ML20099G265

Proposed Tech Specs Implementing Functional Role & Responsibilities of Recently Created Nuclear Assessment Dept

ML20099G265
Person / Time
Site:	Brunswick
Issue date:	08/06/1992
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20099G260	List: ML20099G258 ML20099G265
References
NUDOCS 9208140183
Download: ML20099G265 (33)

Text

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l ENCLOSURE 4 l

BRUNSWICP STCAM ELCCTRIC PLANT, UNITS 1 AND 2 i

NRC DOCKET No. 50 261/ OPERATING LICENSE NO. DPR 23 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CilANGES PROPOSED TEC11NICAL SPES_ElGATIONS - UNIT 1 P

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liRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC-DOCKET !;0. 50 261/0PERATING LTCENSE NO. DPR 23

' REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES PROPOSED TECHNICAL SPECIFICATIONS - UNIJ J l

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ADMINISTRAUVE COITTROLS

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6.2.3.1 Tt.e PA'Oroup Unit shall function to examine facility cperating l

characteristics, NRC 7 spues, indestry advisories, and other sources which may indicate areas for improving facility safety.

x F.ESPONSIBILITIES N

6.2.3.2 ~'1he PA Group Unit shall be re pcinsible for maintaining surveillance l

of facili y activitica to provide independent' verification

• that tr.ese t

. activities are performed correctly and that human'erro{s - are reduced as much an practical.

x N AITTHORITY

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-6.2.3.3 The PA Group Unit shall make detailed recommendations for revlssd_

l procedures, equipment modifications, or other means of improving facility N....

safety to the Manager Nuclear Assessment Department.

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6.2.4 SHIFT TECHNICAL ADXI1QB 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to the Shift Supervisor on matters pertaining to the engineerino aspects assuring

- saf e operation c ? the unit.

6

's FACILITY STAFF UJ IFICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 ~ for comparable posit ons(o) except for d

(1) the Manager. Environmental T. Radiation Control O ; 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 responue and analysis of the plant during transients and accidents.

6.4 TRAINING A retraining and replacement training program for the facility staff 6.4.1 shall be maintained under the direction of-the Manager

• Training- (BSEP) and shall meet or exceed the requirements and recommendations of Section 's.5 of ANSI N18,1-1971 and Appendix "A" of 10 CFR Part 55, 1

6.4.2 I training program for the Fire Brigade shall be maintained under-the direction

'f the Manager - Training (BSEP) and sht.ll meet'or exceed the i

requiremerts of Section 27 of.the NFPA Code-1975.

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Not.renponsible for sign off function.

(a). The r3quir*. ment for t.he. Manager - Operations to hold or have held a senior reactor operator license is exempted for a period of 18 months starting from June 13,.J991.

BRUNSWICK - UNIT 1-6-5 Amendment No. 156

ADMINISTRATIVE CONTROLS 6.5.3 PLANT NUCLEAR SAFETY COMMITTEE (PNSC)

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

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

COMPOSITION 6.5.3.3 The PNSC shall be composed of ther Chairman General Manager - Brunswick Plant

• l Member:

Manzger - Technical Support Member Manager - Operations Membar:

Manager - Maintenance Member:

Hanager - Environmental & Radiation Control Member:

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Technical Assistant to Plant Cencral Manager Manager-QALQC)

Member:

hanager - Regulatory Compliance ALTERNATES 6.5.3.4 All alternate members shall be appointed in writing by the PNSC Chairman to serve on a temporary basis; however, nn more than two alternates shall participate as members at any one time 6.5.3.5 All alternates, shall as a minimum, meet equivalent qualification criteria as specified for professional-technical personnel in Section 4.4 of ANSI N18.1-1971.

MEETING FREQUENCY 6.5.3.6 The PNSC shall meet at least once per calendar month and as convened by the PNSC Chairman or his designated alternate.

QUORUM 6.5.3.7 The minimum quorum of the PNSC necessary for the performance of the PNSC activities of the Technical Specifications shall consist of the PNSC Chairman or his designated alternate and four meriocrs including alternates.

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

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requirement.

• Or designated alternate.

BRlfNSWICK - UNIT 1 6-8 Amendment No. 138

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- g rfVITIE3 6,5.3.8 ThJ PNSC activities shall include the followings Review of all procedures required by Specification 6.8 and changes j

a.

thereto (and any other precedures and changes thereto), any of which 3

constitute an unreviewed safety question or involve a change to the Technical Specitications, prior to implementation.

b.

Review of all proposed tests or experimonts that constitute ar.

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

c.

Review of-all propesel 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 Specificatient or Operating License, prior to i.1plementation,

_ Review of reports en violations of Technical Specifications including-e.

reports covering evaluation and recommendations to prevent recurrence to the: Manager - Brunswick Nuclear Project and to the Manager -

. Nuclear Assessment Department.

f.

Petfennance of special reviews, investigations (or analyses), and reports-thereon as requested by the Manager - Nuclear Assessment Department, g.

- Review of all REPORTABLE h*VEITTS.

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

i'. -

Annual review of the Security Plan.

'j.

Annual-review of the. Emergency Plan, k.

Review of accidental, unplanned, or uncontrolled radioactive release-including the-preparation of reports covering evaluation, recommendations and disposition of - the corrective action to prevent ract nence'and the forwarding of these reports to the Manager -

Brunswick lluclear Project. nd-tP.; !i. jc:

~!Nelcar ?.soeewneet Rpa. mane.

