ML15205A291

V.C. Summer, Unit 1 - License Amendment Request - LAR 14-02981, Proposed Revision to Technical Specification 6.0, Administrative Controls.

ML15205A291
Person / Time
Site:	Summer
Issue date:	07/22/2015
From:	Gatlin T D South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RC-15-0109
Download: ML15205A291 (21)

Text

Thomas D. GatlinVice President, Nuclear Operations 803.345.4342 A SCANA COMPANYJuly 22, 2015RC-15-0109 Document Control DeskU. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12LICENSE AMENDMENT REQUEST -LAR 14-02981PROPOSED REVISION TO TECHNICAL SPECIFICATION 6.0"ADMINISTRATIVE CONTROLS" South Carolina Electric

& Gas Company (SCE&G),

acting for itself and as an agent forSouth Carolina Public Service Authority pursuant to 10 CFR 50.90, hereby submits arequest for amendment to Technical Specifications (TS). The proposed amendment willchange TS Section 6.0, "Administrative Controls" by revising the Shift Supervisor title toShift Manager.

The bases and evaluation for the proposed change are included as anEnclosure.

SCE&G requests approval-of the proposed amendment by June 1, 2016. Once approved, the amendment shall be implemented within 30 days.In accordance with 10 CFR 50.91, a copy of this application, with attachments, is beingprovided to the designated South Carolina Official.

This proposed Change has been reviewed and approved by both the VCSNS Plant SafetyReview Committee and Nuclear Safety Review Committee.

The proposed change does not include any new commitments.

If you have any questions or require additional information, please contact Bruce Thompson at (803) 931-5042.

V. C. Summer Nuclear Station P. 0. Box 88* Jenkinsville, SC *29065. F (803) 941-9776 Document Control DeskLAR/CR-14-02981 RC-15-0109 Page 2 of 2I certify under penalty of perjury that the information contained herein is true and correct.-72 22 )22'/ b_____xec ted on Thomas D. GatlinBJH/TDG/wt

Enclosure:

Evaluation of the Proposed Revision to Technical Specification 6.0,"Administrative Controls" Attachments:

1. Proposed Technical Specification Change (MARK-UP)

2. Proposed Technical Specification Change (RETYPED)

3. List of Regulatory Commitments c: K. B. MarshS. A. ByrneJ. B. ArchieN. S. CarnsJ. H. HamiltonJ. W. WilliamsW. M. CherryV. M. McCreeS. A. WilliamsNRC Resident Inspector K. M. SuttonP. Ledbetter S. E. JenkinsNSRCRTS (CR-14-02981)

File (813.20)PRSF (RC-15-0109)

Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 1 of 8VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12Enclosure Evaluation of the Proposed Revision to Technical Specification 6.0, "Administrative Controls"

Subject:

This evaluation supports a request to amend South Carolina Electric

&Gas Company (SCE&G),

Technical Specifications (TS) Section 6.0,"Administrative Controls" by revising the Shift Supervisor title to ShiftManager.1.0 SUMMARY DESCRIPTION These proposed changes are to be implemented based on recommendations from Institute of Nuclear Power Operations (INPO) within Significant Operating Experience Report (SOER) 96-1, Control Room Supervision Operational Decision-Making and Teamwork dated September 27, 1996 and ACAD 97-004,Guidelines for Shift Manager Selection, Training and Qualification, andProfessional Development dated April 1997. The requested change isadministrative in nature and will not alter the qualifications, functions, responsibilities or authorizations previously established by 10 CFR 50.36, 10CFR 50.54 and 10 CFR 55.SCE&G requests approval of the proposed amendment by June 1, 2016. Onceapproved, the amendment shall be implemented within 30 days or less.2.0 DETAILED DESCRIPTION This amendment request is to revise TS section 6.0, "Administrative Controls,"

for the generic position title Shift Supervisor to Shift Manager.

