Text

Proposed Tech Specs,Deleting Organizational Charts & Incorporating Administrative Changes to Tech Spec Section 6.0 & Updating Tech Spec Section 6.5.4.9 to Reflect Current 10CFR50.72 Reporting Requirements
	ML19332C233
Person / Time
Site:	Brunswick
Issue date:	11/16/1989
From:	; CAROLINA POWER & LIGHT CO.
To:	;
Shared Package
ML19332C231	List: ML19332C230; ML19332C233;
References
	NUDOCS 8911270033
	Download: ML19332C233 (64)
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'4 ENCLOSURE 1 BRUNSWICK STEAN ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 DELETION OF ORGANIZATION CHARTS AND ADMINISTRATIVE CHANGE!i UPDATED TECHNICAL SPECIFICl.T7.ON PAGES (NRC TAC NOS. 73017 AND 73018)

TECHNICAL SPECIFICATION PAGES - UNIT 1 f

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8911270033 891116 (525CRS)

PDR ADOCK 05000324 4

P PDC l

3

O INDEX

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ADMINISTRATIVE CONTROLS SECTION

_ PACE 6.1 RESPONSIBILITY.............................................

6-1 6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS.......................

6-1 l

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

6-1 6.2.3 ONSITE NUCLEAR SAFETY (ONS)

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

6-5 Responsibilities.......................................

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

6-5 I

6.2.4 SHIFT TECHNICAL ADVIS0R................................

6-5 6.3 FACILITY STAFF QUALIFICATION...............................

6-5 6.4 TRAININC...................................................

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

6-7 1

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

6-7 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)

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

6-8 i

Composition............................................

6-8 j

J Alternates.............................................

6-8 Meeting Frequency......................................

6-8 Quorum.................................................

6-8 Activities.............................................

6-9 Authority..............................................

6-10

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

6-10 I

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BRUNSWICK - UNIT 1 XIV Amendment No.

c INDEX ADMINISTRATIVE CONTROLS SECTION PACE 6.5 REVIEW AND AUDIT (Continued) 6.5.4 CORPORATE NUCLEAR SAFETY SECTION Function...............................................

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

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

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

6-12 6.5.5 CORPORATE QUALITY ASSURANCE AUDIT PROGRAM 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 REQUIREMENTS Routine Reports.......................................

6-17 Startup Reports........................................

6-17 Annual Reports.........................................

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

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

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

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

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

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

6-22 l

t BRUNSWICK - UNIT 1 XV Amendment No.

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INDEX ADMINISTRATIVE CONTROLS SECTION PACE 6.10 RECORD RETENTION..........................................

6-23 6.11 RADIATION PROTECTION PROGRAM..............................

6-25 6.12 HICH RADIATION AREA.......................................

6-25 6.13 0FFSITE DOSE CALCULATION HANUAL (0DCM)....................

6-26 6.14 FROCESS CONTROL PROCRAM (PCP).............................

6-26 6.15 MAJOR CHANCES TO LIQUID, CASEOUS, AND SOLI D WASTE TREATMENT SYSTEMS..........................

6-27 W

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BRUNSWICK - UNIT 1 XVI Amendment No.

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6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The General Manager - Brunswick Plant shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

6.2 ORCANIZATION

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6.2.1 0FFSITE AND ONSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.

Lines of authority, responsibility, and communication shall be a.

established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts. These organization charts will be documented in the FSAR and updated in accordance with 10CFR50.71(c).

b.

The General Manager - Brunswick Plant shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant, c.

The Senior Vice President - Nuclear Generation shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d.

The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite managert however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 FACILITY STAFF a.

Each facility on duty shift shall be composed of at least the minimum facility shift crew composition shown in Table 6.2.2-1.

b.

At least one licensed Reactor Operator shall be in the control room when fuel is in the reactor.

c.

When either reactor is in OPERATIONAL CONDITION 1, 2, or 3, at least one licensed Senior Reactor operator shall be in the control room.

BRUNSWICK - UNIT 1 6-1 Amendment No.

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l ADMINISTRATIVE CONTROLS t

FACILITY STAFF (Continued) d.-

The Shift Operating Supervisors, Shift Foremen, and Senior Control Operators shall hold a senior reactor operator license. The Control Operators shall hold a reactor operator license.

e.

An individual qualified to implement radiation protection procedures l

shall be onsite when fuel is in either reactor.*

f.

All CORE ALTERATIONS shall be directly supervised by either a l

licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during i

this operation.

l g.

A Fire Brigade of at least five members shall be maintained onsite at all times.* The Fir 6 Brigade shall not_ include the minimum shift crew shown in Table 6.2.2-1 or any personnel required for other essential functions during a fire emergency.

h.

Administrative procedures shall be developed and implemented to limit j

the working hours of facility staff who perform safety-related functional e.g.,

senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel.

These procedures shall meer. the working hour guidelines published by the Commission in Generic Letter No. 82-12.

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The individual qualified to implement radiation protection procedures and Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence provided i.mmediate action is taken to fill the required positions.

BRUNSWICK - UNIT 1 6-2 Amendment No.

4.

TABLE 6.2.2-1 MINIMUM FACILITY SHIFT CREW COMPOSITION

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i WITH UNIT 2 IN CONDITION 1, 2, OR 3 4

POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & $

5DI 1

1(b)

SOS (a)

SR i

g RO{")

3 3

A0 3

3 STA 1

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WITH UNIT 2 IN CONDITION 4 OR 5 POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & 5

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1 SOS (a) b)

g g

SRga)

R0 3

2 A0 3

3 STA 1

None WITH UNIT 2 DE-FUCLED POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL' POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & 5 1

1 5DI SOS (a) g(b)

SR g

RO{a) 2 2

A0 3

3 STA 1

None BRUNSWICK - UNIT 1 6-3 Amendment No.

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TABLE 6.2.2-1 (Continued)

MINIMUM FACILITY SHIFT CREW COMPOSITION TABLE NOTATION l

SOS - Shift Operating Supervisor with a Senior Reactor Operators License j

SRO - Individual with a Senior Reactor Operators License l

RO - Individual with a Beactor Operators License A0 Auxiliary. Operator (non-licensed-individual) i STA - Shift Technical Advisor

-l (a) Assumes each individual'is licensed on both plants

[.

.b) Does not include the licensed Senior Reactor Operator or Senior Reactor

(

Operator Limited to Fuel Handling, supervising CORE ALTERATIUNS.

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The Shift Crew Composition may be less than the minimum requirements for a-l period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence t

of on-duty shift crew members provided immediate action is taken to restore the

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Shift Crew Composition to within the minimum requirements of Table 6.2.2-1.

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l BRUNSWICK - UNIT 1 6-4 Amendment No.

y, 4-i ADMINISTRATIVE CONTROLS 6.2.3 ONSITE NUCLEAR SAFETY IONS)

FUNCTION 6.2.3.1 The ONS Unit shall func' ion to examine facility operating j

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

RESPONSIBILITIES 6.2.3.2 The ONS Unit shall be responsible for maintaining surveillance of facility ar.tivities to provide independent verification

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

' practical.

AUTHORITY 6.2.3.3. The ONS Unit shall make detailed recommendations for revised

- procedures, equipment modifications, or other means of-improving facility safety to the Manager - Corporate Nuclear Safety Section.

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

6.3 FACILITY STAFF QUALIFICATION 6.S.1 Each member of the facility staf f 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 cuide 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 TRAINING 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 exceea the requirements and recommendations of Section 5.5 of INSI~N18.1-1971 and Appendix "A" of 10 CFR Part 55.

l 6.4.2 ' A training program for the Fire Brigade shall be maintained under the l

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

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Not responsible for sign-off function.

u BRUNSWICK - UNIT 1 6-5 Amendment No.

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1 ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5.1 NUCLEAR SAFETY REVIEWERS 6.5.1.1 Individuals shall be designated / approved by the General Manager -

Brunswick Plant for performing nuclear safety reviews.

6.5.1.2 Individuals designated under Specification 6.5.1.1 above shall have an academic degree in an engineering or related fleid or equivalent and two years related experience.

6.5.1.3 A list shall be maintained of individuals qualified to perform

. nuclear safety reviews, including additional individuals whose expertise may be necessary during the reviews to assure that the reviewers cotlectively possess the background and qualfications in the disciplines necessary and important to the specific review.

6.5.1.4 The list specified in Specification 6.5.1.3 above shall include the disciplines for which each individual is qualified.

6.5.1.5 For those cases where interdisciplinary reviews are required, as many-individuals as necessary shall be used to perform the nuclear review function.

6.5.1.6 One of the two nuclear safety reviewers shall be an individual other than the original preparer or the individual approving the action.

6.5.2 SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONTROL SAFETY EVALUATIONS 6.5.2.1 A safety evaluation shall be prepared for each of the followings a.

Changes.to procedures required by Specification 6.8, or changes to other procedures that affect nuclear safety.

b.