1.

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

f..

- BRUNSWICK - TNIT 1 6-9 Amendment No..156 m.

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l@4ItTTSTPATIVE COfr"PO14 UJrhoPTTt 44,5.3.9 If there is a disagreement between recomendations of a ma]ority of the PNSC and the actions contemplated by the General Manager - Brunswick i

Plant, the PliSC shall provide written notificatien within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the.

1 Manager - Brunswick lluclear Project and the Vice-President.--44uclear-Ser/iceo.

The courso determined by the General Manager # Brunswick Plant to be the most 3

conservative shall be followed.

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PECOPI)S 6.5.* 10 The P!ISC chall maintain written minutes of each P:ISC meetinJ that, 4

at a minimum, document the results of all P!1SC activities performed under the provisions of these Technical Specifications.

Copies shall os provided to the Maneger - Brunswick Nut..ar Project and the Manager - Nuclear Assessment Department.

5.5.4 NUCLEAP ASSESSMEITT DEPART!Elg B_TQI.EE!TDEliT UEVIEW PPGJJAIJ l

UTlh.d M G.S.4.1 The Nuclear Assessment Department chall functicu to provide l

inlependent review of significant plant changes, tests, and procedures; verify that PSPORTABLE EVENTS are itnestigattd ira a tim 31y manner and corrected in s manner that reduces the probability of recetrence of such events; and detect trends that may not be apparent to a day to day observer.

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G.S.4.2 The dividuals assigned responsibility for independent reviews shall be -spec 4fied-an-+echni-oal disciplin es.

These individuals shall collectively have the experience and competence required to review acti nties in the following areas:

a.

nuclear power plant operattens b.

nuclear engineering 12?

c.

chemistry and radiochemintry d.

metallurgy e.

non destructive testing f.

instrumentation c.nd centrol g.

radiological safety h.

mechanical and electrical engineering 1.

administrative controls 1

BRUNSWICK - UNIT 1 6-10 Amendment No. 156

.i ADMTNTSTRATTVE COWTROLS QRGANIZATICN (Continued) 3 seismic and environmental k.

quality assurance practices 1.

Other appropriate fields asseoiat.ed-with-the "M qua-characcar4rdos-of.

the-nueleatw ower-plant, Sahity (b,edUS bathuor 6. !i. 4. 3 The Manager - Nuclear Asseeoment-Geparts. ant 4shall have an academie l

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

6 5.4.4 The ir4depencent safety review program reviewers shall have an (acked " Mademie degree in an engineering or related field oz 6quitaient and, in addition, shall have a minimum of five years related experience.

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

If sufficient expertise is not available within the Nuclear Assessment Department, competent individuals from cther Carolina Power & Light Company organizations or outside corpultants shall be utilized in perf oming independent reviews and investigations.

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g gg 6.5.4. G" ~At75ast-three-inc'wiAnala cualified as discussed in 6.5.4.4 above, g

rshall r.u'.ew each item submitted under the recuirements of imuuim C t-6 2 -

6. 5. 4. */ 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 Department independent safety review program

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shall be conducted in necordance with written, approved procedures.

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N 6.5.4.9 Nuclear Assessment' Department shall perfom reviews of thu l

4 following:

Thesafetyevalut(onefor1) changes to procedures required by a.

Specification 6.8, 2 W ifications of equipment or systems, and

3). tests or experiments tha constitute a change to the safety analysis report'to-verify tha ch actions did not re stitute an unreviewed safety question or invo a change to the Technical Specifications.

Implementation may pro d prior to completion of

-this review.,

b.

Proposed changes to procedures required by Specifica 6.8, and proposed medifications that censtitute an unreviewed safe question r

as defined in 10 CFR 50.59 or a change to the Technical Specifications, prior t.o implementation.

BRUNSWICK UNIT 1 6 11 Amendment No. 156

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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 are encompassed.

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ADMINISTRATIVE CO277ROLS

' R VIEW (Continued)

Proposed tests or experiments that involve an unreviewed safety c.

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

d.

Pr gosed changes to the Tenanical Specifications and Operating Liceh e.

e.

.Violati a of applicable codes, regulations, crders, Technical Specifica ions, license requirements, and internal procedures or instructio having nuclear safety significance, f.

Significant rating abnomalities or deviations from normal and expected perfo ance of plant uafety related structures, systems, or components.

g.

Reportable events, h.

Reports-and minutes of he PNSC.

i.

Any other matter involvin safe operation of the nuclear power plant that the Manager - Nuclear spessment Department deems appropriate for consideration or which is re rred to the Manager Nuclear Assessment Departrsnt by the on site ope ting organization or other functional organizational units within Car ina Power & Light Company.

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

FACQEDR 6.5.4.11 Records of Nuclear Assessment Depsrtment r qiews,' including l

reccamendations and concerns, shall be prepared and dihtributed as indicated belows-a-

Copies of documented reviews shall be retained in e Nuclear Assessment Department files.

h.

Recommendations-and concerns shall be submitted to the eneral Manager - Brunswick Plant and Manager - Brunswick Nuclea Project, within 14 days of ecmpletion of the review.

c.

