ML20235J067

From kanterella
Jump to navigation Jump to search
Proposed Tech Specs,Changing Administrative Controls Section 6.0 to Include Removal of Organizational Figures,Position Change from Radiation Chemistry Technician to Radiation Protection Technician,Per Generic Ltr 88-06
ML20235J067
Person / Time
Site: Byron, Braidwood, 05000000
Issue date: 02/17/1989
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20235J060 List:
References
GL-88-06, GL-88-6, NUDOCS 8902240151
Download: ML20235J067 (44)
v • d • e


Text

{{#Wiki_filter:-.. . ' l' I Y. t'. 4 . 4' t ATTACBIENT A PROPOSED CHANGES TO APPENDIX At

IECHNICAL SPECIFICATIONS, OF FACILITY OfEFATING LICENSES NPF-37, NPF-66, NPF-72 and NPF 1 BXRON BEAIDWOOD Revised Pages XX XX 6 6-1 6-2 6-2 6-3.

6-3 6-4 6-4 6-6 6-6 6 -7 6-7 6-8 6-8 6-9 6-9 6-12 6-12 6-13 6-13 6-14 6-14 6-15 6-15 6-24 6-24 6-25 6-25 /sc1:5428Kt3 8902240151 890217 DR ADOCK 05000454 p PDC g

4 cA ADMINISTRATIVE CONTROLS o f. ( SECTION PAGE- '6.1~ RESPONSIBILITY................................................ 6-1 6.2 ORGANIZATION.................................................. 6-1 FIGURE 6.2-1 SEES!-TE ORGAdaiMM..DF.WT.9...................... 6-3 FIGURE 6.2-2

m. T*-*4Mimmw... p.t. W....E. D........................

6-4 TABLE 6.2-1 MINIMUM. SHIFT CREW COMPOSITION........................ 6-5 6.3 UNIT STAFF QUALIFICATIONS..................................... 6-6 6.4= TRAINING....................................................... 6-6 6.5 REVI EW INVESTIG ATION AND AUDIT................................ 6-6 6.5.1 0FFSITE...................................................... 6-7 Offsite Review and Investigative Function................... 6-7 -Audit Function.............................................. 6-8 Author'ty................................................... 6-9 Records.................................................... 6-10 Procedures.................................................. 6-10 Personnel................................................... 6-10 6.5.2 0NSITE...................................................... 6-12 Onsite. Review and Investigative Function.................... 6-12 Responsibility.............................................. 6-12 i Authority................................................. 6-13 l Records........ 6-14 Procedures.................................................. 6-14 { i Personne1................................................... 6-14 1 I 6.6 REPORTABLE EVENT ACTI0N........................... 6-15 l BYRON - UNITS 1 & 2 XX 1 l

A 4 , ADMINISTRATIVE CONTROLS 6.1-RESPONSIBILITY 6.1.1 The Station Manager, Byron Station, shall be responsible for overall unit operation and shall delegate in writing the succession to this respon-sibility 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 room command function. A management directive to this effect, signed by the/A::!:i n N tresided m? nanar*h M* nag

  • M uctuar Std ie3 shall be reissued to all station personnel on an annual basis.

, Opera He 6.2 ORGANIZATION ice President PWR ^ INsERTI v 0 6.2.1 The offsite organization unit management and technical be as shown in Figure 6.2-1. UNIT STAFF 2 4 e 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 c:ew 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; Protechen c. A Radiation D--!stry 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; F Protecticn p Tie Radiation chemistry Technician may be less than the minimum requirements l fo r a period of time not to exceed 2 hours in order to accommodate unexpected obsence provided immediate action is taken to fill the required positions. AMEN 0MENTNO.17 l Byeov -vuif.S 1 & 2 6-1 l

-INSERT l' l 3 t. l 6.2.1 QUEITE AND OFFSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant, a. Lines of authority, responsibility,.and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of. departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Quality Assurance Manual or the Management Plan for Nuclear Operations, Section 3 Organizational Authority, Activities; Section 6 Interdepartmental Relationships. b. The Station Manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. c. The Senior Vice President-Nuclear Operations shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite managers however, they shall have sufficient organizational freedom to ensure their independence from operating pressures. 6.2.2 IJNIT STAFF The unit staff shall be subject to the followings INSERT 2 f. The Assistant Superintendent Operating shall hold a Senior Reactor Operator License. /sc1:5428K 10

ADMINISTRATIVE CONTROLS f) ' , o UNIT STAFF (Continued) e. 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 i NRC Policy Statement on working hours (Generic Letter No. 82-123 6.2.3 ONSITE NUCLEAR SAFETY GROUP (0NSG) FUNCTION-1 6.2.3.1 The ONSG serves as an independent safety engineering group and shall j' function to examine plant operating characteristics, NRC issuances, industry ll advisories, REPORTABLE EVENTS and other sources of plant design and operating experience information, including plants of similar design, which may indicate j' 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 " r rer of i cicar 5 fety, and the Station Manager, Byron Station. &frey Asses.sms5 Maugtr-COMPOSITION f 6.2.3.2 The 0NSG shall be composed of at least three, dedicated, full-time N engineers located on site. f i-RESPONSIBILITIES l' 6.2.3.3 The 0NSG 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. it RECORDS 6.2.3.4 Records of activities perforrred by the ONSG shall be prepared, main-tained, and forwarded each calendar month to the "ar.c er af-huclear R fety, & N // W h e d 8 d M y r; and the Station Manager, Byron Station. J 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 Shif t Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit. i ;! 4

  • Not responsible for sign-off function.

BYRON - UNITS 1 & 2 6-2 AMEN 0 MENT NO.

  • W

..k

c-7 m_ 'NT _in- = sr e s 1,- !!!-:il its i. c. i g, f,.I so s- -[Lg i: , _[n r = 18 i !si i -L

.g.

s s ..g -!j;l-l stilli E- _i. :1 .ii lii! islji! '1 d,!n siili IIIg a_:. i 4 I1 is

si g
.

i ..lij

i
I'

_fe,3: r 'l =s=Iligll I s If8 1:ti /-- l! 4 / i / 1.;1 g! I! t __._______ / i;; lii Q. .ilil i \\ r -., i!. i .i li in1 es a!jl il-g.

