ML20072C373

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Proposed Tech Specs Re Administrative Controls
ML20072C373
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/12/1994
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20072C361 List:
References
NUDOCS 9408170204
Download: ML20072C373 (29)


Text

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j4fe 2 of 3o INDEX ADMINISTRATIVE CONTROLS SECTION P&E 6.1 RESPONSIBILITY................................................ 6-1 6.2 ORGANIZATION.................................................. 6-1 6.2.1 ONSITE AND OFFSITE ORGANIZATION............................. 6-1 1 1

6.2.2 UNIT STAFF...............,................................. , 6-1 j GA 'E 6. M IMUM IFT CR COMPOS ION TWO ITS WIT C CONTRO 6

.2.3 IND ENDENT SAFETY NGINEER G GROUP ROOM............................/.

SEG)

F nction........ ........ ........ ......... ......... ..... 6-4 I J

Compos ion.. ......... ........ ........ .......... ....... 6-4 l Resp sibil ies.... ........ ......... .................... 6-Re rds.. ........ ........ ......... ......... ............ 4 6.2.4 , IFTJCHNICAL)@ VISOR.,................................ 6-4_)

6.3 UNIT STAFF 00ALIFICATIONS.................................... ~ 6-4 6.4 TRAINING..................................................... 6-5 6.5 novita snu suvii.UO.T...M .. . S6D

..................................... 6-5 6.5.1 TATION PERATI SREVIEWC TTEE (S C)

, Functi n..... ............. ......... ........... .......... 6-5 Comp sitio ....... ...... ......... ............ .......... 6-5 Al ernat ...... ................. ........... ........... . 6-5 etin Freque cy..... ......... ............ ........... .. 6-6 Quor ...... ....... .......... ............ ............... 6-Re onsibil ties............. ............ ........... ..... 66 cords.. ....... ......... ............. ........... ...... -8 6.5.2 OPERATI S REVI COPHITT- (ORC)

Funct n................................................. 6-8 Comp sition. ......... ............ ........................ 6-8 Al rnates. ......... ............ ............ ............ 6-9 C nsultan ........ ............ ............. ............ 6-eeting equency. ........... ............. ............... 6 Quorum. ........ ............ ............. ............ ... -9 Revie ......... ........... ............. ............. .... 6-9 Audi s....... ........... .............. ................... 6-10 Re rds.... ............ ............. ............. ....... 6-11 j

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COMANCHF PFAE HWTTC 1 AND 2 xv Unit 1 - Amendment No. 14 9408170204 940812 PDR ADOCK 05000445 p PDR

p a d- so INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.5h TEthlCAl. R VIEWCONTR AN S.... ........ ..... ..........

fil 6.6 p _, _,_ ~ ~,., _ ~. . ..v..o.r...u..s.e..p... ..................... 6_13 t

6.7 SAFETY LIMIT VIOLATION........................................ 6-13 6.8 PROCEDURES AND PR0 GRAMS....................................... 6-13 6.9 REPORTING RE0VIREMENTS........................................ 6-17 6.9.1 ROUTINE REP 0RTS............................................. 6-17 g-dt et s %,o(t . . ./. . . ./. . . ./ . . ./. . . ./. . . ./. . . ./. . . ./. . . [ . . .j . . ./. . . / / 6./17D AnnualReports.............................................. 6-18 Annual Radiological Environmental Operating Report. . . . . . . .. . 6-19 Annual Radioactive Effluent Release Report. . . . . . . . . . . . . . . . . . 6-19 Monthly Operating Reports................................... 6-19 Core Operating Limits Report................................ 6-20 6.9.2 SPECIAL REP 0RTS............................................. 6-22 6.10 nu.unu 5&D noion..nu ... b/o..T.~...u................

................. 6-22 ,

6.11 "ADI AT I O" "ROTECT IO" ^^00"A;L . N9.V. 454 Og . . . . . . . . . . . . . . . . . _6-23 6.12 HIGH RADIATION AREA.......................................... 6-23 I , mm , . . . - - - . - ---

6.13 \ omm,e muu a sr,wwninut r nuune t ru r 1..M.C.TT.. .M. 5 6. .D.. . .. . .. . . . . .. . .... 6-25

\_

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6.14 0FFSITE DOSE CALCULATION MANUAL (00CM)....................... 6-25 l

l COMANCHE PEAK - UNITS 1 AND 2 xvi Unit 1 - Amendment No. 2b Unit 2 - Amendment No.11

. fefe Yob 30 ADMINISTRATIVE CONTROLS 1

6.1 RESPONSIBILITY 6.1.1 o :: :t':: The ;fVice Presiden th -i'*, " La ,' 9:Nuclear Operations *shall be responsible for overall

/ "h:t ":-

tion of the unit T;m v.w T.u.w.nv noJ ;;r .t.; 1 b cz;:::'Me ':r opera-

..: ^ :7. tion. .nu 6,m 7 .at ";...;;c A hb 4ek shall ee d delegaawe in writing the succ,ession to this responsibility during absence.

6.1.2 theu NSM.T The Shif ,,h;;. eger% }:r dur':; l,; ...m L....;; ' ;

L ;;,,;t:d indi. n u r th ;.ntr:1 rn;, e R ~ 'd h '.: U shall be responsible for the control m connund fu Vice President?,nction.

Nucleare ^ ::: A_ management directive to this effect, signed by the R ::? 5: n _ doAc4iotM shall  ::ibe r issued to allvp%f{ station personnel, 6.2 ORGANIZATION _

6.2.1 IMJ447  ;

ONSITE AND OFFSITE ORGANIZATION i An onsite and an offsite organization shall be established for unit operation and corporate management, respectively.

organization safety of the nuclear shall power include the positions for activities affecting theThe onsite plant.

a.

^

lished and defined from the highest management lev mediate levels to and including all operating organization positions.  !

Those relationships shall be documented and updated, as appropriate, in the for1s of organizational charts, functional descriptions of departmental for ke responsibilities and relationships, and job descriptions tion. y personnel These req positions, or in the equivalent forms of documenta-

b. nts shall be documented in the FSAR.

The Vice Preside overall site safe clear Operation [shall be responsible for activities necessary for safe opeparation and shall have control over those

c. The Group Vice President, Nuclea - gagajintenance of the plant.

-- -W t-d ^ : it h .; shall have corporate responsibility for ove,rall 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 safety.

  • d.

The individuals who train the operating staff and those who carry out the radiation protection and quality assurance functions may report to the appropriate manager onsite; however, they shall have sufficient i organizational freedom to ensure their independence from operating pressures. _

6.2.2 UNIT STAFF ~

4 gjg g]

adch e-

.b The unit organization shal gt: zijnt t. the follow ng: WJ e,u

/ d*v D 'fM i, wih"i ~LgA e

?* %,***

h !(' $" j-N .i $ l % - N M N " 222 ~ " ' " ' " " ~ " " " '

a

_ COMANCHE PEAK - UNITS 1 AND 2 6-1 year 9 Unit 1 - Amendment No. 9, 14 t

' Attachment 3 to TXX-94216 Page 5 of 30 l

I INSERT A 1 i

The Vice President of Nuclear Operations *, or his designee, in accordance with approved administrative procedures, shall approve prior to implementation, each proposed test or experiment and proposed changes and modifications to unit systems or equipment that affect nuclear safety.

