ML20083J283

Suppl to 810728 & 821210 Applications for Amends to Licenses DPR-71 & DPR-62,incorporating Corporate & Plant Organizational Changes

ML20083J283
Person / Time
Site:	Brunswick
Issue date:	12/29/1983
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20083J287	List: ML20083J283 ML20083J338
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-2.B.3, TASK-2.K.3.03, TASK-TM LAP-83-569, NUDOCS 8401050198
Download: ML20083J283 (26)

Text

r Cp&L Carolina Power & Light Company DEC 2 01983 Director of Nuclear Reactor Regulation At tention: Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing thited States Nuclear Regulatory Commission Washington, DC 20555

. BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENTAL REQUEST FOR LICENSE AMENDMENTS AININISTRATIVE CONTROLS

Dear Mr. Vassallo:

SIMMARY In accordance with the Code of Federal Regulations, Title 10, Section 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests revisions to the Technical Specifications (TS) for the Brunswick Steam Electric Plant, Unit Nos. 1 and 2. The enclosed revisions supersede those changes provided in our July 28, 1981 submittal and our December 10, 1982 submittal concerning the Administrative Controls section of the Brunswick TS.

DISCUSSION By letters dated July 28, 1931 and July 10, 1981, CP&L submitted proposed revisions to the TS for Brunswick md H. B. Robinson Unit No. 2 (HBR), respectively, concerning changes to the corporate organization, the plant organization, and the Plant Nuclear Safety Committee (PNSC).

Subsequently, the Staff reviewed and approved (with changes) the HBR TS revisions, which were issued by Amendment No. 70. In response to discussions with the Staff regarding the HBR amendment, CP&L reviewed our July 28, 1981 submittal for Brunswick and prepared revisions to that document. Those revisions were submitted to the Staff by our letter dated December 10, 1982.

Following Staff review of the December 10, 1982 submittal, CP&L received a letter f rom the Staff dated April 21, 1983 that requested additional information concerning the proposed TS revisions. During the preparation of responses to this NRC request, changes were made to the proposed TS section to address the Staff's concerns. As a result of subsequent corporate and plant organizational changes, CP&L found it necessary to again revise the Administrative Controls section to incorporate those organizational changes. In addition, the forthcoming Radiological Ef fluent Technical Specifications (RETS) also include certain Administrative Controls section requirements that nee &d to be incorporated in this revised Administrative Controls section submittal.

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8401050198 831229 PDR ADOCK 05000324 P PDR i 411 Fayetteville Street

• P. O. Box 1551

• Raleigh, N. C. 27602 3 1

e D. B. Vassallo Enclosed is a revised Administrative Controls section for the Appendix "A" TS for each Brunswick Unit. These revisions supersede entirely the changes provided by our December 10, 1982 sd>mittal and provide for the following:

1) Inclusion of recent corporate and plant organizational changes. A summary of the plant organization is included in the enclosed responses to the April 21, 1983 NRC request for additional information (Enclosure 1).

2) Inclusion of additional NUREG-0737 Item I. A.I.3.2 guidance concerning minimum shif t crew composition.

3) Requirements' per NUREG-0737 Item II.K.3.3 for reporting safety / relief valve failures and challenges. Technical Specifications for this item were requested by the NRC in Generic Letter No. 83-02 dated January 10, 1983.

4) Requirements per NUREG-0737 Item II.B.3 for establishing, implementing, and maintaining an administrative program concerning post-accident sampling. Technical Specifications for this item were requested by the NRC in Generic Letter No. 83-36 dated Nova iber 1, 1983.

5) Requirements per NUREG-0737 Item I. A.1.3 concerning the limitation of nuclear power plant-staff overtime. Technical Specifications for this item were requested by the NRC in Generic Letter No. 83-02 dated January 10, 1983.

6) Administrative Controls requirements necessary to support the technical requirements of the RETS. These RETS Administrative Controls requirements were sd)mitted in our letter dated November 11, 1983 (Serial: LAP-83-510).

7) The inclusion of Operating License paragraphs 2.1 and 2.J for Brunswick-1 and Operating License paragraphs 2.F and 2.G for Brunswick-2 in the TS. Inclusion of these requirements in the TS and deletion of the above referenced paragraphs from the Operating Licenses provides consistency with the GE/BWR-4 Standard Technical Specifications.

Administrative revisions to the Brunswick Appendix "B" TS are not included in this submittal since that portion of the Appendix "B" TS is being deleted in conjunction with issuance of the RETS for the Brunswick Plant.

