Text

Proposed Tech Specs 6.5.5.2,adding Radiation Protection to List of Assessments Performed by Nuclear Assesment Section & 6.5.4.4 Rewording
	ML20087G081
Person / Time
Site:	Brunswick
Issue date:	03/06/1995
From:	; CAROLINA POWER & LIGHT CO.
To:	;
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ML20087G079	List: ML20087G077; ML20087G081;
References
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- ENCLOSURE 4 -

. BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 -

NRC DOCKET NOS. 50-325 & 50-324/ OPERATING LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT ,

PERFORMANCE BASED NUCLEAR ASSESSMENT PROGRAM TECHNICAL SPECIFICATION PAGES l

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9503100387 950306 '

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M INISTRATIVE CONTROLS

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$ E C"** ION RGE 6.1 RESPONSIBILITY............................................. 6-1 6.2 CRGANIZATION I 1

6.2.1 OFFSITE AND ONSITE ORGANIZATIONS.......................

4 6-1 6.2.2 rACItITr STAFF......................................... 61 l 6.2.3

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pe lt. s ..- _.._,us,, >.. . e V. . . . . a . . .-- . . . .. .......... ....

-a 6.2.4 SHIFT TECHNICAL ADVISOR.. ........................... 6-5 6.3 FACILITY STAFF OUALIFICATION............................... 6-5 6.4 TRAINING................................................... 6-5 6.5 REVIEW AND ADDIT 6.5.1 NUCLEAR SAFETY REVIEWERS............................... 6-6 6.5.2 SAFETY EVA123ATIONS AND INDEPENDENT REVIEW COFIROL 1

Safety Evaluations..................................... 6-6 I

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1 Procedures, Tests, and Experiments..................... 6-7 Nodifications.......................................... 6-7 I 4

Operating License / Technical Specifications............. 6-7 6.5.3 PLANT NUCLEAR SAFETY CCaetITTEE (PNSC) i Function............................................... 68 Cogos i t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-8

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Neeting Frequency...................................... 6-8 Quorum................................................. 6-8 l Activities............................................. 6-9 Authority.............................................. 6-10 Records................................................ 6-10 BRDNSWICK - UNIT 1 IIV Amendment No.156

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I 6@INISTRATIVE COffTROLS _..

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UCTION -

EA_GE 6.5 REVIEW AND AUDIT !

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".x2cn oe I 6.5.4 NUCLEAR ASSESSMENT 959AAndEatt INDEPENDENT REVIEW PROGRAM :

l Function................................................ 6-10 i Organization............................................ 6 10 Review.................................................. 6-11 Records................................................. 6-12 Se c~.T10 Q 6.5.5 NUCLEAR ASSESSMElff 99PAfIftBIfr AUDIT PROGRAM c .l

............................................... 6u n.x - ..................................................

6-13 l -Recorde . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14

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6-15 6.6 REPORTAnf2 EVENT ACTION.................................... 6-15 6.7 SAFETY f.mTT VIOLATION.................................... 6-15 6.R PEGa M-Et AND P W 85_".................................... 6-16 6.9 REPORTI14G REQUIREMIFFS Routine: Reports ........................................ 6-17 Startup Reports......................................... 6-17 Annual Reports.......................................... 6-18 Pereonnel Exposure and Monitoring Report................ 6-18 Annual Radiological Environmental Operating Report...... 5 Semiannual Radioactive Effluent Release Report.......... 6 20 ,

Monthly Operating Reports............................... 6 21 l Special Reporta......................................... 6-22 Core Operating Limits Reporlt............................ 6-22

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BRUNSWICK - UNIT 1 XV Amendment No. 156

> ' ADMINISTRATIVE CONT....S 6.f 3 70 JECT ASSESS" EAT "'M Dele 7Ec M CTION .. .

6.2.3.1 . PA Group Unit shall function to examine facility operating i

characterist NRC-issues. industry advisories. 'and other sources which may indicate areas rovina facility safety.

RESPONSIBILITIES 6.2.3.2 The PA Group Unit shall sonsible for maintaining surveillance of facility activities to provide indep. t verification

that these activities are performed correctly and that n errors are reduced as much- ;

as practical.

AUTHORITY 6.2.3.3 The PA Group Unit shall' make detailed reconmendations for ised procedures, equipment modifications, or other means of improving facil safety to the Manager - Nuclear Assessment Department.

6.2.4 SHIFT TECHNICAL ADVIS_0_R 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.

6.3 FACILITY STAFF 00ALIFICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum '

qualifications of ANSI N18.1-1971 for comparable positions". except for (1) the Manager - Environmental & Radiation Control who shall meet or exceed ,

the qualifications of Regulatory Guide 1.8. September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant during transients and accidents.

6.4 TRAINING '

6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Manager - Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of

. ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.

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(a) The requirement for the Manager - Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13, 1991.

l BRUNSWICK - UNIT 1 6-5 Amendment No. 169

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ADMINISTRATIVE CCNTRC._

PROCEDURES, "'ESTS. AND EXPERIMEffrS 6.5.2.4 The safety evaluation prepared in accordance with Specifications 6.5.2.1.a and 6.5.2.1.b above shall include a written determination,,with basis,'of whether or not the procedures, proposed tests and experiments, and changes thereto constitute an unreviewed safety question as defined in 10 CFR 50.59, or whether they involve a change to the Technical Specifications.

G.5.2.5 Following the nuclear safety review, the procedures required by Specification 6.8, other procedures that affect nuclear safety, proposed tests - ,

or experiments, and changes thereto (other than editorial or typographical) ' ;

which have been determined to not involve an unreviewed safety question as- '

defined in 10 CFR 50.59 or change to the Technical Specifications shall be approved prior to implementation by the General Manager - Brunswick Plant or his previously designated alternate.

MODIFICATIONS ,

6.5.2.6 The safety evaluation prepared in accordance with ,

Specification 6.5.2.1.c above shall include a written determination, with basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59, 6.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications shall be approved by the General Manager - Brunswick Plant or his previously designated alternats.

OPERATING LICENSE / TECHNICAL SPECIFICATIONS 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above shall include a written preliminary determination, with basis, of whether or not the proposed ,

Operating License / Technical Specification change (s) is a change in the I facility as described in the safety analysis report.

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the i associated proposed action, the request shall be:

a. Reviewed by the Plant Nuclear Safety Cesunittee in accordance with Specification 6.5.3.8.

b.

Sec b1 Reviewed by the Nuclear Assessment C ;_ C ;^;i;; in accordance l

with Specification 6.5.4.9.

BRUNSWICK - UNIT 1 6-7 Amendment No.156

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ADMINISTRATIVE CONTROLS

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6 . 5 . 3' PLANT NUCLEAR SAFETY C0KMITTEE (PNSC) l FUNCTION 6.5.3.1 As an effective means for the regular review, overview, evaluation, and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established.

6.5.3.2 The PNSC shall function through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION 6 .3.3 The PNSC shall be composed of the:

Chairman General Manager - Brunswick Plant

ember: l Manager - Technical Support ber: Manager - Operations Mem c: Manager - Maintenance Membe

Manager - Environmental & Radiat* n Control Member: Technical Assistant to Plant C eral Manager Member: Manager - QA/QC Member: Manager - Regulatory Comp *ance ALTERNATES 6.5.3.4 All alternate members hall be appoi d in writing by the PNSC Chairman to serve on a temporary asis; how er, no more than two alternates shall participate as members at an one t' .

6.5.3.5 All alternates, shall as a * *

, meet equivalent qualification criteria as specified for professi al-te ical personnel in Section 4.4 of ANSI N18.1-1971.

MEETINC FREQUENCY 6.5.3.6 The PNSC shall et at least once per calen r month and as convened by the PNSC Chairman his designated alternate.

QUORUM 6.5.3.7 The animum quorum of the PNSC necessary for the perfo nce of the PNSC activ* tes of the Technical Specifications shall consist of e PNSC Chairman r his designated alternate and four members including alt ates.

No mor than two alternates shall be counted toward meeting the minimu quorum

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req ement.

Or designated alternate.

Delete - Replxe wiTh a%checl INSERT BRUNSWICK - UNIT 1 6-8 Amendment No. 138

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INSERT TO PAGE 6-8. '

a COMPOSITION ,

6.5.3.3.. - The PNSC shall be composed of a Chairman and seven to nine members. ' The members shall be from the following functional areas: -

Operations Maintenance Engineering Health Physics / Chemistry '

Regulatory Affairs

- Nuclear Assessment 6.5.3.4^ Tlie PNSC Chairman, alternate Chairmen, members, and alternate members shall be designated in writing by the Director - Site Operations. Members shall be individuals who are unit manager level or above from the site management !

organization. Alternate members shall, as a minimum, meet equivalent qualification criteria as specified in Section 4.4 of ANSI N18.1-1971 for- !

. professional-technical personnel. !

OUORUM

-6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of '

these Technical Specifications shall consist of the Chairman (or his designated. !

alternate) and four members (including alternates). ;

6.5.3.6 No more than two alternates shall be counted toward meeting the quorum !

requirement or participate as voting members .,f Ae PNSC at any one time.' l MEETING FREOUENCY 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the l PNSC Chairman or his designated alternate. l

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'DMINISTRATIVE A CONTR0u

' ACTIVITIES 6.5.3.8 -The PNSC activities shall-include the.following: ,,

a. Review of all procedures required by Specification 6.8 and changes-thereto (and any other procedures and changes thereto). an which constitute an unreviewed safety question or involve ~y of a change to the Technical Specifications, prior to implementation.

b. ' Review of all propos'ed tests or experiments that constitute an unreviewed safety question or. involve a change to the Technical 1 Specifications, prior to implementation.

c. Review of all proposed modifications that constitute an unreviewed I safety question or involve a change to the Technical Specifications, prior to implementation.

d. Review of all proposed changes to the Technical Specifications or 1 Operating License, prior to isplementation.

e. Review of reports on violations of Technical Specifications-including reports covering evaluation and recommendations to prevent recurrence to the Manager - Brunswick Nuclear Pres'eet and t; tM ".:n:;;r ";-?;;r .";xnr rt. 0;;;;. ; r.t. rkuT

f. Performance of special reviews, investigations (or analyses), and reports thereon as requested by the Manager - Nuclear Assessment se'~5Ed"

g. Review of all REPORTABLE EVENTS.

h. Review of facility operations to detect potential nuclear safety hazards.

1. Annual review of the Security Plan.

J. Annual review of the Emergency Plan,

k. Review of accidental. unplanned, or uncontrolled radioactive release including the preparation of reports cc.ering evaluation, reconnendations and disposition of the corrective action to srevent recurrence and the forwarding of these re 4anager - BrunswickP Nuclear P iEuT. ;r

-d tM ".:n:; ports

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-1. Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

nr. Review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Nuclear Assessment Sect. io9 i

BRUNSWICK - UNIT 1 '6-9 Amendment No. 169

e ADMINISTRATIVE CONTROLS AUTHORITY 6.5.3'.9 If there is a disagreement between recommendations of a majority of the PNSC and the actions contemplated by the General Manager - Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the

" n , .. - Brunswick Nuclear Pre ret - ' - '? ire ?- rid--! *'cl--- fr-rir::.

