ML20077D247
| ML20077D247 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/17/1991 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20077D245 | List: |
| References | |
| NUDOCS 9105290222 | |
| Download: ML20077D247 (26) | |
Text
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ENCLOSURF 1 BRUNSVICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 AND 50-324 OPERATINC LICENSES DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CHANCES TECHNICAL SPECIEICATION PACES - UNIT 1 l
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9105290222 910517 I
UR ADOCK 05003. 4 (1134cun
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INDEX ADdINISTRATIVE CONTROLS SECTION PACE 6.1 R E S P ON S I B I L I TY.............................................
6-1 6.2 ORGANIZATION 6.2.1 0FFSITE AND ONSITE ORGANIZATIONS.......................
6-1 6.2.2 FA C I LI TY S T A FF.........................................
6-1 6.2.3 PROJECT ASSESSMENT (PA)-
l-Function.............................................
6-5 Responsibilities.......................................
6-5 Authority...........................
6-5 6.2.4 Sil1FT TECllNICAL ADVIS0R................................
6-5 6.3 FACI LI TY - STAFF QUA LI FI CATI ON...............................
6-5 6.4-TRAINING...................................................
6-5 6.5 REVIEW AND AUDIT 6.5.1 NU CL EAR S A FETY R EVI EWE RS...............................
6-6 6.5.2 SAFETY EVALUATIONS AND INDE?ENDENT REVIEW CONTROL S a f e t y E va l u a t i o n s.....................................
6-6 i
Procedures, Tests, and E.periments.....................
6-7 Modifications..........................................
6-7 Operat ing License /Technica, ipecifications.............
6-7 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)
-Function...............................................
6-8 Composition............................................
6-8
(
Alternates.............................................
6-8 1
l-Meeting Prequency......................................
6-8 Quorum.................................................
6-8 Activities.............................................
6-9 l-l Authority..............................................
6-10
-Records................................................
6-10
' BRUNSWICK - UNIT 1 XIV Amendment No.
INDEX ADMINISTRATIVE CONTROLS LSECTION PACE 6.5 REVIEW AND AUDIT (Continued) 6.5.4 NUCLEAR I.SSESSMENT DEPARTHENT INDEPENDENT REVIEW PROGRAM Function................................................
6-10 Organization............................................
6-10 Review..................................................
6-11 Records.................................................
6-12 6.5.5 NUCLEAR ASSESSMENT DEPARTHENT AUDIT PROCRAM Function................................................
6-13 Audits..................................................
6-13 Records.................................................
6-14 Authority............................................
6 -1/;
Personnel...............................................
6-14 6.5.6 OUTSIDE /CENCY INSPECTION AND AUDIT PROGRAM.............
6-15 6.6 REPORTABLE EVEF~ ACT10N....................................
6-15 6.7 S A F ETY L 1 H I T V 10 LAT I ON..................................... 15 6.8
-PROCEDUR8S AND PR0 CRAMS....................................
6-16 6.9 REPORTING REQUIREMENTS I
Routine Reports........................................
6-17, l
Startup Reports.........................................
6-17 i
[
Annual Reports..........................................
6-18 Personnel Exposure-and Honitoring Report................_ 18-l Annual Radiological Environmental Operating Report......
6-19
. Semiant.ual Radioact ive Ef fl uent Rel ea se Repor t..........
6-20 Hunthly Operating Reports...............................
6-21 Special Reports.........................................
6-22 Core Operating Limits Report............................
6-22 BRUNSWICK - UNIT 1 XV Amendment No.
, +. ~,
4 4
- ADMINISTRATIVE CONTROLS 6.2.3 PROJECT ASSESSMENT (PA)
FUNCTION 6.2.3.1 The pA Croup Unit shall f unction to examinc f acility operat ing characteristics, NRC issues, industry advisories, and other sources which may indicate areas for improving f acility safety.
