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Enclosure 2 - Volume 16 - St. Lucie Plant, Units 1 and 2, Improved Technical Specifications Conversion ITS Chapter 5.0 Administrative Controls, Revision 0
	ML21265A301
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Site:	Saint Lucie
Issue date:	09/15/2021
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ENCLOSURE 2 VOLUME 16 ST. LUCIE PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 5.0 ADMINISTRATIVE CONTROLS Revision 0

LIST OF ATTACHMENTS

1. ITS Section 5.1, Responsibility

2. ITS Section 5.2, Organization

3. ITS Section 5.3, Unit Staff Qualifications

4. ITS Section 5.4, Procedures

5. ITS Section 5.5, Programs and Manuals

6. ITS Section 5.6, Reporting Requirements

7. ITS Section 5.7, High Radiation Area

8. Relocated/Deleted Current Technical Specifications (CTS)

ATTACHMENT 1 ITS Section 5.1, Responsibility

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

A01 The plant manager or his designee ITS 5.1 ITS shall approve, prior to implementation, 6.0 ADMINISTRATIVE CONTROLS each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.2 6.1 RESPONSIBILITY M01 5.1.1 6.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

the 5.1.2 6.1.2 The Shift Supervisor shall be responsible for the control room command function.

During any absence of the Shift Supervisor from the control room while either unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) L01 license shall be designated to assume the control room command function. During any absence of the Shift Supervisor from the control room while both units are in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function. the unit is 6.2 ORGANIZATION See ITS 5.2 ONSITE AND OFFSITE ORGANIZATION 6.2.1 An onsite and an offsite organization shall be established for unit operation and corporate management. This onsite and offsite organizations shall 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 from the highest management levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organizational charts.

These organizational charts will be documented in the Quality Assurance Topical Report and updated in accordance with 10 CFR 50.54(a)(3).

The plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the UFSAR or the Quality Assurance Topical Report.

b. A specified corporate officer shall be responsible for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

c. The plant manager shall be responsible for overall safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant.

d. Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.

e. Although health physics individuals may report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the radiation protection manager shall have direct access to that onsite individual having responsibility for overall unit management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures.

ST. LUCIE - UNIT 1 6-1 Amendment No. 25, 69, 99, 107, 126, 146, 178, 199, 203 , 217

A01 The plant manager or his designee ITS 5.1 ITS shall approve, prior to implementation, 6.0 ADMINISTRATIVE CONTROLS each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.2 6.1 RESPONSIBILITY M01 5.1.1 6.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

the 5.1.2 6.1.2 The Shift Supervisor shall be responsible for the control room command function.

During any absence of the Shift Supervisor from the control room while either unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) L01 license shall be designated to assume the control room command function. During any absence of the Shift Supervisor from the control room while both units are in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function. the unit is 6.2 ORGANIZATION See ITS 5.2 ONSITE AND OFFSITE ORGANIZATION 6.2.1 An onsite and an offsite organization shall be established for unit operation and corporate management. This onsite and offsite organization shall 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 from the highest management levels through intermediate levels to and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organizational charts.

These organizational charts will be documented in the Quality Assurance Topical Report and updated in accordance with 10 CFR 50.54(a)(3).

The plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the UFSAR or the Quality Assurance Topical Report.

b. A specified corporate officer shall be responsible for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

c. The plant manager shall be responsible for overall unit safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant.

d. Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.

e. Although health physics individuals may report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the radiation protection manager shall have direct access to that onsite individual having responsibility for overall unit management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures.

ST. LUCIE - UNIT 2 6-1 Amendment No. 13, 29, 45, 47, 65, 85, 121, 146, 150, 167

DISCUSSION OF CHANGES ITS 5.1, RESPONSIBILITY ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2 Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1432, Rev. 5.0, "Standard Technical Specifications - Combustion Engineering Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 6.1.1 provides requirements related to responsibility of the plant manager but does not contain any information concerning the plant managers (or designees) role in plant activities that affect nuclear safety. ITS 5.1.1 requires the plant manager or his designee to approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety. This changes the CTS by requiring the plant manager or his designee to approve certain activities to systems and equipment, prior to implementation, that affect nuclear safety.

The purpose of CTS 6.1.1 is to provide specific responsibilities for the plant manager. The proposed change adds a requirement for the plant manager (or his designee) to approve, prior to implementation, proposed tests, experiments, and modifications to systems or equipment that affect nuclear safety. The addition of this responsibility will not alter any of the existing responsibilities. The requirement is being added to ensure the plant manager is cognizant of those activities to plant systems or equipment that can potentially affect nuclear safety.