ADMINISTRATIVE INFORMATION Since this request is a supplement to our July 28, 1981 and December 10, 1982 requests, CP&L has determined that no additional license amendment f ee is required. The responses to the Staf f's April 21, 1983 request for additional information is provided in Enclosure 1. The revised TS J

D. B. Vassallo pages for Brunswick-1 are provided in Enclosure 2, and the revised TS pages for Brunswick-2 are provided in Enclosure 3. These revised TS pages have the changes indicated by vertical lines in the right-hand margins.

Should you have any questions concerning this ad)mittal, please contact our Licensing staff.

Yours very truly, Q .G)-

P. W. Howe Vice President Brunswick Nuclear Project WRM/ccc (9042WRM)

Enclosures cc: Mr. Dayne H. Brown Radiation Protection Branch Division of Facility Services Department of Human Resources Mr. D. O. Myers (NRC-BSEP)

Mr. J. P. O' Reilly (NRC-RII)

Mr. M. Grotenhuis (NRC)

P. W. Howe, having been first July sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

M &- -

Notary (Seal)

My commission expires: 3 o'tO 97

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ENCLOSURE 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION DATED APRIL 21, 1983 BRUNSWICK STEAM ELECTRIC PLANT

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NRC Request No. 1:

Page 6-2, Figure 6.2.2 - No basis o evaluation of the revised corporate organization was provided. Additid information is needed which provides an evaluation of the change and explains the differences between the proposed organization and that shown in the H. B. Robinson Technical Specifications.

CP&L Response:

The revised Brunswick organization is si:milar to the organization for the H. B. Robinson Plant; however, there are several differences in the organizations that are the result of Brunswick being a two unit f acility versus H. B. Robinson being a single unit facility. To facilitate the Staff's review of the proposed Brunswick Plant organization, we have enclosed a brief summary of the responsibilities of each of the management level positions shown in TS Figure 6.2.2-1 (see Attachment 1).

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Attachment 1 SIMMARY OF PLANT MANAGEMENT ORGANIZATION AND RESPONSIBILITIES Vice President - Brunswick Nuclear Project The Vice President - Brunswick Nuclear Project is responsible for all phases of site management, including site construction activities, site engineering, planning & scheduling, and plant operation. He is supported in these responsibilities by the plant General Manager, Manager - Brunswick Nuclear Project - Engineering & Construction, and the Director - Planning &

Scheduling. The Vice President - Brunswick Nuclear Project reports to the Executive Vice President - Power Supply, Engineering & Construction.

General Manager - Brunswick Plant The plant General Manager is responsible for all phases of plant management, including operation, maintenance, and technical supervision. He is responsible for adherence to all requirements of the Operating License and Technical Specifications. He is supported in these responsibilities by the Manager - Plant Operations, Manager - Technical & Administrative Support, Director - Regulatory Compliance, and the Assistant to the General Manager.

In the absence of the General Manager, either the Manager - Plant Operations or the Manager - Technical & Administrative Support will assume his authorities and responsibilities. The General Manager reports directly to the Vice President - Brunswick Nuclear Project.

Manager - Plant Operations The Manager - Plant Operations is responsible f or the operation and direct maintenance support of the two units, including refueling operations. In addition, he is responsible for the chemistry, radiation protection, and environmental monitoring programs at the plant. His responsibilities are accoeplished throigh those reporting to him, including the Manager -

Operations, the Manager - Maintenance, and the Manager - Environmental &

Radiation Control. The Manager - Plant Operations reports to the General Manager and may asstsee the responsibilities and authorities of the plant General Manager in his absence.

Manager - Operations The Manager - Operations is responsible for coordinating and overseeing the duties of the Operations-Superintendent. He is responsible for orderly, safe

, operations, turnovers, cogliance with operating instructions, and adherence to all requirements of the appropriate items of the Operating License and Technical Specifications. He is supported in these responsibilities by the Operations Superintendent.

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Qperations Superintendent The Operations Superintendent is responsible for safe operation of the two units,. adherence to all requirements of the appropriate items of the Operating License and Technical Specifications, ensuring operator training and retraining is provided, and ensuring that operating procedures are followed.

His responsibilities are accomplished through the various licensed operations I

personnel on each shift. The Operations Superintendent shall hold a Senior Operator's License. The Operations Superintendent reports to the Manager -

Operations.

Shif t Operations Supervisor i Each Shif t Operating Supervisor will be responsible for supervising plant operations and implementing the radiation protection program during his i shift. He is responsible for adherence to all requirements of the appropriate items of the Operating License and Technical Specifications. The Shift Operating Supervisor is responsible for all personnel assigned to each shif t, including operators, mechanics, electricians, E&RC technicians, and I&C

technicians. His responsibilities are accomplished through the various foremen and lead personnel assigned to each shif t. The Shift Operating Supervisor shall hold a Senior Operator's License. The Shif t Operating Supervisor reports to the Operations Superintendent.

