Proposed tech specs removing administrative controls ...

Attachment to AEP:NRC:80027A

INDEX ADMINISTRATIVE CONTROLS

Appendix C

6.5 REVIEW6.5.1

AND AUDITPLANT NUCLEAR SAFETY REVIEW COMMITTEEFunctionCompositionAlternatesMeeting FrequencyQuorumResponsibilitiesAuthority .

Records

1.71.71.71.71.71.71.71.7

PAGE138138139139139139140141

6.5.2 NUCLEAR SAFETY AND DESZGN REVZBW COMMITTEE

FunctionCompositionAlternate MembersConsultantsMeeting Frequency .QuorumReviewAuditsAuthorityRecords

1.71.71.71.71.71.71.71.71.71.7

141141142142142142142143144144

6 '.36. 10

TECHNICAL REVIEW AND CONTROL

RECORD RETENTION

1 7 - 145

1.7 - 147

ADMZNZSTRATZVE CONTROLS

6.5 REVIEW AND AUDIT

6.5.1

FUNCTION

6.5.1.1

COMPOSITION

6.5.1.2

Plant Nuclear Safety Review Committee (PNSRC)

The pSSRC shall function to advise the Site Vice presi nt I.'"."':,"i!iiiptii!;I,or designee, on all matters related to nuclear safety.

The PNSRC shall be composed of i,'+la'nt::,::,:Aa iigii":.:;ai.„::.:,his",,di'pig''n'ee~;,:4'x'i'aNlanaeger|S)i::i::::.:!nlt8 Department Susperantendent'teg)'r f'„"'.".:,-g'personnelreporhi:ng d'erectly to en!:~!Rrea;::@Manage pour a: DepartmentSuperintendent. The membership shall represent the functional areasof the plant, including, but not limited to Operations, Brig'iaeexi~Yi',Licensing, Maintenance, and Radiation Protection.

The PNSRC membership shall consist of at least one individual fromeach of the areas designated. All members, including the Chairmanand his alternates, the members and their alternates, shall bedesignated by the Site Vice President /pe>47~,„",:,:.'p..,:,"I.

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ADMINISTRATIVE CONTROLS

PNSRC members and alternates shall meet or exceed the minimumqualifications of ANS1 N18.1-1971 Section 4.4 for comparablepositions. The nuclear power plant operations individual shall meetthe qualifications of section 4.2.2 of ANSI N18.1-1971 except forthe requirement to hold a current Senior Operator License. Theoperations individual must hold or have held a Senior OperatorLicense at Cook Nuclear Plant or a similar reactor. The maintenanceindividual shall meet the qualifications of section 4 '.3 of ANSIN18.1-1971.

ALTERNATES

6.5.1.3 No more than two alternates shall participate as voting members inPNSRC activities at any one time.

MEETING FRE UENCY

6.5.1.4 The PNSRC. shall meet at least once per calendar month and asconvened by the PNSRC Chairman or his designated alternates.

QUORUM

6.5.1.5 The quorum of the PNSRC shall consist of the Chairman or hisdesignated alternate and at least . three members includingalternates.

RESPONSIBILITIES

6.5.1.6 The PNSRC shall be responsible for:Review of all Plant Manager Instructions (PMIs) and revisionsthereto.

Review of safety evaluations for (1) plant site procedures andrevisions thereto which affect the nuclear safety of the plant;(2) changes or modifications to nuclear safety-related structures,systems or components; and (3) tests or experiments which affectplant nuclear safety to verify that such actions did not constitutean unreviewed safety question as defined in 10 CFR 50.59.

Review of (1) proposed procedures and revisions to procedures, (2)changes to equipment, systems, or facilities, and (3) proposed testsor experiments which may involve an unreviewed safety question asdefined in 10 CFR 50.59.

Review of proposed changes to Appendix "A" Technical Specificationsor the Operating License and rendering determinations in writingwith regard to whether or not the proposed change constitutes aSignificant Hazards Consideraticn".,(%p>.

Investigation of all violations of the Technical Specificationsincluding the preparation and forwarding of reports coveringevaluation and recommendations to prevent recurrence to the Chairmanof the NSDRC.

Review of all REPORTABLE EVENTS.

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Attachment to AEP:NRC:80027A Page 3


g. Review of facility operations to detect potential nuclear safetyhazards.

Performance of special reviews, investigat'ons of analyses andreports thereon as requested by the Chairman of the NSDRC.

Deleted

Deleted

Review of any accidental, unplanned, or uncontrolled radioactiverelease including the preparation of reports covering evaluations,recommendations, and disposition of the corrective action to preventrecurrence and the forwarding of these reports to the Ex'eiu'ave VicePresident - Nuclear Generation and to the NSDRC.

