ML20214R815

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Forwards Proposed Changes to Final Draft Tech Specs, Including Section 6.0, Administrative Controls
ML20214R815
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 09/22/1986
From: Johnson I
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
2137K, NUDOCS 8609290287
Download: ML20214R815 (14)


Text

_,

\\ Commonwxlth Edison I

i 72 West Adams Street. Chicago. Illinois Address Reply to: Post Office B5 77

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Chicago, Illinois 60690 0767 September 22, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Braidwood Station Units 1 and 2 Final Draft Technical Specification Changes NRC Docket Nos. 50-456 and 50-457 Reference (a): Letter from I. M. Johnson to H. R. Denton dated September 10, 1986.

Dear Mr. Denton:

Enclosed is an attachment which includes information which is to be i

included in the Final Draft of the Braidwood Technical Specifications.

Reference (a) transmitted the most current CECO on-site and off-site organizational charts for Braidwood Station for inclusion in the Braidwood Tech Specs. We are now transmitting the remaining changes to Section 6.0, Administrative Controls, of the Braidwood Tech Specs in Attachment 1 to this letter.

This submittal completes our review and revision to Section 6.0 Tech Specs. Please incorporate these changes in the Final Draft of the Braidwood Technical Specifications.

Please direct any questions you may have regarding this matter to this office.

One signed original and fifteen copies of this letter and its related attachments are being provided for your review.

Very truly yo rs, I. M. Johnsor Nuclear Licensing Administrator 1m : Proposed Changes to Final Draft Technical Specifications for Braidwood Stations Units 1 and 2 cc:

J. Stevens 2137K B609290287 860922 I

PDR ADOCK 05000456

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ATTACISBNT 1 PROPOSED CHANGES TO FINAL DRAFT TECHNICAL SPECIFICATIONS FOR BRAIDWOOD STATION UNITS 1 AND 2 REVISED PAGES 6-1 6-2 6-6 6-7 6-8 6-9 6-10 6-12 6-13 6-14 6-15 6-16 2137K

1 M FT ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY I

'h A

6.1.1 The M W--- d at, Braidwood Station, shall be responsible for overall unit cperation and shall delegate in writing the succession to this responsi-bility during 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 roomgap g

function.

A management directive to this effect, signed by the -.

... Vice i

President and General Managem'Huclear 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; 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

  • 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.

BRAIDWOOD - UNITS 1 & 2 6-1

. p,,. g

bRAFT ADMINISTRATIVE CONTROLS UNIT STAFF (Continued) 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 (0NSG)

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 0NSG 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 a

Nuclear Safety, and the Superintendent, Braidwood Station.

l COMPOSITION 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 l

f 6.2.3.4 Records of activities performed by the 0NSG shall be prepared, main-tained, and forwarded each calendar month to the Manager of Nuclear Safety, and the

-.., Braidwood Station.

f wwy 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.

BRAIDWOOD - UNITS 1 & 2 6-2 QP 16 363

7

~ DRAFT ADMINISTRATIVE CONTROLS i

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 (SR0) shall be made aware of any significant changes in plant status in a tirely manner by the SCRE.

(3) During the shift, the shift engineer and the shift foreman (SRO) shall l

remain abreast of the current plant status.

The shift foreman (SRO) shall l

return to the control room two or three times per shift, where practicable, to confer with the SCRE regarding plant status. 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 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet o exceed the minimum qualifi-cations of ANSI N18.1-1971, except for the Rad / Chem Supervisor or Lead Health Physicist, who shall meet or exceed'the qualifications of Regulatory Guide 1.8, September 1975, for a Radiation Protection Manager.

The licensed Operators and Senior Operators shall also meet or exceed the minimum qualifications of the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees.

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 Appendix A of 10 CFR 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 familiarization with relevant industry operational experience identified by the-GH+ee of Nuclear Safety.

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 the responsibilities and authorities outilned below.

