ML20095B095
| ML20095B095 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/14/1992 |
| From: | PUBLIC SERVICE CO. OF COLORADO |
| To: | |
| Shared Package | |
| ML20095B093 | List: |
| References | |
| NUDOCS 9204210340 | |
| Download: ML20095B095 (38) | |
Text
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.T_O P-22159 PROPOSED CHANGES This Attachment includes only l those pages with proposed changes.
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Cort St. Vrain Technical Specifications License Information Enclosure (1) to AEC Letter dated 12/21/73 i Amendment No. Page 4 of 5 (2) Technical Specifications The Technical Specifications contained in Appendices A . l and B, as revised through Amendment No. , are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical Specifications. l (3) Until all nuclear fuel has been removed from- the l Protected Area, the licensee shall fully implement and maintain in effect all provisions of the Commissi:n-1 approved physical security, guard training and qua'ification,
. ard safeguards contingency plans including amendments mede pursuant of'the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.05 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The. plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Fort St, Vrain Security Plac Fort St. Vrain
> Guard Training and Oualification Pli a and Fort St. Vrain Safeguards Contingency Plan.- Asi plans are with revisions submitted through June 6,1990 as supplemented i by letter dated September- 14, 1990. After all nuclear 1 fuel has been removed from the Protected Area, these l plans may be terminated, s
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(4) Introduction of New Natural Gas Sources ,
- While_ spent fuel or radioactive graphite core components j remain onsite, no new natural gas sources (i.e., sources other than those analyzed and found acceptable in the staff's Sa fety Eveluation in support of License Amendment No. 82) Snall be introduced within 0.5 miles of the location where spent fuel or radioactive graphite core components are stored, for any purpose, unless the licensee submits and the NRC has. reviewed and approved ,
- an analysis demonstrating that such natural gas will not ,
present an unacceptable hazard to the spent fuel or to the radioactive. graphite core _ components or to the
. equipment or systems:needed to protect the spent fuel or.
radioactive graphite core components. In accordance with this restriction, the opening of the c.-inch isolation valv ~e leading to the inch natural gas pipeliae south of the plant, for any purpose other than short-term maintenance and surveillance activities with the 6-inch valve continuously manned by an operator who has been instructed to promptly close the valve in the event a pipeline rupture is observed or suspe:ted, shall be considered a.new natural gas source ret iring cnalysis. F= . - - , ,,w...-,aet..- ,n- w..-.s., + - , . . _ - , - . - - . . , . . - , , , ---.-.-..-..e~-,--....---.,--..-,,,-----,,-,-.w- - - . . --.--..-,m..,#- , , , --sw
Fort St. Vrain #1 Technical Specifications Amendment No. . Page 7.1-1 7.1 ORGANIZATION, REVIEW, AND AUDIT-AOMINISTRATIVE CONTROLS Applicability Applies to the lines of authority and responsibility for the operational safety of the facility, and the organization for periodir. review and audit of facility operation. l Objectives j To define the principal lines of authority and l l
- responsibility for providing continuing review, evaluation, and 'J,provement of the plant operational safety.
SPECIFICATION AC 7.1.1 - ORGANIZATION, ADMINISTRATIV{ CCNTROLS
- 1. RESPONSIBILITY 1 a. The Defueling and Decommissioning Program Director <
l and. Station Manager shall be responsible for overall unit operation -and shall delegate in writing the succession to this responsibility during his l- absence. l. ! b. The Shif t Supervisor (or during his absence from the i control room and Shif t Supervisor's office, a -> designated individual) shall be responsible for the control room command function. A management I directive to this effect, signed by the Vice l President responsible for 'uclear activities shall be reissued to all station personnel on an annual basis. l.._ _ _ _ . _ . _ . . _ . _ , . _ . _ , . , . . . , , . . . _ . _ . _ _ . ._ _ _ - . - . - - . _ . _ . _
_ _ _ __-._... . _._ __. _ .___ _ _ _.__m _ _._. . . . _ - _ . _ _ Fort St. Vrain 01 Techrical Specificatioas Amendment No. Page 7.1-2 2, ORGANIZATION
- a. Onsite and Offsite Organizations
, Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The orsite and offsite organizations shall include 'he . 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, including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, tunctional ( descriptions of departmental responsibilities i and relationships, and job descriptions for key personnel positions, or in equivalent forms of L docueentation. These requirements shall be documented in the FSAR. , I (2)The Defueling and Decommissioning Program l Director and Station Manager shall be I responsible fnr overall unit safe operation and shall have control over those onsite activities necessary for safe cperation and maintenance of the plant.
4 Fort St. Vrain O! Technical' Specifications Amendment No. Page 7.1-3 l (3) The Vice president responsible for nuclear . I activities 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 technical support to the plant to ensure nuclear sa19ty. (4) The individuals who train the operating ;taff and those who carry out health physics and quality assurance functicns may rcport to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence .i om operating pressures. ~ l
- b. Unit Staff l (1) Until all nuclear fuel has been removed from the l Protected Area (as shown on Figure-6.3-2), each on-duty shif t shall be composed of at least the minimum shift crew composition shown in Table 7.1-1.
