ML20079F095

Proposed Tech Specs in Support of Realignment of Util Nuclear Generation Group Organizational Structure

ML20079F095
Person / Time
Site:	Brunswick
Issue date:	10/08/1991
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20079F087	List: ML20079F084 ML20079F095
References
TAC-79845, TAC-79846, NUDOCS 9110080020
Download: ML20079F095 (26)

Text

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ENCLOSURE 2

. BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2

.NRC DOCKET NOS. 50 325 6. 50 324 OPERATING LICENSE NOS. DPR 11 & DPR 62 NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CllANGES (NRC TAC NOS, 79845 AND'79846)

TECHNICAL SPECIFICATION PAGES UNIT 1 i

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INDEX

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ADMINISTRATIYLCQHIPOLS SECTlQU PAGE 6.1 PESPONSIBILITY, 6-1 6.2 ORGANIZATION 6.2.1 OFF SITE Atm ONSITE ORGANI'ZATIONS,

6-1 6.2.2 FACILITY STAFF....

6-1 6.2.3 PROJECT ASSESSMENT (PA) l Function.

6-5 Responsibilities....

6-5 Authority........

6-5 6.2.4 SHIFT TECHNICAL ADVISOR...

6-5 6.3 FACILITY STAFF OUALIFICATION,.

6-5 6.4 TBAINING.

6-5 6.5 REVIEW AND AUDIT 6.5.1 NUCLEAR SAFETY REVIEWERS.

6-6 6.5.2 SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONTROL Safety Evaluations.

6-6 Procedures, Tests, and Experiments...

6-7 Modificationa...

6-7 Operating License / Technical Specifications.

6-7 6, 5, ~3 PLANT NUCLEAR SAFETY COMMI'ITEE (PNSC)

Function.

6-8 Composition......

6-8 Alternates.

6-8 Meeting Frequency...

6-8 Quorum.,

6-8 Activities.,

6-9 Authority.

6-10 Records.,

G-10 BRUNSWICK - UNIT 1 XIV Amendment No.

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IliEEX ADMINISTRATIVE CONTROLS

' SECTIOff PAGE 6-S REVIEW AND AUDIT (Continued) 6.5.4 NUCLEAR ASSESSMENT DEPARTMEITT INDEPENDENT REVIEW PROGRAM l

Function...,.................

6-10 Organization.....................

6-10 i

Review..................

6 11 i

Records.................................................

6 12 l

6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDIT PROGRAM l

Function........................

6 13 Audits.................,

6-13 Records.................................................

6-14 Authority.

6 14 Personnel......,,.........,...,........,................

6 14

6. 5,6 -.OUTSIDE AGENCY INSPECTION AND AUDIT PROGRAM...,...,...,

6-15 6.6 REPORTABLE EVENT ACTION...............................

6-15 6 '. 7 SAFETY LIMIT VIOLATION.................................

6 15 6.8 PROCEDURES AND PROGRAMS....................................

6 16 6.9 REPORTING REOUIREMENTS Routine Reports 6-17 Startup Reports........................

.... 17 Annual Reports.......,................................,.

6-18 Persennel' Exposure and Monitoring Report................

6,

Annual Radiological Environmental Operating Report......

6-19 Semiannual Radioactive Effluent Release Report..........

6 20 Monthly Operating Reports...........................

6-21 Special Reports....................

6 22 Core Operating Limits-Report........................

6-22 l

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BRUNSWICK - UNIT 1 XV Amendment No.

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ADMIN?STRAT,tVE CWATRQLS 6.2.3 PROJECT ASSESSMENT (PA),

l FUNCTION

.6.2.3.1 The PA Group Unit shall function to examine facility operating l

characteristics, NRC issues, industry advisories, and other sources which may indicate areas for improving facility safety.

RESPONSIBILITIES 6.2.3.2 The PA Group Unit shall be responsible for maintaining surveillance l

of facility activities to provide independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

AtmiORITY 6.2.3.3 The PA Group Unit shall make detailed recommendations for revised l

procedures, equipment modificatione, or other means of improving facility safety to the Manager - Nuclear Assessment Department.

l 6.2.4 SHIFT TECHNTCAL ADVISOR l

6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.

6.3 FACILITY STAFF OUALIFICATION 6 J.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions (*),

except for (1) the Manager Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and rerponse and analysis of the plant during transients and accidents.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staf f shall be maintained under the direction of the Manager Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.