This change is designated as more restrictive because it adds an additional responsibility for the plant manager in the administrative controls chapter of the ITS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 6.1.2 requires an individual with an active Senior Reactor Operator (SRO) license to provide control room command function during any absence of the Shift Supervisor from St. Lucie Unit 1 and Unit 2 Page 1 of 2

DISCUSSION OF CHANGES ITS 5.1, RESPONSIBILITY the control room while either unit is in MODE 1, 2, 3, or 4. An individual with an active Reactor Operator (RO) license may also assume the control room command function during any absence of the Shift Supervisor from the control room while both units are in MODE 5 or 6. ITS 5.1.2 provides similar requirements except an individual with an active RO license may assume the control room command function during the absence of the Shift Supervisor while the unit associated with the control room is in MODE 5 or 6 irrespective of the operational status of the other unit. This changes the CTS by relaxing the control room command function requirement from requiring an SRO to assume these responsibilities while either unit is in MODE 1, 2, 3, or 4 to requiring the SRO to assume the control room command function only when the associated unit is in MODE 1, 2, 3, or 4 and allowing the RO to assume these responsibilities when the unit associated with the control room is in MODE 5 or 6.

The purpose of CTS 6.1.2 is to ensure compliance with the 10 CFR 50.54(m)(iii) requirement that, when a unit is in an operational mode other than cold shutdown or refueling, a person holding a senior operator license for the unit is present at the controls at all times and that when the unit is fueled, including cold shutdown and refueling operational modes, either a senior licensed operator or a licensed operator is present at the controls at all times. Each PSL unit is controlled from a separate control room. The CTS requirement is written for a two unit site with a common control room to ensure an SRO maintains the control room command function when either unit is in MODES 1, 2, 3, and 4. However, with separate and independent control rooms, the assignment of the control room command function is based on the operational status of the associated unit and is irrespective of the operational status of other unit.

This change is acceptable because the ITS continues to assure that a senior licensed operator (i.e., Shift Supervisor or SRO) maintains control room command function in the control room when the associated unit is in MODE 1, 2, 3, or 4 and either a senior licensed operator or a licensed operator (i.e., RO) maintains control room command function in the control room when the associated unit is shutdown and still fueled (i.e., in MODES 5 and 6). Therefore, ITS 5.1.2 will continue to satisfy the requirements of 10 CFR 50.54(m)(iii).

Additionally, this change does not alter the minimum emergency response organizational requirements of the PSL emergency plan and therefore, does not impact PSL compliance with 10 CFR 50.45, Emergency plan, or 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. This change is designated as less restrictive because less stringent requirements are being applied in the ITS than were applied in the CTS.

St. Lucie Unit 1 and Unit 2 Page 2 of 2

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 6.1 5.1 Responsibility

REVIEWER'S NOTES------------------------------------------------

1. Titles for members of the unit staff shall be specified by use of an overall statement referencing an ANSI Standard acceptable to the NRC staff from which the titles were obtained, or an alternative title may be designated for this position. Generally, the first method is preferable; however, the second method is adaptable to those unit staffs requiring special titles because of unique organizational structures. 2

2. The ANSI Standard shall be the same ANSI Standard referenced in Section 5.3, Unit Staff Qualifications. If alternative titles are used, all requirements of these Technical Specifications apply to the position with the alternative title as apply with the specified title.

Unit staff titles shall be specified in the Final Safety Analysis Report or Quality Assurance Plan. Unit staff titles shall be maintained and revised using those procedures approved for modifying/revising the Final Safety Analysis Report or Quality Assurance Plan.

6.1.1 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

DOC M01 The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

shift supervisor 3

6.1.2 5.1.2 The [Shift Supervisor (SS)] shall be responsible for the control room command DOC L01 function. During any absence of the [SS] from the control room while the unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the [SS] from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

Combustion Engineering STS 5.1-1 Rev. 5.0 1 St. Lucie - Unit 1 Amendment XXX

CTS Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 6.1 5.1 Responsibility

REVIEWER'S NOTES------------------------------------------------

1. Titles for members of the unit staff shall be specified by use of an overall statement referencing an ANSI Standard acceptable to the NRC staff from which the titles were obtained, or an alternative title may be designated for this position. Generally, the first method is preferable; however, the second method is adaptable to those unit staffs requiring special titles because of unique organizational structures. 2

2. The ANSI Standard shall be the same ANSI Standard referenced in Section 5.3, Unit Staff Qualifications. If alternative titles are used, all requirements of these Technical Specifications apply to the position with the alternative title as apply with the specified title.