(2) A licensed operator must be in the control room at all times when fuel is in the reactor, [ ,. L t I (3) During shutdown and defueling conditions, until l all nudaar fuel has been removed from the
-( Protected Area, an individual with a valid R0 ,
(or SRO) license shall be present in the control l- room. L .- - - . = - .. . -. . - _ ..---. - - . - - - -
- _ _ . _ . _ ___. . ~ . _ _ . _ _ . _ _ _ _ _ ~ _ . . _ . . . _ _ _ _ _ _ _ . . _ _ _ _ _ _ . _ . . _ .
i 4 i Fort St. Vrain #1 Technical Specificatioas Amendment No. Page 7.1-4
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(4) During the performance of reactor startup, reactor shutdown, and recovery from reactor trip, two licensed operators must be in the control room, (5) All core alterations shall be observed and directly supervised by either a licensed Senior
- - Reactor Operator or Senior Reactor Operator Limi+ed to Fuel Handling who has no other
-concurrent responsibilities during this operation.
(6) An operator nr technician qualified in radiation
' protection procedures shall be present at the l facility at all times that there is nuclear fuel
) within the Protected Area, and during any
) physical activities involving radiologically ,
I contaminated systems or equipment. r (7) Fire Brigade staffing requi re nents have been incorporated into the Fire Protection Program-l [ Plan. A Fire Brigade is not required after all l l l nuclear fuel has been removed from the Protected
.l Area.
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_. _ . . _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ - _ _ . - _ ._._._._m.___. Fort St. Vrain 01 Technical Specifications Amendment No. Page 7.1-6 (d) Except during extended shutdown periods, the i use of overtime should be considered on an ! 1 individual basis and not for the entire staff on shift, i (9) If unusual circumstances arise rec,ui ring l deviation from the above guidelines, such . l deviation shall be authorized by the Defueling j and Decommissioning Program Director and Station Manager, ois designee, or higher levels of management, and with documentation o' the basis for granting the deviation. Controls shall be established such that excessive individual overtime hours have not been assigned. The paramount consideration in overtime assignment shall be that significant reductions in the ( effectiveness of operating personnel would be j highly unlikely, Routine deviation from the above guidelines is not authorized. L Authorized deviations to the working hour guidelines shall be documented and available for review by the Nuclear Regulatory Commission. (l (10)The Shift Supervisors, and the Operations l Manager shall hold a Senior Reactor Operator's license. The Reactor Operators shai! hold a
-l Reactor Operator's license. These are -t l
l requirements after all nuclear fuel nas been [ l -removed from the Protected Area. l
r Fort St. Vrain #1 Technical Specifications Amendment No. Page 7.1-7 (11) Except for the Shift Supervisor, the Shift Crew Composition may be one less than the minimum requirements of Table 7.1-1 for a period of time not to exceed 2 hours 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 of Table 7.1-1. This prot lsion de. 2 not permit any shift crew position to be unmanned upon shift change due to an oncoming shif t crewman being late or absent. This provision also does not exclude the requirement for an SR0 licensed individual to be in the control room at all times other than the shutdown conditions specified in Table 7.1-1. (12) During any absence of the Shift Supervisor from the control room or Shift Supervisor's office i' i while the unit is in Hot, Cold, or Refueling Shutoown, an individual with a valid SR0 license l-or R0 license shall be designated to assume the ! control room command function. During any l-l- - absence of-the Shift Supervisor from the control-room or Shift Supervisor's office during all l other-conditions, an individual with a valid SR0 license shall be designated to assume the l control room command function. These-are not t
- j. requirements after all nuclear fuel has been llI removed.from the_ Protected Area.
Fort St. Vrain 01 ' Technical Specifications
- Amendment No. ?
Page 7.1-8 TABLE 7.1-1 MINIMUM SHIFT CREW COMPOSITION (c) l l Number of Individuals Required to Fill Position l l l l l l I During Hot, Cold, or l l 1 l Position -l Refueling Shutdown (a) l All Other Conditions l I I I I e i I I I l SS (SRO) l 1 1 1 l i i I I I l SRO .I Not Required i 1 l l l 1 l _l R0 l 1 l 2(b) l l l l l I E0 l 1 l 1 l l l l l l AT l- Not Required .l 1 l 1 I I I I SS - Shift Supervisor with a Senior Reactor Operator's License SRO - Individual with a Senior Reac:or Operator's License R0 - Individual with a Reactor Operator's License l EO - Equipment Operator AT - Auxiliary Tender l NOTES
- i. a. Per Technical Specification definitions, Section 2.0.
