ML20012D871
| ML20012D871 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/19/1990 |
| From: | Hunsader S COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800 NUDOCS 9003290022 | |
| Download: ML20012D871 (2) | |
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v Msrch 19, 1990 Dr. Thomas E. Murley Director,' Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn:
Document Control Desk
Subject:
Braidwood Station Units 1 and 2 Supplement to Application for Amendment to Facility Operation Licenses NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Reference (s): August 14, 1989 R..A. Chrzanowski letter to T. E. Murley
Dear Dr. Murley:
In reference (a), pursuant to 10 CFR 50.90, Commonwealth Edison proposed to amend Appendix A, Technical Specifications of Facility Operating
' Licenses NPF-72 and NPF-77.- The proposed amendment requests a change in the number of members of the OnSite Nuclear Safety Group. As stated in reference (a),' based on a summary of the responsibilities and function of other Edison departments,'the Onsite Nuclear Safety Group can be-reduced from four (4) to three (3)' people without any loss in meeting the requirements of the Technical Specifications. The option for establishing a, lower number of personnel is permitted under NUREG-0800. Allowing this reduction will provide for the transfer of an individual to another assignment within Commonwealth Edison.
In reviewing Attachment C to reference (a), a typographical error was identified.
In the fourth paragraph'the words "...in create..." in a misspelling of the words "... increase...".
A corrected copy of Attactunent C is provided for the NRC staff's convenience.
Please direct any questions regarding this submittal to this office.
Very truly yours,
,/ C. fd A
, y S. C. Hunsader Nuclear Licensing Administrator
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Attachment:
Revised Evaluation of Significant Hazards Consideration m8 N
Enclosure:
August 14, 1989 R.A. Chzranowski letter to T.E. Murley
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cc:
oo Resident Inspector-Braidwood M-S.P. Sands - NRR y
W. Shafer - RIII f
I iott Regional Administrator _- RIII W8p/
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Office of Facility Safety - IDNS j
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SCH:wj/0796T
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RevisiDILdated March 19. 1990
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i AIIACHMENI_C j
EYdual.lon of Significant Hazards Consideration l
I Commonwealth F.dison has evaluated this proposed amendment and J
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 nott j
i 1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or 3
I J
2)
Create the possibility of a new of different kind of accident from any accident previously evaluated; or 1
3)
Involve a significant reduction in a margin of safety.
l The purpose of this amendment is to reduce the On-site Nuclear Safety 1
Group minimum staffing requirement from four engineers to three engineers.
The proposed amendment will have no effect on the consequences of an accident previously evaluated because it will not involve any physical change in the tL 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 i
On-site Nuclear Safety Group (ONSG).
However, any increase in this
]
L probability will not be significant and will be compensated for by the activities of several corporate level groups that are independent of the J
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in6nediate' management chain for power production.
These groups perform independent assessments of operating characteristics and safety issues that are often redundtnt to the technical specification responsibilities of the
)
ONSG. This proposed amendment doer not change ONSG areas of review as L
described in the Technical Specifications. The ONSG retains responsibility
)
for review of those items listed in Technical Specification 6.2.3.1, but will 1
make additional use of the independent review work done by the above noted
)
corporate level groups.
There will be no change in the physical plant or in the way the plant is operated. No new accidents are postulated. As a result, operation of the plant in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident 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 pite.c.
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 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 will increate their use of corporate level independent review work performed by new departments.
Based on the preceding discussion, Coirmonwealth Edison believes this proposed amendment involves no significant hazards consideration.
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\\ Commonweehh Edloon i
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' 72 West Actams Street, Chcapo. IlWcs k "_ 2 Kodress Reply to PoTNc7 N f
.\\d Cheago. Ilanois 60690 0767 August 14, 1989 Dr. Thomas E. Murley Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Subject:
Braidwood Station Units 1 and 2 i
Appilcation for Amendment to Facility l
Operating Licenses NPF-72 and NPF-77 1
BRC_ Docket Nos. 50-454 and 50-455 l
l
Dear Dr. Murley:
Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend Appendix A, Technical Specifications of facility Operating Licenses NPF-72 and NPF-77.
The proposed amendment requests a change in the number of members of i
the On-Site Nuclear Safety Group.
The detailed description is contained in Attachment A, the revised Technical Specification page is contained in Attachment B.
The proposed changes have been reviewed and approved by both on-site and off-site review in accordance with Commonwealth Edison procedures.