-A summation of Nuclear Assessment Department's recommendation and l

concerns shall be submitted to the Chaiman/ President; Executi Vice Presidenc - Power-Supply;' Senior Vice President

~ Nuclear Genera on;

-.Vice President - Nuclear. Services; Manager - Brunswick Nuclear Project; General Manager - Brunswick Plant; and others, appropriate, at least once every two months.

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l BRUNSWICK UNIT,1 6-12 Amendment No.156

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REVIEW 6.5.4.9 The Nuclear Assessment Department shall perform reviews of the following:

a.

Written safnty evaluations of significant changes in the facility as described in the Safety Analysis Report, significant changes in procedures as described in the Safety Analysis

Repott, and significant tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10CFR50. 5 D (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 10CFR50. 59 (a) (2).

These reviews may be conducted after appropriate management approval, and implementation may proceed prior to completion of the review.

b.

Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or experiments, any of which involve a change in the Technical Specifications or an unroviewed safety question pursuant to 10CFR50.59(c) prior to implementation.

c.

Proposed changen to the Techlical Specifications or this operating License prior to implementation.

d.

. Violations, deviations and reportable

events, which require reporting to the NRC in writing, such as:

1)

Violations of applicable

codes, regulations, orders,-

technical specifications, license requirements or internal procedures or instructions having safety significance, 2)

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

and 3)

Reportable events as specified in 10CFR, which require reporting to the NRC in writing.

e.

Any other matter involving safe operation of the nuclear power plant that the Manager Nuclear Assessment Department, deems appropriate for consideration or which is referred to the. Manager Nuclear Assessment Department, by the on-site operating organization, Plant Nuclear Safety Committee (PNSC) or by other functional organizational units within Carolina Power Light Company.

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

6.5.4.11 Potentially adverse conditions shall be submitted in accordance with the correctivo action program.

6.5.4.12 A

briefing of the Nuclear Assessment Department activities, along with any potential issues and recommendations shall be presented to the Executive Vice President - Power Supply and Senior Vice President Nuclear Generation Group on an approximately bimonthly i

frequency. Copies of this presentation shall be provided to tho ' Vice President - Brunswick Nuclear Project, General Manager Brunswick

Plant, and-others as appropriate.

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. 6.5.5 NUCLEAR ASSESSMENT DEPARTMENT At?rttT PROGPJJi l

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m,0we e,A sucho c.y.s sn attad 6 W5.1 The Nuclear Assessment Department shall function to perform audits of l

facil'ty-activities specified in Specification 6.5.5.2.

AUDITS 6.5.5.2 Au ige of facility activities she.11 be performed by the Nuclear Assessment De - rtment. These audits shall encompass a.-

The confo ce of facil!.ty operation to provisions contained within the Techni 1 Specifications and applicable license conditions at least once p 12 months.

b.

The_ training and alifications of the entire facility staff at least once per 12 months c.

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

d.

The verification of corglian and implementation of the requi ements of the Quality Assurance Progr to meet the criteria of Appenuix

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10 CFR.50, at least once per 24 nths.

e.

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

f.

The Security PJ an and implementing proce res at least once per 12 months.

g.

The Facility Fire Protection Program and imple enting procedures at least once per 12 months, h.

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

i.

The OFFSITE. DOSE CALCULATIONAL MANUAL and implementing p cedures at

-least once per 24 months.

j.

The PROCESS COJTROL PROGRAM and implemen dng procedures for p ' cessing and packaging of radioactive wastes at least once per 24 months.

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1 BRUNSWICK. UNIT 1 6 12 Amendment No.156

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M)111NISTRATIVE CONTROLS

• hTIII (Continued)

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, une 1974, and Regulatory Guide 4.1, Revision 1, April 1975, at least o e per 12 months.

1.

Any ther area of facility operation considered appropriate by the Manage

- Nuclear Assessment Department.

l 6.5.5.3 Personne performing the audits shall have access to the plant operating records.

PECOP.DS 6.5.5.4 Records of audita.shall be prepared and retained.

6.5.5.5 Audit reports encomp sed by 6.5.5.2 above shall be prepared, approved by the Manager riuc1' r Assessment Department, and forwarded to the l

Executive Vice President Power pply; Senior Vice President - Nuclear Generation; Manager - Brunswick Nu ear Project; General Manager - Brunswick Plant; and others, as appropriate,

' thin 30 days after completion of the audit.

AUTHORITY 6.5.5.6 The Manager - Nuclear Assessment De rtment shall be responsible for l

the followings a.

The administering of the Nuclear Assessme

• Department Audit Program.

l b.

The approval of the individual Ws selected t conduct audits.

l PERSONNEL 6.5.5.7 Audit personnel shall be independent of the area a ited.

6.5.5.8 Selaction of personnel for auditing assignments shall e based on experience or training that establishes that their qualification are commensurate with the complexity or special nature of the activiti 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 consultaats or other individuals independent fr.

those perconnel directly involved in plant operation shall be used to augmen the audit teams when necessary.

I BRUNSWICK UNIT 1 6-14 Amend:: tent No.156

6,5.5 NUCLEAR ASSESSMENT DEPARTMENT, ASSESSMENT PROGRIJ, The Nuclear Assessment Department is responsible for conducting independent assessments of functions / areas affecting nuclear safety, quality and reliability.

This program is described in the FSAR, Section 17.3.3.3.

