ML20071K466
| ML20071K466 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/22/1994 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20071K462 | List: |
| References | |
| NUDOCS 9407290422 | |
| Download: ML20071K466 (38) | |
Text
ENCLOSURE 5 HRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NO. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR -62 REQUEST FOR LICENSE AMENDMENT PERFORMANCE-BASED NUCLEAR ASSESSMENT PROGRAM MARKED-UP TECilNICAL SPECIFICATION PAGES - HSEP 1 i
i 9407290422 9407pj M
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dEEE5 ADMINISTRATIVE CONTPOLS i
(
1 l
ECTION PAQX 6.1 RESPONSIBILITY.............................................
6-1 6.2 ORGANIZATION i
6.2.1 OFFSITE AND ONSITE ORGANIZATIONS........
6-1 t
6.2.2 FACILITY STAFF.........................................
6-1 5
t 6.2.3 P.""..^__'"_^*_
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i 6.2.4 SHIFT TECHNICAL ADVISOR................................
6-5 i
6.3 FACILITY STAFF OUALIFICATION...............................
6-5 6.4 TRAINING...................................................
6-5 6.5 REVIEW AND AUDIT e
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 Operating License / Technical Specifications.............
6-7 t
6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)
Function...............................................
6-8 r
Composition............................................
6-8 i
(
1)eLeTed -.'lterrrrrr....
S *-
Meeting Frequency......................................
6-8 i
Quorum.................................................
6-8 L
Activities.............................................
6-9 Authority..............................................
6-10 Records................................................
6 10 t
i I
e
/
I BRUNSWICK - UNIT 1 IIV Amendment No.156 1
=..... -
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1 JFDEX 1
6@INISTRATIVE CONTROLS i
SECTION p2Hg 6.5 REVIEW AND AUDIT (Continued)d S2Cno 6.5.4 NUCLEAR ASSESSMENT "" An=" INDEPENDENT REVIEW PROGRAM l
Function................................................
6-10 l
Organization.............................................
6-10 Review..................................................
6-11 Records.................................................
6-12 Se c770 0 6.5.5 NUCLEAR ASSESSMENT 99HtR9fBNr AUDIT PROGRAM l
I Fr rti=................................................
6-13 It aM d h =
6 13 Ddd J,
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6,14 r.. ~ a.,.
6-14
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"^rr:r:1...............................................
6-14 i
6.5.6
. ON-AND-AUDPP-P.,~_ _
6-15
_. _. - _. ~.....
?
I 6.6 REPORTABLE EVENT ACTJQH....................................
6-15 i
a g
SirErr tm1T vIOurION.....................................
6-15 6.B PROCEDURES AND PROGRAMS....................................
6-16 l
r 6.9 REPORTING REOUIREMENTS Routine
- Reports........................................
6-17 Startup Reports.........................................
6-17 5
Annual Reports..........................................
6-18 Personnel Exposure and Monitoring Report................
6-18 L
Annual Radiological Environmental Operating Report......
6-19 t
Semiannual Radioactive Effluent Release Report..........
6-20 Monthly Operating Reports................................
6-21 Speclal Reports.........................................
6-22
[
Core Operating Limits Report............................
6-22 6
7 t
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BRUNSWICK - UNIT 1 XV Amendment No.156 i
t
ADMINISTRATIVE CONTROLS 6.2.3 --PROXCT ASSESSME#T-4PA+- De Le7ec N11NCTION 6.2.3.1 PA Group Unit shall function to examine facility operating characterist NRC issues. industry advisories, and other sources which may indicate areas fo roving facility safety.
RESPONSIBILITIES 6.2.3.2 The PA Group Unit shall be onsible for maintaining surveillance of facility activities to provide indep nt verification
- that these activities are performed correctly and that n errors are reduced as much as practical.
AUTHORITY 6.2.3.3 The PA Group Unit shall make detailed recomendations for ised procedures, equipment modifications. or other means of improving facill safety to the Manager - Nuclear Assessment Department.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.
6.3 FACILITY STAFF OUALIFICATION 6.3.1 Each member of the facility staff shall meet or exce for comparable positions"9d the minimum qualifications of ANSI N18.1-1971
. except for (1) the Manager - Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8. September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant during transients and accidents.
6.4 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 exceed the requirements and recomendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
Not responsible for sign-off function.
(a)
The requirement for the Manager - Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13. 1991.
BRUNSWICK - UNIT 1 6-5 Amendment No. 169
I ADMINISTRATIVE CONTROLS l
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 6.5.2.6 The safety evaluation prepared in accordance with Specification 6.5.2.1.c above shall include a written determination, with, basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.
6.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical 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 shall include a written preliminary determination, with basis, of whether or not the proposed Operating License / Technical Specification charge (s) is a change in the facility as described in the safety analysis report.
6.5.2.9 Following the nuclear safety review of ti.e safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6 5.2.1.e above and the associated proposed action, the request shall be:
a.
Reviewed by the Plant Nuclear Safety Committes in accordance with Specification 6.5.3.8.
Sec. tic 4 b.
Reviewed by the Nuclear Assessment Ocp rt=ca; 2c; tion in accordance l
with Specification 6.5.4.9.
i BRUNSWICK - UNIT 1 6-7 Amendment No.156
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 e
.3.3 The PNSC shall be composed of the:
Chairman General Manager - Brunswick Plant
- l ember:
Manager - Technical Support ber:
Manager - Operations Mem r:
Manager - Maintenance Membe
- Manager - Environmental & Radiat* n Control Member:
Technical Assistant to Plant C eral Manager Member:
Manager - QA/QC Member:
Manager - Regulatory Comp 1*ance ALTERNATES 6.5.3.4 All alternate members hall be appoi d in writing by the PNSC Chairman to serve on a temporary asis; how er, no more than two alternates shall participate as members at an one t' e.