Unit staff titles shall be specified in the Final Safety Analysis Report or Quality Assurance Plan. Unit staff titles shall be maintained and revised using those procedures approved for modifying/revising the Final Safety Analysis Report or Quality Assurance Plan.

6.1.1 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

DOC M01 The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

shift supervisor 3

6.1.2 5.1.2 The [Shift Supervisor (SS)] shall be responsible for the control room command DOC L01 function. During any absence of the [SS] from the control room while the unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the [SS] from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

Combustion Engineering STS 5.1-1 Rev. 5.0 1 St. Lucie - Unit 2 Amendment XXX

JUSTIFICATION FOR DEVIATIONS ITS 5.1, RESPONSIBILITY

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal. Titles used in ITS Section 5.1 align with the titles used in ANSI Standard ANSI/ANS 3.1-1978, Standard for Selection and Training of Personnel for Nuclear Power Plants, and alternate titles are not used. ANSI/ANS 3.1-1978 is the same ANS Standard referenced in ITS Section 5.3 (CTS 6.3).

3. The ISTS contains bracketed information and/or values that are generic to Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

St. Lucie Unit 1 and Unit 2 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.1, RESPONSIBILITY There are no specific No Significant Hazards Considerations for this Section.

St. Lucie Unit 1 and Unit 2 Page 1 of 1

ATTACHMENT 2 ITS Section 5.2, Organization

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

A01 ITS 5.2 ITS 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

6.1.2 The Shift Supervisor shall be responsible for the control room command function.

During any absence of the Shift Supervisor from the control room while either unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the Shift Supervisor from the control room while both units are in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

5.2 6.2 ORGANIZATION See ITS 5.1 ONSITE AND OFFSITE ORGANIZATION 5.2.1 6.2.1 An oOnsite and an offsite organizations shall be established for unit operation and corporate management. Theis onsite and offsite organizations shall include the , respectively positions for activities affecting the safety of the nuclear power plant.

5.2.1.a a. Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to and

, functional descriptions including all operating organization positions. Those relationships shall be A06 of departmental documented and updated, as appropriate, in the form of organizational charts.

responsibilities and These organizational charts will be documented in the Quality Assurance LA01 relationships, and job Topical Report and updated in accordance with 10 CFR 50.54(a)(3).

descriptions for key personnel positions, or in The plant-specific titles of those personnel fulfilling the responsibilities of the A02 equivalent forms of positions delineated in these Technical Specifications shall be documented in documentation the UFSAR or the Quality Assurance Topical Report.

5.2.1.c b. A specified corporate officer shall be responsible for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

5.2.1.b c. The plant manager shall be responsible for overall safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant. ; however 5.2.1.d d. Although the iIndividuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.

5.2.1.d

e. Although hHealth physics individuals may report to any appropriate manager

however, these onsite, for matters relating to radiological health and safety of employees and individuals shall the public, the radiation protection manager shall have direct access to that LA02 have sufficient onsite individual having responsibility for overall unit management. Health freedom to ensure their physics personnel shall have the authority to cease any work activity when operational worker safety is jeopardized or in the event of unnecessary personnel radiation independence. exposures.

ST. LUCIE - UNIT 1 6-1 Amendment No. 25, 69, 99, 107, 126, 146, 178, 199, 203 , 217

A01 ITS 5.2 ITS 6.0 ADMINISTRATIVE CONTROLS 5.2 6.2 ORGANIZATION (continued)

UNIT STAFF 5.2.2 6.2.2 The unit staff organization shall meet the requirements of 10 CFR 50.54(m) and A02 include the following:

5.2.2.a a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4. A minimum of three non-licensed operators is required when both units are in MODES 5 or 6. A01 for both units total 5.2.2.b b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 6.2.2.a and 6.2.2.e 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 of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

radiation protection A03 5.2.2.c c. A health physics technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

5.2.2.d d. The operations manager or assistant operations manager shall hold an SRO license.

5.2.2.e e. An individual (Shift Technical Advisor (STA)) shall provide advisory technical A04 support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. The STA position shall be A04 manned in MODES 1, 2, 3, or 4. by use of either a dedicated STA, a Shift Supervisor who meets the qualifications for the STA as required by Technical A05 Specification 6.3.1, or an individual assigned to the unit with a Senior Reactor Operator's license who meets the qualifications for the STA as required by Technical Specification 6.3.1. If the STA position is filled by an STA qualified Shift Supervisor or dedicated STA, then the individual may fill the same position A04 on Unit 2.