RESPONSIBILITIES l
6.2.3.2 The PA Croup Unit shall be responsible for maintaining surveillance of f acility activities to provide independent verification
- that these activities are performed correctly and that hunon errors are reduced as much as practical.
I AUTHORITY 6.2.3.3 The PA Croup Unit shall make detailed recommendations for revised
[
nrocedures, equipment modifications, or other means of improving f acility safety to the Manager - Nuclear Assessment Department.
6.2.4 SHIFT TECHNICAL ADVISOR j
1 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.
I I
6.3 FACILITY STAFF QUALIFICATION 6.3.1 Each member of the facility staff shall meet orexcggtheminimum 1
qualifications of ANSI N18.1-1971 for comparable positions except for (1) the Manager - Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shif t Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, I
and response and analysis of the plant during transients and accidents.
6.4 TRAINING 6.4.1 A ret raining 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.
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 l
requirements of Section 27 of the NFPA Code-1975.
l
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i l
- Not responsible for sign-off function.
l (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 (the date of amendment issuance).
BRUNSWICK - UNIT 1 6-5 Amendment No.
-.______m..
t ADMINISTRATIVE CONTROLS PROCEDURES, TESTS, AND EXPERlHENTS 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 determinat. ion, with basis, of whether or not the procedures, proposed tests and experiment s, and changes thereto constitute an unreviewed safety question as defined in 10 CFk 50.59, or whether they involve a change to the Technicai Specifications.
6.5.2.5 Following the nuclear safety review, the procedures requireu ay
- Specification 6.8, other procedures that af fect 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 Hanager - Brunswick Plant or his previously designated alternate.
MODIFICATIONS 6.5.2.6 The safety evaluation prepared in accordance vitF Specification 6.5.2.1.c above shall include a written.etermination, 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 Manaper - Brunswick Plant or his previously designated alternate.
OPERATING LICENSE /TECilNICAL SPECIFICATIONS 6.5.2.8 The saf ety 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 l
Operating License / Technical Specification change (s) is a chane. in the facility as described in the-safety analysis report.
6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be:
a.
Deviewed by the Plant Nuclear Safety Committee in accordance with Speci fication 6.5.3.8.
b.
Reviewed by the Nuclear Assessment Department'Section in accordance with Specification 6.5.4.9.
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BRUNSWICK - UNIT 1 6-7 Amendment No.
ADMINISTRATIVE CONTROLS ACTIVITIES 6.5.3.8 The PNSC activities shall include the f ollowing:
Resiew of all procedures required by Specification 6.8 and changes a.
thereto (and any other procedures and changes thereto), any of which consti.ute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
b.
Review of all proposed tests or experiments that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
c.
Review of all proposed modifications that constitute an unreviewed safety question or involve a change to the Technical Specifications, prior to implementation.
d.
Review of all proposed changes to the Technical Specifications or Operating License, prior to implementation, e.
Review of reports on violations of Technical Specifications including reports covering evaluation and recommendations to prevent recurrence to the Manager - Brunswick Nuclear Project and to the Manager -
Nuclear Assessment De pa rt me nt,
f.
- Performance of special reviews, investigations (or analyses), and reports thereon as requested by t he Manager - Nuclear Assessment Department.
g.
Review of all REPORTABLE EVENTS.
h.
Review of facility operations to detect potential nuclear safety hazards.
i.
Annual review of the Security Plan.
j.
Annual _ review of the Emergency Plan.
k.
Review of accidental, unplanned, or uncontrolled radioactive release L
including the preparation of repor t s covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Manager -
Brunswick Nuclear Project and the Manager - Nuclear Assessment j ~
Department.
l 1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.
l' BRUNSWICK - UNIT 1 6-9 Amendment No.
i ADMINISTRATIVE CONTROLS AUTil0R ITi 6.5.3.9 If there is a disagreement between recommendations of a majority of the o
L
_PNSC and the actions contemplated by the General Manager - Brunswick Plant, the l
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 Hanager - 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 Hanager - Brunswick Nuclear Project and the Hanager - Nuclear Assessment l
Department.
