ML22193A080
Text
Millstone Power Station Unit 2 Safety Analysis Report Chapter 12: Conduct of Operations
Table of Contents tion Title Page ORGANIZATIONAL STRUCTURE ............................................................... 12.1-1
.1 Management and Technical Support Organization .................................. 12.1-1
.1.1 Technical Support for Operations............................................................. 12.1-1
.1.2 Organizational Arrangement..................................................................... 12.1-1
.2 Operating Organization............................................................................. 12.1-1
.2.1 Plant Organization .................................................................................... 12.1-1
.2.2 Operating Shift Crews .............................................................................. 12.1-1
.3 Qualification of Nuclear Plant Personnel ................................................. 12.1-1
.4 References................................................................................................. 12.1-1 TRAINING PROGRAM ................................................................................... 12.2-1
.1 References................................................................................................. 12.2-1 EMERGENCY PLANNING ............................................................................. 12.3-1
.1 References................................................................................................. 12.3-1 REVIEW AND AUDIT..................................................................................... 12.4-1
.1 Onsite Review........................................................................................... 12.4-1
.2 Independent Review ................................................................................. 12.4-1
.3 Audits........................................................................................................ 12.4-1
.4 Other Review Groups ............................................................................... 12.4-1
.5 References................................................................................................. 12.4-1 PLANT PROCEDURES.................................................................................... 12.5-1
.1 Administrative Procedures........................................................................ 12.5-1
.1.1 Conformance with Regulatory Guide 1.33 ............................................... 12.5-1
.1.2 Preparation of Procedures ......................................................................... 12.5-1
.1.3 Procedures................................................................................................. 12.5-1
.2 Operating and Maintenance Procedures ................................................... 12.5-3
.2.1 Control Room Operating Procedures........................................................ 12.5-3
.2.1.1 General Operating Procedures .................................................................. 12.5-3
.2.1.2 System Operating Procedures ................................................................... 12.5-3
tion Title Page
.2.1.3 Abnormal Operating Procedures .............................................................. 12.5-3
.2.1.4 Emergency Operating Procedures ............................................................ 12.5-4
.2.2 Station Procedures .................................................................................... 12.5-4
.2.2.1 Radiation Protection Procedures............................................................... 12.5-4
.2.2.2 Instrument Maintenance Instructions........................................................ 12.5-4
.2.2.3 Chemistry Procedures ............................................................................... 12.5-4
.2.2.4 Radioactive Waste System Procedures..................................................... 12.5-4
.2.2.5 Material Control Procedures ..................................................................... 12.5-4
.2.2.6 Maintenance and Modification Procedures .............................................. 12.5-5
.2.2.7 Fire Protection Procedures........................................................................ 12.5-5
.2.2.8 Special Procedures .................................................................................... 12.5-5 RECORDS ......................................................................................................... 12.6-1 PHYSICAL SECURITY PLANS...................................................................... 12.7-1
.1 References................................................................................................. 12.7-1 QUALITY ASSURANCE PROGRAM ............................................................ 12.8-1
.1 Quality Assurance Program Description (QAPD) Topical Report........... 12.8-1 DELETED BY PKG FSC MP2-UCR-2011-014............................................... 12.9-1 0 RISK INFORMED CATEGORIZATION AND TREATMENT ................... 12.10-1 0.1 introduction ............................................................................................. 12.10-1 0.2 SSC CATEGORIZATION ..................................................................... 12.10-1 0.3 SSC Treatment ........................................................................................ 12.10-2 0.3.1 Treatment of Component Categories ...................................................... 12.10-2 0.3.2 Enhanced Treatment of RISC-2 SSCs .................................................... 12.10-3 0.4 references ................................................................................................ 12.10-3
ORGANIZATIONAL STRUCTURE rmation regarding the organizational structure is presented in Section 1.0, Organization, of Quality Assurance Program Description (QAPD) Topical Report (Reference 12.1-1). With the eption given below, that information is incorporated herein by reference.
owner, holding 100 percent of the Millstone 2 nuclear plant, is Dominion Nuclear necticut, Inc.
.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION rmation regarding the management and technical support organization is presented in tion 1.0, Organization, of the QAPD Topical Report (Reference 12.1-1). That information is rporated herein by reference.
.1.1 Technical Support for Operations organization providing technical support for operations is described in Section 1.0 of the PD Topical Report (Reference 12.1-1). That information is incorporated herein by reference.