6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Manager Training (BSEP) and shall meet or exceed the requirements of Section 27 of the NFPA Code 1975.

i l

Not responsible for sign off function.

(a) The requirement for the Manager - Operations to hold or have held a senior reactor operatur license is exempted for a period of 18 months starting f rom June 13, 1991.

BRUNSWICK - UNIT 1 6-5 Amendment No.

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._...._.mm_m EtIGISTRATXVE CONTRQhS PROCEDURES. TESTS.' AND EXPERIMENTS 6.5.2.4 The safety evaluation prepared in accordance with Specifications 6.5.2.1.a and 6.5.2.1.b above shall include a written determination, with basis, of whether or not the procedures, proposed teste 4

and experiments, and changes thereto constitute an unreviewed safety question

. as defined in 10 CPR 50.59, or whether they involve a change to the Technical Specifications.

6.5.2.5 Following the nuclear safety review, the procedures required by Specification 6.8, other procedures that affect nuclear safety, proposed tests or experiments, and changes thereto (other than editorial or typographical) which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or change to the Technical Specifications shall be approved prior to' implementation by the General Manager - Brunswick Plant or his previously designated alternate.

MODIFICATIONS

- 6.5.2.6 The safety evaluation prepared in accordance with Specification 6.5.2,1.c above shall include a written determination, with basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.

G.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications shall be approved by the General Manager Brunswick Plant or his previously designated alternate, OPERATING LICENSE / TECHNICAL SPECIFICATIONf2 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6,5.2.1.e above shall include a written proliminary determination, with basis, of whether or not the proposed operating License / Technical Specification change (s).is a change in the facility as described in the safety analysis report.

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be:

a.

Reviewed by the Plant Nuclear Safety Committee in accordance with Specification 6.5.3.8.

b.

Reviewed by the Nuclear Assessment Department Section in accordance l

with Specification 6.5.4.9.

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l BRUNSWICK + UNIT 1 6-7 Amendment No.

ADAINISTRATIVE CONTPO1S ACTIVITIES 6.5.3.8 The PN3C activities shall include the following:

a.

Review of all procedures required by Specification 6.8 and changes thereto (and any other procedures and changes thereto), any of which constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation, b.

Review of all proposed tests or experiments that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation, c.

Review of all proposed modifications that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.

d.

Review of all proposed changes to the Technical Specifications or Operating License, prior to implementation, e.

Review of reports on violations of Technical Specifications including reports covering evaluation and recommendations to prevent recurrence to the Manager Brunswick Nuclear Project and to the Manager -

Nuclear Assessment Department.

f.

Performance of specisl reviews, investigations (or analyses), and reports thereon as requested by the Manager - Nuclear Assessment Department.

g.

Review of all REPORTABLE EVENTS.

h.

Review of facility operations to detect potential nuclear safety

hazards, i.

Annual review of the Security Plan.

j.

Annual review of the Emergency Plan.

k.

Review of accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations And disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Manager -

Brunswick Nuclear Project and the Manager - Nuclear Assessment Department.

1.

Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

BRUNSWICK - UNIT 1 6-9 Amendment No.

{@f4INISTRATIVE CONTROLS 6pTHORITX 6.5,3.9 If there is a disagreement between recommendations of a majority of the PNSC and the actions contemplated by the General Manager - Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Manager - Brunswick Nuclear Project and the Vice President - Nuclear Se rvices.

The course determined by the General Manager - Brunswick Plant to be the most conservative shall be followed.

PECORDS 6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that, at a minimum, document the results of all PNSC activities performed under the provisions of these Technical Specifications. Copies shall be provided to the Manager - Brunswick Nuclear Project and the Manager - Nuclear Assessment Department.

6.5.4 NUCLEAR ASSESSMENT DEPARTMENT INDEPENDENT REVIE PROGRAM l

FUNCTION 6.5,4.1 The Nuclear Assessment Department shall function to provide l

independent review of significant plant changes, tests, and procedures; verify that REPORTABLE EVENTS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day-to-day observer.

OPGANI"ATION 6,5,4.2 The individuals assigned responsibility for independent reviews shall be specified in technical disciplines. These individuals shall collectively have the experience and competence required to review activities in the following areas:

a.

nuclear power plant operations b.

nuclear engineering c.

chemistry and radiochemistry d.

metallurgy e,

non-destructive testing f.

instrumentation and control g.

radiological safety h.

mechanical and electrical engineering i.

administrative controls BRUNSWICK - UNIT 1 6-10 Amendment No.

l ADitINISTPATIVE CONTPOLS QEGANIZATION (Continued) j.

seismic and environmental k.

quality assurance practices 1.