Commonwealth Edison has reviewed this proposed amendment in accordance with 10 CFR 50.92(c) and has determined that no significant hazards consideration exists.
This evaluation is documented in Attachment C.
Commonwealth Edison has evaluated the proposed amendment with the requirements of 10 CFR 51.21. Attachment D.contains the corresponding Environmental Assessment Statement.
6 Commonwealth Edison.is notifying the State of Illinois of our application for this amendment by transmitting a copy of this letter and its attachments to the designated State Official.
Please direct any questions on this matter to this office.
l s
Very truly yours, R. A Chrzanowski Nuclear Licensing Administrator Attachments: A) Detailed Description B) Proposed Technical Specification Changes C) Evaluation of Significant Hazards Consideration D) Environmental Assessment Statement cc:
Resident Inspector Braidwood S. P. Sands -.NRR Regional Administrator - RIII Office of Facility Safety - IDNS 0245T:1 b
i' ATTACHMENT A Following the accident at Three Mlle Island Unit 2, the NRC Staff developed the Action Plan, NUREG-0660, to provide a comprehensive and integrated plan to improve safety at power reactors.
In November, 1980 a set of TMI related actions from NUREG-0660, which were approved for implementation by the Commission, were published in the document NUREG-0737.
Included in this NUREG was Item I.B.I.2 - Independent Safety Engineering Group (ISEG).
Under the heading of " Position", the following requirements for the l'iEG were provided:
"The principal function of the ISEG is to examine plant operating characteristics, NRC lssuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience inform &tton that may indicate areas for improving plant safety.
The ISEG is to perform independent review and audits of plant activities including maintenance, modifications, operational problems, and operational analysis and aid in the establishment of programmatic requirements for plant activities."
"Another function of the ISEG is to maintain surveillance of plant i
operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable.
ISEG will then be.in a position to advise utility management on the overall quality tnd safety of operations."
l In NUREG-0800 Item II.3.6., it is further stated that "That group i
shall be comprised of a minimum of five dedicated, full-time engineers, located on-site, out reporting off-site to a corporate official who holds a high-level, technically oriented position who is not in the management chain for power production.
For utilities with multiple sites, it may be possible to perform portions of the independent safety assessment function in a centralized location for all the utility's plants.
In suen cases, on On-site Group still is required, but it may be slightly smaller than would be the case if it were performing the entire independent safety assessment."
i The requirement for establishing an.ISEG was applied only to applicants for operating licenses.
Therefore LaSalle County Station was the first Edison station to have (NTOL) an ISEG followed closely by Byron and Braidwood.
The size of the ISEG at each of these three stations initially consist of four full-time engineers; presently only Braidwood has 4 full-time engineers as the other two stations have requested and have hkd approved Technical Specification changes reducing the site of the groups to 3 full-time h
engineers. Also, an ISEG has been added to Dresden.
It'is not required by L
the Technical Specification and its size is 2 full time engineers.,
These L
groups are administered by the Safety Assessment Manager who is located in the Company corporate offices.
The Safety Assessment Manager reports directly to Assistant V.P. Quality Programs & Assessment.
Zion and Quad Cities Stations do not have an ISEG; plans are to add groups at these 2 Stations as soon as L
personnel are available, Commonwealth Edison's nuclear program is large; there are six,
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two-unit nuclear stations.
The completion of Braidwood Unit 2 marks the end of the construction program in the nuclear division.
In March of 1989, there L
was a major reorganization of the Commonwealth Edison Company.
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7 t i ATTACHMENT A (continued)
The~new organization includes the Nuclear Operations Quality Programs and Assessment (QP&A) organization.
This group is headed by an Assistant Vice President (AVP) who reports directly to the Senior Vice President Nuclear Operations and is independent of plant operations.
Some of the responsibilities and functions of th!s organization duplicate the efforts of the ISEG.
The new corporate support groups interface with six stations; whereas, the ISEG only covers the four stations at present.
The QP&A organization has responsibility for performance assessment of the six stations.
They monitor station performance utilizing data trending and assessing work procedures and work practices. Among other things, they assess appropriateness of station programs in meeting regulations, standards and guidelines.
In addition, they apprise stat'lon and corporate management of performance problems including identification of underlying causes and timely resolution to problems.
Another function of QP&A is the implementation of the Operation Experience Assessment Program, which includes the coordinated development of corrective actions which are uniform across the six stations.