ST. LUCIE - UNIT 1 6-2 Amendment No. 10, 25, 55, 69, 93, 115, 146, 177, 199, 217, 221

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 1 6-3 Amendment No. 25, 55, 62, 69, 93

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 1 6-4 Amendment No. 37, 51, 62, 69, 173, 177 , 217

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 1 6-5 Amendment No. 69, 93, 115, 126, 155, 185, 199, 208, 217

A01 ITS 5.2 ITS 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

6.1.2 The Shift Supervisor shall be responsible for the control room command function.

During any absence of the Shift Supervisor from the control room while either unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the Shift Supervisor from the control room while both units are in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

5.2 6.2 ORGANIZATION See ITS 5.1 ONSITE AND OFFSITE ORGANIZATION 5.2.1 6.2.1 An oOnsite and an offsite organizations shall be established for unit operation and corporate management. Theis onsite and offsite organizations shall include the , respectively positions for activities affecting the safety of the nuclear power plant.

5.2.1.a a. Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to and

, functional descriptions including all operating organization positions. Those relationships shall be A06 of departmental responsibilities and documented and updated, as appropriate, in the form of organizational charts.

LA01 relationships, and job These organizational charts will be documented in the Quality Assurance descriptions for key Topical Report and updated in accordance with 10 CFR 50.54(a)(3).

personnel positions, or in The plant-specific titles of those personnel fulfilling the responsibilities of the A02 equivalent forms of positions delineated in these Technical Specifications shall be documented in documentation the UFSAR or the Quality Assurance Topical Report.

5.2.1.c b. A specified corporate officer shall be responsible for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support in the plant so that continued nuclear safety is assured.

5.2.1.b c. The plant manager shall be responsible for overall unit safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant. ; however 5.2.1.d d. Although the iIndividuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.

5.2.1.d

e. Although hHealth physics individuals may report to any appropriate manager

however, these onsite, for matters relating to radiological health and safety of employees and individuals shall the public, the radiation protection manager shall have direct access to that LA02 have sufficient onsite individual having responsibility for overall unit management. Health freedom to ensure their physics personnel shall have the authority to cease any work activity when operational worker safety is jeopardized or in the event of unnecessary personnel radiation independence. exposures.

ST. LUCIE - UNIT 2 6-1 Amendment No. 13, 29, 45, 47, 65, 85, 121, 146, 150, 167

A01 ITS 5.2 ITS 6.0 ADMINISTRATIVE CONTROLS 5.2 6.2 ORGANIZATION (Continued)

UNIT STAFF A02 5.2.2 6.2.2 The unit staff organization shall meet the requirements of 10 CFR 50.54(m) and include the following:

5.2.2.a a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4. A minimum of three non-licensed operators is required when both units are in MODES 5 or 6. A01 for both units total 5.2.2.b b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 6.2.2.a and 6.2.2.e 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 of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements. A03 radiation protection 5.2.2.c c. A health physics technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

5.2.2.d d. The operations manager or assistant operations manager shall hold an SRO license.

5.2.2.e e. An individual (Shift Technical Advisor (STA)) shall provide advisory technical A04 support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. The STA position shall be A04 manned in MODES 1, 2, 3, or 4 by use of either a dedicated STA, a Shift Supervisor who meets the qualifications for the STA as required by Technical A05 Specification 6.3.1, or an individual assigned to the unit with a Senior Reactor Operator's license who meets the qualifications for the STA as required by Technical Specification 6.3.1. If the STA position is filled by an STA qualified Shift Supervisor or dedicated STA, then the individual may fill the same A04 position on Unit 1.

ST. LUCIE - UNIT 2 6-2 Amendment No. 29, 55, 65, 93, 128, 146, 156, 167, 171

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 2 6-3 Amendment No. 13, 29

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 2 6-4 Amendment No. 5, 13, 29

A01 ITS 5.2 DELETED ST. LUCIE - UNIT 2 6-5 Amendment No. 113, 167

DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2 Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 5.0, "Standard Technical Specifications - Combustion Engineering Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 6.2.1 requires, in part, to update the organizational charts documented in the Quality Assurance Topical Report (QATR) in accordance with 10 CFR 50.54(a)(3). CTS 6.2.2 requires, in part, for the unit staff organization to meet the requirements of 10 CFR 50.54(m). The ITS does not include these statements.

This changes the CTS by removing the duplicate requirement to comply with the requirements of 10 CFR 50.54. Each PSL facility operating license requires the licensee to be subject to the conditions specified in 10 CFR Section 50.54.