Other appropriate fields associated with the unique characteristics of the nuclear power plant.

6.5.4.3 The Manager Nuclear Assessment Department shall have an academic l

degree in an engineering or related field and, in addition, shall have a minimum of ten years related experienes, of which a minimum of five years shall be in the operation and/or desis of nuclear power plants.

6 5.4.4 The independent safety review program reviewers anall have an academic degree in an engineering or related field or equivalent and, in addition, shall have & minimum of five years related experience.

6.5.4.5 An individual may possess competence in more than one specialty area.

If sufficient expertise is not available within the Nuclear Assessment Department, competent individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing independent reviews and investigations.

6.5.4.6 At least three individuals, qualified as discussed in 6.5.4.4 above, shall review each item submitted under the requirements of Section 6.5.4.9.

6.5,4.7 Independent safety reviews shall be performed by individuals not directly involved with the activity under review or responsible for the activity under review.

6.5.4.8 The Nuclear Assessment Department independent safety re71ew program l

shall be condur'.ed in accordance with written, approved procedures.

REVIEW f.5.4.9 The Nuclear Aesosament Department shall perform reviews of the l

following:

a.

.The safety evaluations for 1) changes to procedures required by Specification 6.8,

2) niodificati ns of equipment or systems, and

3) tests or experiments that constitute a change to the safety analysis report to verify that such actions did not constitute an unreviewed safety question or ir.volve a change to the Technical Specifications.

Implementation may proceed prior to completion of this review.

b.

Proposed changes to procedures required by Specification 6.8, and proposcJ modifications that constitute an unroviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation.

1 BRUNSWICK UNIT 1 6-11 Amendment No.

4 ADMINISTRATIVE CONTROLS 1

Eliy1EM (Conta nued) c.

Propo sed tests or experiments that involve an unreviewed safety queation as defined in 10 CFR 50.59 or a change to the Technical Epec.fications, prior to implementation.

d.

Pr, posed changes to the Technical Specifications and Ope *Ating

License, e.

Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, and internal procedures or instructions having nuclear safety significance, f.

Significant operating abnormalities or deviations from normal and expected performance of plant safety related structures, wystems, or ccmponents, g.

Reportable events.

h.

Reports and minutes of the PNSC.

i.

Any other matter involving safe operation of the nuclear power plant that the Manager - Nuclear Assessment Department deems appropriate for consideration or which is referred to the Manager - Nuclear Assessment Department by the on site operating organization or other functional organizational units within Carolina Power & Light Company.

6.5.4.10 Review of items considered under 6.5.4.9 (e) through (i) above shall include the results of any investigations made and the recommendations resulting from these investigations to prevent or reduce the probability of recurrence of the event.

RECORDS 6.5.4.11 Records of Nuclear Assessment Department reviews, including recommendations and concerns, shall be p epared and distributed as indicated below:

a.

Copies of documented reviews shall be retained in the Nuclear Assessment Department files.

b.

Recommendations and coacernb shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Nuclear Project, within 14 days of completion of the review, c.

A summation cf Nitclear Assessment Department's recommendations and l

concerns shall be submitted to the Chairman / President; Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation; Vice President - Nuclear Services; Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, appropriate, at least once every two months.

BRUNSWICK - UNIT 1 6-12 Amendment No.

I EIFATIVE CotrIEOLS d.5 NUCLEAR 6SSFSEMEttr DFPARTMEtTT 1@lT_,,Ipp1PJE l

l 11'110I1QI.i 0.5.5.1 The Nuclear Assebsment Department shall function to perform audits of l

facilfty activities specified in specification 6.5.5.2.

IRP113 6.5.5.2 Audits of facility activities shall be performed by the Nuclear Assessment Department. These audits shall encompass:

a.

The conformance of facility operation to provisions contained within the Technical Specifications and applicable licence conditions at least once per 12 months.

b.

The training and qualifications of the entire facility staff at least once per 12 months, c.

The results of actions taken to correct deficiencies occurring in f acility equipment, structurec, systems, or methods of eperation that af fect nuclear safety at least or:ce per 6 months, d.

