ML20081D355

Proposed Changes to ETS Re QA Organization

ML20081D355
Person / Time
Site:	Hatch
Issue date:	10/24/1983
From:	GEORGIA POWER CO.
To:
Shared Package
ML20081D340	List: ML20081D339 ML20081D347 ML20081D355
References
NUDOCS 8311010152
Download: ML20081D355 (7)

Text

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ATTACINENT 5 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HA101 NUCLEAR PIANP UNITS 1 AND 2 PROPOSED CHANGE 10 ENVIROtNENTAL TECHNICAL SPECIFICATIONS Replace the following pages of the Appendix "B" Environmental Technical Specifications with the enclosed pages. The revised pages are identified by amendment number and contain a vertical line indicating the area of change.

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! 8311010152 831024 PDR ADOCK 05000321  !

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r 5.0 Administrative Controls This section describes administrative and management controls established to implment the HfP Environmental Technical Specifications (ETS).

Measures specified in this section include assignments of responsibility, review and audit functions, procedures, and reporting requirements.

Corporate responsibility for implementation of the ETS and for assuring that the station is operated in such a way as to provide protection for the environment rests with the Senior Vice President - Power Supply.

Responsibilities for compliance with the ETS and for the environmental monitoring program required by the ETS are given below.

Independent audit shall be provided for all matters, as discussed in Section 5.3.2, by the Manager of Quality Assurance.

5.1 Responsibility 5.1.1 The General Manager is responsible for monitoring plant effluents; I for operating the plant within the Limiting Conditions for Operation (LCOs) specified in Section 2; and for the collection and measurm ents associated with all radiological samples described in Section 3.2, except for clams, American shad, shoreline sediment, and the annual surveys. These exceptions are the responsibility of the Manager of Environmental Affairs. The General Manager also is responsible for implementing the special l surveillance activities described in Sections 4.2 and 4.3.

5.1.2 The Manager of Environmental Affairs is responsible for the environmental monitoring programs specified in Sections 3 and 4, except as noted in Sections 5.1.1 and 5.1.3 He also is responsible for Section 4.1 and for those aspects of Section 3.2 that are not assigned either (1) to the General Manager by Section 5.1.1 or (ii) to the Chief Nuclear Engineer by Section 5. The Manager of Environmental Affairs is responsible for coordinating these programs with appropriate groups.

5.1.3 The Chief Nuclear Engineer is responsible for the interpretation, l evaluation, and routine reporting of the results of the radiological environmental monitoring program described in Section 3.2.

5.1.4 The General Manager of Quality Assurance and Radiological Health and Safety is responsible for conducting periodic audits of plant operations and the environmental monitoring activities to ensure i conformance with the ETS.

5.2 Organization A chart showing company organization relative to environmental matters is presented in Figure 5.2-1. Changes affecting company organization depicted in Figure 5.2-1 will not require NRC approval prior to implementation, but such changes shall be reported to tRC within 30 days in accordance with Section 5.7.2 5-1

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l 5.3 Review and Audit 5.3.1 Independent Review 5.3.1.1 The General Manager is responsible for routine review of l plant operations to ensure that HtP is operated in compliance with the LCOs specified in Section 2.

5.3.1.2 The Manager of Environmental Affairs shall review the i following:

a. The conduct of the environmental monitoring programs, on a routine basis, to ensure that the specifications in Sections 3 and 4 are being implemented.

b. Prooosed changes to plant systems or equipment, provided such changes are identified by the Plant Review Board as having a potential adverse environmental impact.

c. Procedures for implementing the responsibilities specified in Section 5.1.2, and proposed changes thereto.

d. Proposed changes *n the ETS.

e. Proposed changes to the Environmental Programs Description Document.