Therefore, it is unnecessary to state organizational charts in the QATR be updated in accordance with 10 CFR 50.54(a)(3) and the unit staff meet the requirements of 10 CFR 50.54(m) because it is duplicative. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 6.2.2.c requires, in part, that a health physics technician be on site when fuel is in the reactor. ITS 5.2.2.c requires a radiation protection technician to be on site when fuel is in the reactor. This changes the CTS by modifying the generic title of health physics technician with the more appropriate generic title of radiation protection technician. The purpose of CTS 6.2.2.c is to ensure there is an individual responsible for radiation protection on site when fuel is in the reactor. This change is consistent with the generic position in the ISTS and the current plant-specific title for these technicians. The generic title also aligns with the position title provided in ANSI/ANS 3.1-1978, American National Standard for Selection and Training of Nuclear Power Plant Personnel. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 6.2.2.e requires an individual (Shift Technical Advisor (STA)) to provide advisory technical support to the unit operations shift crew, specifically be manned in MODES 1, 2, 3, or 4, and if the STA position is filled by an STA qualified Shift Supervisor or dedicated STA, then the individual may fill the same position on both units. ITS 5.2.2.e requires an individual to provide advisory technical support to the unit operations shift crew but is revised to eliminate reference to the STA position, when the position must be manned, and the details of who may fill STA role for both units. This changes the CTS by eliminating the inference that the STA role is a separate shift crew position instead of a function.

The purpose of the CTS requirement is to ensure engineering expertise is available on shift to provide advisory technical support. NRC Generic Letter St. Lucie Unit 1 and Unit 2 Page 1 of 4

DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION 86-04 Policy Statement on Engineering Expertise on Shift, promulgated the policy statement regarding engineering expertise on shift and established the requirements for eliminating the separate STA position. The NRC policy statement offers the licensees two options for meeting the NUREG-0737, Clarification of TMI Action Plan Requirements, Enclosure 3, Item I.A.1.1 requirement regarding engineering expertise on shift and meeting licensed operator staffing requirements pursuant to 10 CFR 50.54(m)(2). Option 1 provides for elimination of the separate STA position by allowing licensees to combine one of the required SRO positions with the STA position into a dual-role (SRO/STA) function. Option 2 allows a licensee to continue use of an NRC-approved STA program while meeting licensed operator staffing requirements.

Per the policy statement, the Commission encourages licensees to move toward the dual-role (SRO/STA) function, with the eventual goal of the shift supervisor serving in the dual role. Additionally, Item I.A.1.1 of NUREG-0737, Enclosure 3, allows the individual providing advisory technical support function to serve more than one unit at a multiunit site if qualified to perform the advisor function for the various units.

ITS 5.2.2.e eliminates the title of "Shift Technical Advisor (STA)," because the on shift advisory technical support function may be fulfilled by one or more of the other on-shift individuals. This change is necessary so that it does not imply that the STA and the shift supervisor must be different individuals. As a result of eliminating the STA position, it is unnecessary to state when the STA position must be manned. In addition, Item I.A.1.1 of NUREG-0737, Enclosure 3, allows the individual providing advisory technical support to serve more than one unit at a multiunit site if qualified to perform the advisor function for the various units and there is no regulatory requirement that conflicts with this statement. Therefore, it is unnecessary to restate this as an allowance in the Technical Specifications and does not prevent PSL from utilizing this allowance. This change is designated as administrative because an individual with engineering expertise (i.e., dedicated individual or dual role individual) will continue to be required on shift and this same individual may provide support to both units as allowed by NUREG-0737. Therefore, the change does not result in technical changes to the CTS.

A05 CTS 6.2.2.e, in part, includes a description of who specifically may provide advisory technical support to the unit operations shift crew: either a dedicated STA, a Shift Supervisor who meets the qualifications for the STA as required by Technical Specification 6.3.1, or an individual assigned to the unit with a Senior Reactor Operator's license who meets the qualifications for the STA as required by Technical Specification 6.3.1. ITS 5.2.2.e requires an individual to provide advisory technical support to the unit operations shift crew but is revised to eliminate the details of who is qualified to assume the duties. This changes the CTS by eliminating details regarding the individual assigned to provide technical advisory support to the unit operations shift crew.

The purpose of the CTS requirement is to ensure engineering expertise is available on shift to provide advisory technical support. NRC Generic Letter 86-04, promulgated the policy statement regarding engineering expertise on shift and established the requirements for eliminating the separate STA position. The NRC policy statement allowed for the elimination of the separate STA position by St. Lucie Unit 1 and Unit 2 Page 2 of 4

DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION allowing licensees to combine one of the required SRO positions with the STA position into a dual-role (SRO/STA) function. The policy statement indicates that either a dedicated STA, a Shift Supervisor who meets the qualifications or an individual assigned to the unit with a Senior Reactor Operator's license who meets the qualifications may serve the dual-role function.