BRAIDWOOD - UNITS 1 & 2 6-6

y

' DRAFT ADMINISTRATIVE CONTROLS l

6.5 REVIEW INVESTIGATION AND AUDIT (Continued) l OFFSITE W

6.5.1 The ig;hn of the Offsite Review and Investigative Function shall be appointed by the Manager of Nuclear Safety responsible for nuclear activities.

The audit function shall be the responsibility of the Manager of Quality Assurance and shall be independent of operations.

a.

Offsite Review and Investigative Function m 4. w a.a+

The Svym.L. of the Offsite Review and Investigative Function i

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 more than one participant who collectively possess background and qualifications in the subject matter under review to provide comprehensive interdisciplinary revien coverage under this function, (4) independently review and approve the findings and recommendations developed by personnel performing the review and investigative function, (5) approve and report in a timely manner all findings of n -cgmpliance with NRC requirements to the MLS vgWtsiat, yZhn Vice President and Cencral Manager #

g),4 % p NuclearStations,ManagerofQualityAssurance, Mand Qe Jice President -

Nuclear Operations.

During periods when the S l*of Offsite l

1 Review and Investigative Function is unavailable, he shall designate this responsibility to an established alternate.who satisfies the formal training and experience for the 9""g*"of the Offsite l

^

Review and Investigative Function. The responsibilities of the per-sonnel performing this function are stated below.

The Offsite Review and Investigative Function shall review:

1)

The safety evaluations for:

(1) changes to procedures, equip-ment, or systems as described in the safety analysis report, and (2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question.

Proposed changes to the Quality Assurance Program description shall be reviewed and approved by the Manager of Quality Assurance; 2)

Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59; 3)

Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50,59; 1

4)

Proposed changes in Technical Specifications or this Operating License; BRAIDWOOD - UNITS 1 & 2 6-7

,y

,UM I$3N4fy l

ADMINISTRATIVE CONTROLS i

l 0FFSITE (Continued) 5)

Noncompliance with Codes, regulations, orders, Technical Speci-fications, license requirements, or of internal procedures, 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 EVENTS; 8)

All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components; 9)

Review and report findings and recommendations regarding all changes to the Generating Stations Emergency Plan prior to implementation of such change; and

10) Review and report findings and recommendations regarding 3

Superintendent, m @y the Technical Staff Supervisor, S Au'fu& jill items refertge b

Vice President and General Manager /

3 Nuclear Stations, and Manager.of Quality Assurance.

(

b.

Audit F~ unction The audit function shall be the responsibility of the Manager of Quality Assurance independent of the Production Department.

Such responsibility is delegated to the Director of Quality Assurance (Operati~ad) and the "---- ' E--

5-Quality' Assurance O M '"'

(Maintenance).

shall approve the audit agenda and checklists, the findings g

k and the report of each audit.

Audits shall be performed in accord-ance with the Company Quality Assurance Program and Procedures.

/g Audits shall be performed to assure that safety-related functions p

j Ig Q

are covered within the period designated below:

,N N#

1)

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license Q ['

- *c conditions at least once per 12 months;

/

2)

The adherence to procedure, training, and qualification of the s

station staff at least once per 12 months; 3)

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or methods of operation that affect nuclear safety at least once per 6 months; 4)

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, J

10 CFR Part 50, at least once per 24 months; BRAIDWOOD - UNITS 1 & 2 6-8 n,r 16 SE,:

4 1

ADMINISTRATIVE CONTROLS l

i 0FFSITE (Continued) l 5)

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

6)

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

7)

Onsite and offsite reviews; 8)

The Facility Fire Protection programmatic. controls including the implementing procedures at least once per 24 months by i

qualified QA personnel; 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 consultant shall be used at least every third year;

10) The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months; 1
11) The 0FFSITE DOSE CALCULATION MANUAL and implementing procedures l

at least once per 24 months;

12) The 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 s #

recommendations and results of each audib}@ Station /Superin-tendent, Manager of Nuclear Safety, the.......c. Vice President and i

General Managergr Nuclear Stations, Manager of Quality Assurance, I

the Vice Chairman, and the Vice President - Nuclear Operations.

i c.