6.5.3.5 All alternates, shall as a um, meet equivalent qualification criteria as specified for professi al-te ical personnel in Section 4.4 of ANSI N18.1-1971.
MEETING FREQUENCY 6.5.3.6 The PNSC shall eet at least once per cal r month and as convened by the PNSC Chairman his designated alternate.
QUORUM 6.5.3.7 The inimum quorum of the PNSC necessary for the perfo ance of the PNSC activ' tes of the Technical Specifications shall consist of (e PNSC Chairman r his designated alternate and four members including altd ates.
No mor than two alternates shall be counted toward meeting the minimu quorum req ' ement.
- Or designated alternate.
T>eLeTe - Reple tohh athchec}
ipsecT BRUNSWICK - UNIT 1 6-8 Amendment No. 138
1 l
INSEllT TO PAGE 6-8.
I re;viimsITION 6.5.3.3 The PNSC shall be composed of a Chairman and seven to nine members. The members shall be from the following functional areas:
Operations Maintenance Engineering Health Physics / Chemistry Itegulatory Affair.s Nuclear Assessment 6.5.3.4 The PNSC Chairman, alternate Chairmen, members, and alternate members shall be designated in writing by the Director - Site Operations. Members shall be individuals who are unit manager level or above from the site management organization. Alternate members shall, as a minimum, meet equivalent i
qualification criteria as specified in Section 4.4 of ANSI N18.1-1971 for professional-technical personnel.
OMORUM 6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of these Technical Specifications shall consist of the Chairman (or his designated alternate) and four members (including alternates).
6.5.3.6 No more than two alternates shall be counted toward meeting the quorum requirement or participate as voting members of the PNSC at any one time.
MEETING FitEOUENCY 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.
l 2238nti.717
ADMINISTRATTVE CONTROLS l-ACTIVITIES 6.5.3.8 The PNSC activities shall include the following:
a.
Review of all procedures required by Specification 6.8 and changes thereto (and any other procedures and changes thereto), any of which constitute an unreviewed safety question or. involve a change to the Technical Specifications. prior to implementation.
b.
Review of all proposed tests or experiments that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
c.
Review of all proposed modifications that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
d.
Review of all proposed changes to the Technical Specifications or Operating License, prior to implementation.
e.
Review of reports on violations of Technical Specifications including reports covering evaluation and recomendations to prevent recurrence to the Manager - Brunswick Nuclear I " cct and to the Mcnager clear Ancn; cat Ocpert; cat.
%T f.
Performance of special reviews. Investigations (or analyses), and reports thereon as requested by the Manager - Nuclear Assessment i
g.
P,eview of all REPORTABLE EVENTS.
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 Prejzt and the Men;ger cic;r Azcz =cnt Dep;rt:cnt.
Pt M 1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.
m.
Review of the Fire Protection Program and implementing procedures and the submittal of recomended changes to the Nuclear Assessment Dep;rtment.
T Sec. io 9 BRUNSWICK - UNIT 1 6-9 Amendment No. 169
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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the
- ":.qs - Brunswick Duclear Prcj ect =~* 9-Vice Presid^at - W Clair St-fic::.
The course determined by the G neral Manager - Brunswick Plant to be the most conservative shall be followed, p( g s
Vicc PrecidenT 85 CORDS 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 periormed under the rovisions of chese Technical Specifications. Copies shall be provided to the i
"-- ;:: - Brunswick Nuclear Pr: ject and the Manager - Nuclear Assessment Dep2 :;r.t.
PlotJT Sectio 9 3ec fora 6.5.4 NUCLEAR ASSESSMENT 0""J C r INDEPENDENT REVIEW PROGRAM FUNCTION Se.C iord 6.5.4.1 The Nuclear Assessment Gopacement shall function to provide l
independent review of significant plant changes, tests, and procedures; verify that REPORTABLE EVENTS are investigated in a timely manner and corrected in a j
manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day-to-day observer.
ug)p) [g Specj9(c OMAN1M1ON 6.5.4.2 The ndividuals assigned responsibility for independent reviews shall be pecified _n treh ic l disciplines. These individuals shall collectively have the experience and competence required to review activities in the following areas:
a, nuclear power plant operations b.
nuclear engineering c.
chemistry and radiochemistry d.
metallurgy e.
non-destructive testing f,
instrumentation and control g.
radiological safety h.
mechanical and electrical engineering i.
administrative controls BRUNSWICK - UNIT 1 6-10 Amendment No. 156
ADMINISTRATIVE CCNTROLS ORGANIZATION (Continued) j.
seismic and environmental k.
quality assurance practices 1.
Other appropriate fields aseoeieted-wi-th-eh: -iq"e "- scterietie: Of th; nuc1 ;r po u r plane.
%c$oH shall have ak ;;ch S 0tS l
h
..;i; 6.5.4.3 The Manager - Nuclear Assessment Dep;;;;;nt i
degree in an engineering or related field and, in addition, shall have a minimum of ten years related experience, of which a minimum of five years shall be in the operation and/or design of nuclear power plants, bochelor$
6.5.4.4 The independent safety review program reviewers shall have ak ars"-ic 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 Nuclear Assessment
> C:partant, competent individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing Jndependent reviews and investigations. Ee%ce n'$$s 6,$8.6 a'fYkcbb )
GCGIo Q 6.5.4.6
- m. a u m w ih;;; 'ad4"4d"als. Qualified as discussed in 6.5.4.4 above, shall review each item submiMILUDder thg recuirements
- Cactic fF' 9 v
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.