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Manager - Maintenance The Manager - Maintenance is responsible for ensuring that equipment, instrumentation, controls, and mechanical and electrical systems are maintained at optimum dependability, safety, and operating efficiency to l comply with plant Technical Specifications, security, radiation control, and regulatory requirements. He accomplishes this by planning, directing, and controlling a highly skilled staff; inspecting maintenance work; providing effective maintenance procedures and standards; and developing improvements in the Prevention and Corrective Maintenance Programs. Se is assisted in these functions by Maintenance Supervisors and Engineers. The Manager - Maintenance

- reports to the Manager - Plant Operations.

Manager - Environmental & Radiation Control l The Manager - Environmental & Radiation Control is responsible for providing the environmental & radiation control support necessary for the operation of the plant within plant Technical Specifications and applicable state and federal regulations. His responsibilities are accomplished through a staff including the Environmental & Chemistry Supervisor, the Radiation Control Supervisor, and specialists. The Manager - Environmental & Radiation Control reports to the Manager - Plant Operations.

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Manager - Technical Support i

The Manager - Technical Support is responsible for providing technical support for the efficient operation of the Brunswick plant in a manner contributing to high plant efficiency, reliability, and availability. His responsibilities are accomplished through his staff of Engineering personnel. The Manager -

Technical Support reports to the Manager - Technical & Administrative Support.

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i Director - Planning & Scheduling The Director - Planning &' Scheduling is responsible for planning, scheduling, '

and coordinating long and short-term outages; backfit and modification work to 4

provide the lowest downtime and/or least interference with plant operations I and to maintain radiation exposures ALARA.. His is supported in these activities by a staff of engineers. The Director - Planning & Scheduling l reports to the Vice President - Brunswick Nuclear Project.

! Director - Regulatory Compliance The Director - Regulatory Compliance is responsible for providing regulatory support for plant efforts to comply with regulatory (NRC), NSAC, and Corporate Nuclear Safety requirements as well as INPO guidelines. This is accomplished by coordinating and following on-site NRC, CNS, QA/QC, INPO, and NSAC activities, inspections, commitments, and responses and by resolution of concerns. He ensures that commitments are met, responses which accurately i depict the plant's position are submitted, reportable occurrences are detected and reported, documentation is maintained, anc. apport for Technical Specifications and/or revision is provided. The Director - Regulatory

' Compliance reports to the plant General Manager.

Manager - Technical & Administrative Support The Manager - Technical & Administrative Support is responsible for providing '

. technical & administrative support necessary for efficient plant operations in the areas of Engineering, Cost Control, plant Office Services, Document Control, Emergency Preparedness and plant Security. His responsibilities are accomplished through his staff, including the Manager -. Technical Support and

Director - Administrative Support. The Manager - Technical & Administrative Support reports to the plant General Manager.

Director - Administrative Suppcet The Director - Administrative Support is responsible for providing Administrative support necessary for efficient plant operations in the areas of Cost Control, Emergency Preparedness, Security, Document Control, Office Services, Materials, and Industrial Engineering. He is supported in these areas by the Administrative Supervisor, Materials Control Supervisor, Document Control Supervisor, Security Specialist, and Project Engineer - Industrial Engineering. The Director, Administrative Support reports to the Manager -

Technical and Administrative Support.

Manager - Engineering & Construction The Manager - Engineering & Construction is responsible for site project engineering and construction activities. lHe is supported in these areas by the Resident Engineer - Brunswick Engineering Support Unit, and Brunswick Project Construction Manager. The Manager - Engineering & Construction reports to the Vice President - Brunswick Nuclear Project.

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W NRC Request No. 2:

Page 6-3, Figure 6.2.2 The reorganized plant organization shows the Manager, Environmental & Radiation Control reporting to the Manager Plant Operations. This reporting chain appears inconsistent with the NRC position of separation of radiation protection from operating pressures. Based on the Criteria of Regulatory Guide 8.8, Section C.1.b(3) and Regulatory Guide 8.10, Section C.1 3, the Brunswick Radiation Protection Manager (RPM) should have sufficient authority to enforce safe plant operations and be independent of operating, maintenance and technical support functions. This requires the ability to communicate promptly with an appropriate level of management about radiation safety matters. It is our position that the RPM should have direct lines of communications to the Plant's General Manager (either by directly reporting to him or by provision for bypassing the Manager, Plant Operations) to report on radiation safety matters. Your facility organization in Figure 6.2.2.1 should be revised to reflect this position.

1 CP&L Response:

The positions of Manager - Environmental & Radiation Control, Manager -

4 Maintenance, and Manager - Operations report to the Manager - Plant Operations. The objective of having these three disciplines work as an integral unit is to develop a close coordination of operations and maintenance activities with a constant emphasis on the Health Physics and ALARA programs.