INSERT B During any absence of the Shift Manager from the control room while the unit is in MODE 1, 2. 3 or 4. an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.

During any absence of the Shift Manager from the control room while the unit is in MODE 5 or 6 an individual with an active SR0 license or Reactor Operator license shall be designated to assume the control room command function.

INSERT C Duties may be performed by the Plant Manager if that organizational position is assigned.

~-

  • fAfe6 & 3D ADMINISTRATIVE CONTROLS UNIT STAFF (Continued)
b. At least one licensed Operator for each unit shall be in the control room when fuel is in either reactor. In addition, while either unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Operator shall be in the control room;
c. A Radiation Protection Technician
  • and a Chemistry Technician
  • shall be on site when fuel is in the reactor;
d. All C E ALTE TIONS hall be observ and di actly upervi d by eith a lic nsed Se or Ope tor or icons Senio Opera r Li ted to F el Hand ing who has no ther co curren respo ibilit es d ing thi operat on; _ ,

a Q A site Fire Brigade of at least five members

  • shall be maintained on site at all times. The Fire Brigade shall not include the Shift M s g %;;rvi:cr and the two other members of the minimum shift crew l necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency; OC[. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related -

functions (e.g., licensed Senior Operators, licensed Operators, Radiation Protection Technicians, auxiliary operators, and key maintenance personnel).

The amount of overtime worked by unit staff members performing l safety-related functions shall be limited in accordance with the NRC Policy Statement on working hours (Generic Letter No. 82-12); and h The Shift Operations Manager shall hold a Senior Reactor Operator license. ,

I l

l l

l

  • The Radiation Protection and the Chemistry Technicians and Fire Brigade composition may be less than the minimum requirements 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 to accosmodate unexpected absence, provided immediate action is taken to fill the required positions.

COMANCHE PEAK - UNITS 1 AND 2 6-2 Unit 1 - Amendment No. 14

TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION TWO UNITS WITH A COMON CONTROL ROON POSITION

\NUMBEROFINDIVIOUALSREQUIREDTOFILLP BOTH UNITS \ N BOTH UNITS IN ONE UNIT IN MODE I',2,3, or 4 MODE 1,2,3 MODE 5 or 6 or 4 AND or DEFUELED ONEUNITINMODEj or 6 or DEFUELED l SS SRO 1

\1 71 ]

ne**

1

,/ 1 R0 3*

A0 2*\ [ 3*

3* 3*

\ j/ 3*

STA 1*** None

\[ 1***

SS -

SRO -

Shift Supervisor with a S .ior Operator license RO Individual with a Senior op rator license Individual with an Oper ter iconse AO -

Auxiliary Operator ,

STA -

Shift Technical Advi or The shift crew composition may Table 6.2-1 for a period of ti one less than he minimum requirements of ,

unexpected absence of on-duty not to exceed 2 ours in order to accommodate  !

taken to restore the shift er ift crew members p vided immediate action is composition to with the minimum requirements  !

of Table 6.2-1. This provis n does not pemit any ift crew position to be I unmanned upon shift change ue to an oncoming shift c n being late or  !

absent.

During any absence of t is in MODE 1, 2, 3, or Shift Supervisor from the contro room while the unit shall be designated t , an individual with a valid Sento Operator license fabsenceoftheShiftSupervisorfromthecontrolroomwhiletassume unit is in the contr MODE 5 or 6 an i license sha 1 he vidual with a valid Senior Operator licens or Operator ,

. signated to assume the control room command nction.

  • At least position of theunit.

r each required individuals must be assigned to the designated

    • At least one licensed Senior Operator or licensed Senior Operator sited to Fue j has'n otherHandling must be present during CORE ALTERATIONS on either it, who concurrent responsibilities. f
      • The Su TA position shall be manned in MODES 1, 2, 3, and 4 unless the Sh t 3 rvisor or the individual with a Senior Operator license meets the alifications described in Option 1 of the Commission Policy Statement o j ngineering Expertise (50 FR 43621, October 28,1985).  !

COMANCHE PEAK - UNITS 1 AND 2 6-3 Unit 1 - Amendment No. 14 y

f+p 894 30 ADMINISTRATIVE CONTROLS NDEPE ENTSAFETYENdkNEERINGGR6UP(ISEG[ N FUNCTION

[ [

6.2.3.1 The ISEG shaTl functiorvto examin nit ope ting char teris ics, NRC 17 uances, industry advi les, Licertree Event eports, an other sources of unit design and operatin experienc infomati , includi units of k sindlar design /which may,f dicate ar as for i oving unit safety. The I G

, s)(all make dftailed reepfunendatio for revi procedur , equi nt mo fi-(

ations, mai'ntenance a t'ivities, perations tivities, other ans o I

/improvingdanit safet to the Gr p Vice Pr ident, Nucl ar Engi ering nd Operati,pns.

COMPQS'ITION

6.[3.2 The IS G shall . composed / of at least fi , dedica ed, fu -time eng

. ryears located'on site. ach shall ha've a bachelo s degree in eng eering or 7 telated sc 4nce and a least 3 year profession level ex rienc in his fi d RESPONSIR LITIES

. 6.2.3f 5' The ISEG hall be resp sible for intaining rveillnceofun}- '

activities to pr ide independa'nt verifica ion

  • that t ese ac vities ar p formed corre tly and that usan error are reduc as much as practi 1.

// RECORDS k 6.2.3.4 cords of acti ities perf by the SEG shal be prepa d, main-

! tained, fomarded ch calenda month to t Group Vi e Preside t, Nuclear -

Engineeying and Opera ions.

-f (6.2.4 / SHIFT TECitil L ADVISOR _ -

3 76.I.4. The Shift Technical Adv$sor (STA) shall provide advisory technical up rt to the Shif - %:-&r in the areas of themal hydraulics, reactor engineering, and pla t analysis with regard to the safe operation of the unit.

The Shift Technical isor shall have a bachelor's degree or equivalent in a scientific or engineer discipline and shall have received specific training in the response and analy s of the unit for transtants and accidents, and in unitdesignandlayout,incQing_thecapabilitiesofinstrumentationand controls in the control room. Ghger) 6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-i tions of AftSI-4118.1-1971 for comparable positions, except for the Radiation i

. Protection ftinager**--who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, for a Radiation Protection Manager. The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifica-tions of the supplemental requirements specified in Settions A and C of Enclo-sure 1 of the March 28, 1980 NRC letter to all licensees. (Prior to meeting

  • Not responsible for sign-off function.
    • Until the Radiation Protection Manager meets all qualifications per Regulatory Guide 1.8, September 1975, the Assistant Radiation Protection Manager, who meets all of those qualifications, shall be responsible for the technical aspects of the program.