Specifically, thetitle of Shift Supervisor is being changed to Shift Manager in the following TSsections:

6.1.2, Table 6.2-1, 6.2.4, and 6.12.2. This change has been Document Control DeskEnclosure LAR/CR-14-02981 RC-1 5-0109Page 2 of 8recommended by INPO within SOER 96-1 dated September 27,1996.

TheSOER discusses events caused by deficiencies in supervisory oversight, reactivity

control, teamwork, and crew decision-making.

Observations of controlroom operating crews showed that performance is affected by the leadership ofthe Shift Supervisor and Control Room Supervisor.

The individuals filling theroles of supervisors must function as team leaders and maintain close oversight of control room activities to detect errors or lapses in judgment or a breakdown inrole responsibilities by other crew members.

The supervisors must remain fullyinvolved in all control room evolutions and be prepared to assert their authority for command and control whenever high standards are not being maintained.

The change in position title Shift Supervisor to Shift Manager is intended tointegrate the senior licensed shift crew member into the plant management team.As a member of station management, the Shift Supervisor is central to theoperating organization's ability to safely operate the station and meet thedemands of the operations mission in accordance with station management's expectations.

Shift Supervisors fully integrated into the management team arebetter able to internalize the station's goals, articulate those goals to theiroperating crews, and ensure all on-shift operations and support personnel worktoward achieving those goals. The Shift Supervisor's management role is tofacilitate and champion the practical application of the principles of safe andreliable station operation while holding operations and support personnel accountable to the high standards of performance expected by stationmanagement.

The change in generic title to Shift Manager is still representative for the title of the senior licensed shift crewmember.

This proposed changereflects the practice adopted by several licensees to emphasize the scope andsignificance of the responsibilities for this position.

3.0 TECHNICAL EVALUATION Organizational structure and the conduct of operations of South Carolina Electric& Gas Company are discussed in the Final Safety Analysis Review (FSAR)Chapter 13. The Virgil C. Summer Nuclear Station is operated from one centralcontrol room. The Shift Supervisor is directly responsible for the safe andefficient operation of the plant. For the operation of one unit, each shift isnormally manned by one Shift Supervisor (Licensed Senior Reactor Operator),

one Control Room Supervisor (Licensed Senior Reactor Operator),

one NuclearReactor Operator (Licensed Senior Reactor Operator or Licensed ReactorOperator),

and Reactor Operators and Auxiliary Operators (no license required, but desirable).

At least one of the Reactor Operators and Auxiliary Operators willhave a Reactor Operator's License.

There shall be a total of at least twolicensed Senior Reactor Operators and two licensed Reactor Operators per shift.

Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 3 of 8In addition to the "operations" shift crew as stated above, there shall be one shiftengineer and at least one Health Physics Specialist onsite at all times.The Shift Supervisor, who reports to the Manager, Operations via the Operations Supervisor, is in direct charge of the plant, including

startup, power operations, and shutdown.

The Shift Supervisor will initiate immediate action in the event ofan upset situation to avoid exceeding the Technical Specifications limitations, toavert possible injury or undue radiation exposure to personnel, or to preventdamage to plant equipment.

The Shift Supervisor has the responsibility ofsupervising the actions of the station operators (Control Room Supervisor, SeniorReactor Operator, Reactor Operator, and Auxiliary Operators) to assure safe andprudent operation of the facility.

The Shift Supervisor initiates immediate corrective action in any upset situation until assistance, if required, arrives.

Otherresponsibilities include; ensuring plant operating procedures are kept current,and when deemed necessary, initiating changes to these procedures; ensuringthat his or her shift is properly manned and other groups are called in to workwhen necessary; coordinating all maintenance and testing being performed during his or her shift; and ensuring that the training of personnel assigned to hisor her shift as required by the overall training and retraining programs isconducted.

