ML20210C284

Proposed Tech Spec Re Onsite & Offsite Reorganization

ML20210C284
Person / Time
Site:	Byron
Issue date:	09/10/1986
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20210C265	List: ML20210C263 ML20210C284
References
NUDOCS 8609180304
Download: ML20210C284 (17)

Text

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% 4 ATTACHMENT 1 PROPOSED CHANGE TO APPENDIX A TECHNICAL SPECIFICATIONS FOR BYRON STATION UNITS 1 AND 2 FACILITY OPPRATING LICENSE NPF-37 i

Revised Pastes 6-1 6-2 6-3 6-4

• 6-6 6-7 6-8 6-9 6-12 6-13 6-14 6-15 6-16 2093K 8609100304 060910 PDR ADOCK 05000454.

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ADMINISTRATIVE CONTROLS' '

d 6.1 RESPONSIBILITY Stehon (Donog*P" 6.1.1 The M -"+-ad:T Byron Station, shall be responsible for overall unit operation during and shall delegate in writing the succession to this responsibility his absence.

6.1.2 The Shift Engineer (or during his absence from the control room, a designated individual) shall be responsible for the control room command A function. A management directive to this effect, signed by the "'.. . .-. Vice President and General Manager-Nuclear Stations shall be reissued to all station personnel on an annual basis.

6. 2 ORGANIZATION OFFSITE -

6.2.1 The offsite organization for unit management and technical support shall be as shown in Figure 6.2-1.

UNIT STAFF 6.2.2 The unit organization shall be as shown in Figure 6.2-2 and:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; and

b. At least one licensed Operator shall be in the control room when -

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;

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

d. A # CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other cencurrent responsibilities during this operation;

e. A site Fire Brigade of at least five members

• shall be maintained onsite at all times. The Fire Brigade shall not include the Shift Engineer, and the two other members of the minimum shift crew i

necessary for safe shutdown of the unit and 'any personnel required for other essential functions during a fire emergency; and

• The Radiation Chemistry Technician and Fire Brigade composition may be less than the minimum requirements for a meriod 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.

. BYRON - UNITS 1 & 2 6-1

ADMINISTRATIVE CONTROLS-UNIT STAFF (Continued)

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f. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g... licensed Senior Operators, licensed Operators, 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).

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, REPORTABLE 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-tions activities or other means of improving plant safety to the Manager of

' NuclearSafety,andthego. . n - m n ;. , Byron Station.

a COMPOSITION Shaffon M4ndber 6.2.3.2 The ONSG shall be composed of at least four, dedicated, full-time

• engineers located on site.

RESPONSIBILITIES 6.2.3.3 The ONSG shall be responsible for maintaining surveillance of plant activities to provide independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

RECORDS 6.2.3.4 Records of activities performed by the ONSG shall be prepared, main-tained, and forwarded each calendar month to the Manager of Nuclear Safety, and the ' c .... .~m,&, Byron Station.

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6.2.4 SHIFT TECHNICAL ADVISOR The Station Control Room Engineer (SCRE) may serve as the Shift Technical Advisor (STA) during abnormal operating or accident conditions. During these conditions the SCRE or other on duty STA shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit.

"Not responsible for sign-off function.

i BYRON - UNITS 1 & 2 6-2

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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 turnover.

(2) During the shift, the shift engineer and the shift foreman (SRO) shall be made aware of any significant changes in plant status in a timely mannce by the SCRE.

(3) During the shift, the shift engineer and the shift foreman (SRO) shall remain abreast of the current plant status. The shift foreman (SRO) sna11 return to the control room two or three times per shift, wnere practicable, to confer with the SCRE regarding plant status. Where net practicable to return to the control room, the shift foreman (SRO) shalt periodically check with the SCRE for a plant status update. The shift forsman ($AO) shall not abandon duties original to reactor operatien, unless soecif.ically ordered by the shift engineer.

6.3 UNIT STAFF QUALIFICATIONS f 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualiff-cations of ANSI N18.1-1971, except for the Rad / Chem Supervisor or Lead Health Physicist, who shall meet or exceed the qualifications of Regulatcry Guide 1.8, September 1975, for a Radiation Protection Manacer. The licensed Operators and Senior Oparators shall also meet or exceed the minimum qualifications of the

• supplemental recuirenents specified 'in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.

