ML20118A709

Proposed,Revised TS Page 6-6 Re Unit Staff Qualifications & Training & Replacement Training for Unit Staff

ML20118A709
Person / Time
Site:	Byron, Braidwood
Issue date:	09/16/1992
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20118A708	List: ML20118A707 ML20118A709
References
NUDOCS 9209250029
Download: ML20118A709 (6)

Text

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i AUACllMENLD PJROEOSED.CilANGES_TO.APPENDIXA TEcliN10ALSEEC.IE10AIDNS_EOB EACluTYOPEBATINGLICENSES NEE-37. NEE-03. NPF32 AND. NEE-77 Hovisod Page 66 f

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ADMINISTRAVIVE CONTROLS 6.3 UNIT STAFF y 'ICATIONS 6.3.1 Ev h me w . : the unit staff shall meet or exceed the minimum qualifi-cations of ANSI fu8.1-1971, except for the Health Physics Supervisor or Lead h-Health Physicist, who shall meet or exceed the qualifications of Regulatory Guide 1.8, Septemt,er 1975, for a Radiation Protection Manager. -The-44 censed-4pwawors-and-Senier Operator chall :Ise meet-cr eweed-the-e4a4MWHjU lIfiCa" 44 ens-of the :upple=nt:1 require =nt: pec44+d-P Sectien: ^ and C of

-Ent4csurc 1 of the Kweh 23 1980 .""C -letter tMM-44ecreccc.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Production Training Department and shall meet or exceed the requirements and recommendations of Section 5 of ANSI / .

ANS 3.1-1978 and Append!" ^ ef 10 CP omrt 55 nd the tupp4 cent:1 require =nts--

spec!ffed-in Sectiera ,^. and C of N 10: arc 1 cf-th: "cr:F 2S, 1990 ""C letter

-to >H-Meensees, and shall include familiarization with relevant industry operational experience from the program managed by Quality Programs and -

Assessment. <' -

6.5 REVIEW INVESTIGATION AND AUDIT The Review and Investigative Function and the Audit Function of activities affecting quality during facility operations shall be constituted and have th0 r c .'itdlities and authorities outlined below.

OFFLI(L 6.5.1 The Superintendent of the Offsite Review and Investigative function -

shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS) G responsible for nuclear activities. The corporate audit function shall be the /

responsibility of the Manager of QA/NS and shall be independent of operations.

The Manager of QA/NS reports directly to the Chief Executive Officer and has the responsibility to set Corporate Policy for both the areas of Quality (-

Assurance and Nuclear Safety. Policy is promulgated through a central policy 3 committee directed by the Manager of QA/NS. The Manager of QA/NS has the /

responsibility for the perforruance of periodic audits of each nuclear station and corporate department to determine that QA/NS policy is being carried out,

a. Offsite Review and Investigative function The Superintendent of the Offsite Review and Investigative Function shall: (1) provide directions for the review and investigative-function and appoint a senior participant.to provide appropriate direction, (2) select each participant for this function, (3) select a complement of mcre than one participant who collectively possess background and qualifications in the subject metter under review to provide comprehensive interdisciplinary review coverage under this function, (4) independently review and approve the findings and recommendations developed by personnel performing.the review BYRON - UNITS 1 & 2 6-6 AMENDMENT NO. JI

a ADMINISTRATIVE CONTROLS 6.2.4 SHIFT TECHNICAL ADVISOR (Continued)

To assure capability for performance of all STA functions:

(1) The shift foreman (SRO) shall participate in the SCRE shift relief l turnover.

(2) During the shift, the shift engineer 9 d the shift foreman (SRO) shall be ,

made aware of any significant changes in plant status in a timely manner by the SCRE.

(3) During the shift, the shift engineer and the shift foreman (SRG) shall remain abreast of the current plant status. The shift foreman (SRO) shall return to the control room two or three times per shift, whtre practicable, to confer with the SCRE regarding plant t,tatus. Where not practicable to return to the control room, the shift foreman (SRO) shall periodically '

check with the SCRE for a plant status update. The shift foreman (SRO) '

shall not abandon duties original to reactor operation, unless specifically ordered by the shift engineer.

6. 3 UNITSTAFFQUA,llflCA110NS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifi- c? --

cations of ANSI N18.1-1971, except for the Health Physics Supervisor or Lead Health Physicist, who shall meet or exceed the qualifications of Regulitory Guice 1.8, September 1975, for a Radiation Protection Manager. ec ' huw,e4 4perater3 and Safee4pecotees-sha44-o4+e-eeet-oe-eeeed-the-m44 mum-gsa'i f tet+ont-ef--the-tttpp4emente4--eectrirementepeeHied in Sections-*-end+t f feele;ur 1 of4he-Heeeh487-1980446-4et4er- t 011 licemen.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Production Training Department and shall meet or exceed the requirements and recommendations of Section 5 of ANS]/

AN5 3.1-1978 -and-Appeedh ? cf 10 CM-Pert 55 ciMh: : upp!:::-t ! re:c:' r t

.pcr. i f ied-4Hect>, ens A end- C ef Ench.wr 1ef1% b a 23,l'.w NRC Ntiv.