COMANCHE PEAK - UNITS 1 AND 2 6-4 Unit 1 - Amendment No. 9

  • f4fe.1 of =JD  ;

ADMINISTRATIVE CONTROLS UNIT STAFF QUALIFICATIONS (Continued) the qualifications of ANSI-N18.1-1971, technicians and maintenance personnel may be permitted to perform work in the specific task (s) for which qualification has been demonstrated.)

6.4 TRAINING i

6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Vice President, Nuclear Operations and shall meet or exceed the requirements and recommendations of ANSI-N18.1-1971, 10 CFR 55, and shall include familiarization with relevant industry operational experience.

1CVIE" AC A"0IT-Sor A 56 I /STATIOV0PERATIENS REV(EW COMl7 TEE (SodC) l FUN ON

.5.1.1 The C shan functi to adv se th Vice Pr sident, clear Oper .ons. 11 m ters re ted to clea safety. .

C SITI

.5.1. The C sha as a mi r a !; compos of manMrs or i viduals epor ng d actly managers rw S i area listed below and t the requ rene s of I-N18.1-1 1 Sec tons 4. or 4.4 f r requir 'experienc .

O eratio s ainte nce Inst ntat and Co rols Tec feal pport

/

Ra ation rotectio

{ ality ssurance 7 ci The lant Man r shal serve s the c f risan of 5 . A se or hea h physi is acc able fo the R iation rotection re resentat e on RC. Th i RC member shall ~desig ted, i writing, by he Vice side , Nucl r

. peratio .

ALTE TES

  • 1.3 1 altern a rs shall be ppointed n writ by t Vice resid , Nuclear Operat ns to serv nat ary ba s; h ver, no more

'than t alterna s shal participat s voting rs n 50RC activities at a time. L

, i i

l COMANCHE PEAK - UNITS 1 AND 2 6-5

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  • ppe. to of go ADMINISTRATIVE CONTROLS

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MUTING FREQUENC 6.5.1.4 50RC shall et at least ce per calendar no h and as convene y the 50RC airman or h designated ternate. )

5 The q run of th ORC necessary for e performance of e SORC onsibilit and autho yprovisionsoftIseTechnicalSpec) cations

[ resp.1.5 shall cons t of the C rean or his desig ted alternate an majority of the reg members er their alternates .

RESPONSIBILITIE

.l.6 Th RC shall be resp sible for:

a. Review of applica M administrat,i e procedures recomme d in Appendix A of Refulatory Guid 1.33, Revision 2, Fe ary, 1978.
b. Review of safety evalu ions for: (1 p ures, (2) change to proc res, equipment systems or faci i es, and (3) tests or' '

der the provisio of 10 CFR 50.59 to y Wy

/ experi nts completed tha uch actions not constitute unreviewed safety q on;

c. Keview of pro procedures a changes to procedure uipment, systems or ilities which i lve an unreviewed sa question as defined ip 0 CFR 50.59 or volves a change in T nical Specif entions;
d. Re ow of proposed st or experiments wMch involve an unreview '

fety question defined in 10 CFR .59 or requires a cha in Technical 5 ications;

. Review o proposed changes echnical Specificat s or the Opera License;

f. stigation of al lations of the T nical Specifications ,-

. including the fo ing of reports covering evaluation and recoV moedations to vent recurrence to tfie Vice President, Nucleaf operations to the ORC;

g. Review e reports of operati abnormalities, devia ns from expec [d pe nce of plant equipment and of unanticipa deficiencies design or operation,6f structures, syst r components t affect nuclear safet
h. Review of all R RTABLE EVENTS; f'

C%C"2 PEAK - UNITS 1 AND 2 6-6

. .. - . - - - . . - - . = . - - -_ .- - _ . . . , ..

pye. // o s' 3D ADMINISTRATIVE CONTROLS RESPONSIBILifiS(Contdd) ~

l

. vi f the Sec ty Plan and 11 submit recomme d6d changes to

{ j. eview of e Emergency P to the C; and shall submij recommended change

/

k. R ew of changes thePROCESSC0p PROGRAM, the OFF TE 00SE ALCULATION MANU , and Radwaste featment Systems; Review of accidental, un anned or uncontroll radioactive release recommen)dations, and discluding the prep ation of reports co ring -eval sition of the corr ive action to prev recufrence and the fo rding of these re ts to P e'sident, Nuclear erations, and to t the Vice ORC; nv Review of Unit erations to date potential hazards safety; nuclear
n. Investi Chai ions or analysis f special subjegt as requested by the n of the ORC or e Vice President Nuclear Operations; .

o.

view of the Fire rotection Report nd implementing procedu and submittal o ecommended cha s to the ORC; and s Review of Technical Requi nts Manual and revis thereto.

6.5.1.7 The C shall:

a.

k ecosamend in wri ng to the designated ger (see Specificatio 6.5.3) approv or disapproval of it 6.5.1.6a th ugh a prior to their considered under Spec cation lesentation; ,

b.

Render eterminations in writ with regard to what r or not each i

it onsidered under Spec cation 6.5.1.6a. th )

a reviewed safety qu lon; and h e. constitutes i

c. l Provide written no l

President, Nucle ication within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Group Vice y Revieu Committ Engineering and Opera ons and the Operat shs of disagreement bet the 50RC and the manager (seeJ 4 pecification 6.5.3 ignated Nuclear Opsiations shall have res); nsibility for resolver, lon of such the Vice Pr disagre nts pursuant to Speci cation 6.1.1.

i COMANCHE PEAK - UNITS 1 AND 2 6-7 Unit 1 - Amendment No. 9

-- .--- - -. . . -- - .-. .- . = .

'gye./Lof M ADMINISTRATIVE CONTROLS g -

6.5.1.8 /The 50RC sha 1 maintal ritten minute ofeachSORC'meetingt).t, at a misfinus, docuedint the resq s of all 50R activities pe'rformed under the respop'sibility py4 visions of hese Technicay'Specificatio s. Copies fhall be provided to th Vice Presid t, Nuclear 0 rations and e Operatio s Review Co 'ittee.

.5.2 OPE TIONS REVIE COM4ITTEE ( C) I FUNCTI /

6.5, 1 The OR shall functi to provide i ependent r iew and audit des'ignated actt'vities in the reas of:

a. ear power nt operation ,
b. Nuclear engi ring, c radiochemis ry,

! d. Chemistry (an Metallu [

e. Instr ntation and ontrol,
f. Radfological safe ,
g. 'chanical and7octricalentneering,and
h. Quality assur ce practic . -

The C shall repo to and ad se the Group Vi e President, uclear Engine ing a Operations o those area of responsibili specified i Specificatio

.5.2.7 and 6. 2.8.

- COMPOSITION' 6.5. The ORC sha be composed o at least six ndividual of whom no mor,afthan a minori are members h ino line res nsibility or operations at f CF3ES. The Chai and all rs will be appointed by e Group Vice f resident, Nu ar Engineeri nd Operatio .

