ML18153C401

Proposed Tech Specs 6.0 Revising Administrative Controls

ML18153C401
Person / Time
Site:	Surry
Issue date:	10/11/1990
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18153C400	List: ML18153C399 ML18153C401
References
NUDOCS 9010240385
Download: ML18153C401 (7)

Text

e ATTACHMENT ONE TECHNICAL SPECIFICATION CHANGES SURRY - UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY I 90102403A~ 901011

~DR ADO[( 05000280 PDC

TS6.1-1 6.0 ADMINISTRATIVE CONTROLS 6.1 Organization, Safety and Operation Review Specification A. The Station Manager shall be responsible for the overall operation of the facility. In his absence, the Assistant Station Manager (Operations and Maintenance) shall be responsible for the safe operation of the facility.

During the absence of both, the Station Manager will delegate in writing the succession to this responsibility.

An onsite and an offsite organization shall be established for facility operation and corporate management. The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear power plant.

1. Lines of authority, responsibility and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the UFSAR.

2. The Station Manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

3. The Vice President - Nuclear shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the stall in operating, maintaining and providing technical support to the plant to ensure nuclear safety.

4. The management position responsible for training of the operating staff and the position responsible for the quality assurance functions shall have sufficient organizational freedom including sufficient independence from cost and schedule when opposed to safety considerations.

5. The management position responsible for health physics shall have direct access to that onsite individual having responsibility for overall facility management. Health Physics personnel shall have the authority to cease work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures.

e TS 6.1-2 B. The facility organization shall conform to the following requirements:

1. Each member of the facility staff shall meet or exceed the minimum qualifications of ANS-3.1 (12/79 Draft)* for comparable positions, and the supplemental requirements specified in the March 28, 1980 NRG letter to all licensees, except:

a. The Superintendent - Health Physics shall meet or exceed the qualification of Regulatory Guide 1.8, September 1975.

b. The Superintendent - Operations shall hold (or have previously held) a Senior Reactor Operator License for Surry Power Station or a similar design Pressurized Water Reactor plant.

C. The Supervisor Shift Operations shall hold an active Seniorl Reactor Operator License for Surry Power Station.

2. The Shift Technical Advisor shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

3. The Station Manager is responsible for ensuring that retraining and replacement training programs for the facility staff are maintained and that such programs meet or exceed the requirements and recommendations of Section 5 of ANS-3.1 (12/79 Draft)* and Appendix "A" of 1O GFR Part 55 and the supplemental requirements specified in the March 28, 1980 NRG letter to all licensees, and shall include familiarization with relevant industry operational experience identified by the SEC Staff.

4. Each on-duty shift shall be composed of at least the minimum shift crew composition for each unit as shown in Table 6.1-1.

5. A health physics technician shall be on site when fuel is in the reactor.

6. All core alterations shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

e ATTACHMENT TWO DISCUSSION and SAFETY EVALUATION VIRGINIA ELECTRIC AND POWER COMPANY

e e Docket Nos. 50-280 / 281 Serial No.90-581 PROPOSED TECHNICAL SPECIFICATION CHANGES The proposed change to Technical Specification 6.1, "Organization, Safety and Operation Review", adds specific exceptions to the qualification requirements of ANS-3.1 (12/79 Draft) for the Superintendent of Operations and the Supervisor - Shift Operations.

DISCUSSION:

ANS-3.1 (12/79 Draft), which is cited in Technical Specification 6.1.B for establishing the qualification requirements of the plant's staff, requires that the individual fulfilling the function of the "Operations Manager" holds a current Senior Reactor Operator's License. In the past, we have designated the Superintendent - Operations as the equivalent position in our staffing organization and therefore required that position to be filled by a person holding an SRO license.

Requiring the Superintendent - Operations to maintain an SRO license makes it difficult for that individual to perform certain management functions. Specifically, his ability to monitor the quality of operating shift qualification and requalification programs is substantially impaired. The superintendent is not free to fully examine the training programs in progress, simply because he is also a trainee and is thus restricted from obtaining certain information. By relieving the Superintendent -

Operations from the obligation to hold a current SRO license, the Superintendent -

Operations is then able to better fulfill these management responsibilities.

In addition, a substantial part of the Superintendent - Operations' time is consumed in maintaining the SRO license in an active status. The Licensed Operator Requalification Program requires four days of classroom I simulator instruction for each of eight cycles a year. In addition, the SRO must perform on-shift SRO duties, seven days each quarter-year. This 60 days of requalification time each year significantly impacts on the Superintendent - Operations' time available to manage the plant operations effectively.

To relieve the Superintendent - Operations of this burden and yet still satisfy the requirement for an "Operations Manager", we have instituted a position, directly subordinate to the Superintendent - Operations that has cognizance over the plant operating shifts. This position is the Supervisor - Shift Operations. who will be required to maintain a current and active SRO license and will fulfill the functional and qualification requirements of the "Operations Manager" as required by ANS-3.1 (12/79 Draft).

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e Docket Nos. 50-280 / 281 Serial No.90-581 Therefore these proposed changes are of an administrative nature, changing only the staff organization position of the individual designated to fulfill the functions of the "Operations Manager's" as described in ANS-3.1 (12/79 Draft). Requirements for the "Operations Manager" position remains unchanged and consistent with ANS-3.1 (12/79 Draft). The responsibility and authority of the "Operations Manager" position remains as the individual immediately superior to the operating shift supervisors.

In review of this technical specification change, it was identified that the complete reference to ANS-3.1 was missing in one instance. Along with the Superintendent SRO changes, this editorial correction was included in the proposed changes.

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e Docket Nos. 50-280 I 281 Serial No.90-581 BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION We have reviewed the proposed changes to Technical Specification 6.1.B which specifies exceptions to ANS-3.1 (Draft 12/79) to allow the Supervisor - Shift Operations to be the individual specified for providing the management-level Senior Reactor Operator's License, in lieu of the Superintendent - Operations.

We have found that these proposed changes will not involve a significant hazards considerations because:

(1) The changes to Technical Specification 6.1.B will not result in a significant increase in the probability or consequences of an accident previously evaluated.

These changes only redesignate the staff organization position of the individual which is assigned to perform the "Operations Manager's" functions as described in ANS-3.1 (12/79 Draft) without changing the required levels of training and qualification for that individual. The responsibility and authority of the "Operations Manager" will remain as the individual i_mmediately superior to the operating shift supervisors. The changes will not have any affect on the operation of the plant or any plant components or equipment.

(2) The changes to Technical Specification 6.1.B will not create the possibility of a new or different kind of accident. These changes only redesignate the staff organization position of the individual which is assigned to perform the "Operations Manager's" functions as described in ANS-3.1 (12/79 Draft) without changing the required levels of training and qualification for that individual. The responsibility and authority of the "Operations Manager" will remain as the individual immediately superior to the operating shift supervisors. The changes will not have any affect on the operation of the plant or any plant components or equipment.

(3) The changes to Technical Specification 6.1.B will not result in a significant reduction in the margins of safety. These changes only redesignate the staff organization position of the individual which is assigned to perform the "Operations Manager's" functions as described in ANS-3.1 (12/79 Draft) without changing the required levels of training and qualification for that individual. The responsibility and authority of the "Operations Manager" will remain as the individual immediately superior to the operating shift supervisors. The changes will not have any affect on the operation of the plant or any plant components or equipment.

Therefore, pursuant to 10 CFR 50.92, based on the above consideration, it has been determined that these changes will not involve a significant hazards consideration.

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