- b. One of the two Reactor Operators may be an Equipment Operator with a valid R0_ license provided that the staffirg requirement for Equipment Operators is being met by another individual qualified as an Equipment Operator.
l c. Licensed operators and a minimum shift crew composition are - l not required after all nuclear fuel has been removed from the Protected Area. l t i l l l _ _ - . _ , - _ , - - . . - - - . . . . . . , m .- _ . . _ . , . . . _ _ _ , ~ . . . - _ . _ . . - . . . _ _ - . _ _ _ . - - . ~ - . _ . . _ _ - . - - - - - - - . -
Fort St. Vrain #1
. Technical Specifications Amendment No.
Page 7.1-8a
- 3. TECHNICAL ADVISORS l These requirements have been deleted in their entirety, i
I L i I l l. 1
Fort St. Vrain #1 Technical Specifications Amenament No. Page 7.1-8b l
- 4. UNIT STAFF OUALIFICATIONS
- a. The staffing of the plant shall be 'n accordance with Americati National Standards Institute.(ANSI) N18.1-1971,
" Selection and Training of Personnel for Nuclear Power Plants". -
- b. Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for the comparable position, except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8,. September, 1975.
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Fort St. Vrain 01
.- Technical Specifications
, Amendment No. Page 7.1-8c l 5. TRAININC
- a. A retraining and replacement training program for the facility staff shall be maintained under the direction l
l of the Facility Support Manager, and shall meet or y exceed the requirements and recommendations of Section 5.5 of ANSI N18,1-1971 and Appendix "A" of 10 CFR 55. l b, Until all nuclear fuel has been removed trom the l l Protected Area, a training program for the Fire Brigade l shall be maintained under the direction of the Facility Support Manager, and shall meet or exceed the l reoutrements of Section 27 of the NFPA Code-1975, except l 1 for Fire Brigade training / drill sessions which shall be l held at least once per calendar quarter. I
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Fort St. Vrain 01 Technical Specifications
- t. Amendment No.
j_ Page 7.1-9 l Specification AC 7.1.2 - Plant Operations Review Committee 1 (PORC), Administrative Controls l l l The organization, responsibilities, and authority of the l PORC shall be as follows: !~ l- 1. Membership i 1 The Plant Operations Review Committee shall be composed I of the following: l Chairman: Defueling and Decommissioning Program l, l Director and Station Manager l Deputy Program Director l Facility-Support Manager
-l Radiation Protection Manager l Operations Manager l l Defueling/Mcintenance Manager Systems Engineering Manager
-l Decommissioning Engineering Manager 1
4
- 2. Alternates i
An- alternate chairman and alternate members, if required, shall be appointed in writing by the PORC
- l. Chairman to serve the absence of a chairman or a-member; however, no more than two alternate members shall participate as voting members in PORC activities at any one time.
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Fort St. Vrain 01 Technical Specifications Amendment No. 4 Page 7.1-10 l l
- 3. Meeting Frequency The PORC shall meet at least once per calendar month and as convened by the Chairman or his designated alterrate.
- 4. Quorum A quorum shall consist of the Chairman or alternate l
Chairman, and four members including alternates.
- 5. Responsibilities
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i The PORC shall De responsible for: ' i
- a. Review of all procedures required by Technical Specification 7.4(a), (b),- (c), (d) and changes thereto, and any other proposed procedure or changes to approved procedures as determined by the i Defueling and Decommissioning Program Director and
( , Station Manager to affect nuclear safety.
- b. Review of all proposed tests and experiments that affect nuclear safety.
- c. Review of all proposed changes to the Technical Specifications.
~d , Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
l_ . _ . , ___ _._ _ _ __._ _ _...._ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
_ _.._ . _ . . . _ . _ _ _ _ . _ _ _ . _ _ ~ . _ - _ . . . - . _ _ . _ _ . _ _ _ . - _ _ . . . . _ _ _ Fort St. Vrain 01 Technical Specifications Amendment No. Page 7.1-11
- e. Investigation of all violations of the Technical Specifications including the preparation and forwarding of repor,s cov .he evaluation and recommendations to prevent recurrence to the l Defueling and Decommissioning Program Director and 4
Station Manager and to the Chairman of the Nuclear Facility Safety Committee. i f.- Review of all Reportable Events.
- g. Rev:aw of facility operations to detect potential ;
nuclear safety hazards,
- b. Performance of special reviews, investigations, and reports thereon as requested by the Chairman of the Nuclear Facility Safety Committee.
- i. Review of the Plant Security Plan and implementing procedures.
l j. Review of the plant Defueling Emergency Response Plan and implementing procedures. k.- -Review :of the Fire Protection Program Plan and implementing procedures. l l L3
--Fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-11a
- 6. Authority The PORC shall:
l a. Function to advise the Defueling and Decommissioning l Program Director and Station Manager on all matters that affect nuclear safety. [ b. Recommend to the Defueling and Decommissioning l Program Director and Station Manager in writing, approval or disapproval of items considered under 5.a through 5.d, above.
- c. Render determinations in writing with regard to whether or not each item considered under 5.a through 5.e above constitutes an unreviewed safety question.