SeciioLI 6.5.4.8 The Nuclear Assessment C;;;..;nt independent safety review program l
ohall be conducted in accordance with written, approved procedures.
bef.nte dTh Heg 6,5,4.(l-12 @luheh 6.5.
, Nuclear Assessment Department shall perform reviews of the l
following:
a.
The safety eva tions for 1) changes to procedures required by Specification 6.8, modifications of equipment or systems, and
- 3) tests or experiment hat constitute a change to the safety analysis report to verify such actions did not constitute an unreviewed safety question or i lve a change to the Technical Specifications.
Implementation may ceed prior to completion of this review.
b.
Proposed changes to procedures required by Speci ation 6.8, and proposed modifications that constitute an unreviewed ety question as defined in 10 CFR 50.29 or a change to the Technical Specifications, prior to implementation.
BRUNSWICK - UNIT 1 6-11 Amendment No. 156
INSEllT TO PAGE 6-11.
6.5.4.6 The documents submitted under 6.5.4.9 shall be reviewed by individuals meeting the requirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines are encompassed. Multiple reviews will be conducted on documents where required to meet applicable disciplines of 6.5.4.2.
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i 2238nri.717
@ MINISTPATIVE COATROLS
\\EVIEW (Continued) he h (o, 6. 4,f[ - f 2 Q N d d Proposed tests or experiments that involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation, d.
oposed changes to the Technical Specifications and Operating Li nse.
e.
Viola ens of applicable codes, regulations, orders, Technical Specifi ations, license requirements, and internal procedures or instruct. na having nuclear safety significance, f.
Significant perating abnormalities or deviations from normal and expected per ce of plant safety-related structures, systems, or components.
g.
Reportable events.
h.
Reports and minutes the PNSC.
i.
Any other matter involvi g safe operation of the nuclear power plant that the Manager - Nuclea Assessment Department deems appropriate for consideration or which is ferred to the Manager - Nuclear Assessment Department by the on-site op ating organization or other functional organizational units within Ca olina Pcwer & Light Company.
6.5.4.10 Review of items considered unde 6.5.4.9 (e) through (i) above shall include the results of any investigations de and the recommendations resulting from these investigations to prev t or reduce the probability of recurrence of the event.
RECORDS 6.5.4.11 Records of Nuclear Assessment Department.. views, including l
recommendations and concerns, shall be prepared and
'stributed as indicated below:
a.
Copies of documented reviews shall be retained in he Nuclear Assessment Department files.
b.
Recommendations and concerns shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Nucle
- Project, within 14 days of completion of the review.
c.
A summation of Nuclear Assessment Department's recommendatic and l
concerns shall be submitted to the Chairman / President; Execut e Vice President - Power Supply; Senior Vice President - Nuclear Gener tion; Vice President - Nuclear Services; Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, approprint at least once every two months.
s BRUNSWICK - UNIT 1 6-12 Amendment No.156
~.
INSERT TO PAGES 6-11 AND 6-12.
6.5.4.9 REVIEW t
The Nuclear Assessment Section shall perform reviews of the following:
Written safety evaluations of changes in the facility as described in the a.
St ety Analysis Report, changes in procedures as described in the Safety r
Analysis Report, and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). These reviews are to verify that such changes, tests, or experiments do not involve a change in the Technical Specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). These reviews may be conducted after appropriate management approval, and implementation may proceed prior to completion of the review.
b.
Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or experiments, any of which involve a change in the Technical Specifications or an unreviewed safety question pursuant to 10 CFR 50.59(a)(2) prior to implementation.
c.
Proposed changes to the Technical Specifications or this Operating License prior to implementation.
d.
Violations, deviations and reportable events, which require reporting to the NRC in writing, such as:
1.
violations of applicable codes, regulations, orders, technical specifications, license requirements or internal procedures or instructions having safety significance.
2.
significant operating abnormalities or deviations from normal or expected performance of plant safety-related structures, systems, or components, and 3.
REPORTABLE EVENTS as specified in 10 CFR 50.73.
Any other matter involving safe operation of the nuclear power plant that c.
the Manager - Nuclear Assessment Section, deems appropriate for consideration or which is referred to the Manager - Nuclear Assessment i
Section, by the on-site operating organization, Plant Nuclear Safety Committee (PNSC) or by other functional organizational units within CP&L.
223Snri.717
1 INSERT TO PAGES 6-11 AND 6-12.
RECORDS 6.5.4.10 Results of Nuclear Assessment Section independent safety reviews shall be documented and retained.
I 2238nri.717
e ADMINISTRATIVE COTTTROLS l
s Tcon Assessm v7 ec l
6.s.s NUCLEAR ASSESSMEITT tEP?_""-"'
""I"' PROGRAM h cTIon Replace euTire Ser7/oM 6.S.5 tviTh ctTTorkd 6.5.
.1 The Nuclear Assessment Department shall function to perfom audits of l
facil'ty activities specified in Specification 6.5.5.2.
AUDITS 6.5.5.2 Au ts of facility activities shall be perfomed by the Nuclear Assessment De rtment. These audits shall encompass:
a.
The confo ce of facility operation to provisions contained within the Technic Specifications and applicable license conditions at least once p 12 months.
b.
The training and aalifications of the entire facility staff at least once per 12 months c.
The results of action taken to correct deficiencies occurring in facility equipment, str' tures, systems, or methods of operation that affect nuclear safety at ast once per 6 months.
d.
The verification of complian and implementation of the requirements of the Quality Assurance Progr to meet the criteria of Appendix "B',
10 CFR 50, at least once per 24 nths.
e.