Proposed tests or experiments that affect nuclear safety.

r c.

Proposed modifications to plant systems or equipment that affect nuclear safety.

d.

Proposed changes to the Technical Specifications.

e.

Proposed changes to the Operating License.

6.5.2.2 Two nuclear safety reviews of the item and safety eval.uation(s) prepared in accordance with Specification 6.5.2.1 above shall be performed prior to_ approval and implementation.

6.5.2.3 The item and associated safety evaluatica(s) shall be examined in order to determine whether an incerdisciplinary review is required in accordance with Specification 6.5.1.5 above.

BRUNSWICK - UNIT 1 6-6 Amendment No.

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! ADMINISTRATIVE CONTROLS 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 tests and experiments, and changes thereto 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, 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 6.5.1.6 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 constituten an unreviewed safety question as defined in 10 CFR $0.59.

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 Specifications shall be approved by the General Manager - Brunswick Plant or his previously designated' alternate.

OPERATING 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 shsl1 include a written preliminary 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:

1 Reviewed by the Plant Nuclear Safety Committee in accordance with a.

Specification 6.5.3.8.

b.

Reviewed by the Corporate Nuclear Safety Section in accordance with Specification 6.5.4.9.

BRUNSWICK - UNIT 1 6-7 Amendment No.

w ADMINISTRATIVE CONTROLS 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)

FUNCTION 6.5.3.1 As an effective means for the regular review, overview, evaluation, and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established.

6.5.3.2 The PNSC shall function through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION 6.5.3.3 The PNSC shall be composed of ther Chairman General Manager - Brunswick Plant

l Membert Manager - Technical Support y

Membert Manager - Operations 1

Member:

Manager - Maintenance Membert Manager - Environmental & Radiation Control Members' Technical Assistant to Plant General Manager Member:

Manager - QA/QC Membera Manager - Regulatory Compliance ALTERNATES i

6.5.3.4 All alternate n. embers shall be appointed in writing by the PNSC Chairman to. serve on a temporary basis; however, no more than two alternates shall participate as members at any one time.

6.5.3.5 All alternates, shall as a minimum, meet equivalent qualification criteria _as specified for professional-technical-personnel in Section 4.4 of ANSI N18.1-1971.

MEETING FREQUENCY 6.5.3.6 The PNSC-shall meet at least once per calendar month and as convened by the PNSC Chairman or'his designated alternate.

-QUORUM-6.5.3.7 The minimum quorum of the PNSC necessary for the performance of the PNSC activities of the Technical Specifications shall consist of the PNSC Chairman or his designated-alternate and four members including alternates.

a No more than.two alternates shall be counted toward meeting the minimum quorum i

requirement.

Or designated alternate.

BRUNSWICK - UNIT 1 6-8 Amendment No.

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. ' ADMINISTRATIVE CONTROLS ACTIVITIES 4

i 6.5.3.8.The PNSC activities shall include the followings 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 involvn 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.

a.

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 -

Corporate Nuclear Safety Section.

f.

Performance of special reviews, investigations (or analyses), and

' reports thereon as. requested by the Manager - Corporate Nuclear Safety Section.

.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 - Corporate Nuclear Safety Section.

'l.

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

8 BRUNSWICK - UNIT 1 6-9 Amendment No.

I ADMINISTRATIVE CONTROLS AUTHORITY 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Manager - Brunswick Nuclear Project and the Vice President - Nuclear Services. The course determined by the General Manager - Brunswick Plant to be'the most conservative shall be followed.

RECORDS 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 - Corporate Nuclear Safety Section..

6.5.4 CORPORATE NUCLEAR SAFETY SECTION FUNCTION 6.5.4.1 The Corporate Nuclear Safety Section (CNSS) of the Nuclear Services Department shall. function to provide 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 s

recurrence of such events; and detect trends that may_not be apparent to a day-to-day observer.

ORGANIZATION 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 l

l BRUNSWICK - UNIT 1 6-10 Amendment No.

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ADMINISTRATIVE CONTROLS i

ORCANIZATION (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 - Corporate Nuclear Safety Section shall have an academic 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 program 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.

6.5.4.5 An individual may possess competence in more than one specialty I

area. If sufficient expertise is not available within the Corporats Nuclear Safety-Section,-competent individuals from other Carolina Power'& Light Company organisations 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 Corporate Nuclear Safety Section independent safety review program shall be conducted in accordance with written, approved procedures.

REVIEW 6.5.4.9 The Corporate Nuclear Safety Section shall perform reviews of the 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 an unreviewed 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 Specifications, prior to implementation.

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BRUNSWICK - UNIT 1 6-11 Amendment No.

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ADMINISTRATIVE CONTROLS i.

REVIEW (Continued)

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c.

Proposed tests or experiments that involve an unreviewed safety

^

question as defined in 10 CFP 50.59 or a change to the Technical

' Specifications, prior to implementation.

d.

Proposed changes to the Technical Specifications and Operating

License, i

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 j

expected performance of plant safety-related structures, systems, or J

components.

g.

Reportable events.

h.

Reports and_ minutes of the PNSC.

1.

Any other matter involving safe operation of the nuclear power plant that the Manager - Corporate Nuclear Safety Section deems appropriate for consideration or which is referred to the Manager - Corporate Nuclear _ Safety Section 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 I.

. 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 Corporate Nuclear Safety Section reviews, including recommendations and concerns, shall be prepared and distributed as indicated belows:

a.

Copies of documented reviews shall be retained in the CNSS files.

l b.

Recommendations and concerns shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Nuclear Project, l

within 14 days of completion of the review.

f c.

A summation of Corporate Nuclear Safety Section's~ recommendations and L

concerns shall be submitted to the Chairman / President; Executive Vice L

President - Power Supply; Senior Vice President - Nuclear Generation; l~

Vice President - Nuclear Services; Manager - Brunswick Nuclear Project; Ceneral Mannher - Brunswick Plant; and others, appropriate, at least once every two months.

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l BRUNSWICK - UNIT 1 6-12 Amendment No.

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t A3INISTRATIVECONTROLS 6.5.5 CORPORATE QUALITY ASSURANCE AUDIT PROGRAM FUNCTION 6.5.5.1 The Quality Assurance Auditing Unit (QAAU) of the Corporate Quality Assurance Department'shall function to perform audits of facility activitien specified in Specification 6.5.5.2.

AUDITS-6.5.5.2 Audits of facility activities shall be performed by the QAAU. These audits shall encompasst a.

The conformance.of facility operation to provisions contained within l

the Technical Specifications and applicablet license conditions at least once per 12 months.

b.

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

The results of actions taken to correct deficiencies occurring in c.

facility equipment, structures, 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.

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 Facility Fire Protection Program and implementing procedures at 1 cast 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.

BRUNSWICK - UNIT 1 6-13 Amendment No.

1 ADMINISTRATIVE' CONTROLS 5

AUDITS (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 - Quality Assurance Services Section.

6.5.5.3 Personnel performing the quality assurance 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 - Quality Assurance Services Section, and forwarded to the Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation; Manager - Brunswick Nuclear Project; Vice President - Nuclear

-Services; General Manager - Brunswick Plant; and others,-as appropriate, within 30 days after completion of the audit.

AUTHORITY-6.5.5.6-The Manager ~- Quality Assurance Services Section under the Manager -

! Corporate Quality Assurance shall be responsible for the following:

a.

The administering of the Corporate Quality Assurance Audit Program.

i b.

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

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 experience or' training that establishes 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 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 1 6-14 Amendment No.

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i ADMINISTRATIVE CONTROLS:

6.5.6 OUTSIDE AGENCY INSPECTION AND AUDIT PF.OCRAM l

6.5.6.1 Am independent fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

6.5.6.2 '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.

l 6.6 REPORTABLE EVENT ACTION 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 requirements of Section 50.73 to 10 CFR Part 50, and b.

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

Corporate Nuclear Safety Section 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 SHUTDOWN within two hours.

b.

The NRC Operations Center shall be notified by telephone as soon as possible and-in all. cases within one hour. The Manager - Brunswick Nuclear Project and the Manager - Corporate Nuclear Safety Section shall be notified-within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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 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 -

Corporate Nuclear Safety Section within 14 days of the violation.

BRUNSWICK - UNIT 1 6-15 Amendment No.

o o

Mr(

^.4 ADMINISTRATIVE CONTROLS

)

6.8 PROCEDURES AND PROCRAMS 6.8.1 Written procedures shrill be established, implemented, and maintained covering the activities referenced below:

)

_The applicable procedures recommended in Appendix "A" of Regulatory

- a.

Guide 1.33, Novemberfl972, b.

Refueling operations.

'c.

Surveillance and test activities of safety related equipment.

d.

Security Plan implementation.

c._

Emergency Plan implementation.'

j f.

Fire Protection Program implementation.

g.-

0FFSITE DOSE CALCULATION MANUAL implementation.

h.-

PROCESS CONTROL PROGRAM implementation.

i.