  • t y II.

ji lien ii; 11 i I i j;t__, i1l,l a i i a l i I t. 1 i c l!i j' /. I ur i o y-i 3 l 1. Il !I i i i 1 t _ , I,' t -B / \\ -111!!.il' /n"_11 = r !nig ; 'is il ll _a i .i i! / i i !4 l. !i "j,I g !y!! lM I. I. 5. I Il I si l r-T Ii a=- .qi -srs n = i,. v i. =i ,i. !i' z,i ';, Jil Id irl til ij I 11 g's \\ l ) g,g! n L i' 5 g,! i!!! .lli 3

7. I_ .I li

'sl: g i! ilI a til 1., 5

,l lIl

.!i - i 1-S !!i lll ll g {_ l / I ,i I I T l .i. n !. 'I ,j _L .L \\ li i i a[ '1 d, ' if I l l gli si ll [ Astendiment No. na - m 1 s d'L 18e 8'

F, .w .g l-C' 3 g,i. ,j i 4 g .j-s_ g i .1 i.- x,-l 8-st <3 \\ a-;1 l5;3j. i I .si I: 8 e-rI !=- In: 6-1g. .231;is 1 ll_._ .i .p i.x = i sin s ul I 1152 1 lii gi i 11!1 l I, p i . s. :: - 1 l 8.1 X iii I gi 5 Igs1 11 g ss- .i s s! \\ aI II / nd s! n iiIg pist E! .I g:g ![ gi 3 g cs .'11 a i ir

  • I
  • i i

11 i / T-T- W- / \\ p- .__ gl;p -y,--- -- t_ 'I'll l 5i o 9 g ] 5fg !!- I

I

\\ _l. 11 la. 1l il is:5 gi 'g m vI g 3 i,,,,,

d O

7 E}el _f i t ? s 7 59' 3: 4l I ll 8 El g] s m !J ji ll [? 6 lA ~ 1 a .i

q@

3 o a ,a { .E 0 11 l, ei L - sis i e c i n g i

g

_f re I ]; l } ]~ i

g1 l

-l 2 i g.] i i i Eg i gg j "I ![ ja g je ei 1 i r ,y L-J "~ Amendment No. ) BYRON - HITS 1 & 2 64 l

A

  • TABLE 6.2-1 f',

MINIMUM SHIFT CREW COMPOSITION Q POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION BOTH UNITS IN BOTH UNITS IN ONE UNIT IN MODE 1, 2, 3 OR 4 MODE 1, 2, 3, MODE 5 OR 6 AND OR 4 OR DEFUELED ONE UNIT IN MODE 5 OR 6 OR DEFUELED SE 1 1 1 SF 1 None## 1 RO 3 2 3 A0 3 3 -3 STA or SCRE 1 -None 1 Shift Supervisor (Shift Engineer) with a Senior Operator SE license Shift Foreman with a Senior Operator license SF Individual with an Operator license RO Auxiliary Operator A0 Shift Technical Advisor STA ,f.3 S,CRE - Station Control Room Engineer with a Senior Operator License U The Shift Crew Composition may be one less than the minimum requirement's of Table 6.2-1 for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements of Table 6.2-1..This provision does not permit any shift crew position to be unmanned upon shif t change due to an oncoming shif t crewman being late or absent. During any absence of the Shift Supervisor from the control room while the Unit is in MODE 1, 2, 3 or 4, an individual with a valid Senior Operator license shall be desi.gnated to assume the control room command function. During any absence of the Shift Supervisor from the control room while the Unit is in MODE 5 or 6, an individual with a valid Operator license shall be designated to assume the control room command function.

  1. At least one of the required individuals must be assigned to the designated position for each unit.

l

    1. At least one licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling must be present during Core Alterations on either unit, who has no other concurrent responsibilities.
  • Table 6.2-1 will replace Table 6.2-la when Unit 2 receives an operating license.

C) BYRON - UNITS 1 & 2 6-5 u;

4 s ( D

  • ADMINISTRATIVE CONTROLS w/

6.2.4 SHIFT TECHNICAL ADVISOR (Continued) To assure capability for performance of all STA functions: (1) The shif t foreman (SRO) shall participate in the SCRE shift relief turnover. 1 (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 manner e by the SCRE. (3) During the shift, the shift engineer and the shift foreman (SRO) shall remain abreast of the current plant status. The shif t foreman (SRO) shall return to the control room two or three times per shift, where practicable, r 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. N 6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum quaU fi-cations of ANSI N18.1-1971, except for the L#0hr Sper"her 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 ,1 supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees. I. 6.4 TRAINING 1: A retraining and replacement training program for the unit staff shall j. 6.4.1 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 p i operational experience 4deni4ied-by-the-Departme44f-Nudet-G,1(ety, Assessmcf. 1 from the r escarn mar.aaed og cowl % iivyrums ans e 6.5 REVIEW INVESTIGATION AND AUDIT The Review and Investigative function and the Audit function of activities j affecting quality during facility operations shall be constituted and have the responsibilities and authorities outlined below. . -i BYRON - UNITS 1 & 2 6-6 Amendment No. ~ m: >u 1,1

4 ADMINISTRATIVE CONTROLS s D V' ~6.5 REVIEW INVESTIGATION AND AUDIT (Continued) r f c(la,0y AsurantelHw'l'argj OFFSITE 7' 8 i[p/p'p ~6.5.1.The Supe intendent of the Offsite Revie and Investigative Function i shall be appoint d by the fianager of Nucica. safct, responsible for nuclear activities. The audit function shall be the responsibility of the Manager of (SA/A)3 f<uelity Assurcrx and shall be independent of operations.

  • [Nsrcr 3 w-a.

Offsite Review and Investigative Function l l 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 more than one participant who collectively possess background and qualifications in the subject matter 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 %tc &csdc6 and investigative function, (5) approve and report in a timely PulA de " # 9 nanner all findings of non compliance with NRC requirements to the ]SenM[ I Moocf r of Gtation Manager,jM:i; tant Vice President and Generel Le, s d?A/A S,, / Nuclear Statierz, 'enager cf Quality 5:ur n:c, and theWice President - [ y As3dto.nb Vecc, Nuclear Operations. During periods when the Superintendent of Offsite p 'g gg Review and Investigative Function is unavailable, he shall designate this responsibility to an established alternate, who satisfies the O*N,y 075 formal training and experience for the Superintendent of the Offsite and Asnsest, 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 repert, 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 ggMsurance, 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; 4) Proposed changes in Technical Specifications or this Operating License; O BYRON - UNITS 1 & 2 6-7 AMENDMENT NO. a