.1.2 Organizational Arrangement organizational arrangement is as described in Section 1.0 of the QAPD Topical Report ference 12.1-1). That information is incorporated herein by reference.
.2 OPERATING ORGANIZATION
.2.1 Plant Organization plant organization is as shown in Reference 12.1-1.
.2.2 Operating Shift Crews minimum shift crew composition and license requirements during all modes of operation are tained in Section 6.2 of the Technical Specifications.
.3 QUALIFICATION OF NUCLEAR PLANT PERSONNEL cation and experience requirements are established by Section 6.3 of the Technical cifications.
.4 REFERENCES
-1 Quality Assurance Program Description Topical Report.
mal training programs have been established to train and qualify the personnel who operate maintain the Millstone nuclear units. These programs are structured to fulfill the requirements training set forth in ACAD 91-015 (Reference 12.2-1). The programs are based on a Systems roach to Training and are accredited by the National Academy for Nuclear Training. Initial editation of these programs was awarded on August 21, 1986, for operator training and on ember 15, 1987, for Maintenance and Technical training. These programs are implemented the following categories of nuclear power plant personnel:
Nonlicensed Operator Reactor Operator Senior Reactor Operator Shift Manager Continuing (Requalification) Training for Licensed Personnel Shift Technical Advisor Instrument and Control Technician Electrical Maintenance Personnel Mechanical Maintenance Personnel Chemistry Technician Radiological Protection Technician Engineering Support Personnel
.1 REFERENCES
-1 ACAD 91-015, National Academy for Nuclear Training, The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry.
Staff approved Millstone Nuclear Power Station Emergency Plan (Reference 12.3-1) resses the criteria set forth in NUREG-0654, FEMA-REP-1, Criteria for Preparation and luation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear er Plants, Revision 1, November 1980 and NUREG-0737, Supplement 1. As such, the NRC roved Emergency Plan provides for an acceptable state of emergency preparedness and meets requirements of 10 CFR Part 50 and Appendix E thereto.
.1 REFERENCES
-1 J. F. Opeka letter to U. S. Nuclear Regulatory Commission Document Control Desk, transmitting Revision 6 to the Millstone Nuclear Power Station, Unit Numbers 1, 2, and 3 Emergency Plan, dated 11/4/91, and subsequent revisions thereto submitted on an annual basis.
rogram describing the review and audit of activities important to and affecting station safety ng the operational phase has been established and complies with Regulatory Guide 1.33, ality Assurance Program Requirements (Operation). The program provides a system to ure that these activities are performed in accordance with company policy, rules, and approved cedures.
.1 ONSITE REVIEW site review is conducted by committee(s) as described in the Quality Assurance Program cription (QAPD) Topical Report (Reference 12.4-1).
.2 INDEPENDENT REVIEW ependent review of activities affecting the unit's safety is performed by the Management ety Review Committee as described in the QAPD Topical Report.
.3 AUDITS Audit Program for activities affecting safety related systems, structures, or components is as cribed in the QAPD Topical Report.
.4 OTHER REVIEW GROUPS er review groups evaluate, on a periodic basis, the effectiveness of the units. These groups are:
pendent consultants, task forces, nuclear industry management assessments, insurance ections, etc.
.5 REFERENCES
-1 Quality Assurance Program Description Topical Report.
ion procedures are written on a unit and station services level controlling the specifics of ion operations, including specifications; maintenance and modification; periodic test, ection, calibration, and special processes, and plant and equipment.
5.1 ADMINISTRATIVE PROCEDURES 5.1.1 Conformance with Regulatory Guide 1.33 ulatory Guide 1.33, issued February 1978, Quality Assurance Program Requirements, is used uidance for the preparation of administrative and station procedures.
5.1.2 Preparation of Procedures paration, review and approval of procedures is as described in the Quality Assurance Program cription (QAPD) Topical Report.
