ML20214Q984

Proposed Tech Specs,Recognizing Creation of Central Illinois Electric Generating Co as Subsidiary & co-licensee of Facility

ML20214Q984
Person / Time
Site:	Braidwood
Issue date:	05/28/1987
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20214Q957	List: ML20214Q955 ML20214Q984
References
NUDOCS 8706050286
Download: ML20214Q984 (8)

Text

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ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 4

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MO mw 6.1.1 The Station Manager, Braidwood S shall be responsible for overall unit operation and shall delegate in writing the succession to this responsi-bility during his absence.

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• n The Shift Engi M^ (*o*r during his absence from the control room, a

"( nanwe 6.1.2 cesignateh individual) shall be responsible for the control room command function.

A management directive to this effect, signed by the Assistant Vice President and General Manager Nuclear Stations shall be reissued to all y

station personnel on an annual basis.

G C.ommm eo /M, Ed, s o n 6.2 ORGANIZATION OFFSITE commoq u., ea !

• h Gils* n Thekoffsiteorganizationforunitmanagementandtechnicalsupportshall 6.2.1 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 compositicn 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; d.

All 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 concurrent 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 necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency; and 8706050286 870528 PDR ADOCK 05000456 P

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

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FENCE LINE ________________j EXHIBIT G

-M BRAIDWOOD STATION DETAIL I

i UNITS 1 & 2 f

Sheet - 2

ATTACHMENT 1 The following general information is provided in support of the application for license amendment.

I.

Subsidiary A.

Name: Central Illinois Electric Generating Company B.

Address:

P.O. Box 767 Chicago, IL 60690 C.

Business

Purpose:

The Subsidiary will be a corporation established to hold title to the Facility and, through Commonwealth Edison Company as agent, operate the Facility for the purpose of selling the electricity generated thereby in accordance with rates approved by the Federal Energy Regulatory Commission.

D.

Organization and Management: The Subsidiary has not yet been created.

It will be created sometime in the future after favorable consideration by the Illinois Commerce Commission. The Subsidiary will be a corporation organized and existing under the laws of the State of Illinois. Its principal office will be located in Chicago, Illinois. All of the stock of the corporation will be owned by Commonwealth Edison Company. All of the subsidiary's directors and principal officers will be employees of Commonwealth Edison Cowpany.

All will be citizens of the United States. They will be:

Name Subsidiary and Edison Position James J. O'Connor Chaiman and President

• Wallace B. Behnke, Jr.

Vice Chairman

• Bide L. Thomas Executive Vice President

• Raymond P. Bachert Vice President and Comptroller Harlan M. Dellsy Vice President and General Counsel James W. Johnson Vice President Thomas J. Maiman Vice President Robert J. Manning Vice President Donald A. Petkus Vice President Cordell Reed Vice President George P. Rifakes Vice President J. Patrick Sanders Vice President John J. Viera Vice President Ernest M. Roth Treasurer Klaus H. Wisiol Secretrary

• Also will be members of the Board of Directors of Central Illinois Electric Generating Company

. It is not contemplated that the Subsidiary will have any other employees with the possible exception of a few administrative staff persons. As explained below, all personnel and other resources needed to operate, maintain and decommission the Facility safely will be provided by Commonwealth Edison Company.

II.

Facility Under the Facilities Transfer agreement, title to the Facility will be conveyed to the Subsidiary, including control over the site exclusion area as described in Section 2.1 of the Safety Evaluation Report, dated November, 1983, which was issued by the NRC for Braidwood Station.

The Facility is depicted in Exhibit G, Sheets 1 and 2, and consists of the following structures and equipment for each unit:

a.

Reactor Containment b.

Reactor Vessel c.

Reactor internals including control rod drive mechanisms, instrumentation and detectors, pressurizer and steam generators including separator and dryer.

d.

Cranes and floists used solely in connection with operation of the Unit e.

Main and Misc. Instrument and control Panels f.

Piping, including valves and supports used solely in connection with operation of the Unit g.

Circulating Water Pumps used solely in connection with operation of the Unit h.

Turbine (including foundation) 1.

Generator (including foundation)

_ _ _ _ _ ~ -

. j. Condenser k.