L INSERT 3 .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 conmittee directed by the Manager of QA/NS. The Manager.of QA/NS has the responsibility for.the performance of periodic audits of each nuclear station and corporate department to determine that QA/NS policy is being carried out. I-l /sc1:5428K:12

l 4-A g.' ADMINISTRATIVE CONTROLS-l Q. ' 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

  • W0) Review and report findings and recommendations regarding Me.e P'ts d aT \\

all items referred by the Technical Staff Supervisor, Station NR O/erdm2 [ Manager,%wkt:nt Vic "recident and Cencr:1 "anca r g 9uclear Stations, and M:n ;;;r of Quality ^.::urance AVP d?ualh ) Programs anJ Aussmen/t.i

b. 3 Audit Function i

sta k pg Theaudit function shall be the responsibility of the ",:n:ger of g ) Quality.^;;urance independent of the Production Such I 6,$ y...,~,... f g/cv 1 responsibility is delegated to the Circeter of Quality Assurance L J. "@ PCT 2tiOnO 00MC CiTCCtGT GI Quality A330F65Ce Edinten6nCO-Gus/@ j Proya *5

Either of 1.he h, or designated corporate staff or supervision

[ Nan e.Jer', approved by thefan ;;cr of Quality,^::urance shall approve the audit / agenda and checklists, the findings and the report of each audit. Audits shall be performed in accordance with the Company Quality Assurance Program and Procedures. Audits shall be performed to W P O o/dj/ assure that safety-related functions are covered within the period anc designated below: &cyrams /).ssess ment 1) The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months; 2) The adherence to procedure, training, and qualification of the station staff at least once per 12 months; 3)- The results of actions taken to correct deficiencies cccurring in facility equipment, structures, systems, or methods of operation tnat 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, 10 CFR Part 50, at least once per 24 months; O BYRON - UNITS 1 & 2 6-8 AMENDMENT NO. y

4 .,q U ADMINISTRATIVE CONTROLS -OFFSITE (Continued) 5) The Facility Emergency Plan and implementing procedures at least on'ce 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 including the implementing procedures at least onca per 24 months by' qualified QA personnel; 9). The fire protection equipment and program implementation at l 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; 7

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

ggg Report all findings of noncompliance with NRC requirements and ' g/g J recommend _ations and results of each audit to the Station Manager, Manager of t :10 r 50fety, the A;;i; tent "!:: "r :ident end " --C:ncr:1 Managen - Nuclear 4tatlent, Manager c' Qual"y nee" rwa. / gg the " ice Chaiman, and thqVice President - Nuclear Operations and 44c j f gry//eg Pige Chef Q rd y of'feeA, Mr fed 4,essg Authority c. ~ <4M/AIS repor65 fo ehe chdf E'weufwIa=Of Euc y The Manager of @teFity-Anurance-and-the-Ma e Mariager of % lity-W ld6 %nnr+ +n +ha r'hai.cmamand Dr+rA4efvt. Meer M:ur:nce er the--# negar of Nuclear Safety has the authority to order unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions. The AVP G?du Royams and rftsessmerd repods k f4e [enik- ()]ce k Presdhaat - Nachoe cmfks. 71e MP caualNy Roya~s and Assesvw t r Qi hus he au&rHy 'to tvesmmeo.cl <>M s}uddow oc reper a,,y di,er-r'o an s unsafe pland <% d Csa.r. ask uth aL lc decns necc sary&c reyw1cd s<meOtal 6 tLe /fanagl e ik sach disag reemeds sh< O y d cedus and +he ew %~ ofw. BYRON - UNITS 1 & 2 -9 AmendmentNof __-_____ _ _A

4 i ' ADMINISTRATIVE CONTROLS l ,q, 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 Superintendent 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 Manager. a. Onsite Review and Investigative Function The Station Manager shall: (1) provide directions for the Review and Investigative Function and appoint the Technical Staff Supervisor, or -s 1 other comparably qualified individual as the senior participant to provide appropriate directions; (2) approve participants for this function; (3) assure that at least two participants who collectively possess background and > qualifications in the subject matter under review are selected.to provide comprehensive interdisciplinary review coverage under this function; (4) independently review and approve the findings and recommendations developed by personnel performing the Review and Investigative Function; (5) report all findings of i noncompliance with NRC requirements, and prpvid? recommendations 4e-the A::i t nt Vice Prc:ident :nd C ncr:1 " n ger - h elegr Statione and the perintendent of th O f-f+&t: Review and Investigative Func - [ -t.iea; and (6) submit to the Offsite Review and Investigative Function for concurrence in a timely manner, those items described in Speci-fication 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 Manager to affect nuclear safety; 2) Review of all proposed tests and experiments that affsct nuclear safety; AmendmentNo.[ BYRON - UNITS 1 & 2 6-12 . o-JO

a 4 4 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 recurrence 3 e the-t staat=Vice-Presfdent end-@neral= Manager v4tuelear: Stations WW dWk t he4 aper 4ntende ntmf=the:OffstW RevieWJand = Invest 4YD Pco& %a husmes tive-Enm+4rq $%n W Review of all REPORTABLE EVENTS; i etccordance M 7) Performance of special reviews and investigations and reports JSpeclficqHen thereon as requested by the Superintendent of the Offsite Review Q,. 5. 2. d l and Investigative Function; ~ 8) Review of the Station Security Plan and implementing procedures and submittal of recommended changes to the Station Security 'p PlantotheDirectorofCorporateSecuritg; 9) identificaHen Review of the Emergency Plan and station implementing procedures and d.v in ai of recommended changes,ta=the= Assistant:Vice: tessidentamf:Generst ManagerE-sarr$tationsT.

10) Review of Unit operations to detect potential hazards to nuclear safety; and br war dM3
11) Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation o reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrenceyand=hs11'orwarding=of=he-+epus = thF Ass 3 stant3tce:Presidsnt=anddieneral:+tanagMiudsar=6tations.