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ADMINXSTRATIVE CONTROLS h6_ OtTTSIDE AGENCY INSPLCTION AND AUDIT PROGPJM

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As independqnt fire protection and loss prevention inspection and audit,hal' be performed-a Q as:. once per 12 months utilizing either qualis.ied offsite licennee perDonagl or an outside fire protection firm.

6.5.6.2 An inspection and audit of the fire s ection and lose prevention program chall be performed by an outside qualified."-

consultant at intervals no greater than 36 months.

6.6 PEPORTABLE EVENT ACTION 6.6.1 The followir.g 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 EVE!TT shall be reviewed by the Plant Nuclear Safety Committee - Brunswick Plant and shall be submitted to the Manager -

Nuclear Assessment Department and the Manager - Brunswick Nuclear Project.

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 SHUTDOWJ within two

hours, b.

'the NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour. The Manager - Brunswick Nuclear Project and the Manager - Nuclear Assessment Department shall l

be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c.

A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the Genera 2. Manager - Brunowick Plant. This report shall describe (1) applicable circumstan*

preceding the violation, (2) effects of the violation upon facilit, components, systems, or atructures, and (3) corrective action taken to prevent recurrence.

d.

The Safety Limit Violation Report shall be submitted to the Commienion, the Manager - Brunswick Nuclear Project, and the Pm ager -

Nuclear Asseusment Department within 14 days of the violation.

BRUNSWICK - UNIT 1 6-15 Amendment No. 156

a ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued) b.

Records and logs of principal maintenance activities, insoections, repair and replacement of principal items of equipment related to nuclear safety.

c.

All REPORTABLE EVENTS.

d.

Records of surveillance activities, inspections, and calibrations required by these Technical Specifications.

e.

Records of changes made to Operating Procedures.

f.

Records of radioactive shipments.

g.

Records of sealed source and fission detector leak tests and results.

h.

Records of annual physical inventory of all sealed source material of record.

6.10.2 The following records shall be retained for the duration of the Facility Operating License Records and drawing changes reflecting facility design modifications a.

made to systems and equipment described in the Final Safety Analysis Report.

b.

Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c.

Records of facility radiation and contamination surveys.

d.

Records or radiation exposure for all individuals entering radiation control areas.

e.

Records of gaseous and liquid radioactive material released to the environs.

f.

Records of transient or operatiot 1 cycles for those facility components identified in Table 5.7.1-1.

g.

Records of reactor tests and experiments.

h.

Records of training and qualification for current members of the plant staff.

l i.

Records of inservice inspections performed pursuant to these Technical Specifications.

j.

Record e--of4a11 y f.eeeeenee-eeti v i t i ce-eequi-nwi-by-the-QA-Manue-l.

Records $ $ 1 u d y p a-h j Y R e q & w BRUNSWICK - UNIT 1 6-24 Amendment No. 138

JO?MINISTPATIVE OONTROLS l

• RECORDS PETEm' ION (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 analysea required by the radiological environmental monitoring program.

h meetings of the PNSC, W m :Mngs-of-the--previeue-of-f-n.

Records of site-eeview crganinatsenr-eho-Gompany-Nuol+4 c-Gaf4ty-Committoe-(CNSGt,

W-the-independent-reviewe-pe rformed-by-the-Fuolea M.euooement Depa Lient, and M-the--independent--reviewo-performed-by--the-Corporeee-QuaHey-Assurance-Audit-Progr=, Quali ty-Assurance-J.ud king--Unit.

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

6.12 HIGH RADIATION AREA E.12.1 In lieu of the " Control Device or " alarm signal" required by a

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 barri,aded and conspicuously posted as a high radiation area and entrance thereto sha.',1 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 monicoring device which continuously integrates the radiation dose rate in the area and alarms when a preset lategrated dose is received.

Entry into such areas with this monitoring device may be made afcec 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.

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l BRUNSWI"K - UNIT 1 6-25 Amendment No.156

i ENCLOSURE S BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 URG DOCKET No. 50 261/0PERATING LICENSE NO. DPR-23 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANCES PROPOSED TFCitNICAL SPECIFICATIONS - UNIT 2 E5 1 (1383sup.ctv)

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6.2.3.1

".e PA 'DN:42p Unit she.ll function to examine facility op rating l

]M Jharacteristics, NRCN es, industry advisories, and other souc%.s which m*.y h4 indicate areas for irgron gg tility safety.

EESPONSIBILITIES A

6.2.3.2 The PA Group Unit shall De reoph !.ble for maintaining surveillance l

[i of facility activitied to provide independ-N erificatior* that these act: vities are periormM correctly and that humar trors are reduced as much y

{; y as practical.

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\\ N 6.2.3.3 Tne PA Grcup Unit shall make detailed recocM ndations for

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procedures, equipment modifications, or other means afimprovingfaci?ih t

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safety to the &aager - huclear Assessment Depar '. ment.

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6.2.4.1

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_alcal Advisor shall serve in an advisory cgacity to the Sh P

on matters pertaining to the engineering aspects assuring safe o, 2 unit.