The Emergency Plan and implementing rocedures at least once per 12 months.
f.
The Security Plan and implementing proce res at least once per 12 months.
g.
The Facility Fire Protection Program and imple nting procedures at least once per 12 months.
h.
The radiological environmental monitoring program the results thereof at least once per 12 months.
i.
The OFFSITE DOSE CALCULATIONAL MANUAL and implementing p cedures at least once per 24 months.
j.
The PROCESS CONTROL PROGRAM and implementing procedures for p cessing and packaging of radioactive wastes at least once per 24 months.
BRUNSWICK - UNIT 1 6-13 Amendment No.156
i INSERT TO PAGE 6-13.
6.5.5 Nuclear Assessment Section Assessment Program 6.5.5.1 Assessments of facility activities shall be performed by the Nuclear Assessment Section. Assessments will be performance based and will be scheduled based on plant performance and importance to safety but at a frequency not to exceed 24 1
months. These assessments shall encompass:
a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.
b.
The performance, training and qualifications of the entire facility staff.
c.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
d.
The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix B,10 CFR 50.
c.
Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant.
f.
The Fire Protection Program and implementing procedures.
g.
The Radiological Environmental Monitoring Program and the results thereof.
h.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.
i.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.
6.5.5.2 Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable regulation. These assessments shall encompass:
a.
Emergency Preparedness (per 10 CFR 50.54(t))
b.
Security (per 10 CFR 50.54(p))
2238nri.717
ADMINISTRATIVE COITTROLS Rephe eOTire secTiog 65 5 to',th dTnded hUDITS (Continued)
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 I
ce per 12 months.
1.
Any ther area of facility operation considered appropriate by the Manag
- Nuclear Assessment Department.
l 6.5.5.3 Personne performing the audits shall have access to the plant operating records.
RECORDS e
6.5.5.4 Records of audit shall be prepared and retained.
6.5.5.5 Audit reports enc seed by 6.5.5.2 above shall be prepared, approved by the Manager - Nucl r Assessment Department, and forwarded to the l
Executive Vice President - Power upply; Senior Vice President - Nuclear Generation; Manager - Brunswick N lear Project; General Manager - Brunswick Plant; and others, as appropriate, thin 30 days after completion of the audit.
AUTHORITY 6.5.5.6 The Manager - Nuclear Assessment De artment shall be responsible for l
the following:
The administering of the Nuclear Assessme t Department Audit Program.
l a.
b.
The approval of the individual (s) selected t conduct audits.
l EERSotM L 6.5.5.7 Audit personnel shall be independent of the area a dited.
6.5.5.8 Selection of personnel for auditing assignments shall e based on experience or training that establishes that their qualification are commensurate with the complexity or special nature of the activiti e to be audited.
In selecting audit personnel, consideration shall be give to special abilities, specialized technical training, prior pertinent e
- rience, personal characteristics, and education.
6.5.5.9 Qualified outside consultants or other individuals independent fr those personnel directly involved in plant operation shall be used to augmen the audit teams when necessary.
BRUNSWICK - UNTT 1 6-14 Amendment No.156
i l
ADMTWISTRATIVE CONTROLS 5.5.'
OL""CID" ACC"'"I I"CPEC'"!O!? ?J" '"DIT ""^nT.M independent fire protection and loss prevention inspection and audit shall be d at least once per 12 months utilizing either qualified offsite licensee 1 or an outside fire protection firm.
6.5.6.2 An inspection and audit of the fire prote- -
d loss prevention program shall be perfonned by an outside qualified fire connu intervals no greater than 36 months.
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 reviewed by the Plant Nuclear Safety Committee - Brunswick Plant and shall be submitted to the Panager -
Nuclear Assessment 00partment and the Nanagee - Brunswick Nuclear Proyeet.
Sec* tion Yice-FreddenT FLaGT 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.
Vi Ce - fre% Pd b.
The NRC Operations Center shall be notified telephone as soon as possible and in all cases within one hour. The.".1.:ger - Brunswick Nuclear P eteet
"" 'eer ?.:::::::nt 00partment shall l
be notif ed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
PLo ot vice - PrtNeJt-c.
A Safety Limit Viol ion Report shall be prepared. The report shall be reviewed by the "-~' "- --
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.
ViC Prebc%T TheSafetyLimktVholationReportshallbesubmittedtothe d.
Commission, the hger - Brunswick Nuclear }rej :1, and the Manager -
Nuclear Assessment Department within 14 days' of the violation.
Sec.~ho n klctr$
BRUNSWICK - UNIT 1 6-15 Amendment No.156
1 ADMINISTRATIVE CONTROLS EECORDS RETENTION (Continued) k.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
1.
Records of the service lives of all hydraulic and mechanical snubbers referenced in Section 3.7.5 including the data at which the service f
life commences and associated installation and maintenance records.
m.
Records of analyses required by the radiological environmental i
monitoring program.
Records of Y%{ meetings of the PNSC,
'M
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- u... u.
.u.
C"-lity A r - r: lufft 0 :;:::, Ouzlity 1 : r122: Arfitir; "rit.
O.
Records op Iwdepqgde,# gg,y', egg 6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
6.12 HIGH RADIATION AREA r
6.12.1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203 (c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*.
Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
{
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
I b.
A radiation monitoring device which continuously integrates the radiation dose rato 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.
1 I
I
- Health Physica personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of I
their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.
I BRUNSWICK - UNIT 1 6-25 Amendment No.156
I ENCLOSURE 6 1
HRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NO. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR -62 l
REQUEST FOR LICENSE AMENDMENT PERFORMANCE-IIASED NUCLEAR ASSESSMENT PROGRAM MARKED-UP TECilNICAL SPECIFICATION PAGES - HSEP 2 t
1 i
l f
I f
6 i
f i
f 2238nri.717 E6-1
INDEX ADMINISTPATIVE CONTP,OLS 1
SECTION EAGE 6.1 PESPONSIBILITY.............................................