The ORC ainoan shall h a Bachelor' degree in an engineering or p)fsical scien told or equiv,4 ent experien and a minimuur of 6 years tech feal man rial experi .-

e ORC member n an engineeri or physical science fiel(yorhall hold a Bac equivalent eiperienceelor's degr and a inimum of 5 ye s technical experienc Vuith the exceptifn of CASE's esentative, Mrs Juanita Ellis, and CASE's, alternate designated by Mrs. Ellis It is the res nsibility of t Chairman to ensure expatience and coupe 4nce is availab to review pro ens in ar s listed in Spec)fication 6.5.2.1 . through h. To a large measu , this perience and comp 6tence rests with he membership .the ORC. I ecialized areas, this experience may be pro ed by personnel who act as con itants to the ORC, /

,/ -

COMANCHE PEAK - UNITS 1 AND 2 6-8 Unit 1 - Amendment No. 9

p.gfe, /3 c 4 9 0 ADMINISTRATIVE CONTROLS p

ALTERNATES

/

6.5.2.3 The alternate for the' Chairman an all alternat members shall be  ;

appointedJn,writingbytheAroupVice/ resident,Nucl,enrEngineeringand P'

Operatioris shall 6ticipate toasserve votingon a ' temporary membe basis; however, 6s at any one timl in ORC activitj .

CONSULTANTS 5.2.4 Consul nts shal ba utilized as tormined by the C airman, ORC

[toprovidee t advic to the ORC.

MEETING FREOUENCY 6.5.2. The ORC hall meet at l o t once per calen r quarter during the init 1 year f ng and at least once therofMnit fter. operation /.o11 ceding fuel loa r

6 nths '

I l 000 RUM 6.5.2.6 The quorum of he ORC necessar for the perforaanc the ORC review and au it functions these Technic Specifications sha consist of not , k les than a majorit of the conoin th individuals (or the r alternates) and hairman or h s desi7u+n 0.ernate. No more t an a minority of the rum s 11 have line responsibility for operation of th nit.

CASE's repr entative, Mrs Juanita Ellis or f E's alternate des ated by s

Mrs. Ellis during the p iod she serves as member of the ORC shall be I entitl o all of th ights and privil s that all other i ividuals have as member of the ORC, t for the purpos of this paragraph all not be counted for tablishing meeting quorum r uirements.

j EVIEW 6.5.2.7 he ORC shall responsible for t review of:

a. The safet evaluations for: ) changes to procedure , equipment, or sy  ; and (2) tests experiments completed nder the provision of 1 FR-50.59, to ver that such actions di et constitute an jewed safety que ion;
b. Proposed changes o procedures, equipse , or systems which invo e an unreviewed saf y question as defined n 10 CFR 50.59;

[ c. Proposed sts or experiments wh questic as defined in iG CFR involve an unrevi safety

(.

.59;

d. Pro sed changes to Techn tal Specifications or is Operating L ense; COMANCHE PEAK - UNITS 1 AND 2 6-9 Unit 1 - Amendment No. 9 ,

1

' p e., l'f o f- 3 D l

ADMINISTRATIVE CONTROLS b

hEVIEW(Contirw6M /

e.

/ / /-

Violations o - es, regulaM ons, orde (TechnicalSpecficaticns, license re rements, or,ef internal cedures or instr)uctions having nuclear ety signific(nce; ,

f. Sigpdicantopera,1 abnormal its or deviatioffs from normal and pected pe ance of uni equipment that ffect nuclear safe y; All REPOST BLE EVENTS-
h. All gnized ipd cations of an nticipated defift'ency in some.

spect of desigff or operation o structures, sys s, or components that could fact nuclear saf y; and -

l

1. Repor and meeting min s of the SORC. l AUDITS 6.5.2. Audits of uni p ctivities shall performed under cognizance of the C. These audi f shall encompass-
a. The cofiformance of uni paration to prov ons contained within T3c(nical Specifica ns and applicabl iconse conditions at ast nce per 12 month ,

. The perfo ce, training, and alifications of the tire unit staff at least ce per 12 months-

c. The sults of actions aken to correct def ciencies occurrin n unit e ipment, structur , systems, or motbed of operation th affect fiuclear safety, east once per 6 nths;

. The perfo . ce of activities uired by the ational Quality Assurancyfrogram to meet t criteria of Ap dix B, 10 CFR 50, at least once per 24 months-

e. e fire protectio rogrammatic c is including the imp nting procedures at 1 l t once per 24 ths by qualified lice e QA f '

personnel; l

f. The fi ~p Fotection equi nt and program impi ntation at least once per months utilizin either a qualified site licensee f protection eng eer or an outside i pendent fire protecti onsultant. An o side independent fi protection consulta shall be used at less every third year;
g. The Radioly cal Environmental nitoring Program a he results thereof . east once per 1 nths;
h. T FFSITE DOSE CALCU TION MANUAL a enenting procedures at

- st once per 24 y hs; f COMANCHE PEAK - UNITS 1 AND 2 6-10

y 15 o f M j l

ADMINISTRATIVE CONTROLS Q ITS (Continuedf

1. ePROCESSCONT)t0LPROGRAMandimplement)figproceduresforprocessing f fand packaging af radioact 9e wastes at 4ast once per 24 months; l

The perforpra e of activities requiped by the Quality urance Program or effluenVand environmental monitoring at,l' east once per 12 mop s;

k. Ap[otherar f unit operation considered appyepriate by the ORC r the Group V President, Nuclear Engineering ind Operations; an  ;

The perf reance of ac Kvities required by he Technical Requirements Manual at least once 'per 24 months.

ECORDS

/6.5.2.9ecords of ORC ctivities shallA e prepared, appro ed, and distributed as indi ated below: /

a. Minutes,s' each ORC me ng shall be prepar , approved, and forwarded to the,Afice Presiden , Nuclear Operations nd Group Vice President, Nuciptr Engineerin and Operations with 14 days following each .

me ing;

b. Reports of r iews enecepassed by pecification 6.5.2.7 hall be prepared. ' to the Vice Presi t, Nuclear Operati (,sapproved, and Groupand Viceforwar P dent, Nuclear Engi ering and Operat ns within 14 days lowing completion the review; and j c. A t reports encompa by Specificatio .5.2.8 shall be fo ded

[ f the Vice Presiden Nuclear Operatio and Group Vice Pre nt, Nuclear Engineeri and Operations a to the management p tons responsible for e areas audited hin 30 days after c letion of the audit by e auditing organi tion.  ;

6. 3 TECHNICAL REVM W Ale CONTROLS 6.5.3.1 Activi es which affect clear safety shall be nducted as follows: l
a. urei~requir by Specification 6.8 a other procedures wh affect plant nuc ar safety, and changes ereto, shall be propred, reviewed and a roved. Each such proc re or procedure cha e shall be rev by a qualified ind dual /troup other th the individual / oup which prepared th procedure or procedu change, but who be from the same o ization as the indiv ual/ group which pared the procedure procedure change. Vice President, Nuc1 r Operations, shall a ove Station Administ tive Procedures, Se rity Plan Implementiny>rocedures, and Energ cy Plan Implementing) ocedures. Other proc ures shall be approv y the appropriat je

/

COMANCHE PEAK - UNITS 1 AND 2 6-11 Unit 1 - knendment No. 9

' ge, & of- 3 0 ADMINISTRATIVE CONTROLS

/ -

~-

TECHNICAL REVIEW ANO. CONTROLS (Continue V depar) manager as pr iously designat Vice Pre NucJear Operations, i writing. Indivi is responsibl or procedure r,efiews shall be ers of the Nucl Operations gement Staff reviously desigpd'ted by the Vic President, Nucle Operations.