, ThecoursedeterminedbytheGkneralManager-BrunswickPlanttobethemost

( conservative shall be followed.\ p g W ce Prec,;,cire9T RECORDS ,

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6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that, at a minimum, document the results of all PNSC activities perforined under the '

revisions of these Technical Specifications. Copies shall be provided to the l 46emages - Brunswick Nuclear See9een and the Manager - Nuclear Assessment Depeeemene. PLaJT l SecTion Sect orJ 6.5.4 NUCLEAR ASSESSMENT BRIERMERFF INDEPENDENT REVIEW PROGRAM l !

FUNCTION SCiti iod I 6.5.4.1 The Nuclear Assessment Sepasement shall function to provide l ,

independent review of significant plant changes, tests, and procedures; verify that REPORTABLE EVENTS are investigated in a timely manner and corrected in a. ,

manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day-to-day observer.

ORGANIZATION gog,,] [g gpec;g;C r 6.5.4.2 'Ihe ndividuals assigned responsibility for independent reviews shall be :;:rific' _- t:" " r' disciplines. .These individuals shall collectively I have the experience and competence required to review activities in the following areas: '

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy , ;

e. non-destructive testing i f, instrumentation and control

g. radiological safety !

h. mechanical and electrical engineering

i. administrative controls BRUNSWICK - UNIT 1 6-10 Amanckment No.156

. g ADMINII'"RATT7E COFI" S T f ORGANIZATICIT (Continued)

j. seismic and environmental ,

k. quality assurance practices .

1. Other appropriate fields ircrri : d rie "r " 2-"r " r- rrirtir: :d .

2; zin: ; - .: ;1z1. -

6.5.4.3 The Manaaer . Nuclear Assessment ke7.' ow .

d' espesement shall have ak __ ; acheln l

degree in an engineering or related field and,- in addition, shall have a - "

minimum of ten years related experience, of which a =4n4== of five years shall be in the operation and/or design of nuclear power plants. .i bachelors dhdivideals peMN* m3 I 6.5.4.4 Thevindependent safety reviewpoogueer-woveesese-shall have ab ' l degree in an engineering or related field or equivalent and, in ,

addition, shall have a mini == of five years related experience.

6.5.4.5 An individual may possess competence in more than one specialty area. j If sufficient expertise is not available within the Nuclear Assessment

8eposeneme, cospetent individuals from other Carolina Power & I.ight Cospany organizations or outside consultants shall be utilised in performing

'Sektaandependent reviews and investigations. ReMace uth 4.5N.6 attnehed 3 - -

6.5.4.7 Independent safety reviews shall be performed by individuals not directly involved with the activity under review or responsible for the i activity under review, i

SecTioki .

6.5.4.8 The Nuclear Asseemsent Beyesenset independent safety review program l l shall be e m eted in accordance with written, approved procedures.

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" I EeM dTh Ned 6.5.4 9- 12 (aTTorbeM l 6.5.4.9 Nuclear Assessment Department shall perform reviews of the

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following:

a. The safety a tions for 1) changes to procedures required by' Specification 6.8, modifications'of equipment or systems, and j

3) tests or expe::iment t constitute a change to the safety analysis report to verify ]

such actions did not constitute an unreviewed safety question or ve a change to the Technical ,

Specifications. Implementation may - eed prior to cospletion of this review.

b. P:oposed changes to procedures required by Spec tion 6.8, and proposed modifications that constitute an unrevie ety question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation.

BRUNSWICK - UNIT 1 6-11 n==aammat No. 156 d

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+- '6.5.4.6 The documents submitted under 6.5.4,9 shall be reviewed by individuals -

. meeting the_ requirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines - ~!

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are encompassed. Multiple reviews will be conducted on documents where - '

required to meet' applicable disciplines of 6.5.4.2. ;

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\rvirw(Continued) g l e te $ .r, 5.'(. 9 - 12 a R ot d d -

. Proposed tests or experiments that involve'an unreviewed safety

question as defined in 10 CFR 50.59 or a. change to the :'echnical Specifications, prior to implementation.

d. oposed changes to the Technical Specifications and Operating Li noe.

e,

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viola 'ons of applicable codes,. regulations, orders, Technical !

Specifi tions, license' requirements, and internal procedures or :!

instruct a having nuclear safety significance.

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f. Significant erating abnormalities or deviations from normal and '

espected per ce of plant safety-related structures, systems, or components.

g. Reportable events, t

h. Reports and minutes the PNSC. !

i. Any other matter involv g safe operation of the nuclear power plant j that the Manager - Nuclea Assessment Department deems appropriate for l consideration or which is ferred to the Manager - Nuclear Assessment i Department by the on site ating organization or other functional ,

organisational units within C "clina Power & Light Company.

6.5.4.10 Review of items considered - 6.5.4.9 (e) through (i) above shall ;

include the results of any investigations p and the recommendations l resulting from these investigations to prevt t or reduce the probability of l recurrence of the event. ,

RECORDS ,

6.5.4.11 Records of Nuclear Assessment Department views, including l ,

recommendations and concerns, shall be prepared and 'stributed as indicated i below:

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a. Copies of documented reviews shall be retained in he Nuclear Assessment Department files. i

b. Re W ations and concerns shall be submitted to the neral Manager - Brunswick Plant and Manager - Brunswick Nucle Project, ;

j- within 14 days of completion of the review. <

c. A sussistion of Nuclear Assessment Department's recommendati and l concerns shall be submitted to the chairman / President; Execut Vice i President - Power Supply; Senior Vice President - Nuclear Gener ion; i Vice President - Nuclear Services; Manager - Brunswick Nuclear ;

Project; General Manager - Brunswick Plant; and others, appropriat j at least once every two months. l 1

BRUNSWICK - UNIT 1 6-12 A=an'tamat No.156 i l

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< INSERT TO PAGES 6-11 AND 6-12. d l

-6l5.4.9 REVIEW j The Nuclear Assessment Section shall perform reviews of the'following:

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a. 1 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 _ 1 Analysis Report which are completed without prior NRC approval under !

the provisions of 10 CFR 50.59(a)(1). These reviews are to. verify that: ' :

j such changes, tests, or experiments do not involve a change in'the Technical Specifications or an unreviewed safety question' as defined in - .j 10 CFR 50.59(a)(2). These reviews may be conducted after appropriate a management approval, and implementation may proceed prior to j completion of the review. ;

b. - Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or +

experiments, any of which involve a change in the Technical !

Specifications or an unreviewed safety question pursuant to }

10 CFR 50.59(a)(2) pnor to implementation. 't

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c. Proposed changes to the Technical Specifications or this Operating- !

License prior to implementation.~ 3 i

d. Violations, deviations and reportable events,'which require reporting to. l the NRC in writing, such as: ;

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l. violations of applicable codes, regulations, orders, technical l specifications, license requirements or internal procedures or - j instructions having safety significance. j t

2. significant operating abnormalities or deviations from normal or l expected performance of plant safety-related structures, systems, or -

l components, and >

3. REPORTABLE EVENTS'as specified in 10 CFR 50.73. l l

e. Any other matter involving safe operation of the nuclear power plant that ; ;

the Manager - Nuclear Assessment Section, deems appropriate for i consideration or which is referred to the Manager - Nuclear Assessment i Section, by the on-site operating organization, Plant Nuclear Safety l Committee (PNSC) or by other functional organizational units within i CP&L.

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INSERT TO PAGES 6-11 AND 6-12.

c RECORDS 6.5.4.10 Results of Nuclear Assessment Section independent safety reviews shall be documented and retained.

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2 l ArMmisTRArnT cruTnot.s secTion Assessin evT -

6 . 5 *. 5 NUCLEAR ASSESSMENT OEEAAGEE8EE-J.GDM PPOGFJui l cTren 8eplace edT,re SedTioN 6.5.5 tvITh o'TTcekcl 6.5. .1 The Nuclear Assessment Department shall function to perform audits of l fac11'ty activities specified in Specification 6.5.5.2.

AUDITS 6.5.5.2 Au !ts of facility activities shall be performed by the Nuclear Assessment De rtment. These audits shall encompass:

a. The confo ce of facility operation to provisions contained within the Techni specifications and applicable license conditions at least once p 12 months. j

b. The training and lifications of the entire facility staff at least once per 12 months

c. The results of action taken to correct deficiencies occurring in facility equipment, st tures, systems, or methods of operation that j affect nuclear safety at aut once per 6 months. '

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d. The verification of complian and implementation of the requirements l of the Quality Assurance Progr to meet the criteria of Appendix "B", j 10 CFR 50, at least once per 24 ths.

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e. The Emergency Plan and implementing rocedures at least once per 12 )

months.

f. The Security Plan and implementing proce res at least once per 12 months.

g. The Facility Fire Protection Program and impl nting procedures at least once per 12 months.

h. The radiological environmental monitoring program the results thereof at least once per 12 months.

i. The OFFSITE DOSE CALCDIATIONAL ICudUAL and implementing p cadures at least once per 24 months.

j. The PROCESS CONTROL PROGRAM and implementing procedures for p cessing and packaging of radioactive wastes at least once per 24 months, i

l BRUNSWICK - UNIT 1 6-13 Amendment No.156 l

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$n INSERT TO PAGE 6-13.

6.5.5 Nuclear Assessment Section Assessment Program 6.5.5.1 Assessments of facility activities shall be performed by the Nuclear Assessment Section. Assessments will be performance based and will be scheduled based on plant performance and importance to safety but at a frequency not to exceed 24 months. These assessments shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

b. The performance, training and qualifications of the entire facility staff.

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety,

d. The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix B,10 CFR 50.

e. Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant.

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g-f, The Radiological Environmental Monitoring Program and the results thereof.

f.g. The OFFSITE DOSE CALCULATION MANUAL and implementing-procedures.

p, The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.

6.5.5.2 Assesrments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable regulation. These assessments shall encompass:

a. Emergency Preparedness (per 10 CFR 50.54(t))

b. Security (per 10 CFR 50.54(p)) ,

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2238nri.717

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Af2rTNTETRATIVE t.uninuts '

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(Continued) Rephe, e dsm SetIsos : 6.5 5 6th ptTTndd 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 .

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ce per 12 months.

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Any ther area-of facility operation considered appropriate by the Manag - Nuclear Assessment Department.