The verificacion of compliance and implementation of the requirements of the Quality Assurance Progsam to meet the criteria of Appendix "B",

10 CFR 50, at least once per 24 months.

e, The Emergency Plan and implementing procedures at least once per 12 months.

f.

The Security Plan and implementing procedures at least once per 12 months.

g.

The Fac.lity Fire Protection Program and implementing procedures at least once per 12 months.

h.

The radiological environmental monitoring program and the results

)

thereof at least once per 12 months.

i.

The OFFSITE DOSE CALCULATIONAL MANUAL and implementing procedures at leawt once per 24 months.

j, The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

BRUNSWICK - UNIT 1 6-13 Amendment No.

ACIANISTRATIVE CONTROLS AUDIT 1 (Continued) k.

The perf ormance of acsivities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least once per 10 months.

1.

Any other area of facility operation considered appropriate by the Manager - Nuclear Assessment Department.

l 6.5.5.3 Personnel performing the audits shall have access to the plant operating records.

P32911'1 6.5.5.4 Records et audits shalt be prepared and retained.

6.5.5.5 Audit reptrts encompassed by 6.5.5.0 above shall be prepared, approved by the Manager Nuclear Assessment Department, and forwarded to the l

Executive Vice Presiden*

Power Supply; Senior Vice President Nuclear Generation; Manager Brunswick Nuclear Project; General Manager Brunswick Plant; and others, as appropriate, within 30 days after completion of the audit AUTHORITY 6.5.5.6 The Hanager Nuclear Assessment Department shall be responsible for l

the following:

a.

The administering of the Nuclear Assessment Department Addit Program.

b.

The approval of the individual (s) selected to conduct audits.

l EERSONNrb 6.5.5.7 Audit perconnel shall he independent of the area audited.

6.5,?.8 Selectica of personnel for auditing assignments shall be based on experience or training that establish.s that their qualifications are commensurate with the complexity or special nature of the activities to be audited.

In selecting audit personnel, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristien, and education.

6.5.5.9 Qualified outside consultants or other individuals independent from those persc1nel directly involved in plant operation shall be used to augment the audit teams when necessary.

BRUNSWICK UNIT 1 6 14 Amendment No.

4 l

j AD$12XSTRAK3VE CONTRQL4 j

6.5.6 OUTSIDE. AGENCY INSPECTIQN AND AUDIT PROGPJd4 I

L 6.5.6,1 An independent fire protection and loss prevention inspection and.

f audit shall be performed at least once per 12 months utilising either

[

qualified effsite licensee personnel or an outside fire protection firm, 6.5.6.2 An inspection and audit of the fire protection and lose prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.

I 6.6 REPORTABLE. EVENT ACTION I

6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

The Commission shall be notified and a report submitted pursuant;to a.

the requirenents of Section 50.73 to 10 CFR Part $0, and b.-

Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safety

-Committee Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment Department and the Manager Brunswick Nuclear Project.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a safety Limit is violated:

a.

The facility shall be placed in at least HOT SNUTDOWN within two hours.

b.-

The NRC Operations Center bhall be notified by telephone as soon as possible and in all cases within one hour.

The Manager - Brunswick.

Nuclear Project and the Manager Nuclear Assessment Department shall l

be notified within-24 hours.

c.

A Safety Limit Violation Report shall be prepared. The report shall

be reviewed by the General Manager Brunswick Plant.

This report shall describe (1) applicable circumotances 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 t

Commission, the Manager Brunswick Nuclear ' Project, and the Manager -

Nuclear Assessment Department within 14 days of the violation.

i BRUNSWICK

' NIT 1 6 15 Amendment No.

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• BECORDS P,ETENTION (Continued)

I k.

Records of reviews performed for changen made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

1.

Records of the service lives of all hydraulic and mechanical onubbers referenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance record 6.

m.

Records of analyses required by the radiological environmental monitoring program, n.

Records of (1) meetings of the PNSC, (2) meetings of the previous off-site review organization, the Company Nuclear Safety Committee (CNSC),

(3) the independent reviews performed by the Nuclear Assessment Department, and (4) the independent reviews performed by the Corporate Quality Assurance Audit Program, Quality Assurance Auditing Unit, 6.11 RADIATION PROTECTION _PROGPJM 6.11.1 Procedures for personnel radiation protection shall be pt:epared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for eli operations involving personnel radiation exposure.

6.12 HIGH P101 ATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203 (c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*.

Any individual or group of indivrduals permitted to enter such areas shall be provided with or accompanied by one or more of the followings a.