-and:1t:eduperintendent of=ths-Offsitadavtawrand:Investdgatisv-tunttinnrand

12) Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE

{ DOSE CALCULATION MANUAL, and the Radwaste Treatment Systems; cmd

13) Review of the Fire Protection Program and implementing instruc-idenHFicnhee tions and shmittri of recommended changes ta=tiw:0fhita-Rwisw l

~ anddnvestigatizedunction. l c. Authority 1 The Technical Staff Supervisor is responsible to the Station I Manager and shall make recommer.dations in a t'imely manner in all areas of review, investigation, and quality control phases of plant maintenance, operation, and administratha procedures relating to facility operations and shall have the authu ity to request the action necessary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Manager shall follow such recommendations or select a course J l BYRON - UNITS 1 & 2 6-13 AMENDMENT N0. I \\ A

I ,-ADMINISTRATIVE CONTROLS _() ' ONSITE (Continued) of action that is more conservative regarding safe operation of the facility. All such disagreements shall be reported immediately to t t :i t:nt Vie: Prc:ident--:nd Gener:1 M: nager - Nucle:r Station andtheSuperintendentoftheOffsiteReviewandInvestigativeFunction.f d. Records 1) Reports, reviews, investigations, and recommendations shall be documented with copies to the k ristant vice ore:fdent :nd Qc pc,3,3C {_L- -C:n:r;l ":n g:r - Nucle:r St:ti;n;, the Superintendent of the .4-e Offsite Review and Investigative Function, the Station Manager, d N f. O pera b i m Assessntent,; unless *Uwnobc sP*cg' ect.r G7ue/R'4/Pr75mS *1 and the M:n: r :f Qu lity ^--"-- 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: A 1) Content and method of submission and presentation to*i.he Station p Manager,Attictant "*: President and Cener:1 Manager - Mecle:r Q Statient, and the Superintendent of the Offsite Review and J Investigative Function, 2) Use of committees, 3) Review and approval, 4) Detailed listing of items to be reviewed, 5) Procedures for administration of the quality control activities, and 6) Assignment of responsibilities. f. Personnel 1) The personnel performing the Onsite Review and Investigative Function, in addition to the Station Manager, shall consist of persons having expertise in: a) Nuclear power plant technology, b) Reactor operations, c) Reactor engineeririg, I d) Chemistry e) Radiological controls, f) Instrumentation and control, and g) Mechanical and electrical systems. AMENDMENT NO.) k BYRON - UNITS 1 & 2 6-14 O

3 <vice. Pre _sicient PWR 3 -{ o'pem% ] ' ADMINISTRATIVE 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_:f 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'rev_iewed'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 fusish t b.R+--; dent M " r.efai Mne;er -:-Muctsar-5Wans. [ 6.7 SAFETY LIMIT VIOLATION' .6.7.1 The following actions shall tt taken in the event a Safety Limit is violated: a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour. The 4+ht=- 1 "tw*=sident p " =-;--- 'r 'eer ytetie = and.the Offsite Review and 2n? c:=:m' + Investigative Function shall be notified within 24 hours; 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 the Commission, JCL c. the Offsite Review and Investigative Function and the Aeeiste::t Vic-Lei &L end:SenerJd= Manager-- Meclear= Stations, within 14 days of the violation; and d. Critical operation of the Unit f hall not be resumed until authorized j by the Commission. I s 6.8 PROCEDURES AND PROGPAM_S. H 6.8.1 Written procedures shall be established, implemented, and maintained [ covering the activities referenced below; The applicable procedures recommended in Appendix A, of Regulato'ry a. Guide 1.33, Revision 2, February 1978, I i BYRON - UNITS 1 & 2 6-15 Amendment No. p

ADMINISTRATIVE CONTR01.S HIGH RADIATION AREA (Continued) source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures 1.;;., :9MachutEian) or personnel continuously escorted by such individuals may be exempt from the RWP. issuance requirement during the perfomance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures'for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following: A radiat1 n monitoring device which continuously indicates the a. 9 radiation dose rate in the area; or ~~ ~ ~" 4 b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them; or An individual-qualified in radiation protection procedures'with a c. radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at-the frequency specified in the Radiation Work Permit. 6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Foreman on duty and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under ari approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, i direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation prote: tion procedures to provide positive exposure control over the activities being performed within the area. During emergency situations which involve personnel injury or actions taken to prevent major equipment damage, continuous surveillance and radiation monitoring V of the work area by a qualified individual may be substituted for..the-routine - RWP procadure. For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within-targe areas, such as PWR containment, where no enclosure exists for purposes of locking, and wnere no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded (by a more substantial obstacle than rope), conspicuously posted, and a flashing light shall be activatad-as a warning device. BYRON - UNITS 1 & 2 6-24 Anendment :lo.[ i t _ _ -- - J

4 +:

3 l

l D:k.' I ' ADMINISTRATIVE" CONTROLS A t l 6.13 PROCESS CONTROL PROGRAM (PCP) I 6.13.1 The PCP shall be' approved by'the Commission prior to' implementation. 6.13.2 ' Licensee-initiated changes to the PCP: a. Shall be submitted to the Commission in the Semiannual Radfeactive Effluent Release Report for the period in which the' change (s) was: -made. This submittal'shall contain: ll) Sufficiently detailed information to totally support the rationale for the change wt out benefit of additional or-supplemental information; 6 2): A determination that the change did not' reduce the~overall conformance of.the-solidified waste product to. existing-criteria for solid wastes; and 3) Documentation of the fact that the change has been reviewed and found acceptable by the Onsite ' Review and Investigative Function.- b. Shall become effective upon review and' acceptance by-the Onsite Review and Investigative Function in accordance with Specification 6.5.2. -6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to-implementation. 6.14.2 Licensee-initiated changes to the ODCM: a. Shall<be submitted.to the Commission.by inclusion.in the Monthly Operating Report pursuant to Specification 6.9.1.8 within 90 days of the date the change (s) was made effective. This submittal shall contain: 1)- Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information. Information submitted should consist of a package of those pages of the ODCM to be changed with each page numbered, dated and containing the revision number, together with appropriate analyses or evaluations justifying the change (s); 2) A determination that the change will not reduce the accuracy cr reliability of dose calculations or Setpoint determinations; and 3) Documentation of the fact that the change has been reviewed and found acceptable by the Onsite Review and Investigative Function, b. Shall become effective upon review and acceptance by the Onsite Review and Investigative Function in accordance with Specification 6.5 :. BYRON - UNITS 1 & 2 6-25

g.. n- )ADMINISTRATIVECONTROLS f= SECTION PAGE 6.1 RESPONSIBILITY................................................ 6-1 6.2 ORGANIZATION.................................................. 6-1 FIGURE 6.'2-1 'OPF8878:0RGAN334%30m.. #@.6.T@.................... 6-3 FIGURE 6. 2-2. ONt*:0RGAN334*30m....D ff4TfA......................, 6-4 TABLE 6.2-1 MINIMUM SHIFT. CREW COMPOSITION........................ 6-5 TABLE 6.2-la MINIMUM SHIFT CREW COMPOSITION....................... 6-Sa 6.3 UNIT STAFF QUALIFICATIONS..................................... 6-6 6.4 ' TRAINING...................................................... 6-6 6.5 REVIEW INVESTIGATION-AND AUDIT................................. 6-6 6.5.1 0FFSITE..................................................... 6-7 Offsite Review and Investigative Function................... 6-7 i Audit Function.............................................. 6-8 Authority................................................... 6-9 R e c o r d s... -................................................ '.. 6-10 Procedures.................................................. 6-10 Personnel................................................... 6-10 6.5.2 0NSITE...................................................... 6-12 Onsite Review and Investigative Functions................... 6-12 Responsibility.............................................. 6-12 i Authority................................................... 6-13 l Records..................................................... 6-14 Procedures.................................................. 6-14 'Persor.nel..........................,........................ 6-14

6. 6 REPORTABLE EVENT ACTI0N.......................................