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6.5.5.3 Personne ' performing the~ audits shall have access to the plant ,

operating records, i

BECQEDS 6.5.5.4 Records of. audit shall be prepared and retained. '

6.5.5.5 Audit reports one seed by 6.5.5.2 above shall be prepared, approved by the Manager - Nucl Assessment Department, and forwarded to the Executive vice President - Powe upply; Senior Vice President - Nuclear- .l Generations Manager - Brunswick lear Project; General Manager'--Brunswick '

Plant; and others, as appropriate, thin 30 days after cospletion'of the audit. t i

ADTHORITY 6.5.5.6 The Manager - Nuclear Assessment taant shall be responsible for the following: l

a. The' administering of the Nuclear Asses t Department Audit Program. l~

b. The approval of the individual (s) selected t conduct audits. l PERSONNEL >

6.5.5.7 Audit personnel shall be independent of the area a ted.

6.5.5.8 Selection of personnel for auditing assignments shall based on i experience or training that establishes that their qualificati are c - asurate with the cosplexity or special nature of the activit a to be audited. In selecting audit personnel, consideration shall be give to special abilities, specialized technical training, prior pertinent e rience, personal characteristics, and education.

6.5.5.9 Qualified outside consultants or other individuals independent fr tatose personnel directly involved in plant operation shall be used to augmen the audit teams when necessary. ,

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BRDNSWICK - UNIT 1 6-14 mnenne No.156

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independent fire protection and loss prevention inspection and audit shall be d at least. once per' 12 months utilizing .either .

qualified cifsite licensee 1 or an cutside fire protection firm. i 6.5.6.2 An inspection and audit of the fire prote d loss prevention program shall be performed by an outside qualified fire consu intervals no greater than 36 months. trE'T* '

6.6 REPORTABLE IVENT ACTION 6.6.1' The following actions shall be taken for REPORTABLE EVENTS: !

a. The Coestission shall be notified and a' report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part_50, and

b. Each REPORTABLE EVENT shall be r'eviewed by the Plant Nuclear Safety Ceautittee -- Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment -Beparement and the Managee - Brunsvick Nuclear -

r;;;;;;. SecTierJ Yice-PresMe9T bT 6.7 SAFETY ttw?T 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 j hours. , i YiCe-ffe%ckPN

b. The NRC Operations Center shall be notified telephone as.soon as j possible and in all cases within one hour. The Manager - Brunswick Nuclear T-% : = - ' " "-- ;:: 7 :?:_r 1 :: --- : 2:; _- - : shall l )

be notif d within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . l PL # !

c. A Safety Limit Violg( vice-PresNeJT ion Report shall be prepared. The report shall l I

be reviewed by the "-- r:1 "-- ;:: - Branswick Plant. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility ccaiponents, systems, or structures, and (3) correceive action taken to prevent recurrence.

Prese1<aT Vicho~1stion Report shall be submitted to the

d. The Safety L v Cosmission, the - Brunswick Nuclearj , and the Manager -

Nuclear Assessment Department within 14 days @of the violation. ;

St.c. Tion 1%r$

l 4

l BRDNSWICK - UNIT 1 6-15 Amendment No.156

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' ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued) ;

k. Records of reviews performed for. changes made to procedures or equipment or reviews of tests and esperiments pursuant to !

10 CFR 50.59.

t

1. Records of the service lives o'f all hydraulic and mechanical snubbers ;

referenced in Section.3.7.5 including the data at which the service life commences and associated installation and maintenance records. !

m. Records of analyses required by the radiological environmental [

monitoring program.

.n. Records of. % meetings'of the.PNSC, (0; :::in;: cf " ;z i: : cff

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0-Records of 'Iwdef%dduit Review '

6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for pet nel radiation protection shall be prepared consistent with the requis ents of 10 CFR Part 20 and shall be approved, maintained and adhered to r all operations involving personnel radiation exposure.

i 6.12 HIGH RADIATION AREA 6.12,1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203 (c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. 'Any individual or group of individuals permitted.to enter such areas shall be provided with or accompanied by one or more of the following: ,

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation senitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may.be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

Health Physics persacnol or personnel escorted by Health Physics personnel shall be exaspt from the RWP issuance requirement during the performance of thiir assigned radiation protection duties, provided they cosply with approved radiation protection procedures for entry into high radiation areas.

BRUNSWICK - UNIT 1 6-25 Amendment No.156

IN2EX ADMINISTRATIVE CONTROLS .

E.ISE P.A9I 6.1 k2SPONSIBILITY............................................. 61 6.2 CRGANI2ATION 6.2.1- OFFSITE AND ONSITE ORGANIZATIONS....................... E1 6.2.2 FACILITY STAFF......................................... 61 e

6.2.3 6 l'

._..__a.._.. ..... . ..... . .

_____.m.,..

.__m__... ...... . ... . .... .. . .... ..

4 ..u_a s__ _____ m.,_ . .... ..... . . . ... . .. .. ..... . .. ,

6.2.4 SHIFT TECHNICAL ADVISOR................................ 65 6.3 FACILITY STAFF OUALIFICATION............................... 6-5 6.4 TRAINING................................................... 6-5 6.5 REVIEW AND AUDIT 6.5.1 NDCLEAR SAFETY REVIEWERS............................... 66 6.5.2 SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONI'ROL Safety Evaluations..................................... 66 Procedures, Tests, and Experiments..................... 6 Modifications.................................. ....... 6-7 operating License / Technical Specifications............. 67 6.5.3 PLANT NUCLEAR SAFETY COMMITI'EI -(PNSC) f Function............................................... 6-8 Compos i t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 nat=-*=*--. _ _ _

___ ______ S*

Neeting Frequency...................................... 5-8 Quorum................................................. 5-8 Activities............................................. 5-9 i

Authority.............................................. 6-10 Records................................................ 6-10 1

l BRUNSWICK - UNIT 2 ,

XIV Amendment No.187 ;

e INOEX

@LMINISTRATIVE CONTPOLS . . _ ___ .

SECTION Eqq 6.5 REVIEW AND AUDIT (Continued)

SeuNi ced

, 6.5.4 NUCLEAR ASSESSMENT N INDEPENDE!TT REVIEW PROGRAM l Function................................................ 6-10 Organization............................................ 6-10 Review......... ........................................ 6-11 Records................................................. 6-12 S e.cT. io u 6.S.5 NUCLEAR ASSESSMENT 499NW9ENR' AUDIT PROGRAM l

r 6-12

. _ _=.n_ _m. ...............................................

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":::rd:............................................. ... 6-14

n t t : r i t / . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14 wt+ l- .____ _,

-,~.u

s. ___. ........................................... ..... 6-14 f

6.5.6 9 - . . -,... . .... ...... _._ _____ ...__.___..S ......... 6-15 6.6 RE PORTAB LE EVENT AcrION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 15 6.7 SAFETY LIMIT VIOLATION..................................... 6-15 6.8 PROCEDURES JRD PROGRAMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16 6.9 REPORTING REOUIREMENTS Routine Reports ........................................ 6-17 Startup Reports......................................... 6-17 Annual Reports.......................................... 6-18 Personne1 Exposure and Monitoring Report................ 6-18 l Annual Radiological Environmental Operating Report...... 6-19 l Semiannual Radioactive Effluent Release Report.......... 6-20 Monthly Operating Reports............................... 6-21 Special Reports......................................... G-22 Core Operating Limits Report............................ 6-22 l 1

1 1

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BRUNSWICK - UNIT 2 XV Amendment No.187

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ADM!NISTRATlVE CONTkuuS 6.2 3 "^'ECT ASSESS"E T '"9 Delet. ed

.N CTION 6.2.3.1 PA Group Unit shall function to examine facility operating characteristi .

RC issues. industry advisories. and other sources which may indicate areas for roving facility safety.

RESPONSIBILITIES 6.2.3.2 The PA Group Unit shall be r nsible for maintaining surveillance of '

facility activities to provide independent ification* that these activities :

are performed correctly and that human errors a educed as much as practical.

AUTHORITY 6.2.3.3 The PA Group Unit shall make detailed recomendations for sed procedures. equi fety to the Manager pment Nuclearmodifications, or other means of improving facili Assessment Department..

6.2.4 SHIFT TECHNICAL ADVISOR

[

6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity.to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe :

operation of the unit.

6.3 FACILITY STAFF OUALIFICATION 6.3.1 Each member of the facility staff shall meet or excp the minimum qualifications of ANSI N18.1-1971 for comparable positions '. except for (1) the !

Manager - Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8. September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant during transients and accidents. !

6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall .

be maintained under the direction of the Manager - Training (BSEP) and shall meet or exceed the re and Appendix "A"quirements and of 10 CFR Part 55.recommendations of Section 5.5 of ANSI N18.1-1971 !

i

^

nut iespunaiule i a - i ,- . c f f I C i ; ..

(a) The requirement for the Manager - Operations to hold or have held a senior ,

reactor operator license is exempted for a period of 18 months starting from June 13. 1991.

BRUNSWICK - UNIT 2 6-5 Amendment No. 200 l

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- ADMINISTRATIVE CONTROw PROCEDURES. "'ESTS . AND EXPERIMENTS 6.5.2.4 The safety evaluation prepared in accordance with Specifications 6.5.2.1.a and 6.5.2.1.b above shall include a written determination, with basis, of whether or not the procedures, proposed tests. !

and experiments,-and changes thereto constitute an unreviewed safety question !

as defined in 10.CFR 50.59, or whether they involve a change to the Technical Specifications.

i 6.5.2.5 Following the nuclear safety review, .the procedures required by i Specification 6.8, other procedures that affect nuclear safety, proposed tests !

or experiments, and char.ges thereto (other than editorial or typographical) !

which have been determined to not involve an unreviewed safety question as j defined in 10 CFR 50.59 or change to the Technical Specifications shall be i approved prior to implementation by the General Manager - Brunswick Plant or I his previously designated alternate.

MODIFICATIONS 6.5.2.6 The safety evaluation prepared in accordance with Specification 6.5.2.1.c above shall include a written determination, with-basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical >

Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.

6.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined ,

in 10 CFR 50.59 or a change to the Technical. Specifications shall be approved by the General Manager - Brunswick Plant or his'previously designated ,

alternate.

OPERATING LICENSE / TECHNICAL SPECIFICATIONS 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above shall include a written preliminary determination, with basis, of whether or not the proposed Operating License / Technical Specification change (s) is a change in the

?

facility as described in the safety analysis report. :

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be.

a. Reviewed by the Plant Nuclear Safety Committee in accordance with Specification 6.5.3.8. i SecTioeJ

b. Reviewed by the Nuclear Assessment ----- -- ' -- in accordance with Specification 6.5.4.9. l l

h BRUNSWICK - UNIT 2 6-7 Amendment No. 187 !

a. :

((

ADMINISTRATTIVE CONTROLS 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC).

FUNCTION 6.5.3.1 As an effective means for the regular review, overview, evaluation, and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established. ,

6.5.3.2 The PNSC shall function through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION 6.5.3.3 The PNSC shall be composed of the:

Chairman: General Manager - Brunswick Plant * '

Member Manager - Technical Support ember: Manager - Operations bar: Manager - Maintenance .