A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b.

A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms 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 established and personnel have been made knowledgeable of them.

• Psalth Physics personnel or personnel escorted by Health Physica personnel shall be exempt f rom the RWP issuance requirement during the pet formance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

BRUNSWICK - UNIT 1 6 25 Amendment No.

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ENCthSURE 3 i

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 325 6 50 324 OPERATING LICENSE NOS. DPR.71 6 DPR 62 NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CilANCES (NRC TAC HOS 79845 AND 79846)

TECilNICAL SPECIFICATION PAGES + UNIT 2 l

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6DMINISTRATIVE CONTROLS i

h SECTION plag 6.1 RESPONSIBILITY..............................

b1 6.2 ORGAN 1 EAT 10B 6.2.1 OFFSITE AND ONSITE ORGANIEATIONS.......................

61 6.2.2 FACILITY STAFF...................................

61 l

[

6.2.3 PROJECT ASSESSMENT (PA)

Function...........................

65 Responsibilities.....

65 Authority............

65 65

' [

6.2.4 SHIFT TECHNICAL ADVISOR.........

-6.3 rat 1LIrv srArr oUAtfrIcATIeN...............................

65 6.4 TRAINING.......................

6-5 i

gall REVIEW AND AUDIT i

6.3.1 NUCLEAR SAFETT REVIFWERS...............................

66 6.5.2 SAFETY EVALUATIONS AND I!!DEPENDEPTT REVIEW CONTROL Safety Evaluations...................................

66 Procedures, Tests, and Experiments.........

67 i

Modifications...............................

67 Operating License / Technical Specifications.............

67 6.5.3 PLANT NUCLEAR SAFETY COMMI*ITEE (PNSC)

~

Function...............................................

68 Composition............................................

68 Alternates.........................................

68 l

Meeting Frequency......................................

68 Quotum.................................................

68 Activities.............................................

69 Authority..........................

6 10 Records..........................,......................

6 10 l

T BRUNSWICK - UNIT 2 XIV Amendment No.

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60111111STPATIVE CONTRQLS EECT.12H EAGE 6.5 REVIEE_la'D AUDIT (Continued) 6.5.4

!TUOLEAR ASSESSMENT DEPARTMENT INDEFENDENT REVIEd PROGPAM l

Function.......

6 10 Organization.....

6-10 Review.....................

6 11 Records....................

6-12 6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDIT PROGRAM l

Function.

6-13 Auditw....

6 13 Records.

6-14 Authority.......

6 14 Personnel...

6 14 6.5.6 OUTSIDE AGENCY INSPECTION AlsD AUDIT PROGRAM..

6 15 1.6 REPORTABLE EYENT ACTION.....

6 15 6.7 J AFETY LIMIT VIOLATION...

6 15 6.8 PPOCEDURES AND PROGRAMS.........,..........

6 16 6.9 REPQRTING REOUIREMENTS Routine Reports..

6 17 Startup Reporte...

6 17 Annual Reports.

6 18 Personnel Exposure and Monitoring Report......

6 18 Annual Radiological Environmental Operating Report......

6-19 Semiannual Radioactive Effluent Release Report..........

6-20 Monthly Operating Reports....,

6 21 Special Reports.

6-22 Core Operating limits Report.......

6 22 i

BRUNSWICK - UNIT 2 XV Amendment No.

-_---.-.e---.-.~-.------..--

i

&RdlH2STRATIVE CONTDOLS 6.2.3 PROJECT ASSESSMENT (PA) l l

FUNCTIOM 6.2.3 1 The PA Group Unit shall function to examine facility operating j

characteristics, NRC issues, industry advisories, and other sources which may indicate aread for improving facility safety.

RESPONSIBIL111ES 6.2.3.2 The PA Group Unit shall be responsible for maintaining surveillanco l

of f acility activities to provide independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

61ZD10RITY 6.2.3.3 The PA Group Unit shall make detailed recommendations for revised I

procedures; equipment modifications, or other means of improving facility safety to the Manager

• Nuclear Assessment Department.

l 6 2.4 SHIFT TECitNICAL ADVISOR 6.2.4.1 The Shif t Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.

6.3 FACILITY STAFF OUALIFICATION G.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N16.1-1971 for comparable positionsUO, except for (1) the Manager Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant during transients and accidents.

