ML20066F437

Application for Amends to Licenses DPR-62 & DPR-71,revising Tech Spec Section 6.0, Administrative Controls, Reflecting Changes in Organizational Structure.Detailed Description of Proposed Changes & Basis for Changes Encl

ML20066F437
Person / Time
Site:	Brunswick
Issue date:	01/15/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20066F441	List: ML20066F437 ML20066F449
References
NLS-90-197, TSC-90TSB13, NUDOCS 9101230333
Download: ML20066F437 (9)

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Carolina Power & Light Company >

P.0, Box 1561 e Reieigh, N C. 27002 ' -\

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SERIAL:- .NLS 90 197 -;

-10CFR50.90 -  !

G. E. VAUGHN Vice President Nuclear servicoe Department H

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-i United States Nuclear Regulatory Commission  !

ATTENTION: Document Control Desk Washington, DC 20555-BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 -

DOCKET NOS. 50 325 & 50-324/ LICENSE NOS. DPR-71 &-DPR 62 '

REQUEST FOR LICENSE AMENDMENT.

NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CHANGES Gentlemen: ,

.In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and.

2.101, Carolina Power & Light Company-(CP&L) hereby requests a revision to the Technical Specifications for the -Brunswick Steam Electric Plant (BSEP) . The proposed change revises Section 6.0, " Administrative Controls,"'of the '

' Technical Specifications to reflect changes'in the organizational structure of-g CP&L.

1 Carolina Power & Light Company (CP&L) has created a Nuclear Assessment Department (NAD) which'will perform internali evaluation'and assessment i activities and will serve as senior management's staff for the objective oversight of. Nuclear Generation Group performance relating to nuclear safety, reliability,-and quality. The department's fundamental. role is to assist senior management-in the early identification' fo those1 barriers which may -

prevent the Company's nuclear projects from achieving the- desired level of i performance on a sustained _ basis and in: ensuring their effective correction.

The NAD will assume the-functions'and responsibilities for (1) administering the Company's independent review program for nuclear-facilities which is currently-provided by the Corporate Nuclear Safety Section (CNSS); and (2) the audit of unit activity currently provided by the Quality-Assurance' Services Section of the Corporate Quality Assurance Department.

Creation of the Nuclear Assessment Department requires that'the Technical

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Specifications be modified to reflect changes in the organizational-structure '

of CP&L. Accordingly, titles of positions and organizations referenced in the Technical Specifications must be changed to reflect this organizational-change.

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i. Document Control Desk NLS 90 197-/ Page 2 i

Enclosure 1 provides a detailed descriptionJof the proposed' changes and the= 6 basis for the changes.-

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Enclosure -2. details t.he basis for .the Company's -determintA'on that the proposed changes do not involve'a significant: hazards consideration. g 1

Enclosure 3 details the.' basis-for the Company's dotermination that the 'l proposed changes- require no environmentalf assessment. .?

':1 Enclosures-4 and 5 providoithe proposed. Technical Specification pages!for each  !

unit. 1 In order to allow time' for- procedure revisionf andfordehly ' incorporation;into copies of the Technical Specifications CP&L requests thattthe. proposed:

amendments.-once approved by:the NRC, be-issued with an effective date to be- {

no later than 60 days from the issuance 'of;the -amenctment. l Please refer

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.y quea.i ms regarding;this submittaltto,Mr. M..R. Oates-at j (919) 546 6063.  ;

fYoursLvery truly,  ;

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C. E 'Vaughn i

JCP/ecc (824BNP)

Enclosures:

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1. Basis for Change Request

2. 100FR50.92 Evaluation-

3. Environmental Considoration >

4. Unit 1' Technical Specification Pages- I

5. ~ Unit 2 Technical Specification Pages j l

I cc: Mr. Dayne H. Brown.  :!

Mr. S. D.. Ebneter j Mr. N.-B. Le Mr. R. L. Prevatte -

C. E. Vaughn, having been first duly sworn, did depose andcsayLthat the infor.

-mation contained herein is true 'and' correct to theibest of his informationt knowledge and belief; and the sources:of his information are officers, employees, contractors,.and age'nts of Carolina Power 6 Light Company. .