Mem c: Manager - Environmental & Radi ion Control '

Member Technical Assistant to Plant eneral Manager Member Manager - QA/QC Member Manager - Regulatory Co iance ALTERNATES 6.5.3.4 All alternate membe shall be app nted in writing by the PNSC Chairman to serve on a temporar basis; ever, no more than two alternates shall participate as members at a on ime. ,

6.5.3.5 All alternates, shall as

mi mum, meet equivalent qualification criteria as specified for profes tonal-t hnical personnel in Section 4.4 of I ANSI N18.1-1971.

]

MEETING FREQUENCY 6.5.3.6 The PNSC sh meet at least once per calen r month and as convened by the PNSC Chai or his designated alternate.

QUORUM 6.5.3.7 e minimum quorum of the PNSC necessary for the perfo ace of the PNSC a vities of the Technical Specifications shall consist of t PNSC Chai n or his designated alternate and four members including alte ates. No me taan two alternates shall be counted toward meeting the minimum q rum quirement.

Or designated alternate.

htde. - Replace 6th st%ched Issee t '

BRUNSWICK - UNIT 2 6-8 Amendment No. 170 I

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),i INSERT TO PAGE 6-8. l COMPOSITION -

. 6.5.3.3 The PNSC shall be composed of a Chairman and seven to nine members. The .

members shall be from the following functional areas: '

y

, . Operations Maintenance Engineering .

Health Physics / Chemistry.

Regulatory A. fairs Nuclear Assessment ' :

, - 6.5.3.4 The PNSC Chairman, alternate Chairmen, members, and alternate members - t shall be designated in writing by the Director - Site Operations. Members shall !

be individuals who are unit manager level or above from the site management .

organization. Alternate members shall, as a minimum, meet equivalent ;

qualification criteria as specified in Section 4.4 of'ANSI N18.1-1971 for.-

- professional-technical personnel.

OUORUM l 6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of these Technical Specifications shall consist of the Chairman (or his designated alternate) and four members (including alternates).

l 6.5.3.6 No more than two alternates shall be counted toward meeting the quorum- !

requirement or participate as voting members of the PNSC at any one time.

{

MEETING FREOUENCY ;

- 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the j PNSC Chairman or his designated alternate.

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2238nri.717

. - . . - . .. - - . - ~ - .___ - . -- .

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ADMINISTRATIVE CONTROLS i

ACTIVITIES 6.5.3.8 The PNSC activities shall include the following: ,. .i

a. Review of all procedures required:by Specification 6.8 and changes !

thereto (and any other procedures and changes thereto),.any of which ;

constitute an unreviewed safety question or involve a change to the. t' Technical Specifications, prior- to implementation.

b. Review of all proposed tests or. experiments that constitute an -l

unreviewed safety question or involve a change to the Technical a Specifications, prior to implementation.

~ ,

c. Review of all proposed modifications that constitute an unreviewed i safety question or involve a change to the Technical Specifications, t prior to implementation. ,

d. Review of all proposed changes to the Technical Specifications or -

Operating License, prior to implementation. ,

e. Review of reports on violations of Technical Specifications including >

reports covering evaluation and recomendations.to )revent recurrence to the Manager - Brunswick Nuclear Preseet rd tc t: "r:;r Scl =r ?= = 7.; 5;:-t ct. PLogt

f. Perfonnance of special reviews, investigations (or analyses), and-reports thereon as requested by the Manager - Nuclear Assessment T2i;[

g. Review of all REPORTABLE EVENTS.

h. Review of facility operations to detect potential nuclear safety i hazards.

1. Annual review of the Security Plan. !

j. Annual review of the Emergency Plan.

i

k. Review of accidental, unplanned, or uncontrolled radioactive release l including the preparation of reports covering evaluation, recomendations and disposition of the corrective action to prevent . i recurrence and the forwarding of these reports to the Manager - ;

Brunswick Nuclear .r4 th; "; ; ;;.- 1;lar. "cx: ~c.: ;

"w,,. i t ~c.t. . i

1. Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

m. Review of the Fire Protection Program and implementing procedures and the submittal of recomended changes to the Nuclear Assessment St.dio94 BRUNSWICK - UNIT 2 6-9 Amendment No. 200

( :

AcurwisTnaTivr corrROLS AUTHORITY 6'.5.3.'9 If there is a disagreement between recommendations of a majority' of the PNSC and the actions contemplated by the General Manager - Brunswick Plante the PNSC shall provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Brunswick Nuclear ?- j;;;;. " "- 1"_cr MPN M-- M-irrr .

[ Manages.

The course determined by the General Manager - Brunswick Plant to be the most g conservative, shall be followed.\ pg V;ce - f'reo. des

.[ RECCRDS 6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that, at a minimum, document the results of all PNSC activities performed under the ,

provisions of these Technical Specifications. Copies shall be provided to the Menegee - Brunswick Nuclear Soopees and the Manager - Nuclear Assessment 0:-- - - 0. Pto.Tr

'- SECT;o9 SecTioN 6.5.4 NUCI. EAR ASSESEMENT PEDAREREIFF INDEPENDENT REVIEW PROGRAM l e FUNCTION SecDoM 6.5.4.1 The Nuclear Assessment Geyesemena shall function to provide l independent review of significant plant changes, tests, and procedures; verify that REPORTABLE M FFS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events; and detect

trends that may not be apparent to a day to-day observer.

ORGANI M ION Oob 4SfeCihic 6.5.4.2 Th individuals assigned responsibility for independent reviews shall be :; ri'ird ' tr ' '--' disciplines. These individuals shall collectively have the experience and competence required to review activities in the ,

following areas

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry ;

d. metallurgy

e. non-destructive testing

f. instrumentation and control !

radiological safety g.

h. mechanical and electrical engineering

i. achninistrative controls t

h BRUNSWICK - UNIT 2 6-10 m a h at No. 187

J e

AOMINTETRATI'7E COFPROLS ORdANItATION (Continued)

j. ' seismic and environmental

k. quality assurance practices

1. Other appropriate fields crerir- ' ith *'- "-4 70 '- rrierirtic: :f th; x;;1 :: ;;ur pin;. ,

6.5.4.3 The Manager SR.8 ion backsks Nuclear Assessment Depasement shall have af acadeau j ,

degree in an engineering or related fisld and, in addition, shall have a minimum of ten years related experience, of which a minimum of five years shall be in the operation and/or design of nuclear power plants.

ihetividuels periorming backeLors 6.5.4.4 The (ndependent safety reviewJasegsen eeemeensees shall have lys degree in an engineering or related field or equivalent and, in addition, shall have a minimum of five years related experience.

6.5.4.5 An individual may possess competence in more than one specialty area.

If sufficient expertise is not available within the Nuclear Assessment 0;e .- --;, competent individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing independent reviews and investigations.

Sectio 4 Re. Place. Oiih Neva 4.5.4.t. ahked 7 6.h .4. k lified as discussed in 6.5.4.4 above shall review each item submitted undar the recui t

6.5.4.7 Independent safety reviews shall be performed by individuals not l directly involved with the activity under review or responsible for the i activity under review.

SecIlod 6.5.4.8 The Nuclear Assessment Depassment independent safety review program l i shall be conducted in accordance with written, approved procedures. :

MEW .

Rep 6co to.Th Neu) 6.s.4 9 -12 aftekst 6.5.4.9 4 Nuclear Assessment Department shall perform reviews of the l following:

a. The safety eva ons for 1) changes to procedures required by i Specification 6.8, fications of equipment or systems, and

3) tests or experiments constitute a change to the safety analysis report to verify tha uch actions did not constitute an i unreviewed safety question or in a change to the Technical Specifications. Isplementation may p ed prior to completion of this review. l

b. Proposed changes to procedures required by Specific 6.8, and proposed modifications that constitute an unreviewed sa question as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation. !

BRUNSWICK - UNIT 2 6-11 Amendment No.187

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o INSERT TO PAGE 6-11.. I q

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16.5.4.6. The documents submitted under 6.5.4.9 shall be reviewed by individuals meeting the requirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines .

' are encompassed. Multiple reviews will be conducted on documents where l required to meet applicable disciplines of 6.5.4.2. .!

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2238nri.717

ADMINISTRATT*/E CaNTROLS N EW (Continued) y g1 ggg,9. g ddd '

. Proposed tests or experiments that involve an unreviewed safety

_ question'as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior to implementation.

d. oposed changes to the Technical Specifications and Operating- i Li noe.

i

e. Viola ens of applicable codes, regulations, orders, Technical ,

Specif. ations, license requirements; and internal procedures or instruct a having nuclear safety significarice. i

f. Significant erating abnormalities or deviations from normal and expected per ruance of plant safety-related structures, systems, or components. !

g. Reportable events.

h. Reports and minutes the PNSC.

i. Any other matter involv g safe operation of the nuclear power plant that the Manager - Nucles Assessment Department deems appropriate for consideration or which is ferred to the Manager - Nuclear Assessment >

Department by the on site op ating organization or other functional organisational units within C clina Power & Light Company.

6.5.4.10 Review of items considered 6.5.4.9 (e) through (i) above shall include the results of any investigations de and the recommendations resulting from these investigations to pre t or reduce the probability of recurrence of the event.

RECORDS 6.5.4.11 Records of Nuclear Assessment Department. views, including l recomunendations and concerns, shall be prepared and stributed as indicated below:

a. Copies of documented reviews shall be retained in he Nuclear Assessment Department files. ,

b. Recommendations and concerns shall be submitted to th General Manager - Brunswick Plant and Manager - Brunswick Nucle Project, within 14 days of completion of the review.

c. A summation of Nuclear Assessment Department's recomunendati and l concerns shall be submitted to the Chai!: man / President; Execut Vice President - Power Supply; Senior Vice President - Nuclear Gene tion; Vice President - Nuclear Services; Manager Brunswick Nuclear Project; General Manager Brunswick Plant; and others, appropriat at least once every two months.