.1.3 Procedures ministrative control and station procedures cover a wide range of topics. Major areas are cribed as follows.
nding Orders to Operating Personnel ministrative control procedures define the authorities and responsibilities of operating onnel. The procedures specify the number of personnel with reactor operator and senior tor operator licenses required to be on site or at the controls in all plant conditions. The inistrative procedures direct the proper maintenance, review, and disposition of operating rds, establish requirements for shift turnover, and establish the authority and responsibilities he person in charge of the control room to limit access. Procedures also direct the assignment hift personnel to duty stations, establish limits for scheduled working hours, provide methods imely and concise feedback of operating experience to applicable plant staff, and describe hods used to verify operational activities are performed correctly. Plant procedures also vide for shift turnover such that all necessary information is properly transmitted to the oming shifts.
cial Orders of a Transient or Self-Cancelling Character ht orders are issued as necessary to provide guidance to operating shifts and are of a porary nature but will be incorporated into an administrative control if the need becomes manent.
ructions are written to specify proper methods of obtaining clearances on plant equipment for ntenance or construction and to specify procedures for control of jumpers, inhibits, and wire oval. The clearance procedure assigns responsibility for clearance issue to the shift supervisor.
censed operator, after ensuring he is aware of the effect of the activity on the system, is uired to authorize all maintenance, tests, and surveillances performed on plant systems. Upon pletion of the item, the document is returned to the operator for acceptance or for the purpose eturning the system to service. The administrative procedures which control these evolutions vide the required explicit notification of operational personnel whenever a safety related em is removed from and returned to service. The clearance procedure also contains certain rictions on the issuance of a clearance. The instructions for control of jumpers, inhibits, and e removal allow temporary alterations to critical structures, systems, or components to litate tests, maintenance, or operations. They specify administrative procedures to be followed erforming such alterations.
trol of Maintenance and Modifications ministrative control procedures implement the review and approval requirements for ntenance and modifications. These procedures include the control of plant modifications and ntenance on safety-related equipment. These procedures establish a framework of special cess and maintenance procedures.
ster Surveillance Testing Schedule administrative control procedure establishes a master test control list, implements the eillance test program, and assigns responsibility for review and approval of surveillance cedures in accordance with Technical Specifications. Written surveillance procedures are trolled as station or unit procedures.
cedures for Logbook Usage and Control administrative control procedure establishes the requirements for logbook usage and control.
ntenance and Testing of Safety-Related Systems cedures for maintenance and testing of safety-related systems specify that prior to the removal safety-related system from service, the redundant system is verified operable. For equipment requires specific surveillance in accordance with Technical Specifications, the surveillance ing is completed prior to removing the system from service.
se procedures are reviewed and improved, if necessary, to ensure operability of safety systems r to taking credit for the system(s) to satisfy Technical Specification requirements.
cial procedures are prepared as necessary to support infrequently performed activities which not to be included in the permanent list of station procedures. A special procedure can be ten for any type of station procedure (i.e., maintenance, operating). The form of a special cedure is the same as the applicable type of station procedure. All requirements for review, roval, revisions, and changes are the same as for permanent station procedures.
.2 OPERATING AND MAINTENANCE PROCEDURES rating and maintenance procedures are divided into several categories which are described in following subsections. The list of these procedures is contained in the Master Document ex.
rating and maintenance procedures preparation is the responsibility of the appropriate artment head. When a procedure is written, the applicable Department Head/Manager is onsible to forward the procedure for review and approval in accordance with the QAPD ical Report.
nt operations are performed in accordance with written and approved Station and Department cedures.
ependent position verification of safety-related components/systems (valves, breakers, and trol switches) with no indication in the control room are performed prior to the return-to-ice of the component/system.
.2.1 Control Room Operating Procedures
.2.1.1 General Operating Procedures se procedures cover major plant evolutions. Step-by-step instructions are provided for the ction or task with the appropriate cross reference to system operating procedures for details of cific system operation. Appropriate precautions and limitations are included.
.2.1.2 System Operating Procedures se procedures provide step-by-step details for systems operations with appropriate equisites, precautions, limitations, and alarm responses. Each procedure covers the expected des of operation of the system as well as startup, shutdown, filling and venting, and standby ration as applicable.
.2.1.3 Abnormal Operating Procedures rating procedures are prepared for abnormal operation of the unit. Abnormal operation is a dition that could degrade into an emergency or could violate Technical Specifications if proper
.2.1.4 Emergency Operating Procedures ergency operating procedures are prepared for conditions which might possibly lead to injury plant personnel or the public if the release of radioactivity in excess of established limits urs. These procedures include symptoms of the emergency conditions, automatic actions that or should occur, and immediate and subsequent operator actions. All immediate actions are uired to be memorized by the operator since the primary responsibility for detection of an rgency and initiation of corrective action rests upon the operator.