6.4 TBAINING l

6.4.1 A retraining and replacement training program for the facility staff shall be' maintained under the direction of the Manager + Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1 1971 and Appendix "A"

of 10 CFR Part 55.

6.4.2 A training program for the Fire Brigade shall be. maintained under the I

direction of the Manager Training (BSEP) and shall meet or exceed the requirements of Section 27 of_the NFPA Code 1975.

Not responsible for sign-off function.

(a) The requirement for the Manager Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13, 1991.

BRUNSWICK w UNIT 2-65 Amendment No.

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ADM'INISTRATIVE CONTROLS i

PROCEDURES. TESTS, AND EXPERIMENTS 6.5.2.4 The safety evaluation prepared in accordance with Specifications 6.5.2.1.a and 6.5.2.1.b above shall include a written de te rmination, with basis, of whether or not the procedures, proposed tests and experiments, and changes thareto constitute an unreviewed safety question as defined in 10 CFR 50.59, or whether they involve a change to the Technical Specifications.

6.5.2.5 Following the nuclear safety review, ths procedures required by.

Specification 6.8, other proceduren that affect nuclear safety, proposed tests or experiments, and changes theteto (other than editorial or typographical) which have been determined to not involve an unteviewed safety question as defined in 10 CFR 50.59 or change to the Technical Specifications shall be approved prior to implementation by the General Manager Brunswick Plant or his previously designated alternate.

MODIFICATIONS 6.5,2.6 The safety evaluation prepared in accordance with Specification 6.5.2.1.c above shall include a written determination, with basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change-to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.

6.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical dpecifications shall be approved by the General Manager Brunswick Plant or his previously designated alternate.

i QEERATING LICENSE / TECHNICAL SPECIFICATIONS 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1,d and 6.5.2.1.e above shall inc3ude a written preltminary detetuination, with basis, of whether or not the proposed Operating-License / Technical Specification change (s) is a change in the facility as described in the safety analysis report, i

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be:

a.

Reviewed by the Plant Nuclear Safety Committee in accordance with l

Specification 6.5.3.8.

1 b.

Reviewed by the Nuclear Assessment Department Section in accordance l

with Specification 6.5.4.9.

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BRUNSWICK UNIT 2 67 Amendment No.

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ADRINISTPATIVE COtTTROLS ACTIVITIES 6.5.3.8 The PNSC activities shall include the following:

Review of all procedures required by Specification 6.8 and changes a.

thereto (and any other procedures and changes thereto), any of which constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.

b.

Review of all proposed tests or experiments that constitute an unreviewed safety question or involve a change to the Technical i

specifications, prior to implementation.

c.

Review of all proposed modifications that constitute an unreviewed sat'ety question or involve a change to the Technical Specifications, prior to implementation.

d.

Review of all proposed changes to the Technical Specifications or operating License, prior to implementation, Review of reports on violations of Technical Specifications including e.

reports covering evaluation and recommendationn to prevent recarrence to the Manager a litunswick Nuclear Project and to the Manager -

Nucleat Assessment Department.

l f,

Perfomu4ce of special reviews, investigations (or analyses), and reports thereon as requested by the Manager + Nuclear Assessment j

Department.

]

g.

Review of all REPORTABLE EVENTS.

t h.

Review of facility operations to detect potential nuclear safety

hazards, i.

Annual review of-the Security Plan.

j.

Annual review of the Emergency Plan, k.

Review of accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to'the Manager -

Brunswick Nuclear Project and the Manager - Nuclear Assessment Department.

1.

. Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

J BRUNSWICK - UNIT 2 6-9 Amendment No.

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s ADM'INISTRATIVE C0!nROLS

/R DIORITY 6.5.3.9 If there is a disagreement between recommendations of a majority of the PNSC and the actions contemplated by the General Manager Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Manager - Brunswick Nuclear Project and the Vice Presidens - Nuclear Services.

The course determined by the General Manager - Brunowick Plant to be the most conservative shall be followed.

EECCFDS 6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that, at a minimum, document the results of all PNSC activities performed under the provisions of these Technical Specifications.

Copies shall be provided to the Manager - Brunswick Nuclear Project and the llanager Nuclear Assessment Department.

6.5.4 NUCLEAR ASESSMENT DEPARTMENT _l!EEPE! CENT PJVIEW PPOGP1JJ l

EU117 TION 6.5.4.1 The Nuclear Assessment Lepartment shall function to provide l

independent review cf nignificant plant changes, tests, and procedures; verify that REPORTABLE EVE!GS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day to-day observer.

