ML20078R723
| ML20078R723 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/11/1983 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20078R721 | List: |
| References | |
| 83TSB16, NUDOCS 8311150268 | |
| Download: ML20078R723 (48) | |
Text
r ENCLOSURE 1 RADIOLOGICAL-EFFLUENT TECHNICAL SPECIFICATIONS (Administrative Controls Section)
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 1 REFERENCE NO. 83TSB16 8311150268 831111 PDR ADOCK 05000324 P
y.
INDEX ADMINISTRATIVE CONTROLS SECTION PAGE REVIEW AND AUDIT (Continued)
Subjects Requiring Independent Review..................
6-10 Follow-up Action.......................................
6-11 6.5.4 OPERATION AND MAINTENANCE UNIT Function...............................................
6-12 Personne1..............................................
6-13 Reports................................................
6-13 6.5.5 OUTSIDE AGENCY INSPECTION AND AUDIT PROGRAM............
6-13 6.6 REPORTABLE OCCURRENCE ACTI0N................................
6-13 6.7 SAFETY LIMIT VIOLATION......................................
6-14 6.8 PROCEDURES..................................................
6-14 6.9 REPORTING REQUIREMENTS Routine Reports and Reportable Occurrences.............
6-15 Startup Reports........................................
6-15 An nu a l Re p o r t s.........................................
6-16 Annual Radiological Environmental Operating Report.....
6-16 Semiannual Radioactive Ef fluent Release Report.........
6-17 Monthly Operating Report...............................
6-19 Re por table Occu rrences.................................
6-19 Prompt Notification With Written Fo11ow-up.............
6-20 Th i r t y Day Wri t t en Re p o r t s.............................
6-21 Special Reports........................................
6-22 6.10 RECORDS RETENTION..........................................
6-22 6.11 RADIATION PROTECTION PR0 GRAM...............................
6-24 6.12 HIGH RADIATION AREA........................................
6-24 6.13 0FFSITE DOSE CALCULATION MANUAL (0DCM).....................
6-25 6.14 PROCESS CONTROL PROGRAM (PCP)...............................
6-25 BRUNSWICK - UNIT 1 XV Amendment No.
r-INDEX ADMINISTRATIVE CONTROLS SECTION--
PAGE 6.15 MAJOR CHANGES TO LIOUID, GASEOUS. AND SOLID WASTE TREATMENT SYSTEMS....................s........
6-26 6.16 ENVIRONMENTAL QUALIFICATION................................
6-27 4..
BRUNSWICK - UNIT'l XVI Amendment No, i
1 ADMINISTRATIVE CONTROLS MEETING FREOUENCY 6.5.1.4 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.
OUORUM 6.5.1.5 A quorum of the PNSC shall consist of the Chairman or Vice Chairman and ~ three members including alternates.
RESPONSIBILITIES 6.5.1.6. The. PNSC shall be responsible for:
a.
Review of 1) all procedures required by Specification 6.8 and changes thereto, 2) any other proposed procedures or changes thereto as determined by the General Manager to affect nuclear safety.
b.-
Review of all proposed tests and experiments that affect nuclear safety.
c.
Review of all proposed changes to Technical Specifications.
d.
Review of all-proposed changes or modifications to plant systems or equipment that affect nuclear safety.
e.
Investigation of all. violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President. - Euclear Operations and to the Manager - Corporate Nuclear Safety and-Quality Assurance Audit.
f.-
Review of all. events requiring 24-hour notification to the Commission.-
g.
Review of facility operations to detect potential safety hazards.
h.
Performance of special reviews, investigations, and reports thereon as requested by the ?bnager - Corporate Nuclear Safety and Quality Assurance Audit.
-1.
Review. of the Plant Security Plan and implementing procedures.
j.
Review of the Emergency Plan and implementing procedures.
k.
Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation of reports coverning evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President-BRUNSWICK - UNIT 1 6-7 Amendme t No.
n i
.. -,. _ _ ~,,, -.,
l ADMINISTRATIVE CONTROLS RESPONSIBILITIES (Continued)
Nuclear Operations and the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.
AUTHORITY 6.5.1.7 The PNSC shall:
Recommend to the General Manager written approval or disapproval of a.
itens considered under 6.5.1.6(a) through (d) above, b.
Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e) above constitutes an unreviewed safety question.
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 Vice President -
c.
Nuclear Operations and the Manager - Corporate Nuclear Safety and Quality Assurance Audit of disagreement between the PNSC and the General Manager; however, the General Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above.
RECORDS 6.5.1.8 The PNSC shall maintain written minutes of each meeting that, at a minimum, document the results of all PNSC activities performed under the responsibility and authority provisions of these technical specifications, and copies shall be provided to the Vice President - Nuclear Operations and to the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
-6.5.2 CORPORATE NUCLEAR SAFETY AND OUALITY ASSURANCE AUDIT SECTION (CNS & OAAS)
RESPONSIBILITY 6.5.2.1 The Manager - Corporate Nuclear Safety and Quality Assurance Audit, under the Vice President - Nuclear Safety and Research, is charged with the overall responsibility for administering the independent offsite review and quality assurance audit programs as follows:
Approves selection of the individuals to conduct offsite safety a.
reviews and quality assurance audits.
b.
Has access to the plant operating records and operating personnel in performing the independent reviews and quality assurance audit.
c.
Prepares and retains written records of review and audits.
BRUNSWICK - UNIT 1 6-8 Amendnent No.
i ADMINISTRATIVE CONTROLS RESPONSIBILITIES (Continued) d.
Assures independent safety reviews are conducted on all items required by Section 6.5.3.3 and quality assurance audits cover all items included in Section 6.5.4.1.
- e..
Distributes reports, records of PNSC meetings, and other records to the appropriate managers and individuals assigned to conduct the off-site safety reviews and quality assurance audits.
6.5.3 CORPORATE NUCLEAR SAFETY UNIT (CNSU)
FUNCTION 6.5.3.1 The Corporate Nuclear Safety Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section shall provide independent offsite review of significant plant changes, tests, and procedures; verify that reportable occurrences are promptly investigated and corrected in a manner which reduces the probability of recurrence of such events; and detect trends which may not be apparent to a day-to-day observer.
PERSONNEL 6.5.3.2 a.
Personnel ar. signed responsibility for independent reviews shall be specified in technical disciplines, and shall collectively have the exprilence and competence required to review problems in the following areas:
1.
Nuclear power plant _ operations 2.
Nuclear engineering 3.
Chemistry and radiochemistry 4.
Metallurgy 5.
Instrumentation and control 6.
Radiological safety 7.
Mechanical and electrical engineering 8.
Administrative controls 9..
Seismic and environmental 10.
Quality assurance practices
'b.
The following minimum experience requirements shall be established A
for those persons involved in the independent offsite safety review program:
1.
Manager of CNS and QAAS - Bachelor of Science in engineering or-related field and ten (10) years related experience including five (5) years involvement with operation and/or design of-nuclear-power plants.
BRUNSWICK - UNIT 1 6-9 Ame dment No.
n
=--
x-
ADMINISTRATIVE CONTROLS PERSONNEL (Continued) 2.
Reviewers - Bachelor of Science in engineering or related field or equivalent and five (5) years related experience including three (3) years involvement with operation and/or design of nuclear power plants.
An individual may possess competence in more than one specialty c.
If sufficient expertise is not available within the Corporate area.
Nuclear Safety U'it, competent individuals from other Carolina Rur er n
and Light Company organizations or outside consultants shall be utilized in performing independent offsite reviews and investigations.
d.
At least threo persons, qualified as discussed in Specification 6.5.2.3.b, shall review each item submitted under the requirements of Section 6.5.3.3.
Independent safety reviews shall be performed by personnel not e.
directly involved with the activity or responsible for the activity.
. SUBJECTS REOUIRING INDEPENDENT REVIEW 6.5.3.3 The following subjects shall be reviewed by the Corporate Nuclear Safety Unit:
Written safety evaluations of changes in the facility as described in a.
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). This review is to verify that such changes, tests, or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2).
b.
Broposed changes in procedures, 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(c). Matters of this kind shall be referred to the Corporate Nuclear Safety Unit by the Plant Nuclear Safety Committee following its review, or by other functional organizational units within Carolina R>r er & Light Company prior to implementation.
Proposed changes to the Technical Specifications or this operating c.
license.