6.4 TRAINING s 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the 7toduction Training Department and shall meet or exceed the requirements and reccomendations of Section 5 of AN$!/

ANS 3.1-1978 and Appendix A of 10 CFD Part 55 and the supplemental requirements  ;

specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter -

to all licensees, and shall include famili.arization with reltavant industry operational experience toentified by the "TT?s. of Nuclear Safety.

6.5 REVIEW INVEST!GATION ANC AUDIT

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The Review and Investigative Function and tne Audit Fun: tion of act-ivities affecting quality during facility opeaations shall be constituted and have the responsibilities and autherities outlined below.

BYRON - UNITS 1 & 2 6-6 [

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T ADMINISTRATTE CONTROLS

6. 5 REVIN INVESTIGATION AND AUDIT (Continued) 0FFSITE

5. 5.1 The Supervisor of the Offsite Review and Investigative Fonction shall be appointed by the Manager of Nuclear Safety responsible for nuclear activities.

The audit function shall-be the responsibilicy of the Manager of Quality Assurance and shall be indepencent of oper.ations.

a. Offsite F.eview and Investigative Function The Supervisor of the Offsite Review and Investigative Functicn shall: (1) provide directions for the review and irivestigative function aco appoint a senior participant to provide appropriate cirection, (2) select each participant for this function, (3) select a templement of more than one participant who collectively possess background and qualifications in the subject matter under review tc provide ccmprehensive interdisciplinary review coverage under -

this function, (4) independently review and approve the findings and recernmendations developed by personnel performing the rniew g o p, p y F ar1 W orinvestigative all finding:function, (5) approve and report in a timelyof non-comp Statihr-int:-M, DM:'fvice President and General Manager -

huclear Stations, Hanager of Quality Assurance, and the Vice President -

- Nuclear Operations. During perf oos when the Supervisor of Of fsite Review and Investigative Function is unavailable, he shall designate this resoonsibility to an established titernate, who satisfies the

• formal training and experience for the Supervisor of the Offsite Review and Investigative Function. The responsibilities of the per-sonnel perforring this function are stated below. The Cffsite Review anc Investigative Function shall review:

1) Tre safety evaluations for: (1) changes to proceduret, equip-eent, or systems as described in the safety analysis report, and (2) tests or azperiments completed unocr the provision of 10 CFR 50.59 to verify that suct actions did not constitute an unreviewsd safety question. Preposed changes to the Quality Assurance Program descriotion shall be reviewed and apprcved by the Manager of Quality Assurance;

2) Proposed changes to procedures, equipment or systems which '

invohe an unreviewed safety questien as defired in 10 CFR 50.59:

3) Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59;

4) Proposed changes in Technical Specifications or this 0;erating License; BYRON - UNIT 3 1 & 2 6-7

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ADMINISTP.ATIW CONTRCt.5 '

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0FFSITE (Continued) 5)

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Noncompliance with Codes, regulations, orders, Technical Spect-fications, license requirements, or of internal prochdores, or instructions having nuclear safety significance;

6) .Significant operating abnormalities or deviation from normal and expected performance of plant equipment that affect nuclear safety as referred to it by the Onsite Review and Investigative Function;

7) All REPORTABLE EVENT 5;

8) All recognized indications of an unenticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components;

9) Reviw and report findings knd reccmmendations regarding all changes to the Generating Stations Emergency Plan prior to

• implementation of such change; and ~

10) Review and report findings and recommendations regarding '

all items referred by the Technical Staff Supervisor, Station M eaneger- t~^+-C., "; i. :- Vice President and General Manager -

Nuclear Stations, and Manager of Quality Assurance.

b.

AspMed Audit Function .

The audit functicn shall be the responsibility of the Manager of Quality Assurance independer.t of the Production Department. Such responsi ity is delegatedto the Director of Quality Assurance (Operati -2 (Maintenance).and the

• M . M .g NL . Quality Assurance Either shall approve the audit egenda and checklists, the findings and the report of each audit. Aucits shall be perforned in accord-ance alth tne Ccmpany Quality Assurance Program and Procedures.