FSAR section 13.1.3.1.5 provides a general guideline of thequalification requirements for the Shift Supervisor that meet the minimumrequirements set forth in Regulatory Guide 1.8, "Qualification and Training ofPersonnel for Nuclear Power Plants" Revision 2.SCE&G is committed to NQA-1-1994, Parts 1, 11, and 111. The Shift Supervisor position is discussed within various types of procedures used by SCE&G togovern the design, operation, and maintenance of its nuclear generating plants.SCE&G follows the guidance of Appendix A to Regulatory Guide 1.33 Revision 2in identifying the types of activities that should have procedures or instructions tocontrol the activity.

Quality Assurance Program Description (QAPD) reflects theShift Supervisor responsibilities and the requirement that a directive beestablished that contains clear delineation of the management chain of authority.

The proposed changes for this amendment impacts the title only and, therefore, the change will not alter the qualifications, functions, responsibilities orauthorizations previously established.

Needed changes to the QAPD would notbe a reduction in effectiveness, therefore, changes can be processed under a 10CFR 50.54(a)

Evaluation.

This proposed change will not lower the safety or effectiveness of theorganization.

The title change from Shift Supervisor to Shift Manager does notchange the intent of the Technical Specifications or the qualifications, functions, responsibilities and authorizations previously established by 10 CFR 50.36,10 CFR 50.54 and 10 CFR 55. This proposed change reflects the practice Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 4 of 8adopted by several licensees to emphasize the scope and significance of theresponsibilities for this position.

4.0 REGULATORY EVALUATION For reactor operators, senior reactor operators, fuel handlers, fire protection personnel, and positions specified in 10 CFR 50.120, programs are developed, established, implemented and maintained using a systems (or systematic) approach to training (SAT) as defined by 10 CFR 55.4 and ANSI/ANS-3.1-1993 as endorsed by Regulatory Guide (RG)-1.8.

The title of Shift Supervisor iscategorized within 10 CFR 50.120 but is never defined and within RG 1.8,Sections 4.3.1.1, the generic title of "Shift Supervisor,"

of ANSI/ANS-3.1-1981 isendorsed.

NUREG-0578 makes a reference to the Shift Supervisor's commandfunction or position as that of a "manager" or "commander" of shift operations and the latest draft revision of the Standard Review Plan Chapter 13.1.2 (DraftRevision

7) section 3.C.iii uses the title interchangeably with shift manager.4.1 Applicable Regulatory Requirements

/ Criteria10 CFR 50.34(b)(6)(i) requires that the FSAR for a license to operate a nuclear power plantinclude information concerning the organizational structure, personnel qualifications, and related matters.10 CFR 50.36(c)(5) requires administrative controls related to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assureoperation of the facility in a safe manner to be in the Technical Specifications.

The details of the organization and management that are required to be in theTechnical Specifications were delineated in Generic Letter (GL) 88-06, "Removalof Organization Charts From Technical Specifications Administrative ControlRequirements,"

dated March 22, 1988. These details included the "Designation of those positions in the onsite organization that require a senior reactor operator(SRO) or reactor operator (RO) license."

10 CFR 50.54(I) The licensee shall designate individuals to be responsible for directing thelicensed activities of licensed operators.

These individuals shall be licensed assenior operators pursuant to part 55 of this chapter.

Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 5 of 810 CFR 55.4 Definitions Senior operator means any individual licensed under this part to manipulate thecontrols of a facility and to direct the licensed activities of licensed operators.

SRP-800 Chapter 13.1.2 (Draft Revision 7)3.C.iii operating Shift Supervisors/managers.

NUREG-0578 "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations,"

section 2.2 "Operations."

NUREG-0737 and Supplement 1,"Clarification of TMI Action Plan Requirements,"

Items I.A.1.1, "Shift Technical Advisor,"

and I.A.1.3, "Shift Manning."

NUREG-1791 "Guidance for Assessing Exemption Requests from the Nuclear Power PlantLicensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)".

4.2 Precedent

4.2.1 Letter from K. Young (Calloway Plant) to Document Control Desk (NRC),"Proposed Revision to Technical Specification

5.0 'Administrative

Controls' (License Amendment Request OL 1267)," dated March 28, 2006[ML061020060].