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FACILITY STAFF OUALICICATION 6.3.1 Each member of the facility staff shall meet or exceed the minimum

. cl.ificstions of ANSI N18.1-1971 for comparable positions (a), except for

t. w Manager - E.avironmental & Radiation Control who shall meet or exceed tt.

rp m ifications of RegulatoCy Guide 3.8, September 1975 and (2) the Shift Techniesl Advisor who shall have a bachelor's degree or equivalent in a e'ientific or engineering discipline with specific training in pinnt design, and resprse and analysis of the plant during transients and accide.nta.

f.4 TRAINING C.4.1 A retraining and replacement training progr,.n. for the f acility staf f snall be maintained under the direccion of the Manager - Training (BSEP' and shall : net. or exceed the ruquirements and recommendations of Sectica 5.5 of ANSI N18.1-1971 and Appendix "A"

of 10 CFR Part 55.

6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Manager - Training (BSEP) and shall met t or exceed the requirements of Section 27 of the NFPA Code-1975.

Not esponsible for sign-off function.

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

BRUNSWICK - UNIT 2 6-5 Amendment No.187 l

1

'-4 ADMINICTRATTIVE CONTROLS-6.5.3 -PLANT NUCLEAR SAFETY C0KMITTEE (PNSC)

FUNCTION

'6.5.3.14:As an effective means'for,the regular review, overview, evaluation,.

and maintenance of plant operational rafety, a Plant Nuclear Safety Committee (PNSC) shall be established.

6.5.3.2 -The PNSC shall function thro _,

he 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:

Ceneral Manager - Brunswick Plant

• Mernber:

Manager - Technical Support j

Member:

Manager - Operations Member:

Manager - Maintenancs Member:

Manager --Environmental & Radiatico Control Member:

Technical Assistant to Plant General Mantger hlv7t1 -~ lMember:

Manager-QA/QCl

. Member:

Manager - Regulatory Compliance ALTERNATES 6.5.3.4 All: alternate members shall be appointed in writing by the PNSC Cheirn:an P.of serve: on a temporary basis; however, no more than two alternates

shall participate as-members at any ont time.

615.3.5; All alternates, shall is a minimum, meet equivalent qualification

criteria as specified'for professional-technical personnel in Section 4.4 of ANSI' NI S;1-1971'.

MEETING FREQUENCY.

6.5.3.6;iThe PNSC shall meet at least once per calendar month and as convened eby the PNSC Chairman or his designated alternate.

QUORUM 6.5.3.7 2-The minimum quorum of the PNSC necessary for the performance of'the

'PNSCl activities of the Technical Specifications shall ' onsist-of the PNSC c

Chairman-or his designated alternate and four members including alternates.

No 9

-more than two alternates shall be counted toward meeting the. minimum quorum i

.requirementi

• .Or designated altJenate.

BRUNSWICK ~ UNIT 2:-

6-8 Amendment No. 170 j

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-'- g)5?WISTRAT2VE CONTROLS

• ACTIVITIES 6.5.3.8 The:PNSC activities shall include the following:

Revie'.) of all procedures required by Specitication 6.8 and changes a.

thereto (and any other procedures and changes thereto), any of wnich constitute an unroviewed safety question or involve a change to the Technical Specifications, prior to implementation.

b.

Review of all proposed tests or experiments that constitute 2 unreviewed safety question or involve a change tc the Technical Specifications, pr' or to implemer

• tion.

c.

Review of all proposed modificatiow that constitute an utm. viewed safety question or' involve a change to the Technical Specification.-

prior to implementation, y

d.

Review of all proposed changes to the Technical Specifications or Operatir.g License, prior to implementation, Review of reports on violations of Technical Specifications including e.

reports covering evaluation and recommendations to prevent racurrence to the Manager Brunswick Nuclear Project and to the Manager -

Nuclear. Assessment _ Department.

l f.

Performance of special reviews, investigations (or analyses), and

' reports thereon as requested by the Manager - Nuclear Assessment Department, g.

Review of all REPORTA&'E E7?NTS.

h-Poview of facility operations to ceteet potential nuclear safety hazards.

L 1.

. Annual.eview of the Security Plan.

j.

Annual review of the Emergency Plan, k.

Review of accidental, unplanned, or uncontrolled radioactive release including the-preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports:to the Manager _-

Brunswick Nuclear Project.and-the-Hanagc Wc'. car Asscsemcn Depart 4nent, e

'l.

-Review of changes to the PROCESS CONTROL PROGRAM and the OFFS TE DOSE TCALCULATION MANUAL.

r 1

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BRUNSWICK - UNIT.2 6-9 Amendt.ent No. 187

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' * &QldlJ1TSTRATIVE COMTROLS AUTHORITY 6.5.3.9 If thete is a disagreement between recommendations of a majority of the PNSC and the. actions centemplated by the General Manager - Brunswick Plant, the PNSC shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the

- Manager Brunswick Nuclear Project and the Vic; I'rcak4ent Muelea-r-6erviees.

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

RECOPDR Y~

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• ^ '

• 6.5.3.10 The PNSC chall maintain written minutes of each PNSC meeting that, at a minimura, document the results of all PNSC activities performed under the provisions of-these. Technical Specifications.

Copies shall be provided to the Manager Bnanswick Nuclear Pr0 ject and the Manager - Nuclear Assessment Department.

,6.5.4 NUCLEAR ASSESSMENT DEPAR E 3T INDEPENDENT REVIhd_FFOGRA,M l

FlfNCTION 6.5.4.1 The Nuclear Assessmen Department 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-dsy observer.

