ML19354D495

Proposed Tech Specs,Changing Number of Members of Onsite Nuclear Safety Group

ML19354D495
Person / Time
Site:	Braidwood
Issue date:	08/14/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19354D494	List: ML19354D493 ML19354D495
References
NUDOCS 8911090370
Download: ML19354D495 (4)

Text

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ATTACHMENT B

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M l PROPOSED CHANGE TO APPENDIX A.

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TECHNICAL SPECIFICATIONS. OF FACILITY

,. S'? Glo OPERATING LICENSES NPF- P AND NPF W 4

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. < Revised Page: 6-2 l

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'8911090370 890814 PDR- ADOCK 05000454 .

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~ ADMINISTRATIVE CONTROLS I UNIT STAFF (Continued)-

b. At least one licensed Operator shall be in the control room when c ~ fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or.4, at least one licensed Senior Operator shall.be in the contro1~- room; s

c. A Radiation Protection Technician,* qualified .in radiation protection procedures,.shall be on site when fuel is in the reactor; d

d. All CORE ALTERATIONS shall be observed and directly supervised by

< either a licensed Senior Operator or licensed Senior Operator Limited i

3 to Fuel Handling who has no other concurrent responsibilities during -l this' operation; i

e. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related i functions; e.g., licensed Senior Operators, licensed Operators, l health physics personnel, equipment operators, and key maintenance personnel.

The amount of overtime worked by Unit staff members performing '

safety-related functions shall be limited in accordance with the NRC Policy. Statement on working hours (Generic Letter No. 82-12); .

f. The Assistant Superintendent Operating shall hold a Senior Reactor Operator License. / 4 l

6.2.3 ONSITE NUCLEAR SAFETY GROUP (ONSG)

FUNCTICN 6.2.3.1 The 0NSG serves as.an independent safety engineering group and shall function to examine. plant operating characteristics, NRC issuances, industry advisories, REPORTA8LE EVENTS and other sources of plant design and operating '

experience information, including plants of similar design, which may indicate areas for improving plant safety. The ONSG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, opera- '

l tions activities or other means of improving plant safety to the Safety Assessment Manager, and the Station Manager, Braidwood Station. ~

COMPOSITION three 6.2.3.2 The 0NSG shall be composed of at least 4ew, dedicated, full-time engineers located on site.

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• The Radiation Protection Technician may be less than the minimum requirements l for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

BRAIDWOOD - UNITS 1 & 2 6-2 AMENDMENT NO.

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. ' '/ * ' ATTACHMENT C e t

Evaluation of Stanificant Hazards Consideration Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards consideration. According

'to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with amendment would not:  ;

1). Involve a significant increase in the probability or consequences of an accio0nt previously evaluated; or a

2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) Involve a significant reduction in a margin of safety.

' The purpose of this amendment is to reduce the On-site Nuclear Safety Group minimum staffing requirement from four engineers-to three engineers. '

The proposed amendment will have no eff9ct on'the consequences of an accident ,

previously evaluated because it will not involve any physical change in the plant.or operating procedures. The' proposed amendment may have some effect on the probability of an accident previously evaluated since there will be fewer people performing the independent safety assessment function within the

'On-site Nuclear Safety Group (ONSG). However, any increase in this probability will not be significant and will be compensated for by the activities of several corporate level groups that are independent of-the immediate management chain for power production. These groups perform independent assessments of operating characteristics and safety issues that  :

are of ten redundant to the technical specification responsibilities of the ONSG. This proposed amendment does not change ONSG areas of review as described in the Technical Specifications. The ONSG retains responsibility <

for review of those items listed in Technical Specification 6.2.3.1, but will make additional use of'the independent review work done by the above noted corporate level groups.

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-There will be no change in the physical plant or in W e way the plant l 1s operated. No new accidents are postulated. As a result, operation of the l plant in accordance with the proposed amendment will not create the L possibility of a new or different kind of accident from any accident j previously evaluated.

The proposed amendment will not involve any physical change in the margin of safety because there will be no physical change in the plant or change in operation of the plant. There may be some effect on the margin of safety in terms of the amount of review of operating characteristics and safety issues, but this change will not be significant due to the independent L assessment activities of corporate level groups. These groups have responsibilities that often overlap the technical specification responsibilities of the ONSG. When performing their on-site reviews, the ONSG i will in create their use of corporate level independent review work performed by new departments.

Based on the preceding discussion, Commonwealth Edison believes this proposed amendment involves no significant hazards consideration.

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' ,.: < ATTACHMENT D l 3

ENVIRONMENTAL ASSESSMENT STATEMENT j 1

. This proposed Amendment relates to changes in recordkeeping, )

reporting or' administrative procedures or requirements. Accordingly, i Commonwealth Edison believes this Amendment meets the eligibility criteria.for,  !

categorical exclusion set forth in 10 CFR 51.22 (c) (10). Therefore, pursuant 1 to 10 CFR 51.22 (b) no environmental impact statement or environmental 1 assessment is necessary in connection.with this proposed' amendment.

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