Calloway received their SER on July 11, 2006[ML061250207].

The changes proposed within the Calloway submittal are similar in thechange in title for the Shift Supervisor to Shift Manager.

Within thissubmittal Calloway also requested a change to the title for the HealthPhysics organization that does not apply to VC Summer. Another delta isthe Quality Assurance Program in that VC Summer has been approved forNQA-1 (1994) Quality Assurance Requirements for Nuclear Applications.

VC Summer has incorporated the administrative control requirements ofAmerican National Standards Institute (ANSI) N18.7-1976/American Nuclear Society (ANS) 3.2 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plans as endorsed byRG 1.33 revision

2.

Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 6 of 84.3 No Significant Hazards Consideration

1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.The proposed changes to the Technical Specifications (TS) regarding ShiftSupervisor to Shift Manager are administrative changes.

It has no impact onaccident initiators or plant equipment and thus does not affect the probability orconsequences of an accident.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

Response:

No.The proposed change does not involve a change to the physical plant oroperations.

This is an administrative title change that does not contribute toaccident initiation.

Therefore, it does not produce a new accident scenario orproduce a new type of equipment malfunction.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.Since the change is administrative and changes no previously evaluated accidents or creates no possibility for any new unevaluated accidents to occur,there is no reduction in the margin of safety. This change also does not affectplant equipment or operation and therefore does not affect safety limits or limitingsafety systems settings.

4.4 Conclusions

Based on the above, SCE&G concludes that the proposed amendment presentsno significant hazards consideration under the standards set forth in10 CFR 50.92(c),

and accordingly, a finding of "no significant hazardsconsideration" is justified.

Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 7 of 85.0 ENVIRONMENTAL CONSIDERATIONS SCE&G has determined that this proposed amendment involves no significant hazardous considerations and no significant change in the types of any effluents thatmay be released off-site and that there is no significant rise in individual orcumulative occupational radiation exposure.

Accordingly, this proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environment assessment need be prepared in connection with this amendment.

6.0 REFERENCES

6.1 10 CFR 50.36, Technical Specifications 6.2 10 CFR 50.54, Conditions of Licenses6.3 10 CFR 55.4, Definitions 6.4 ACAD 97-004 Guidelines for Shift Manager Selection, Training and Qualification, and Professional Development 6.5 Callaway Plant ULNRC-05267, Proposed Revision to Technical Specification 5.0,"Administrative Controls" (License Amendment Request OL 1267)6.6 Generic Letter 88-06, Removal of Organization Charts from Technical Specification Administrative Control Requirements 6.7 NUREG 0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations 6.8 NUREG-0800 13.1.2-13.1.3, Standard Review Plan, Operating Organization 6.9 NUREG 1431, Section 5.0, "Administrative Controls" 6.10 Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear PowerPlants6.11 Regulatory Guide 1.33, Quality Assurance Program Requirements 6.12 Regulatory Guide 1.114, Guidance to Operators at the Controls and to SeniorOperators in the Control Room of a Nuclear Power Unit Document Control DeskEnclosure LAR/CR-14-02981 RC-15-0109 Page 8 of 86.13 Safety Evaluation to QAPD, Virgil C. Summer Nuclear Station, Unit 1, Approvalof Quality Assurance Program Description 6.14 SOER 96-1, Control Room Supervision, Operational Decision-Making, andTeamwork6.15 TSTF-65-A, Improved Standard Technical Specifications Change Traveler6.16 WANO OP.1-1, 2014 WANO Area for Improvement Document Control DeskAttachment 2CR-14-02981 RC-15-0109 Page 1 of 5VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12Attachment 1Proposed Technical Specification Change (MARK-UP)