6-1 6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS.......................
6-1 6.2.2 FACILITY STAFF.........................................
6-1 6.2.3 "litOJr ASSESSMENT-4PAf-gy, r= =i=..........................
ne. pen. win tics.
%tet-heefty...........
0:
6.2.4 SHI FT TECHNI C7.'. ADVI SOR................................
65 L3 FACILITY STAFF OUAL7Fl. CATION...............................
6-5 6.4 TRAINING................................
6-5 6.S REVIEW AIO AUDIT 6.5.1 NUCLEAR SAFETY REVIEWERS...............................
6-6 6.5.2 SAFETY EVALUATIONS AND INDEPENDEITT REVIEW CONTROL Safety Evaluations.....................................
6-6 l
Procedures, Tests, and Experiments.....................
6 Modifications..........................................
6-7 Operating License / Technical Specifications.............
6-7 6 5.3 PIANT NUCLEAR SAFETY COMMITTEE (PNSC)
Function...............................................
6-8 Composition............................................
6-8 Alternates.
5-9 Meeting Frequency......................................
68 Quorum.................................................
6-8 Activities.............................................
6-9 Authority..............................................
6-10 Records................................................
6-10 i
I I
l BRUNSWICK - UNIT 2 XIV Amendment No.187 l
4
i INDRK LD_MTNISTRATIVE CCNTRQLS
(
i i
l SE.f.T.I.CEI PXd fj REVIEW AND AUDIT (Continued)
- Ec.c-n c4 6.5.4 NUCLEAR ASSESSMEN"r 42."?."'n'C:7 INDEPENDENT REVIEW PROGRAM l
Function................................................
6-10 Organization............................................
6-10 Review..................................................
6-11 Records.................................................
G-12 S ELtTIC O 6.5.5 NUCLEAR ASSESSMENT OCTJ '"n:/'T AUDIT PROGRAM l
rrmmc:cm...................
6-12 n.
I?eldTe c) arecre...............................................
6-14
?=therity.......................
6-14 T> ele 7ed r:r :m. 1...............................................
6-14 s
6.5.6 OffPSIDE AGENCY INSPECTION AND AUDIT P"OC"J2'.............
6-15 6.6 REPORTABLE EVENT ACTION....................................
6-15 6.7 SAFETT LIMIT VIOLATICE.....................................
6-15 6.8 PROCEDURES AND PPOGRAMS....................................
6-16 i.9 REPORTING REOUIREMENTS 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 ReleaLe Report..........
6-20 Monthly Operating Reports...............................
6-21 Special Reports.........................................
6-22 Core Operating Limits Report............................
6-22 SRUNSWICK - UNIT 2 XV Amendment No.187 I
ADMINXSTRATIVE CONTROLS 6.2.3 TROI CT ASSFSSMOU 'P^) del 8ed
.N NCTION 6.2.3.1 RPA Group Unit shall function to examine facility operating characteristics.
RC issues, industry advisories, and other sources which may indicate areas for roving facility safety.
RESPONSIBILITIES 6.2.3.2 The PA Group Unit shall be r nsible for maintaining surveillance of facility activities to provide independent sQfication*thattheseactivities are performed correctly and that human errors ar educed as much as practical.
AUTHORITY 6.2.3.3 The PA Group Unit shall make detailed recomendations for v sed procedures, equipment modifications, or other means of improving facil{it ty to the Manager - Nuclear Assessment Department.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.
6.3 FACILITY STAFF OUALIFICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable aositions*, except for (1) the Manager - Environmental & Radiation Control who s1all meet or exceed the qualifications of Regulatory Guide 1.8. September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design. and response and analysis of the plant during transients and accidents.
6.4 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 exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
Not responsible for sign-off function.
(a)
The requirement for the Manager - Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13. 1991.
BRUNSWICK - UNIT 2 6-5 Amendment No. 200
r SQMINISTRATIVE 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 t
Specifications.
6.5.2.5 Following the nuclear safety review, the procedures required by Specification 6.8, other procedures that affect nuclear safety, proposed tests or experiments, and changes thereto (other than editorial or typographical) which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or change to the Technical Specifications shall be approved prior to implementation by the General Manager - Brunswick Plant or his previously designated alternate.
MODIFICATIONS 6.5.2.6 The safety evaluation prepared in accordance with Specification 6.5.2.1.c above shall include a written determination, with basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.
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 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.
2 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 t
l a.
Reviewed by the Plant Nuclear Safety Conmittee in accordance with Specification 6.5.3.8.
Sectio,a b.
Reviewed by the Nuclear Assessment T -
-t Errt'-- in accordance l
l' with Specification 6.5.4.9.
i 1
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BRUNSWICK - UNIT 2 6-7 Amendment No. 187 I
l i
ADMINISTRATTIVE CONTROLS l
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 the:
Chairman:
General Manager - Brunswick Plant
- Member:
Manager - Technical Support g
. ember Manager - Operations
.ber:
Manager - Maintenance Mem r:
Manager - Environmental & Radi ion Control Menibert Technical Assistant to Plant eneral Manager Member Manager - QA/QC Member Manager - Regulatory Co iance ALTERNATES 6.5.3.4 All alternate membe shall be app nted in writing by the PNSC Chairman to serve on a temporar basis; ever, no more than two alternates shall participate as members at a on ime.