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6.5.4 NUCLEAR ASSESSMENT DEPARTMENT INDEPENDENT REVIEW PROGRAM
. FUNCTION 6.5.4.1 The Nuclear Assessment De pa rt me nt shall function to provide independent l
L review of significant pl ant. changes, test s, and proceduresi veri fy that REPORTABLE l
EVENTS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such eventri 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 E
l expertence and competence required to review activities in the following areas:
l 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 l
h.
mechanical and electrical engineering J
i.
administrative controls BRUNSWICK - UNIT 1 6-10 Amendment No.
l N
l ADMINISTRATIVE CONTROLS i
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 - Nuclear Assessment De pa rt ment 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 Nuclear Assessment
. Department, competent individuals from other Carolina Power & Light' Company I
organizations or outside consultants shall be utilized in performing independent reviews and investigations.
6.5.4.6 AL least three individuals, qualified as discussed in 6.5.4.4 above, shall review each item submitted under the reouirements 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 tLe 1
activity under review.
6.5.4.8 The Nuclear Assessment De pa rtment independent safety review program shall be conducted in accordance with written, approved procedures.
REVI EW
-6.5.4.9 The Nuclear Assessment Department 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 cf 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 CPR-50.59 or a change to the Technical-Specifications, prior to implementation.
BRUNSWICK - UNIT 1 6-11 Amendment No.
i L
ADMINISTRATIVE CONTROLS REVIEW (Continued) c.
Proposed test s or experiments that involve an unrevicwed safety question as defined in 10 CFR 50.59 or a rhange to the Technical Specifications, prior to implementation, d.
Proposed changes to the Technical Specifications and Operat ing License.
e.
Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, and internal procedures or instructions having nuclear safety significance, f.
- Signi ficant operating abnormalities or deviations f rom normal and expected performance of plant safety-related structures, syst ems, or components.
g.
Reportable events.
h.
Reports and minutes of the PNSC.
i.
Any other maller involving safe operation of the nuclear power plant that the Manager - Nuclear Assessment Department deems appropriate for consideration or which is referred to the Manager - Nuclear Assessment Department by the on-site operating organization or other functional organizational units within Carolina Power & Light Company.
6.5.4.10 Review of items considered under 6.5.4.9(e) through (i) above shall include the results of any investigations made and the recommendations resulting frora these investigations to prevent or reduce the probability of
- recurrence of the event.
RECORDS 6.5.4.11 Records of Nuclear Assessment. Department reviews, including recommendations and concerns, shall be prepared and distributed as indicated belows a.
Copies of documented reviews shall be retained in the Nuclear Assessment Department files.
b.
Recommendations and concerns shall be submitted to the General Manager - Brunswick Piant and Manager - Brunswick Nuclear Project, within 14 days of completion of the review.
A summation of Nuclear Assessment Department's recommendations and c.
concerns shall be submitted to the Chairman / President; Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation; Vice President - Nuclear Services; Hanager - Brunswick Nuclear Project; Ceneral Manager - Brunswick Plant; and others, appropriate, at least once every two months.
BRUNSWICK - UNIT 1 6-12 Amendment No.
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ADMINISTRATIVE CONTROLS J6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDIT PROCRAM FUNCT'! ON -
6.5.5.1 The Nuclear Assessment De pa rt ment shall function to perform audits of farility activities specified in Specification o.5.5.2.
AUDITS 6.5.5.2 Audits of f acility activities shall be performed by the Nuc. lear Assessment Department. The;e 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.
Tha training and qualitications of the entire facility staf f at least once per 12 months.
c.
The results of actions taken to correct deficiencies occurring in 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.
j e.
The Emergency Plan and implementing procedures at least once per 12 i
months.
f.
The Security Plan and implementing procedures at least once per 12 months.
g.
The Facility Fire Protection Program and implementing procedures _ at _
least once per 12 months.
h.