As indicated in the enclosed proposed Technical Specifications, Section 6, Figures 6.2.2-1 and 6.2.2-2, the Manager - Environmental & Radiation Control has direct and open lines of communication with the plant General Manager, Manager - Corporate Health Physics, and the Manager - Radiological & Chemical Support for matters regarding the radiological health and safety of employees and the public. The Manager - Environmental & Radiation Control is charged with the responsibility and is encouraged to use these lines of communications to ensure the company policy for Health Physics and ALARA are implemented.

Carolina Power & Light Company believes that the above organization meets the l intent of the NRC's guidance, since the Manager - Environmental & Radiation Control does not report to the Manager - Operations or Manager - Maintenance' but reports to the next level of management, the Manager - Plant Operations.

This organization includes the additional check and balance of encouraging the l Manager - Environmental & Radiation Control to communicate directly to the plant General Manager and Corporate Managers in Health Physics matters and unresolved concerns.

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NRC Request No. 3:

In response to Generic Letter 82-12, please submit a proposed change to Section 6.2 in respect to the policy c1 overtime.

CP&L Response:

Enclosed are proposed Technical Specification (TS) revisions to address the NRC policy on limiting shift overtime in accordance with NRC Generic Letter No. 82-12 dated June 15, 1982 and NRC Generic Letter No. 83-02 dated January 10, 1983 The proposed TS revision provided herein (refer to proposed TS 6.2.2.g) meets the intent of the Staff TS guidance in Generic Letter 83-02 (NUREG-0737 Technical Specifications).

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NRC Request No. 4:

Page 6-8, Section 6.5.1 - This item should be revised to include provisions for assuring interdtsciplinary review, as necessary, and to limit authority for approval of reviewed items to predesignated high level managers.

CP&L Response:

The NHC concerns discussed above were raised during review of the H. B.

Robinson (HBR) Administrative Controls Technical Specifications (TS) revisions and are addressed on page 8 of the Safety Evaluation Report for HBR Amendment No. 70 (copy attached). During discussions with the Staff concerning the HBR TS request, CP&L proposed revisions to the request to address assurance of interdisciplinary review and limitation of approval authority for reviewed ,

items (refer to HBR Specification 6.5 1.1.4, copy attached). The HER revisions addressing the interdisciplinary review concern have already been incorporated in proposed Specifications 6.5.1.4, 6.5.1.5, and 6.5.2'.2 for Brunswick. The revisions addressing the predesignated approval concern are provided in proposed Specifications 6.5.2.4 and 6.5.2.6.

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8-However, we require that:

1 the qualificatinns of the pers:nnel performing tne review shall, as a nini .um, meet the qualification requiremer.ts for professional-technicai .wesonnel specified by Section c.? of'A"S: 315.1-1 971 .

2. the participants'shall collectively possess the background and qualifications in the subject matter under review to provide a ..

comprehensive, inter-disciplinary review .. .

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3. the Plant General fianager shall be responsible to review and

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approve the reports and recommendations developed by the reviewers and forward them to the independenc review grouo. We recogni::e that in order to fulfill this responsibility, the Plant General

?!anager may delegate some of these activities to other specific appropriate plant staff managers. This delegation must be in writing and specific to the particular review activity being performed.

We found that the proposed changes to the Robinson TS, as submitted by the licensee in its' July 10, 1981 letter to the NRC did not adequately address all of these three requirenents.

Recuirement 1 BytelephoneccEunicationthelicenseesubsecuentlyagreedtomooifyitsnew Section 5.5.1.5.1 to state that incivicuals cesignated for the two-party safety reviews shall have a Bacnelor of Science in engineering or relatec field or equivalent and two years related experience. This recuirement .eets

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6 .5 .1.1.3 Prior to approval, a second safety review shall be performed on all procedures, tests, or experiments that affect nuclear safety.

This review shall be performed by an individual other than :he individual who was the original preparer.

q 6 .5 .1.1.4 Following the two par:y review, procedures, tes:s, and experi=en:s '

and per:anen: changes thIereto (other than editorial o= .

typographical) which have been deter ined neither to involve an '

unreviewed rafety question as defined in 10CFR50.59(a)(2), nor a change to the Technical Specifications, shall be approved prior :o imple=enta: ion by one- of the following: . .

2. Plant General Manager, or designated alter $ ate, or .

b. The Manager of the functional area affected by the proceduras tests, and experiments and permanent changes thereto as previously designated by the Plant General Manager.

The individual approving the procedure, test, or experimen: or change : hereto shall be other than those who perfor=ed the required reviews.