6.5.3.5 All alternates, shall as mt ' mum, meet equivalent qualification criteria as specified for profes tonal-t hnical personnel in Section 4.4 of ANSI N18.1-1971.
MEETING FREQUENCY 6.5.3.6 The PNSC sh 1 meet at least once per calen r month and as convened by the PNSC r, hair or his designated alternate.
QUORUM i
6.5.3.7 e minimum quorum of the PNSC necessary for the perfo nce of the PNSC a tvities of the Technical Specifications shall consist of t PNSC l
Chai n or his designated alternate and four members including alte ates. No mo than two alternates shall be counted toward meeting the minimum q rum equirement.
L
- Or designated alternate.
Detde. - Replace eth ccmcheJ Toser t ~
BRUNSWICK - UNIT 2 6-8 Amendment No. 170
INSERT TO PAGE 6-8.
COMPOSITION 6.5.3.3 The PNSC shall be composed of a Chairr.ian and seven to nine members. The members shall be from the following functional areas:
Operations Maintenance Engineering Health Physics / Chemistry Regulatory Affairs Nuclear Assessment 6.5.3.4 The PNSC Chairman, alternate Chairmen, members, and alternate members shall be designated in writing by the Director - Site Operations. Members shall be individuals who are unit manager level or above from the site management organization. Alternate members shall, as a minimum, meet equivalent qualification criteria as specified in Section 4.4 of ANSI N18.1-1971 for professional-technical personnel.
OUORUM 6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of these Technical Specifications shall consist of the Chairman (or his designated alternate) and four members (including alternates).
6.5.3.6 No more than two alternates shall be counted toward meeting the quorum requirement or participate as voting members of the PNSC at any one time.
MEETING FREOUENCY 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.
1 2238nri.717
ADMINISTRATIVE CONTROLS ACTIVITIES 6.5.3.8 The PNSC activities shall include the following:
a.
Review of all procedures required j 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 I
unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
c.
Review of all proposed modifications t' at constitute an unreviewed n
safety question or involve a change to the Technical Specifications.
Fior to implementation I
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 recomendations to 3revent recurrence to the Manager - Brunswick Nuclear Prefect :nd tc tic ".:n:ger Nuclear,t;::::ent Dep;rt=nt.
ThJt f.
Performance of special reviews. investigations (or analyses). ar,d reports thereon as requested by the Manager - Nuclear Assessment D
M-accmon g.
Review of all REPORTABLE EVENTS.
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.
P k.
Review of accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation.
recommendations and disposition of the crrr ative action to prevent recurrence and the forwarding of these.t, T to the Manager -
Brunswick Nuclear Pro"t :nd the ";n;ga - Aci:;r. A;;c :nnt Oepe rt.T,cnt.
Plan r
1.
Review of changes to the PROCESS CONTROL PROGRAM and the CFFSITE DOSE CALCULATION MANUAL.
l Review of the Fire Protection Program and implementing procedures and m.
the submittal of recommended changes to the Nuclear Assessment Dcp rt=cnt.
Sect;o9
' BRUNSWICK - UNIT 2 6-9 Amendment No. 200
ADMIWISTPATIVE CONTPOLS MIli2BlII 6.5.3.'9 If there is a disagreement between recommendations of a majority of the PNSC and the actions contemplated by the General Manager - Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Manages - Brunswick Nuclear P:g ect rd the '? ice Pre:id-at "ucleer Serficer.
j The course determined by the Ggneral Manager - Brunswick Plant to be the most conservative shall be followed.\\ g g
[ Vke - nestclect 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 Managee - Brunswick Nuclear Prej: t and the Manager - Nuclear Assessment Dep:zt r.t.
PLo NT SecTion g7;og 6.5.4 NUCLEAR ASSESSMENT '"""."MM INDEPEEJNT REVIEW PROGRAM l
BBCTION Se.citou 6.5.4.1 The Nuclear Assessment Depa*tment shall function to provide l
independent review of significant plant changes, tests, and procedures; verify that REPORTABLE EVENTS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day-to-day observer.
g*;Qye ec.i pic ORGANIZATION 6.5.4.2 The individuals assigned responsibility for independent reviews shall be :p::i'ird i-ter'.ie:1 disciplines. These individuals shall collectively have the experience and competence required to review activities in the following areas:
a.
nuclear power plant operations b.
nuclear engineering c.
chemistry and radiochemistry d.
metallurgy e.
non-destructive testing f.
instrumentation and control g.
radiological safety h.
mechanical and electrical engineering i.
administrative controls BRUNSWICK - UNIT 2 6-10 Amendment No. 187
-4
-.m y
,m.-.-
--.---y
AQl4INTSTRATIVE CO E %S ORGANIZATION (Cor ta 'ted) a j.
seismic and enytronmental k.
quality assurance practices 1.
Other appropriate fields recrriste rith the " '~"r ' " rrterirti r :f d
th; nuc1;;r p = p1;;t.
SR.diod bh bek$
6.5.4.3 The Manager - Nuclear Assessment repir - t shallhaveaf l
degree in an engineering or related field and, in addition, shall have a minimum of ten years related experience, of which a minimum of five yuars shall be in the operation and/or design of nuclear power plants.
bo cMelorG
.5.4.4 The independent safety review program reviewers shall have hp em*e 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 Nuclear Assessment se p;....a n t, competent individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing inde
. Scc % pendent reviews and investigations. Replace. kATk 9etu b.5.4.ta bMeA D 0
6. 5. e. t>
m.
1-ee; thrrr 4 "d 4 v4 dna l s, cualified as discussed in 6.5.4.4 abcve shall review each item anh=4tted under the recuiremem.s v - 0.;;ir f C A 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.