- d. Pr' =< ide immediate written notification to the l Defueling and Decommissioning Program Director and Station Manager, and the Chairman of NFSC of l disagreement between the PORC and the Defueling and l Decommissioning Program Director and Station l Manager; however, the Defueling and Decommissioning l Program Director and Station Manager shall have responsibility for resolution of such disagreements pursuant to 6.a above.
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Fort St. '!rcin 01 Technical Specifications Amendment No. Page 7.1-12 4
- 7. Records The PORC shall maintain written minutes of each meeting l and copies shall be provided to the Defueling and l Decommissioning Program Director and Station Manager, and "hairman of the Fort St. Vrain Nuclear Facility Sa1.ty Committee.
6pecif P.ation AC 7.1.3 - Nuclear Facility Safety Committee (NFSC), Adminisirative Controls The organization, responsibilities, and authority of the NFSC shall be as follows:
- 1. Function The Nuclear Facility Safety Committee shall collectively have the competence required to review problems in the following areas:
- a. Nuclear Power Plant Operations
- b. Nuclear Engineering
- c. Chemistry and Radiochemistry L
- d. Metallurgy l
_ __ _ . .._ ._ _ . . m . _ _ _ _ . _ _ _ . _ _ _ . . . _ _ _ . _ . _ . . _ _ _ _ _ _ _ . _ . . . Fort St. Vrain #1 Technical Specifications Amendmant No. Page 7 1-13
- t. -Instrumentation and Control f Radiciogical Safety 4echanical and Electrical Engineering cy Assurance Practices appropriate fields associated with the unique
'acteristics of the nuclear power plant. 'g.'
- 2. Members The NFIC snal ce composed of the toliceeng:
Chei rman (As appointed - See Step 4) l Defueling and Decommis aning Program Director and Station
! Manager ,
l Deputy Program Director
-l Nuclear Licens!ng Manager l Systems'Engineeriag 'e nta<e l Decommissianing Engineering Manager l Quality Assurance t.4 nager l Radiation Protection Manager Safec, and Security Director i
Consultants,. as required, shr.ll b3 appointed in writing by ?
-l tiie Vict President responsible for nuclear activities.
- 3. Alternates p
Alternate . members,.1f required, shall be appointed in writing by L l tne Vice President responsible for nuclear activisies, however, no more than two alternate members shall participate as voting i p members in NFSC activities at any one time. l I. l [_
.>....,.- . ..-. - . - . - -. . - - . . - - ..- .. - - .. - . .-.- - ~ Fort St. Vrain #1 Technical Specifications Amendment No. Page 7.1-14
- 4. Chairman The Chairman and Alternate Cha'rman of the NFSC shall be I appointed in writing by the Vice President responsible l for nuclear activities and shall serve as members of the NFSC.
- 5. Consultants Consultants shall be utflized as determined by the Chairman, NFSC, to provide expert advice to the NFSC.
.6. Meeting Frequency The NFSC shall meet at least once per calendar quarter during the initial year of facility operation following l
fuel loading and at least once per six months thereafter.
- 7. Quorum A quorum of the NFSC shall consist of the Chairman or
- his designated alternate and a maj ori ty of the NFSC l
l members including alternates. No more tN.. a minority j_ of the -quorum shall have line responsibilities for L operation of the facility. B. Responsibilities
- a. The Nuclear Facility Safety Committee shall review:
(1).The safety evaluations for safety significant changer to procedures, equipment, or systems
Fort St. Vrain #1
- e- - Technical Specifications Amendment No.
Page 7.1-18 personnel or an outside fire protection firm; (b) a biennial audit of the fire protection program'and implementing piScedures; (c) a triennial fire protection and loss prevention inspection and audit utilizing an outside qualified fire consultant. , (9) The Offsite Oose Calculation Manual and Process l Control Program and implementing procedures at least once per 24 montns.
- (10) The Radiological Environmental Monitoring Program and the results thereof at least once
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per 12 months. (11) The performance of activities required by the , Quality Aesurance Program to meet the provisions of Regui.itory Guide 1.21 Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1. April 1975, at least once per 12 months.
- 9. Authority i l The NFSC shall report to and dvise the Vice President l- responsible for nuclear activities c. those areas of responsibility specified in 8.a, 8.b-and 8.c above.
- 10. Records- ,
Records. of NFSC-activities shall be prepared, approved,. and distributed as indicated below: \. l . L a. Minutes of each NFSC meeting shall be prepared and l forwarded to the Vice President rasponsible for 1 [ nuclear activities within 30 days following each meeting. l b o
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l Fort St. Vrain 01 i Technical Specifications Amendment No Page 7.1-19 l b. After preliminary approval by the Vice President l -responsible for nuclear activities, the minu'es shall be distributed to all NFSC members, and apprc,ved at the next NFSC meeting.
- c. Reports of reviews encompassed by Section 8.a, l above shall be forwarded to the Vice President i
l l responsible for nuclear activities, within 30 days l. l following completion of the review.
- d. Audit reports encompassed by Section 8.c, above l shall be forwarded to the Vice President responsible l for nuclear activities, and to the management positions responsible for the areas audited within 30 days after completion of the audit.