The Plant General Manager" or other d' esignated =anager approving the review activities of the two-party review shall assure that the 3 l

reviewers collec:ively possess :he background and qualifica:icas in I

all of the disciplines necessary and i=portant to the specific review. To assure tha: the individuals selected for the :wo par:y I

i review are qualified and have the background necessary, :he Plan:

} General Manager shall a7 prove and =aintain a lis: of qualified persons. Included in this list will be individuals in addition to the first and second party reviewer whose expertise nay be necessary during :he review to assure that :he reviewers collectively possess the background and qualifica:icns in the disciplines necessary and inportant to :he specific review.

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The list will include the disciplines for which erch person is qualified.

6.5.1.1.5 Te:porary changes to procedures, tes:s. or experiments =ay be approved by two ne bars of the plant manage:ent staff, at least -=

one of whom holds a Senior Reac:or Operator License if such change does not enange the intent of the original rocedur'e, ~:est, or ,

experisent. Temporary changes shall be documented and, within 21 days of receiving temporary approval, be reviewed in accordance with specification 6.5.1.1.2, 6.5.1.1.3 and 6.5.1.1.4 and incorporated as a pirianent ' change or dele'ted. ' ~

6.5.1.1.6 Those procedures, tests, or experiments and ch,anges thereto tha: ,

cons:itute an unreviewed safety ques:1on, or involve a change to Technical Specifications shall be reviewed by the Plant Nuclear Safety Committee and submitted to the NRC for approval prior to implementation. All such procedures, tests, or experiments and changes shall be reviewed by the Corporate Nuclear Safety Section prior to implementation.

6.5.1.1.7 Procedures, tests, or experiments, which constitute a change to the FSAR shall also be reviewed by the Corporate Nuclear Safety See:1on. These reviews may be conducted af ter plant Management approval, and implementation may proceed prior to co=ple: ion of -

review as provided for by 10CFR50.59(a)(1).

6.5.i.2 Modifications 6.5.1.2.1 A safety analysis shall be prepared for all =edifica: ions that affec: nuclear safety. The analysis shall include a written decernina: ion of whether or not :he =odification is a change in the f acili:y as described in the FSAR, involves a change to the Technical Specification, or constitutes an unreviewed safety question as defined in 10CFR50.59(a)(2).

This analysis constitutes a first party saf ety review and =ay be accomplished by the individual who prepared the modification.

6.5-3 AMENDMENT NO. 70

f NRC Request No. 5:

Page 6-8, Section 6.5.2 - The Safety Review and Control function should contain provisions for the independent review of the primary items; not just for the review of the safety evaluations of those items.

CP&L Resoonse:

Enclosed are proposed Technical Specification (TS) revisions that contain provisions for the independent review of both the primary item and the associated safety evaluation (refer to proposed TS 6.5.2.2).

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NRC Request No. 6:

Page 6-12, Section 6.5 3.7 - The quorum statement should be changed to require a majority of the PNSC; i.e., the Chairman and four members.

CP&L Response:

Enclosed are revised Technical Specifications (refer to TS 6.5 3 7) which require a majority of Plant Nuclear Safety Committee (PNSC) members to be present in order to have a quorum for a meeting. The required majority has also been revised to reflect the addition of new individuals as PNSC members.

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NRC Request No. 7:

Page 6-12, Section 6.5 3.8.a. b. and c. - The wording needs to be clarified.

If it means the PNSC reviews only unreviewed safety questions, it is unacceptable; if the meaning is otherwise, then it needs to be clarified to provide for more explicit PNSC overview of the Safety Review and Control function.

CP&L Response:

By letter dated July 10, 1981 (Serial No. NO-81-1193), Carolina Power & Light Company (CP&L) proposed revisions to the H. B. Robinson (HBR) Administrative Controls Technical Specifications (TS) to address organizational changes and revised methods for accomplishing the safety review and control function. The NRC Staff concern discussed above was raised during review of the HBR Administrative Controls TS revision and is addressed on pages 4, 6, 7, 8, 9, 10, and 11 of the Safety Evaluation Report for HBR Amendment No. 70 (copy attached). During discussions with the Staff concerning the HBR TS request, CP&L proposed revisions to the HBR request to address three NRC stipulations. This modified HBR request is what CP&L used as the NRC-approved model on which to base the Brunswick TS revisions.

Among the requirements, HER TS 6.5.1.6.6.d requires the reviews of Specifications 6.5.1.1.6, 6.5.1.2.4, 6.5.1 3.1, and 6.5.1.4.1 to be performed by the Plant Nuclear Safety Committee (PNSC).

8 HBR TS 6.5.1.1.6 requires the PNSC to review "those procedures, tests or experiments and changes thereto that constitute an unreviewed safety question or involve a change to Technical Specifications."