Review of changes to the PROCESS CONTROL PROGRAM, OFFSITE DOSECALCULATION MANUAL, and radwaste treatment system.

AUTHORITY

6.5.1.7 The PNSRC shall:a Recommend to the Site Vice President ~~j+>',::,, or designee, written

approval or disapproval of items considered under 6.5.1.6 (a)through (d) above.

b. Render determinations in writing with regard to whether or not eachitem considered under 6 '.1.6 (a) through (c) and (e) aboveconstitutes an unreviewed safety question.

Provide written notification within 24 hours to the Exe'phid VicePresident - Nuclear Generation and the NSDRC of disagreement betweenthe PNSRC and the Site Vice President .„';, g>j,~ ; however, the SiteVice President shall have responsibili y for resolution of suchdisagreements pursuant to 6. 1. 1 above.

RECORDS

6.5.1.8 The PNSRC shall maintain written minutes of each meeting and copiesshall be provided to the Chairman of the NSDRC ~

6.5.2 NUCLEAR SAFETY AND DESIGN REVIEW COMMITTEE NSDRC

FUNCTION

6.5.2.1

b.

d.

e.

The NSDRC shall function to provide independent review and audit ofdesignated activities in the, areas of:nuclear power plant operations

nuclear engineering

chemistry and radiochemistry

metallurgy

instrumentation and control

1 7 " 140 January 1997



Page 4

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance practices

COMPOSITION

6.5.2.2 The NSDRC shall be composed of the following regular members:

SX'iSCti6XV8 Vice President- Nuclear generation (NSDRC Chairman)

3.

6.

7 ~

8.

10

12.

13.

51~8',SAW - R8gNXAt'O~r,';,',i'A'fggiM8'NSDRC Secretary)

Site Vice President pp';.';;.gQ - Donald C. Cook Nuclear Plant+y,xxx«pCo~wxx«pxoxc«« . X&&CCr:~«oxaxox~e+eg+ y&xeC.c«o>gq.N«rex')ore«ex«xrcp~~ox~r

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Additional members and Vice Chairman may bepace:::ip'resa dent .

appointed by the @j'iutivetsxvx«&c'xeN4o&c«oi

ALTERNATE MEMBERS

6.5.2.3 Designated alternate members shall be appointed by the XX«eouhiseS'L'Oe'a:.",peeeid~8 or such other person as he shall designate. 'Inaddi%i~on, emporary alternate members may be appointed by the NSDRCChairman to serve on an interim basis, as required. Temporaryalternate members are empowered to act on the behalf of the regularor designated alternate members for whom they substitute.

CONSULTANTS

6.5.2.4 Consultants shall be utilized as determined by the NSDRC Chairman toprovide expert advice to the ÃSDRC.

MEETING FRE UENCY

6.5.2.5 The NSDRC shall meet at least once per six months.

1.7 - 141 January 1997



UORUM

6.5.2.6 A quorum, the minimum number of regular members and alternatesrequired to hold a NSDRC meeting shall be eight members, of whom nomore than two shall be designated or temporary alternates. TheChairman or acting Chairman shall be present for all NSDRC meetings.If the number of members present's greater than a quorum, then themajority participating and voting at the meeting shall not have lineresponsibility for operations of the facility. For the purpose ofa quorum, only the Plant Manager is considered to have lineresponsibility.

REVIEW

6.5.2 ' The NSDRC is responsible for assuring that independent" reviews ofthe following are performed:

a ~ The safety evaluations for 1) changes to procedures, equipment orsystems and 2) tests or experiments completed under the provision of10 CFR 50.59 to verify that such actions did not constitute anunreviewed safety question.

Proposed changes to procedures, equipment or systems which involvean unreviewed safety question as defined in 10 CFR 50.59.

Proposed tests or experiments which involve an unreviewed safetyquestion as defined in 10 CFR 50.59.

d. Proposed changes in Technical Specifications or this operatinglicense. l

Violations of codes, regulations, orders, Technical Specifications,license requirements, or of internal procedures or instructionshaving nuclear safety significance.Significant operating abnormalities or deviations from normal andexpected performance of plant equipment that affect nuclear safety.All REPORTABLE EVENTS.

All recognized indications of an unanticipated deficiency in someaspect of design or operation of safety-related structures, systems,or components.

Reports and meeting minutes of the PNSRC.

'Regular NSDRC members are expected to attend the meeting whenever possible, andalternates may attend as voting members only on an irregular basis. If both aregular member and his alternate attend a meeting, only the regular member mayparticipate as a voting member, and the alternate is considered a guest."Independent reviews may be performed by groups which report directly to theNSDRC and which must have NSDRC membership participation.