Audits shall be performed to Essure that safety-related functions are covered witiiin the period designated below:

1) The confermance of facility operation te provisions contained within the Technical Specifications and, applicable license conditions at least once per 12 months;

2) The adherence to procedure, trainin:, and qualification of the station staff at l. east once per 22 runths;

3) The results of actions then to correct deficiencias occurring in facility equipment, structuras, systems, or metneds of ope.ation that affect nuclear safety at least once per 6 months;

4) The performance of activities required by the Operational Quality Assurance Prog'*am to meet the criteria of Appendix 8, 10 CFR Part 50, at least once per 24 months; BYRON - UNIT 5 1 & 2 6-8

ADMINISTRATIVE CONTROLS OFFSITE (Cor,tinued) *

5) The Facility Emergency Plan and implementing procedures at least once per 12 months;

6) The Facility Security Plan and implementing procedures at least once per 12 months;

7) Onsite and'offsite reviews;

8) The Facility Fire Protection programmatic controls incivding the implementing procedures at least once per 24 months by qualified QA personnel; i

9) The fire protection equipment and program implementation at least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire pro-tection cc.1sultant shall be used at least every third year; *

10) The Radiological Environmental Monitoring Program and the results thereof at least once par 12 months;

11) The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months;

12) Thi, PROCESS CONTROL PROGRAM and implementing procedures for solidification of radioactive wastes at least once per 24 months;

• and

13) The performance of activities required by the Company Quality Assurance Program for effluent and environmental monitoring at least once per 12 months.

Report all findings of noncompliance with NRC requirements and recommendations M

MG, Manager of and resultsSafety, Nuclear of eachthe audit M.to' .mVice the Station ' fi.

President and MF General Manager - Nuclear Stations, Manager of Quainy Assurance, Mb the Vice Chairman, and the Vice President - Nuclear Operations.

c. Authority The Manager of Quality Assurance and the Manager of Nuclear Safety report to the Chairman and President. Either the Manager of Quality Assurance or the Manager of Nuclear Safety has the authority to order unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions.

BYRON - UNITS 1 & 2 6-9

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ADMINISTRATIVE CONTROLS' -

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OFFSITE (Continued) -

h) Instrumentation and Control Engineering graduate or equivalent with at least 5 years of experience in instrumentation and control design and/or operation.

1) Metallurgy Engineering graduate or equivalent with at least 5 years of experience in the metallurgical field.

3) The Supervisor of the Offsite Review and Investigative Function shall have experience and training which satisfy ANSI N18.1-1971 requirements for plant managers.

• ONSITE 6.5.2 The Onsite Review and Investigative Function shall be supervised by.

the Station L,... :.._._..;.Monager. .

a. Onsite Review and Investigative Function The Station a;an.e3;u-y :n ~ nt.it shall: (1) provide directions for the Review and Investigative Function and appoint the Technical Staff

. Supervisor, or other comparably qualified individual as the senior participant to provide appropriate directions; (2) approve partici-pants fur this function; (3) assure that at least two participants .

who collectively possess background and qualifications in the sub-ject matter under review are selected to provide comprehensive interdisciplinary review coverage under this function; (4) indepen-dently review and approve the findings and recommendations developed by personnel performing the Review and Investigative Function; (5) report all findings of noncompliance with NRC recuirements and p e g provide recommendations to the 0h'-MVice President and General Manager - Nuclear Stations and the Supervisor of the Offsite Review and Investigative Function; and (6) submit to the Offsite Review and Investigative Function for concurrence in a timely manner, those items described in Specification 6.5.la which have been approved by the Onsite Review and Investigative Function.

b. Responsibility ,

The responsibilities of the personnel performing this function are:

1) Review of: (1) station specific portions of all procedures required by Specification 6.8.1 and changes thereto, (2) all programs required by Specification 6.8.4 and changes thereto, and (3) any other proposed procedures or changes thereto as determined by the Station U :.' 1 .. ..;. to affect nuclear safety; NM$W"

2) Review of all proposed tests and experiments that affect nuclear safety; BYRON - UNITS 1 & 2 6-12 1

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ADPfINISTRATIVE CONTROLS ~

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ONSITE (Continued)

3) Review of all proposed changes to the Technical Specifications;

4) Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety;

5) Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the A55OrdN Vice President and General Manager - Nuclear Stations and to the Supervisor of the Offsite Review and Investigative Function;

6) Review of all REPORTABLE EVENTS;

7) Performance of special reviews and investigations and reports thereon as requested by the Supervisor of the Offsite Review and Investigative Function; .