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j ENCihSURE1 BRUNSWICK STEAM ELECTRIC ~ PLANT, UNITS-1.AND 2- d NRC' DOCKETS 50 325 & 50 324:

-OPERATINC LICENSESJDPR 71 & DPR 62- _[

REQUEST FOR LICENSE AMENDMENT. _. ((

NUCLEAR ASSESSMLNT DEPARTMENT,ORCANIZATION' CHANGES 1 BASIS FOR-CHANCE REQUEST- j Prooosed Chances:- ,

Creation of the-Nuclear Assessment Department (NAD)1 requires:that the j Technical-Specifications be modified.to reflectfchanges;in the-. organizational 4 structure,: Accordingly,4 titles of-positions?and organizations referenced in. y the Technical Specifications must; be changed tol reflect this -organizational t A change. 'The proposed change modifies the following; sections of the-Technical a Specifications as. indicated:- f Section 6.2 I d

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-6.2.3 Revised to reflect that ~ thel Project Assessme_nt -(PA) Group of_ tho ' ,9 Nuclear Assessment Department (NAD) shall; assume the functions, .

responsibilities and authority currently described;in-_this-section-for 3 the Onsite Nuclear Safety---(ONS) unit of the Nuclear Services: Department. 3 3

-Section 6.5 -!

6.5.2.-9 Revised to specify that~in'accordance. with  !

Specification 6.5.4,9 the NAD rather than' the. Corporate Nuclear Safety. }

Section (CNSS) shall review. safety' evaluations prepared in1accordance: 1 with 6.5.2.1.d and 6.5.2.1.o.-

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, 6. 5. 3,8. Revised to specify that the Manager - NAD rather than thel Ei l Manager - CNSS'be.'n

recipient of reports covering evaluationsjand' L recommendations to prevent recurrence offviolation Lof; Technical  :

Specifications. Revised.to authorize the Manager 1.NAD;rather than'the--

f- Manager - CNSS to' request the: Plant-Nuclear l Safety CommitteeT(PNSC).to: '

- perform special reviews, investigationsL(or? analyses)~and; reports.1 ,

Revised to require forwarding:of PNSC. reports covering evaluation ~,- y recommendations and' disposition _of corrective action:to prevent:

recurrence-of accidental', unplanned-orl uncontrolled radioactive releases to the' Manager - NAD rather than:the Manager :CNSS. ,

L 6.5,3.9 Revised to specify that the~-Manager NAD rather_than the Vice .;

President Nuclear Service'sthe the recipient of.thes24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written; -

i notification of .a disagreement between recommendations ofia majority -ofl the PNSC and the actions contemplated by the1 General _ Manager - Brunswick-Plant. ,

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6.5.3.10 Revised to require submittal of copies of v.*itten PNSC meeting minutes to the Manager NAD rather than the Manager CNSS.

6.5.4 Revised to reassign to the NAD rather than the (NSS responsibility for administering the independent review program described in this section. Revised to define the qualifications for the Manager NAD rather than the Manager - CNSS. Revised to address documentation, distribution and summation of NAD reviews, recommendations, and concerns rather than those of the-CNSS.

6.5.5 Revised to reassign to the NAD rather than the Quality Assurance Auditing Unit, responsibility for performing audits of facility activities described in Technical Specification 6.5.5.2. Revised to authorize-the Manager - NAD rather than the Manager - Quality Assurance Services Section, responsibility for administering the NAD audit program and approving individuals selected to conduct audits. Also , revises distribution of audit reports to delete Vice -President Nuclear Services due_to this function being reassigned to NAD.

Section 6.6 6.6.1 Revised to specify that the Manager - NAD rather than the Manager - CNSS be a recipient of REPORTABLE EVENT reports.

Section 6.7 6.7.1 Revised to specify that the Manager - NAD rather than the Manager - CNSS shall be notified in the-event a Safety Limit is violated. Revised to specify that the Manager - NAD rather than the -

Manager - CNS shall be a recipient of Safety Limit violation reports.