.QP,GANIZATION QuolI-hid - i) SferiEC ti. 5. 4. 2 The ndividuals assigned renponsibility for independent reviews shall be specified ir. techr.icel disciplines. These individuals shall collectively have the experience and competence required to review activities in the

-following areas:

a.

nuclear power plant operations-b.

nuclear engineering c.

chemistry and radiochemistry d.

metallurgy e.

non-destructive testing f,

instrumentation and control g.

radiological _ safety h.

mechanical and electrical engineering

~i.

administrative controls i.

BRUNSWICK - UNIT 2 6-10 Amendr it No. 187

l

'*-- &DMT??ISTRATIVE COi4TROLS ORGANIZATION (Continued) 4 j.

-seismic and environmor.tal k.

quality assurance practices 1.

Other appropriate fields aseeeisted ::th the = ige Wraccaristice of the nucicar powcr plar,e.

% M y fl.h m a liDit kcithe 6.5.4.3 The Manager Nuclear '.ce :cment Depanment shall have an aeademte l

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

6.5.4.4 The independent safety review program reviewers shall have an

%)d o j.

eeadem k degree in an engineering or related field or equivalent and, in addition, shall have a minimum of five yaars related experience.

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

If sufficient expertise is not available within the Nuclear Assessment Department, competent individuals from other Carolina Power & Light Company or2anizations or outside consultants shall be utilized in performir.g independent reviews and investigationu.

RcPL

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6.5.4.6 At least three individuals, qualified as dis:ussed in 6.5.4.4 above, shal1~ review-each item submitted under the requirements of Section 6.5.4.9.

ct Tic 1hc[

"6.5.4.7 Indepent.ent safety reviews shall be performed by individuals not 1

~

directly involved with the activity under review or responsible for the activity under review, 6.5.4.8 The Nuclear Assessment Department independent safety review program l

shall be conducted in accordance with written, approved procedures.

Re.1%E WITh N uc (,. S. 4. 9 - l2 dI h ked 6.5.\\.9 4

e Nuclear Asaes *

' Department shall perform reviews of the l

following:

a.

The safety luations for 11 changes to procedures required by Specification 6.

2) modifications of equipment or systems, and

3) tests or experim-a that constitute a change to.the safety

. analysis report to veru

• that such actions did not constitute an unreviewed safety-question - involve a change to the Technical Specific.a tions. -Implementati

- ay proceed prier to completion of this' review.

'b.

Proposed changes to procedures ret.c'. ired

" ecification 6.8, and groposed modifications that constit 2te an unr 4ewed safety question as defined in 10 CFR 50.59 or a chaige to the Tec. ' cal Specifications,' prior to implementation.

r-f BRUNSWICK - UNIT 2 6-11 Amenument No.- 187 W

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6;5.4.6~ The documents submitted under 6.5.4.9 shall be reviewed by

.ndividuals meeting the requirements of - 6. 5. 4. 2 and 6,5.4.4 to ensure.applicablo disciplinos are encompassed.

i l

l.

' - @jdITfSTPAT2VE COETTROLS hEVIEW (Continued).

a Proposed tests or experiments that involve an u reviewed safety question as defined in 10 CFR 50.59 or a change co the Technical Specifications, prior to implementation, d.

oposed changes to the Technical Specifications and Operating Li nae.

e.

Viola one of applicable codes, regulations, orders, Technical Specifi ations, license requirements, and inta mal procedures or instruct na having nuclear safety significance f.

Significant perating abnormalities or deviations from nomal and expected per mance of plant safety-related stmetures, systems, or components.

9 P.eportable events.

h.

Reports and minutes the PNSC.

i.

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

. Department by the on-site rating organization or other functional organizational units within C olinv rower & Light Company.

6.5.4 Ig :'eview of items considered' und 6.5.4.9 (e) through (1) above shall include the results of any investigations ade and the recommendations resulting from these investigations to prev c or reduce the probability of recurrence of the event.

. RECORDS 6.5.4.11 -Records of Nuclear Assessment Departrent eviews, including l

recommendations and concerns, shall be prepared and stributed as indicated.

'below:

a.

Copies of documented reviews shall be retained i the Nuclear Assessment 1 Department files.

th.

- Recommendations',nd concerns shall be submitted to th General

~ Manager - ' Brunswick - Plant und Manager - Bmnswick Nucl r Project, within 14 days of completion of the review, A summation of Nuclear Assessment Department's recommendatiKns and l

c.

concerns shall be submitted to the Chairman / President; Rxecubive Vice-President Power Supply; Senior Vice President - Nuclear Gene ation; Vice-President - Nuclear Services; Manager - Brunswick Nuclear

. Project; General Manager - Brunswick Plant; and others, appropria e, at least once every two months.

' BRUNSWICK - UNIT 2l 6-12 AmendT. int No.'187

~

• ^ REVIEW 6.5.4.9 The Nuclear.Tssessment Department shall perform reviews of the following:

a.

Written safety evaluations of significant changes -in the facility as described in the Safety Analysis Report, significant changes in procedures as described in the Safety Analysis

Report, and significant tests-or experiments not described in the Safety Analysis Report which are completed without prier NRC approval under the provisions of 10CFR50. 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 10CFR50. 59 (a) (2).