The radiological environmental monitoring program and the results l
thereof-at least once per 12 months.
i.
The OFFSITE DOSE CALCULATIONAL HANUAL and implementing procedures at least once per 24 months.
l i-j.
The PROCESS CONTROL PROCRAM and implementing procedures f or L
processing and packaging of radioactive wastes at least once per 24 montho.
BRUNSWICK - UNIT 1 6-13 Amendment No.
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, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least once per 12 months.
1.
Any other area of facility operation considered appropriate by the Manager - Nuclear Assessment De pa r t me nt.
6.5.5.3 Personnel performing the audits shall have access to the plant operating records.
RECORDS 6.5.5.4 Records of audits shall be prepared and retained.
6.5.5.5 Audit reports encompassed by 6.5.5.2 above shall be prepared, approved by the Manager - Nuclear Assestment Department, and forwarded to the Executive Vice President - Power Supply; Senior Vice President - Nuclear Gene ra t i on Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, as appropriate, within 30 days af ter completion of the audit.
AUTil0RITY 6.5.5.6 The Manager - Nuclear Assessment Department shall be responsible for the following:
a.
The administering of the Nuclear Assessment Department Audit Program.
b.
The approval of the individual (s) selected to conduct audits.
l PERSONNEL l
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6.5.5.7 Audit personnel shall be independent of the area audited, o.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 o special nature of the activities to be aud'ted.
In selecting audit personnel, consideration shall be given to I
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.
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BRUNSWICK - UNIT 1 6-14 Amendment No.
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 audit shall be performed at least once per 12 months utilizing either qualif ied of f site 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 EVENTS:
a.
The Commission shall be notified and a report submitted pursuant to the requirement s of Section 50.73 t o 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 De pa rt ment and the Manager - Brunswick Nuclear Project.
6.7 SAFETY LIMIT VIOI.ATION 6.7.1 The following actions shall be taken in the event a Sat ely Limit is violated:
a.
The facility shall be placed in at leact 110T 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 - Nuclear Assessment De pa r t me r.t shall be noti fied within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
c.
A Saf et y Limit Viol at ion Report shall be prepared. The report shall be reviewed by the General Manager - Brunswick Plant.
This report shall describe (1) applicable circumstances preceding t he violation, (2) effects of the violation upon facility components, systems, or structures, and (3) corrective actinn taken to prevent recurrence.
d.
The Safety Limit Violation Report shall be sub:aitted to the Commission, the Manager - 3runswick Nuclear Project, and the Manager -
Nuclear Assessment Department within 14 N ys of the violation.
BRUNSWICK - HNIT 1 6-15 Amendment No.
ADMINISTRATIVE CONTROLS RECORDS 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 ref erenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance records.
m.
Records of analyses required by the radiological environmental monitoring program.
n.
Records of (1) meetiigs of the PNSC, (2) meetings of the previous of f-site review organizat ion, the Company Nuclear Safet y Commit tee (CNSC), (3) the independent reviews perf ormed by the Nuclear Assessment Departmen., and (4) the independent reviews performed by the Corporate Qualit y Assurance Audit Program, Quality Assurance Auditing Unit.
6.11 RADI ATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be p re pa red consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
l 6.12 111Cl! R ADI ATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" requiired by paragraph 20.203(c)(2) of 10 CFR 20, each high radiat;on area in which tite 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 continuor-ly indicates the radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.
Entry into such areas with this monitoring device may be made af ter the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
- Ilealth Physics personnel or personnel escorted by llealth Physics personnel l
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.
l BRUNSWICK - UNIT 1 6-25 Amendment No.
l
ENCLOSURE 2 BRUNSWICK STEAM E12CTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 AND 50,324 OPERATING LICENSES DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT ORGANIZATION CHANGES TECHNICAL SPECIFICATION PACE 3 - UNIT 1 1
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I (1134GLU)
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INDEX ADMINISTRATIVE CONTROLS SECTION PACE 6.1 R E S PON S I B I LI TY.............................................