Sec. Tion 6.5.4.8 The Naclear Assessment Depas4 ment independent safety review program l
shall be conducted in accordance with written, approved procedures.
Rep 6re ehh b 6.s.4.ct -12 cd h kur Nuclear Assessment Department shall perform reviews of the l
6.5.4.9 i
following:
a.
The safety eval ons for 1) changes to procedures required by Specification 6.8, edifications of equipment or systems, and
- 3) tests or experiments constitute a change to the safety analysis report to verify tha uch actions did not constitute an unreviewed safety question or iny a change to the Technical Specifications.
Implementation may pr ed prior to completion of this review, b.
Proposed changes to procedures required by Specific n 6.8, and proposed modifications that constitute an unreviewed sa question as defined in 10 CFR 50.59 or a change to the Technical Spacifications, prior to implementation.
I BRUNSWICK - UNIT :
6-11 Amendment No.187
1 i
INSERT TO PAGE 6-11.
6.5.4.6 The documents submitted under 6.5.4.9 shall be reviewed by individuals meeting the requirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines are encompassed. Multiple reviews will be conducted on documents where l
}
required to meet applicable disciplines of 6.5.4.2.
l l
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l 2238nri.717
____ - ___--____._ - ___ ____________ -____ - - ________-___-____ -._____ __ - _ w
l ADMINISTRATIVE CONTROLS kEVIEW (Continued) {
gg,y,g g gM Proposed tests or experiments that involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation.
d.
oposed changes to the Technical Specifications and Operating Li.nse.
e.
Viola ons of applicable codes, regulations, orders, Technical Specif ations, license requirements, and internal procedures or instruct na having nuclear safety significance.
f.
Significant perating abnormalities or deviations from normal and expected per rmance of plan
- safety-related structures, systems, or components.
g.
Reportable events.
h.
Reports and minutes the PNSC.
1.
Any other matter involv g safe operation of the nuclear power plant that the Manager - Nuclea Assessment Department deems appropriate for consideration or which is ferred to the Manager - Nuclear Assessment Department by the on-site op rating organization or other functional organizational units within C olina Power & Light Company.
6.5.4.10 Review of items considered und 6.5.4.9 (e) through (i) above shall include the results of any investigations de and the recommendations resulting from these investigations to prev t or reduce the probability of recurrence of the event.
RECORDS 6.5.4.11 Records of Nuclear Assessment Department views, including l
recommendations and concerns, shall be prepared and
'stributed as indicated below:
a.
Copies of documented reviews shall be retained in he Nuclear Assessment Department files.
b.
Reconmendations and concerns shall be submitted to the General Manager - Brunswick Plant and Manager - Brunswick Nucle
- Project, within 14 days of completion of the review.
c.
A summation of Nuclear Assessment Department's recommendatic s and l
concerns shall be submitted to the Chairman / President; Execut e Vice President Power Supply; Senior Vice President Nuclear Gener tion; Vice President - Nuclear Services; Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, appropriat at least once every two months.
BRUNSWICK - UNIT 2 6-12 Amendment No. 187
I INSERT TO PAGES 6-11 AND 6-12.
t 6.5.4,9 REVIEW The Nuclear Assessment Section shall perform reviews of the following:
a.
Written safety evaluations of changes in the facility as described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report, and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). These reviews are to verify that such changes, tests, or experiments do not involve a change in the Technical Specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). These reviews may be conducted after appropriate management approval, and implementation may proceed prior to completion of the review, b.
Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or experiments, any of which involve a change in the Technical Specifications or an unreviewed safety question pursuant to 10 CFR 50.59(a)(2) prior to implementation.
c.
Proposed changes to the Technical Specifications or this Operating License prior to implementation.
4 d.
Violations, deviations and reportable events, which require reporting to the NRC in writing, such as:
1.
violations of applicable codes, regulations, orders, technical specifications, license requirements or internal procedures or instructions having safety significance.
2.
significant operating abnormalities or deviations from normal or expected performance of plant safety-related structures, systems, or components, and 3.
REPORTABLE EVENTS as specified in 10 CFR 50.73.
e.
Any other matter involving safe operation of the nuclear pcwer plant that the Manager - Nuclear Assessment Section, deems appropriate for consideration or which is referred to the Manager - Nuclear Assessment Section by the on-site operating organization, Plant Nuclear Safety Committee (PNSC) or by other functional organizational units within CP&L.
2238nri.717
r INSERT TO PAGES 6-11 AND 6-12.
EECORDS 6.5.4.10 Results of Nuclear Assessment Section independent safety reviews shall be documented and retained.
A
+
i I
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2238nri.717
ADM2f7TSTPATIVE CORikOLS such AssessmeJT 6.5.5 NUCLEAR ASSESSMENT 0C = 2 2 5 ?."" O PROGRAM l
Replace euhseJtoo 65 5-d% araded 6.5.
.1 The Nuclear Assessment Department shall function to perform audits of l
facil *y activities specified in Specificatien 6.5.5.2.
AUDITS 6.5.5.2 Aud s of facility activities shall be performed by the Nuclear Assessment Dep tment. These audits shall encompass:
a.
The confo ce of facility operation to provisions contained within the Technic Specifications and applicable license conditions at least once pe 12 months, b.
The training and alifications of the entire facility staff at least once per 12 mon *.hs.
c.
The results of actions aken to correct deficiencies occurring in facility equipment, stru ures, systems, or methods of operation that affect nuclear safety at 1 st once per 6 months.
d.
The verification of compliane and implementation of the requirements of the Quality Assurance Progr to meet the criteria of Appendix "B",
10 CFR 50, at least once per 24 m ths.
e.