QPJBt!EATIR11 6.5.4.2 The individuals assigned responsibility for independent reviews shall be specified in technical disciplines.

These individuals shall collectively have the experience and competence required to review activities in the following areas:

a.

nuclear power plant operations b.

nuclear engineering c.

chemistry and radiochemistry d.

metallurgy e.

non destructive testing f,

instrrmentation and control g.

radiological safety h.

mechanical and electrical engineering i.

administrative controls BRUNSWICK - UNIT 2 6-10 Amendment No.

o

@MINISTRATIVE CONTROLS ORGANIZATIdd (Continued) j.

seismic and environmental k.

quality assurance practices 1.

Other appropriate fields associated with the unique characteristics of the nuclear power plant.

6.5.$ 3 The Manager Nuclear Assessment Department shall have an academic l

degree in an engineering or related field and, in addition, shall have a minimum of ten years related experience, of which a minimum of five years shall be in the operation and/or design of nuclear power plants.

6.5.4.4 The independent safety review progrAa reviewers shall have an.

academic degree in an engineering or related field or equivalent and, in addition, shall have a minimum of five years related experience.

6.5.4.%

An individual may possess competence in more than one specialty area.

If sufficient expertise is not available within the Nuclear Assessment-Department, competent. individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing independent reviews and investigations.

6.5.4.6 At least three. individuals, qualified as discussed in 6.5.4.4 above, shall review each item submitted under the requirements of Section 6.5.4.9.

6.5.4.7 Independent safety reviews shall be performed by individuals not directly involved with the activity under review or responsible for the activity under review.

6.5.4.8 The Nuclear Assessment Department independent safety review program l

shall be conducted in accordance with writter, approved procedures.

REVIEW 6.5.4.9 The Nuclear Assessment Department shall perform reviews of the l

following a.-

The safety evaluations for 1) changes to procedures required by Specification 6.8,-2) modifications of equipment or systems, and

3) tests or experiments that constitute a change to the safety analysis report to verify that such actions did not constitute ar; unrevieweat safety question or involve a change to the Technical Specifications.

Implementation may proceed prior to completion of this review..

b.

Proposed changes to procedures required by Specification 6.8, and proposed modifications that constitute an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical p

~ Specifications, prior to implementation.

BRUNSWICK - UNIT 2 6 11 Amendment No.

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@MINISTRATIVE CONTROLS

' PEVIEW (Continued) c.

Proposed tests or experiments that involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation, d,

Proposed changes to.he Technical Specifications and Operating License.

e.

Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, and internal procedures or instructions having nuclear safety significance.

l f.

Significant operating abnormalities or deviations from normal and expected performance of plant safety related structures, systems, or couponent s.

g.

Reportable events.

h.

Reports and minutes of the PNSC.

i.

Any other matter involving safe operation of the nuclear power plant that the Manager Nuclear Assessment Department deems appropriate for consideration or which is referred to the Manager Nuclear Asressment Department by the on site operating organization or other functional organizational units within Carolina Power & Light Company.

6.5.4.10 Review of items considered under 6.5,4.9 (e) through (1) above shall include the results of any investigations made and the recommendations resulting from these investigations to prevent or reduce the probability of recurrence of the event.

EEfDADA 6.5.4.11 Records of Nuclear Assessment Department reviews, including l

recommeedations and concerns, shall be prepared and distributed as indicated below:

a.

Copies of documented reviews shall be retained in the Nuclear Assessment Department files, b.

Recommendations and concerns shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Naclear Project, within 14 days of completion of the review, c.

A summation of Nuclear Assessment Department's recommendations and l

concerns shall be submitted to the Chairman / President; Executive Vice President - Power Supply; Senior Vice President Nuclear Generation; Vice President Nuclear Services; Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, appropriate, at least once every two months.

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BRUNSWICK - UNIT 2 6-12 Arendment No.

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e ANIINISTRATIVE COIR 5 JLS 6.5.5 NUCLEAR ASSESSME!TI DEPARTMEffr AUDIT PROGRAM l

FUNCTIO!{

6.5.5.1 The Nuclear Assessment Department shall function to perform audits of l

facility activities specified in Specification 6.5.5.2.

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6.5.5.2 Audits of facility activities shall be performcd by the Nuclear Assessment Department. These audits shall encompass:

a.

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.

b.