Quality Assurance. Program for effluent and environmental monitoring i

~

using the guidance in Regulatory Guide 1.21, Revision 1, June 1974, and -Regulatory Guide 4.1,: Revision 1, - April 1975._

6.8.2 Temporary _ changes to procedures of Specification 6.8.1 above, any other

. procedures that affect nuclear safety, and. proposed tests or experiments may be made provided:-

The intent of the original procedure, proposed test or experiment is

.a.

not altered.

b.-

The change is approved by two members of the plant management staff, at least one of'whom' holds a Senior Reactor Operator' License on the

+

unit affected.

The change is documented, reviewed pursuant to specifications 6.5.2.1 c.

and 6.5.2.2 and approved by the General Manager - Brunswick Plant or his previously designated alternate within 14 days of implementation.-

- 6.8.3 The following programs shall be established, inplemented, and maintained:

a.-

Primary Coolant Sources Outside Containment A program to reduce leakage fron thesa portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The program shall include the following:

BRUNSWICK - UNIT 1 6-16 Amendment No, t

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'e

+

y.

.i E

ADMINISTRATIVE' CONTROLS PROCEDURES AND PROCRAMS (Continued) 1.

Preventive maintenance and periodic visual inspection requirements, and 2.-

Integrated leak test requirements for each system at refueling cycle intervals or less.

b.

In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident ~

conditions. This program shall include the following:

1.

. Training of personnel, 2.

Procedures for monitoring, and i

3.

Provisions for maintenance of sampling and analysis equipment.

c.

Post-Accident Sampling A program which will ensure-the capability to obtain and analyze reactor coolant, radioactive-iodines and particulates in plant. gaseous effluents, and containment atmosphere samples under accident 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.

y

'6. 9 REPORTINC REQUIREMENTS 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 ot' the Regional Office unless otherwise noted.

y STARTUP REPORTS

< a:

6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (1) receipt of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of

' fuel that has a different design or has been manufactured by a.different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic-performance of the plant.

BRUNSWICK - UNIT 1 6-17 Amendment No.

7 l

r E

ADMINISTRATIVE CONTROLS STARTUP REPORTS (Continued) 9 6.9.1.2 The startup report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the. operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additioaal specific details required in lleense conditions based on other commitments shall be included in this report.

6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, (3) 9 months follo91ng initial criticality, whichever is earliest.

If the Startup Report does not cover all three events, i.e.,

initial criticality, completion of startup test program, and resumption or commencement of commercial power operation, supplementary reports shall be submitted at least every three months until all three events have been completed.

= ANNUAL REPORTS 1!

6.9.1.4 Annual' reports covering the activities of the unit as described below during 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.

2I PERSONNEL EXPOSURE AND MONITORINC REPORT 6.9.1.5 Reports required on an annual basis shall include a tabulation of the number of station,~ utility, and other personnel, including contractors, receiving exposures greater than 100 mrem /yr, exposureaccordingtoworkandjobfunctions:pndtheirassociatedman-rem e.g., reactor operations and surveillance, inservice inspcetion, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignments to various duty functions may be estimated, based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20 percent of the individual total dose need not be accounted for.

In the aggregate, at least 80 percent of the total whole body dose received from external sources shall be assigned to specific major work functions.

1/ 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.

2/' This tabulation supplements the requirements of $20.407 of 10 CFR Part 20.

BRUNSWICK - UNIT 1 6-18 Amendment No.

. w.

ADMINISTRATIVE CONTROLS i

3/

ANNUAL RADIOLOGICAL-ENVIRONMENTAL OPERATING REPORT i

6.9.1.6 Routine radiological environmental operating reports covering the operation of the facility during the previous calendar year shall be submitted prior to May 1 of each year.

6.9.1.7. The Annual Radiological Environmental' Operating Report shall include the following:

a.

Summaries, interpretations, and an analysis of trends of the results.

of the radiological environmental surveillance activities for the report period, including a comparison with pre-operational studies, with operational controls (as appropriate), and with previous environmental surveillance reports, and an assessment of the observed impact of the-plant operation on the environment.

b.

Results of land uses censuses required by Specificaton 3.12.2.

c.

Recults'of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the OFFSITE DOSE CALCULATION MANUAL, as well as summarized and tabulated-results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision ~1, November 1979.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data should be submitted as soon as possible in a supplementary report.

d.

A summary description of the radiological environmental monitoring program.

least two legible mapsb! covering all sampling locations keyed to a e.

At table giving distances and directions from the center'.ine of one

reactor, f.

The results of-licensee participation in the Interlaboratory Comparison Program,' required by Specification 3.12.3.

3/ A single submittal may be made for a multiple unit station.

4/ One map shall cover stations near the SITE BOUNDARY; a second map shall

. include the more distant stations.

BRUNSWICK - UNIT 1 6-19 Amendment No.

. 1 y

3 ADMINISTRATIVE CONTROLS

' ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATINC REPORT (Continued) i g.

_ Discussion of all deviations from the sampling schedule of Table 3.12.1-1.

t h.

Discussion of all analyses in which the LLD required by Table 4.12.1-1 was not achievable.

SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORTS /

6.9.1.8 Routine radioactive effluent release reports. covering the operation of' the facility'during the previous 6 months of operation shall be submitted-within the time periodo specified in Specifications 6.9.1.9 and 6.9.1.10 below.

6.9.1.9 The portion of the Semiannual Radioactive Effluent Release Reports to be submitted within 60 days after January 1 and July 1 of each year shall

. include the following:

a.

A summary of the quantities of radioactive liquid and gaae>us effluents and solid waste released from the facility as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactivity Materials.

in Liquid and Caseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis similar to the format of Appendix B thereof.

b.

The information.specified below for each class of solid waste (as defined by 10 CFR Part 61, when implemented) shipped offsite during the report period:

1.

Container volume, 2.

Total curie quantity (specify whether determined by measurement or estimate),

3.

Principal radionuclides (specify whether determined by measurement or estimate),

4.

Source of waste and processing employed (e.g., dewatered spent-resin, compacted dry waste, evaporator bottoms),

5.

Type of-container (e.g., LSA, Type A, Type B, Large Quantity),

and 1-5/- 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.

l l

BRUNSWICK - UNIT 1 6-20 Amendment No.

4.

gf ADMINISTRATIVE CONTROLS

. SEMIANNUAL RADI0 ACTIVE EFFLUSNT RELEASE REPORT ~(Continued) 6.

Solidification agent or absorbent (e.g., cement, urea formaldehyde).

c..

A list of-description of unplanned releases from the site to.

UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

d.

Any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) or the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or

~

environmental monitoring identified.by the land use census pursuant to Specification 3.12.2.

e.

A summary of radioactivity released from the site by incineration of radioactive waste oil.

4 6.9.1.10 The portion of the Semiannual Radioactive Effluent Release Report to be submitted within 90 days af ter January 1'of each year shall include the followingt a.

An annual sumary of hourly metorological data collected over the previous calendar year. This annual sumary may be either-in the' form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.6/

b.

An assessment of the radiation doses due to the radioactive' liquid and

~ gaseous efflue'nts released from the station during the previous calendar year.

MONTHLY OPERATINC REPORTS 6.9.1.11 ' Routine reports of operating statistics and shutdown _ experience,..

including documentation of all challenges to main steam asystem. safety / relief valves,-shall be submitted on a monthly basis to the Director, Office of 4

lJ, Resource Management, U. S. Nuclear Regulatory Comission, Washington, D.C.

20555, with a copy to the Regional Administrator of the Regional Office no l

Later than the 15th of each month following the calendar month covered by the report.

l l'

6/ In lieu of submission with the Semiannual Radioactive Effluent Release l

l.

Report, the licensee has the option of retaining this sumary of required

[

meteorological data in a file that shall be provided to the NRC upon request.

BRUNSWICK - UNIT 1 6-21 Amendment No.

l 4

n t

i

- ^.

ADMINISTRATIVE CONTROLS SPECIAL REPORTS

-6.9.2 Special reports shall be submitted to the Regional Administrator of the Regional Office within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to f

the requirements of the-applicable reference specification.

j Inoperable Seismic Monitoring Instrumentation,-Specification 3.3.5.1.

b.

Seismic event analysis, Specification 4.3.5.1.2.

c.

Accident Monitoring. Instrumentation, Specification 3.3.5.3.

d.

Fire detection instrumentation, Specification 3.3.5.7.

e.

Reactor coolant specific activity analysis, Specification 3.4.5.

f.

ECCS actuation, Specifications 3.5.3.1 and 3.5.3.2.

g.

Fire suppression systems, Specifications 3.7.7.1, 3.7.7.2, 3.7.7.3, and 3.7.7.5.

h.

Fire' barrier penetration, Specification 3.7.8.

i.

Liquid Effluents Dose, Specification 3.11.1.2.

j.

Liquid Radwaste Treatment, Specification 3.11.1.3.

k.

Dose - Noble Cases, Specification 3.11.2.2.

1.