6-1 6.2 ORCANIZATION 6.2.1 0FFSITE AND ONSITE ORGANIZATIONS.......................
6-1 6.2.2 FACILITY STAFF.........................................
6-1 6.2.3 PROJECT ASSESSMENT (PA) l Function...............................................
6-5 Re s p on s i bi l i t i e s.......................................
6-5 Authority..............................................
6-5 6.2.4 Sil l FT TECH NI CA L ADVI S0 R................................
6-5
-6.3 FACI LI TY STAFF QUALI FI CATI ON...............................
6-5 6.4 TRAININC...................................................
b-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 Proc ed ores, Te s t s, and Expe r imen t s.....................
6-7 Modifications..........................................
6-7 Operating License / Technical Specifications.............
6-7 L
- 6. 5. 3.
PLANT NUCLEAR SAFETY COMMITTEE (PNSC)
Function...............................................
6-8 Composition............................................
6-8 Alternates.............................................
6-8 l
Meeting Frequency......................................
6-8 l.
Quorum..............
6-8 Activities.............................................
6-9 g
l j:
Authority..............................................
6-10 j'
Records................................................
6-10 1
t I
BRUNSWICK - UNIT 2 XIV Amendment No.
INDEX ADMINISTRATIVE CONTROL 5 SECTION PACE 6.5 REVl EW AND AUDIT (Continued) 6.5.4 NUCLEAR ASSESSMENT DEPARTMENT INDEPENDENT REVIEW PROCRAM l
Function................................................
6-10 Organization............................................
6-10 Review..................................................
6-11 Records.................................................
6-12 6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDIT PROGRAM l
Function................................................
6-13 Audits..................................................
6-13 Records.................................................
6-14 Authority...............................................
6-14 Personne1...............................................
6-14 6.5.6 OUTSIDE ACENCY INSPECTION AND AUDIT PROGRAM.............
6-15 6.6J REPORTABLE EVENT ACTI0N....................................
6-15 l
6.7 S A F ETY LI M I T V 10 LATI ON.....................................
6-15 6.8
' PR OC ED UR ES ' A ND P R0CR AM S....................................
6-16 i
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 Semiannual-Radioactive Effluent Release Report..........
6-20 M on th l y O pe ra t i ng R e p o r t s...............................
6-21 S pe c i a l R e p o r t s.........................................
6-22 Core Operating Limits Report............................
6-22 l
BRUNSWICK - UNIT 2 XV Amendment No.
I ADMINISTRATIVE CONTRGLS
.~.__
6.2.3 PROJECT A'SESSMENT (PA) l PUNCTION
,l 6.2.3.1 The PA Croup Unit shall fi..: Lion to examine f acility operating l
l charmeristics, NRC i ssues, induw ry advisories, and other sources which may l
indicate areas for improving iac lity safety.
l 1
1 RESPONSI BII I fl Er
{
6 <.:. 3. 2 The PA Group L'ait shall be resrc.sible f or maintaining surveillance l
of fetility actisi ties t, provide independent verification
- that these j
antvities are perforr.d correctly and that human errors are reduced as much as i
pr:,tical.
]
W 2
AUTil0RITv G.2.3.3 The PA Croup Unit shall make detailed recommendations for revisea l
procedures, equipcient mcditications, re other means of improvir,g facility J
safety to the Man.sger - Nuclea-Asse,sment Department.
l l
6.2.4 - SHIFT TECf.NICAL ADVISOR j
- 6. 2. 4.1 - The Shift Technical Adviso inhall serve in an aNisory capacity to the Shif t Supervisor on matters pert:init y to the engineer;,g aspects assuring safe operatinn of the unit.
