical Advisor, nor the two other members of the minimum sh'ft crew necessary for safe shutdown of the unit and any personnel-requiced for other essential functions during a fire emergency; and f.

Administrative pro edures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions (e.g.,

licensed Senior Oper'itors, licensed Operators, health physicists, auxiliary operators, and key maintenance personnel).

-Adequate shift coveragt shall be maintained without routine heavy use of overtime. The objectivt shall be to have operating personnel work a normal 8-hour day, 40-hotr week while the unit is operating. However, in the event.that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major unit modifications, on a temporary basis the following guidelines shall be followed:

1.

An individual should not ce permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time.

2.

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

3.

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

4.

'Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

LIMERICK - UNIT 1 6-2 Amendaent No. 10

' UNIT STAFF.

Any deviation fromLthe above guidelines shall be authorized by the Plant Manager or the Superintendent Operations, (for operating personnel) or-the Superintendent-Maintenance / Instrumentation and Controls (for key.

maintenance and instrument'and control personnel), or the Superintendent-Plant Services (for chemistry and health physics personnel) or.the Superintendent-Technical (for technical personnel), or the Superintendent-Modifications (for construction personnel) or their designee 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 shall be reviewed monthly by the Plant Manager, or the appropriate superintendents of their designees to assure that excessive hours have not been assigned.

Routine deviation from the above, guidelines is not authorized.

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ,.in order to t

accommodate unexpected absence, provided immediate action is taken to fill-the required positions.

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LIMERICK - UNIT 1 6-3 Amendment No. 10 he_m_.-_--_-____-_A_

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LIMERICK - UNIT 1 6-4 Amendment No. 10

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ADMINI{TRATIVECONTROLS l

i 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

FUNCTION l

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

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procedures, equipment modifications, maintenance activities, operations activities, or other means of improving unit safety. Such recommendations shall be submitted through the Gen:ral Manager-Nuclear Quality Assur9.nce to the Executive Vice President-Nuclear.

COMPOSITION l

6.2.3.2 The Limerick ISEG shall be composed of at least five, dedicated, full-time engineers, including the ISEG Supervisor, located onsite.

Each shall have a bachelor's degree in engineering or related science and at least two years professional level experience in his or her field. The Limerick ISEG Supervisor shall have at least six years of experience in the nuclear field. The LGS ISEG reports to the General Manager -

Nuclear Quality Assurance.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaini.ng surveillance of unit activities to provide independent verification

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

RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to the General Manager - Nuclear Quality Assurance.

g 6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to Shift Supervision in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to 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.

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for comparable positions, except for the Senior Health Physicist who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

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

Not responsible for sign-off function.

LIMERICK - UNIT 1 6-6 Amendment No. 10 l

y 1 ADMINISTRATIVE CONTROLS.

RESPONSIBILITIES l(Continued).

Provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Vice. President. Limerick c.

. Generating Station and the Nuclear Review Board of-disagreement between the PORC~

and the Plant Manager; however, the Plant Manager.shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1.:

RECORDS'

,6.5.1.8 The PORC shall maintain written minutes of each PORC meeting that, at a minimum,.

. document the results of all PORC activities performed under the responsibility provisions of.

these Technical Specifications. Copies shall be provided to the Vice President, Limerick Gennrating Station, Plant Manager, and the Nuclear Review Board.

6.5.2 NUCLL'AR' REVIEW BOARD (NRB)

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

za.

' Nuclear power plant operations, 1b.

Nuclear engineering.

c.

. Chemistry and radiochemistry,

~.

Metallurgy, d

e.

Instrumentation and control, f.

Radiological safety, g.

Mechanical and electrical engineering, and i'

h.

Quality assurance practices.

The NRB shall report to and advise the Executive Vice President - Nuclear on those areas of responsibility in Specifications 6.5.2.7 and 6.5.2.8.

COMPOSITION 6.5.2.2. The Chairman, members, and alternates of the NRB shall be app the Executive.Vice President - Nuclear, and shall have an academic degree in an engineering or physical' science field; and in addition, shall have a minimum of 5 years technical experience, of which a minimum of 3 years shall be in one or more areas given in specification 6.5.2.1.