It is an ITS convention to not include cross-references to comply with other Specification requirements. Compliance with other Specifications is understood.

Compliance with CTS 6.3.1 (ITS 5.3.1) is required and referencing this Specification is unnecessary. Refer to ITS 5.3, Unit Staff Qualifications, for changes to CTS 6.3.1 requirements. This change is designated as administrative because an individual with engineering expertise and appropriate qualifications will continue to be required on shift. Therefore, the change does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 6.2.1.a requires, in part, to document the organizational charts in the QATR. ITS 5.2.1.a does not include this requirement. The requirement that organizational charts be documented in the QATR is moved to the Updated Final Safety Analysis Report (UFSAR). This changes the CTS by moving a requirement to the UFSAR. The removal of this requirement from the Technical Specifications is acceptable because this type of information is administrative and not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement to document and update, in organizational charts, the relationship of the management levels through intermediate levels to and including operating organization positions, as appropriate. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59 which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because requirements for meeting Technical Specifications are being relocated from the Technical Specifications to the UFSAR.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.2.1.e states that, although health physics individuals may report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the radiation St. Lucie Unit 1 and Unit 2 Page 3 of 4

DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION protection manager shall have direct access to that onsite individual having responsibility for overall unit management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures. ITS 5.2.1.d provides a similar requirement but does not provide procedural detail related to organizational freedom for health physics individuals (e.g., radiation manager shall have direct access to the individual having responsibility for overall unit management and health physics individuals authority to cease any work activity when worker safety is jeopardized). ITS 5.2.1.d states, in part, The individuals who carry out health physics functions shall have sufficient organizational freedom to ensure their independence from operating pressures. The procedural detail of what activities constitute operational independence for health physics individuals, including the radiation protection managers direct access to overall unit management individual, is moved to the UFSAR. This changes the CTS by moving procedural detail related to health physics individuals responsibilities to the UFSAR and replacing the information with a general statement. The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for health physics individuals to have sufficient freedom to ensure their operational independence. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59 which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None St. Lucie Unit 1 and Unit 2 Page 4 of 4

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 6.2 5.2 Organization 6.2.1 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

6.2.1.a a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the [FSAR/QA Plan], 2 Updated Final Safety Analysis Report or the Quality Assurance Topical Report 6.2.1.c b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant, 6.2.1.b c. A specified corporate officer 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 4 technical support to the plant to ensure nuclear safety, and functions 6.2.1.d d. The individuals who train the operating staff, carry out health physics, or 6.2.1.e perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 5.2.2 Unit Staff The unit staff organization shall include the following:

6.2.2.a a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

REVIEWER'S NOTE----------------------------------------

Two unit sites with both units shutdown or defueled require a total of three non-licensed operators for the two units. 3 A total of three non-licensed operators are required for both units when both units are in MODE 5 or 6.

Combustion Engineering STS 5.2-1 Rev. 5.0 1 St. Lucie - Unit 1 Amendment XXX

CTS Organization 5.2 5.2 Organization 6.2.2 5.2.2 Unit Staff (continued) 6.2.2.b b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.e 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 of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

6.2.2.c c. A radiation protection technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

6.2.2.d d. The operations manager or assistant operations manager shall hold an SRO license.

6.2.2.e

e. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Combustion Engineering STS 5.2-2 Rev. 5.0 1 St. Lucie - Unit 1 Amendment XXX

CTS Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 6.2 5.2 Organization 6.2.1 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

6.2.1.a a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the [FSAR/QA Plan], 2 Updated Final Safety Analysis Report or the Quality Assurance Topical Report 6.2.1.c b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant, 6.2.1.b c. A specified corporate officer 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 4 technical support to the plant to ensure nuclear safety, and functions 6.2.1.d d. The individuals who train the operating staff, carry out health physics, or 6.2.1.e perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 5.2.2 Unit Staff The unit staff organization shall include the following:

6.2.2.a a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

REVIEWER'S NOTE----------------------------------------

Two unit sites with both units shutdown or defueled require a total of three non-licensed operators for the two units. 3 A total of three non-licensed operators are required for both units when both units are in MODE 5 or 6.

Combustion Engineering STS 5.2-1 Rev. 5.0 1 St. Lucie - Unit 2 Amendment XXX

CTS Organization 5.2 5.2 Organization 6.2.2 5.2.2 Unit Staff (continued) 6.2.2.b b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.e 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 of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

6.2.2.c c. A radiation protection technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

6.2.2.d d. The operations manager or assistant operations manager shall hold an SRO license.