6-15 B.1AIDWOOD - UNITS 1 & 2 XX i _______________O

ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Station Manager, Braidwood Station, shall be responsible for overall unit operation 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 room command function. A management directive to this effect, signed by the"^.;;i:t:nt "!: - Prc:ident and Cenical "uneg;r M l;;r Stati: = shall be reissued to all station personnel on an annual basis. gg g 6.2 ORGANIZATION 0 6.2.1 The offsite orga n for unit managem echnical support shall be as shown in Figure 6.2-1. UNIT STAFF G e unit organization shall be as shown in Figure 6.2-2 and: V Each on duty shift shall be composed of at least the minimum shift a. 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; Protectwn A Radiation O mu etry Technician,* qualified in radiation protection c. procedures, shall be on site when fuel is in the reactor; All CORE ALTERATIONS shall be observed and directly supervised by d. either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation; O-Protecton

  • The Radiation E+remstry Technician may be less than the minimum requirements for a period of time not to exceed 2 hours in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

BRAIDWOOD - UNITS 1 & 2 6-1

cL.' - ~ 4 INSERT l' '?I,, 6.2.1 ONSITE AND'OFFSITE ORGANIZATIONS Onsite and offsite organizations shall be established for ' nit l operation.and u corporate management, respectively. -The onsite and offsite organizations-shal? include the positions for activities.affecting'the safety.of the nuclear power plant. a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels. through intermediate levels to and including all' operating organization positions, These, relationships shall'be documented and updated,'as appropriate, in the form of organization charts, functional descriptions of departmental. responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms-of documentation. These requirements shall be documented in the Quality Assurance Manual or the Management Plan for Nuclear Operations, Section 3 Organizational Authority, Activities; Section 6 Interdepartmental Relationships, b. The Station Manager shall be responsible for overall ur.it safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. c. The Senior Vice President-Nuclear Operations shall have corporate responsibility for overall plent nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating,' maintaining, and providing technical support to the plant to ensure nuclear safety. d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures. 6.2.2 UNIT ST4ff The unit staff shall be subject to the following: INSERT 2 f. The Assistant Superintendent Operating shall hold a Senior Reactor Operator License. /sc1:5428K:10

l: 3 ,r$ ' O ADMINISTRATIVE CONTROLS UNIT STAFF (Continued) e. 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 raster 2 ~RC Policy Statement on working hours (Generic Letter No. 82-12)) N 6.2.3 ONSITE NUCLEAR SAFETY GROUP (ONSG) FUNCTION 6.2.3.1 The 0NSG 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 Sn:;; r Of.Sak Asxssment. 5:1: r 5 f:t3, and the Station Manager, Braidwood Station. Manger-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 0NSG 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 inc cr of Sclear 'Ianyc,e, ftty and the Station Manager, Braidwood Station. Safet.v Assessment I 6.2.4 SHIFT TECHNICAL ADVISOR The Station Control Room Engineer (SCRE) may serve as the Shif t 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 O Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit. l l l

  • Not responsible for sign-off function.

BRAIDWOOD - UNITS 1 A 7 6-2 3

n.. t !!!~!El-II' ~;llc til! j r! 1 a itilli -ijjdj - 1 It!l 131Illjfluhl{I q b,_ li {tg!!tijj--~ !q I' jj -'Ils '~4 i f p ~~ if 4,. I pt ?.,=-- g=1---lij-!!!. / .!!'l T 3 4 1 i i.-I II 4 + "T' / 1;4- . I~~l a t s );ll-W [p] ,i.I S_b gjlf f.,_ 1 fi 1 i. b ~~' i{i[)j r ~= l a E l"i It ri W l, j!i 5 \\i. 8 1 i .1 i #At* The$aubtfunctionshallbetheresponsibilityoftheihncgcrofdPwe* Pad 0 Prge4 is W Quality A;;urcnce independent of the ? reduction u was wmus. Such up oudg (Opcrc. tion;) and tb-responsibility is delegated to the Oircctcr of Quality A;;uren jp m,,,,g =ggQ t {:: -Eithcr cfIe.abeve, or designated %)rporate Staf f or Supervisi [ approved by the,"uougo, vf Quality A;;urcncc: shall approve the audit agenda and checklists, the findings and the report of each audit. Audits shall be performed in accordance with the Company Quality Assurance Program and Procedures. Audits shall be performed to assure that safety-related functions are covered within the period designated below: i 1) The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months; 2) The adherence to procedure, training, and qualification of the 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, 10 CFR Part 50, at least once per 24 months; 9 BRAIDWOOD - UNITS 1 & 2 6-8 AMENDMENT NO.

1; > H m EG , ADMINISTRATIVE' CONTROLS OFFSITE (Continued)- '~ 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; The Facility Fire Protection programmatic controls-including 8) the implementing procedures at least once per 24 months by qualified QA personnel; The fire protection equipment and program implementation at 9) 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;
11) The 0FFSITE DOSE CALCULATION MANUAL and implementing procedures O-at least once per 24 months; The PROCESS CONTROL PROGRAM and implementing procedures for-12) solidification of radioactive wastes at least once per 24 months; and The performance of activities required by the Company Quality 13)