Dose - Iodine-131, Iodine-133, Tritium, and Radionuclides in Particulate Form, Specification 3.11.2.3.

e m.

Caseous Radwaste Treatment, Specification 3.11.2.4.

n.

Ventilation Exhaust Treatment, Specification 3.11.2.5.

o.

Total Dose, Specification 3.11.4.

p.

Monitoring Program, Specification 3.12.1.b.

q.

Primary Containment Structural Integrity, Specification 4.6.1.4.2 CORE OPERATINC LIMITS REPORT 6.9.3.1 Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, for the following:

a.

The AVERACE PLANAR LINEAR HEAT CENERATION RATES (APLHCR) for Specification 3.2.1.

BRUNSWICK - UNIT 1 6-22 Amendment No.

,4 ADMINISTRATIVE CONTROLS CORE OPERATINC LIMITS REPORT (Continued) b.

The Kg core flow ' adjustment factor for Specification 3.2.3.1.

c,

-The MINIMUM CRITICAL POWER RATIO (MCPR) for Specifications 3.2.3.1 and 3.2.3.2.

and shall be documented in the CORE OPERATING LIMITS REPORT.

6.9.3.2 The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents.

a.

.NEDE-24011-P-A, " General Electric Scandard Application for Reactor Fuel" (latest approved version).-

b.-

The May 18, 1984'and October 22, 1984 NRC Safety Evaluation Reports for the Brunswick Reload Methodologies described in:

1.

Topical Report NF-1583.01, "A Description and Validation of Steady-State Analysis Methods fo7 Boiling Water Reactors,"

February 1983.

2.

Topical Report NF-1583.02, " Methods of RECORD," February 1983.

3.

Topical Report NF-1583.03, "Hethods of PRESTO-B," February 1983.

4.

Topical Report NF-1583.04, " Verification of CP&L Reference BWR Thermal-Hydraulic Methods Using the FIBWR Code," May 1983.

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

6.9.3.4'~The CORE OPERATINC LIMITS REPORT, including any mid-cycle revisions or supplements shall be provided, upon issuance for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

l l

6.10 RECORD RETENTION 1

Facility records shall be retained in accordance with ANSI-N45.2.9-1974.

l 6.10.1 The following records shall be retained for at least five years:

1 a.

Records and logs of facility operation covering time interval at each

-l l-power level.

J l

BRUNSWICK - UNIT 1 6-23 Amendment No.

l-j j

l-i

U' ADMINISTRATIVE CCNTROLS

.i RECORDS RETENTION (Continued) b.

Records and' logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear' safety.

Lc.

All REPORTABLE EVENTS.

'd.

Records of surveillance activities, inspections, and ralibrations required'by these Technical Specifications.

-e.-

Records of changes made to 0perating Procedures.

f.

Records of radioactive shipments.

g.

Records cf sealed source and fission detector leak tests and results.

h.

-Records of annual physical inventory of all sealed source material of record.

6.10.2.The following record's shall be retained for the duration of the Facility Operating Licenses a.

Records'and drawing changes reflecting facility design modifications cade to systems and equipment described in the Final Safety Analysis Report..

b.

Records of new and irradiated-fuel inventory, fuel transfers and assembly burnup hit. tories.

-c.

Records of facility radiation and contamination surveys.

d.

Records or radiation exposure for all individuals entering radiation control areas.

e.

Records of gaseous and liquid radioactive material released to the

= environs.

f.

Records of transient or operational cycles for those facility components identified in Table 5.7.1-1.

o g.

Records of reactor tests and experiments.

h.

Records of training and qualification for current members of the plant staff.

i.

Records of inservice inspections performed pursuant to these Technical Specifications.

j.

Records of Quality Assurance activities required by the QA Manual.

BRUNSWICK - UNIT 1 6-24 Amendment No.

m 1

~~

ADMINISTRATIVE CONTROI.S RECORDS RETENTION (Continued) 4 k.

Records of reviews performed for changer, 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 environmenta't l

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 Corporate Nuclear Safety Section, and (4) che independent reviews performed by the Corporate Qus11ty 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-HICH 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

- conspicuously posted as a high radiation area and entrance therato 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 followings a.

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

4 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.

'

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.

BRUNSWICK - UNIT 1 6-25 Amendment No.

6 v

M v

v

.'I a

3-e -

ADMINISTRATIVE C0NTROLS HICH RADIATION AREA-(Continued) c.

An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual'shall be responsible-for providing positive control over the activities within the area and shall perform periodic radiation

. surveillance at the frequency specified by the facility Health Physicist in the Radiation Work Permit.

6.12.2 The' requirements _of 6.12.1 above shall also apply to each high radiation area in which the intensity of radi'ation is greater than 1000 mrem /hr. In addition, locked doors shall be provided to prevent t.nauthc,rized entry into such areas and the keys shall be maintained under the administrative control of the Operations Shift Foreman on duty and/or,the

~

Radiation Contro1~ Supervisor.

6.13 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.13.1 ' The OFFSITE DOSE CALCULATION MANUAL (ODCH) shall be approved by the =

Commission prior to implementation.

6.13.2 Licensee initiated changes to the ODCH:

a.-

Shall be submitted to the Commission in the Semitnnual Radioactive Effluent Release Report for the period in which the-change (s) was made effective. This submittal shall contain:

1.

Sufficiently detailed information to totally support rationale without benefit of additional or supplemental information.

Information submitted should consist of a package of those pages of the ODCH to be changed with each page numbered and provided with an approval and date box, together with appropriate analyses or evalur.tions justifying the change (s);

p l

2.

A determination that the change will not reduce the. accuracy or reliabllity of dose calculations or setpoint determinations; H

and, 3.

Documentation of:the fact that the change has been reviewed and found acceptable by the PNSC.

b.

Shall become effective upon review and acceptance by the PNSC.

6.14 PROCESS CONTROL PROGRAM (PCP) l I

6.14.1. The PROCESS CONTROL PROGRAM (PCP) shall be approved by the Commission f

prior to implementation.

u y

6.14.2 Licensee initiated changes to the PCP:

L BRUNSWICK - UNIT 1 6-26 Amendment No.

g a

-ADMINISTRATIVE CONTROLS PROCESS CONTROL PROGRAM (PCP) (Continued)

-a.:

.Shall be submitted to the Commission in the Semiannual Radioactive' Effluent Release Report for the period-in_which the change (s) was made. This. submittal shall containt l '.

Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information;

-i 2.

A determination that the change did not reduce the overal1~

conformance of the solidification waste product to existing criteria for solid wastes).and 3.

Documentation of-the fact _that the change has been reviewed and found acceptable by the PNSC.

b..

Shall become effective upon review and acceptance by the PNSC.

6.15 MAJOR CHANCES TO LIQUID, CASEOUS, AND SOLID WASTE TREATMENT SYSTEMS 7/

6.15.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous, and. solid):

.a.

Shall-be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in-which the evaluation was reviewed by the PNSC. The discussion of each change shall contain 1.

.A summary of the evaluation that led to the determination:that the change could be made in accordance with 10 CFR Part 50.59; l-2.

Sufficient detailed information to totally support the reason for the change without benefit of-additional or supplemental information; l

i 3.

A detailed description of the equipment, components, and.

processes involved and the interfaces with other plant. systems; 4.

An evaluation of the change that shows the predicted release of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; 5.

.An evaluation of the change that shows the expected maximum exposure to an individual in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto; 7,/ Licensees may choose to submit the information called for in this Specification as part of the annual FSAR update.

BRUNSWICK - UNIT 1 6-27 Amendment No.

F!

-e.

s

'ADMINISTRATIVI CONTROLS KAJOR CHANCES TO LIQUID, CASEOUS, AND SOLID WASTE TREATMENT SYSTEMS (Continued)

-6..

A comparison'of the predicted' releases of: radioactive materials,'

in liquid:and gaseous effluents and irt solid waste, to the actual releases for'the period prior to when the changes are to be madel 7.

An estimate of the exposure to plant operating personnel as a result of the changel and

8. -

Documentation of the-fact that the change was reviewed and found

+

acceptable to the PNSC.

b.

Shall become effective upon review and acceptance by the PNSC.

)

.s 2

BRUNSWICK - UNIT 1 6-28 Amendment No.

m?

/

1 4 -

l

.'4-F ENCLOSURE 2 F

}

BRUNSVICK. STEAM ELECTRIC' PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 DELETION OF ORGANIZATION CHARTS AND ADMINISTRATIVE CHANGES UPDATED TECHNICAL SPECIFICATION PAGES.

(NRC TAC NOS. 73017-AND 73018)

TECHNICAL SPECIFICATION PAGES - UNIT 2 1

l l

1.

(525CRS)

m y

04 INDEX

. ADMINISTRATIVE CONTROLS SECTION PACE 6.1-RESPONSIBILITY.............................................-

6-1 16.2-ORCANIZATION

'6.2.1

'0FFSITE AND ONSITE ORGANIZATIONS.......................-

6-1 l

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

6,

3'.-

6.2.3 ONSITE NUCLEAR SAFETY (ONS)

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

6-5 Responsibilities.......................................