These reviews may be conducted after appropriate management approval, and-implementation may proceed prior to completion of the review.

b.

Proposed changes in procedures required by these Technical Specifications, proposed changes in the facility, or proposed tests or experiments, any of which involve a change in the Technical Specifications or an unreviewed safety question pursuant to - 10CFR50.59 (c) prior to implemec2tation.

c.

Proposed changes to the ' Technical Specifications or this operating License prior to implementation, d.

Violations, deviations and reportable

events, which require reporting to che NRC in writing, such as:

1) violations of applicable

codes, regulations,

orders, technical specifications, license requirements or internal procedures or instructions having safety significence,-

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 10CFR, which require reporting to'the NRC in writing.

e.

Any.other matter involving s afe operation of the nuclear power plant that the Manager Nuclear Assessment Department, deems appropriate for consideration or which is referred to the Manager Nuclear Assessment Department, by the on-nite operating organization, Plant l

Nuclear-Safety Committee (PNSC) or by other functional

)

organizational units within Carolina Power Light J

Company.

1

RECORDS.

6.5.4.10 Results of Nuclear Assessment Department independant safety reviews shall be documented and retained.

6.5.4.11 Potentially adverse conditions shall be submitted in accordance with the corrective action program.

6.5.4.12 A

briefing of the Nuclear Assessment Department activities, along with any potential issues and 3 commendations shall be presented to the Executive Vice i esident - Power Supply and Senior Vice President -

Nuclear Generation Group on an approximately bimerthly frequency. Copies of this presentation shall be pro *ided to the Vico President - Drunswick Nuclear Project, General Manager Brunswick

Plant, and others as appropriate.

4 a

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. ADMINISTRATIVE CONTROI.S 4"

As s essonuHl 6.5.5 NUCLEAR ASSESSMENT DEPARTMENT AUDI3F PROGRAM f

.\\FUNCTIQ[{

helace edt>e re h, hop 4,.s.5 w it h uTndmj 6.

5.1 The Nuclear Assessment Departmont shall function to perform audits of l

faci ty acti.*ities specified in Specification 6.5.5.2.

ETDITS 6.5.5.2 Au te of facility activities shall be performed by the Nuclear Assessment De,artment.

These audits shall encompass:

a.

'"he conf ce of facility operation to provisions contained within the Techni 1 Specifications and applicable license conditions at least once p r 12 months, m

b.

The training an qualifications of the entire facility staff at least once.per 12 month c.

The results of actio taken to correct deficiencies occurring in facility equipment, st. ctures, systems, or methods of operation that affect nuclear' safety at least once per 6 months.

d.

The verification of compli

-e and inylementation of the requirements of tde Quality Assurance Prcy m tc aeet the criteria of Appendix "B",

10'CFR 50, at:least ones pur 24

onths, e.

The Emergency Plan and implementin procedures at least once per-12 months.

f.

Tne Security Plan and implementing proc ures at least once per 12 months.

-g.

The Facility Fire Protection Program and imp menting procedures at least once per 12 t.tonths.

hi The radiological environmental monitoring program nd the results thereof at least once per-12 months, i.

The OFFSITE DOSE' CALCULATIONAL MANUAL and implementing recedures at least once per 24 months.

J.

The PROCESS CCNTROL PROGRAM and implementing procedures for ocessing

- and packagirgr of radioactive wastes at least once per 24 month

' BRUNSWICK - UNIT 2 6-13 Amendment No.187 l

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(Continued) k The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, une 1974,. and Regulatory Guide 4.1, Revision 1, April 1975, at least l

o ce per 12 months.

i 1.

Any

~her' area ef facility operation coreidered appropriate by the Ehnage Nuclear Assessment Deparurent.

l 6.5-5.3 Personne performir.g the audits shal. have access to the plant operating'rscords.

=EECQPJ!S

-6.5.5.4 Records of audit shall be prepared and retained.

~6.5.5.5 Audit reports enc.

ssed by 6-5.5 2 above shall be prepared, approved by the Man /Ager - Nucl r Assessment Department, and forwarded to the l

Executive Vice President Power upply;. Senior Vice President - Nuclear L

Generatien; Manager.- Brunswick N lear-Project; General Manager Brunswick

. Plant;.and others, as appropriate,

' chin 30 days after completion of the audit.

AUTHORITY-6.5.5.6$-:The Manag7r - Nuclear Assessment De artment snall be responsible for the'following:

.a.

The administering of the Nuclear Assessm t Department Audit Pragram.

l b.

1The - approval of the individual (s) selected conduct audits.

l EERSONNEL 6.5.5.7 fAudit personnel shall be independent of the area udited.

-6.5.5.8 Selection:of personnel for auditing asoignments shal be based on

. experience-or training that establishes that,their qualificatic s are ecmmensurate with the conplexity or special nature of the activi (es to be audited..In selectine :ad2t personnel, consideration shall be giv to special abilitfis, specialized technical training, prior pertinent e erience,

.-personal characteristics, and education.

-6.5.5.9, Qualified outside consultants or.other individuals independent om those personnel directly involved in plant cperation shall be used to augm t the audit teams when necessary.

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BRUNSWICK - UNIT 2 6-14 Amendment No. 187

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5 a

i 5.5 NUCLEAR ASS 5lSSMENT DEPARTMENT ASSESSMENT PF.OGRAM The Nuclear Assessment Department is responsible for conducting independent assessments of functions / areas affectinq nuclear safety, quality and reliability.