Assurance Program for effluent and environmental monitoring at least once per 12 months. 68e. d Report all findings of noncompliance with NRC requirements and Frode recommendations and results of each audit to the Station Manager, b8 0PM g [J the As;istant Vice President cad 4 Manager of _ -.~, %,, -Cinical. anagcr Of Sclear Statione, ":n:ger Of Quality Assurance,d (he 2nd thef ce President - Nuclear Operations,oaCh Vi //r quoky th " ice Chri-2^, & der- % rams and c. Authority elas //g%f. b -- repe + +ger of 41ity Assuranc; end the "anag-ef Nucle v The Mana the Chei mer 2nd oresit nt. frweendsY.o*he a rnager of Nuclear Safety has the authority to order u t eurance er the %if h4 *e unit shutdown or request any other action which he deems necessary to .I orr;ehr, / avoid unsafe plant conditions. T};e dt/f Qualky Pre 3 cam.s and Asserwmt repds 6 & Sen<* be. lear cpero%s, The MP Qual &y Royams om/ Asesmob b5 Ne du +a reummond udt sku%n er tepst any ather-och*n wMA. he. deems necess o 0-w ;u, a se .nuansa m..ais.m n u w n w ns Manager of cM/sss and % Chkf operub9 O((gj,7, 6-9 BRAIDWOOD - UNITS 1 & 2

1 l + .(X) ADMINISTRATIVE CONTROLS ~ l 1 0FFSITE (Continued) h) Instrumentation and Control Engineering graduate or equivalent with at least 5 years-of experience in instrumentation and control design and/or: operation. i) Metallurgy Engineering graduate or equivalent with at least 5 years of experience in the metallurgical field. 3) The Superintendent of'the Offsite Review and Investigative Func-tion 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 Manager, a. Onsite Review and Investigative Function [v] The Station Manager 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 participants for this 1 function; (3) assure that at least two participants who collectively L possess background and qualifications in the subject matter under review are selected to provide comprehensive interdisciplinary review coverage under this function; (4) independently review and approve the findings and recommendations developed by personnel performing the Review and Investigative Function; (5) report all findings of. noncompliance with NRC requirements, and provide recommendations 4e 1 -th: M;i; tent-Vic: Prc;ident cnd Cencral Manager of Nuclear Stations =d the--Supee4ntendent-of-the-Mfdte4eyh and Investigative func 44en; and (6) submit to the Offsite Review and Investigative Function for concurrence in a timely manner, those items described in Specifi-cation 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 Manager to affect nuclear 9 safety; 2) Review of all proposed' tests and experiments that affect nuclear safety; BRAIDWOOD - UNITS 1 & 2 6-12 b

.s. w . ADMINISTRATIVE CONTROLS N. ONSITE (Continued) .v 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 recurrences b-ttre Msistant Vice i' resident and Ccncral Managcr of Nuclear Stations end..tc the Super 4atendent of the Offrite Revic./ and Investigative- %c!! ~~ ; _ 6) Review of all. REPORTABLE EVENTS; M the. /WF d?uald,3k7) Performance of special reviews and investigations and reports thereon as requested t he Superintendent of the Offsite Review r in5 ' d and Investigative Fur .on; ,A occu dsa4 d i4 8) Review of the Station Security Plan and implementing procedures Fggj g, f and submittal of recommended Security Plan changes to the Director of Corporate Security; u , 9.) Review of the Emergency Plan and station implementing procedures 'denf[cdik @Mritt:1 of-recommended changesj tc the StoLivn S u u i i Ly f I'lon to the Circctor of Corpcratc Security, g 1

10) Review of Unit operations to detect potential hazards to nuclear O

safety; e g fo n d e r b *y b'

11) Review of any accidental, unplanne, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrencejand the forward 4 -of-these rcports to thc-9 1,ssistant Vice Pretkent-and-General-Manager-of-Nuc4 ear-Stet 4 ens end the Superktendent-of-the-Offs 4te-Retica and Invcatigative-c = tion; ene
12) Review of changes to the PROCESS CONTROL PROGRAM, the 0FFSITE DOSE CALCULATION MANUAL, and the Radwaste Treatment Systemsj *^o,-
  1. gQ,,g
13) Review of the Fire Protection Program and implementing instruc-tions and T Amittal of recommended changes,te the Off5itc Rev.ww and Investigative Iunctica.

c. Authority The Technical Staff Supervisor is responsible to the Station Manager and shall make recommendations in a timely manner in all areas of review, investigation, and quality control phases of plant mainte- ) nance, operation, and administrative procedures relating to facility operations and shall have the authority to request the action neces-3 sary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Manager l shall follow such recommendations or select a course of action that

9 BRAIDWOOD - UNITS 1 & 2 6-13 AMENDMENT NO.

l 1

ADMINISTRATIVE CONTROLS ONSITE (Continued) q Q %* ed-is more conservative regarding safe operdtion of the facility. All d such disagreements shall be reported immediately to the Accict:nt M Yd*.MpYi 0 Prc;ident and C ncral ",anager of Nucl ;r 2 ;ti:n; and the Super-L intendent of the Offsite Review and Investigative Function. E" f*di'kd T k P"'e&&Spedcaton C.5:2h d. Records 1) Reports, reviews, investigations,andrecommendations/shall [ Mee /ksu4nt 1 be documented with copies to the 4::ictant Vice Prc:id:nt :nd - pyg gp,7,f,ks C ncr; "anager of Nuclear Stati;n:, the Superintendent of the Offsite Review and Investigative Function, th; Statica " car.gt; and the ": nager Of Q-lity M :ur: dei).r. We cpudg peop oad on/ns ekwde stee As.v:sswd'll records and documentation shall' be kept on f 2) Copies of a 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: Q pyg mg, ~ O ~~ 1) Content and method of submission and presentation to the Stauon Manager, M;i; tant Vice Prc:ident and G ncr ! ": nager of "ucled l- -Station:, and the Superintendent of the Offsite Review and i Investigative Function, 2) Use of committees, 3) Review and approval, 4) Detailed listing of items to be reviewed, 5) Procedures for administration of the quality control activities, and 6) Assignment of responsibilities. f. Personnel 1) The personnel performing the Onsite Review and Investigative Function, in addition to the Station Manager, shall consist of persons having expertise in: a) Nuclear power plant technology, b) Reactor operations, l c) Reactor engineering, 'q d) Chemistry C/ e) Radiological controls, f) Instrumentation and control, and g) Mechanical and electrical systems. BRAIDWOOD - UNITS 1 & 2 6-14 (_