6-5 4

Authority..............................................

6-5' 6.2.4 SHIFT TECHNICAL ADVIS0R................................

6-5

.c 6.3 FACILITY STAFF QUALIFICATION...............................

6-5 6.4 TRAININC.......................'............................

6-5

'6.5' REVIEW AND AUDIT l

6.5.1~

NUCLEAR SAFETY REVIEWERS...............................

6 I

'6.5.2

.SAFETYJEVALUATIONS-AND INDEPENDENT REVIEW CONTROL-Safety. Evaluations.....................................

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

6-7 Modifications.......................................... 7 Operating License / Technical Specifications.............

6-7 L

6.5.3 PLANT NUCLEAR' SAFETY COMMITTEE (PNSC)

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

6-8 Composition............................................

6-8 s

Alternates.............................................

6-8 Meeting Frequency......................................

6-8 Quorum.................................................

6-8 f

Activities.............................................

6-9 1 ',

Authority..............................................

6-10 Records................................................

6-10 l

l l-i l-BRUNSWICK - UNIT 2 XIV Amendment No.

i' 1

s

-)

r

.4 1

t INDEX

' ADMINISTRATIVE CONTROLS i

SECTION PACE 6.5 REVIEW AND AUDIT (Continued) 6.5.4-CORPORATE NUCLEAR SAFETY SECTION.

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

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

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

6 Records.....'............................................

6-12 6.5.5

. CORPORATE QUALITY ASSURANCE AUDIT PROGRAM Function................................................

6-13s Audits..................................................

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

6-14 Authority...............................................

6-14 Personnel...............................................

6-14 6.5.6I 0UTSIDE AGENCY INSPECTION AND AUDIT PROGRAM.............:

.6-15

.6.6 REPCETABLE EVENT ACTION....................................

6-15

'6.7 SAFETY LIMIT VIOLATION.....................................

6-15 6.8 PROCEDURES AND PR0CRANS....................................

6-16 6.9 REPORTINC REQUIREMENTS Routine Reports........................................

6-17 Startup Reports.........................................

6-17 Annual Reports..........................................

6-18

)

Personnel Exposure and Monitoring Report................

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

6-19 L

Semiannual Radioactive Effluent Release Report..........

6-20 I

l Monthly Operating Reports...............................

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

6-22 i

.1 Core Operating Limits Report............................

6-22 i

l l.

1 l

l l

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BRUNSWICK - UNIT 2 XV Amendment No.

u

e l

a-

. r INDEX r

' ADMINISTRATIVE CONTROLS SECTION PAGE 6.10 RECORD RETENTION..........................................

6-23 6.11 RADIATION PROTECTION PROGRAM..............................

6-25

'6.12 HICH RADIATION AREA.......................................

6-25 6.13 0FFSITE DOSE CALCULATION MANUAL (0DCM)..................

6-26 6.14' PROCESS CONTROL PROGRAM (PCP).............................

6-26'-

6.15 MAJOR CHAh'CES TO LIQUID, CASEOUS, AND SOLID WASTE TREATMENT SYSTEMS..........................

6-27 I

i f

4 BRUNSWICK - UNIT 2 XVI Amendment No.

m 4

I

.O 6.0 ADMINISTRATIVE CONTROLS i

-~

6.1 RESP 0NSIBILITY 6.1.1 The General Manager - Brunswick Plant shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

6.2 ORGANIZATION 6.2.1 0FFSITE AND ONSITE ORCANIZATIONO Onsite and offsite organizations shall be established for ani* opetation and I

corporate management, respectively. The onsite and off sits orstanizations shall include the positions for activities affecting the safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be t

establisheo and defined for the highest management levet: through intermediate levels to and including all operating organir.ation l

positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts. These organization charts will be ducumented in the FSAR and updated in accordance with 10CFR50.71(e).

b.

The General M;. nager - Brunswick Plant shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant, c.

The Senior Vice President - Nuclear Generation shall have corporate resp nsibility for overall-plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d.

The individuals wha train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate aasite managert however, they shall have sufficient organizationa'. freedom to ensure their independence from operating l

pressures.

i c.2.2 FACILITY STAFF Each facility on duty shift shall be composed of at least the minimum a.

facility shift crew composition shown in Table 6.2.2-1.

b.

At least oae licensed Reactor Operator shall be in the cor. trol room when fuel is in the reactor.

c.

When either reactor is in OPERATIONAL CONDITION 1, 2, or 3, at least

)

one licensed Senior Reactor Operator shall be in the control room.

BRUNSWICK - UNIT 2 6-1 Amt.hent No.

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' r.

l ADMINISTRATIVE CONTROLS t

FACILITY STAFF (Continued) d.

The Shift Operating Supervisors, Shift Foremen, and Senior Control Operators shall hold a senior reactor operator license. The Control Operators shall hold a reactor operator license.

e.

An individual qualified to implement radiation protection procedures l

shall be onsite when fuel is in either reactor.*

f.

All CORE ALTERATIONS shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited l

to Fuel Handling who has no other concurrent responsibilitier during this operation.

g.

A Fire Brigade of at least five members shall be maintained onsite at all times.* The Fire Brigade shall not include the minimum shift crew shown in Table 6.2.2-1 or any personnel required for other essential functions during a fire emergency.

h.

Administrative procedures shall be developed and implemented to limit l

the working hours of facility staff who perform safety-related functionet e.g.,

senior reactor operators, reactor operators, health physicists, auxiliary operators, and key. maintenance personnel.

These procedures shall meet the working hour guidelines published by the Commission in Generic Letter No. 82-12.

f i

The individual qualified to implement radiation protection procedures and Fire Brigade composition may be less than the minimum cequirements for a period of time not to exceed two hours in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

BRUNSWICK - UNIT 2 6-2 Amendment No.

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I TABLE 6.2.?-l i

MINIMUM FACILITY SHIFT CREW COMPOSITION WITH UNIT 1 IN CONDITION 1, 2, OR 3 POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & 5 1

1(b)

-SOS (a) g(b) g SRpa) 3 3

RO A0 3

3 STA 1

1 f

WITH UNIT 1 IN CONDITION 4 OR 5 t

POSITION NUMBER OF TNDIVIDUALS REQUIRED TO FILL POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & 5 I(DI I

SOS 1

g' b)

SRga(a) i g

)

3 2-RO A0 3

3 i

i STA 1

l None F

WITH UNIT 1 DE-FUELED POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION CONDITIONS 1, 2, & 3 CONDITIONS 4 & 5 I(DI I

SOS 1

b)

SRfa) g g

R0 a) 2 2

A0 3

3 STA 1

None BRUNSWICK - UNIT 2 6-3 Amendment No.

f TABLE 6.2.2-1 (Continued)

MINIMUM FACILITY 3HIFT CREW COMPOSITION I

TABLE NOTATION I'

{

SOS - Shift Operating Supervisor with a Senior Reactor Operators License

[

SRO - Individual with a Senior Peactor Operators License Individual.with a Reactor Operators License Ro Auxiliary Operator (non-Licensed individual)

AO

-STA - Shift Technical Advisor i

i (a) Assumes each individual is licensed on both plants.

i (b) Does not include the licensed Senior Reactor Operator or Senior Reactor r

Operator Limited to Fuel Handling, supervising CORE ALTERATIONS.

t The Shift Crew. composition may be less than the minimum requirements for a l

1 period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence-of on-duty shift crew members provided immediate action is taken to restore the Shift Crew composition to within the minimum requirements of Table 6.2.2-1.

i r

f i

t i

j

-BRUNSWICK - UNIT 2 6-4 Amendment No.

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e E

ADMINISTRATIVE CONTROLS

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6.2.3 ONSITE NUCLEAR SAFETY (ONS)

FUNCTION 6.2.3.1 The ONS Unit shall function to examine facility operating characteristics, NRC issues, industry advisories, and other sources which may indicate areas for improving facility safety.

P.ESPONSIBILITIES 6.2.3.2 The ONS Unit shall be responsible for maintaining surveillance of facility activities to provide independent verification

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

AUTHORITY 6.2.3.3 The ONS Unit shall make detailed recommendations for revised procedures, equipment modifications, or other means of improving facility safety to the Manager - Corporate Nuclear Safety Section.

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

6.3 FACILITY STAFF QUALIFICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI W18.1-1971 for comparable positions, except for (1) the Manager - Environmental & Radiation Control who shall meet or excced 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 TRAINING 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 n.eet or exceed the requiremencs 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.

Not responsible for sign-off function.

BRUNSWICK - UNIT 2 6-5 Amendment No.

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ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5,1 NUCLEAR SAFETY REVIEWERS 6.5.1.1 Individuals shall be designated / approved by the General Manager -

Brunswick Plant for performing nuclear safety reviews.