At the station level, the On-sitt tr+ latory Assurance Department is is under the functional control of the Nucien Licensing Department which is in QP&A.
This control provides consistency in the review of NRC licensing, inspection and enforcement correspondence, the tracking of commitments and evaluation of NRC' policies and regulations and their impact on he operating stations.
Another department that impacts on the functions of ISEG is the operational section of the On-site Quality Assurance Group.
Like the Department of Nuclear Safety, the Quality Assurance Department is entirely independent of the Nuclear Operations area and reports to'the AVP of OP&A.
The operational section of the on-site Quality Assurance Group at each of the six stations has one to two people licensed at the SR0 level.
With their knowledge of plant systems and the technical specifications they are able to perform a knowledgeable independent review and assessment of plant operations.
Since the ISEG is part of the technical specifications, the Quality Assurance Department conducts periodic audits of the ISEG to determine if they are in compliance with the requirements of the applicable section of the Technical Specifications.
The technical specification required functions of the ISEG are not changed by this proposed amendment.
Those review items listed in Technical Specification 6.2.3.1 will continue to be reviewed by the ISEG, however, the
(;
ISEG will make further use of the corporate level independent review work in l
performing on-site reviews.
Based on the above information, it has been concluded that the ISEG size could be reduced from four to three people without any loss in meeting the requirements of the technical specifications.
Using the material developed by all these other support groups in the Nuclear Operations area as a base, the ISEG can perform their functions in a more effective manner with a lower investment in manhours, and hence fewer people. The option for a lower number of personnel is permitted under NUREG-0800.
l
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ATTACHMENT B
.y-i EROPOSED CHANGE TO APPENDIX A.
TECHNICAL SPECIFICATIONS. OF FACILITY OPERATING LICENSES NPF-72 AND NPF-77 i
Revised Page:
6-2 1
5 i1 l-i r
l 99 // OTC)D 99, L
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~ ADMINISTRATIVE CONTROLS j
UNIT STAFF (Continued)
AUeast one licensed Operator shall be in the control room when b.
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 control room; i
,i A Radiation Protectiun Technician,* qualified in radiation protection d
c.
procedures, shall be on site when fuel'is in the reactor; All CORE ALTERATIONS shall be observed and directly supervised by
-I d.-
either a licensed Senior Operator or licensed Senior Ope stor Limited to Fuel Handlin this operation;g who has no other concurrent responsibilities during Administrative procedures shall be developed and implemented to.
e.
limit the workin functions; e.g.,g hours of unit staff who perform safety-related licensed Senior Operators, licensed Operators, health physics personnel, equipment operators, and key maintenance p
personnel.
j 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.
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6.2.3 ONSITE NUCLEAR SAFETY GROUP (ONSG)
FUNCTION 6.2.3.1 The ONSG serves as an independent safety engineering group and shall function to examine plant operating characteristics, NRC issuances, industry advisories, REPORTAELE 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 0NSG shall make detailed recommendations 1
for revised procedures, equipment modifications,- maintenance activities, opera-tions activities or other means of improving plant safety to the Safety Assessment Manager, and the Station Manager, Braidwood Station.
COMPOSITION iMeee 6.2.3.2 The ONSG shall be composed of at least deep, dedicated, full-time engineers located on site.
- The Radiation Protection Technician may be less than the minimum requirements I
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 ANENDNENT NO.
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ATTACHMENT C 4
Evaluation of Stanificant Hazards Consideration i
Commonwealth Edison has evaluated this proposed amendment and j
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 accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously evaluated; or 1
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.
i The proposed amendment will have no effect 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 often redundant to the technical specification responsibilities of the ONSG.
This proposed amendment'does not change ONSG areas of review as l
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.
There will be no change in the physical plant or in the way the plant is operated.
No new accidents are postulated. As a result, operation of the plant in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.
h The proposed amendment will not involve any physical change in the l
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 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 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.
/sc1:0245T:5
j ATTACHMERI_Q ENVIRONMENTAL ASSESSMENT STATEMENT T.
This proposed Amendment relates to changes in recordkeeping,-
I reporting, or administrative procedures or requirements. Accordingly, Commonwealth Edison believis this Amendment meets;the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (10).
Therefore, pursuant to 10 CFR 51.22-(b)..no environmental impact' statement or environmental-assessment is necessary in connection with this proposed amendment.
/scl:0245T:6 L
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