Section 6.10-6.10.2 Revised to require that records of independent review performed by the NAD shall be retained for the duration of the facility operating license.

Basis The content required in the Administrative Controls Section of the Technical Specifications is specified in 10 CFR 50.36c(5). The regulation requires that the Technical Specifications contain the controls and provisions that are necessary to assure operation of the facility in a safe manner.

Creation of the Nuclear Assessment Department (NAD) requires that the Technical Specifications'be modified to reflect changes in the organizational structure. Accordingly, titles of positions and organizations referenced in the Technical Specificatiors must be changed to reflect this organizational change.

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The independent review function currently provided by the-Corporate Nuclear Safety Section (CNSS) as outlined 11n theiTechnical Specifications, will not- be_- -

altered.by the. change. 'Rather the proposed' change' will merely reflect a

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reporting realignment-of the individuals and organizations currentlysproviding the independent review function. Similarly,;.the audit of unit activity; _

function currently,provided by-the Quality Assurance Auditing Unit of-..the Corporate; Quality Assurancc~ Department will.not-be altered by the' change;-but-will-reflect a reporting realignment of_theiindividuals'and organizations  ;

currently providing the audit-function, Consistent with current;and previous record retention _ requirements,_recordsiof Nuclear Assessment Department' reviews and Nuclear _ Assessment, Department: audits- +

will be retained as life time records:of the plant.

In accordance with Specification _6.2.la,flines of_ authority,; responsibility,.

and communication will be documented and provided in the next: annual. update of' the Final Safety Analysis Report'(FSAR) as required by:105CFRl50.71(c).--

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ENCLOSURE 2 i

BRUNSWICK STEAM ELECTRIC-PLANT, UNITS 1 AND 2: ~

-NRC DOCKETS 50 325 & 50 324 OPERATING LICENSES'DPR 71 & DPR 62' REQUEST FOR LICENSE AMENDMENT' NUCLEAR-ASSESSMENT-DEPARTMENT ~ ORGANIZATION CHANCES-

-10 CFR 50.92 EVALUATION.

TheCommissionhasprovidedstandards'in10fCFR50'92'(chfordetermining whether.a significant hazards consideration exists. iA~ proposed: amendment to-an operating. license.for.a facility involves no significant: hazards-consideration if operatAon of the facility in-accordance_with the proposed-amendment would not: -(1) involve a'significant increase in the probability or  ;

consequences of'an accident previously evaluated,1(2) create the possibility -!

of a new or different kind of-accidentffrom any accident previously~ evaluated, '

or (3) involve a significant reduction :in: a' mar 6 n :of 1 _ safety.1- - Carolina 1 Power & Light Company has reviewed this" proposed, license-_ amendment. request and

determined that its adoption would not involve a' significant" hazards consideration , The bases for this'detecmination are as:follows:-

-Pronosed Chance *-

Creation of the-Nuclear Assessment Department (NAD)? requires:that the-

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p Technical Specifications be modified to yoflect changes'in the organizational structure. Accordingly,= titles.of'positionstand' organizations referenced in-the Technical Specifications ~mustLbe changed to reflectethis' organizational d change.- ]

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Basis 4

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The change does.not involve a-significant' hazards consideration for the' i following' reasons:

1. The proposed amendment does not involvo a.significant increase in the probability'or consequences of an_ accident previously evaluated:because .

it is administrative in nature and.does not physically alter _ any safety- ' l" related systems nor does'it affect the'way in which any safety related systems: perform their' functions. The revisions:to.Section 6,0-of the  ;

Technical Specifications reflect changes 11n the organizational. reporting'  ;

structure of CP&L due to the creation of the. Nuclear Assessment 1 Department (NAD). The proposed change is administrative in nature in 1 that the changes reflect organizational reporting changesirather than changes Lin the nature or depth of reviewsuand : audits; recommendations ,

for procedures, modifications, maintenance and operations. activities; or other means.of affecting unit safety. . The independent review'functioni currently provided by"the Corporate Nuclear'3afety Section-(CNSS)'as  !

outlined-in the Specifications, will not be altered by the change.