Changes to propedures which d ot change the iptint of approved pro-cedures may e approved for splementation by, two members of the j/

/ Nuclear 0 rations Mana nt Staff, at le g one of whom hol Senior perator Licen , provided such 4pifroval is prior to t plemen-tat sh and is docu ted. Such chang t'shall be approv y the o ginal approva authority within days of impi ation; b Proposed t s and experiment ich affect pla nuclear safety shall be prepa d, reviewed, and proved. Each su test or experiment -

ified individua roup other than the shall ind vidual/ ,be reviewed group whicby a .repared the prop ed test or experiment ro-d test and ex nts shall be a roved before implemen ion by e Plant Nanag Individuals re nsible for conducti such reviews shall e members of the clear. Operations N ement Staff '

previously signated by tne ice President, Nucl Operations;

, c. Propo changes or modif tations to plant clear safety-related g st ures, systems an components shal reviewed as designate V '

he Chief Engine . Each such ication shall be revie d by

- qualified indiv ual/ group meet the experience requipesients of

, ANSI N18.1-1g7 Section 4.6 ot r than the individua roup which designed th ification, who say be from th organization as the in vidual/ group designed the mod cations.

Indivi is/ groups resp sible for conducti such reviews shall be i prov usly designat y the Chief Engi r. Proposed modificatio toj lant nuclear s ety-related stru res, systems and compo by the Plant Ma er prior to implementat  ;

/hallbeapprov

. Individual responsible for views performed in ac ance with the re nts of Spec cations 6.5.3.la and .3.lb, shall be membe of the Nuclea rations Management ff previously de nated by the ce President, Nuclear rations. Each such

! law shall in e a determination of other or not additiona cross-discip ary review is necessa . If deemed necessary, ch

, , review sh be done in accordanc ith the appropriate qual ication requi nts; i

e. h review shall includ determination of'whether r not an unreviewed safety ques on is involved. For item nvolving unreviewed safety q stions, NRC approval shal obtained pt r to the Plant Man r approval for implement on; and 2
f. The Securit lan and Emergency Plan, a implement procedures, shall be viewed at least once per 1 months. R oemended changes to he i ementing procedures shall approved b the Vice President, COMANCHE PEAK - UNITS 1 AND 2 6-12 1 -

c .

f+fc /70 S 3D l ADMINISTRATIVE CONTROLS I

ICHNIdAL REVIIW AND C6NTROLS TontinuedV Nuclear 0 rations Reco ed chan s to th lans sh

'eviewe#pursuan be otherequirementsofSpec1[eication .5.1.6 nd

/ approved shall/be obtai by d asthe, ice dent, Pre ap opriate.

Nu lear Operations. N appro al

6. 5.3. 2 : .cyrds of t to ffhe Vic above at ivities/ described n 6.5.3.} shall provided) required r views. Presiden , Nuclear /Operatio,rls, SORC, jind/or f ORC 'as nece7sary f 6.6, E E"E"T ACTION _#0 7 (AC &b g T follo ing a 'ttons shall take for R RTABL EVENTS.

t a

The onmiis ion s 11 be otift and a report ubmitt d purs ant t th requi ement of 10 FR 50 73 and

b. ach RE RTA8L EVEN shall e revi of thi revi d by he 50 , and he re ults Nucle r Oper ions.

shal be su itted o the C and he Vic Pres dent j e

6.7 SAFETY LIMIT VIOLATION

~

6.7.1 The following actions shall be taken in the event a Safety Limit is violated: -

a. f4st /AAusyerf Th In accordance with 10 CFR 50.72 the NRC Operations Center, shall be notified by telephone as soon, as practical and in all case within o 1 Presiden hour after the vio4ation has been detemined.Th ice uclear Operations and the Operations Review Comittee (ORC) sha0+i be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

A Licensee Event Report shall be prepared in accordance with 10 CFR 50.73.

fQ gz,s

c. The Licensee Event Report shall be us M tted to the C is n n accordance with 10 CFR 50.73, and tokthe Vice Presiden J uclear Operations *, Station Operations Review Committee (SORC), and Operation Review Committee (ORC) within 30 days after discovery of the event.
d. Critical operation of the unit shall not be resumed until authorized by the Nuclear Regu1& tory Commission.

6.8 PROCEDURES AND PROGpM S 6.8.1 Written procedures sha17 be established, implemented, and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978; j

%- lf far oegahAHowa.I fosHhd is Ass31u&

COMANCHE PEAK - UNITS 1 AND 2 6-13 1

'pp If o f- 3 C)

ADMINISTRATIVE CONTROLS I

, , I PROCEDURES AM) PROGRAMS (Continued)

b. The emergency operating procedures required to implement the require-ments of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Section 7.1 of Generic Letter No. 82-33;

~ lut ws* P m

c. -Secur4ty-F14n-4mpi:::nt at hn;-

Mt and

{

d. E :rg:r.:y Pl:n iii;ple.ent& tion; i M,7 urue '
e. QROCESS CONTROL PROC"JM 4mp ;ntationi
f. OFFSITE DOSE CALCULATION MANUAL implementation; ,

)

g. Quality Assurance for effluent and environmental monitoring;
h. Fire protection program implementation; and
i. Tachaical Requirements Manual implementation.

ran m W 6.8.2 EteA prece+Fe 2nd id-iaietnti = palicy af Spect'icatien 6.8.1 abeve, and ch: ;:s therete, sham-be-revir:i and apprev^d prier te i;;;1: :9tatien :n set feth ia Saecification 5.5 t have; -

6.8.3 The following programs shall be established, implemented, and maintained: "

a. Primary Coolant Sources Outside Containannt A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the post accident recirculation portions of the Containment Spray System, Safety Injection System, Chemical and Volume Control System, RHR System, and RCS Sampling System (Post Accident Sampling System portion only). The program shall include the following: ,
1) Preventive maintenance and periodic visual inspection require-ments, and
2) Integrated leak test requirements for each system at refueling le intervals or less. l ht ese 1
b. , In-P! sat Ediatiea Mariteri # ,

l f A program t de 'ermin /the Ich wit ensur the cap ility t 'accur9 ely airborne ine co centra on in y al area under acciden condition . This progr shall i lude th fall ng:

( 1) T aining f pers' nel, ,

l l

COMANCHE PEAK - UNITS 1 AND 2 6-14 l

l

l g e l'f c h 3 D ADMINISTRATIVE CONTROLS PROCEDURES AE PROGRAMS (Continued)

In tRa'diationknitorinoIContinued!