6.3 FACILITY STAFF O!!ALIFICATION 6.3.1 Each menbar of the facility staff shi 1 meet or exc g the minimum quali f icat ion'; of ANSI N.3.1-1971 for comparcele positions
, except for (1) the Manr.ger - Environmentsl & Radiation Cot trol who shall meet or exceed 1
the qualiiications of Regulc.cory Guide 1.8, Sept omber 1975 and (2) the Shift i
Technical Advisor who shal have-a bachelor's dagree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant durtng transients and acciden'.s.
6.4 ThAINING 6.4.1
.A retraining and replacement training program f ot-the f acility staf f shall be maintained under the direction of the Manager - Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
6.4.2 A t raining 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.
~
l
- Not responsible for sign-of f 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 (the date of amendment issuance).
BRUNSWICK - UNIT 2 6-5 Amendment No.
..- __ _..~~ __.-- _ _ _ _ __
m.-._,
ADMINISTRATlVE CONTROLS-qtOCEDURES, TESTS, AND EXPERIMENTS 6.5.2.4 The salety 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 experiment s, and changes thereto constitute an unreviewed saf ety 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 saf et y 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 au 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 /TECllNICAL SPECIFICATIONS l
6.5.2.8 The saf ety 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 l
Operating License / Technical Specification change (s) is a. change =in the L
. facility as described in t he saf ety analysis. report.
6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications-6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be:
a.
Reviewed by the Plant Nuclear Saf ety Comnit tee in accordance with Specification 6.5.3.8.
i l
b.
Reviewed by the Nuclear Assessment Department Section in accordance l
with Specification 6.5.4.9.
l l
' BRUNSWICK - UNIT 2 6-7 Amendment No.
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ADMINISTRATlVR 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 t hereto (and any other procedures and changes thereto), any of which constitute an unreviewed safety question or involve a change in the
- Technical Speci fications, 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 saf ety question or involve a change to the Technical Specifications, prior to implementation.
d.
Review of all proposed changes to the Technical Speci fications or Operating License, prior to implementation.
' Review of reports on-violations of Technical Specifications including e.
reports covering evaluation and recommendations to prevent recurrence to the Manager - Brunswick Nuclear Project and to the Manager -
Nuclear Assessment Department.
l f.
Performance of special reviews, investigations (or analyses), and reports thereon as requested by the Manager - Nuclear Assessment l
Department.
g.
Review of all REPORTABLE EVENTS.
h.
Review of facility _ operations to detect potential nuclear safety L
hazards.
l 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 report s covering. evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Manager -
Brunswick Nuclear Project and the Manager - Nuclear Assessment g
i -
Department.
L 1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE L
CALCULATION MANUAL.
i l-l 1-I-
l BRUNSWICK - UNIT 2 6-9 Amendment No, i
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ADMINISTRATlVE 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 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 - Nuclear Assessment l
Department.
-6.5.4 NUCLEAR ASSEE NENT DEPARTHENT INDEPENDENT REVIEW PROGRAM
-FUNCTION 16.5.4.1 The Nuclear Assessment Department shall function to provide independent y
review of significant plant changes, tests, and procedures; verify that RE PORTAB LE i
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
. appa rent to a day-to-day observer.
ORCANIZATION l
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 c.
chemistry and radiochemistry
-- d.
metallurgy non-destructive testing e.
f.
instrumentation and control l
l g.
radiological safety h.
mechanical and electrical engineering i.
administrative controls BRUNSWICK - UNIT 2 6-10 Amendment No.
ADMINISTRATIVE CONTROLS 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 - Nuclear Assessment De pa rt ment shall have an academic l
degree in an engineering or related field and, in addition, shall have a minimum of ten years related experience, of which a minimum of five years shall be in the operation and/or design of nuclear power plants.
6.5.4.4 The independent safety review program reviewers shall have an academic degree in an engineering or related field or aquivalent and, in addition, shall have a minimum of five years related *. eerience.
6.5.4.5. An individual may possess competence in more than one specialty area.
If suf ficient expertise is not available within the Nu: lear Assessment l
Department, competent individuals from other Carolina Power & Light Company organizations or outside consultants shall _ be utilized in performing independent reviews and'investigaticns.