The NRB shall be composed of no less than eight and no more than 12 members.

The members and alternates of the NRB will be competent in the area of Quality Assurance practice and cognizant of the Quality Assurance requirements of 10 CFR Part 50, Appendix B.

' Additionally, they will be cognizant of the corporate Quality Assurance Program and will have the corporate Quality Assurance organization available to them.

LIMERICK - UNIT 1 6-9 Amendment No. 10

t ADMINISTRATIVE CONTROLS

REVIEW (Continued) 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 1.

Reports and meeting minutes of the PORC.

AUDITS' 6.5.2.8 Audits of unit activities shall'be performed under the cognizance of the NRB. These audits shall encompass:

a.

The conformance of unit operation to provisions contained within'the Technical Specifications and applicable license conditions at least once per 12 months;-

b. -

The performance, training and qualifications of the entire unit staff at least once per 12 months; The results of actions taken to correct deficiencies occurring'in unit c.

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 Par 50, at least once per'24' months; The Emergency Plan and implementing procedures at least once per 12 e.

months.

f.

The Security Plan and implementing procedures at least once per 12 months.

g.

Any other area of unit operation considered appropriate by the NRB cr the Executive Vice President - Nuclear.

h.

The Fire Protection Program and implementing procedures at least once per 24 months.

i.

An independent-fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

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 36 months.

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LIMERICK - UNIT 1 6-11 Amendment No. 10 l

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ADMINISTRATIVE CONTROLS zAUDITS (Continued) k.

The radiological environmental monitoring program and the results thereof at;1 east once per 12 months.

' 1.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months, The PROCESS CONTROL PROGRAM and implementing procedures at least once per m.

24 months.

The performance of activities required by the Quality Assurance Progrem n.

to meet the criteria of Regulatory Guide 4.15, December, 1977, at least once per 12 months.

RECORDS

~6.5.2.9 Records of NRB activities shall be prepared, approved, and distributed as indicated below:

Minutes of each NRB meeting shall be prepared, approved, and forwarded to-a.

the Executive Vice President - Nuclear within 14 days following each l

meeting.

b.

Reports of reviews encompassed by Specification 6.5.2.7 shall be prepared, approved, and forwarded to the Executive Vice President -

Nuclear within 14 days following completion of the review.

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

the Corporate Officer (s) and to the management positions responsible for l

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:

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

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

Each REPORTABLE EVENT shall be reviewed by the PORC and submitted to the NRB, Plant Manager and the Vice President, Limerick Generating Station.

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

a.

-The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The Vice President, Limerick Generating Station, Plant Manager, and the NRB shall be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

LIMERICK - UNIT 1 6-12 Amendment No. 10 a~-x------

_-a.-

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l J.S ADMINISTRATIVE ' CONTROLS.

t.

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PROCESS CONTROL PROGRAM (Continued) 2.

A determination that the change did not reduce.the overall conformance of the solidified waste product to existing criteria for solid wastes; and 3.

Documentation of the fact.that the change has been reviewed and found acceptable by the PORC.

b.

Shall become effective upon review and acceptance by the PORC.

6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation.

6.14.2 Licensee-initiated changesLto the ODCM:

i a.

Shall be' submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made effective. This submittal shall contain:

1.

Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information.

Information submitted should consist of a package of those pages of the ODCM to be changed with each page numbered and provided with an approval and date box, together with appropriate analyses'or evaluations justifying the change (s);

2.

A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and 3.

Documentation of the fact that the change has been reviewed and g

found acceptable by the PORC.

I b.

Shall become effective upon review and acceptance by the PORC.

l 6.15 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS 6.15.1 Licensee-initiated major changes to the radioactive waste systems (liquid, gaseous, and solid):

a.

Shall be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change was made effective.

The discussion of each change shall contain:

1.

A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; LIMERICK - UNIT 1 6-22 l

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ML20246L895

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