Authority The Manager of Quality Assurance and the Manager of Nuclear Safety report to tha 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 i

avoid unsafe plant conditions.

)

4 l

i BRAIDWOOD - UNITS I & 2 6-9 SEP 16 95 l

7 m

DRAFT "ADMINISTkATIVE CONTROLS l

1 I

0FFSITE (Continued) d.

Records 1)

Reviews, audits, and recommendations shall be documented and distributed as covered in Specification 6.5.la. and 6.5.lb.;

and 2)

Copies of documentat'io'n, reports, and correspondence shall be kept on file at the station.

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~

e.

Procedures l

I Written administrative procedures shall be prepared and maintained l

for the offsite reviews and investigative functions described in Specification 6.5.la. and for the audit functions described in Specification 6.5.lb.

Those procedures shall cover the following:

1)

Content and method of submission of presentations to the

[jggg of the Offsite Review and Investigative Function, 2)

Use of committees and consultants, 3)

Review and approval,

(

4)

Detailed listing of it' ems to be reviewed, 5)

Method of:

(1) appointing personnel, (2) performing reviews, investigations, (3) reporting findings and recommendations of l

reviews and investigations, (4) approving reports, and (5) distributing reports, and 6)

Determining satisfactory completion of action required based on approved findings and recommendations reported by personnel performing the review and investigative function.

f.

Personnel 1)

The persons, including consultants, performghg,rgiew and

]

investigative function, in addition to the --

...~. of the

[

Offsite Review and Investigative Function, shall have expertise in one or more of the following disciplines as appropriate for the subject or subjects being reviewed and investigated:

a)

Nuclear power plant technology, b)

Reactor operations, c)

Utility operations, d)

Power plant design, e)

Reactor engineering, f)

Radiological safety, g)

Reactor safety analysis,

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BRAIDWOOD - UNITS 1 & 2 6-10 SEP 18 :E

E

~ '~

7

6. u u u m u.,..

$WT ADMINISTRATIVE CONTROLS OFFSITE (Continued) h)

Instrumentation and Control Engineering graduate or equivalent with at least 5 years of experience in instrumentation and control design and/or l

operation.

l i)

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

3)

The Yir of the Offsite Review and Investigative Function shall have experience and training which satisfy ANSI N18.1-1971 M

I requirements for plant managers.

ONSITE 6.5.2 The Ongte Review and Investigative Function shall'be supervised b the Station 9f??.C u., A N- %"'YEd '"!4 * %y d

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g nr.*mm-m.

+ W p s: uit. i.gu Q, 3

p OnsiteReviewandInvest)iativeFunction l

a.

u. 4t The Stat erinte'nden shall:

(1) provide directions for the q

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-l pants for 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 noncomg provide recommendations to the L,lJype with NRC requirements, ' nd a

Manager - Nuclear Stations and the 4.. M resident and General

. m.J. d 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 i

determined by the Station, Superintendent to affect nuclear 3

D.m daap.etJD safety; q

2)

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

&EP 16 tre:

a

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,,, Z, -

~DRiifT ADMINISTRATIVE CONTROLS 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 rec'trrence to the

    • '"d 94,4e4en Vice President and General Manager e Nuclear Stations
  • and to the !_,_.

, of the Offsite Review and Investigative Function; Se"*

6)

Review of all REPORTABLE EVENTS; 7)

Performance of.special reviews and investigations and reports and Investigative Function; *-.. "_.. of the Offsite Review l

thereon as requested by the -

8)

ReviewoftheStationSecurityPlanandimplepe,n,tp.gprocedures and submittal of recommended changes to the Gibasasen Vice a

President and General Managerft Nuclear Stations; 9)

Review of the Emergency Plan and station impiegen, Ling procedures and submittal of recommended changes to the h Vice President and General ManagerpNuclear 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