6.5.1.2 Individuals designated under Specification 6.5.1.1 above shall have an academic degree in an engineering or related field or equivalent and two years related experience.

6.5.1.3 A list shall be maintained of individuals qualified to perform nuclear safety reviews, including additional individuals whose expertise may be necessary during the reviews to assure that the reviewers collectively possess the background and qualfications in the disciplines necessary and important to the specific review.

6.5.1.4 The list specified in Specification 6.5.1.3 above shall include the disciplines for which each individual is qualified.

6.5.1.5 For those cases where interdisciplinary reviews are required, as many individuals as necessary shall be used to perform the nuclear review function.

6.5.1.6 One of the two nuclear safety reviewers shall be an individual other than the original preparer or the individual approving the action.

6.5.2 -SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONTROL SAFETY EVALUATIONS 6.5.2.1 A safety evaluation shall be prepared for each of the followingt a.

Changes to procedures required by Specification 6.8, or changes to other procedures that affect nuclear safety.

b.

Proposed tests or experiments that affect nuclear safety.

c.

Proposed modifications to plant systems or equipment that affect nuclear safety.

d.

Proposed changes to the Technical Specifications.

c.

Proposed changes to the Operating License.

6.5.2.2 Two nuclear safety reviews of the item and safety evaluation (s) prepared in accordance with Specification 6.5.2.1 above shall be performed prior to approval and implementation.

6.5.2.3 The item and associated safety evaluation (s) shall be examined in order to determine whether an interdisciplinary review is required in accordance with Specification 6.5.1.5 above.

BRUNSWICK - UNIT 2 6-6 Amendment No.

4 ADMINISTRATIVE CONTROLS PROCEDURES, TES.TS, 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 tests and experiments, and changes thereto 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, the procedures required 'oy 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 Managtr - Brunswick Plant or his previously designated alternate.

MODIFICATIONS 6.5.2.6 The rafety evaluation prepared in accordance with Specification 6.5.2.1.c above shalt 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 Specifications shall be approved by the General Manager - Brunswick Plant or his previously designated alternate.

OPERATING LICENSE / TECHNICAL SPECIFICi.TIONS 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 preliminary 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 bet a.

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

b.

Reviewed by the Corporate Nuclear Safety Section in accordance with Specification 6.5.4.9.

BRUNSWICK - UNIT 2 6-7 Amendment No.

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ADNINISTRATTIVE CONTROLS 6.5.3 PLANT NUCLEAR SAFETY COHMITTEE (PNSC)

FUNCTION 6.5.3.1 As an effective means for the regular review, overview, evaluation, i

and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established.

I i

6.5.3.2 The PNSC shall function through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION I

6.5.3.3 The PNSC shall be composed of that Chairman:

General Manager - Brunswick Plant

Membert Manager - Technical Support l

Membert Manager - Operations Membert Manager - Maintenance Membert Manager - Environmental & Radiation Control Membert Technical Assistant to Plant General Manager Member Manager - QA/QC Membert Manager - Regulatory Compliance ALTERNATES 6.5.3.4 All alternate members shall be appointed in writing by the PNSC Chairman to serve on a temporary basist however, no more chan two alternates shall participate as members at any one time.

6.5.3.5 All alternates, shall as a minimum, meet equivalent qualification criteria as specified for professional-technical personnel in Section 4.4 of ANSI N18.1-1971.

MEETING FREQUENCY 6.5.3.6 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.

QUORUM 6.5.3.7 The minimum quorum of the PNSC necessary for the performance of the PNSC activities.of the Technical Specifications shall consist of the PNSC Chairman or his designated alternate and four members including alternates. No i

more than two alternates shall be counted toward me, sting the minimum quorum requirement.

Or designated alternate.

BRUNSWICK - UNIT'2 6-8 Amendment No.

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Q ADMINISTRATIVE CONTROLS ACTIVITIES 6.5.3.8 The PNSC activities shall include the followingt 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 -

Corporate Nuclear Safety Section.

f.

Performance of special reviews, investigations (or analyses), and reports thereon as requested by the Manager - Corporate Nuclear Safety Section.

1

(

g.

Review of all REPORTABLE EVENTS.

f h.

Review of facility operations to detect potential nuclear safety hazards.

1.

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 - Corporate Nuclear Safety Section.

1.

Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE C/LCULATION MANUAL.

BRUNSWICK - UNIT ?

6-9 Amendment No.

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(I O

ADMINISTRATIVE CONTROLS AUTHORITY 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Manager - Brunswick Nuclear Project and the Vice President - Nuclear Services.

The coerse determined

'by the General Manager - Brunswick Plant to be the most conservative shall be followed.

RECORDS 6.5.3.10 The PNSC shall maintain written minutes cf 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 Ma.iager - Corporate Nuclear Safety

~

Section.

6.5.4 CORPORATE NUCLEAR SAFETY SECTION FUNCTION 6.5.4.1 The Corporate Nuclear Safety Section (CNSS) of the Nuclear Services Department shall function to provide independent review of significant plant changes, tests, and procedurest 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.

ORCANIZATION 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 areast a.

nuclear power plant operations b.

nuclear engineering t

c.-

chemistry and radiochemistry d.

metallurgy e,

non-destructive testing t

f.

instrumentation and control g.

radiological safety h.

mechanical and electrical engineering i.

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

e n

e

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ADMINISTRATIVE CONTROLS ORCANIZATION (Continued) t 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 - Corporate Nuclear Safety Section shall have an academic 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 program 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.

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

If sufficient expertise is not available within the Corporate Nuclear Safety Section, 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.

l i

6.5.4.8 The Corporate Nuclear Safety Section independent safety review program shall be conducted in accordance with written, approved procedures.

REVIEW 6.5.4.9 The Corporate Nuclear Safety Section shall perform reviews of the followingt a.

The safety evaluations for 1) changes to procedures required by Specification 6.8, 2) mndifications 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 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 Specificatiocs, prior to implementation.

BRUNSWICK - UNIT 2 6-11 Amendment No.

o ADMINISTRATIVE CONTROLS REVIEW (Continued) c.

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

.d.

Proposed changes to the Technical Specifications and Operating License.

e.

Violations of applicable codes, regulstions, orders, Technical l

l Specifications, license requirements, and internal procedures or instructions having nuclear safety signific,snce.

f f

f.

Significant operating abnormalities or deviations from normal and l

l expected performance of plant asfety-related structures, systems, or l

components.

l g.

Reportable events.

f h.

Reports and minutes of the PNSC.

I I

1.

Any other matter involving safe operation of the nuclear power plant that the Manager - Corporate Nuclear Safety Section deems appropriate for consideration or which is referred to the Mattager - Corporate Nuclear Safety Section by the on-site operating organization or other i

functional organizational units within Carolina Power & Light Company.

p 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 l!-

i 6.5.4.11 Records of Corporate Nuclear Safety Section reviews, including recommendations and concerns, shall be prepared and distributed as indicated belows a.

Copies of documented reviews shall be retained in the CNSS files.

t b.

~ Recommendations and concerns shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Nuclear Project, l

within 14 cays of completion of the review.

c.

A summation of Cotporate Nuclear Safety Section's recommendations and concerns shall be submitted to the Chairman / President; Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation; Vice President - Nuclear Services; Kanager - Brunswick Nuclear Project; Ceneral Manager - Brunswick Plant; and others, appropriate, at least once every two months.

BRUNSWICK - UNIT 2 6-12 Amendment No.

o ADNINISTRATIVE CONTROLS 6.5.5 CORPORATE QUALITY ASSURANCE AUDIT PROCRAM FUNCTION 6.5.5.1 The Quality Asst.rance Auditing Unit (QAAU) of the Corporate Quality l

Assurance Department shall function to perform audits of facility activities specified in Specification 6.5.5.2.

AUDITS 6.5.5.2 Audits of facility activities shall be performed by the QAAU. These l

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 facility staff at least once per 12 months.

c.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, sy;tems, 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 6

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

j h.

The radiologic.1 environmental monitoring program and the results thereof at least once per 12 months.

i 1.

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 vastes at least once per 24 months.

l l

BRUNSWICK - UNIT 2 6-13 Aa.endment No.

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i C-ADMINISTRATIVE CONTROLS AUDITS (Continued) k.

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, i

June 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least once per 12 months.

7 1.

Any other area of facility operation considered appropriate by the i

Manager - Quality Assurance Services Section, j

6.5.5.3 Personnel performing the quality assurance 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, e

approved by the Manager - Quality Assurance Services Section, and forwarded to the Executive Vice President - Power Supplyl Senior Vice President - Nuclear Generation Manager - Brunswick Nuclear Project) Vice President - Nuclear Servicest General Manager - Brunswick Planti and others, as appropriate, within 30 days after completion of the audit.

t AUTHORITY 6.5.5.6 The Manager - Quality Assurance Services Section under the Manager -

Corporate Quality Assurance shall be responsible for the followingt a.

The administering of the Corporate Quality Assurance Audit Program.

b.