1 7 - 142 january 1997



AUDITS

6.5.2.8 Audits of facility activities shall be performed under thecognizance of the NSDRC. These audits shall encompass:

a ~ The conformance of facilityoperation to provisions contained withinthe Technical Specifications and applicable license conditions atleast once per 12 months.

b. The performance, training, and qualifications of the entire facilitystaff at least once per 12 months.

The results of actions taken to correct deficiencies occurring infacility equipment, structures, systems or method of operation thataffect nuclear safety at least once per 6 months.

The performance of activities required by the Quality AssuranceProgram to meet the criteria of Appendix "B", 10 CFR 50, at leastonce per 24 months.

Deleted.

Deleted.

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1 ~

The fire protection programmatic controls including the implementingprocedures at least once per 24 months by qualified licensee QApersonnel.

The fire protection equipment and program implementation at leastonce per 12 months using either a qualified offsite licensee fireprotection engineer or an outside independent fire protectionconsultant. An outside independent fire protection consultant shallbe used at least every third year.

The Radiological Environmental Monitoring Program and the resultsthereof at least once per 12 months.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures atleast once per 24 months.

The PROCESS CONTROL PROGRAM and implementing procedures for'solidification of radioactive wastes at least once per 24 months.

The performance of activities required by the Quality AssuranceProgram to meet the criteria of Regulatory Guide 1.21, Rev. 1, June1974 and Regulatory, Guide 4.1. Rev. 1, April 1975 at least once per12 months.

Any other area of facility oper:tion considered appropriate by tho.NSDRC.

AUTHORITY

6.5.2.9 The NSDRC shall report to "nd advise the SMCgtj'ye Vice PresidentNuclear Generation on those areas of responsNi.lity specified inSections 6.5.2.7 and 6.5.2.8.

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Attachm'ent to AEP:NRC:80027A Page 7


RECORDS

6.5.2. 10 Records of NSDRC activities shall be prepared, approved anddistributed as indicated below:

Minutes of each NSDRC meeting shall be prepared, approved and issuedwithin 14 days following each meeting.

b. Reports of reviews encompassed by Section 6.5.2.7 above, shall beprepared, approved and issued within 14 days following completion ofthe review.

c ~ Audit reports encompassed by Section 6.5.2.8 above, shall beforwarded to the Ezecnb'd'ye Vice President Nuclear Generation Q,:;j andto the management"posi.'tions responsible for the areas audited within30 days after completion of the audit.

6.5.3 TECHNICAL REVIEW AND CONTROL

6.5.3.1 Activi.ties which affect nuclear safety shall be conducted asfollows:

a Procedures required by Specification 6.8 and other procedures whichaffect plant nuclear safety, and changes thereto, shall be prepared,reviewed. and approved. Each such procedure or procedure changeshall be reviewed by a qualified individual/group other than theindividual/group which prepared the procedure or procedure change,but who may be from the same organization as the individual/groupwhich prepared the procedure or procedure change. Procedures otherthan Plant Manager Procedures shall be approved by the appropriatedepartment head as previously designated in writing by the Site VicePresident+(!::!:~;.',:jg!, or designee. The Site Vice President(~<!:::;,i:;.:i:;::<.g, ordesignee, shal'l approve Plant Manager Procedures. Temporary changesto procedures which do not change the intent of the approvedprocedures shall be approved for implementation by two members ofthe plant staf f, at least one of whom holds a Senior Operatorlicense, and documented. The temporary changes shall be approved bythe original approval authority within 14 days of implementation.For changes to procedures which may involve a change in intent ofthe approved procedures, the person authorized above to approve theprocedure shall approve the change prior to implementation.

Proposed changes or modifications to plant nuclear safety-relatedstructures, systems and components shall be reviewed as designatedby the Site Vice President/.:,"'j~>gag:.',":„~~',;), or designee. Each suchmodification shall be reviewed (reference T/S 6.5.3.1.e) by aqualified (reference T/S 6.5.3.1.d)individual/group other than theindividual/group which designed the modification, but who may befrom the same organization as the individual/group which designedthe modifications. Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved priorto implementation by the Site Vice President +<,,',~, or designee.

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Attachmentj 'Ito AEP:NRC:80027A Page 8


d.

Proposed tests and experiments which affect plant nuclear safety andare not addressed in the Final Safety Analysis Report or TechnicalSpecifications shall be prepared, reviewed, and approved. Each suchtest or experiment shall be reviewed by qualified individuals/groupsother than the individual/group which prepared the proposed test orexperiment to assure cross disciplinary review as appropriate forthe proposed test or experiment. Proposed tests and experimentsshall be approved before implementation by the Site Vice President

or designee.