/#1 :' M'n Vice President and General Manager # Nuclear Stations and the C".N"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 dup 3 gitdSuperintendent and shall make recommendations in a timely manner in all areas of review, investigaticn, 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 d

hen in his opinion such action is necessary. The Station #' ear n q,rn:/ proce ures wSuperintendent shall follow such recommendations or BRAIDWOOD - UNITS 1 & 2 6-13 SLt U.jc

f DRAFI

' ADMINISTRATIVE CONTROLS ONSITE (Continued) of action that is more conservative regarding safe operation of the facilit g,'id Vice President and General Manager f Nuclear Stations All such disagreements shall be reported immediately to the M ;;i and the S-r...Mof the Offsite Review and Investigative Function.

w.,%

d.

Records

,s be documented with copies to the

...sg commendations shall 1)

Reports, reviews, investigations,g AgPgident and V

General Manager / Nuclear Stations, the Stpennor of the Offsite Review and Investigative Function, the Station Superintendent, and the Manager of Quality Assurance.

,q,rd 2)

Copies of all records and documentation shall be kept on file I

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:

1).eContent and method of subgi,piop and presentation to the M

tation,Su Manager./(perintendent, h;;;n.. Vice President and General gg Nuclear Stations, and the km.:,a of the Offsite Review and Investigative Function, 5 -'* W 2)

Use of committees, 3)

Review and approval, I

4)

Detailed listing of items to be reviewed, 5)

Procedures for administration of the quality control activities, and l

6)

Assignment of responsibilities.

f.

Personnel

. NyiIf 4

1)

The personnel performing the Onsite Review and Investigative Function, in addition to the Station Superintendent, shall consist of persons havir.g expertise in:

a)

Nuclear power plant technology, b)

Reactor operations, c)

Reactor engineering, d)

Chemistry e)

Radioingical controls, f)

Instrumentation and control, and g)

Mechanical and electrical systems.

BRAIDWOOD - UNITS 1 & 2 6-14 g 16

BRAFT ADMINISTRATIVE CONTROLS ONSITE (Continued) 2)

Personnel performing the Onsite Review and Investigative Function shall meet minimum acceptable levels as described i

in ANSI N18.1-1971, Sections 4.2 and 4.4.

6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shalf De 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 i

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 Functior. and the

  1. "#*"-0$w$ sten Vice President and General Managerd Nuclear Stations.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

The NRC Operations Cente) shall be notified by tggne as soon as a.

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 D...

.... Vice President

- and. General Manager e Muclear 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;

'The Safety Limit Violation Report shall be submitted to thegmmission, c.

the Offsite Review and Investigative Function and the DN a= Vice President and General Manager # Nuclear Stations eth' '" L,7

f j'

-tw _ ; utiL

.: ~ w, wal w so.x 4 to c.rg y g, d.

Critical operation of the Unit shall not be resumed until aut'horized by the Commission.

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

The applicable procedures recommended in Appendix A, of Regulatory a.

Guide 1.33, Revision 2, February 1978, BRAIDWOOD - UNITS 1 & 2 6-15 gg

.......... = = -

  • ' ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) b.

The emergency operating procedures required to implement the require-ments of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Sec-tion 7.1 of Generic Letter No. 82-33;

.c.

Plant Security Plan implementation, d.

Radiol gical Emergency Response Plan implementation, N e.

PROCESS CONTROL PROGRAM implementation, OFFSITE DOSE CALCULATION MANUAL implementation, and g.

Quality Assurance Program implementation for effluent and environ-mental monitoring 3 M b-6 A % Wh~.

6.8.2 Each procedure of Specification 6.8.1 above, and changes thereto, shall be reviewed prior to implementation as set forth in Speci.fication 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; 1

b.

The change is approved by two members of the plant management staff, I

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 StatioS uperintendent within S

14 days of implementation.

y g

M 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 and Volume Control System, and RHR System.

The program shall include the following:

1)

Preventive maintenance and periodic visual inspection requirements, and 2)

Integratad leak test requirements for each system at refueling cycle intervals or less.

BRAIDWOOD - UNITS 1 & 2 6-16 3sP 15 ESS