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

PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area audited, i

6.5.5.8 Selection of personnel for auditing assignments shall be based on experience or training that establishes 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 experienes, personal characteristics, and education.

j i

l 6.5.5.9 -Qualified outside consultants or other individuals' independent from L

those personnel directly involved in plant operation shall be used to augment l

the audit teams when necessary.

1 BRUNSWICK - UNIT 2 6-14 Amendment No.

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C ADMINISTRATIVE CONTROLS i

6.5.6 OUTSIDE ACENCY INSPECTION AND AUDIT PROCRAM 6.5.6.1 An independent fire protection and loss prevention inspection and t

audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

6.5.6.2 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.

6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTSt The Commission shall be notified and a report submitted pursuant to a.

the requirements 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 -

Corporate Nucicar Safety Section 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 SHUTDOWN within two hours.

b.

The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour. The Manager - Brunswick Nuclear Project and the Manager - Corporate Nuclear Safety Section shall be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

A Safety Limit Violation Report shall be prepared.- The report shall be reviewed by the Ceneral Manager - Brunswick Plant. This report shall describe (1) appilcable 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 -

Corporate Nuclear Safety Section within 14 days of the violation.

BRUNSWICK - UNIT 2 6-15 Amendment No.

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j

.O ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROCRAMS l'

6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below!

The applicable procedures recommended in Appendix "A" of Regulatory a.

Guide 1.33, November 1972.

L b.

Refueling operations.

c.

Surveillance and test activities of safety related equipment.-

d.

Security Plan implementation.

e.

Emergency Plan implementation, f.

Fire Protection Program implementation.

g.

OFFSITE DOSE CALCULATION MANUAL implementation.

h.

PROCESS CONTROL PROGRAM implementation.

i.

Quality Assurance Program for effluent and environmental monitoring using the guidar.ce in Regulatory Cuide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975.

6.8.2 Temporary changes to procedures of Specification 6.8.1 above, any other procedures that affect nuclear safety, and proposed tests or experiments may be made provided:

a.

The intent of the original procedure, proposed test or. experiment is not altered, b.

The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator License on the unit affected.

c.

The change is documented, reviewed pursuant to Specifications 6.5.2.1 and 6.5.2.2 and approved by the Ceneral Manager - Brunswick Plant or his previously designated alternate within 14 days of implementation.

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

a.

Primary Coolant Sources Outside Containment 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 program shall include the followingt BRUNSWICK - UNIT 2 6-16 Amendment No.

o 9

(

l ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 1.

Preventive maintenance and periodic visual inspection requirements, and 2.

Integrated leak test requirements for each system at refueling cycle intervals or less.

b.

In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the i

airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

?

1.

Training of personnel, l

2.

Procedures for monitoring, and 3.

Provisions for maintenance of sampling and analysis equipment.

c.

Post-Accident Sampling A program which will ensure the capability to obtain and analyze reactor coolant, radioactive lodines and part!culates in plant gaseous effluents,.and ccntainment atmosphere samples under accident 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.

l 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, code of Federal Regulatione, the following reports shall be submitted to the Regional Administrator of the Regional Office unless otherwise noted.

STARTUP REPORTS l

6.9.1.1 A summary report of plant startup and power escalation testing shall j

be submitted following (1) receipt of an operating license,_(2) amendment to the license involving a planned increase in power level, (3) installation of i

fuel that has a different design or has been manufactured by a different fuel i

supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulle performance of the plant.

i BRUNSWICK - UNIT 2 6-17 Amendment NO.

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8, s ADMINISTRATIVE CONTROLS STARTUP REPORTS (Continued) i 6.9.1.2 The startup report shall address each of the tests identified in the 1

FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report.

K 6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events, i.e.,

initial criticality, completion of startup test program, and resumption or commencement of commercial power operation, supplementary reports shall be submitted at least every three months until all three events have been completed.

ANNUAL REPORTS 1/

6.9.1.4 Annual reports covering the activities of the unit as described below during 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.

2!

PERSONNEL EXPOSURE AND MONITORINC REPORT 6.9.1.5 Reports required on an annual basis shall include a tabulation of the number of station, utility, and other personnel, including contractors, receiving exposures greater than 100 mrem /yr exposureaccordingtoworkandjobfunctions27ndtheirassociatedman-rem e.g., reactor operations and surveillance, intervice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignments to various duty functions may be estimated, based on pocket dos. meter, TLD, or film badge measurements. Small exposures totalling less than 20 percent of the individual total dose need not be accounted for.

In the aggregate, at least 80 percent of the total whole body dose received from external sources shall be assigned to specific major work functions.

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

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2/ This tabulation supplements the requirements of $20.407 of 10 CFR Part 20.

BRUNSWICK - UNIT 2 6-18 Amendment No.

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i L-ADMINISTRATIVE COWTROLS y

ANNUAL RADIOLOCICAL ENVIRONMENTAL OPERATINC REPORTE!

6.9.1.6 Routine radiological environmental operating reports covering the operation of the facility during the previous calendar year shall be submitted i

prior to May 1 of each year.

6.9.1.7 The Annual Radiological Environmental Operating Report shall include the followings a.

Summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with pre-operational studies, with operational controls (as appropriate), and with previous environmental surveillance reports, and an assessment of the observed impact of the plant operation on the environment.

b.

Results of land uses censuses required by Specificaton 3.12.2.

[

Results of analysis of all radiological environmental samples and of c.

all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the OFFSITE DOSE CALCULATION MANUAL, as well as summarized and tabulated results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data should be submitted as soon as possible in a supplementary report.

d.

A summary description of the radiological environmental monitoring

program, At least two legible mapsb! covering all sampling locations keyed to a e.

table giving distances and directions from the centerline of one reactor.

f. --

The results of licensee participation in the Interlaboratory Comparison program, required by Specification 3.12.3.

2/ A single submittal may be made for a multiple unit station.

3/ One map shall cover stations near the SITE BOUNDARY; a second map shall include the more distant stations.

BRUNSWICK - UNIT 2 6-19 Amendment No.

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ADMINISTRATIVE C0NTROLS ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATINC REPORT (Continued) g.

Discussion of all deviations from the sampling schedule of Table 3.12.1-1.

h.

Discussion of all analyses in which the LLD required by Table 4.12.1-1 was not achievable.

SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORTb/

6.9.1.8 Routine radioactive effluent release reports covering the operation of the facility during the previous 6 months of operation shall be submitted

.I within the time periods specified in Specifications 6.9.1.9 and 6.9.1.10 below.

6.9.1.9 The portion of the Semiannual Radioactive Effluent Release Reports to be submitted within 60 days af ter January 1 and July 1 of each year shall include the followings a.

A summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactivity Haterials in Liquid and Caseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis similar to the format of Appendix B thereof.

b.

The information specified below for each class of solid waste (as defined by 10 CFR Part 61, when implemented) shipped offsite during the report periodt 1.

Container volume, 2.

Total curie quantity (specify whether determined by measurement or estimate),

3.

Principal radionuclides (specify whether determined by measurement or estimate),

4.

Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporator bottems),

5.

Type of container (e.g., LSA, Type A, Type B, Large Quantity),

and 5/ 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.

BRUNSWICK - UNIT 2 6-20 Amendment No.

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b b

ADMINISTRATIVE CONTROLS i

SEMIANNUAL RADI0 ACTIVE EFFLUENT RELFASE REPORT (Continued) 6.

Solidification agent or absorbent (e.g., cement, urea formaldehyde).

c.

A list of description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

d.

Any changes made during the reporting period to the PROCESS CONTROL PROCRAM (PCP) or the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land use census pursuant to Specification 3.12.2.

e.

A summary of radioactivity released from the site by incineration of radioactive waste oil.

6.9.1.10 The portion of the Semiannual Radioactive Effluent Release Report to be submitted within 90 days after January 1 of each year shall include the following a.

An annual summary of hourly metorological data collected over the f

previous calendar year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.L b.

An assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the station during the previous calendar year.

MONTHLY OPERATING REPORTS 6.9.1.11 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to main steam system safety / relief valves, shall be submitted on a monthly basis to the Director, Office of Resource Management, U. S. Nuclear Regulatory Commission, Washington, D.C.

20555, with a copy to the Regional Administrator of the Regional Office no i

later than the 15th of each month following the calendar month covered by the report.

6/ In lieu of submission with the Semiannual Radioactive Effluent Release Report, the licensee has the option of retaining this summary of required i

I meteorological data in a file that shall be provided to the NRC upon i

L request.

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BRUNSWICK - UNIT 2 6-21 Amendment No.

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e ADMINISTRATIVE CONTROLS SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Regional Administrator of the Regional Office within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirean.s of the applicable reference specification.

c.

Inoperable Seismic Monitoring Instrumentation, Specification 3.3.5.1.

b.

Seismic event analysis, Specification 4.3.5.1.2.

j c.

Accident Monitoring Instrumentation, Specification 3.3.5.3.

d.

Fire detection instrumentation, Specification 3.3.5.7.

i e.