BRUNSWICK - UNIT 2 6-12 Amendment No. 187 ;

m _ ,

INSERT TO PAGES 6-11 AND 6-12. -

6.5A9 REVIEW '

The Nuclear Assessment Section shall perform reviews of the following:

i a.. Written safety evaluations of changes in the facility as described in the 1 Safety Analysis Report changes in procedures as described in the Safety Analysis Report, and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under ,

the provisions of 10 CFR 50.59(a)(1). These reviews are to verify that ,

such changes, tests, or experiments do not involve a change in the . ';

Technical Specifications or an unreviewed safety question as defined in

10 CFR 50.59(a)(2). These reviews may be conducted after appropriate -

management approval, and implementation' may proceed prior to i completion of the review. *

b. Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or experiments, any of which involve a change in the Technical 3 Specifications or an unreviewed safety question pursuant to 10 CFR 50.59(a)(2) prior to implementation. ;

c. Proposed changes to the Technical Specifications or this Operating License prior to implementation.

d. Violations, deviations 'and reportable events, which require reporting to l the NRC in writing, such as:

1. violations.of applicable codes, regulations, orders, technical specifications, license requirements or internal procedures or 1 instmetions having safety significance. :

2. significant operating abnormalities or deviations from normal or expected performance of plant safety-related structures, systems, or components, and i

3. REPORTABLE EVENTS as specified in 10 CFR 50.73.

I

e. Any other matter involving safe operation of the nuclear power plant.that )

the Manager - Nuclear Assessment Section, deems appropriate for consideration or which is referred to the Manager - Nuclear Assessment Section, by the on-site operating organization, Plant Nuclear Safety .l Committee (PNSC) or by other functional organizational units within CP&L.

l 2238nrL717

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' INSERT TO'PAGES 6-11 AND 6A12.

RECORDS-

+

6 5.4.10 - Results of Nuclear Assessment Section independent safety reviews shall' be' Edocumented and retained. ',

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' 2238nri.717

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s

^ !ADMTNISTRATI'N CONTKOL3' Sec. Tion AssessmeJT 6.s.5 NUCLEAR ASSESSMENT GENandIMB-MIDH' PROGRAM l

b "" Regace euTire_ se.cT. ico 6,s:s d,Th cathcAed 6.5. .1 -The Nuclear Assessment Department'shall' function to perform audits of. 'l facil y activities specified in Specification 6.5.5.2.

~

, ADDITS

.)

l 6.5.5.2 Aud s of facility activities shall be performed by the Nuclear ;

Assessment Dep tment. These audits shall encompass: i

. l

a. The conto ce of facility operation to provisions contained within. ,

the Technic Specifications and applicable license conditions at !

least-once pe 12 months. )

i

b. We training and lifications of the entire facility staff at least once per 12 months.

I

c. The results of actions sken to correct deficiencies occurring in facility equipment, stru aures, systems,.or methods of operation that affect nuclear safety at 1 se once per 6 months.

d. The verification of complianc and iglementation'of the requirements of the Quality Assurance Progr to meet the criteria of Appendix "B",

10 CFR 50, at least once per 24 ths.

e. The Emergency Plan and implementing cedures at least once per 12 months.

f. 25 Security Plan and iglementing proce a at least once per-12 months.

l

g. Se Facility Firs Protection Program and imp 1 ting procedures at -

least once per 12 months.

h. The radiological environmental monitoring program an the results thereof at least once per 12 months, i

1. The OFFSITE DOSE CALCUIATIONAL MANUAL and iglementing pro dures at .

least once per 24 months.

l

j. Se PROCESS COlr11t0L PROGRAM and iglementing procedures for pro asing and packaging of radioactive wastes at least once per 24 months.

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BRUNSWICK - UNIT 2 6-13 Amendment No. 187

._ __ _ _ _ _ _ _ _ _ _ _ . _ . ___ _ _ _ _ , . _ _ _ __.____ _ _~ . , . _

i

.. l INSERT TO PAGE 6-13.

6.5.5 Nuclear Assessment Section Assessment Program 6.5.5.1 Assessments of facility activities shall be performed by the Nuclear Assessment Section. Assessments will be performance based and will be scheduled based on plant performance and importance to safety but at a frequency not to exceed 24 months. These assessments shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

b. The performance, training and qualifications of the entire facility staff.

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

d. The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix B,10 CFR 50.

e. Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant.

A 6alamentino ara ~A"---

/ T : Pr ";=d:: "r;:-

A. The Radiological Environmental Monitoring Program and the results thereof. ,

f.g. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.

p. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.

6.5.5.2 Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable regulation. These assessments shall encompass:

a. Emergency Preparedness (per 10 CFR 50.54(t))

b. Security (per 10 CFR 50.54(p))

c.. Radia t-ion Pmte.ett on (pee to cMt ao.itor ce))

2238nri.717 ,

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1 ADMTNISTRATIVE'CONTROLE j

' UD I"'S (Continued) .k & dirq ~ % Tis -( .s.s- 6-th aad

. 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 ce per 12 months.

1. Any ther area of facility operation considered appropriate by the.

Manag - Nuclear Assessment. Department.

l' 6.5.5.3 Personn performing the audits shall have access to the plant ;

operating records.

RECORDS 1

6.5.5.4 Records of audi shall be prepared and retained. l 6.5.5.5 Audit reports en seed by 6.5.5.2 above shall be prepared, 1 approved by the Manager - Nuc ar Assessment Department, and forwarded to the l Executive Vice President - Powe Supply; Senior Vice President - Nuclear Generation; Manager - Brunswick lear Project; General Manager Brunswick Plant; and others, as appropriate, ' thin 30 days after completion of the audit.

AUTHORITY i

6.5.5.6 The Manager - Nuclear Assessment D artment shall be responsible for the following: l

a. The ackninistering of the Nuclear Asses t Department Audit Program. l'

b. The approval of the individual (s) selected conduct audits. l PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area dited.

6.5.5.8 Selection of personnel for auditing assignments shal _ e based on experience or training that establishes that their qualificati are commensurate with the complexity or special nature of the activit a to be audited. In selecting audit personnel, consideration shall be gi to special abilities, specialized technical training, prior pertinent e rience, personal characteristics, and education.

6.5.5.9 Qualified outside consultants or other individuals. independent f those personnel directly involved in plant operation shall be used to augme the audit teams when necessary.

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BRUNSWICK - UNIT 2 6-14 Amendment No. 187 J

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_1fwtNTETRATTVE CONTROLE g ,e - ... . -, . .. ..-, .. . - . - . . ~ . . d'TC T~

'N '

An independent fire protection and loss prevention. inspection and

. audit shall d at least~once per 12 months utilizing either ;

qualified offsite licensee y.._ =1 or an outside-fire protection firm.

6.5.6.2 An inspection and audit of 'a=a- revention program shall be performed by an outside qualified fire consultant a gy .

intervals no greater than 36 months.

6.6 REPORTABLE EVErr ACTION

6.6.1 The following actions shall be taken for REPORTABLE EVElfrS: '

a. The Cassiission shall be notified and a report sutunitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and ,

b. Each REPORTABLE EVMrf shall be reviewed by the Plant Nuclear Safety C e ttee - Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment 4epestmeme and the Manager - Brunswick Nuclear

%e,d' .es. section 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 NOT SHtrfDOWN within two. ;

hours. '

Vice-fredicle9T

b. The NRC Operations Center shall be notified telephone as soon as possible and in all cases within one hour. The 4esmagee - Brunswick Nuclear *:;;::: - ' " "-- ;:r " r'rr- ? ::: -- ? 0r;2_=

_ shall- l be noti ed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Pla d

c. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the General Manager - Brunswick Plant. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violatica upon facility components, systems, or structures, and (3) corrective action taken to prevent recurrence. i

d. The Safety Limit Violation Report shall be submitted to the Commission, the-41smages. - Brunswick Nuclear ;;;;;, and the Manager -

Nuclear Asse t!r ' within 14 of the violation. I Vice-pes _dJT SetiM PlwT i

. BRUNSWICK - UNIT 2 6-15 Amenhnt No.187

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ADMINISTRATnT CCFTROLS ,

i i

RECCRDS RETENTICN (Continued) ,

l

k. Records of reviews performed for. changes made to procecures or l equipment or reviews of tests.and experiments pursuant to )

10 CFR 50.59. l l

1. Records of the service lives of all hydraulic and mechanical snubbers !

referenced in Section 3.7.5' including the' data at which the' service life commences and associated installation and maintenance records. I

m. Records of analyses required by the radiological environmental monitoring program. '

n. Records of k meetings of the PNSC, (f! :: i- : Of -' ;__ irr: 200 )

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O. R$c${ of ~1udepwf u$ R$~&$ i 6.11 RADIATION PROTICTION PROGRAM !

6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation j exposure. l l

6.12 HIGH RADIATION AREA l i

i 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 mres/hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates'the radiation dose rate in the area and alarms when a preset, integrated does is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them, i

Health Physics personnel or personnel escorted by Health Physics personnel shall be exoset from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas. I BRUNSWICK - UNIT 2 6-25 Amendment No. 187

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. ADMINISTRATIVE CONTROLS .,

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'SECTION- ,

Eeff 6.1 RESPONSIBILITY.............................................. 6-1

'6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS'.................. . ..... 6-1 6.2.2 - FACILITY STAFF........................................... 6-1 16.2.3 DELETED

'6.2.4 SHIFT TECHNICAL ADVISOR... .............................. 6 !

6.3' FACILITY STAFF 00ALIFICATION................................ 6-5

'6.4 TRAINING................ ................................... 6-5 6.5 REVIEW AND AUDIT-6.5.1 NUCLEAR SAFETY REVIEWERS............... ................. 6-6 6.5.2 SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONTROL Safety Evaluations. . .......... .. ..................... 6-6 Procedures . Tests , and Experi ments . . . . . . . . . . . . . . . . . . . . . . 6-7 Mod i f i c a t i on s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7 Operating License / Technical Speci fications. . . . . . . . . . . . . . . 6-7 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)

Function................. ......... ..................... 6-8 Composition................................... .......... 6-8 t

Quorum...... . .......................................... 6-8 I t

Meeting Frequency................. ................... 6-8 -;

Activities. ... ................ . .................... 6-9 .l. l Authority....... .................... ............. ...... 6-10 I Records....... .................. ...... ................ 6-10 1 l

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i BRUNSWICK - UNIT 1 XIV Amendment No. l l

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INDEX ADMINISTRATIVE CONTROLS .

1 l

SECTION PAG.E 6.5 REVIEW AND AUDIT (Continued) 6.5.4 NUCLEAR ASSESSMENT SECTION INDEPENDENT REVIEW PROGRAM i Function............... ........ . ..... ..... .......... 6-10 L Organization.......... ...... ... ........ .. ...... ... 6-10 j Review........ ... ... .... . . .. .... . . ... 6-11 Records. .... .............. ...... ...... ... ........ 6-12 1 6.5.5 NUCLEAR ASSESSMENT SECTION ASSESSMENT PROGRAM.... ....... 6-13 1 6.5.6 0UTSIDE AGENCY INSPECTION AND AUDIT PROGRAM... .. .. . 6-15

I

6.6 REPORTABLE EVENT ACTION.................. ........... ...... 6-15 6.7 SAFETY LIMIT VIOLATION. . ..... .. . . ............. .... 6-15

'6.8 PROCEDURES AND PROGRAMS. . ... .. . . .. ... . . .. 6-16 6.9 REPORTING RE0VIREMENTS l Routine Reports.... ..... .. ........ . . ... ....... . 6-17 Startup Reports.... . .. . ... ...... . ... . .. 6-17 Annual Reports.... .. ... ..... ..... ... ..... ..... .. 6-18 Personnel Exposure and Monitoring Report.. . .. . .. 6-18 Annual Radiological Environmental Operating Report.... . 6-19 Semiannual Radioactive Effluent Release Report. . . . . . . . . . 6-20 Monthly Operating Reports... ... .. . ......... ... . ... 6-21 Special Reports.......... . .. .. ............ .... 6-22 Core Operating Limits Report...... .. .... .... .... 6-22 BRUNSWICK - UNIT 1 XV Amendment No. I

ADMINISTRATIVE CONTROLS 6 2.3 DELETED 6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit.