• EBR TS 6.5.1.2.4 requires the PNSC to review " modifications that are determined to either constitute an unreviewed safety question, as defined in 10 CFR 50.59(a)(2), or a change to the Technical Specifications."

1. HBR TS 6.5.1.3.1 requires the PNSC to review "each proposed Technical Specification or Operating Licensing change."

HBR TS 6.5.1.4.1 requires the PNSC to review reports evaluating all violations of Technical Specifications.

Listed below are TS references for the HBR requirements discussed above and the corresponding proposed Brunswick TS references that fulfill the same requirement:

H. B. Robinson Brunswick TS 6.5.1.1.6 TS 6.5.3.8.a TS 6.5 3.8.b TS 6.5.1.2.4 TS 6.5.3.8.c TS 6.5.1 3 1 TS 6.5 3.3.d TS 6.5.1.4.1 TS 6.5 3.8.e (7079WRMkjr)

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6.5 Review and Audit

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The licensee ::ro::osed to eliminate the current TS recut. ements for review

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of certain activities by the Plant Nuclear Safety Committee (Pf!SC). It also oroposes that some, but not all, of the review requirstents that are eliminated frc= the required list,of PilSC reviews will be assigned to other plant staff personnel.

In order to specify these revised review requirements, the licensee proposed to extensively modify' a'nd res'tructure TS Section 6.5, Review and "'

Audit. '

It also proposed to eliminate TS Section 5.8, Procedures and to provice . .

all requirements concerning procedures in Section 6.5 5thereasSection6.5.1.

of the current TS describes the Plant Nuclear Safety Committee (PNSC) and lists 10 specific items (items 6.5.1.7a-j) of review responsibility, the proposed change reorganizes Section 6.5 around and to provide specific and more detailed requirements related to the preparation, review and approval of tne following activities:

Procedures, Tests and Exceriments (New Section 6.5.1.1)

Modifications (New Section 6.5.1.2)

Technical Specification and License Changes (New Section 6.5.1.3)

• Review of Technical Specification Violations (New Section 6.5.1.4) 6.5.1 Plant !!uclear Safety Committee (PNSC)

The licensee proposes to place this PNSC infor ation in new Section 6.5.1.5.

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6 6.5.1.4 Consultants - The licensee proposes to delete the information in

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nis section whicn states consultants shall be utilized as determined by : e pNS: Chairman. We do not believe t'his statement is necessary-or r.eeded and -

find its deletion acceptable.

J 6.5.1.6 Quorum - The current quorum required by this section is four members.

The licensee propos'es to place this quorum information in new Section 6.5.1.6.5 and to retain this same quorum of four members. We note that for most plants -

the current quorum requirement is five members. However, it is not our practice to require that licensees modify their TS to meet the latest, mos:

recently developed, or more stringent requirements each time they request a TS. change. Since the current quorum requirement for Robinson is four memoers, we accept this same quorum in the revised TS.

6.5.1.7 Responsibilities - The licensee has proposed in new Section 6.5.1.1 on precedures, Tests and Experiments and 6.5.1.2 on Modi'ications to specify a new requirement that a two-party review be performed prior to approval of w r e - - ,Tv - - - - - , e

- - c c procedures, tests, exceriments and plant modifications. This two-party review will rovide a written safety analysis including a determination of whether or not -~.e activity involves a change in the facility as described in the FSAR, "

a change o the TS or constitutes a'n unreviewed safety question.-

• The current TS Sections' 6.S.I.7a, b and d specify that the PNSC be responsible for review of all proposed procedures , tests, experiments and plant modifica-tions that affect nuclear safety. The licensee has proposed that procedures, tests, experiments and plant modifications that do not constitute an unreviewed -

safety' question need not be reviewed by the PNSC. It proposed instead to require only the two-party review as discussed above and require approval prior to implementation by (1) the Plant General Manager or the Manager of the functional areas affected in the case of procedures, tests and experiments and by (2) the Plant General Manager or the Manager of Technical Support in the case of plant modifications.

It has also proposed that in the absence of any of these three, an alternate designated in writing by the Plant General Manager could approve these ,.

activities prior to implementation.

It is acceptable to us to have all of the currently required onsite review and investigative functions handled by a single committee (PNSC) as required by the current TS or to have only parts of the onsite review and investigative

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functions perforned by a committee and the 6emainder ::erformed by plant

, organi:stional units or ;;ersonnel as is being proposed by -he licensee, i .

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However, we require that:

1. the qualifications of the personnel performing ne review shall, as a nininum, meet the qualification requirements for professional-technical personnel specified by Section 4.4 of* AtiSI til'S.I'-1971 .

2. the participants'shall collectively possess the background and qualifications in the subject matter under review to provide a ..

comprehensive, inter-disciplinary review . .