8) Review of the Station Security Plan and implementing procedures and submittal of recommended changes to the Of. L E"Vice A58W President and General Manager - Nuclear Stations;

9) Review of the Emergency Plan and station implementin

. and shall submit recommended changes to the Ohi t rocedureg ice A88 "i""_1 President and General Manager - Nuclear Stations;

10) Review of Unit operations to detect potential hazards to nuclear safety;

11) Review of any 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 A A 65 M 0i; L .m. Vice President and General Manager - Nuclear Stations and the Supervisor of the Offsite Review and Investigative Function; and

12) Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and the Radwaste Treatment Systems.

c. Authority

• The Technical Staff Supervisor is responsible to the Station Meneger E;r'-tru and shall make recommendations in a timely manner in all areas of review, investigation, and quality control phases of plant maintenance, operation, and administrative procedures relating to facility operations and shall have the authority to request the action necessary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station N 4M4$"" 97 ' n . _ shall follow such recommendations or select a course BYRON - UNITS 1 & 2 6-13

ADMINISTRATIVE CONTROLS ONSITE (Continued) of action that is more conservative regarding safe operation of the facility.

ASS -

All such disagreements shall be reported immediately to the Ti.i;i; Vice President and General Manager - Nuclear Stations and the Supervisor of the Offsite Review and Investigative Function.

d. Records g

1) Reports, reviews, investigations and recommendations shall be documented with copies to the A ...... Vice President and General Manager - Nuclear Stations, the Supervisor of the Offsite Review and Investigative Function, the Station S r i.-t zd...t, and the Manager of Quality Assurance. N* f5*S

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2) Copies of all records and documentation shall be kept on file at the station,

e. Procedures Written administrative procedures shall be prepared and maintained for conduct of the Onsite Review and Investigative Function. These procedures shall include the following:

Harm 0ger s'

1) Content and method of nd presentation to the

' StationCr..J.xJm(submission , Di ! & .. Vice President and General Manager - Nuclear Stations, and the Supervisor of the Offsite Review and Inves+igative Function, .

2) Use of committees,

3) Review and approval,

4) Detailed listing of items to be reviewed,

5) Procedures for admiH stration of the quality control-activities, and

6) Assignment of responsibilities,

f. Personnel

1) The personnel performing the Onsite Review and Investigative i

F consistnction, of in addition persons to the having O m Mim. , , shall Station in:

expertise 8.9er

.O Nuclear poser plant technology,

• )

. Reactor cperations, c) Reactor engineering, d) Chemistry e) Radiological controls, f) Instrumentation and control, and g) Mechanical and electrical systems.

BYRON - UNITS 1 & 2 6-14

) . l ADMIN 1STRATIVE CONTROLS ONSITE (Continued)

2) Personnel performing the Onsite Review and Investigative Function shall meet minimum acceptable levels as described in ANSI N18.1-1971, Sections 4.2 and 4.4.

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

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

b. Each REPORTABLE EVENT shall be reviewed by the Onsite Review and Investigative Function and the results of this review shall be submitted to the Offsite Review and Investigative Function and the AS8IM9+r$w$wr Vice President and General Manager - Nuclear Stations.

6.7 SAFETY LIMIT VIOLATION -

6.7.1 .The following actions shall be taken in the event a Safety Limit is violated:

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soon as TheNRCOperationsCentershallbenotifiedbytelephon[icePre possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The E %:... v

, and General Manager - Nucl~ ear Stations and the Offsite Review and Investigative Function shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;' ,

b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the Onsite Review and Investigative Function. This report shall describe: (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective action taken to prevent recurrence; gg

c. The Safety Limit Violatich Report shall be submittea to tne mmission, the Offsite Review and Investigative Function and the E '-#_ Vice President and General Manager - Nuclear Stations within 14 days of the violation; and

d. Critical operation of the Unit shall not be resumed until authorized by the Commission.