BRUNSWICK - UNIT 1 6-10 Amendment No.
-ADMINISTRATIVE CONTROL SUBJECTS REOUIRING INDEPENDENT REVIEW (Continued) d.
Violations, deviations, and reportable events, which require reporting to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and as defined in the plant technical specifications such as:
1.
Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, or internal procedures or instructions having safety significance; and 2.
Significant operating abnormalities or deviations from normal or expected performance of plant safety-related structures, systems, or components.
Review of events covered under this paragraph shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
l e.
Any other matter involving safe operation of the nuclear power plant which the Manager - Corporate Nuclear Safety and Quality Assurance Audit Section deems appropriate for consideration, or which is referred to the Manager - Corporate Nuclear Safety and Quality Assurance Audit Section by the onsite operating organization or by other functional organizational units within Carolina Power and Light Company.
f.
Reporta and meeting minutes of the PNSC.
FOLLOW-UP ACTION 6.5.3.4 Results of Corporate Nuclear Safety (CNS) reviews, including recommendations and concerns shall be documented.
a.
Copies of the documented review shall be retained in the Corporate Nuclear Safety and Quality Assurance Audit Section files.
b.
Recommendations and concerns shall be submitted to the Vice President - Nuclear Operations within 14 days of determination.
c.
A summation of Corporate Nuclear Safety recommendations and concerns shall be submitted to the Chairman / Chief Executive Of ficer; Senior Executive Vice President and Chief Operating Officer; Executive Vice President - Power Supply and Customer Services; Senior Vice President - Bawer Supply; Vice President - Nuclear Safety and Research; Plant General Manager; and others, as appropriate on at least a bimonthly frequency.
6.5.3.5 The Corporate Nuclear Safety Unit review program shall be conducted in accordance with written, approved procedures.
BRUNSWICK - UNIT 1 6-11 Amendment No.
ADMINISTRATIVE CONTROLS 6.5.4 OPERATION AND MAINTENANCE UNIT (OMU)
FUNCTION 6.5.4.1 The Operation and Maintenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section shall perform audits of plant activities. These audits shall encompass:
The conformance of facility operation to all provisions contained a.
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.
The results of actions taken to correct deficiencies occurring in c.
facility equipment, structures, systems, or method of operation that affect nuclear safety at least once per 6 months.
d.
The verification of compliance and implementation of the requirements of the Ouality Assurance Program to meet the criteria of Appendix "B",
10 CFR 50, ac least once per 24 months.
The Emergency Plan and implementing procedures at least once per 24 e.
months.
f.
The Security Plan and implementing procedures at least once per 24 months.
g.
The Facility Fire Protection Program and implementing procedures at least once per 24 months.
h.
The radiological environmental monitoring program and the results thereof at least once per 12 months, i.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
j.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radicactive wastes at least once per 24 months.
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 Corporate Quality Assurance Audit Operation and Maintenance Unit, the Executive Vice President - B3wer Supply and Customer Service, or the Senior Vice President - Power Supply.
BRUNSWICK - UNIT 1 6-12 Amendment No.
r ADMINISTRATIVE CONTROLS PERSONNEL 6.5.4.2 a.
Audit personnel shall be independent of the area audited. Selection for auditing assignments is based on experience or training which establishes that their qualifications are commensurate with the complexity or special nature of the activities to be audited.
In selecting auditing personnel, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and education.
b.
Qualified outside consultants or other individuals independent from those personnel directly involved in plant operation, but within the Operations Group, shall be used to augment the audit teams when necessary.
REPORTS 6.5.4.3 Results of audit are approved by the Manager - Corporate Nuclear
' Safety and Quality Assurance Audit Section and transmitted directly to the Company President / Chief Executive Officer, the Senior Executive Vice President and Chief Operating Officer, the Executive Vice President - Power Supply and Customer Services, the Senior Vice President - Pbwer Supply, and the Vice President - Nuclear Safety and Research, and others, as appropriate within 30 days after the completion of the audit.
6.5.4.4 The Corporate Quality Assurance Audit Program shall be conducted in accordance with written, approved procedures.
6.5.5 OUTSIDE AGENCY INSPECTION AND AUDIT PROGRAM 6.5.5.1 An independent fire protection and loss prevention program inspection and audit shall be performed at least once per 12 months utilizing an outside fire protection firm.
6.5.5.2 An inspection and audit of the fire protection and loss prevention program shall be performed by a qualified outside fire consultant at least once per 36 months.
6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 the following actions shall be taken for REPORTABLE DCCURRENCES:
a.
The Commission shall be notified and/or a report submitted pursuant to the requirements of Specification 6.9.
BRUNSWICK - UNIT 1 6-13 Amendment No.
I ADMINISTRATIVE CONTROLS REPORTABLE OCCURRENCE ACTION (Continued)
J b.
Each REPORTABLE OCCURRENCE requiring 24-hour notification to the Commissions shall be reviewed by the PNSC and submitted to Manager -
Corporate Nuclear Safety and Ouality Assurance Audit and the Vice President - Nuclear Operations.
6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
a.
The facility shall be placed in at least HOT SHUTDOWN within two hours.
b.
The Safety Limit violation shall be reported to the Commission, the Vice President - Nuclear Operations, and the Manager - Corporate Nuclear Safety and Quality Assurance Audit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
c.
A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the PNSC, This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems, or structures, and (3) corrective action taken to prevent recurrence.
d.
The Safety Limit Violation Report shall be submitted to the Commission, the Manager - Corporate Nuclear Safety and Quality Assurance Audit, and the Vice President - Nuclear Operations within 14 days of the violation.
6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.
b.
Refueling operations.
c.
Surveillance and test activities of safety-related equipment.
d.
Security Plan implementation.
e.
Emergency Plan implementation.
f.
Fire Protection Program implementation.
g.
OFFSITE DOSE CALCULATION MANUAL implementation.
h.
PROCESS CONTROL PROGRAM implementation.
BRUNSUICK - UNIT 1 6-14 Amendm nt No.
e
ADMINISTRATIVE CONTROLS PROCEDURES (Continued) 1.
Quality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975.
6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed by tha PNSC and approved by the General Manager prior to implementation and reviewed periodically by the PNSC ns set forth in administrative procedures.
6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:
a.
The intent of the original procedure is not altered.
b.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the Brunswick Plant.
The change is documented, reviewed by the PNSC, and approved by the c.
General Manager within 14 days of implementation.
6.9 REPORTING REOUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.
,STARTUP REPORT 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (1) receipt of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.
The startup report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described.
Any additional specific details required in license conditions based on other commitments shall be included in this report.
6.1.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest.
If the Startup Report does not cover all three events (i.e., initial criticality, BRUNSWICK - UNIT 1 6-15 Amendment No.
ADMINISTRATIVE CONTROLS STARTUP REPORT (Continued) completion of start-up test program, and resumption or commencement of commercial power operation), supplementary reports shall be submitted at least every three months until all three events have been completed.
ANNUAL REPORTS M
6.9.1.4 Annual reports covering the activities of the unit as described below during the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year following. initial criticality.
6.9.1.5 Reports required on an annual basis shall include a tabulation of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem /yr a exposureaccordingtoworkandjobfunctions,gtheirassociatedmanrem
.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions.
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT E 6.9.1.6 Routine radiological environmental operating reports covering the operation of the facility during the previous calendar year shall be submitted prior to May 1 of each year.
6.9.1.7 The Annual Radiological Environmental Operating Report shall include the following:
a.
Summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with pre-operational studies, with operational controls (as appropriate), and with previous environmental surveillance reports, and an assessment of the observed impact of the plant operation on the environment.
O A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station.
U This tabulation supplements the requirements of Section 20.407 of 10 CFR Part 20.
E A single submittal may be made for a multiple unit station.
BRUNSWICK - UNIT 1 6-16 Amendm nt No.
e
ADMINISTRATIVE CONTROLS ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (Continued) b, Results of land uses censuses required by Specification 3.12.2.
Results of analysis of all radiological environmental samples and of c.
all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the OFFSITE DOSE CALCULATION MANUAL, as well as sununarized and tabulated results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.
In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data should be submitted as soon as possible in a supplementary report.
d.
A summary description of the radiological environmental monitoring program.
AtleasttwolegiblemapsJb[coveringallsamplinglocationskeyedto e.
a table giving distances and directions from the centerline of one reactor.
f.