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Fort St. Vrain #1
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Technical Specifications Amendment No. .l Page 7.2-1 l l 7.2 SAFETY LIMITS, ADMINISTRATIVE CONTROLS l Applicability Applies to the administrative procedu'cas to be followed in the event that a safety limit is exceeded. Objectives To define the administrative procedures which will be
.followed in the event that a safety limit is exceeded.
Specification AC 7.2 - Action to be Taken if e Safety Limit is Exceeded, Administrative Controls If a safety limit is exceeded, as defined in Specification SL 3.1 and 3.2, the following action shall be taken:
- a. The reactor will be shut down immediately and reactor operations shall not be resumed until approval is received from the NRC.
- b. The safety limit violation shall be reported to the l Commission, the Defueling and Decommissioning
[ Pn0 gram Director and Station Manager, and to the Chairman, NFSC immediately,
- c. A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the PORC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective action taken .to prevent recurrence. ?- , d. The Safety Limit Violation Report- shall be submitted to -the. Commission, _the Chairman, NFSC and the l: 'l Defueling 'and Decommissioning Program Director and Station Manager within ten days of the violation. l [ l L L
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1 Fort St. Vrain #1 Technical Specifications Amendment No. Page 7.4-1 - 7.4 PROCEDURES - ADMINISTRATIVE CONTROLS Applicability Applies to administrative procedures which will goverr. plant operations. Objective To ensure that written procedures wiil be maint- . to define requirements-for plant operation. Specifica, tion AC 7.4 - Procedures, Administrative Controls
- a. Written procedures shall be established, implemented and maintained covering the activities
. referenced below:
E
- 1. The applicable procedures recommended in Appendix A of Safety Guide 33, November,1972.
-l: 2. Defueling activities.
- 3. Surveillance and test activities of safety-related equipment.
L- 4. Security Plan implementation.
- 5. Emergency Plan implementation.
- 6. Process Control Program (PCP) implementation.
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_ . . _ , . . _..m._ _ _ _ . - . _ _ . _ _ _ . _ - _ __ . _ . . . ~ . _ . _ _ _ _ _ _ . _ . - . . _ _ Fort St. Vrain #1 ,
- Technical Specifications >
Amendment No. , Page 7.5-3 and- surveillance, in-service inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and g refueling. The dosa assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film L.'ge measurements. Small exposures totaling less than 20% of-the individual total dose need not be accounted for. .In the aggregate, at least 80's of "ie whole body dose received from external sources shall be assigned to specific 4 major work functic:4.
.I c. Monthly'Ogerating Report i
l-L l The requirement for this report has been
-{: deleted.
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Fort St. Vrain #1 Technical Specif1 cations Amendment No. Page 7.5-4 l . i i 1 l l i 1 i l i I i l
- d. Annual Radiological Environmental i-Monitoring Report l:
l l A . report on the Radiological Environmental
' Monitoring Program for the previous calendar year shall be submitted to the- Nuclear Regulatory Commission in accordance with c
i 10 CFR 5:.4 as a separate document by-May 1 of each year, l: I r: L
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u Fort St. Vrain #1 Technical Specif', cations
/aendment No.
Page 7.s-7 , prepared .and submitted to the Nuclear P --
. Regul a to ry cot,mtssion in the Annual Radiological Envircnmental Monitoring Repo,t.
Effluent
- e. Semi-annual Radioactive Release Report Routine Radioactive Effluent Release Reports
- l covering the: activities or the unit during the ic l previous / menths shall be submitted within 60 days aftcr January 1 and July 1 of each Fear.
1- , The Radioactive Effluent Release Reports shall include a summary. of the quantities of radioactive liquid and gaseous effluents and solid vaste released from the unit as outlined
-in Regulato ry -Guide'1,21, " Measuring, Evaluating, and Reporting . Radioactivity in Solid Wastes and Releases of Radioactive Faterials in Liquid and Gaseous-Effluents from Light-Water-Cooled Nuclear . Power Plants,"
l Revision 1, June, 1974, with data summarized on -a quarterly basis following the format of . TAppencix B thereof. An annual summary of hourly meteorological data collected over the previous year shall be L
- maintained- for five years by the licensee.