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained

. covering the activities referenced below:

I

a. The applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978, l

BYRON - UNITS 1 & 2 6-15 L

ADMINISTRATIVE' CONTROLS' 2.L PROCEDURES AND PROGRAMS (Continued)

b. The emergency operating procedures required to implement the require-ments of NUREG-0737 and Supplement I to NUREG-0737 as stated in Sec-tion 7.1 of Generic Letter No. 82-33;

c. Plant Security Plan implementation,

d. Radiological Emergency Response Plan implementation,

e. PROCESS CONTROL PROGRAM implementation,

f. OFFSITE 00SE CALCULATION MANUAL implementation, and

g. Quality Assurance Program implementation for eff1'uent and environ-mental monitoring.

6.8.2 Each procedure of Specification 6.8.1 above, and changes thereto, shall be reviewed prior to implementation as set forth in Specification 6.5 above. '

6.8.3 Temporary changes to procedures of Specification 6.8.1 above, may be made provided:

a. The intent of the original procedure is not altered;

b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Operator license on the Unit affected; and *

c. The change is documented, reviewed by the Onsite Review and Investi-gative Function, and approved by the Station '" M ... .. .. within 14 days of implementation. 8 8 M S ,$ C

.6.8.4 The following programs shall be established, implemented, and maintained:

a. Reactor Coolant Sources Outside Containment .

A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the recirculation portion of the Containment Spray System, Safety Injection System, Chemical an.d Volume Control System, and RHR System. The program shall include the following:

1) Preventive maintenance and periodic visual inspection requirements, and

2) Integrated leak test requirements for each system at refueling cycle intervals or less.

BYRON - UNITS 1 & 2 6-16

ATTACHMENT 2 SUI 9tARY OF CHANGES The proposed changes identified in the Byron Station Technical Specifications fall in one of three categories, as indicated below. All changes are considered to be administrative in nature.

1) Title Channes: Due to organizational changes within Commonwealth Edison, two position titles found in the Technical Specifications are no longer appropriate. The title of

" Station Superintendent" should be replaced with " Station Manager" and " Division Vice President" should be replaced with

" Assistant Vice President". This is considered to be an administrative change.

2) Inappropriate Names / Titles: The correct name for the " Office of Nuclear Safety" is the." Department of Nuclear Safety", and this substitution should be made in Section 6.4 of the Byron Tech Specs. Additionally, the title of the Quality Assurance

! individual responsible for maintenance found in Section 6.5.lb of the Byron Tech Specs is " Director of Quality Assurance (Maintenance)", not " General Supervisor". This is considered to be an administrative changes.

i 3) Typographical channes: Section 6.2.2d, replace the word "ALL" 4

with "All" and replace the word " Operating" with " Operations",

in Section 6.S.lb. This is considered to be an administrative changes.

l l.

ATTACHMENT 3 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Description of Amendment Request The requested change involves revising the on-site and off-site organizations for Commonwealth Edison to reflect our most current organizational structure. Additionally, this proposed license amendment seeks to make typographical changes and correct title inaccuracles.

Basis for Proposed No Sianificant Hazards Consideration Commonwealth' Edison.has evaluated this proposed amendment and determined that it involves no significant hazards considerations. In accordance with the criteria set forth in 10CFR 50.92(c), the proposed amendment does not:

1) Involve a significant increase in the probability of I

consequences of an accident previously evaluated because:

a)- the proposed amendment merely revises the Commonwealth Edison on-site and off-site organizational structure as found in the Byron Station Technical Specifications.

This has no impact on plant design or operations, hence, i the probability or consequences of previously evaluated accident is unaltered.

2) Create the possibility of a new or different kind of accident previously evaluated because:

l a) the proposed amendment does not' introduce any new equipment or modes of operation in Byron Station that I could create the possibility of a new or different kind of accident that that which was previously evaluated.

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3) Involv3 o oignifictnt reducticn in tha margin cf s fsty, because; a) these changes'are considered to be administrative.

There are no changes being made to hardware or in the manner that plant systems are being operated as a result of this license amendment. Therefore, the margin of safety is not being compromised or i changes.  !

Based on the preceeding assessment, Commonwealth Edison has determined that this proposed amendment involves no significant hazards consideration and request its approval in accordance with the provisions of 10CFR 50.91(a)(4).

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