2) Proce\ ures for monitorin , and
3) Provis pns for mgintenanc sof sampli and an lysis (quipme t.
c. Secondary Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. This program shall include:

1)

Identification of a sampling schedule for the critical variables and control points for these variables, 2)

Identification the of the procedures used to measure tha values of critical variables, 3)

Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage, 4)

Procedures for the recording and management of data, 5)

Procedures defining corrective actions for all off-control '

point chemistry conditions, and

6) A procedure identifying:

(a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action.

d. Post-Accident Sa=alina A program which will ensure the capability to obtain and analyze effluents, and containment atmosphere samples und conditions.

The program shall include the following:

1) Training of personnel,
2) Procedures for sampling and analysis, and '

3)

Provisions for maintenance of sampling and analysis equipment.

e.

Radioactive Effluent Controls Procram A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS achievable. OF THE PU81.IC from radioactive affluents as low as reas The program (1) shall be contained in the 00CM, (2) shall COMANCHE PEAK - UNITS 1 AND 2 6-15

  • (7* y e. 2D o f - BD ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)
e. Radioactive Effluent Controls Proaram (Continued) be implemented by operating procedures, and (3) shall-include remedial

, actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and set-point determination in accordance with the methodology in the 00CM,
2) Limitations on the concentrations of radioactive material i released in liquid effluents to UNRESTRICTED AREAS conforming to 10 CFR 20, Appendix B, Table II, Column 2,
3) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the 00CM, >
4) Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS -

conforming to Appendix I to 10 CFR 50,

5) Determination of cumulative and projected dose contributions from radioactive affluents for the current calendar quarter and current calendar year in accordance with the methodology and ,

parameters in the 00CM at least every 31 days, 4 1

6) Limitations on the operability and use of the liquid and gaseous l effluent treatment systems to ensure that the appropriate por- I tions of these systems are used to reduce releases of radioactiv- i ity when the projected doses in a 31-day period would exceed 2 l percent of the guidelines for the annual dose or dose connitment conforming to Appendix I to 10 CFR 50,
7) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the SITE BOUNDARY conforming to the doses associated with 10 CFR 20, Appendix B, l Table II, Column 1, 1
8) Limitations on the annual and quarterly' air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR 50,
9) Limitations on the annual and quarterly doses to a MEMBER OF  ;

THE PU8LIC from Iodine-131, Iodine-133, tritium, and all radio- 1 nuclides in particulate form with half-lives greater than 8 days 1 in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR 50, and COMANCHE PEAK - UNITS 1 AND 2 6-16

e -,;w. - - - _ _ .

f4f e 3/ o h 30

, ADMINISTRATIVE CONTROLS 1

PROCEDURES AE PROGRAMS (Continued)

e. Radioactive Effluent Controls Procram (Continued)
10) Limitations on the annual dose or dose connitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR 190, n V

/

f. RadioloaicIl Environme[tal Monitorina Proaram A program shall b rovided to monitor t e radiati and radio clides in the envirorgof the plant'. The prcMiram shall rovide (1)fepresen-tative measurements of radioactivity /in the higke,st potential exposure pathways, program an modeling

/ monitoring,ahd The prpfram shall ()) be contain,pf (2) ver[if t' cation environmental ed in the QtfCM, guidance of Appendix ! to 10 CFR 50, and G) include t (2) conf rmexposure to the following:

of / pa

1) Monitoring sampling, analysis, an reporting radiation and radionuc}' ides in th environment n accordanc with the methodology and pa amaters in t 00CM,
2) AL d Use Cens to ensure atchangesJhtheuseofaras.at and beyond the ITEBOUNDAylareidentifjedandthatmodi' fica- )

/ ions to the nitoring p ogram are madd if required by/the results of is census, nd 3 Particip. ion in a I erlaboratory C. arison Program to ensure that i pendent ch ks on the prec sion and accurjicy of th measur nts of ra onctivemateriisinenvironapntalsamp/ le matr s are perf aspartofthequalityas7uranceprogram for , vironmental monitoring. ,

6.9 REPORTING RE00IREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional

. Administrator of the Regional Office of the NRC unless otherwise noted.

STAkTdk>[tdotish L- , - .

6.9.1_._1ksuadaryrpp'ortof'unitdtof fartu [ndp _ _ ' esca ation t ' sting 11 6 M rece Oper ing Li ense, ) amen nt tfI

)' be thesutnyritted/following:

1 const'invol ing a g an)ned/increa in p r lov , (3) i stalla on ql fue hat has a ifferent des n or been nufac red by diffe/ent f4el s su lier and ) mod ficati s tha y hav signiycantly i tered' thef~~uel e ar,,

t,rtcal or h rauli perfo ance the u t

COMANCHE PEAK - UNITS 1 AND 2 6-17 Unit 1 - Amendment No. 14

/ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _

y 2% o b 30 ADMINISTRATIVE CONTROLS TARTUPREPORi(Cont /nued) ~

The init Star up Re t shall'iddress sa of thi st tup tests dentified n I the Fin afety/nalysisRe rt and sha include descript 6n l Chapter of the' measure/14 of,d valuys of the/ operating nditions or characteri ics obta ned I during theftest program and a compariso of these vt ues with d ign pred ctions '

anp'specif1 cations /. Any co/rective ac ions that were required o obtain satis-f ctory operatiovshall al'so be described. Any ad'itional d s cific det ils equirpd in lics'nse conditions bases on other conimitments s 1 be ine uded in j r up tests hat are this yeport.

neceAsary , Subsequent t demonstrate the Startup 1% of acceptability ports changesshalland iddress sta#ortions. modifi St tup Re rts sh4 be subai ed within: (1) 90 days following ompleti n of the St. tup Test Program, 2) 90 days f 11owing res tion or commenc nt of dommerci power operation, (3) 9 mon s followin initial e iticali y, j isearfiest. If a Startup port does t cover a thre events

[w(hichev i.e., nitial criticality completion of Startup T st Progr , and r;tsumption 1

l or countencement/of commer ial operati ), suppl taryrepo/tsshaflbesub- '

mittedlat leastyevery 3 nths until all three av nts have been completed.

/

q _ /

ANNUAL REPORTS

  • l 6.9.1.2 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year.

The initial report shall be submitted prior to March 1 of the year following ,

initial criticality.

Reports required on an annual basis shall include:

a. A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mres/yr and their associated man-res exposure according to work and job functions ** e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling.

The dose assignments to various duty functions may be estimated based on pocket dosimeter, thermoluminescent dosimeter (TLD), or i film badge measurements. Small exposures totalling less than 20% of the individual total dose need not be accounted for. In the aggre-gate, at least 80% of the total whole-body dose received from external sources should be assigned to specific major work functions;

  • A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station.