to-a44-44censees, and shall include f amiliarization with relevant industry

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operational experience from the proram managed by Quality Programs and Assessment. C')

6. 5 REVIEW INVESTIGATION AND AUDIT The Review and Investigative function and the Audit function of activities affecting quality during facility operations shall be constituted and have tne responsibilities and authorities outlined below, i

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

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. ATTACHMENLC l

SUMMARY

_OfLTilE EVALUATION OESIGNIEICANT liAZABDS_CONSIDERATKMS l

Commonwealth Edison Compan (CECO) has evaluated t, 's proposed amendment and I detormined that it involves no si nificant hazards considorations. According to Titio 10, 1 Codo of Fodoral Regulations, P tt 50, Section 92, Paragraph (c) [10 CFR 50.92(c)), a i proposed amendment to an operating licenso involves no significant hazards I considerations if operation of the facility in accordance with the proposed amendment would not: i I  :

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1. Involve a significant increase in the probability or  !

consequences of an hacident provlourly evaluatod; or l l

2. Create the possibility of a now or different kind of accident from any accident previously evaluated; or i 3. Involvo a sl0nificant reduction in a margin of safety.

The basis for this determination of no significant hazards considerations is presented below.

l The proposed amendment would doloto the reference to the March 28,1980 NRC letter to all ilcensees in Specifications 6.3.1 and 6.4.1. Additionally, a reference to Appendix A of 10CFR Part 55 is being removed. This appendix was previously incorporated into the body of 10CFR Part 55.

The purpose of the March 28,1980 NRC letter to alllicensees was to set forth revised critoria to be used by the NRC staff in evaluating reactor operator training and licensin0 under the regulations in offect at the time of the etter. These revised criteria were established based on the Commission review of the Three Milo Island Unit 2 accident which occurred on March 28,1979. The letter stated that the Commission review in tho area of operator training and qualification would continue and could be expected to i result in additional critoria being ostablished. The letter also stated that final requirements would be established throu0hrulomaking proceedings.

The continued Commission review in the area of operator training and qualification resulted in revisions to 10 CFR 55 and the issuance of NUREG-1021, Operator l Licensing Examiner St8ndards, which provides guidance regarding the implementation of 10 CFR 55 requiremente. These requirements supercede those delineated in the March 28,1980 NRC letter to oil licensees.

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9 Since the initial license examinations at both Byron and Braldwood Stations, operator training and qualification has been evaluated against the requirements of NUREG 1021.

Additionally, a reference to Appendix A of 10CFR Psrt 55 is being removed. This appendix was areviously incorporated into the body of 10CFR Part 55. These changes are considerec to be administrative in nature.

The Chapter 15 Analyses are unaffected by this reques' The proposed change will have no effect on the sequence of events leading to the initiation of a transient. The chapter 15 Analyses assume a range of mechanical failures (l.o. pipe breaks, loss of heat sink, etc.) as the initiating event for the purpose of demonstrating the continued protection of the public. These failures are not assumed to be triggered by personnel actions. As such, the specific training requirements for the plant staff are not related to the probability of the occurrence of a previously analyzed accident.

The consequences of any previously analyzed accidents are not increased. The licensed Operators and Senior Operators at Byron and Braidwood Stations are trained in accordance with a Systems Approach to Training based program that has been accredited by the Institute for Nuclear Power Operations and evaluated against the requirements of NUREG-1021. Successful completion of this training 3rovides a high level of confidenca that operator actions assumed by the accident ana yses will occur when required to mitigate the consequences of the accidents. Additionally, specifiu.

short term actions assumed by the analyses are procedurally directed.

There is no possibilty of an accident or malfunction of a type different from those described in the SAR occurring as a result of this proposed change. This change does not alter the installed configuration of any plant equipment. The plant equipment

• not operated in a new or different manner, nor are there any equipment or system interactions introduced by these revisions. As such, no new or different failures are introduced, and hence, accidents of a new or different type will not be created by the change to the noministrative requirements governing the qualification of licensed operators.

l There will be no reduction in the margin of safety as a result of the proposed change.

The proposed change to the Technical Specifications are administrative in nature and

have no effect on alant equipment or the setpoints at which the equipment would be actuated to mitigaLe the consequences of an accident, i

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i ATTACHMENT D  !

ENVIRONMENTAL ASSESSh4ENT STATEMENT [

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l l Commonwealth Edison has ovaluated the proposed amendment aDainst the criterla for  ;

I and identification of licensin0 and regulatory actions requirin0 environmentat ,

assostment in accordance with 10 CFR 51.21. It has boon dolormined that the proposed changos moot the critoria for a categorical exclusion as provided for under 10 '

i CFR 51.22(c)(9). This determination is based on the following:

1. These changes are being " 7 posed as an .tmondment to a license for a reactor oursuant to 10 CFh .s0 which cho.1ges a requiremont with respect to the qua ification and training of licensed Operators and Senior Operators,

2. the amendment involves no significant hazy?ds consideration,

3. there is no significant increase in the amounts of any offluents that may be released offsito, and

4. there is no significant increase in individual or cumulative occupational i radiation exposure, k

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