~ a I j i V de ?f P.5I h k N E C f W o I M h t ' ADMINISTRATIVE CONTROLS i ONSITE (Continued) ~ 2) Personnel performing the Onsite Review and Investigative j 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 hi; tant Vice President-and-General--Manager of Nuclear St=Hane V 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety tiniit is violated: The NRC Operations Center shall be notified by telephone as soon as g (~l a. U possible and in all cases within 1 hour. The Ae h tent 4 ce Preside m and Ceneral Manager Of Nuclear Statiens and the Offsite Review and Investigative Function shall be notified within 24 hours; b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the Onsite Review and Investigative Function. This J 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 the Commission, c. the Offsite Review and Investigative Function and the k;htant Vicc + heshent-and-General Manager of Nuclear Staticn 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: The applicable procedures recommended in Appendix A, of Regulatory a. Guide 1.33, Revision 2, February 1978, BRAIDWOOD - UNITS 1 & 2 6-15

,9 ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued) I source or from any surface which the radiation penetrates snall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures O.;;., ".;i'Ch;- T;;h.ici;.) or personnel continuously escorted by such individuals may be exempt from the RWP ' issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following: I a. A radiation monitoring device which continuously indicates the i radiation dose rate in the area; or b. A radiation monitoring device which continuously integrates the j; radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them; or c. An individual qualified in radiation protection procedures with a ~ radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and l; shall perform periodic radiation surveillance at the frequency j: specified in the Radiation Work Permit. 6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mR/n at 45 cm (18 in.) from j the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be ll'I maintained under the administrative control of the Shift Foreman on duty and/or health physics supervision. Doors shall remain locked except during periods of 4' access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, ) direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area. During emergency situations which involve personnel injury or actions taken to prevent major equipment damage, continuous surveillance and radiation monitoring of the work area by a qualified individual may be substituted for the routine RWP procedure. For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within large areas, such as l PWR containment, where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that 1 individual area shall be barricaded (by a more substantial obstacle than rope), conspicuously posted, and a flashing light shall be activated as a warning device. l BRAIDWOOD - UNITS 1 & 2 6-24 _- ___ __ a :

I l 1 ADMINISTRATIVE CONTROLS 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implementation. 6.13.2 Licensee-initiated changes to the PCP: a. Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contain: 1) Sufficiently detailed information to totally support the rationale for the change out benefit of additional or supplemental information; 2) A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and 3) Documentation of the fact that the change has been reviewed and found acceptable by the Onsite Review and Investigative Function. b. Shall become effective upon review and acceptance by the Onsite Review and Investigative Function in accordance with Specification 6.5.2. 6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation. 6.14.2 Licensee-initiated changes to the ODCM: a. Shall be submitted to the Commission by inclusion in the Monthly Operating Report pursuant to Specification 6.9.1.8 within 90 days of the date the change (s) was made effective. This submittal shall contain: 1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information. Information submitted should consist of a package of those pages of the 00CM to be changed with each page numbered, dated and containing the revision number, together with appropriate analyses or evaluations justifying the change (s); 2) A determination that the change will not reduce the accuracy or reliability of dose calculations or Setpoint determinations; and 3) Documentation of the fact that the change has been reviewed and found acceptable by the Onsite Review and Investigative Function. b. Shall become effective upon review and acceptance by the Onsite Review and Investigative Function in accordance with Specification 6.5.2. -m m n no an

l O e l ATTACIMENT_B DETAILED _DESCRIPILON AND SU191ABI The proposed amendment requests several changes to the Administrative Controls Section 6.0 of the Technical Specifications which include: (1) Removal of Organizational Figures 6.2-1 and 6.2-2, (2) a position change from Radiation Chemistry Technician to Radiation Protection Technician, (3) several position title changes due to reorganization, (4) a clarification to the distribution requirement for Onsite Reviews, and (5) typographical or editorial changes. Following is a description of each of the changes. 1) In accordance with Generic Letter 88-06, we propose replacing the Organizational Figures 6.2-1 and 6.2-2 in Technical Specifications with' more general organizational requirements. These general requirements capture the essence of those organizational features depicted on the figures that are necessary for ensuring safe operation. The proposed revision to the Technical Specifications will require organizational charts to be maintained in the Quality Assurance Manual. In addition, the important organizational features depicted on the organizational figures are also contained in other regulatory controlled documents. Chapter 13 of the UFSAR contains details of the organizational structure and a description of the Conduct of Operations. This information is required by 10 CFR 50.71 to be maintained and updated annually. Also a Quality Assurance (QA) program is required for Byron and Braidwood by 10 CFR 50, Appendix B. In addition to the organizational charts, the Quality Assurance Manual and Topical Report CE-1-A contain descriptions of the functional responsibilities and reporting requirements. The Technical Specifications are not specifically required to contain organizational figures by 10 CFR 50.36. Organizational figures in themselves do not have a significant safety relevance. However, specific operational requirements that bear more directly on safety matters of concern, than organizational figures, are required elsewhere in the Technical Specifications (TS). For example, the organizational element responsible for the control room command function is identified in TS 6.1.2, and the requirements for minimum staffing under various operating conditions is identified in Table 6.2-1. The organizational management functions for review investigations and audits, and onsite and offsite review and investigative groups, and shift technical advisors are also specified in other TS. It_____

O i e s The important features identified on the organizational figures, but not currently included in the Technical Specifications as identified by Generic Letter 88-06, have been proposed to be added to TS 6.2. The proposed change to 6.2.la only references the organizational charts because that is the only item being removed from the TS. The Generic Leiter 88-06 references to functional descriptions of departmental responsibilities and description of key personnel position is already included in the UFSAR. The addition of TS 6.2.2f only specifies the Assistant Superintendent Operating since the other positions required to hold a license are discussed on Table 6.2-1. The organizational figures in the Quality Assurance Manual are of a level of detail consistent with that shown on the organizational figures in TS. The proposed change will permit changes to the onsite and offsite organizational structures to be implemented without first obtaining NRC approval through issuance of a license snendment to update the TS. We believe changes to these figures have resulted in processing unnecessary mnendments by both Commonwealth Edison Company and the NRC and, therefore, l deletion will eliminate needless expenditure of resources for both l organizations without affecting safe operation of the plant.

2) This change involves revising the position title of " Radiation Chemistry Technician" to " Radiation Protection Technician".

A reorganization is in progress which will result in separate positions for a Radiation Protection Technician and a Chemistry Technician in lieu of a single Radiation Chemistry Technician. The individual fulfilling the Radiation Protection Technician position would be qualified in radiation protection procedures. NUREG-0452 " Standard Technical Specifications for Westinghouse Pressurized Water Reactors", Revision 4 and draft Revision 5, requires a llealth Physics Technician to be onsite when fuel is in the reactor. The Radiation Protection Technician will satisfy the requirements for a flealth Physics Technician specified in the Standard Technical Specification. Therefore, this change is to address a position title change. Also, the reference to Red / Chem Technician was deleted on page 6-24. This particular reference is unnecessary and its deletion will prevent the need to amend the Technical Specifications in the future for a position title change.