The results of licensee participation in the Interlaboratory Comparison Program, required by Specification 3.12.3.
g.
Discussion of all deviations from the sampling schedule of Table 3.12.1-1.
h.
Discussion of all analyses in which the LLD required by Table 4.12.1-1 was not achievable.
SEMIANEUAL RADIOACTIVE EFFLUENT RELEASE REPORT 5/
6.9.1.8 Routine radioactive effluent release reports covering the operation of the facility during the previous 6 months of operation shall be submitted within the time periods specified in Specifications 6.9.1.9 and 6.9.1.10 below.
6.9.1.9 The portion of the Semiannual Radioactive Ef fluent Release Reports to be submitted within 60 days after January 1 and July 1 of each year shall include the following:
$/ One map shall cover stations near the SITE BOUNDARY; a second map shall include the more distant stations.
5/ A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station.
t l
BRUNSWICK - UNIT 1 6-17 Amendment No.
F ADMINISTRATIVE CONTROLS SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT (Continued)
A summary of the quantities of radioactive liquid and gaseous a.
effluents and solid waste released from the facility as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactivity Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis similar to the format of Appendix B thereof.
b.
The information specified below for each class of solid waste (as defined by 10 CFR Part 61, when implemented) shipped offsite during the report period:
1.
Container volume, 2.
Total curie quantity (specify whether determined by measurement or estimate),
3.
Principal radionuclides (specify whether determined by measurement or estimate),
4.
Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporated bottoms),
5.
Type of container (e.g., LSA, Type A, Type B, Large Quantity),
and 6.
Solidification agent or absorbent (e.g., cement, urea formaldehyde).
c.
A list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.
d.
Any changes made during the reporting period to the PROCESS CONTROL PROGRAM (FCP) or the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land use census pursuant to Specification 3.12.2.'
6.9.1.10 The portion of the Semiannual Radioactive Effluent Release Report to be submitted within 90 days after January 1 of each year shall include the following:
a.
An annual summary of hourly metorological data collected over the previous calendar year.
This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind BRUNSWICK - UNIT 1 6-18 Amendm nt No.
e
ADMINISTRATIVE CONTROLS SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (Continued) direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distrib ions of wind speed, wind direction, and atmospheric stability.
b.
As assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the station during the previous calendar year.
MONTHLY OPERATING REPORT i
\\l 6.9.1.11 Routine reports of operating statistics and shutdown experience,.
~
including documentation of all challenges to main steam system safety / relief valves, shall be submitted on a monthly Fasts to the Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with t a copy to the Regional Office, to arrive no later than the tenth of each month following the calendar month covered by the report.
REPORTABLE OCCURRENCES 6.9.1.12 The REPORTABLE OCCURRENCES of Specifications 6.9.1.13 and 6.9.1.14 l
below,. including corrective actions and measures to prevent recurrence, shall be reported to the NRC.
Supplemental reports may be required to fully describe final resolution of occurrence.
In case of corrected or supplemental reports, a licensee event report shall be completed and reference shall be made to the original report date.
l
$/ In lieu of submission with the Semiannual Radioactive Effluent Release Report, the licensee has the option of retaining this summary of required meteorological data in a file that shall be provided to the NRC upon request.
BRUNSWICK - UNIT 1 6-19 Amendm nt No.
e
AININISTRATIVE CONTROLS PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP 6.9.1.13 The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l
by telephone apd confirmed by telegraph, mailgram, or facsimile transmission to the Director of the;Ppgional Office, or his designate no later than the first working day following the event, with a written followup report within two weeks. The written followup report shall include, as a minimum, a completed copy of a licensee event report form.
Information provided on the licensee event report form shall be supple:nented, as needed, by additional narrative material tjo provide complete exp1.anation of the circumstances surrounding theievect'.
Failure of the reactor protection system or other systems subjeci to a.
limiting safety system settings to initiate the required protective funcrion by the time a monitored parameter, reaches the setpoint specified as the limiting safety system setting in the technical specifications or f ailure to complete the required protective function.
b.
Operation ofe:he unit or affected systems when any parameter or operation subject to a limiting condition for operation is less conservative than the least conservative aspect of the limiting 5
condition for operation established in the technical specifications.
c.
Abnormal degradation discovered in fuel cladding, reactor coolant pressure boundary, or primary containment.
d.
Reactivity anomalies involving disagreement with the predicted value of reactivity balance under,steadys tate conditions during power s
operation greater than or eq'ual to X &/k; a calculated reactivny balance \\ indicating a SHUIDOWN NARGIN less conservative than specified in the technical specifications; short-term reactivity increases that I
correspond.co a reactor period of less than 5 seconds or, if
,s
- /
iuberitini', ansunplanned reactivity insertion of more than
/.'
OkSE 2k/k; or,cccurrence of any unplanned criticality.
I e.
Failure or malfunction of one or more components which prevents or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the SAR.i f.
Personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems rcquired to cope with accidents analyzed in the SAR.
BRUNSWICK - UNIT 1 6-20 Amendment No.
I-
/
ADMINISTRATIVE CONTROLS PROMPT NOTIFICATION WITH WRITTEN FOLLOW-UP (Continued)
Conditionsarisingfro5[nat'uralorman-madeeventsthat, as a direct g.
result'of the event require plant shutdown, operation of safety systems, or other protective. measures required by technical l
specifications.
h.
Errors discovered in the transient or accident analyses.or in the I
methods used for such analyses as described in the safety analysis.
t report or in the bases for the technical specifications that have'or could have permitted reactor operation in a manner less conservative than assumed in the analyses.
i.
Performance of structures, systems, or components that requires remedial action or corrective meas.ures to prevent operation in a l
manner less conservative than assumed in the accident analyses in the safety analysis report or technicak' specifications bases; or discovery during plant life of conditions'nat specifically considered l
in the safety analysis report or technical specification that require l
remedial action or correctiite measures t'o prevs:nt the existence or development of an unsafe condition..
3' s
,~.
THIRTY-DAY WRITTEN REPORTS g'
6.9.1.14 The types of events., listed below shall be the subject of written l
reports to the Director of the Regional Office within thirty days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a licensee event report form.
Information provided on the licensee event report form shall be supplemented, as needed, by additional
- ~
narrative material to provide co'mp1ete explanation of the circumstances surrounding the event.
~'
l q'
s
.+
a.
Reactor protection system or engineered safety feature instrument settings which are found to be less conservative than those i
established by the technical specifications but which do not prevent l
the fulfillment of the. functional requirements of affected systems.
?
j, b.
Conditions leading.to c,paration in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.
c.
Observed inadequacies in the implementation of administrative or procedural' controls which threaten to cause reduction of degree of redundancy provided tw reactor protection systems or engineered safety feature systems.
d.
Abn'ormal degradation of Systems ott ar than those 'specified in 6.9.1.13.c above designed to contain radioactive material resulting f rom the fission process. ' -,j 9
i
,j. '
j BRUNSWICK - UNIT.1 4
6-2k Amendment No.
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.e-ADMINISTRATIVE CONTROLS i
SPECIAL REPORTS SpecialreportssballbesubmittedtotheDkrectoroftheOfficeof 6.9.2 Inspection and Enforcement Regional Office within' the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification:
a.
Inoperable Seismic Monitoring Instru6entation, Specification 3.3.5.1.
b.
Seismic event analysis, Specification 4.3.5.1.2.
c.
Reactor coolant specific activity analysis, Specification 3.4.5.
d.
Fire detection instrumentation, Specification 3.3.5.7.
e.
Fire suppression systems, Specifications 3.7.7.1, 3.7.7.2, and 3.7.7.3.
f.
. ECCS actuation, Specifications 3.5.3.1 and 3.5.3.2.
g.
Fire barrier penetration, Specification 3.7.8.
h.
Liquid Effluents Dose, Specification 3.11.1.2.
i.
Liquid Radwaste Treatment, Specification 3.11.1.3.
J.
Dose - Noble Cases, Specification 3.11.2.2.
k.
Dose - Iodine-131, Iodine-133, Tritium, and Radionuclides in Particulate Form, Specification 3.11.2.3.
1.
Caseous Radwaste-Treatment, Specification 3.11.2.4.
a m.
Ventilation Exhaust Treatment, Specification 3.11.2.5.