This program is described in the FSAR, Section 17.3.3.3.

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' *ISMINISTRATIVE CONTROLS V:

E

. NhomSIos noENer INsPECrIoN mo numr PROoPm Ih55 *dh n U CM P *E*M IJTo FS AR SeB4n! i 7. 3.3. 3 6. 5. 6.1. An indep da t fire protection and loss prevention-inspection and audit shall be performe east once per 12 months utilizing either qualified offsite licensee perso or an outside fire protection fim.

6.5.6.2 An insp1ction and audit of the fire p

-tion and loss prevention program shall bn performed by an outside qualified fl

-nsultant at intervala no greater than 36_ months.

6.6 PEPORTABLE EVE.NT. ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

I a.

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

-Each REPORTABLE EVENT shall be reviewed by the Plant Nuclear Safcty Committee ~- Brunswick Plant and shall be submitted to the Manager -

Nuclear Assesrl ment Department and the Manager - Brunswick Nuclear Project.

6;7' SAFETY LIMIT VIOLATION 6.7.1 ihe-following actions shall be taken in the event a Safety Limit is violated; a.

The facility shall be placed in at least H7f SHUTDO'iN within two hours.

b.

The NRC Operations Center shall be notified by telephone as soon as pessible and in all cases within one hour..The Manager - Brunswick Nuclear Project and-the Manager - Nuclear Assessment Department shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c.

A Safet1C Limit Violation Report shll be prepared.

Tue report shall be reviewed by the General Manager - Brunswick Plant. This report shall describe (1) applicable circumetances preceding the violation,

'::) effects of the violation upon facility components, systems, or scructures, and' (3) corrective action taken to prevent recurrence.

d.

The Safety Limit Violation Repcrt shall he' submitted to the Commisuien, the Macager - Erunswick Nuclear Project, and the Maragor -

Nuclear Assessment Department within 14 days-of the violation.

BRUNSWICK - UNIT 2 6-15 acendr. ant No.187

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ADMINISTRATIVE CONTROLS RECORDS RETENTION (Continued) b.

Records and logs of principal maintenance activities, inspections, repair and repla:ement of principal items of equipment related to nuclear safety.

c.

All REPORTABLE EVENTS.

d.

Re:ords of surveillance activities, inspections, and calibrations required by these Techn. cal Specificationa.

e.

Accords of changes made to Operating Procedures.

f.

Records of radioactive shipments.

g.

P.ecords of sealed source and fission detector leck tests and results.

h.

Recerds of annual physical inventcry of all sealed source material of record.

s 10.? The foilowing records shall be retained for the duratien of the

.acility Operating License:

a.

Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b.

Rec' rds of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c.

Records of facility radiation and contamination surveys.

d.

Records or radiation exposure for all individuals entering radiation control areas, e.

Reccra= of gascaus and liquid radioactive material released to the environs.

8 f.

Records of transient or operatirnal cycles for those facility componente identified in Table $.7.1-1.

g.

Records cf reactor tests and experiments, h.

Records of training and qualification for current members of the plant staff.

i.

Records of inservice inspections performed pursuant to these Technical Specifications.

j.

Records-of--Qua1. n y Au m mice ect i Vi t i;;; c c q u i ce+&r-+he '}A-Mamel.

Recorcls n$ 19d vpe,aldt~ [Nec;

)

BRUNSWICK - UNIT 2 6-24 Amendment No. 170 l

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• A'ADMINISTPliPIVE COETROI,S

~' "

RECOPDS RgIFLyLQ1{ (Continued) k.

. Records of review 9 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 S 7.5 including the data at which the service liftr commences and associated installation and maintenance records, Records of analyses required by the radiological environmental m.

moni:oring program, eite-review N meetings of the PNSC, 62+--meerrings-of-the previcue off-Records of-n.

organisatien, the C%any ::uciccMafety Commiete

'C;:00-),

G)--the-independent-revic= perf emed by the "" clear Acccesment Deputa.ent, r

'd' the independent re rie': r pa"#0" ed M" the Ccrporat-e Quali-ty J.ccuranee Audit P rogrer., Ouality Assuwanee-Audh-hm-Unit.

6.11 PADIATIO!LEOTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepm.d consistent with the requirements of 10 CFR Part 20 and snall be ap

aved, maintained and adhered to for all operations involving personre]

r.Aation exposure.

6.12 HIGH PIDIATION AREA 6.12.1 In lieu of the " Control Device" or " alarm siinal" requised by paragraph 20 203 (c) (2) of 10 CFR 20, each high radiation area.. vhich the intensity of. radiation is 1000 mrem /hr or loss shall be barrir*Adeo 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 pert.litted to enter such areas shall be provided wi~.;h or accompanied by one or more of the following:

A radiation monitoring davice which continuously indicates the a.

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 raceived.

Entry into such areas with this monitoring device l.

c:sy be made. af ter the 'ese rate levels in the area have been established and personnel have been made knowledgeable of them.

• Health Physics personnel-or porponnel ercorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protect.icn durias, provided they ecmply with apnoved radiation protection procedures for encry into high radiation areas, BRUNSWICK - UNIT 2 6-25 Amendment No. 187

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