4) Several places in the Administrative Section 6.0 of TS, position title changes are required due to reorganization. The title revisions include changing " Assistant Vice Pref 2ident and General Manager - Nuclear Stations" to "Vice President PWR Operations", and "Vice President - Nuclear Operations" to " Senior Vice President - Nuclear Operations", and " Chairman and President" to " Chief Executive Officer".

These changes are required to accurately reflect current organizational titles and functional responsibilities.

s. >g

e.,
5). Changes-are proposed to TS 6.5.2 to clarify the distribution requirements of reports, reviews, investigations and recommendations that have been prepared and performed as part of the Onsite Review and Investigative Function.

Currently TS 6.5.2b lists the responsibility of the Onsite Review and Investigative Function. Of the list'of 13 items, several. specify that recommendations should be submitted and reports forwarded to specific groups or individuals. However, TS 6.5.2d also requires that reports, reviews, investigations and recommendations be documented and sent to several individuals. TS 6.5.2d requires distribution to more people than TS 6.5.2b. Therefore, to remove any ambiguity, we propose deleting the distribution listings from IS 6.5.2b and thereby allowing TS 6.5.2d to address the distribution requirements. We also propose revising TS 6.5.2d to delete distribution to the Station Manager. The Station Manager supervises the Onsite Review and Investigative Function. Therefore, it is unnecessary for the Station Manager to distribute a copy to himself when TS 6.5.2d2 requires a copy to be maintained on file at the Station.

6) A typographical error has been identifie6 in Section 6.1.3.2.al), an "1"

must be added to the word "without". I I l l i l l l /sc1:5428K 4-6 i l I i

<4.

  • 6 e.

.i 4. L a*. : h , ~p DD o-l EVALUATION OF SIGNIFICANT HAZARD' CONSIDERATIONS t: Commonwealth Edison has evaluated this proposed unendment.and determined that it' involves no'significant hazards consideration. According; to 10 CFR 50.92(c), a proposed amendment to an operating license involves no l-significant hazards considerations if operation of the facility in accordance with the proposed snendment 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 3.- Involve a significant reduction in a margin of safety. The proposed Technical Specification amendment requests several changes. The first change involves the removal of organizational Figures 6.2-1 and 6.2-2 and the revision of TS 6.2.1 and 6.2.2 in accordance with the guidance provided in Generic Letter 88-06. The second proposed revision involves a position change from Radiation Chemistry Technician to Radiation [ Protection Technician in TS 6.2.2 and 6.12. The third proposed revision ^ corrects several position titles that changed due to corporate reorganization. The fourth change clarifles the distribution requirements for onsite review documentation discussed in TS 6.5.2. The fifth and last change is a typographical correction. None of the proposed changes are initiating events for an accident, therefore, the probability of an occurrence of an accident is not affected. 'Even though the organizational figures are being removed, TS 6.2.la is being revised to require the organizational figures be maintained in the Quality Assurance Manual. In addition, TS 6.2.1 proposed revision adds general requirements that capture the essence of the organizational features included in the figures. Also, important organizational featuros are contained in other regulatory controlled documents. Therefore, safe plant operation is not

a .s y o ,' l 1 l affected and the consequence of any accidents presented in the UFSAR are not imparted by the first change. The revisions proposed with Change 2 does not alter the Station's adherenco with regulatory guidance currently existing in NUREG-045?, 10 CFR 50.71 requirements for the UFSAR, ANSI Standards and Regulatory Guides. The remaining changes address organizational changes,. j clarification for documentation distribution and editorial and typographical changes. All these changes are administrative in nature and the consequences of an accident as described in the UFSAR are not affected. The proposed changes do not revise any functional or design parameters used at the Station. These changes do not modify any equipment or systems or cause the unit to be operated in a different manner. Therefore, the possibility of a new or different kind of accident is not created. All the proposed changes are administrative, editorial or i typographical and, as such, do not affect any margins of safety. The proposed i organization changes do not affect safe operation of the plant. Creation of a f Radiation Protection Technician position in lieu of a Radiation Chemistry Technician adequately meets the requirements for Health Physics coverage identified in NUREG 0452. Updating position titles, clarifying documentation distribution requirements and typographical and editorial changes, facilitate plant operations but do not affect safe operations. For the preceding reasons, Commonwealth Edison believes all the changes proposed for the Technical Specification snendment do not involve any significant hazards considerations. ) /sc1:5428K:7-8

o

. g ATIhCHMENT D s

SAFETY EVALUATION AND ENVIRONMENTAL ASSESSMENT 4 Typically onsite and offsite organizations are defined by organization charts included under administrative control requirements of the Technical Specification (TS). This requires the processing of a license amen &nent to change an organization chart before implementing a change in organizational structure. The guidance provided in Generic Letter 88-06 addresses amendments that may be proposed for removing organization charts from the a&ninistrative control requirements of the TS. The staff has previously determined that with appropriate changes to these administrative control requirements, the onsite and offsite organization charts may be removed. The changes involve the addition of general requirements that capture the essential aspects of the organizational structure that are defined by existing onsite and offsite organization charts. to Generic Letter 88-06 provides guidance for license snendment requests to remove organization charts from TS. to Generic Letter 88-06 provides an example of this change that was made to the administrative control requirements of the existing Westinghouse Standard Technical Specifications (STS). The staff has found that this change will not reduce plant safety and it is generically applicable to all power reactors. The removal of organization charts is a line item improvement that was proposed on a lead-plant basis for the Shearon Harris plant and was endorsed by the Westinghouse Owners Group. This change was reviewed as part of the NRC's program for improvements in TS. The objectives of that program were established by the Commission's Interim Policy Statement on Technical Specification Improvements. The staff concludes that the removal of organization charts from TS will provide greater flexibility for licenses to implement changes in both the onsite and offsite organizational structure, consistent with Commission policy. Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actions requiring environment assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for a categorical l exclusion as provided for under 10 CFR 1.22(c)(9). This determination was l based on the fact that changes are being proposed as an amendment to a license issued pursuant to 10 CFR 50. The changes are of an administrative nature only. The changes involve no significant hazards, there are no significant 2 changes in the types or amounts of off-site effluents, and there are no significant increases in individual or cumulative occupational exposure. ) /sc1:5428K:9 l _a}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20235J067&oldid=3950872"