J J
n.
Total' Dose, Specification 3.11.4.
. ;l,
.o.
, Monitoring Program, Specificatic.,a 3.12.1.b.
6.10 RECORD RETEITION
~
/
Facility. records shall be retained in accordance with ANSI-N45.2.9-1974.
t 6.10.1-The f 11owing records shall be retained for at least five years:
a.
Records and logs of facility operation covering time interval at each power level.
b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.
BRUNSWICK - UNIT 1 6-22 Amendment No,
~
ADMINISTRATIVE CONTROLS RECORD RETENTION (Continued) c.
All REPORTABLE OCCURRENCE submitted to the Commission.
d.
Records of surveillance activities, inspections, and calibrations required by these Technical Specifications.
Records of changes made to Operating Procedures.
e.
-f.
Records of radioactive shipments, g.
Records of sealed source and fission detector leak tests and results.
h.
Records of annual physical inventory of all sealed source material of record.
6.10.2-The following records shall be retained for the duration of the Facility Operating License:
a.
Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.
b.
Records of new and irradiated fuel inventory, fuel transfers, and assembly burnup histories.
Records of facility radiation and contamination surveys.
c.
d.
Records or radiation exposure for all individuals enterir.g radiation control areas.
e.
Records of gaseous and liquid radioactive material released to the environs.
f.
Records of transient or operational cycles for those facility components identified in Table 5.7.1-1.
g.
Records of reactor tests and experiments.
h.
Records f training and qualification for current members of the o
plant staff.
i.
. Records of in-service inspections performed pursuant to these Technical' Specifications.
J.
Records of Quality Assurance activities required by the OA Manual.
k.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
BRUNSWICK - UNIT 1 6-23 Amendm nt No.
e
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' ADf1NISTRATIVE CONTROLS RECORD RETENTION (Continued) 1.
Records of meetings of the PNSC and of the previous offsite review organization, the Company Nuclear Safety Committee (CNSC).
m.
Records of analyses required by the radiological environmental monitoring program.
n.
' Records for Environmental qualification which are covered under the provisions of paragraph 6.16.
6.11 RADIATION PROTECTION PROGRAM 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 1
7 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 *. '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 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 unde af ter the dose rate level in the area has been established and personnel have been made knowledgeable of them.
c.
An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiation Work Permit.
- Health Physics personnel shall be exempt f rom the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply;with approved radiation protection procedures for entry into high radiation areas.
BRUNSWICK - UNIT 1 6-24 Amendment No.
ADtINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued) 6.12.2 The requirements of 6.12.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mres/hr.
In addition,11ocked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shif t Foreman on duty and/or the Plant Health Physicist.
6.13 0FFSird DOSE CALCULATION MANUAL' (ODCM) 6.13.1 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be approved by the Commission prior to' implementation.
6.13.2 Licensee initiated changes to the ODCM:
- Shall be submitted to the Commission in the Semiannual Radioactive a.
Ef fluent Release Report 'for the period in which the change (s) was
'made effective. This submittal shall contain:
Sufficiently detailed information to totally support rationale
- 1. -
without benefit of additional or supplemental information.
Information sdamitted should consist of a pac'kage of those pages of the ODCM to be changed with each page numbered and provided with an approval and date box, together with appropriate analyses or evaluations justifying the change (s);
2.
A determination that the changes will not reduce the accuracy or reliability of dose calculations or setpoint determinations;
- and, 3.
Documentation of the f act that the change has been reviewed and found acceptable by the PNSC.
b.
Stall become ef fective upon review and acceptance by the PNSC.
6.14 PROCESS CONTROL PROGRAM (PCP) 6.14.1 The PROCESS CONTROL PROGRAM (PCP) sh4'1 be approved by the Commission prior-to implementation.;
6.14.2 Licensee initiated changes to PCP:
[
a.
Shall be submitted to the Commission in the Semiannual Radioactive Ef fluent Release Report for the pericd in which the change (s) was made. This submittal shall contain:
1.
Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information; BRUNSWICK - UNIT 1 6-25 Amendment No.
3-
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1 ADMINISTRATIVE CONTROLS 6.14 PROCESS CONTROL PROGRAM (PCP) (Continued) 2.
A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria
-for-solid wastes; and, 3.
Documentation of the fact that the change has been reviewed and found acceptable by the PNSC.
'b.
Shall become effective upon review and acceptance by the PNSC.
6.15 MAJOR CHANGES TO LIQUID. CASEOUS. AND SOLIP WASTE TREATMENT SYSTEM 2[
6.15.1 Licensee initiated major changes to the radioactive wasrc systems (liquid, gaseous, and solid):
a.
Shall be reported to the Commission in the Semiannual' Radioactive Effluent. Release Report for the period in which the evaluation was reviewed.by the PNSC. The discussion of each change shall contain:
1.
A summary of the evaluation that led to the determination that that change could be made in accordance with 10 CFR Part 50.59.
2.
Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; 3.
A detailed description of the equipment, components, and processes involved and the interfaces with other plant systems;
~4.
An evaluation of the change that shows the predicted release of radioactive materials. in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously
. predicted in the license application and amendments thereto :
5.
An evaluation of the change. that shows the expected maximum
~
exposure to an individual in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto ;
6.
A comparison of the predicted releases of radioactive materials, in liquid and gaseous = effluents and in solid waste, to the actual releases for the' period prior to when the changes are to
-be made ;
ll Licensees may chose to submit the information called for in this Specification as part of the annual FSAR update.
BRUNSWICK - UNIT 1 6-26 Amendm nt No.
e
l ADMINISTRATIVE CONTROLS i
l 6.15 MAJOR CHANGES TO LIOUID, GASEOUS, AND SOLID WASTE TREATMENT SYSTEM (Continued) 7.
An estimate of the exposure to plant operating personnel as a result of the change; and 8.
Documentation of the fact that the change was reviewed and found acce9 table to the PNSC.
b.
Shall become effective upon review and acceptance by the PNSC.
6.16 ENVIRONMENTAL OUALIFICATION A.
By no later than June 30, 1982 all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of:
Division of Operating Reactors " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors" (DOR Guidelines); or, NUREG-0588 " Interim Staff Basition on Environmental Qualification of Safety-Related Electrical Equipment", December 1979.
Copies of these documents are attached to Order for Modification of License DPR-71 dated October 24, 1980.
B.- By no later than December 1,1980. complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0588. Thereafter, such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified.
BRUNSWICK UNIT 1 6-27 Amendment No.
... -- =..__.
. -.z 4
ENCLOSURE 2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (Administrative Controls Section)
L BRUNSWICK STEA!! ELECTRIC PLANT, UNIT NO.-2 REFERENCE NO. 83TSB16 1
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INDEX ADf1NISTRATIVE CONTROLS SECTION PAGE REVIEW AND AUDIT (Continued)
Subj ects Re quiring Independent Review...................
6-10 Follow-up Action........................................
6-11 6.5.4 OPERATION AND MAINTENANCE UNIT Function................................................
6-12 Personnel...............................................
6-13 Reports.................................................
6-13 6.5.5 0UTSIDE AGENCY INSPECTION AND AUDIT PROGRAM.............
6-13 6.6 REPORTABLE O CCURRENCE A CTI0N................................
6-14 6.7 SAFETY LIMIT VIOLATION......................................
6-14 6.8 P R O C E D UR E S..................................................
6-14 6.9 REPORTING REQUIREMENTS Routine Re ports and Re portable Occurrences...................
6-15 Startup Reports..............................................
6-15 ka nua l Re p o r t s...............................................
6-16 Annual Radiological Environmental Operating Report...........
6-16 Semiannual Ra dioactive Ef fluent Re lease Report...............
6-17 Monthly Ope ra ting Re po rt.....................................
6-19 Re po r t ab le Oc currence s.......................................
6-19 Prompt Notification with Written Followup....................
6-19 Th ir t y Da y Wr i t t en Re po r t s...................................
6-20 Special Reports..............................................
6-21 6.10 RE CO R D R ET ENT I O N...........................................
6-21 BRUNSWICK - UNIT 2 XV Amendment No.
INDE.X ADMINISTRATIVE CONTROLS SECTION PAGE 6.11 RADIATION PROTECTION PR0 GRAM...............................
6-23 6.12' HIGH RADIATION AREA........................................