Proposed Technical Specification Changes SummaryReplace the following pages of the Technical Specifications with the attached revisedpages. The revised pages are identified by amendment number and contain marginallines indicating the areas of change.Remove Pages6-1, 6-2, 6-3, 6-18Insert Pages6-1, 6-2, 6-3, 6-18Paqe Affected Bar Description of Change Reason for ChangeSection #6-1 6.1.2 1 Remove Supervisor and SOER 96-1replace with Manager6-2 Table 6.2-1 1 Replace SS with SM SOER 96-16-2 Table 6.2-1 2 Replace SS with SM; Replace SOER 96-1Supervisor with Manager6-2 Paragraph 1 3 Remove Supervisor and SOER 96-1replace with Manager6-2 Paragraph 2 4 Remove Supervisor and SOER 96-1replace with Manager6-3 6.2.4 1 Remove Supervisor and SOER 96-1replace with Manager6-18 6.12.2 1 Remove Supervisor and SOER 96-1replace with Manager 6.0 ADMINISTRATIVE CONTROLS6;1 RESPONSIBILITY 6.1.1 The General Manager, Nuclear Plant Operations shall be responsible foroverall unit operation and shall delegate in writing the succession to thisresponsibility during hjisaManager 6.1.2 The Shift 1 shall be responsible for unit operations.

Amanagement directive to this effect, signed by the Vice President, NuclearOperations, shall be reissued to all station personnel on an annual basis.6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS Offsite and Onsite organizations shall be established for unit operation and corporate management, respectively.

The offsite and onsite organiza-tions shall include the positions for activities affecting the safety ofthe nuclear power plant.a. Lines of authority, responsibility and communication shall beestablished and defined from the highest levels through intermediate levels to and including all operating organization positions.

Thoserelationships shall be documented and updated, as appropriate, inthe form of organizational charts, functional descriptions ofdepartment responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms ofdocumentation.

The organizational charts will be documented in theFSAR and updated in accordance with 10 CFR 50.71(e).

b. The General Manager, Nuclear Plant Operations, shall be responsible for overall unit safe operation and shall have control over onsiteactivities necessary for safe operation and maintenance of the-plant.c. The Vice President, Nuclear Operations, shall have corporate responsibility for overall plant nuclear safety and shall take anymeasures needed to ensure acceptable performance of the staff inoperating, maintaining, and providing technical support to the plantto ensure nuclear safety.d. The individuals who train the operating staff and those who carryout the health physics and quality assurance functions may report tothe appropriate onsite manager;

however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 UNIT STAFFa. Each on-duty shift shall be composed of at least the minimum shiftcrew composition shown in Table 6.2-1.SUMMER -UNIT 1 6-1 N 79 TABLE 6.2-1MINIMUM SHIFT CREW COMPOSITION SUMMER UNIT 1NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITIONPOSITIONMODES 1, 2, 3, & 4MODES 5 & 6_CRF//ROSMI- ADSTA--Managerl112211None1NoneISS -Shift SipepFse with a Senior Reactor Operators License on Unit 1CRF -Control Room Supervisor with a Senior Reactor Operators License onMUnit 1SM RD -Individual with a Reactor Operators License on Unit 1AD -Auxiliary OperatorSTA -Shift Technical Advis ManagerExcept for the Shift S ep460r, the Shift Crew Composition may be one lessthan the minimum requirements of Table 6.2-1 for a period of time not toexceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shiftcrew members provided immediate action is taken to restore the Shift CrewComposition to within the minimum requirements of Table 6.2-1. This provision does not permit any shift crew position to be unmanned upon shift change dueto an oncoming shift crewman being late or absent.During any absence of the Control Room Supervisor from the Control Room whilethe unit is in MODE 1, 2, 3 or 4, an individual (other than the Shift Technical Advisor) with a valid SRO license shall be designated to assume the Contra ManagerRoom command function.

During any absence of the Shift &6pepyis roithe L...Control Room while the unit is in MODE 5 or 6, an individual with a valid ROor SRO license shall be designated to assume the Control Room command function.