6.3 FACILITY STAFF OUALIFICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-19711/ comparable positions"), except for (1) the Manager - Environmental & Radiation Control who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant during transients and accidents.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Manager - Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.

i I

(a) The requirement for the Manager - Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13. 1991. l l

l BRUNSWICK - UNIT 1 6-5 Amendment No. l l l

l

I i ADMINISTRATIVE CONTROLS i i i. ,i.., ii ii PROCEDURES. TESTS. AND EXPERIMENTS 6.5.2.4 The safety evaluation ~ prepared in accordance with '!

> Specifications 6.5.2.1.a and 6.5.2.1.b above shall include a written i determination, with basis, of whether or not the procedures, proposed tests ,

and experiments, and changes thereto constitute an unreviewed safety question t as defined in 10 CFR 50.59. or whether they involve a change to the Technical ;

Specifications, j 6.5.2.5 Following the nuclear safety review. the procedures required by l Specification 6.8. other procedures that affect nuclear safety, proposed tests ;

or experiments, and changes thereto (other than editorial or typographical) !

which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or change to the Technical Specifications shall be i approved prior to implementation by the General Manager - Brunswick Plant or his previously designated alternate. ,

MODIFICATIONS 6.5.2.6 The safety evaluation 3repared in accordance with Specification 6.5.2.1.c above s1all include a written determination, with basis, of whether or not the proposed modification is a change in the facility '

as described in the safety analysis report. involves a change to the Technical i Specifications, or constitutes an unreviewed safety question as defined in i 10 CFR 50.59.

6.5.2.7 Following the nuclear safety review, propwed modifications which have been determined to not involve an unreviewed safety question as defined ;

in 10 CFR 50.59 or a change to the Technical Specifications shall be approved i by the General Manager - Brunswick Plant or his previously designated ,

alternate.

OPERATING LICENSE / TECHNICAL SPECIFICATIONS 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above shall include a written preliminary determination, with basis, of whether or not the proposed Operating License / Technical Specification change (s) is a change in the facility as described in the safety analysis report.

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared ;

in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the '

associated proposed action, the request shall be:

a. Reviewed by the Plant Nuclear Safety Committee in accordance with Specification 6.5.3.8. :

b. Reviewed by the Nuclear Assessment Section in accordance with I ,

Specification 6.5.4.9.

BRUNSWICK - UNIT 1 6-7 Amendment No. I

ADMINISTRATIVE CONTROLS 6.5.3 PLANT NUCl. EAR SAFETY COMMITTEE (PNSC)

FUNCTION 6.5.3.1 As an effective means for the regular review, overview, evaluation, and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established.

6.5.3.2 The PNSC shall junction through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION 6.5.3.3 The PNSC shall be composed of a chairman and seven to nine members.

The members shall be from the following areas: '

Operations Maintenance Engineering Health Physics / Chemistry Regulatory Affairs Nuclear Assessment 6.5.3.4 The PNSC Chairman, alternate Chairmen, members and alternate members shall be designated in writing by the Director - Site Operations. Members shall be individuals who are unit manager level or above from the site management organization. Alternate members shall, as a minimum, meet equivalent qualification criteria as specified in Section 4.4 of ANSI N18.1-1!C1 for professional-technical personnel.

OUORUM 6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of these Technical Specifications shall consist of the Chairman (or '

his designated alternate) and four members (including alternates).

6.5.3.6 No more than two alternates shall be counted toward meeting the quorum requirement or participate as voting members of the PNSC at any one time.

MEETING FREQUENCY 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.

BRUNSWICK - UNIT 1 6-8 Amendment No. I

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? ADMINISTRATIVE CONTROLS- _

1 ACTIVITIES l J

6.5.3.8 The~PNSC activities shall: include the following: q

'a. Review of all procedures required by Specification 6.8 'and changes'.. ;

'thereto.(and any'other procedures and changes thereto).-any of'which

constitute an unreviewed safety question or involve a change to the l

' Technical Specifications, prior to implementation. i j

b. Review of. all' proposed te' s ts or experiments that' constitute an.

unreviewed safety question or involve a change to.the Technical ~-

Specifications. prior to implementation.

q

c. Review of all proposed modifications that constitute' an unreviewed; ,

safety question.or involve a' change to the Technical Specifications. >

prior to implementation. 4

d. Review of all proposed changes to the Technical Specifications or Operating License, prior to implementation. '

e. Review of: reports on violations of. Technical Specifications including i reports covering evaluation and recommendations to prevent recurrence-to the Vice President - Brunswick Nuclear Plant. 1 -

f; Performance of special reviews, investigations (or analyses), and-reports thereon as requested by the Manager - Nuclear Assessment- -

Section. I ;

g. Review of all REPORTABLE EVENTS.

h. Review of facility operations to detect potential nuclear safety.

hazards, t

i. Annual review of the Security Plan. f

j. Annual. review of the Emergency Plan. ,

i

k. Review of accidental, unplanned, or uncontrolled radioactive release- !

including the preparation of reports covering evaluation. . :

recommendations and disposition of the corrective action to prevent. ;

recurrence and the forwarding of these reports to the Vice President -

Brunswick Nuclear Plant. -

1. Rrview of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSEL CALCULATION MANUAL.

1

m. Review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Nuclear Assessment ;

Section. I :

l BRUNSWICK - UNIT 1 6-9 Amendment No. i l t

ADMINISTRATIVE CONTROLS AUTHORITY 6.5.3.9 If there is a disagreement between recommendations of a majority of the PNSC and the actions contemplated by the General Manager - Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Vice President - Brunswick Nuclear Plant. The course determined by the General Manager --Brunswick Plant to be the most conservative shall be followed.

RECORDS 6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that, at a minimum, document the results of all PNSC activities performed under the provisions of these Technical Specifications. Co)ies shall be provided to the Vice President - Brunswick Nuclear Plant and the Manager - Nuclear Assessment l Section. l 6.5.4 NUCLEAR ASSESSMENT SECTION INDEPENDENT REVIEW PROGRAM l FUNCTION 6.5.4.1 The Nuclear Assessment Section shall function to provide independent I review of significant plant changes. tests. and procedures: verify that REPORTABLE EVENTS are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events; and detect trends that may not be apparent to a day-to-day observer.

ORGANIZATION 6.5.4.2 The individuals assigned responsibility for independent reviews shall be qualified in specific disciplines. These individuals shall collectively I have the experience and competence required to review activities in the following areas:

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy

e. non-destructive testing

f. instrumentation and control

g. radiological safety

h. mechanical and electrical engineering

i. administrative controls BRUNSWICK - UNIT 1 6-10 Amendment No. l

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" ADMINISTRATIVE CONTROLS l l

ORGANIZATION (Continued) i

j. seismic and environmental ;

k. quality assurance practices

l. Other appropriate fields. I 6.5.4.3 The Manager - Nuclear Assessment Section shall have a bachelor's degree I in an engineering or related field and, in addition, shall have a minimum of ten years related experience, of which a minimum of five years shall be in the operation and/or design of. nuclear power plants.

6.5.4.4 The individuals performing independent safety reviews shall have a I bachelor's degree in an engineering or related field or equivalent and in addition, shall have a minimum of five years related experience. ,

6.5.4.5 An individual may possess competence in more than one specialty area.

If sufficient expertise is not available within the Nuclear Assessment Section. I competent individuals from other Carolina Power & Light Company organizations or outside consultants shall be utilized in performing independent reviews and investigations.

6.5.4.6 The documents submitted under 6.5.4.9 shall be reviewed by individuals meeting the recuirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines are encompassec. Multiple reviews will be conducted on documents where required to meet applicable disciplines of 6.5.4.2.

6.5.4.7 Independent safety reviews shall be performed by individuals not directly involved with the activity under review or responsible for the activity ,

under review.

6.5.4.8 The Nuclear Assessment Section independent safety review program shall I be conducted in accordance with written, approved procedures.

REVIEW 6.5.4.9 The Nuclear Assessment Section shall perform reviews of tha following: l

a. Written safety evaluations of changes in the facility as described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report, and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval-under the provisions of 10 CFR 50.59(a)(1). These reviews are to verify that such changes, tests or experiments do not involve a change in the Technical Specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). These reviews may be conducted after appropriate management approval, and implementation may proceed prior to. completion of the review.

BRUNSWICK - UNIT 1 6-11 Amendment No. I

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^ ~ +:; LADMINISTRATIVE CONTROLS REVIEW (Continued)

b. Proposed changes in procedures required by these-Technical Specifications, proposed changes in the facility. or aroposed tests or .

- experiments, any of which involve a change in the Tec1nical t Specifications or an unreviewed safety question pursuant .to 10 CFR 50.59(a)(2) prior to implementation, j

c. ' Proposed changes'to the Technical Specifications or this Operating License prior to implementation. <

d. Violations ' deviations and reportable events, which req'uire reporting 1 to the NRC in writing, such as:

1. -Violations of applicable codes, regulations ~, orders, technical. specifications, license requirements or internal-procedures or instructions having safety significance.

2. Significant operating abnormalities or deviations from normal or expected performance of plant safety-related-structures, systems, or components, and

3. REPORTABLE EVENTS as specified in 10 CFR'50.73.

e. Any other matter involving safe operation of the nuclear power . !

plant that the Manager - Nuclear Assessment Section, deems ,

ap3ropriate for consideration or which is referred to the Manager .

iuclear Assessment Section, by the on-site operating l organization Plant Nuclear Safety Committee, or other functional; :

organizational units within CP&L.

RECORDS 6.5.4.10 Results of Nuclear Assessment Section, independent safety reviews shall be documented and retained.

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BRUNSWICK.- UNIT 1 6-12 Amendment No. l

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sW ! ADMINISTRATIVE' CONTROLS

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7, 6.5.5' NUCLEAR ASSESSMENT SECTION ASSESSMENT PROGRAM C

6.5.5i1 Assessments of facility activities shall be 3erformed by the Nuclear

Assessment-Section. Assessments will be performance Jased and will be

'. scheduled based on plant performance and importance to safety but.at a ,

frecuency not to exceed 24 months. These assessments shall encompass:

a: The conformance of facility operation to. provisions contained j

within the Technical Specifications and applicable license conditions. !