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.E The Nuclear Assessment Department independent safety review program l
shall be conducted in accordance with written, approved procedures.
REVIEW 6.5.4.9 The Nuclear Assessment Department shall perform reviews of the l
following:
a.
The safety evaluations for 1) changes to procedures required by Specification 6.8, 2) modificationa ~of equipment or systems, and
- 3) tests or experiments that constitute a change to the safety analysi s report to verify that such actions did not constitute an unreviewed safety question or involve a change to the Technic al 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.
BRUNSWICK - UNIT 2 6-11 Amendment No.
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,4 ADH1NISTRATIVE CONTROLS REVIEW (Continued).
c.
Proposed tests or experiments that involve an uareviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation.
d.
Proposed changes to the Technical Specifications and Operating License.
Violations of app' :able codes, regulations, orders, Technical e.
Specliications, license requireme:.ts, and internal procedures c+
instructions having nuclear safety significance.
f.
.Significant operating abnormalities or deviations f rom normal and expected performance of plant saf ety-related st ructures, systems, or components.
g.
Reportable events.
h.
Reports'and minutes of the PNSC.
i.
Any other matter involving safe operation of the nuclear power plant that the Manager - Nuclear Assessment Department-deems appropriate f or consideration or which is referred to the Manager - Nuclear Assessment Department by the on-site operating organization or other functional organizational units within Carolina Power & Light Company.
6.5.4.10.
Review of items considered under 6.5.4.9(e) through (i) above shall include the results of any investigations made and the recommendations resulting from these investigations to prevent or reduce the probability of recurrence of the event.
RECORDS 6.5.4.11 Records of Nuclear Assessment De pa rt r.en t reviews, including l
recommendations and concerns, shall be prepared and distributed as indicated below:
a.-
Copies of documented reviews shall tn retained in the Nuclear Assessment De pa rt ment files.
b.
Recommendations and concerns shall be submitted to the General L
Manager.- Brunswick-Plant and-Hanager - Brunswick Nuclear Project, within 14 days of completion of the review.
c.
A summation of Nuclear Assessment Department's recommendations-and l
cencerns shall be submitted to the Chairman / President; Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation;-
Vice President - Nuclear Services; Hanager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, appropriate, at least once every two months, l-BRUNSWICK - UNIT 2 6-12 Amendment No.
ADMINISTRATIVE CONTROLS l
6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDIT PROGRAM FUNCTION 6.5.5.1 The Nuclear Assessment De pa rt me nt 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 Nuclear Assessment Department. These audits shall encompass:
a.
The conformance of f acility 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 'esults of actions taken to correct deficiencies occurring in f acilit y equi pment, structures, systems, or methods of operation that af fect nuclear safety at least once per 6 months.
d.
The verification of compliance and implementation of the requirements of the Quality Assurance Program to meet the criteria of Appendix "B",
10 CFR 50, at least once per 24 months.
The Emergency Plan and implementing procedures at least once per 12 e.
months.
f.
The Security Plan and implementing procedures at least once per 12 months.
g.
The Facility Fire Protection Program and implementing procedutos at least once per 12 months.
h.
The radiological environmental monitoring program and the results thereof at least once per 12 months.
i.
The OFFSITE DOSE CALCULATIONAL MANUAL and implement ing procedures at least once per 24 months.
j.
The PROCESS CONTROL PROGRAM and implementing procedures f or processing and packaging of radioactive wastes at l ea s t once per 24 months.
i BRUNSWICK - UNIT 2 6-13 Amendment No.
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1 4
~ ADHINISTRATIVE CONTROLS AUDITS (Continurd) 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 f acility operation considered appropriate by ti e Hanager - Nuclear Assessment Department.
l 6.5.5.3 Personnel performing the audits shall have access to the plant g
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 Hanager - Nuclear Assessment Department, and forwarded to the l
Executive Vice President - Power Supply; Senior Vice President - Nuclear Generation; Hanager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, as appropriate, within 30 days after completion of the I
audit.