SUMMER -UNIT 16-2Amendment No. 10,90,79JUL 2 4 1B9I ADMINISTRATIVE CONTROLS6.2.3 NOT USED6.2.4 SHIFT TECHNICAL ADVISOR A gerThe Shift Technical Advisor shall provide technical support to the Shift Stpemise in theareas of thermal hydraulics, reactor engineering and plant analysis with regard to the safeoperation of the unit.6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications ofANSI N18.1-1971 for comparable positions except for the Radiation Protection Manager whoshall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.6.4 NOT USEDIISUMMER -UNIT 16-3Amendment No. 4858,-9,406.,147, 151JUL Se 0lW ADMINISTRATIVE CONTROLS6.12.2 In addition to the requirements of 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mrem/hr*

but less than 500 rads/hr**

shall be provided with locked doorsSManager Fto prevent una~iuthorized entry, and the keys shall be maintained under the administrative control ofthe duty Sh ept w and/or health physics supervision.

Doors shall remain locked exceptduring periods of access by personnel under an approved RWP which shall specify the dose ratelevels in the immediate work area. The maximum allowable stay time for Individuals in that areashall be established prior to entry. In lieu of the stay time specification of the RWP, direct orremote continuous surveillance (such as closed circuit TV cameras) shall be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.For individual areas accessible to personnel with radiation levels greater than 1000 mrem/hr*

butless than 500 rads/hr**

that are located within larger areas (such as PWR containment) where noenclosure can be reasonably constructed around the individual areas, then those areas shall bebarricaded, conspicuously posted, and a flashing light shall be activated as a warning device.6.13 PROCESS CONTROL PROGRAM (PCP)6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Changes to the PCP:a. Shall be documented and records of reviews performed shall be retained for theduration of the Unit Operating License.

This documentation shall contain:1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s);

and2) A determination that the change will maintain the overall conformance of thesolidified waste product to existing requirements of Federal, State, or otherapplicable regulations.

b. Shall become effective after review and acceptance by the PSRC and approval ofthe General Manager, Nuclear Plant Operations.

• Measurement made at 30 cm (12 in.) from the radiation source or from any surface penetrated by the radiation.

"Measurement made at 1 meter from the radiation source or from any surface penetrated by theradiation.

SUMMER -UNIT 1 6-18 Amendment No. 35,7-9,104T 43,, 188 Document Control DeskAttachment 2CR-14-02981 RC-15-0109 Page 1 of 5VIRGIL C. SUMMER NUCLEAR STATION.

(VCSNS)DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12Attachment 2Proposed Technical Specification Change (RETYPED) 6.0 ADMINISTRATIVE CONTROLS6.1 RESPONSIBILITY 6.1.1 The General Manager, Nuclear Plant Operations shall be responsible for overall unitoperation and shall delegate in writing the succession to this responsibility during hisabsence.6.1.2 The Shift Manager shall be responsible for unit operations.

A management directive to this effect, signed by the Vice President, Nuclear Operations, shall be reissued to allstation personnel on an annual basis.6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS Offsite and Onsite organizations shall be established for unit operation and corporate management, respectively.

The offsite and onsite organizations shall include thepositions for activities affecting the safety of the nuclear power plant.a. Lines of authority, responsibility and communication shall be established anddefined from the highest levels through intermediate levels to and including alloperating organization positions.

Those relationships shall be documented andupdated, as appropriate, in the form of organizational charts, functional descriptions of department responsibilities and relationships, and jobdescriptions for key personnel positions, or in equivalent forms ofdocumentation.

The organizational charts will be documented in the FSAR andupdated in accordance with 10 CFR 50.71(e).

b. The General Manager, Nuclear Plant Operations, shall be responsible foroverall unit safe operation and shall have control over onsite activities necessary for safe operation and maintenance of the plant.c. The Vice President, Nuclear Operations, shall have corporate responsibility foroverall plant nuclear safety and shall take any measures needed to ensureacceptable 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 out the healthphysics and quality assurance functions may report to the appropriate onsitemanager;

however, they shall have sufficient organizational freedom to ensuretheir independence from operating pressures.