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Fort St. Vrain #1 Technical Specifications Amandment No. Page 7.8-1 ll 7,8 HIGH RADIATION AREA
-l 7.8.1 Pursuant to 10 CFR 20, in lieu of the " control l device" or "aiarm signal", each high radiation l area, as defined in 10 CFR Part 20, shall be ll barricaded and conspicuously pested as a high
'l radiattor area and entrance thereto shall bc l controlled by requiring issuance of a Radiation l' l' Work Permit (RWP). Individuals qualified in l radiation protection procedures (e.g., Health l Physics personnel) or personnel continuously l escorted by sacF individuals may be exempt from the l RWF issuance requirement during the performance of l their assigned duties ir, high radiation areas with l exposure rates equal tc or less than 1000 mR/h, I provided they are ctherwise following plant l radiation-pratection procedures for entry into such
-j high radiation areas. Any individual or group of l: individuals permitted to etter such areas shall be ,
l provided with or accompanied by one or more of the l following: l a. A radiation monituring device which l- continuously indicates the radiation dose rate
- l. in the area, or l b. A _ radiation monitoring device which l continuously inteorates the radiation dose l rate -in 'the area and alarms when a preset i integrated dose is received. Entry into such s
- l. areas with this monitoring device may be made I af ter -the dose rate level ir, the area has been L
l established and personnel have been made (= knowledgeable of_them, or +
-1 c. A health physics qualified individual (i.e.,
l q2.!ified in radiation prctection procedures) l wito a radiation dose rate monitoring device j -who is responsible for providir positive
;l control over the ar.tivities within the area j and shall perform' periodic radiation l- rurveillance et the frequency specified by the l facility Health Physics staff in the RWP.
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F rt St. Vrain #1 ' Technical Specifications Amendment No. Page 7.8-2 l- 7.8.2 ;In addition to the require nts.of 7.8.1, areas j- accessible .to personnel with radiation levels j greater than 1000 mR/h at 45 cm (18 in.) f rom the [ radiation source or from~ any surface which the
-j radiatien penetrates shall be provided with locked l enclotures to prevent unauthorized entry, and the
.l keys shall be maintained uncer the administrative l control of the Shift Sup_rvisor on duty and/or j health physics supervision. Enclosures shall
] remain locked except during periods of access by l- personnel under an approved RWP which shall specify
-l the dose rate levels in the immediate work area.and l the maximum allowable stay time for individuals in j that area. In lieu of the stay time specification l of the RWP, direct or remote (such as use of closed l circuit TV cameras) continuous surveillance may be l- made by personnel qualified in radiation protection l procedures to provide positive exposure control l~ over tha activities within the area.
l For individual areas accessible to personnel with I radiation levels of greater than 1000 mR/h that are l located within large areas, where no enclosure l exists for purposes of locking, and no enclosure I can be reasonably constructed around the individual l . areas, then that area shall- be barricaded, [ conspicuously posted and a flashing light shall be
-l activated as a warning device whenever the dose 1 rate in the area exceeds or will shortly exceed
-l 1000 mRin.
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ATTACHMENT 3 70 P-92159-- NO SIGNIFICANT HAZARDS CONSIDERATION ANAIV3IS i I , i l' \ l
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Attachmer" 3 to P-9215; ' Page 1 UO SIGNIFIQANT HAZARDS CO'ISIDERATION ANALYSIS I This request to amend the FSV Facility-Operating License and the , Administrative Controls Section of the Technical specifications involves several administrative changes, all of which are associated with program re"isior.s and organizational changes appropriate for a permanently shutdown plant. Each change will be described and justified individually. These descriptions will then be followed by a No Significant Hazards Consideration Analysis in accordance with the criteria contained in 10 CJR 50.92.
- 1. Manacement Title CJLancres PSC has undr rtaker, a re-organization within Nuclear Operations to allow a better transition to the decommissioning organization. This re-organization eliminates certain positions and creates others, with the result that many of the positions identified within the Tecnnical Specifications must be revised.
I All references to.the Vice President, Nuclear Operations have been replaced with the Vice President responsible for nuclear activities. This designates the executive level position with , responsibility for all activities associated with Fort St. L Vrain. h All references to the Manager, Nuclear Production and Station Manager have been replaced with the Defueling and Decommissioning Program Director and Station Manager. Plant Operatich.3 Review Committee (FORC) membership has been l revised to include the following: Defueling and Decommissioning Program Director and Station Manager (formerly Manager, Nuclear l- Production and Station Manager) , L Deputy Program Director (new position) l- Facility Support Manager ' (formerly Nuclear Training and Support Manager) Radiation Protection Manager (formerly Superintendent of "hemistry and Radiation Protection) ll Operations Manager Defueling/ Maintenance Manager (new position) Systems Engineering Manager ' Decommissioning Engineering Manager (new position) l l l l . -. . .- .. - - - - - -
l Attachment 3 to P-92159 Page 2 Nuclear Facility Safety Comei+-tee (NFSC) membership has been revised to include the following: Chairman Defueling and Decommissioning Program Director and Station Manager (formerly Manager, Nuclear Production and Station Manager) Deputy Program Director (new position) Nuclear Licensing Manager (formerly Manager, Nuclear Licensing and Resource Management) Systems Engineering Manager (formerly Manager, Nuclear Engineering Division) Decommissioning Engineering Manage *- (new position) Quality Assurance Manager (formerly Manager, Quality Assurance Division) Radiation Protection Manager (formerly Nuclear Training and Support Manager) Safety and Security Director Consultants, as required t Justificattojl;_ The re-organization described above is illustrated on the attached organi?ation chart, provided for information. This organization will imp ove internal communications by reducing overall management positions and eliminating at least one level of management. Also, this organization focuses on the Office of the Program Director which will facilitate the transition into the Early Dismantlement decommissioning organization upon the completion of defueling. This organization retains sufficient-_ expertise and diversification within both the PORC and NFSC, consistent with ! that contained in the present committees, and with the guidance provided in the Standard Technical Specifications (e.g., Westinghouse STS, NUREG-04':2, Revirion 5). The functions and charters of these committees have not b1 1 l changed. l-l- l~ 1 l l 1
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l Attachment 3 to P-92159 l Page 4
- 2. Spyrity Prociram Deletion Af ter Fuel RemovT1 License Condition 3 was revised to allow the termination of the physical security plan, guard training and qualification, and safeguards contingency plans after all nuclear fuel has been removed from the FSV Protected Area, iTustificationi After all nuclear fuel has been removed from the FSV Protected Area, PSC will implement an Access Control plan, consistent with Section 8 of the Proposed Decommissioning Plan. At that time, FSV will not be a utilization facility as defined in 10 CFR 50.2, we will not conduct activitics licensed pursuant to 10 CFR 70, and formula quantities of strategic special nuclear material or special nuclear material will no longer be within the FSV Protected
' Area. Therefore, a physical security plan, guard training and qualification, and safeguard contingency plans in accordance with 10 CFR 73 will not be required.