COMANCHE PEAK - UNITS 1 AND 2 6-18

g 23 of 30 j ADMINISTRATIVE CONTROLS

. ANNUAL REPORTS (Continuedi

b. The results of specific activity analyses in which the primary coolant exceeded the limits of Specification 3.4.7. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded (in graphic and tabular format); (2) Results of the last isotopic analysis for radiciodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radiciodine activity was reduced to loss than limit. Each result should include date and time of sampling and the

.radiciodine concentrations; (3) Clean-up flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration (yC1/gm) and one other radioidine isotope concentration (gCi/ga) as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary i coolant exceeded the radioiodine limit.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM, and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix ! to 10 CFR 50.

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT **

l.

6.9.1.4 The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted prior to May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. .The material provided shall be (1) consistent with the objectives outlined in the 00CM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of-Appendix ! to 10 CFR 50.

MONTHLY OPERATING REPORTS 4

6.9.1.5 Routine reports of operating statistics and shutdown experience, including documentat' ion of all challenges to the PORVs or safety valves, i

  • A single submittal may be made for a multiple unit ' station.

1

    • A singlr, submittal may be made for a multi-unit station. The submittal should combine those sections that are common to all units at the station; l however, for units with separate radwaste systems','the' submittal shall 'i specify the releases of radioactive material from each unit, j i

. COMANCHE PEAK - UNITS 1 AND 2 6-19 Unit 1 - Amendment No. 25 I Unit 2 - Amendment No.11

/+7e M of 3 0 ADMINISTRATIVE CONTROLS MONTHLY OPERATING REPORTS (Continued) shall be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regi 1 Administrator of the Regional Office of the NRC, no later than th -Mth-of each month following the calendar month covered by the report, p CORE OPERATING LIMITS REPORT l

6.9.1.6a Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT (COLR) before each reload cycle or any remaining part of a reload cycle for the following:

1). Moderator temperature coefficient BOL and E0L limits and 300 ppm sur-veillance limit for Specification 3/4.1.1.3, 2). Shutdown Rod Insertion Limit for Specification 3/4.1.3.5, 3). Control Rod Insertion Limits for Specification 3/4.1.3.6, 4). AXIAL FLUX DIFFERENCE Limits and target band for Specification 3/4.2.1.,

5). Heat Flux Hot Channel Factor, K(Z), W(Z), and FqRTP for Specifica-tion 3/4.2.2, 6). Nuclear Enthalpy Rise Hot Channel Factor Limit and the Power Factor Multiplier for Specification 3/4.2.3.

6.9.1.6b The following analytical methods used to determine the core operating limits are for Units 1 and 2, unless otherwise stated, and shall be those previously approved by the NRC in:

1). WCAP-9272-P-A, ' WESTINGHOUSE REL0AD SAFETY EVALUATION NETH000 LOGY,"

July 1985 (M Proprietary). (Methodology for Specifications 3.1.1.3 -

Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Bank Insertion Limit, 3.1.3.6 - Control Bank Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 - Heat Flux Hot Channel Factor, and 3.2.3 - Nuclear Enthalpy Rise Hot Channel Factor.)

2). WCAP-8385, " POWER DISTRIBUTION CONTROL A2 LOAD F0LLOWING PROCEDURES -

TOPICAL REPORT," September 1974 (W Proprietary). (Methodology for Specification 3.2.1 - Axial Flux Difference [ Constant Axial Offset

. Contro1b)_ l 3). T. M. Anderson to K. Kniel (Chief of Core Performance Branch, NRC

. January 31, 1980--

Attachment:

Operation and Safety Analysis Aspects of an -Improved Load Follow Package. (Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control).)

4). _MUREG-0800, Standard Review Plan, U.S. Nuclear Regulatory Cossnission, Section 4.3, Nuclear Design, July 1981. Branch Technical Position CP8 4,3-1, Westinghouse Constant Axial Offset Control (CAOC), Rev. 2, July 1981. (Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control).)

COMANCHE PEAK - UNITS 1 AND 2 6-20 Unit 1 - Amendment No. 6, 14

a "

g gg 4 3e

, ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (Continued) 5). WCAP-10216-P-A, " RELAXATION OF CONSTANT AXIAL OFFSET CONTROL F SURVEIL-LANCE TECHNICAL SPECIFICATION," June 1983 (W Proprietary).

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor (W(z) surveillance requirements for F Methodology).)

6). WCAP-10079-P-A, "NOTRUMP, A N00AL TRANSIENT SMALL BREAX AND GENERAL NETWORK CODE," August 1985, (W Proprietary). l 7). WCAP-10054-P-A, " WESTINGHOUSE SMALL BREAK ECCS EVALUATION MODEL USING THE NOTRUMP CODE", August 1985, W Proprietary). l 8). WCAP-11145-P-A, " WESTINGHOUSE SMALL BREAX LOCA ECCS EVALUATION MODEL GENERIC STUDY WITH THE NOTRUMP CODE", October 1986, W Proprietary). l 9). RXE-90-006-P, " Power Distribution Control Analysis and Overtemperature N-16 and Overpower N-16 Trip Setpoint Methodology," February 1991.

(Methodology for Specification 3.2.1 - Axial Flux Difference, 3.2.2 -

l Heat Flux Hot Channel Factor.)

10). RXE-88-102-P, "TUE-1 Departure from Nucleate Boiling Correlation",

January 1989.

11). RXE-88-102-P, Sup. 1, "TUE-1 DN8 Correlation - Supplement 1",

December 1990.

12). RXE-89-002, "VIPRE-01 Core Thermal-Hydraulic Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", June 1989.

13). RXE-91-001, " Transient Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", February 1991.

14). RXE-91-002, " Reactivity Anomaly Events Methodology", May 1991.

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Bank Insertion Limit, 3.1.3.6 -

Control Bank Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 -

Heat Flux Hot Channel Factor, 3.2.3 - Nuclear Enthalpy Rise Hot Channel Factor.)

15). RXE-90-007,. "Large Break Loss of Coolant Accident Analysis

! Methodology", December 1990.

16). TXX-88306, " Steam Generator Tube Rupture Analysis", March 15, 1988.

Reference 17) is for Unit 1 only: l 17). WCAP-9220-P-A, " WESTINGHOUSE ECCS EVALUATION MODEL, February 1978 Version," February 1978 (W Proprietary).

COMANCHE PEAK - UNITS 1 AND 2 6-21 Unit 1 - Amendment No. 4,6,+4,M,21 Unit 2 - Amendment No. 4,7

  • ~
  • pje, 2 G c h } 0 ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (Continued)

Reference 18) is for Unit 2 only: l 18). WCAP-9220-P-A, Rev. 1 " WESTINGHOUSE ECCS EVALUATION MODEL- 1981 Version", February 1982 (W Proprietary).