- b .- The performance, training, and qualifications of the entire facility staff. {

c. The results of actions taken to correct deficiencies occurring in l facility equipment,' structures, systems, or methods of operation that affect nuclear safety. ]

d. The performance of activities required by the Quality Assurance i Program to meet the criteria of Appendix B. 10 CFR 50. l

?

e. Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant. .

f. - The-Radiological Environmental Monitoring Program and the results i thereof. :

1 The 0FFSITE DOSE CALCULATION MANUAL and implementing procedures. .

h. The PROCESS CONTROL-PROGRAM and implementing procedures for processing and packaging of radioactive wastes. i 6.5.5.2 Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the ~ applicable l

regulation. These assessments shall encompass:

a. Emergency Preparedness (per 10 CFR 50.54(t)) ,

b. Security (per 10 CFR 50.54(p))

c. Radiation Protection (per 10 CFR 20.1101(c)) !

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BRUNSWICK - UNIT 1 6-13 Amendment No. l l

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L BRUNSWICK - UNIT 1 6-14 Amendment No. I I

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ADMINISTRATIVE CONTROLS t

6.5.6 0UTSIDE AGENCY INSPECTION AND AUDIT PROGRAM 6.5.6.1 An independent fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

6.5.6.2 An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.

6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Commission shall be notified and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and

b. Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safety Committee - Brunswick Plant and shall be submitted to the Manager - Nuclear Assessment Section and the Vice President -

Brunswick Nuclear Plant. .

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 NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour. The Vice President i

- Brunswick Nuclear Plant shall be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

c. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the Vice President - Brunswick Nuclear Plant. l 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 Vice President - Brunswick Nuclear Plant, and the Manager - Nuclear Assessment Section within 14 days of the violation.

BRUNSWICK - UNIT 1 6-15 Amendment No. I

b

( 9,

" ' ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued) ,

k. Records of reviews performed for changes made'to procedures or equiament or reviews of tests and experiments pursuant to 10 CTR 50.59.

L 1. Records of the service lives of all hydraulic and mechanical snubbers ieferenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance records. ,

Records of analyses required by the radiological environmental m.

monitoring program.

n. Records of meetings of the PNSC. I

o. Records of Independent Review. ,

6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation arotection shall be prepared consistent with the requirements of 10 CFR 3 art 20 and shall be approved, maintained and adhered to for. all operations involving personnel radiation -

exposure.

~

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" required by .

paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area,

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made '

knowledgeable of them.

Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the '

performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

BRUNSWICK - UNIT 1 6-25 Amendment No. I

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INDEX

% ADMINISTRATIVE CONTROLS 1

'SECTION- PjAGE 6'.1 ' RESPONSIBILITY;........... .................................. 6-1r 6.2 ORGANIZATION l

6.2.1 0FFSITE AND ONSITE ORGANIZATIONS;........................ 6 i 6.2.2 FACILITY STAFF... ................... ................... 6-1 l b 6.2.3 ' DELETED I 6.2.4 SHIFT TECHNICAL ADVISOR... .... .......... .............. 6-5 3 6.3 FACILITY' STAFF 0UALIFICATION............................. . 6-5 6.4 TRAINING......... .................. ...... ................ 6-5 .l

'6.5 REVIEW AND AUDIT- i 6.5.1 NUCLEAR SAFETY REVIEWERS................................. 6-6' !

6.5.2 SAFETY EVALUATIONS AND INDEPENDENT REVIEW CONTROL 3

Safety Evaluations.......... .................. ......... 6-6 Procedures . _ Tests , and Experiments. . . . . . . . . . . . . . . . . . . . . . 6-7 i Modi fi cat i ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7 :

Operating License / Technical Speci fications . . . . . . . . . . . . . . . 6-7 ;

i 6.5.3 -PLANT NUCLEAR SAFETY COMMITTEE-(PNSC).

t Function............ .... ............................... 6-8 i

. Composition........ ................ .................... 6-8' -!

0uorum.................................................. 6-8 ,

Meeting Frequency.............. .................... .... 6-8 i Activities....................... .......... ............ 6-9 '

Authority........................ . ..................... 6-10 Records... . ............. . ..................... ...... 6-10 i

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i BRUNSWICK - UNIT 2 XIV Amendment No. I ;

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ADMINISTRATIVE CONTROLS I

-SECTION: _PAGE ,

2 6.5 REVIEW AND AUDIT (Continued)L j 6.5.4L NUCLEAR ASSESSMENT SECTION INDEPENDENT REVIEW PROGRAM' .I Function..... .................................. ........ ;6-10

. Organization........ .................................... 6 .

Review............................................. .... 6-11' .

Records. ..................... ............................ 6-12 ;

-6.5.5 NUCLEAR ASSESSMENT SECTION ASSESSMENT PROGRAM........... '6-13 1 1

6.5.6 0UTSIDE AGENCY INSPECTION AND AUDIT PROGRAM.. .......... ~6-15 '

i 6.6 REPORTABLE EVENT ACTION....... ............................. 6-15 :

i 6.7 SAFETY LIMIT VIOLATION..... ......................... ..... 6-15 -!

t 6.8- PRDCEDURES AND PROGRAMS..... ............................... 6-16 i i

6.9 REPORTING REQUIREMENTS '

Routine Reports.. .......... ............................ 6-17 l Startup Reports...................................... .. ,6-17 i Annual Reports........................................... 6-18 l Personnel Exposure and Monitoring Report. . . . . . . . . . . . . . . . . 6-18 Annual Radiological Environmental Operating Report. .. . .. 6-19 Semiannual Radioactive Effluent Release Report. . . . . . . . . . . 6-20 ,

Monthly Operating Reports.......... ....... .... ...... . 6-21 i i

Special Reports.............. . ....... ....... ....... 6-22 '

Core Operating Limits Report............................. 6-22 l

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. BRUNSWICK - UNIT 2 XV Amendment No. 1 i 1

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. ADMINISTRATIVE CONTROLS 6.2.3 DELETED l. ;

6.2.4' SHIFT TECHNICAL ADVISOR ,

6.2.4.1- The Shift Technical Advisor shall serve in an advisory capacity to.

the Shift Supervisor on matters pertaining to the engineering aspects assuring safe operation of the unit. '

l 6.3 FACILITY STAFF OUALIFICATION l

6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications. of ANSI N18.1-1971 for comparable positions"), except for (1) the Manager - Environmental & Radiation Control who shall meet or exceed

'the qualifications of Regulatory Guide 1.8. September 1975 and (2) the Shift .

Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design. !

and response and analysis of the plant during transients and accidents. I 6.4 TRAINING :

6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Manager - Training (BSEP) and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.

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(a) The requirement for the Manager - Operations to hold or have held a i senior reactor cperator license is exempted for a period of 18 months starting from June 13. 1991. ,

BRUNSWICK - UNIT 2 6-5 Amendment No. l

ADMINISTRATIVE CONTROLS >

PROCEDURES. TESTS. AND EXPERIMENTS 6.5.2.4 The safety evaluation prepared in accordance with Specifications 6.5.2.1.a and 6.5.2.1.b above shall include- a written determination, with basis, of whether or not the procedures, proposed tests and experiments, and changes thereto constitute an unreviewed safety question as defined in 10 CFR 50.59. or whether they involve a change to the Technical Specifications. ;

6.5.2.5 Following the nuclear afety review the procedures required by Specification 6.8, other procec.a es that affect nuclear safety, proposed tests ,

or experiments, and changes thereto (other than editorial or typographical) which have been determined to not involve an unreviewed safety question as .

defined in 10 CFR 50.59 or change to the Technical Specifications shall be approved prior to implementation by the General Manager - Brunswick Plant or his previously designated alternate.

MODIFICATIONS 6.5.2.6 The safety evaluation 3repared in accordance with Specification 6.5.2.1.c above s1all include a written determination, with basis, of whether or not the proposed modification is a change in the facility as described in the safety analysis report, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10 CFR 50.59.

6.5.2.7 Following the nuclear safety review, proposed modifications which have been determined to not involve an unreviewed safety question as defined in 10 CFR 50.59 or a change to the Technical Specifications shall be approved by the General Manager - Brunswick Plant or his previously designated alternate.

OPERATING LICENSE / TECHNICAL SPECIFICATIONS 6.5.2.8 The safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above shall include a written preliminary determination, with basis, of whether or not the proposed Operating License / Technical Specification change (s) is a change in the facility as described in the safety analysis report.

6.5.2.9 Following the nuclear safety review of the safety evaluation prepared in accordance with Specifications 6.5.2.1.d and 6.5.2.1.e above and the associated proposed action, the request shall be:

a. Reviewed by the Plant Nuclear Safety Committee in accordance with Specification 6.5.3.8.

b. Reviewed by the Nuclear Assessment Section in accordance with l Specification 6.5.4.9. ;

1 BRUNSWICK - UNIT 2 6-7 Amendment No. 1 I

' ADMINISTRATIVE CONTROLS 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)

FUNCTION 6.5.3.1 As an effective means for the regular review, overview. evaluation, and maintenance of plant operational safety, a Plant Nuclear Safety Committee (PNSC) shall be established.

6.5.3.2 The PNSC shall function through the utilization of subcommittees, audits, investigations, reports, and/or performance of reviews as a group.

COMPOSITION 6.5.3.3 The PNSC shall be composed of a chairman and seven to nine members.

The members shall be from the following functional areas:

Operations Maintenance Engineering Health Physics / Chemistry Regulatory Affairs Nuclear Assessment 6.5.3.4 The PNSC Chairman, alternate Chairmen, members and alternate members shall be designated in writing by the Director - Site Operations. Members shall be individuals who are unit manager level or above from the site management organization. Alternate members shall, as a minimum, meet-equivalent qualification criteria as specified in Section 4.4 of ANSI N18.1-1971 for professional-technical personnel.

OUORUM 6.5.3.5 The quorum of the PNSC necessary for the performance of the activities of these Technical Specifications shall consist of the Chairman (or his designated alternate) and four members (including alternates).

6.5.3.6 No more than two alternates shall be counted toward meeting the quorum requirement or participate as voting members of the PNSC at any one-time.

MEETING FREQUENCY 6.5.3.7 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.

BRUNSWICK - UNIT 2 6-8 Amendment No. I

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@ ADMINISTRATIVE' CONTROLS pi.

LACTIVITIES--

'6.5.3.81 The PNSC activities'shall include the~following: ,

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a. Review of. all prccedures: required by Specification 6.8 and changes ?

thereto (and any other procedures and changes thereto).'any of which constitute an unreviewed safety question .or involve a change toLthe.