.2.2 Station Procedures ion procedures are written by the chemistry, health physics, security, generation test, building ices, stores, nuclear records, computer operations, station services engineering and any other ion group. These procedures control the specific activities of these departments in support of or station operation (may be common site or unit specific). Station calibration procedures ten by the maintenance or instrument departments are also station procedures.
.2.2.1 Radiation Protection Procedures iation Protection procedures support Section 13.5 and 10 CFR 20 requirements.
.2.2.2 Instrument Maintenance Instructions rument maintenance instructions are prepared for the performance of periodic calibration, ing, and channel checking of safety-related plant instrumentation and all instruments used to sfy Technical Specification requirements. These instructions ensure measurement accuracies quate to maintain plant safety parameters within operational and safety limits. In addition, rument maintenance instructions outline the periodic calibration and accuracy requirements of equipment necessary to support the calibration of safety-related instrumentation.
.2.2.3 Chemistry Procedures mistry procedures are prepared covering the routine analysis and sampling methods to ensure pliance with plant chemistry and discharge limits.
.2.2.4 Radioactive Waste System Procedures cedures for operation of radwaste systems are included in system operating procedures.
.2.2.5 Material Control Procedures s topic is covered by administrative procedures in Section 12.5.1.3.
ntenance procedures are prepared to cover safety-related work which requires a specific nique or sequence not normally part of an individuals routine skill.
procedures support the requirements and programs of Section 12.5.1.33 which covers inistrative control of maintenance and modification.
.2.2.7 Fire Protection Procedures Fire Protection Program is described in Section 9.10.
.2.2.8 Special Procedures s topic is covered by administrative procedures.
ords are kept and maintained in accordance with the applicable federal, state, and operating nse requirements. The records and retention program is as described in the Quality Assurance gram Description Topical Report. These controls include all quality related records including t and as-built drawings.
security plan (Reference 12.7-1) states the security measures to be employed by the licensee the protection of Millstone Units 1, 2, and 3 at the Millstone Nuclear Power Station, erford, Connecticut, against radiological sabotage. The plans have been submitted in ordance with 10 CFR Part 73, Section 73.55, Requirements for Physical Protection of ensed Activities in Nuclear Power Reactors Against Radiological Sabotage.
se plans include measures to deter or prevent malicious actions that could result in the release adioactive materials into the environment through sabotage. This protection is provided ugh the use of armed guards, physical barriers, monitors, personnel access controls, alarms, munications, response to security contingencies, and liaison with appropriate law orcement agencies.
7.1 REFERENCES
-1 J. F. Opeka letter to the Nuclear Regulatory Commission, Millstone Nuclear Power Station Unit Numbers 1, 2, and 3 Physical Security Plan, Revision 15, dated December 16, 1991, and subsequent revisions thereto.
.1 QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD) TOPICAL REPORT omprehensive Quality Assurance Program (QAP) has been developed and implemented to re conformance with established regulatory requirements, set forth by the Nuclear Regulatory mmission, and accepted industry standards. The participants in the QAP assure that the design, curement, construction, testing, operation, maintenance, repair, and modification of nuclear er plants are performed in a safe and effective manner.
QAPD Topical Report complies with the requirements set forth in Appendix B of CFR Part 50, along with applicable sections of the Safety Analysis Report (SAR) for each nse application, and is responsive to NUREG-0800, which describes the information ented in the Quality Assurance Section of the SARs for nuclear power plants. The QAPD ical Report is incorporated herein by reference.
QAP is also established, maintained, and executed with regard to Radioactive Material nsport Packages as allowed by 10 CFR 71.101(f).
QAPD Topical Report is submitted periodically to the NRC in accordance with CFR 50.54(a).
0.1 INTRODUCTION
lstone has implemented 10 CFR 50.69 using the processes for categorization of Risk-rmed Safety Class (RISC)-1, RISC-3, and RISC-4 structures, systems, and components Cs) using:
Probabilistic Risk Assessment (PRA) model to evaluate risk associated with internal events, including internal flooding; the Appendix R program to evaluate fire risk; and the shutdown safety assessment process to assess shutdown risk; The Arkansas Nuclear One, Unit 2 (AN0-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; The results of non-PRA evaluations that are based on the IPEEE [Individual Plant Examination of External Events] Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/
10.2 SSC CATEGORIZATION outlined in the Safety Evaluation Report (SER) for License Amendment 337 to Renewed ility Operating License No. DPR-65 (Reference 12.10-3), Millstone 2 will use the hodology described in Section 12.10.
hould be noted that 10 CFR 50.69 does not replace the existing safety-related and nsafety-related classification. Instead 10 CFR 50.69 divides these classifications into two categories based on high or low safety significance, such that there are four categories of risk-rmed safety class (RISC), as shown below:
C-1: safety-related SSCs that perform (high) safety significant functions.