Reactor coolant specific activity analysis, Specification 3.4.5.

f.

ECCS actuation, Specifications 3.5.3.1 and 3.5.3.2.

g.

Fire suppreosion systems, Specifications 3.7.7.1, 3.7.7.2, 3.7.7.3, and 3.7.7.5.

I h.

Fire barrier penetration, Specification 3.7.8.

1.

Liquid Effluents Dose, Specification 3.11.1.2.

j.

Liquid Radwaste Treatment, Specification 3.11.1.3.

k.

Dose - Noble Cases, Specification 3.11.2.2.

1.

Dose - Iodine-131, Iodine-133, Tritium, and Radionuclides in Particulate Form, Specification 3.11.2.3.

t m.

Caseous Radweste Treatment, Specification 3.11.2.4.

n.

Ventilation Exhaust Treatment, Specification 3.11.2.5.

-o.

Total Dose, Specification 3.11.4.

p.

Monitoring Program, Specification 3.12.1.b.

q.

Primary Containment Structural Integrity, Specification 4.6.1.4.2.

CORE OPERATING LIMITS REPORT 6.9.3.1 Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, for the followingt a.

The AVERAGE PLANAR LINEAR HEAT CENERATION RATES (APLHGR) for Specification 3.2.1 including core flow and core power adjustments.

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BRUNSWICK - UNIT 2 6-22 Amendment No.

i 1

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ADrlINISTRATIVE CONTROLS 3

CORE OPERATINC LIMITS REPORT (Continued) i b.

The core flow and core power adjustments for Specification 3.2.2.1.

c.

The MINIMUM CRITICAL POWER RATIO (MCPR) for Specifications 5.2.2.1 I

and 3.2.2.2.

d.

The rod block monitor upscale trip setpoint and allowable value for Specification 3.3.4.

I and shall be documented in the CORE OPERATING LIMITS REPORT.

6.9.3.2 The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents.

i a.

NEDE-24011-P-A, "Ceneral Electric Standard Application for Reactor

.i Fuel" (latest approved version).

b.

The May 18, 1984 and October 22, 1984 NRC Safety Evaluation Reports for the Brunswick Reload Methodologies described in:

1.

Topical Report NF-1583.01, "A Description and Validation of Steady-State Analysis Methods for 3 oiling Water Reactors,"

February 1983.

2.

Topical Report NF-1583.02, " Methods of RECORD," February 1983.

3.

Topical Report NF-1583.03, " Methods of PRESTO-B," February 1983.

4.

Topical Report NF-1583.04, " Verification of CP&L Reference BWR Thermal-Hydraulic Methods Using the FIBWR Code," May 1983.

6.9 3.3 The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown mergin, transient analysis limits, and accident analysis limits) of the safety analysis are met'.

6.9.3.4 The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements shall be provided, upon issuance for each reload cycle, to the l

WRC tucument Control Desk with copies to the Regional Administrator and Resident Inspector.

ll 6.10 RECORD RETENTION l

Facilir.y records shall be retained in accordance with ANSI-N45.2.9-1974.

l

-6.10.1 The following records shall be retained for at least five years a.

Records and logs of facility operation covering time interval at each power level.

BRUNSWICK - UNIT 2 6-23 Amendment No.

O ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued) b.

Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of. equipment related to nuclear safety.

c.

All REPORTABLE EVENTS.

d.

Records of surveillance activities, inspections, and calibrations required by these Technical Specifications.

e.

Records of-changes made to Operating Procedures.

f.

Records of radioactive shipments.

g.

Records of scaled source and fission detector leak tests and results.

h.

Records of annual physical inventory of all sealed source material of record.

6.10.2 The following records shall be retained for the duration of the Facility Operating Licenses a.

Records and drawing changes reflecting facility design modifications i

made to systems and equipment described in the Final Safety Analysis

. Report.

e b.

Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c.

Records of facility radiation and contamination surveys, d.

Records or radiation exposure for all individuals entering radiation control areas.

e.

Records of gaseous and liquid radioactive material released to the environs.-

f.

Records of transient or operational cycles for those facility components identified in Table 5.7.1-1.

g.

Records of reactor tests and experiments.

j h.

Records of training and qualification for current members of the plant staff.

i.

Records of inservice inspections performed pursuant to these 1

Technical Specification <,.

i j.

Records of Quality Assurance activities required by the QA Manual.

l BRUNSWICK - UNIT 2 6-24 Amendment No.

o' j

ADMINISTRATIVE CONTROLS l

RECORDS RETENTION (Continued) k.

Records of. reviews performed for changes made to procedures or 1

equipment or reviews of tests and experiments pursuant to j

10 CFR $0.59.

l 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.

n).

Records of analyses required by the radiological environmental monitoring program.

Records of (1) meetings of the PNSC, (2) meetings of the previous I

n.

off-site review organization, the Company Nuclear Safety Committee l

(CNSC), (3) the independent reviews performed by the Corporate j

Nuclear Safety Section, and (4) the independent reviews performed by the Corporate Quality Assurance Audit Program, Quality Assurance l

l Auditing Unit.

I 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 HICH RADIATION AREA 6 ~.12.1 In lieu of the " Control Device" or " alarm signal" required by

-l 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 individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following A radiation monitoring device which continuously indicates the a.

radiation dose rate in the area.

l 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 i

established and personnel have been made knowledgeable of them.

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Health Physics personnel or personnel escorted by Health Physics personnel shall be _ exempt from the RWP issuance requirement during the perforrrance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

BRUNSWICK - UNIT 2 6-25 Amendment No.

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ADMINISTRATIVE CONTROLS HICH RADIATION AREA (Continued) j c..

An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device.- This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiation Work Permit.

6.12.2 The requirements of 6.12.1 above shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr.

In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Operations Shift Foreman on duty and/or the i

Radiation Control Supervisor.

f 6.13 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.13.1 The OFFSITE DOSE CALCULATION MANUAL (ODCMI shall be approved by the Commission prior to implementation.

i 6.13.2 Licensee initiated changes to the ODCM a.

Shall be submitted to the Commission in the Semlannual Radioactive Effluent Release Report for the period in which the change (s) was made effective. This submittal shall containt 1.

Sufficiently detailed information to totally support rationale without benefit of additional or supplemental information.

Information submitted should consist of a package of those pages l

of the ODCM to be changed with each page numbered and provided

_l with an approval and date box, together with appropriate analyses or evaluations justifying the change (s);

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2.-

A determination that the change will not reduce the accuracy or

[

reliability of dose calculations or setpoint determinations; and,-

3.

Documentation of the fact that the change has been reviewed and found acceptable by the PNSC.

b.

Shall become effective upon review and acceptance by the PNSC.

6.14 PROCESS CONTROL PROCRAM (PCP) i 6.14.1 The PROCESS CONTROL PROGRAM (PCP) shall be approved by the Commission prior to implementation.

6.14.2 Licensee initiated changes to the PCP:

BRUNSWICK - UNIT 2 6-26 Amendment No.

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ADMINISTRATIVE CONTROLS PROCESS CONTROL PROGRAM (PCP) (Continued) a.

Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was l

made. This submittal shall containt 1.

Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information 2.

A determination that the change did not reduce the overall conformance of the solidification vaste product to existing criteria for solid wastest and 3.

Documentation of the fact that the change has been reviewed and found acceptable by the PNSC.

]

b.

Shall become effective upon review and acceptance by the PNSC.

6.15 MAJOR CHANCES TO LIQUID, CASEOUS, AND SOLID WAETE TREATMENT SYSTEMS.I.I 6.15.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous, and solid):

a.

Shall be reported to the Commission in the hemiannual Radioactive Effluent Release Report for the period in thsch the evaluation was reviewed by the PNSC. The discussion of each change shall contain:

1.

A summary of the evaluation that led to the determination that the change could be made in accords.nce with 10 CFR Part 50.591 2.

Sufficient detailed information to totally support the reason for the charge without benefit of additional or supplemental information; i

3.

A detailed description of the equipment, components, and processes involved and the interfaces with other plant systems; 4.

An evaluation of the change that shows the predicted release of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments theretot 4

5.

An evaluation of the change that shows the expected maximum exposure to an individual in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments theretol J,/ Licensees may choose to submit the information called for in this Specification as part of the annual FSAR update.

BRUNSWICr - UNIT 2 6-27 Amendment No.

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O-ADMINISTRATIVE CONTROLS l

' MAJOR CHANCES TO LIQUID, CASEOUS, AND SOLID WASTE TREATMENT SYSTEMS

?

(Continued)

I 6.

A comparison of the predicted releases of radioactive materials, in liquid and_ gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be madel 7.

An estimate of the exposure to plant operating personnel as a result of the changel and 8.

Documentation of the fact that the change was reviewed and found acceptable to the PNSC.

b.

Shall become effective upon review and acceptance by the PNSC.

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E BRUNSWICK --UNIT 2 6-28 Amendment No.

2

ML19332C233

Text

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