The training and qualifications of the entire facilit/ staff at least once per 12 months.

c.

The results of actions taken to correct deficiencies occurring in facility equipment, st ructure s, systems, or methods of operation that affect nuclear safety at least once per 6 months.

d.

The verification of compliance and implementation of the requirements of the Quality Assurance Program to meet the criteria of Appendix "B",

10 CFR 50, at least once per 24 months, The Emergency Plan and implementing procedures at least once per 12 e.

months, f.

The Security Plan and implementing procedures at leact once per 12 months.

g.

The Facility Fire Protection Program and implementing procedures at least once per 12 months.

h.

The radiological environmental monitoring program and the results thereof at least once per 12 months, i.

The OFFSITE DOSE CALCULATIONAL MANUAL and implementing procedures at least once per 24 months.

j.

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

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BRUNSWICK - UNIT 2 6-13 Amendment No.

i ADMIN 3STRATIVE CONTROLS i

AUDIIS (Continued) k.

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least once per 12 months.

1.

Any other area of facility operation considered appropriate by the Manager - Nuclear Assessment Department.

l 6.5.5.3 Personnel performing the audits shall have access to the plant operating records.

RECORDS 6.5.5.4 Records of audits shall be prepared and retained.

6.5.5.5 Audit reports encompassed by 6.5.5.2 above shall be prepared, approved by the Manager - Nuclear Assessment Department, and forwarded to the l

Executive Vice President - Power Supply; Senior Vice President

• Nuclear Generation; Manager - Brunswick Nuclear Project; General Manager - Brunswick Planti and others, as appropriate, within 30 days after completion cf the audit.

AUTHORITY 6.5.5.6 The Manager - Nuclear Assessment Department shall be responsible for the following:

The administering of the Nuclear Assessment Department Audit Program.

l a.

b.

The approval of the individual (s) selected to conduct audits.

l PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area audited.

6.5.5.8 Selection of personnel for auditing assignments shall be based on j

experience or training that establishes that their qualifications are commensurate with the complexity or special nature of the activiti6s to be audited.

In selecting audit personnel, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and education.

6.5.5.9 Qualified outside consultants or other individuals independent from those personnel directly involved in plant operation shall be used to augment the audit teams when necessary.

BRUNSWICK UNIT 2 6 14 Amendment No.

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Annunnpftnyg corrrRoLS 6.5.6 Otfrf1DE AGENCY INSPECTIM.ldE.AWIT. FPQ2EM 6.5.6.1 An independent fite protection and loss prevention inspet; tion and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection fitw.

6.5.6 : An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.

f_Ji _PIEETMlLE_IlllfL.ACUCH 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a.

The Commission shall be notified and a report submitted pursuant to the requitements of Section 50.73 to 10 CFR Part 50, and b.

Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safety Committee Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment Department and the Manager Brunswick Nuclear Project.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a.

Tht. facility shall be placed in at least HOT SNUTDOWN within two

hours, b.

The NRC Operations Center shall be notified by telephone aJ soon as possible and in all cases within one hour. The Manager Brunswick Nuclear Project and the Manager Nuclear Assessment Department shall l

be notifiestj within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c.

A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the General Manager Brunswick Plant. This report shall der.cribe (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 Manager - Brunswick Nuclear Project, and the Manager -

Nuclear Assessment Department within 14 dayr of the violation.

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i BRUNSWICK UNIT 2 6-15 Amendment No.

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'h&t$111STRATIVE. CONTROLS d

O

' RECORDS RETENTIOM (Continued) k.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

1.

Records of the service lives of all hydraulic and mechanical snubbers referenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance records.

m.

Records of analyses required by the radiological environmental monitoring program.

n.

Records of (1) meetings of the PNSC, (2) meetings of the previous off-site review organization, the Company Nuclear Safety Committee (CNSC),

(3) the independent reviews performed by the Nuclear Assessment Department, and (4) the independent reviews performed by the Corporate Quality Assurance Audit Program, Quality Assurance Auditing Unit.

6.11 RADIATION PROTECTION PROGRAM 6.11.1-Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203 (c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and l

conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*.

Any individual-or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

i a.

A radi.ation monitoring device which continuously indicates the radiation dose rate in the area.

J b.

A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device l

may be made after tte dose rate levels in the area have been l

established and personnel have been made knowledgeable of them.

l l'

• Health Physics _ personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of

- their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

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BRUNSWICK - UNIT 2 6-25 Amendment No.

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