5.3.1.3 The Safety Review Board (SRB) shall review the following:

a. Proposed changes to the ETS.

b. Results of the environmental monitoring programs prior to their submittal in each Annual Environmental Surveillance Report,

c. Violations of ETS 'to determine whether. adequate corrective action is being taken to prevent recurrence.

d. Procedures or changes hereto, which could affect' the monitoring of station operation, that may be considered by the Manager of Environmental Affairs,'

the Chief Nuclear Engineer, or the Plant Review Board to be appropriate for SRB review. l.

5.3.1.4 The Plant Review Board (PRB) shall review the following:

a. Proposed changes to plant systems or equipment.

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b. Procedures for implementing the responsibilities specified in Section 5.1.1, and proposed changes l thereto. l

c. Proposed changes to the ETS.

d. Unplanned releases of a radioactive material from the ,

sit e. '

5.3.1.5 The Chief Nuclear Engineer shall review the following: l

a. Proposed changes to plant systems or equipment, provided that such changes are identified by the PRB as having. a potential radiological environmental impact. ~

b. Proposed changes to Section 3.2 of the ETS.

5.3.2 Audit Responsibility 5.3.2.1 The General Manager of Quality Assurance and Radiological Health and _ Safety is responsible for an -

audit, conducted at least once a year, of the activities of the General Manager, the Manager of Environmental Affairs, ._and the Chief Nuclear Engineer related to- l compliance with the ETS.

5.3.2.2 Audits of facility activities shall be performed at least once a year under the cognizance of the SRB - to ensure conformance of facility operation to all provisions of the ETS.

5.4 Action to be taken if a Limiting Condition for Operation is Exceeded 5.4.1 Remedial action, as permitted by the ETS, shall be taken until the LCO.can be achieved.

5.4.2 Violations of an LCO will be reportedIimmediately- to the General Manager. ~

5.4.3 A separate. report oft each LC0 violation shall be prepared by the General Manager. - Copies of such reports 'will be submitted to the Vice President and-General Manager Nuclear Generation, the Manager of Environmental Affairs, the Chief Nuclear Engineer, and -the Chairman of.the SRB for review and approval of corrective ~ actions, as specified in Section 5.3.1.3c. .

5.4.4 The General Manager ~shall report 'such > violations ~ to : the NRC ;in' accordance with Section 5.7.2.

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5.5 ' State and Federal Permit Certifications .

Section '401- of - PL- 92-500,n.the _ ~ Federal ' Water - Pollution - Control . Act ?

Amendments -of>1972 (FWPCA), requires any-applicant for a Federal license or permit to conduct any activity;that may result in any discharge into;

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provisions of Sections 301, 302, 306, and 307 of the FWPCA. Section 401 of PL 92-500 further requires that any certification provided under this smtion shall set forth any effluent limitations and other limitations and monitoring requirements nmessary to assure that any applicant for a federal license or permit will comply with the applicable limitations.

Certifications provided in accordance with Section 401 set forth conditions on the Federal license or permit for which the certification is provided. Accordingly, the licensee shall comply with the requirements set forth in the currently applicable 401 certification dated December 22, 1972, and amendments thereto issued to the licensee by the Georgia Environmental Protection Division. In accordance with the provisions of the Georgia Water Quality Control act, the FWPCA and the rules and regulations promulgated pursuant to each of these acts, the Georgia Environmental Protection Division, under authority delegated by the U. S.

EPA, issued NPDES Permit No. GA 0004120 to the licensee. The NPDES permit authorizes the licensee to discharge from HNP Units 1 and 2 to the Altamaha River in accordance with effluent limitations, monitoring requirements, and other conditions stipulated in the permit, effective June 1,1977, through March 31, 1982.

Subsequent revisions to the certifications will be accommodated in accordance with the provisions of Section 5.7.3.

5.6 Procedures Detailed written procedures, including applicable check lists and instructions, shall be prepared and followed for all activities involved in imp 1menting the ETS. Procedures shall apply to sampling, data recording and storage, instrument calibration, measurement and data recording and storage, instrument calibraton, measurement and analysis, and actions to be taken when limits are approached or exceeded. These frequencies shall be determined from experience with similar instruments in similar environments and from manufacturers' technical manuals.