345 KV Main power Disconnect Switch (1/2 interest) 1.

Cooling Lake III. Technical Oualifications The NRC has determined under the operating license that Commonwealth Edison company is qualified to operate the Facility. These circumstances will not change as a result of the proposed license amendment. The Subsidiary will appoint commonwealth Edison as its agent responsible for the operation, maintenance and decommissioning of the Facility. This relationship is established under paragraphs 4 and 13 of the Construction and Operating Agreement (Exhibit D).

paragraph 13 also states that the Subsidiary shall have no right to " assign, convey, pledge or otherwise transfer any of its rights" without the written consent of Commonwealth Edison Company. Moreover, as sole owner of the shares of the Subsidiary, Edison will control all decision-making to assure that the Facility's nuclear operations organization, which was found technically qualified by the NRC in its Safety Evaluation Report (SER, dated November, 1983), will remain in place. Finally, the NRC will have regulatory control over the subsidiary as a co-licensee of the Facility as well as Edison thereby subjecting any change in the operating entity of the Facility to the NRC's approval.

IV.

Financial Oualifications Commonwealth Edison Company is responsible financially for the operation, maintenance, and decommissioning of the Facility under the proposed amendment and as set forth in Article II of the Financing Agreement as that term is used in the NRC's regulations (Exhibit E).

In accordance with its obligations under those regulations, commonwealth Edison Company commits to provide the necessary financial resource to operate, maintain and decommission the Facility safely.

Commonwealth Edison company is an electric utility as defined in 10 CFR Section 50.2, and pursuant to 10 CFR Section 50.33(f) and 57.57(a)(4) no finding of financial responsibility to operate the Facility was required when the operating license was issued. None is required of the Subsidiary since (i) Commonwealth Edison is assuming full responsibility for the Facility, and (ii) the Subsidiary also qualifies as an electric utility under 10 CFR Section 50.2 because as the owner of the Facility its legal status properly qualifies it as a generator and seller of electricity through rates established by a separate regulatory authority.

ATTACHMENT 2 Antitrust Review Commonwealth Edison Company submitted the requisite information under 10 CFR Section 50.33a and Appendix L to Part 50 in connection with the operating license antitrust review for Braidwood Unit 1.

The information was reviewed by the Attorney General and comments were solicited from the public.

1 On September 18, 1986 the NRC's Director of the Office of Nuclear Reactor Regulation made findings, in accordance with Section 105(c)(2) of the Atomic Energy Act of 1954, as amended, that no significant changes had occurred since the construction permit reviews by the Attorney General and the NRC for Braidwood Unit I which would require a second antitrust review in connection with the OL application.

(See 51 Fed. Reg. 34171 (September 25, 1986)).

The following discussion will demonstrate that neither the Agreement which occasions this Amendment application nor its implementation constitute changed circumstances which raise any significant issues under the antitrust laws or which require a further antitrust review.

For a period of five to eight years after the effective date of the Agreement, Edison (and through it, Edison's customers) will be entitled to all of the power generated by the Units. That is no different from the situation without the Agreement. At all times, both with and without the Agreement, the price of power generated by the Units, and thus as an economic matter, what is paid for entitlement to the power, is subject to regulatory control. The Illinois Commerce Commission controls the price of power sold to Edison's retail customers and the FERC controls the price of power sold to other utilities (including municipal systems).

What may be different under the Agreement is that after the initial period (the duration of which, 5 to 8 years, is to be determined by the Illinois commerce Commission) is the identity of the utility entitled to the power and, more importantly, what is to be paid for that entitlement. Under Edison's ownership, the situation without the Agreement, the amount paid for entitlement to the power is determined by traditional rate base / rate of return regulation. Such regulation serves to place both a cap and a floor on the amounts (rates) paid for the electricity generated. However, with the subsidiary's ownership of the Units under the Agreement, the amounts paid for entitlement to the power may be lower than with Edison's ownership. The Subsidiary, unlike Edison, has no service territory and thus, has no assured market for the power. This means that the Subsidiary may be unable to sell the power at prices equivalent to those permitted by regulation.

In that circumstance, the power will be sold at rates determined by competitive market forces. This circumstance is dependent on the options which are exercised by Edison at the end of the initial 5 year term of the power Supply Agreement, as directed by the Illinois Commerce Commission. This arrangement between Edison, the Subsidiary and the Illinois Commerce Commission is, if anything, pro-competitive.

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e ATTACHMitNT 3 Analysis of No Significant Hazards Consideration The application to amend the operating license to add the Subsidiary as a co-licensee of the Facility involves no significant hazards consideration as demonstrated herein.

The tests for determining whether a proposed amendment involves no significant hazards consideration are set forth in 10 CFR Section 50.92(c).

The proposed amendment involves no change in the Facility, the manner in which the Facility is operated, or in the personnel who operate it.

The proposed change will involve no alterations to the facility itself and no modifications to plant procedures. Therefore, the proposed amendment involves no increase in the probability or consequences of an accident previously evaluated. Nor does it create the possibility of a new or different kind of accident from any accident previously evaluated or involve any reduction in a margin of safety.

3107K

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