- 3. Deletion of Licensed Operatcrs After Fucl Removal All requirements for licensed operators (e.g., RO, SPO, SSLO) were revised to allow the deletion of these positions once all nuclear fuc.1 has been removed from the FSV Protected Area.
JustifLcAtion: Once all nuclear fuel has bee 1 removed from the- FSV Protected Area, then Fort St. Vrain will no longer be considered a nuclear reactor or a utilization facility as-defined in 10 CFR 50.2. Therefore, the operator licensing requirements in 10 CFR 55 are not applicable and licensed operators are not required. This is consistent with the organizational requirements contained in the proposed FSV Decommissioning Technical Specifications (PSC Letter, Crawford to Weiss, dated March 19.-1992, P-92115).
. l Attachment 3 to P-92159 Page 5-
- 4. Deletion of Technical Advisor ,
All references to Technical Advisors were deleted. Justification: Deletion of the Technical Advisor position car. be accomplished at the present time, based on the permanent ! shutdcwn condition of the plant. This is consistent with the ! equivalent Shift Technical Advisor (STA) requirenents in the l Westinghouse Standard Technical Specifications (NUREG 0452, Revision 5). STS Table 6.2-1, Minimum Shif t c' ew Composition, j does not require that the STA position be ma. lined during cold ; shutdown and_ refueling modes. The permanently shutdown condition c.f Fort St. Vrain allows sufficient time for any
-plant-concerns'to_be resolved by available staff, including Operations, System Engineering, and Management personnel.
- 5. Dfletion of the Fire Bricade After Fuel Removal All requirements for a Fire Brigade were revised to allow deletion of the Fire Brigade after all nuclear fuel has been removed from the FSV Protected Area.
i Justification: Once all nuclear fuel has been removed , from the FSV Protected Area, Fort St. Vroin will essentially L have the same fire hazards that will exist during decommissioning. PSC has developed a Decommissioning Fire Protection Plan (D/FPP) appropriate for the hazards during decomm.ssion4.ng, and this plan does not include requirements 4 for a fire brigade.. The 10 CFR 50.59 safety evaluation for the 5/?PI states that a fire brigade is not required after all nuclear fuel has been removed from the plant based on the reduced consequences of a fire, and considering the availability of local offsite-fire department assistance. A copy of the 10 CFR 50.59 safety evaluation for the D/FPP was provided for NRC information under separate cover (PSC Letter, Crawford to Weiss, dated December 20, 1991, P-91434). l i. I l 1
N ' Attachment 3 to P-92159 Page 6
- 6. Fedefinition of Requirements for Radiation Protection Personnel The requirenent that an operator or technician qualified in radiation -protection procedures be present at the facility whenever fuel is on site was revised to apply whenever nuclear fuel is within the FSV Protected Area and during physical activities involving radioactively contaminated systems or equipment.
Justification: The FSV Independent Spent Fuel Storage Installation (ISFSI) is located on PSC property and therefore could be considered "on site". However, the ISFSI design does l not require that radiation protection personnel be on site : while fuel is being stored in the ISFSI. After all nuclear fuel has been removed from the Protected Area, radiation 4 protection personnel will be required on site during physical activities involving radioactively contaminated systems or equipment, to ensure adequate worker protection. i 1
- 7. Recuirement for Defuelina Procedures l Section 7.4 was revised to require. written procedures for "Defueling activities" in lieu of "Pefueling operations".
Justification: This revision .ormalizes PSC's current practices for applying the previous requirements for I l
" Refueling" administrative controls to "Defueling" activities.