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3. the plant General fianager shall be responsible to review and approve the reports and recommendations developed by the reviewers and forward them to the independent review grouo. We recognize that in order to fulfill this responsibility, the plant General Manager may delegate some of these activities to other specific appropriate plant staff managers. This delegation must be in writing and specific to the particular review activity being performed.

We found that the proposed changes to the Robinson TS, as submitted by the licensee in its' July 10, 1981 letter to the .'1RC did not adequately address all of these three requirenents.

Recuirement i BytelegnenecomEunicationthelicenseesubsecuentlyagreedtomocifyitsnew Section 6.5.1.5.1 to state that individuals designatec 'or tne two-party safety reviews shall have a Bachelor of Science in engineering or relatec

k. field or equivalent and two years related experience. This requirement .eets

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-g-or exceeds the minimum qualifications specified in Section 4.4 of ANSI-N18.1-1971 and therefore is acceptable. The members of the PNSC are plant managers who are required to meet the qualifications for their particular management position as spaified by Sections 4.2.1, 4.2.2. 4.2.3 and 4.2.4 of ANSI-Ni8.1-1971 and are therefore acceptable. .

We also found that the proposed specification did not directly address the minimum qualification requirements for. alternates to .the PNSC. The licensee ..

has informed us orally that it tries to appoint alternates who meet the.

qualification requirements for the management position held by the member -

for whom they serve. However, the licensee subsequently agreed to add the following statement to the licensee's proposed new Section 6.5.1.6.3:

" Alternates shall as a minimum meet the qualifications specified for professional-technical personnel in Section 4.4 of ANSI-N18.1-1971."

We find this addition acceptable.

Recuirement 2 The proposed sections on two-party review do not address the need to assure e

• that reviewers collectively possess the qualifications in the subject matter under review to provide a comprehensive interdisciplinary review. However, during subsequent telephone communications the licensee agreec to add the following statement to the proposed new Sections 5.5.1.1. " and 6.5.1.2.3:

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The Plant General Manager or other designated manager approving the review activities of the two party review shall assure that the reviewers collectively possess the background and qualifications in all of ' het disciplines necessary and i=portant to the specific review. To assure that the individuals selected for the two party review are qualified and have the background necessary, the Plant General Manager shall approve and =aintain a list of qualified -

persons. Included in this list will be individuals in addition to the first and second party reviewers whose expertise may be necessary during the review to assure that the reviewers collectively possess the background and qualifications in the disciplines ne.essary and imporcant to the specIific r'aview. ihe list will include the disciplines for which each person is -

qualified.

We conclude this addition acceptable.

Recuirement 3

, We find the licensee's proposal in new Section 6.5.1.46 that procedures, tests and experiments be approved by the " manager of the functional area affected by the procedures, tests, or experiments" appears to leave it up to the manager to decide if he or she is the approval authority for the case in point. We believe that the subject matter that is to be approved by each manager should be previously specified by the Plant Manager. Therefore, we require that the following statement be added to new Section 6.5.1.1.4b: "as previously designated by the Plant General Manager." We have added this statement in At:achment 1.

Thelicensee,bytelephoneccmmuniha-icn,hassubsequentlyproposedtomocify new Sec-fons 5.5.1.1.4a and 5.5.1.2.3a to add tha the designated alterr.1:e to the Plant General Manager may approve two-par y reviews. It has also

( agreed to, delete new Sections 6.5.1.4c and 6.5.1.2.3c concerning appointment of alternates. We conclude that this change is acceptable.

The current TS Section 6.5.1.7e specified that the PflSC is res;:ensible for investiga$ ion of all violations of TSs. The licensee proposed to delete both (1) the requirement that all violations of TSs be investigated and (2) the requirement that the PilSC is responsible for the " investigation of TS -

violations. The licenjee proposed instead, in new Section 6.5.1.4.1, to require investigation of only those TS violations that (1) require 24-hour reports -

to the NRC or (2) involve safety lim [t violations. It also proposed that

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reports of these investigations be approved by the General Manacer or his ,

designee.

It did not state who performs the investigation or precares the reports.

Deletion of the requirement for investigation of all TS violations is not

[N acceptable. We require that all TS violations be investigated and that a report covering the evaluation and recommendations to prevent recurrence be prepared and submitted to the Manager - Corporate Nuclear Safety (independent review group) and to the Vice President - Nuclear Operations.

The license ~ e has subsequently informed us, by telephone co=unication, that

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it is (1) modifying its proposed Sections 6.5.1.4.1 and 6.5.1.6.6 to require that the PNSC perform a review of all violations to TSs. With these codi-fications we conclude that the proposed TSs require appropriate review of all TS violations and are acceptable.