Individuals who conducted the reviews performed in the accordancewith Specification 6.5.3.1a, 6.5.3.1b, and 6.5.3.1c, shall bemembers of the plant management staff previously designated by theSite Vice President)P)$ ~":.'„;::)Pg and shall meet or exceed the minimumqualifications of XNSX" 518.1-1971 Section 4.4 for comparablepositions. Each such review shall include a determination ofwhether or not additional, cross-disciplinary review is necessary.

e.

If deemed necessary, such review shall be performed by qualifiedpersonnel of the appropriate discipline.Each review shall include a determination of whether or not anunreviewed safety question is involved. Pursuant to 10 CFR 50.59,NRC approval of items involving unreviewed safety questions shall beobtained prior to the approval of the Site Vice President (jan+.;-;:sQ,or designee, for implementation.

Deleted.

g, Deleted.

6.5.3.2 Records of the above activities shall be provided to the Site VicePresident g'pg or designee, PNSRC and/or the NSDRC as necessary forrequired re'v'i:ews.

6. 6 REPORTABLE EVENT ACTION

6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

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Each REPORTABLE EVENT shall be reviewed by the PNSRC, and theresults of this review shall be submitted to the NSDRC and theRX~COF~CV, Vice President - Nuclear Generation.

6. 7 SAFETY LIMIT VIOLATION

6.7.1 The following actions shall be taken in the event a safety limit isviolated:

The NRC Operations Center shall be notified by telephone as soon aspossible and in all cases within 1 hour. WXghi'n':;:Z4:";:honrpjnagiSg.';:tie

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1 7 - 145 January 1997



A Safety Limit Violation Report'hall be prepared. The report shallbe reviewed by PNSRC. This report shall describe (1) applicablecircumstances preceding the violation; (2) effects of the violationupon facility components, systems or structures; and (3) correctiveaction taken to prevent recurrence.

6.8 PROCEDURES AND PROGRAMS

6.8.2 Each procedure and administrative policy of 7i@~D;"pg;'Specification 6.8.1Q,:,~i::,;,':::;:,"'!,:;":::g, and changes thereto, including tempoiaiy changes, shall bereviewed prior to implementation as set forth in Specification 6.5 above.

6.10 RECORD RETENTION

6. 10". 1 The following records shall be retained for at least five years:

Records and logs of unit operation covering time interval at eachpower level.Records and logs of principal maintenance activities, inspections,repair and replacement of principal items of equipment related tonuclear safety.

c. All REPORTABLE EVENTS submitted to the Commission.

Records of surveillance activities, inspections and calibrationsrequired by the(gq Technical Specifications.Records of changes made to the procedures required by h'iihn&caiSpecification 6.8.1.

Records of sealed source and fission detection le." tests andresults.Records of annual physical inventory of all sealed source materialon record.

6.10.2 The following records shall be retained for the duration of the FacilityOperating License:

Records and drawing changes reflecting unit design modificationsmade to systems and equipment described in the Final Safety AnalysisReport.

Records of new and irradiated fuel inventory, fuel transfers andassembly burnup histories.Records of radiation exposure or all individuals entering radiationcontrol areas.

Records of gaseous and liquid radioactive material released to theenvironment.

1.7 - 146 January 1997



Page 10

Records of transient or operational cycles for those facilitycomponents identified in the Updated Final Safety Analysis Report.

f. Records of reactor tests and experiments.

Records of training and qualification for current members of thePlant Staff.Records of in-service inspections performed pursuant to theseTechnical Specifications.

i. Records of Quality Assurance activities required by the QA Manual.

Records of reviews performed for changes made to procedures orequipment or review of tests and experiments pursuant to 10 CFR50.59.

k. Records of meetings of the PNSRC and the NSDRC.

1. Records of radioactive shipments.

Records of the service lives of hydraulic snubbers including thedate at which service life commences and associated installation andmaintenance records.

Records of reviews performed for changes made to the OFFSITE DOSECALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

6.13 PROCESS CONTROL PROGRAM PCP

6.13.1 Changes to the PCP:

Shall be documented and records of reviews performed shall beretained as required by Specification 6.10.2.n. This documentationshall contain:

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"<rii":F i~isa,>in::!iieeaical~:agan fi~~t~an7'i')':

Shall become effective after review and acceptance by the PNSRC andapproval of the Plant Manager.

6.14 OFFSITE DOSE CALCULATION MANUAL ODCM

6.14.1 Changes to the ODCM:

Shall be documented and record of reviews performed shall beretained as required by Specifi«stion 6.10.2.n. This documentaticeshall contain:

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Shall become effective after review and acceptance by the PNSRC andthe approval of the Plant Manager.

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1.7 - 147 January 1997

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