. AUT110R ITY 6.5.5.6 The Hanager - Nuclear Assessment Department shall be responsible for l
. the followings i
a.
The administering of the Nuclear Assessment Department Audit Prog ram.
l b.
The approval of the individual (s) selected to conduct audits.
l PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area audited.
6.5.5.e Se1ection ei personnel for auditing assignments shaii be based on
(:
experience or training that establishes that their qualifications are L
connensurate with the cc:aplexity or special nature of the activities to be audited.
In selecting audit personnel, consideration. shall be given to special abilities, ' specialized technical t raining, prior pertinent experience, persoi. 1-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.
l-BRUNSWICK - UNIT 2 6-14 Amendment No.
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l ADMINISTRATIVE CONTROLS i-i 6.5.6 0UTSIDE ACENCY INSPECTION AND AUDIT PROGRAM i
6.5.6.1 An independent fire protection and loss prevention inspection and i
a'u d i t shall be performed at least once per 12 months utilizing either j
qualified offsite licensee personnel or an outside fire protection firm.
l'j 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 1
intervals no greater than 36 months.
}
j 6.6 REPORTABLE EVENT ACTION I
lt 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
V i
a.
The Commission shall be notified and a report submitted pursuant to l
the requirements of Section 50.73 to 10 CFR Part 50, and i
j b.
Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safety Committee - Brunswick Plant and shall be submitted to the Manager -
b-Nuclear Assessment Department and the Manager - b: inswick Nuclear l
l Project.
6.7 SAFETY LIMIT VIOLATION I
6.7.1 The following actions shall be taken in the event a Safety Limit is j
violated:
l d,
a.
The facility shall be placed in at least 110T SilUTDOWN within two l
l hours.
~
L 1
b.
The NRC Operations Center shall be notified by telephone as soon as j
possible and in all cases within one hour. The Manager -. Brunswick Nuclear Project and the Manager - Nuclear Assessment De pa rtment shall l
j be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, s-l A Safety Limic Violation Report shall be prepared. The report shall c.
be reviewed by the General Manager - Brunswick Plant.
This report I-shall describe (1) applicable circumstances preceding.the violation, i
(2) effects of the violation upon facility components, systems, or structures, and (3) corrective action taken to prevent recurrence.
i d.
The Safety Limit Violation Report shall be submitted to the Commission,-the Manager - Brunswick' Nuclear Project, and the Manager -
Nuclear Assessment Department within-14 days of the violation.
l BRUNSWICK - UNIT 2 6-15 Amendment No.
r ADMINISTRATlW CONTROLS RECORDS 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 lif e commences and associated installation and maintenance records, m.
Records of analyses required by the radiological environmental monitoring program, n.
Records of (1) meetings of the PNSC, (2) meetings of the previous of t-site review organization, the Company Nuclear Safety Committee (CNSC), (3) the independent reviews performed by the Nuclear Assessment De pa r t me nt, and (4) the independent reviews performed by the Corporate Quality Assurance Audit Program, Qualit y Assurance Auditing Unit.
6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures f or personnel radia.on protect ion sha! ! be p re pa red consistent with the requirements of l' CFR Part 20 and shall be approved, maintained and adhered to for all op ations involving personnel radiation ex po su re.
6.12 illC11 RADI ATION AREA 6.12.1 In lieu of the " Cont rol Device" or " alarm signal" requireu by paragraph 20.203(c)(2) of 10 CPR 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.
b.
A radiation monitoring device which cor.tinuously integrates the radiation dase rate in the area and alarms when a pres't integrated dose is received.
Entry into such areas with this mo toring device may be made af ter the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
- llealth Physics personnel or personnel escorted by lleal th Pl.ysics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved l
radiation protection procedures for entry into high radiation areas.
I BRUNSWICK - UNIT 2 6-25 Amendment No.
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1