6.9.1.6c The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as SHUTDOWN MARGIN, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.6d The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements thereto, shall be provided upon issuance, for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector, i

l l

1 COMANCHE PEAK - UNITS 1 AND 2 6-21a Unit 1 - Amendment No. 21 Unit 2 - Amendment No. 7

/+7c 27of- @

' ADMINISTRATIVE CONTROLS ,

SPECIALREPORTS 6.9.2 In addities to the applicable reporting requirements of Title 10, Code of Federal Requistions, special reports shall be submitted to the Regional Admin-1strator of the Regional Office of the NRC within the time period specified for each report y

6.10 bRff0RD-RETENTIDW A/CT US 60- '

v - . - .

/ \

f6 1 In addition'to the spili' cable reco 4tention requirements of Title 10

- Code of FederapRegulationsMhe follow cords sha Ybe retained si at least the minimue period indicat6d.

6.10.2 The followin (records sh41 be retaine

/s or at least years:

. Records and logs a nit oper ton covering , time interval at level; h power

/

/ f

b. , Atcords an & ogs of princijIa1 maintenance activities, inspections, repair, replacenertt'of principal ftens of equipment' related to 1

nucle afety; l i

c. Al REPORTABLUEVENT5; d Records of rveillance activities, ins tons, and calibr ions required'by the Technical Specificati Technical Reggirements l Manual, and Fire Prot ~ection Report ,axcept as explic Ty covered in / 1 Spesification p

6.10'3; /

e./ Records of changes made to t procedures regg red by j / SpecificatJ4n 6.8.1;

/ f. Records /fradioactive ipments; l g. Re s of sealed

'" estsandresults/

h. Records of urce a/nd fis fon detector val physical nventory of al rial less

\

af record /

l t

,O6.10/3 The fol i ating Lic se ng record shall be retain or the durati f the unit

\

l i a. Records and rawing changes pe acting unit systems ign modificatio made to equipment described in the Fin l'$afety Analysis (aport; i b. Recettis of new and irr ated fuel iny tory, fuel trans i assembly burnup histories; and h  ;

e Records of rad,H on exposure f all individual interingradiaJion

i control are j

\

d. Records gaseous and ligdid radioactive

- ertal releas to the envir,ons; d COMANCHE PEAK - UNITS 1 AND 2 6-22 Unit 1 - knentinent No.1

=

  • a p g ,:?f M N ADMINISTRATIVE CONTROLS ORDRETENTION(Cont und)

Records transient'or operat onal cycles fo those unit co

/ identified in Ta#Te 5.7-1; e s

/ /

/ f. /

.Rdcords of eactor tests and experiment ;

i g,,/Reco dse ftraining/and qualifica fon / for curr ,

stafp members of the un X

/

/ h. Records off inservice ins Specific tions; ions pe ormed pursuant to the Technical-Recoy of quality assurance ivities required b l AsyranceMan he Quality i

/ l j.

Records of reviews pep ormed for changes to procedures or equipment,4r reviews of tests and experi nts pursuant to 10 CFR 50.59;

k. Rep s of me ings of the SORC the ORC;
1. Records e service live ~

required'by the Technical 'f all hydraulic and mechanical snubbers trements Manual incl y 6dinq the date at whic44he service mai enance records; life causences and associated instal' ation and

m. Records of sec ry water sampling anVwater quality;  !

Records of alyses required b toring P ran that would pers)y evaluation Radiological Envi neental Mont-of th curacy of the analysja' rat a later date, his should include specified times and QA r rds showing that t se procedures edures effectiv !at '

followed; and wer

o. Records of review-CALCUi.ATION MAljud[. performed for and the PROCESS cha to the OFFSITE DOSE s made ROL PROGRAM. /

6.11 Itai = E TE ii G ?7G "AM t1o r MsEb]

6.1 '.1 l

co istent wi the sfrperh'nneltr nt ofadiat'onproactionkhallhprepfred 10 FR 20 anyadiferedt for 11 op(ratio shallbejapproved,mainained, invo ving p(rsonne)' radlAtton exposure.

6.12 HIGH RADIATION AREA 6.12.1 Pursuant to paragraph 10 CFR 20.203 i device' or "alars signal" required by paragr(c)(5), in lieu of the " control aph 10 CFR 20.203(c), each high i

radiation area, as defined in 10 CFR 20, in which the intensity of radiation is equal to or less than 1000 mR/h at 45 cm (18 in.) from the radiation source ,

or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be COMANCHE PEAK - UNITS 1 AND 2 6-23 L l

hhh ADMINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA (Continued) controlled by requiring issuance of a Radiation Work Permit (RWP). Indi-viduals qualified in radiation protection procedures (e.g., Radiation Protec-tion Technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the perfomance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area; or
b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alams when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been estab-lished and personnel have been made knowledgeable of them; or
c. An individual qualified in radiation protection procedures with a

, radiation dose rate monitoring device, who is responsible for pro-viding positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by _

the RWP.

6.12.2 In addition to the requirements of Specification 6.12.1, areas acces-sible to personnel with radiation levels greater than 1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the_ keys shall be maintained under the administrative control of the Shift SFpervise@ondutyand/orradiationprotectionsupervision. Doors shall remain

/b=pr ioeger yXcept during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the iimmediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, direct or remoto (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the. activities being perforised within the area.

For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within-large areas, such as PWR containment, where no enclosure exists for purposet of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

1 i

COMANCHE PEAK - UNITS 1 AND 2 6-24

,qp Sc? o f- 30 ADMINISTRATIVE CONTROLS

, , 6.13b"CC:::

t 20""0L""00"*" "'R #07 M Chan s to e PCP:

a. all b docume ed an records f revi s perfor ed shall e retai d as r uired y Specif' cation .10.30. his doc entati m sha contai :

Suff cient ' n forma t i to s port the change t ether 'th the ap opria analys or e uations ustifyin the ch ge(s) d

2) deter ination hat t change 1 maint n the o erall l confor ance of he so dified w ste produ to ex' ting requ' ements f Fede al, Stat , or other applica ,e reg atio[s.
b. hall b come ef ctive fter rev ew and ac ptance y the ORC nd l

the ap royal o the V' e Presi nt, Nucle r Opera ons.

- r -

6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM)

Changes to the ODCM:

a. Shall be documented and records of reviews performed shall be retaine Q : m.o.,y 5, 5,,_iT L ,m, 0.12.2.. This documentation -

shall conTain:

h N M diod a[ 7h udit Operdid L5C&Ch

1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and
2) A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.
b. Shall become effective after revi andacceptancebygte50RCand the approval of the Vice Presiden lear Operations.
c. Shall be submitted to the Commission n the form of a complete, legible copy of the entire 00CM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the 00CM was ma6e. Each change shall

, be identified by markings in the margin of be affected pages, clearly indicating the area of the page that was changed, and shall-indicate the date (e.g., month / year) the cha,nge was implemented.

ht k C>dlas M4 A\ pec Pv4crad h y TS rk Pl a % .c 3 he rLt ory,h n.sM

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COMANCHE PEAK - UNITS 1 AND 2 6-25 Unit 1 - Amendment No. 25

Unit 2 - Amendment No. 11

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