C-2: nonsafety-related SSCs that perform (high) safety significant functions.
C-3: safety-related SSCs that perform low safety-significant functions.
C-4: nonsafety-related SSCs that perform low safety-significant functions CRF 50.69(f)(2) requires updating the UFSAR to reflect which systems have been gorized. The list below is revised as part of the periodic UFSAR update to reflect systems that e been categorized.
tem Name iation Monitoring (2404)
0.3.1 Treatment of Component Categories programs or processes that implement the special treatment requirements are revised to gnize that the special treatments no longer apply to RISC-3 and RISC-4 SSCs. The programs rocesses either allow continued application of the special treatments or acceptable alternative tments, as applicable, to provide reasonable confidence that these SSCs would perform their ty-related function under design basis conditions.
those components that are categorized as Low Safety Significant, 10 CFR_50.69(b)(1) allows pliance with alternative requirements in lieu of the following special treatment requirements:
- 2. The portion of the 10 CFR 50.46a(b) that imposes requirements to conform to Appendix B to 10 CFR Part 50
- 3. 10 CFR 50.49
- 5. The in-service testing requirements in 10 CFR 50.55a(f): the in-service inspection and repair, and replacement (with the exception of fracture toughness),
requirements for ASME Class 2 and Class 3 SSCs in 10 CFR 50.55a(g); and the electrical component quality and qualification requirements in Section 4.3 and 4.4 of IEEE 279 and Sections 5.3 and 5.4 of IEEE 603-1991, as incorporated by reference in 10 CFR 50.55a(h)
- 6. 10 CFR 50.65, except for paragraph (a)(4)
- 7. 10 CFR 50.72
- 8. 10 CFR 50.73
- 9. Appendix B to 10 CFR Part 50
- 10. The Type B and Type C leakage testing requirements in both Options A and B of Appendix J to 10 CFR Part 50, for penetrations and valves meeting the following criteria:
- a. Containment penetrations that are either 1-in. nominal size or less, or continuously pressurized.
- b. Containment isolation valves that meet one or more of the following criteria:
- 2. The valve is normally closed and in a physically closed, water-filled system;
- 3. The valves is in a physically closed system whose piping pressure rating exceeds the containment design pressure rating and is not connected to the reactor coolant pressure boundary; or
- 4. The valve is 1-in. nominal size or less.
- 11. Appendix A to Part 100, Sections VI(a)(1) and VI(a)(2), to the extent that these regulations require qualification testing and specific engineering methods to demonstrate that SSCs are designed to withstand the Safe Shutdown Earthquake and Operating Basis Earthquake.
en applying alternative treatment, 10 CFR 59.69 requires that the licensee shall ensure, with onable confidence, that RISC-3 SSCs remain capable of performing their safety-related ctions under design basis conditions, including seismic conditions and environmental ditions and effects throughout their service life.
ormance monitoring is being performed on all RISC-1, RISC-2, RISC-3, and RISC-4 SSCs the station adjusts, as necessary, to either the categorization or treatment process so that the gorization process and results are maintained valid.
0.3.2 Enhanced Treatment of RISC-2 SSCs 10 CFR 50.69 procedures and 10 CFR 50.69(d)(1) require that RISC-2 SSCs perform their ctions consistent with the categorization process assumptions by evaluating treatment being lied to these SSCs to ensure that it supports the key assumptions in the categorization process relate to their assumed performance.
0.4 REFERENCES
0-1 NEI 98-03, Guidelines for Updating Final Safety Analysis Reports, Revision 1, dated June 1999.
0-2 Regulatory Guide 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e), dated September 1999.
0-3 Safety Evaluation by the Office of Nuclear Reactor Regulation related to Amendment No. 337 to Renewed Facility Operating License No. DPR-65 Dominion Energy Nuclear Connecticut, Inc. Millstone Power Station, Unit No. 2, Docket No. 50-336.