6-23 6.13 ~0FFSITE DOSE CALCULATION MANUAL (0DCM).....................
6-24 6.14 PROCESS CONTROL PROGRAM (PCP)..............................
6-24 6.15 MAJOR CHANGES TO LIOUID, GASEOUS.
AND SOLID WASTE TREATMENT SYSTEMS.......................
6-25 6.16 ENVIRONMENTAL 0UALIFICATION................................
6-26 BRUNSWICK - UNIT 2 XVI Amendment No.
ADMINISTRATIVE CONTROLS MEETING FREQUENCY 6.5.1.4 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.
OUORUM 6.5.1.5 A quorum of the PNSC shall consist of the Chairman or Vice Chairman and three members including alternates.
RESPONSIBILITIES 6.5.1.6 The PNSC shall be responsible for:
Review of 1) all procedures required by Specification 6.8 and changes a.
thereto, 2) any other proposed procedures or changes thereto as determined by the General Manager to affect nuclear safety.
b.
Review of all proposed tests and experiments that affect nuclear safety.
Review of all proposed changes to Technical Specifications.
c.
d.
Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety, Investigation of all violations of the Technical Specifications e.
including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice Ptesident - Nuclear Operations and to the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
f.
Review of all events requiring 24-hour notification to the Commission.
g.
Review of facility operations to detect potential safety hazards.
h.
Performance of special reviews, investigations, and reports thereon as requested by the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
i.
Review of the Plant Security Plan and implementing procedures.
J.
Review of the Emergency Plan and implementing procedures.
k.
Review of any 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 Vice President
- Nuclear Operations and the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
1.
Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.
BRUNSWICK - UNIT 2 6-7 Amendment No.
ADMINISTRATIVE CONTROLS AUTHORITY 6.5.1.7 The PNSC shall:
Recommend to the General Manager written approval or disapproval of a.
items considered under 6.5.1.6(a) through (d) above.
b.
Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e) above constitutes an unreviewed safety question.
c.
Bcovide 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 Vice President -
Nuclear Operations and the Manager - Corporate Nuclear Safety and Quality Assurance Audit of disagreement between the PNSC and the General Manager ; however, the General Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above.
RECORDS 6.5.1.8 The PNSC shall maintain written minutes of each meeting that, at a minimum, document the results of all PNSC activities performed under the responsibility and authority provisions of these technical specifications, and copies shall be provided to the Vice President - Nuclear Operations and to the Manager - Corporate Nuclear Safety and Quality Assurance Audit.
6.5.2 CORPORATE NUCLEAR SAFETY AND OUALITY ASSURANCE AUDIT SECTION (CNS & OAAS)
RESPONSIBILITY 6.5.2.1 The Manager - Corporate Nuclear Safety and Quality Assurance Audit, under the Vice President - Nuclear Safety and Research, is charged with the overall responsibility for administering the independent offsite review and quality assurance audit programs as follows:
a.
Approves selection of the individuals to conduct offsite safety reviews and quality assurance audits.
b.
Has access to the plant operating records and operating personnel in performing the independent reviews and quality assurance audits.
c.
Prepares and retains written records of review and audits.
d.
Assures independent safety reviews are conducted on all items required by Section 6.5.3.3 and quality assurance audits cover all items included in Section 6.5.4.1.
e.
Distributes reports, records of PNSC meetings, and other records to the appropriate managers and individuals assigned to conduct the off-site safety reviews and quality assurance audits.
BRUNSWICK - UNIT 2 6-8 Amendment No.
. ADMINISTRATIVE CONTROLS
'6.5.3 CORPORATE NUCLEAR SAFETY UNIT'(CNSU)
FUNCTION 6.5.3.1 The Corporate Nuclear Safety Unit of' the Corporate Nuclear Safety and
. Quality Assurance Audit Section shall provide independent offsite review of 7
significant plant changes, tests, and procedures; verify that reportable
. occurrences are promptly investigated and corrected in a manner which reduces the probability of recurrence of such events; and detect trends which may not be apparent to a day-to-day observer.
PERSONNEL' 6.5.3.2 a.
Bersonnel assigned responsibility for independent reviews shall be specified in technical disciplines, and shall collectively have the experience _ and. competence required to review problems in the following. areas:
1.
Nuclear power plant operations
~ 2.
Nuclear engineering 3.
Chemistry and radiochemistry 4._
Metallurgy 5.
Instrumentation and control j
6.
Radiological ~ safety _
7.
Mechanical and electrical engineering-8.
Administrative controls I.
.9.
Seismic-and environmental l'
10.
Quality assurance' practices b.
Th'e following minimum experience requirements shall be established for those persons involved in the independent offsite safety review program:
-1.
Manager of CNS and 0AAS - Bachelor of Science in engineering or related field and ten -(10) years related experience including five (5) years involvement with operation and/or design of
~
i nuclear power plants.
2.
Reviewers - Bachelor of Science in engi'.aering or related field or equivalent and five (5) years related experience including three (3) years involvement with operation and/or design of i
nucJear power plants.
a BRUNSWICK - UNIT 2 6-9 Amendment No.
_. -..,. _ _ _ _,, _... -. - _ _. _, _. -.. ~,.
ADMINISTRATIVE CONTROLS PERSONNEL (Continued) c..
An individual may possess competence in more than one specialty area.
If sufficient expertise is not available within the Corporate
- Nuclear Safety Unit, competent individuals from other Carolina Rawer and Light Company organizationa or outside consultants shall be utilized in performing independent offsite reviews and
~
investigations.
d.,
- At least three persons, qualified as discussed in Specification
- 6.5.2.3.b, shall review each item submitted under the requirements of Section 6.5.3.3.
e.
Independent safety reviews shall be performed by personnel not directly involved with the activity or responsible for the activity.
-SUBJECT REQUIRING INDEPENDENT REVIEW 6.5.3.3 The following subjects shall be reviewed by the Corporate Nuclear Safety Unit:
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). This~ review is to verify that such changes, tests, or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in' 10 CFR 50.59(a)(2).
b.
.Broposed changes in procedures, proposed changes in the facility, or proposed tests or experiments, any of which involves a change in the Technical Specifications or an unreviewed safety question pursuant to 10 CFR 50.59(c). Matters of this kind shall be referred to the Corporate bbelear-Safety : Unit by-the Plant Nuclear Safety Committee -
following its review, or by other functional organizational units within Carolina R>wer & Light Company prior to implementation.
Proposed changes to the Technical Specifications or this operating c.
license.
i L
l I
t-1 Ame dment No.
i -
BRUNSWICK - UNIT 2 6-10 n
I
ADMINISTRATIVE CONTROL SUBJECTS REOUIRING INDEPENDENT REVIEW (Continued) d.
Violations, deviations, and reportable events, which require reporting to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and as defined in the plant technical specifications such as:
1.
Violations of applicable codes, ;egulations, orders, Technical Specifications, license requirements, or internal procedures or instructions having safety significance; and 2.
Significant operating abnormalities or deviations from normal or e xpected performance of plant safety-related structures, systems, or components.
Review of events covered under this paragraph shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
Any other matter involving safe operation of the nuclear power plant e.
which the Manager - Corporate Nuclear Safety and Quality Assurance Audit Section deems appropriate for consideration, or which is referred to the Manager - Corporate Nuclear Safety and Quality Assurance Audit Section by the onsite operating organization, or by other functional organizational units within Carolina Power and Light Company.
f.
Reports and meeting minutes of the PNSC.
FOLLOW-UP ACTION 6.5.3.4 Results of Corporate Nuclear Safety (CNS) reviews, including recommendations and concerns shall be documented.
Copies of the documented review shall be retained in the Corporate a.
Nuclear Safety and Quality Assurance Audit Section files.
b.
Recommendations and concerns shall be submitted to the Vice President - Nuclear Operations within 14 days of determination.
A summation of Corporate Nuclear Safety recommendations and concerns c.
shall be submitted to the Chairman / Chief Executive Officer ; Senior Executive Vice President and Chief Operating Officer; Executive Vice President - Power Supply and Customer Services ; Senior Vice President - Bwer Supply; Vice President - Nuclear Safety and Research; Plant General Manager; and others, as appropriate on at least a bimonthly frequency.
6.5.3.5 The Corporate Nuclear Safety Unit review program shall be conducted in accordance with written, approved procedures.
Ame dment No.