6.2.2.e

e. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Combustion Engineering STS 5.2-2 Rev. 5.0 1 St. Lucie - Unit 2 Amendment XXX

JUSTIFICATION FOR DEVIATIONS ITS 5.2, ORGANIZATION

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal. Since the PSL is a two unit site, ISTS 5.2.2.a includes an additional statement requiring a total of three non-licensed operators for both units when both units are in MODE 5 or 6 (i.e., shutdown) consistent with the CTS requirement. This requirement does not extend to when both units are defueled because the ISTS nor 10 CFR 50.54(m) require licensed operators assigned to the reactor or control room when the reactor is defueled.

Therefore, it unnecessary to require non-licensed operators when both units are defueled.

4. Grammatical correction made to the ITS to clarify ISTS 5.5.2.d includes individuals required to carry out health physics functions.

St. Lucie Unit 1 and Unit 2 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.2, ORGANIZATION There are no specific No Significant Hazards Considerations for this Section.

St. Lucie Unit 1 and Unit 2 Page 1 of 1

ATTACHMENT 3 ITS Section 5.3, Unit Staff Qualifications

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

A01 ITS 5.3 ITS 6.0 ADMINISTRATIVE CONTROLS 5.3 6.3 UNIT STAFF QUALIFICATIONS 5.3.1 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI / ANS-3.1-1978 for comparable positions, except for:

the radiation protection manager.

(1) tThe radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975,. Revision 1, (2) the Shift Technical Advisor who shall have specific training in plant design and plant operating characteristics, including transients and accidents, and any of the following educational requirements:

L01

- Bachelors degree in engineering from an accredited institution; or

- Professional Engineers (PE) license obtained by successful completion of the PE examination; or

- Bachelors degree in engineering technology from an accredited institution, including course work in the physical, mathematical, or engineering sciences, or

- Bachelors degree in physical science from an accredited institution, including LA01 course work in the physical, mathematical, or engineering sciences.

(3) the Multi-Discipline Supervisors who shall meet or exceed the following requirements:

a. Education: Minimum of a high school diploma or equivalent.

b. Experience: Minimum of four years of related technical experience, which shall include three years power plant experience of which one year is at a nuclear power plant.

c. Training: Complete the Multi-Discipline Supervisor training program.

5.3.2 6.3.2 For the purpose of 10 CFR 55.4, a licensed senior reactor operator and a licensed reactor operator are those individuals who, in addition to meeting the requirements of 6.3.1, perform the functions described in 10 CFR 50.54(m).

Specification 5.3.1 6.4 DELETED 6.5 DELETED ST. LUCIE - UNIT 1 6-6 Amendment No. 25, 37, 69, 126, 161, 173, 189, 199, 210

A01 ITS 5.3 6.0 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 1 6-7 Amendment No. 59, 69, 93, 107, 126, 158, 177, 178, 189

A01 ITS 5.3 6.0 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 1 6-8 Amendment No. 69, 72, 99, 107, 112, 115, 126, 147, 158, 177, 178, 189

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 1 6-9 Amendment No. 18, 55, 69, 88, 93, 102, 107, 178, 189

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 1 6-10 Amendment No. 18, 55, 69, 102, 177, 189

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 1 6-11 Amendment No. 25, 59, 69, 107, 140, 178, 189

A01 ITS 5.3 ADMINISTRATIVE CONTROLS 6.6 DELETED 6.7 DELETED ST. LUCIE - UNIT 1 6-12 Amendment No. 69, 93, 102, 107, 178, 189, 199, 202, 203

A01 ITS 5.3 ITS 6.0 ADMINISTRATIVE CONTROLS 5.3 6.3 UNIT STAFF QUALIFICATIONS 5.3.1 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI /

ANS-3.1-1978 for comparable positions, except for:

the radiation protection manager.

(1) tThe radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975,. Revision 1, (2) the Shift Technical Advisor who shall have specific training in plant design and plant operating characteristics, including transients and accidents, and any of the following educational requirements:

L01

- Bachelors degree in engineering from an accredited institution; or

- Professional Engineers (PE) license obtained by successful completion of the PE examination; or

- Bachelors degree in engineering technology from an accredited institution, including course work in the physical, mathematical, or engineering sciences, or

- Bachelors degree in physical science from an accredited institution, including course work in the physical, mathematical, or engineering sciences.

(3) the Multi-Discipline Supervisors who shall meet or exceed the following requirements: LA01

a. Education: Minimum of a high school diploma or equivalent.

b. Experience: Minimum of four years of related technical experience, which shall include three years power plant experience of which one year is at a nuclear power plant.

c. Training: Complete the Multi-Discipline Supervisor training program.