Rather the proposed change will merely reflect'a reporting realignment  ;

of the individuals and; organizations currently providing the independent '

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review function. Similarly,- the audit of unit activity function '

currently provided by the Quality Assurance Auditing Unit of the Corporate Quality Assurance Department will not be altered by the change, but will reflect a reporting realignment of the individuals and organizations currently providing the audit function. The other revisions to titles and' organizations in the proposed change solely revise the Technical Specifications to reflect the revised organizational structure of the company,

2. The proposed amendment does not create the possibility of a new or

different kind of accident from any accident previously evaluated. As j stated in Item 1, the proposed change is. administrative in nature and does not physically alter any safety related systems, nor does it a ffect j the way in which any safety related systems perform their function-e.

Therefore, the proposed amendment does not create the passibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment does not-involve a significant reduction in the margin of safety. The proposed change in-administrative in nature and does not physically alter any safety related systems nor does it affect the way in which any safety related systems perform their functions. As a result of the change, the Brunswick Technical Specifications.will better reflect the actual-management structure at both the Brunswick

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Planc and the Corporate Office, Therefore, the proposed amendment does-not involve a significant reduction in margin of safety.

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l ENCIDSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 i NRC DOCKETS 50 325~& 50-324-REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CHANGES ENVIRONMENTAL CONSIDERATION 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an- 1 environmental assessment. A proposed _ amendment to an operating license for_a '

facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of atj effluents that_may be released offsite; and (3) result in an increase in an individual or cumulative occupational radiation exposure. Carolina Power & Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. This basis for this determination follows:

Pronosed Chance Carolina Power & Light Company (CP&L) has created a Nuclear Assessment -

' Department (NAD) which will perform internal evaluation and assessment-activities and will serve as senior management's staff for the objective oversight of Nucicar Generation Group performance relating to r.uclear safety, reliability, and quality. The department's fundamental role _-is to assist senior management in the early identification of those barriors Yhich may prevent the Company's nuclear projects from achieving the desired level of performan.:e en a sustained basis and in ensuring their effective correction.

The NAD will assuue the functions and respcasibilities for- (1) idministering the Company's independent review program for nuclear facilities which is currently provided by the Corporate Nuclear Safety Section (CNSS); and (2) the audit of unit activity currently provided by the Quality Assurante Services

-Section of the Corporate Quality Annurance Department.

Creation of the Nuclear Assessment Department requires that the Technical Speci.fications be modified to reflect changes in the organizational structure of CP&L. Accordingly, titles of positions and organizations referenced in the Technten1 Specifications must be changed to reflect this or6anizational change.

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Basis This change meets the eligibility criteria for categorical exclusion set forth- j in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in Enclosure 2, the proposed amendment does not=involveL a significant hazards consideration, l

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2. The proposed amendment does not resultsin a significant change in'the types or significant increase in=the amounts of-any; effluents that may be released offsite. c]i i

The proposed change is-purely administrative in nature:and-only revises Section 6 " Administrative Controls",of the Technical Specifications to i

reflect changes in the organizational: reporting structure'of.CP&L

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the creation of the NAD. The proposed amendment does'notcintroduce any  ?,

new equipment nor does it_ require-any; existing-equipment or. systems to j perform a different type of= function than-they are currently designed to .j perform. As such, the-change cannot affect the' types or amounts of any '

effluents that may be released offsite.  !

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3. The proposed amendment does-not result-in an increase in' individual'or- l cumulative occupational radiation exposure.- The proposed change is purely-administrative in nature and .only-revises--Section16

" Administrative Controls" of the Technical Specifications to: reflect changes in the organizational reporting structure of CP6L due'to the

• creation of the NAD. LNo additional surveillances or testingf results 5

from the amendment. Therefore, L the amendment has no~ affect cn) either individual or cumulative occupational radiation exposure.

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