BRUNSWICK - UNIT 2 6-11 n
-ADMINISTRATIVE CONTROLS
- 6. 5. 4' OPERATION AND MAINTENANCE UNIT (OMU)
FUNCTION 6.5.4.1 The Operation and Maintenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section shall perform audits of plant activities. These audits shall encompass:
The conformance of facility operation to all provisions contained a.
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.
The results of actions taken to correct deficiencies occurring in c.
facility equipment, structures, systems, or method of operation that affect nuclear safety at least once per 6 months.
)
d.
The verification of compli&nce and implementation of the requirements of the Quality Assurance Program to meet the criteria of Appendix
'L", 10 CFR 50, at least once per 24 months.
The Emergency Plan and implementing procedures at least once per 24 e.
months.
f.
The Security Plan and implementing procedures at least once per 24 months.
g.
The Facility Fire Protection Bcogram and implementing procedures at least once per 24' months.
h.
The radiological environmental monitoring program and the results thereof at least once per 12 months.
i.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
J.
The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
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 Corporate Quality Assurance Audit Operation and Maintenance Unit, the Executive Vice President - bwer Supply and Customer Service, or the Senior Vice President - Power Supply.
BRUNSWICK - UNIT 2 6-12 Amendment No.
ADMINISTRATIVE CONTROLS PERSONNEL 6.5.4.2 a.
Audit personnel shall be independent of the area audited. Selection for auditing assignments is based on experience or training which establishes that their qualifications are commensurate with the complexity or specici nature of the activities to be audited.
In selecting auditing personnel, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and education.
b.
Qualified outside consultants or other individuals independent from those personnel directly involved in plant operation, but within the Operations Group, shall be used to augment the audit teams when necessary.
REPORTS i
6.5.4.3 Results of audit are approved by the Manager - Corporate Nuclear Safety and Quality Assurance Audit Section and transmitted directly to the Company President / Chief Executive Officer, the Senior Executive Vice Ptesident and Chief Operating Officer, the fxecutive Vice President - Power Supply and Customer Services, the Senior Vice President - bwer Supply, and the Vice President - Nuclear Safety and Research, and others, as appropriate within 30 days after the completion of the audit.
6.5.4.4 The Corporate Quality Assurance Audit Bcogram shall be conducted in accordance with written, approved procedures.
6.5.5 OUfSIDE' AGENCY INSPECTION AND AUDIT PROGRAM 6.5.5.1 An independent fire protection and loss prevention program inspection and audit shall be performed at least once per 12 months utilizing an outside fire protection firm.
6.5.5.2 An inspection and audit of the fire protection and loss prevention program shall be performed by a qualified outside fire consultant at least once per 36 months.
Ame dment No.
BRUNSWICK - UNIT 2 6-13 n
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ADMINISTRATIVE CONTROLS 6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for REPORTABLE OCCURRENCES:
The Commission shall be notified and/or a report submitted pursuant a.
to the requirements of Specification 6.9.
b.
Each REPORTABLE OCCURRENCE requiring 24-hour notification to the Commission ~ shall~ be reviewed by the PNSC and submitted to Manager -
Corporate Nuclear Safety and Quality Assurance Audit and the Vice President - Nuclear Operations.
6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
a.
The facility shall be placed in at least HOT SHUTDOWN within two hours.
b.
The Safety Limit violation shall be reported to the Commission, the Vice President - Nuclear Operations, and the Manager - Corporate Nuclear Safety and Quality Assurance Audit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
A Safety Limit Violation Report shall be prepared. The report shall c.
be reviewed by the PNSC. This report shall describe (1) applicable circumstances preceding the violation ;
(2) effects of the violation upon facility components, systems, or structures; and (3) corrective action taken to prevent recurrence.
d.
The Safety Limit Violation Report shall be submitted to the Commission, the Manager - Corporate Nuclear Safety and Quality Assurance Audit, and the Vice President - Nuclear Operations within 14 days of the violation.
6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix "A" of Regulatory a.
Guide 1.33, November, 1972.
b.
Refueling operations.
Surveillance and test activities of safety-related equipment, c.
d.
Security Plan implementation.
e.
Emergency Plan implementation.
'f.
Fire Protection Program implementation.
g.
OFFSITE DOSE CALCULATION MANUAL implementation.
BRUNSWICK - UNIT 2 6-14 Amendment No.
ADMINISTRATIVE CONTROLS PROCEDURES (Continued) h.
PROCESS CONTROL PROGRAM implementation.
i.
Quality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975.
6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed by the PNSC and approved by the General Manager prior to implementation and reviewed periodically by the PNSC as set f orth in administrative procedures.
6.8.3 Temporary changes to procedures of 6.8.1 above may be made, provided:
a.-
The intent of the original procedure is not altered.
b.
The change is. approved by two members of the plant management staff,
at least one of whom holds a Senior Reactor Operator's License on the Brunswick Plant.
c.
The change is documented, reviewed by the PNSC, and approved by the General Manager within 14 days of implementation.
6.9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Of fice of Inspection and Enforcement unless otherwise noted.
STARTUP REPORT 6.9.1.1 A sunmary report of plant start-up and power escalation testing shall be submitted following (1) receipt of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.
6.9.1.2 The start-up report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications.
Any corrective actions that were required to obtain satisf actory operation shall
- also be described. Any additional specific details required in license conditions based cn other commitments shall be included in this report.
6.9.1.3 Start-up reports shall be submitted within (1) 90 days following
. completion of the s tart-up test program, (2) 90 days f ollowing resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest.
If the Start-up Report does not cover all three events (i.e., initial criticality, BRUNSWICK - UNIT 2 6-15 Am ndment No.
e
3 ADMINISTRATIVE CONTROLS STARTUP REPORT (Continued) completion of start-up test program, and resumption or commencement of commercial power operation), supplementary reports shall be submitted at least every three months until all three events have been completed.
ANNUAL REPORTSE!
6.9.1.4 Annual reports covering the activities of the unit as described below during the. previous calendar year shall be submitted prior to March 1 of each year.
The initial report shall be submitted prior to March 1 of the year following initial criticality.
6.9.1.5 Reports required on an annual basis shall include a tabulation of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem /yr app their associated man rem exposure according to work and-job functions, --
e.g.,
reactor operations and surveillance. inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty f unctions-may be estimates based on pocket dosimeter, TLD, or film badge measurements.
Small exposures totaling less than 20% of the I-individual total dose need not be accounted f or.
In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions.
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.6 -Routine radiological environmental operating reports covering the operation of the f acility during the previous calendar year shall be submitted prior-to May 1 of each year.
6.9.1.7 The Annual Radiological Environmental Operating Report shall include the following:
a.
Summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with pre-operational studies, with operational controls (as appropriate), and with previous environmental surveillance reports, and an assessment of the observed impact of the plant operation on the environment.
b.
Results of land uses censuses required by Specification 3.12.2.
1/ A single submittal may be made f or a multiple unit station.
The submittal should combine those sections that are common to all units at the station.
2/ This tabulation supplements the requirements of Section 20.407 of 10 CFR Part 20.
3/ A single submittal may be made f or a multiple unit station.
BRUNSWICK - UNIT 2 6-16 Amendment No.
ADMINISTRATIVE CONTROLS ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (Continued) c.
Results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the OFFSITE DOSE CALCULATION MANUAL, as well as summarized and tabulated results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.
In the event that some individual results are not available f or inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing r esults. The missing data should be submitted as soon as possible in a supplementary report.
d.
A summary description of the radiological environmental monitoring program.
least two legible maps 4/ covering all sampling locations keyed to e.
At a table giving distances and directions f rom the centerline of one reactor.
f.
The results of licensee participation in the Interlaboratory Comparison Program, required by Specification 3.12.3.
g.
Discussion of all deviations f rom the sampling schedule of Table 3.12.1-1.
h.
Discussion of all analyses in which the LLD required by Table 4.12.1-1 was not achievable.
b SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6.9.1.8 Routine radioactive effluent release reports covering the operation of the f acility during the previous 6 months of operation shall be submitted within the time periods specified in Specifications 6.9.1.9 and 6.9.1.10 below.
6.9.1.9 Die portion of the Semiannual Radioactive Ef fluent Release Reports to be submitted within 60 days after January 1 and July
- of each year shall include the f ollowing:
a.