The current TS Section 6.5.1.7f specifies that the pt!SC is resconsible for the review of facility operations to detect cotential sa#ety hatarcs. The licensee proposed to delete the requirement for revie> . facility operations

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NRC Request No. 8:

Page 6-14, Section 6.5.4.4 - The qualification requirements for the independent safety review program reviewers should include three years experience with operation and/or design of nuclear power plants.

CP&L Response:

The NRC concern discussed above was evaluated during review of the H. B. Robinson (HBR) Administrative Controls Technical Specifications (TS) revisions and is addressed on page 8 of the Safety Evaluation Report for HBR Amendment No. 70 (copy attached). During telephone discussions with the Staff concerning the EBR TS request, CP&L agreed to modify the proposed HBR TS 6.5.1.5.1 to require that independent safety reviewers have two years of related experience.

The proposed TS 6.5.1.2 for the Brunswick Plant requires that independent safety reviewers have "an academic degree in an engineering or related field or equivalent and two years related experience." This requirement meets or exceeds the minimum qualifications specified in Section 4.4 of ANSI-N18.1-1971.

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However, we require that

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the qualificatinns of the personnel perfcrming the review shall, as a nini um, ceet the qualifica:icn recuirements for professional-technical personnel specified oy Section 4.4 of' ANS: NI E .1 -1971

2. the participants'shall collectively possess the background and qualifications in the subject matter under review to provide a ..

comprehensive, inter-disciplinary review - .

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the plant General Manager shall be responsible to review and

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approve the reports and recommendations developed by the reviewers and forward them to the independent review group. We recognize that in order to fulfill this responsibility, the plant General Manager may delegate some of these activities to other specific appropriate plant staff managers. This delegation must be in writing and specific to the particular review activity being performed.

We found that the proposed changes to the Robinson TS, as submitted by the licensee in its' July 10, 1981 letter to the NRC did not adequately address all of these three requirenents.

Recuirement 1

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By telephene communication the licensee subtacuently agreed to mocify it Section 6.5.1.5.1 to state that indivicuals designated for :ne two-par:y safety reviews shall have a Bachelor cf Science in engineering or relatec field or equivalent and two years related experience.

This requiremen: T.ee ts

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or exceeds the minimum qualifications specified in Section 4.4 of ANSI-N18.1-1971 and therefore is acceptable. The members of the PNSC are plant mar. agers who are requirec to meet the qualifica-icr.s for their carticular 1-management position as speified by Sections 4.2.1, 4.2.2. 4.2.3 and 4.2.4

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of ANSI-M18.1-1971 and are therefore acceptable. .

We also found that the proposed specification did not directly address the minimum qualification requirements for. alternates to .the PNSC. The licensee ..

has informed us orally that it tries to appoint alterna:as who meet the.

qualification requirements for the management position held by the member -

for whom they serve. However, the licensee subsecuently agreed to add the following statement to the licensee's proposed new Section 6.5.1.6.3:

"Alterna es shall as a minimum meet the qualifications specified

( for professional-technical personnel in Section 4.4 of ANSI-N18.1-1971."

We find this addition acceptable.

Recuirement 2 The proposed secticns on two-party review do not address the need to assure a .

that reviewers collectively possess the qualifications in :ne subject matter under review to provide a comprehensive interdisciplinary review. However, during subsequent telephcne ccm=unications the licensee agreed :: add the following statement to the prop: sed new Sections 6.5.1.1.4 and 6.5.1.2.3:

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NRC Request No 9-l Page 6-15, Section 6.5.4.9 - The review responsibilities of the Corperate '

Nuclear Safety Section should be revised to include those items described in Section 4 3 of ANSI-N18.2, 1976 or Section 6.5.2 of the Standard Technical ,

Specifications.

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CP&L Resoonse:

Enclosed are proposed Technical Specifications (TS) revisions which revise the review responsibilities of the Corporate Nuclear Safety Section. ,

l Specifically, TS 6.5.4.9 has been revised to include all the review items I described in Section 4.3 of ANSI-N18.7,- 1976. This revised TS 6.5.4.9 is also consisteht with the list of review items provided in Standard Technical Specification 6.5.2.1.

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NRC Request No. 10:

Page 6-17, Section 6.5.5.2 - The audit frequency for the Security Plan and Fire Protection Program should be changed to once per 12 months to be consistent with NRC policy.

CP&L Response:

Enclosed are proposed Technical Specification (TS) revisions to address the audit frequency for the Security Plan and the Fire Protection Program. The proposed TS revision provided herein (refer to TS 6.5.5.2.f and 6.5.5.2.g) are consistent with the Staff guidance provided in Generic Letter 82-17 dated October 1, 1982 and Generic Letter 82-23 dated October 30, 1982.

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