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e Attachment 3 to P-92159 ! Page 7- l
- 8. Deletion of Monthly Operatina Report l l
The requirements to submit a Monthly Operating Report were i deleted. Justification: FSV AC 7.5.1.c requires that the Monthly Operating Report include: (1) a narrative summary of operating experience including major safety-related maintenance, (2) a report of aray single release of radioactivity or radiation exposure which accounts for more than 10% of the allowable annual values, (3) a report of indications of failed fuel, and (4) monthly statistical information contained in Regulatory Guide 1.16. Relative to Item (1), the FSV Possession Only License precludes any further operation of the plant. Therefore, there will be no additional operating experience to report. Also, the amount of major safety related maintenance has been and f s expected to be small, would not be of gener.ic interest, and is-not significant enough to support a monthly report. Regarding Item (2),. radioactivity releases that exceed specified limits must be reported within 30 days in accordance with Administrative Control 7.5.3, and- reports of overexposures are requir(i by 10 CFR 20.405. Regarding Item (3), there is no mechanism to create additional failed fuel, as long as LCO 4.2.15 PCRV liner cooling ; requirements are met. Any LCO 4.2.15 violations would be reportable via an LER. Regarding Item (4) , the Possession Only License precludes any further operation, so there will be no further power level, availability, or generation statistics to report, as required by Regulatory Guide 1.16.
- Most- of the Anthly Operatirj Report information is not l applicable for a permanently shutdown plant, and the
! information that would be applicable is available from other sources. Therefore, the continued submittal of a FSV Monthly Operating Report is not meaningful and this task mcy be deleted. i l l l 1 l
l Attachment 3 to P-92159 Page 8
- 9. Be_v_Jeion of Semi-annual Radioactive Ef fluerlt Release Report The requirement for the Semi-annual Radioactive Effluent Release Report to cover the previous six months of operation was revised to cover the previous six months.
Justifiqation: Further operation of Fort St. Vra i n has l been precluded by the Possession only License. Therefore, it j is appropriate that the Semi-annual Radioactive Effluent ' Release Report cover the previous six month period.
- 10. Addition of Hicth Radiation Area Controls ]
l 1 New Section 7.8 was added to provide requirements for conducting activities in a high radiation area under i Radioactive Work Permit controls. l Justification: These requirements are consistent with the Westinghouse Standard Technical Specifications (NUREG-0452, Revision 5), and with Appendix D of Draft Regulatory Guide DG-8006, " Control of Access to High and Very High Radiation Areas in Nuclear Power Plants", which is being developed cor,sistent with the new 10 CFR 20 requirerentr., 1 The proposed Section 7.8 differs from the Standard Technical l Specification (STS) wording in that specific 10 CFR 20 paragraph references have been deleted. Also, the specific criteria that dafine a high radiation area have been deleted, so that a high radiation area is "as defined in 10 CFR Part L 20". The paragraph numbers and the high radiation area i criteria differ retween the current 10 CFR 20 and the new 10 CFR 20. . PSC currently anticipates that defueling will be i completed before the implementation date of the new 10 CFR 20 requirements, and that the Decommissioning Technical Specifications will then supersede the existing Technical Specifications. However, the proposed Section 7.8 wordirig will allow use of either the current 10 CFR 20 or the new 10 CFR 20 requirements. An additional change from the STS wording is that the last sentence in Section 7.8.2 states that a flashing light will be activated as a warning device "whenever the dose rate in the area exceeds or will shortly exceed 1000 mR/h." The phrase in quotes in included in DG-8006, but it is not 3-part of the STS wording; PSC included this phrase as a clarification of the requirements for a warning device around a very high radiation area. i a
Attachment 3 to F-92159 Page 9 No Sionificant Ha::ards Conqlderation Analysis In accordance with the standards in 10 CFR 50.92, and based on the justification provided above, the proposed amendment to the FSV Facility Operating License and Technical Specifications involves no significant i.azards consideration, since it would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
This amendment generally maintains the current level of administrative controls until all nuclear fuel has been removed from the FSV Protected Area. The elimination of l Technical Advisors and the establishment of new high radiation i area controls is consistent with controls provided in the Standard Technical Specificacions in use at other nuclear facilities. Based on the justifications provided above in the discussion of individual proposed changes, the program reductions allowed after fuel has been removed from the Protected Area and the other proposed changes do not increase L the probability or the consequences of any previously evaluated accidents.
- 2. Create the possib._ity of a new or different kind of accident from any accident previously evaluated.
The proposed revisions to the Admi..istrative Controls do not create any new or abnormal modes of equipment operation and do not create the possibility of any new accidents.
- 3. Involve a'significant reduction in a margin of safety.
l~ l As1 long as nuclear fuel is located within the FSV Protected l Area, the same level of administrative review will be retained j as is currently in effect and personnel qualifications will be maintaintd. After nuclear fuel has been removed, the level of administrative controls provides an appropriate administrative i margin of - safety. No operational margins of safety are l- affected by this proposed amendment.
Conclusion:
Based on the above, it is concluded that performance of defueling or other shutdown activities at Fort St. Vrain, in accordance with the proposed changes to the Administrative Controls, will involve no'significant hazards consideration. l l
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