A summary of the quantities of radioactive liquid and gaseous effluents and solid waste releasel from the facility as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactivity Fbterials in Liquid and Gaseous Ef fluents f rom Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis similar to the f ormat of Appendix B thereof.
4/ One map shall cover stations near the SITE BOUNDARY; a second map shall include the more distant stations.
5/ A single submittal may be made f or a multiple unit station.
The submittal should combine those sections that are common to all units at the station.
BRUNSWICK - UNIT 2 6-17 Amendment No.
ADMINISTRATIVE CONTROLS SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (Continued) b.
The information specified below for each class of solid waste (as defined by 10 CFR Part 61, when implemented) shipped offsite during the report period:
1.
Container volume, 2.
Total curie quantity (specify whether determined by measurement or estimate),
3.
Principal radionuclides (specify whether determined by measurement or estimate),
4.
Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms),
5.
Type of container (e.g., LSA, Type A, Type B, Large Quantity),
and 6.
Solidification agent or absorbent (e.g., cement, urea i
formaldehyde).
c.
A list and description of unplanned releases f rom the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.
d.
Any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) or the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land use census pursuant to Specification 3.12.2.
6.9.1.10 The portion of the Semiannual Radioactive Ef fluent Release Report to be submitted within 90 days after January 1 of each year shall include the following:
a.
An annual summary of hourly meteorological data collected over the previous calendar year. This annual summary may be either in the f orm of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the f orm of joint f requency disgyibutions of wind speed, wind direction, atmospheric stability. --
i b.
As assessment of the radiation doses due to the radioactive liquid and gaseous effluents released f rom the station during the previous calendar year.
--6/
In lieu of submission with the Semiannual Radioactive Ef fluent Release Report,~the licensee has the option of retaining this summary of required meteorological data in a file that shall be provided to the NRC upon request.
BRUNSWICK - UNIT 6-18 Am ndment No.
e
ADMINISTRATIVE CONTROLS MONTHLY OPERATING REPORT 6.9.1.11 Routine reports of operating statistics and shutdown experience, l
including documentation of all challenges to main steam system safety / relief
. valves, shall be submitted on a monthly basis to the Of fice of Inspection and
,E-
-Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Regional Of fice, to arrive no later than the tenth of each month following the calendar month covered by the report.
~ REPORTABLE OCCURRENCES 6.9.1.12 '1he REPORTABLE OCCURRENCES of ' Specifications 6.9.1.13 and 6.9.1.14 l
~
below,' including corrective actions and measures to prevent recurrence, shall
_ be reported to the NRC. Supplemental reports may be required to fully describe final resolution of occurrence.
In case of corrected or supplemental reports, a licensee event report shall be completed and reference shall be made to the original report date.
PROMPT NOTIFICATION WITH WRITTEN FOLLOW-UP 6.9.1.13. The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l
by telephone and confirmed by telegraph, mailgram, or facsimile transmission.
'to.the Director of the Regional Of fice, or his designate, no later than the first working day following the event, with a written. follow-up report within two weeks. The written follow-up report shall include, as a minimum, a completed copy of a-licensee ever.t report form.
Information provided on the licensee event. report f orm shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.
a.
Failure of the reactor protection system or other systems subject to limiting safety system settings to initiate the required protective function by the time a monitored parameter reaches the setpoint specified as the limiting safety system setting in the technical specifications.or f ailure to complete the required protective function.s i
b.
Operation of the unit or aff ected systems when any parameter or operation subject to a limiting condition for operation is less conservative than the least conservative aspect of the limiting 1
condition for operation established in the technical specifications.
A c.
Abnormal degradation discovered in f uel cladding, reactor coolant pressure boundary, or primary containment.
d.
Reactivity anomalies involving disagreement with the predicted value of reactivity balance under steady state conditions during power operation greater than or equal to-1% ek/k; a calculated reactivity balance indicating a SHUTDOWN MARGIN less conservative than specified in the techcical specifications; short-term reactivity increases that
_ correspond to a reactor period of less than 5 seconds or, if subcritical, an unplanned reactivity insertion of more than 0.5%
ak/k; or occurrence of any unplanned criticality.
BRUNSWICK - UNIT 2,
6-19 Amendment No.
ADMINISTRATIVE CONTROLS PROMPT NOTIFICATION WITH WRITTEN FOLLOW-UP (Continued)
Failure or malfunction of one or more components which prevents or e.
could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the SAR.
f.
R3 rsonnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems required to cope with accidents analyzed in the SAR.
g.
Conditions arising from natural or man-made events that, as a direct result of the event, require plant shutdown, operation of safety systems, or other protective measures required by technical specifications, h.
Errors discovered in the transient or accident analyses or in the methods used for such analyses as described in the safety analysis report or in the bases for the technical specifications that have or could have permitted reactor operation in a manner less conservative than assumed in the analyses, i
1.
Berformance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or technical specifications bases ; or discovery during plant life of conditions not specifically considered in the safety analysis report or technical specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition.
THIRTY-DAY WRITTEN REPORTS 6.9.1.14 The types of events listed below shall be the subject of written l
reports to the Director of the Regional Office within thirty days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a licensee event report form.
Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.
Reactor protection system or engineered safety feature instrument a.
settings which are found to be less conservative than those established by the technical specifications but which do not prevent the fulfillment of the functional requirements of affected systems.
b.
Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.
Observed inadequacies in the implementation of administrative or c.
procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.
BRUNSWICK - UNIT 2 6-20 Ame dment No.
n
AD11NISTRATIVE CONTROLS THIRTY-DAY WRITTEN REPORTS (Continued) d.
M) normal degradation of systems other than those specified in 6.9.1.13.c above designed to contain radioactive material resulting l
' f rom the fission process.
SPECIAL REPORTS 6.9,2 Special reports shall be sdamitted to the Director of the Of fice of Inspection and Enforcement Regional Office within the time period specified for each report. These reports shall be sdamitted covering the activities
. identified below pursuant to the requirements of the applicable reference
- specification:
a.-
Inoperable seismic monitoring instrumentation, Specification 3.3.5.1.
b.
Seismic event analysis, Specification 4.3.5.1.2.
c.
Reactor coolant specific activity analysis, Specification 3.4.5.
d.
Fire detection instrumentation, Specification 3.3.5.7.
i e.
Fire suppression systems, Specifications 3.7.7.1, 3.7.7.2, and-3.7.7.3.
f.
ECCS actuation, Specifications 3.5.3.1 and 3.5.3.2.
g.
Fire barrier penetration, Specification 3.7.8.
h.
Liquid Ef fluents Dose, Specification 3.11.1.2.
1.
Liquid Radwaste Treatment, Specification 3.11.1.3.
j.
Dose -- Noble Cases, ' Specification 3.11.2.2.
k.-
Dose - Icdine-131, Iodine-133, Tritium, and Radionuclides in Particulate Form, Specification 3.11.2.3.
1.
Gaseous Radwaste Treatment, Specification 3.11.2.4.
m._
Ventilation Exhaust Treatment, Specification 3.11.2.5.
n.
Total Dose, Specification 3.11.4.
o.
Monitoring Program, Specification 3.12.1.b.
6.10 RECORD RETENTION Facility records shall be retained in accordance with ANSI-N45.2.9-1974.
6.10.1 The following records shall be retained for at least five years:
a.
Records and logs of f acility operation covering time interval at each power level.
BRUNSWICK - UNIT 2 6-21 Amendment No.
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ADMINISTRATIVE CONTROLS-
-RECORD RETENTION (Continued) b.
Records and logs of principal maintenance activities, inspections.
repair, and replacement of principal items of equipment related to nuclear safety.
c.
All REPORTABLE OCCURRENCES submitted to the Commission.
d.
Records of surveillance activities, inspections, and calibrations required by these ~ Technical Specifications.
e.
Records of changes made to Operating Procedures.
f, Records of radioactive shipments.
g.
Records of sealed source and fission detector leak tests and results.
h.
Records of annual physical inventory of all sealed source material of record.
6.10.2_ The following records shall be retained for the duration of the Facility Operating License:
a.
Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.
b.
Records of new and irradiated fuel inventory, fuel transfers, and assembly burnup histories, c.
Records of facility radiation and contamination surveys.
1 d.
Records of radiation exposure for all individuals entering radiation control areas.
e.
Records of gaseous and liquid radioactive material released to the environs.
f.