Plant operating procedures may be referenced in the above procedures in areas pertaining to maintenance and calibration of instrumentation and in other such areas of interface with the above procedures.

All procedures shall be maintained in a manner convenient for review and inspection. Procedures which are the responsibility of the General l Manager shall be kept at the plant. Procedures which are the responsibility of the Manager of Environmental Affairs and the Chief l Nuclear Engineer shall be kept at the GPC General Office.

5.6.1 Environmental Programs Description Document Based on these procedures, the licensee shall prepare and follow an environmental program description document (EPDD) describing the monitoring programs that are required by Sections 3.1 and 4.1. This document shall include descriptions of sampling

! equipment locations, frequencies and number of replications, sample analyses, data recording and storage, and instrument calibrations where appropriate.

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c. The licensee shall maintain records of changes to EPDD and to facility design or operation made pursuant to this section. The licensee also shall maintain records of tests and experiments carried out pursuant to paragraph (a) of this section. These records shall include a written evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question of substantive impact, or does not constitute a change in the objmtives of the ETS, or does not affect the requirements of Section 5. 6. 5. The licensee shall furnish to the NRC, annually or at such shorter intervals as may be specified in the license, a report containing descriptions, analyses, int erpretations, and evaluations of such changes, tests, and experiments.

d. Changes in the EPDD which affect sampling frequency, location, gear, or replication shall be reported to the NRC within 30 days after their imp 1 mentation, unless otherwise reported in accordance with Section -

5.7.3. Changes which affect sampling technique or data recording and storage shall be reported to the NRC at the end of the year. These reports shall provide a description of the changes made, the reasons for making the changes, and an evaluation of the environmental impact of these changes.

e. Proposed changes or modifications to plant systems or equipment shall be reviewed in accordance with Section 5.3.

f. Proposed changes to procedures for implementing the responsibilities specified in Section 5.1.1 shall be reviewed and approved by the PRB. Tmporary changes to the procedures that do not change the intent of the original procedure may be made with the concurrence of two individuals holding senior reactor operator licenses. Such changes shall be documented and subsequently reviewed by the PRB and approved by the General Manager on a timely basis. l

g. Proposed changes to procedures for implementing the responsibilities specified in Section 5.1.2 shall be reviewed by the staff of Environmental Affairs. Such proposed changes shall subsequently be reviewed and approved by the Manager of Environmental Affairs.

Proposed changes to procedures for imp 1menting the responsibilities specified in Section 5.1.3 shall be reviewed by the staff of the Chief Nuclear Engineer. l Such proposed changes shall subsequently be reviewed and approved by the Chief Nuclear Engineer. When l deemed appropriate by the Manager of Environmental Affairs or the Chief Nuclear Engineer, such proposed l changes also shall be reviewed by the SRB prior to implemenation.

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• CURRENTLY VACANT

• • CURRENTLY FILLED BY SAFE INDIVIDUAL EXECUTIVE VICE PRESIDENT POWER SUPPLY GEhTRAL MANAGER SAFETY REVIEW QUALITY ASSURANCE Ahl) ~'

BOARD (SRB) RADIOLOGICAL IEALTH AND SAFETY I I SENIOR SENIOR V.P.

.'VICE PRESIDENT ENG. CONSTRUCTION POWER GENERATION & PROJECT MANAGER w

S I V.P. POWER **

VICE PRESIDENT SUPPLY ENGINEERING

- & GENERAL MANAGER NUCLEAR GENERATION AND SERVICES I I H GIER**

NUCLEA GENERATI N ,

I I GENERAL MANAGER, MANACER OF PLANT HATCH ENVIRONMENTAL AFFAIRS N

HATCH PLANT REVIEW -

QUALITY ASSURANCE BOARD (PRB) SITE MANAGER ORGANIZATION STRUCTURE RELATED TO ENVIRONMENTAL ACTIVITIES FIGURE 5.2-1 A