The Emergency Plan and implementing ocedures at least.once per 12
- months, f.
The Security Plan and implementing procedu s at least once per 12 months.
g.
The Facility Fire Protection Program and implem ting procedures at least once per 12 months, h.
The radiological environmental monitoring program an the results thereof at least once per 12 months.
i.
The OFFSITE DOSE CALCULATIONAL MAN A.tud implementing pro dures at least once per 24 months.
j.
The PROCESS CONTROL PROGRAM and implementing procedures for pro ssing and packaging of radioactive wastes at least once per 24 months.
BRUNSWICK - UNIT 2 6-13 Amendment No. 187 l
l
.~
.~- -
T INSERT TO PAGE 6-13..
6.5.5 Nuclear Assessment Section Assessment Program 6.5.5.1 Assessments of facility activities shall be performed by the Nuclear Assessment Section. Assessments will be performance based and will be scheduled based on plant performance and importance to safety but at a frequency not to exceed 24 months. These assessments shall encompass:
a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.
b.
The performance, training and qualifications of the entire facility staff.
c.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
d.
The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix B,10 CFR 50.
c.
Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant, f.
The Fire Protection Program and implementing procedures.
g.
The Radiological Environmental Monitoring Program and the results thereof.
h.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.
i.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.
6.5.5.2 Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable regulation. These assessments shall encompass:
a.
Emergency Preparedness (per 10 CFR 50.54(t))
b.
Security (per 10 CFR 50.54(p))
223Snri.717 l
r ADMINISTRATIVE CONTROLS Rep {acg efk ghe lod ().S Y Ed tb CJbCb UDITS (Continued)
The performance of activities required.by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.22, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least ce per 12 months.
1.
Any ther area of facility operation considered appropriate by the Manag
- Nuclear Assessment Department.
l 6.5.5.3 Personn performing the audits shall have access to the plant operating records.
RECORDS 6.5.5.4 Records of audi shall be prepared and retained.
6.5.5.5 Audit reports enc, used by 6.5.5.2 above shall be prepared, approved by the Manager Nuc ar Assessment Department, and forwarded to the l
Executive Vice President - Powe Supply; Senior Vice President - Nuclear Generation; Manager - Brunswick h lear Project; General Manager - Brunswick Plant; and others, as appropriate, ithin 30 days after completion of the audit.
AUTHORITI 6.5.5.6 The Manager - Nuclear Assessment D artment shall be responsible for the following:
a.
The administering of the Nuclear Assessm t Department Audit Program.
l b.
The approval of the individual (s) selected conduct audits.
l PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area dited.
6.5.5.8 Selection of personnel for auditing assignments shal e based on experience or training that establishes that their qualificatic are commensurate with the complexity or special nature of the activit
's to be audited.
In selecting audit personnel, consideration shall be give to special abilities, specialized technical training, prior pertinent e ~ erience, personal characteristics, and education.
6.5.5.9 Qualified outside consultants or other individuals independent f m
those personnel directly involved in plant operation shall be used to augme the audit teams when necessary.
4,
BRUNSWICK - UNIT 2 6-14 Amendment No. 187
r ADMINISTRATIVE CONTROLS
'5C OUTGIDE-AGENCY-INSPEGT-IC" ?J'O ?."DIT ""OC"15 An independent fire protection and loss prevention inspection and audit shall ed at least once per 12 months utilizing either qualified offsite licensee ersonna or an outside fire protection firm.
6.5.6.2 An inspection and audit of the fire protection rever. tion program shall be performed by an outside qualified fire consultzmt a h intervals no greater than 36 onrha.
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 rubmitted pursuant to 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 -
Nuclear Assessment Dep :t=cne and the Manager - Brunswick Nuclear Project.
SedT/od PhtdT 6.7 SATETY LIMIT VIOLATIQ1{
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 SHDTDOWN within two
- hours, VICe-fresic}ed b.
The NRC Operations Center shall be notified telephone as coon as l
possible and in all cases within one hour. The Managee - Brunswick Nuclear " reject a d
"" ' - r Ar r e e r c a t Dep r--a t shall l
be noti ed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Plo4T 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 siihm4 tted to the Commission, the,"-a-er - Brunswick Nuclear "rej;;t, and the Manager -
Nuclear Asse sent Ccpe a.6 % within 14 day of the violation.
Yice - fm Med[ ' See io tJ ObcWY l
i i
BRUNSWICK - UNIT 2 6-15 Amendment No.187 i
'444Elll {~ "
BEMIUISTRATIVE CONTPOLS I
PECORDS RETENTION (Continued) k.
Records of reviews performed for changes made to procecures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
1.
Records of the service lives of all hydraulic and mechanical snubbers referenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance records.
m.
Records of analyses required by the radiological environmental monitoring program.
n.
Records of (i} meetings of the PNSC, 42) m:-:tir ef the previru: Off-ait: ::rier erg =i:: tion, th: C:q =y "u:1::: Caf ety "~'--' tte: W SC),
G) the-independert revier perf = d hy the "ucles: ?. : eement Depastment, and 't) the indeptad: t :: vier: performed by th: Cerperst:
Whesu - - - ^ " '" * " -~- - -- 0 -lity ? r = : ?diting M t.
O. Renards 4 ~Independost' Ruvuus 6.11 RADIATION PROPTECTION PROGPJJ4 6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203 (c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be j
controlled by requiring issuance of a Ptdiation Work Permit (RWP)*,
Any 1
individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates'the radiation dose rate in the area and alarms when a preset integrated i
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 i
i radiation protection procedures for entry into nigh radiation areas.
4 BRUNSWICK - UNIT 2 6-25 Amendment No. 187 I
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