Records of transient or operational cycles for those facility components identified in Table 5.7.1-1.
g.
Records of reactor tests and experiments.
h.
Records of training and qualification for current members of the plant staff.
i.
Records of in-service inspections performed pursuant to these Technical Specifications.
J J.
Records of Quality Assurance activities required by the QA Manual.
k.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.
BRUNSWICK - UNIT 2 6-22 Ame dment No.
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AININISTRATIVE CONTROLS RECORD RETENTION (Continued) b 1.
Records of meetings of the PNSC and of the previous offsite review
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organization, the Company Nuclear Safety Committee (CNS).
~
Records of analyses required by the radiological environmental m.
monitoring program.
- x Records for Environmental Qualification which are ' covered under the n.
provisions of paragraph 6.16.
6.11 RADIATION PROTECTION PROGRAM 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 sigrial" 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 ertrance thereto sh'all be controlled by requiring issuance of a Radiation Wor 4 Permit *. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
A radiation monitoring device which cont'.nuously indicates the a.
radiation dose rate in the area.
b.
A radiation monitoring device which corc:inuously integrates the ;
radiation dose rate in the area and alarms when a preset integratad dose is received.
Entry into such areas with this monitoring d'c' rice may be made af ter the dose rate level in the area has been
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established and personnel have been made knowledgeable of it.
An individual qualified in radiation protection procedures who is c.
equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the f requency specified by the facility ' Health Physicist in the Radiation Work Permit.
i s
- Health Physics personnel shall be exempt f rom the RWP issuance requirkaenti, ' ~
during the performance of their assigned radiation protection duties,'
provided they comply with approved radiation protection procedures Mor entry into high radiation areas.
1 BRUNSWICK - UNIT 2 6-23 Amendment No.
ADMINISTRATIVE, CDNTROIN i
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E HIGH RADIATION AREA (Continued).
- & )< D; jh a
p 6.12.2 The requirements of 6.12.1, above, shall also apply to each high
( /
radiation area in which the intensity of radiation is greater than 1000
,(o j rran/hr. NIn addition, locked doors shall be provided to prevent unauthorized
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4 entry'into such areas end the keys shall be maintained under the administrative c'hntrol of the Shif t Foreman on duty and/or the Plant Health Physicist.
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6.13 0FFSITE DOSE C'ALCULATION MANUAL (ODCM) fN 6.13.1 lhe OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be approved by the 1
Connaission prior to implementation.
Licensee initiated [. hinges to the ODCM:
l 6.13.2 a.
Shall be submitted to the Commission in the Semiannual Radioactive Ef fluent Releape R$ port f or the period in which the change (s) was made effective.. This submittal shall contain:
1.-
Sufficienti detailed information to totally support rationale without benefit of additional or supplemental information.
s.
'Information submitted should consist of-a package of those pages of the ODCM to be~ changed with each page numbered and provided with an approval and date box,'t.ogether with appropriate analyses or. evaluations justifying the change (s),
i' s
2.-
A determination that the ch'anges will not reduce the accuracy or reliability of dose [ calculations or setpoint determinations;
- and, i
1 3.
. Documentation of the f act that the change has been reviewed and found acceptable by thei?NC'.
M'
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b.
Shall become effective upon review and acceptance by the PNSC.
6.14-PROCESS CONTROL-PROGRAM (PCP
( '
6.14.1 1he PROCESS CONTROL PROGRAM (PCP) shall be approved by the Commission prior to implementation.
6.14.2. Licensee initiated changes to the PCP:
Shill' be submitted to the Commission in the Semiannual Radioactive a.
Ef fluent Release Report f or the period in which the change (s) was made. 'This submittal"ghall contain:
istly detailed informatio. to tbthily support the 1.
rfic rationale for the change'without' benefic of additional or s
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supplemental inf ormation; A.
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v BRUNSWICK - UNIT 2 6-24 '
Amendment No.
s s.
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P ADMINISTRATIVE CONTROLS 6 14 PROCESS CONTROL PROGRAM (PCP) (Continued) 3 2.
A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; an' r
3.
Documentation of the f act that the change has been reviewed and found acceptable by the ?.NSC.
b.
Shall become eff ective upon Ireiew and acceptance by the PNSC.
MAJ0P uaNGES TO LIQUID, CASEOUS. AND SOLID WASTE TREATltENT SYSTEN 6.15 6.15.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid):
/
a.
Shall be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the evaluation was
)
reviewed by the PNSC. The discussion ob each change shall contain:
l s
1.
A summary of the evaluation that led to the determination that that change could be made in'accordance with 10 CFR Part 50.59.
2.
Sufficient detailed information to totally support the reason f or the change without benefit of additional or supplemental information; f
3.
A detailed description of the equipment.. components and processes involved and the interfaces with other plant systems; 4.
An evaluation of the change that shaws the predicted release of radioactive materials in liquid and gareous cffluents and/or l
quantity of solid waste that differ f ron those previously predicted in the license application and amendments thereto; 5.
An evaluation of the change that shows the expected maximum exrosure to an individual in the UNRESTRICTED AREA and to the general population that diff er f rom those previously estimated in the license application and amendments thereto; 6.
A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the l
actual releases f or the period prior to when the changes are to be made; 7.
An estimate of tLe exposure to plant operating personnel as a result of the change; and 7/
Licensees may chose to submit the information called f or in this Specification as part of the annual FSAR update.
BRUNSWICK - UNIT 2 6-25 Amendment No.
ADMINISTRATIVE CONTROLS MAJOR CHANGES TO LIQUID, CASEOUS, AND SOLID WASTE TREATMENT SYSTEN (Continued) 8.
Documentation of the f act that the change was reviewed and found acceptable to 'he PNSC.
b.
Shall become effective upon review and acceptance by the PNSC.
6.16 ENVIRONMENTAL QUALIFICATION A.
By no later than June 30, 1982 all saf ety-related electrical equipment in the facility shall be qualified in accordance with the provisions of:
Division of Operating Reactors " Guidelines f or Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors" (DOR Guidelines); or NUREG-0588 " Interim Staff Position on Environmental Qualification of. Safety-Related Electrical Equipment", December 1979.
Copies of these documents are attached to Order for Modification of Licen9e DPR-62 dated October 24, 1980.
B.
By no later titan-December 1,1980, couplete and auditable records must be
~
available and maintained at a central location which describe the environmental qualification method used f or all safety-related electrical equipment in sufficient detail to document. the degree of compliance with the DOR Guidelines or NUREG-0588. Thereaf ter, such records should be updated and maintained current as equipment 1,s replaced, further tested, or otherwise f urther qualified.
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BRUNSWICK - UNIT 2 6-26 Amendment No.
ENCLOSURE 3
SUBJECT:
Records Retention APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS 6.10.2.m PROPOSED TECHNICAL SPECIFICATION (TS) CRANCE: Revise TS 6.10.2, item a to "m.
Records of analyses required by the radiological environmental monitoring program."
JUSTIFICATION FOR PROPOSED CRANGE:
The purpose of this requirement is to require sufficient documentation to " permit evaluation of the accuracy of the analysis at a later date" and is to relegate these records to a role comparable to that of nuclear safety-ralated systems. Analyses of environmental data in no manner serves a protective role comparable to that of the engineered safety systems and,
~ therefore, should not require similar document retention requirements.
Environmental monitoring data is similar to the plant dosimetry data which are not required ~to meet the "later date" analysis specification for the life of the plant.
The record retention requirement is sufficiently vagut
. to produce a wide variance in interpretation as to what work record, lab note. and other data should be retained for the life of the plant.. Such a variance in
- interpretation places CP&L in an unduly vulnerable position for an NRC finding of noncompliance.
This can occur when an inspector identifies some obscure data set as being integral to effective reanalysis of the environmental data.
To retain records f or reanalysis during the life of the plant requires a complex archival and retrievable system. Such a system is expensive, unreliable, and provides no additional protective purpose for the public or the employees.
The existing quality assurance, quality control, calibration programs, the required Interlaboratory Compariron study coupled with NRC inspection, corporate QA, and internal technical / reviews of the programs and procedures-should be adequate and sufficient to assure the production of 4
high quality environmental radiation data and to detect system and program flaws as the data is generated. This effort should alleviate any need to require the retention of data other than the analytical results for the life of the plant.