5.3.2 6.3.2 For the purpose of 10 CFR 55.4, a licensed senior reactor operator and a licensed reactor operator are those individuals who, in addition to meeting the requirements of 6.3.1, perform the functions described in 10 CFR 50.54(m).

Specification 5.3.1 ST. LUCIE - UNIT 2 6-6 Amendment No. 5, 49, 65, 69, 102, 113, 146, 159, 167

A01 ITS 5.3 6.0 ADMINISTRATIVE CONTROLS 6.4 DELETED 6.5 DELETED ST. LUCIE - UNIT 2 6-7 Amendment No. 13, 65, 102, 133, 146, 159

A01 ITS 5.3 6.0 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-8 Amendment No. 13, 29, 47, 65, 86, 97, 119, 121, 133

A01 ITS 5.3 6.0 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-9 Amendment No. 13, 29, 47, 53, 55, 65, 97, 119, 121, 133

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-10 Amendment No. 13, 25, 29, 45, 47, 121, 133

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-11 Amendment No. 13, 80, 119, 133

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-12 Amendment No. 47, 69, 80, 95, 121, 133

A01 ITS 5.3 ADMINISTRATIVE CONTROLS DELETED ST. LUCIE - UNIT 2 6-12a Amendment No. 69, 121, 133

DISCUSSION OF CHANGES ITS 5.3, UNIT STAFF QUALIFICATIONS ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2 Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1432, Rev. 5.0, "Standard Technical Specifications - Combustion Engineering Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 6.3.1(3) provides minimum education, experience, and training requirements for multi-discipline supervisors. ITS 5.3.1 does not include these requirements. The minimum education, experience, and training requirements for multi-discipline supervisors are moved to the Updated Final Safety Analysis Report (UFSAR). This changes the CTS by moving an administrative requirement to the UFSAR. The removal of this requirement from the Technical Specifications is acceptable because this type of information is administrative and not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains minimum qualification requirements for members of the facility staff for comparable positions as defined in ANSI/ANS-3.1-1978 or Regulatory Guide 1.8, as appropriate. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59 which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because administrative requirements in Technical Specifications are being relocated from the Technical Specifications to the UFSAR.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 6.3.1(2) provides specific training requirements and minimum educational requirements for the Shift Technical Advisor. ITS 5.3.1 does not include these requirements. This changes St. Lucie Unit 1 and Unit 2 Page 1 of 2

DISCUSSION OF CHANGES ITS 5.3, UNIT STAFF QUALIFICATIONS the CTS by deleting explicit administrative training and qualification requirements for the shift technical advisor function.

The purpose of CTS 6.3.1(2) is to ensure the individual that provides advisory technical support to the unit operations shift crew (i.e., shift technical advisor) meets minimum qualifications and training pursuant to NUREG-0737, Clarification of TMI Action Plan Requirements, Enclosure 3, Item I.A.1.1 This change is acceptable because the Florida Power & Light Company Quality Assurance Topical Report requires training for positions identified in 10CFR50.120, which includes the shift technical advisor position, be accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy for Nuclear Training that implements a systematic approach to training. The systematic approach to training process develops and maintains training programs to ensure individuals are trained and meet minimum educational requirements necessary to perform their required tasks. Therefore, an individual who provides the shift technical advisor function will continue to be adequately trained and qualified to provide engineering expertise on shift. This change is designated as less restrictive because less stringent administrative LCO requirements are being applied in the ITS than were applied in the CTS.

St. Lucie Unit 1 and Unit 2 Page 2 of 2

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Unit Staff Qualifications CTS 5.3 5.0 ADMINISTRATIVE CONTROLS 6.3 5.3 Unit Staff Qualifications

REVIEWER'S NOTE-------------------------------------------------

Minimum qualifications for members of the unit staff shall be specified by use of an overall qualification statement referencing an ANSI Standard acceptable to the NRC staff or by 2 specifying individual position qualifications. Generally, the first method is preferable; however, the second method is adaptable to those unit staffs requiring special qualification statements because of unique organizational structures.

6.3.1 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of

[Regulatory Guide 1.8, Revision 2, 1987, or more recent revisions, or ANSI 3

Standard acceptable to the NRC staff]. [The staff not covered by Regulatory Guide 1.8 shall meet or exceed the minimum qualifications of Regulations, Regulatory Guides, or ANSI Standards acceptable to NRC staff].

6.3.2 5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

ANSI/ANS-3.1-1978 for comparable positions, except for the radiation protection manager.

The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

Combustion Engineering STS 5.3-1 Rev. 5.0 1 St. Lucie - Unit 1 Amendment XXX