6.2.2 UNIT STAFFa. Each on-duty shift shall be composed of at least the minimum shift crewcomposition shown in Table 6.2-1.SUMMER -UNIT 16-1Amendment No. 4&,79, TABLE 6.2-1MINIMUM SHIFT CREW COMPOSITION SUMMER UNIT 1POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITIONMODES 1, 2, 3, &4 MODES 5 & 6SM 1 1CRF I NoneRO 2 1AO 2 1STA 1 NoneSM -Shift Manager with a Senior Reactor Operators License on Unit 1CRF -Control Room Supervisor with a Senior Reactor Operators License on Unit 1RD -Individual with a Reactor Operators License on Unit IAD -Auxiliary OperatorSTA -Shift Technical AdvisorExcept for the Shift Manager, the Shift Crew Composition may be one less than theminimum requirements of Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order toaccommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements ofTable 6.2-1. This provision does not permit any shift crew position to be unmanned uponshift change due to an oncoming shift crewman being late or absent.During any absence of the Control Room Supervisor from the Control Room while the unit isin MODE 1, 2, 3 or 4, an individual (other than the Shift Technical Advisor) with a valid SROlicense shall be designated to assume the Control Room command function.

During anyabsence of the Shift Manager from the Control Room while the unit is in MODE 5 or 6, anindividual with a valid RO or SRO license shall be designated to assume the Control Roomcommand function.

SUMMER -UNIT I6-2Amendment No. 58, 79, ADMINISTRATIVE CONTROLS6.2.3 NOT USED62.4 SHIFT TECHNICAL ADVISORThe Shift Technical Advisor shall provide technical support to the Shift Manager in the areasof thermal hydraulics, reactor engineering and plant analysis with regard to the safeoperation of the unit.6,3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications ofANSI N18.1-1971 for comparable positions except for the Radiation Protection Manager whoshall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.6.4 NOT USEDSUMMER -UNIT 16-3Amendment No. 18,-58, 79,

154, ADMINISTRATIVE CONTROLS6.12.2 In addition to the requirements of 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mrem/hr*

but less than 500 rads/hr**

shall be provided with locked doorsto prevent unauthorized entry, and the keys shall be maintained under the administrative control ofthe duty Shift Manager and/or health physics supervision.

Doors shall remain locked exceptduring periods of access by personnel under an approved RWP which shall specify the dose ratelevels in the immediate work area. The maximum allowable stay time for individuals in that areashall be established prior to entry. In lieu of the stay time specification of the RWP, direct orremote continuous surveillance (such as closed circuit TV cameras) shall be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.For individual areas accessible to personnel with radiation levels greater than 1000 mrem/hr*

butless than 500 rads/hr**

that are located within larger areas (such as PWR containment) where noenclosure can be reasonably constructed around the individual areas, then those areas shall bebarricaded, conspicuously posted, and a flashing light shall be activated as a warning device.6.13 PROCESS CONTROL PROGRAM (PCP)6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Changes to the PCP:a. Shall be documented and records of reviews performed shall be retained for theduration of the Unit Operating License.

This documentation shall contain:1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s);

and2) A determination that the change will maintain the overall conformance of thesolidified waste product to existing requirements of Federal, State, or otherapplicable regulations.

b. Shall become effective after review and acceptance by the PSRC and approval ofthe General Manager, Nuclear Plant Operations.

• Measurement made at 30 cm (12 in.) from the radiation source or from any surface penetrated by the radiation.

• • Measurement made at 1 meter from the radiation source or from any surface penetrated by theradiation.

SUMMER -UNIT 1 6-18 Amendment No. , 79, 104,130, 188, Document Control DeskAttachment 3LAR/CR-14-02981 RC-15-0109 Page 1 of 1VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12Attachment 3List of Regulatory Commitments There are no regulatory commitments created due to this License Amendment Request.Any other statements in this submittal are provided for information purposes and are notconsidered to be regulatory commitments.

Please direct questions regarding thesecommitments to Mr. Bruce L. Thompson at (803) 931-5042.

Commitment Due DateNONE N/A