Technical Specifications, prior to implementation.

b. . Review of all:prooosed tests:or experiments that constitute'an -

unreviewed isafety question or involve a ~ change to the Technical

Specificattons, prior to implementation.

c. Review of all proposed modifications that constitute an unreviewed' safety question or involve a. change.to .the. Technical Specifications,- -

prior to implementation.

d. Review of all proposed changes to the Technical Specifications or -

Operating License, prior to implementation.

e. Review of reports on violations of Technical Specifications including-reports covering evaluation and recommendations.to prevent recurrence - ,

to the Vice President - Brunswick Nuclear Plant. I

f. Performance of special reviews, investigations (or analyses), and reports thereon as requested by the Manager - Nuclear Assessment ~

Section. I

g. Review of all REPORTABLE EVENTS.

h. Review of facility operations to detect potential nuclear safety-hazards.

1. Annual review of the Security Plan. I

j. Annual review of the Emergency Plan.

k. Review of accidental, unplanned, or uncontrolled radioactive release -

including the preparation of reports covering evaluation, recommendations and dispos'ition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President -

Brunswick Nuclear Plant.

1. Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE -

CALCULATION MANUAL.

m. Review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Nuclear Assessment Section. l BRUNSWICK - UNIT 2 6-9 Amendment No. I 5

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< ADMINISTRATIVE CONTROLS ,

-AUTHORITY y '

6.5.3.9 ' If there is'a disagreement between recommendations of a majority 'of- ,

the PNSC and the actions contemplated by the General Manager - Brunswick. . 'i Plant, the PNSC shall provide written notification within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s-to the Vice

. President - Brunswick Nuclear Plant. The course determined by the General Manager - Brunswick Plant'to be the most conservative shall be followed.

RECORDS 6.5.3.10 The PNSC shall maintain written minutes of each PNSC meeting that. i at a minimum, document the results of all PNSC activities performed under the provisions of these Technical Specifications. Copies shall be provided to the Vice President- Brunswick Nuclear Plant and the Manager - Nuclear Assessment I a Section. I 6.5.4 NUCLEAR ASSESSMENT SECTION INDEPENDENT REVIEW PROGRAM i FUNCTION 6.5.4.1 The Nuclear Assessment Section shall function to provide independent I review of significant plant changes, tests, and procedures: verify that REPORTABLE EVENTS ~are investigated in a timely manner and corrected in a manner that reduces the probability of recurrence of such events: and detect trends that may not be apparent to a day-to-day observer.

ORGANIZATION 6.5.4.2 The individuals assigned res be qualified in specific disciplines.ponsibility for independent These individuals reviews shall . I shall collectively have the experience and competence required to review activities in the following areas:

a. nuclear power plant operations l

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy i

e. non-destructive testing i

f. instrumentation and control

g. radiological safety ,

b. mechanical and electrical engineering ;

i. administrative controls BRUNSWICK - UNIT 2 6-10 Amendment No. I L

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1 ADMINISTRATIVE CONTROLS' !

, ORGANIZATION-(Continued) j ' seismic and environmental

k. quality. assurance practices

1. Other appropriate fields. -l 6.5.4.3. The Manager - Nuclear Assessment Section shall have a bachelor's_ degree l in an engineering or related field and, in addition, shall have a minimum of ten' years related experience, of which a minimum of five years shall .be in the.

operation and/or design.'of nuclear power plants. .

6.5'.4.4 The individuals performing independent safety' reviews shall have a_ I bachelor's degree in an engineering or related field or equivalent and, in ,

addition, shall have a minimum of five years related experience. l 6.5.4.5 An individual may possess competence in more than one specialty area. ;

If sufficient expertise is not available within the Nuclear Assessment Section, I.

competent individuals from other Carolina Power & Light Company organizations.or outside consultants shall be utilized in performing independent reviews and investigations.

6.5.4.6 The documents submitted under 6.5.4.9 shall be reviewed by individuals' ;

meeting the recuirements of 6.S.4.2 and 6.5.4.4 to ensure applicable disciplines are encompassec. Multiple reviews will be conducted on documents.where required to meet applicable disciplines'of 6.5.4.2. i 6.5.4.7 Independent safety reviews shall be performed by individuals not ;

directly involved with the activity under review or responsible for the activity.

under review.

c 6.5.4.8 The Nuclear Assessment Section independent safety review program shall I 4

be conducted in accordance with written, approved procedures. ;

REVIEW ;

6.5.4.9 The Nuclear Assessment Section shall perform reviews of the following: l

a. Written safety evaluations of changes in the facility as described in i the Safety Analysis Report changes in procedures as described in the

Safety Analysis Report, and tests or experiments.not deswibed in the Safety Analysis Report which are completed without prior NRC approval i under the provisions of 10 CFR 50.59(a)(1). These reviews are to verify that such changes, tests, or experiments do not involve a change in the !

lechnical Specifications or an unreviewed safety question as defined in 10 CFR 50 59(a)(2). These reviews may be conducted after appropriate management approval, and implementation may proceed prior to completion of the review.

i BRUNSWICK - UNIT 2 6-11 Amendment No. I -

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LADMINISTRATIVElCONTROLSL REVIEW (Cont'inued)~ -

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b .' . Proposed changes in procedures re' quired by. these~ Technical ..

Specifications proposed changes;in the facility. or' 3roposed tests.~or L experiments, any of which involve a change .in the Tecinical '3

- Specifications or an unreviewed safety question pursuant to' :

.10'CFR 50.59(a)(2) prior to implementation.

c .- Proposed changes to the Technical Specifications or this Operating :

License prior to implementation.

d. Violations,' deviations and reportable events, which require: reporting to_

the NRC in writing, such as: l

1. Violations of applicable codes, regulations. orders..' technical specifications, license requirements or internal procedures or 1 instructions having. safety significance. ,

2. Significant operating abnormalities or deviations from normal or '

expected performance of plant safety-related structures, systems, r or components, and

3. REPORTABLE EVENTS as specified in 10 CFR 50.73.

e. Any other matter involving safe operation of the nuclear power plant that the Manager - Nuclear Assessment Section.. deems appropriate for i consideration or which is referred to the Manager - Nuclear Assessment. :

Section by the on-site operating. organization. Plant- Nuclear Safety ;

Committee (PNSC), or other functional organizational units within CP&L.

RECORDS 6.5.4.10 Results of Nuclear Assessment Section independent safety reviews ;

shall be documented and retained. i a

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BRUNSWICK - UNIT 2 6-12 Amendment No. I i j

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ADMINISTRATIVE CONTROLS

- 6. 5. 5 NUCLEAR ASSESSMENT SECTION-ASSESSMENT -l

-6:5.5.1 Assessments ~of facility activities shall be 3erformed by the. Nuclear Assessment Section. Assessments'will be performance Jased and will'be scheduled

-based on plant performance.and importance'to safety but at.a frequency not to-exceed 24 months. These assessments shall~ encompass:

.a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

b. The performance. training, and qualifications of the entire facility.

staff,

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety.

d .- - The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix B.10 CFR 50

e. Any other area of facility operation considered appropriate by the Vice President - Brunswick Nuclear Plant.

f. The Radiological Environmental Monitoring Program and the results thereof.

g. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.

h. The PROCESS CONTROL PROGRAM and implementing procedures for processing-and packaging of radioactive wastes.

6.5.5.2 Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable ' regulation.

These assessments shall encompass:

a. Emergency Preparedness (per 10 CFR 50.54(t))

b. Security (per 10 CFR 50.54(p))

c. Radiation Protection (per 10 CFR 20.1101(c))

i-BRUNSWICK - UNIT 2 6-13 Amendment No. I

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BRUNSWICK - UNIT 2 6-14 Amendment No. l

p f- '4" i " ADMINISTRATIVE CONTROLS ,

6.5.6' OUTSIDE AGENCY INSPECTION AND AUDIT PROGRAM ,

6.5.6.1 An independent fire protection and. loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm. .

6.5.6.2 An inspection and audit of the fire protection and loss prevention l program shall be performed by an outside qualified fire consultant.at-intervals no greater than 36 months. ;

6.6 REPORTABLE-EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Commission shall be notified and a report submitted pursuant to the-requirements of Section 50.73 to 10 CFR Part 50. and

b. Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safety-Committee - Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment Section and the Vice President - Brunswick Nuclear Plant.

6.7 SAFETY LIMIT VIOLATION j 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 NRC Operations Center shall be notified by telephone as soon as ,

possible and in all cases within one hour. The Vice President -

Brunswick Nuclear Plant shall be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ,

c. A Safety Limit Violation Report shall be pre)ared. The report shall be reviewed by the General Manager - Brunswick Plant. .This report shall describe (1) applicable circumstances preceding the violation.

(2) effects of the violation upon facility components, systems, or i structures, and (3) corrective action taken to prevent recurrence.

d. The Safety Limit Violation Re) ort shall be submitted to the Commission, j the Vice President - Brunswicc Nuclear Plant, and the Manager - Nuclear '

Assessment Section within 14 days of the violation.

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BRUNSWICK - UNIT 2 6-15 Amendment No. I

i* ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued)

k. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

1. Records of the service lives of all hydraulic and mechanical snubbers referenced in Section 3.7.5 including the data at which the service life commences and associated installation and maintenance records.

m. Records of analyses required by the radiological environmental monitoring program.

n. Records of meetings of the PNSC.

o. Records of Independent Review. l 6.11 RADIATION PROTECTION PROGRAM i 6.11.1 Procedures for personnel radiation arotection shall be prepared consistent with the requirements of 10 CFR part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " Control Device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20. each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thcreto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

BRUNSWICK - UNIT 2 6-25 Amendment No. I

4 Fzra No.: NG-5024 'Atttchment 4 10/90 to NGGN 304-01

, 0 OUTGOING CORRESPONDENCE' FSAR CHANGE IDENTIFICATION FORM ASSOCIATED DOCUMENT IDENTIFICATION: k5 d U$ 'O bM (e.g., LETTER NUMBER, TITLE, DOCUMENT NUMBER)

//5Vt=0(EMA/VCE NKd Nu'cwv?- nssxsyvsvr- fizcwinM NOTES: (1) If noted FSAR changes have already been identified and are being processed per another process or procedure (e.g., NPMP, CAP), a note to that effect is sufficient.

(2) If a complete FSAR change package is not currently available, insert the responsible person's name, anticipated completion date, and the method being utilized for tracking (e.g. , FACTS $ ). ,

(3) Refer to 10CFR50.71 and applicable nuclear project FSAR Change i Control procedure (s) if in doubt of applicable change l requirements.

(1) FSAR PAGE(S)/ FIGURE (S) AFFECTED: bM E // I N/M' Pc /2 RFG. G-c)< D E /. /6'G - SEE DESiQ3svW 70 0R77/ D AJ /.6 3 d- MC 7Y ON /7 ]

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(2) DESCRIPTION OF CHANGE (See Notes): OM [ O 6-/2 M bdh68[

572 At'So /Nt7tRL LEcDutzS7- cf 7/22/Py AffviausL V 9,AM f f ind 7D N/LC (AS NECESSARY FOR CLARITY, ATTACH MAREED-UF, CURRENT FSAR PAGES.)

l PREPARER: $A DATE: M (3061ATTs)

ML20087G081

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