ML20237E233

Revised Pages of Section 20 of Rev 66 to CE-1-A, QA Topical Rept

ML20237E233
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle
Issue date:	08/21/1998
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20237D979	List: ML20237D977 ML20237E233
References
CE-1-A-ERR, NUDOCS 9808310049
Download: ML20237E233 (21)

Text

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INDEPENDENT REVIEW PROGRAM SECTION 20

1. POLICY Safety reviews of plant operations are conducted to ensure that day-to-day activities are conducted in a safe manner. Senior management is periodically provided with overall assessments of facility operations and recommendations to improve nuclear safety .

2. RESPONSIBILITIES The following organizations are responsible for carrying out the requirements of this Section:

Nuclear Generation Grcup, Headquarters l Nuclear Oversight Nuclear Stations Nuclear Safety Review Boards Plant Operations Review Committees l

3. REQU:REMENTS Section 20A defines the Nuclear Generation Group and Nuclear Safety Review Board (NSRB) requirements. The NSRB is responsible for the Offsite Review. The NSRB Chairperson will fulfill the requirements delineated in the Technical Specifications for the Director of Safety Review.

Section 20B defines the Nuclear Stations Technical Review and Plant Operations Review Committee (PORC) requirements. The PORC is responsible for Onsite Review at the operating facilities.

Section 20C defines the Offsite Review and Onsite Review functions for permanently shutdown facilities (Dresden Unit-1 and Zion Units 1 and 2). The Vice President Nuclear Oversight appoints the offsite review Senior Participant who will fulfill the requirements delineated for the Director of Safety Review. j

4. REFERENCES The following references were used in the generation of this Section.

. Facility Operating Licenses (Technical Specifications)

. Letter dated October 20,1994 from G.F. Dick (NRC) to D.L. Farrar (Comed) .

. ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel"

. ANSI N18.7-1976 (ANS-3.2), " Quality Assurance for the Operational Phase of l 1

Nuclear Power Plani.s" j l

l Page 20-1 REVISION 66 9008310049 900821 PDR ADOCK 05000010 W PDR , j l

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NUCLEAR SAFETY REVIEW BOARDS SECTION 20A

1. POLICY The Nuclear Safety Review Board (NSRB) is an offsite committee that provides senior level oversight of the Comed nuclear program with respect to nudear safety. ,

The NSRB reviews the activities of the line organizations, as well as other review, audit, and verification organizations. The NSRB provides senior level management with a periodic assessment of facility operations and recommendations to improve l l nuclear safety,

2. RESPONSIBILITIES The following organizations are responsible for carrying out the requirements of this Section:

l Nuclear Generation Group, Headquarters '

Nuclear Stations i

3. REQUIREMENTS 3.1 NSRB CHAIRPERSON I

3.1.1 The NSRB Chairperson has an independent reporting relationship to the I President, N / clear Generation Group (NGG) and Chief Nudear Officer and other NGG management on nuclear safety matters. He is responsible for reviewing and approving the findings and recommendations of the NSRB; advising the President, NGG and Chief Nuclear Officer on the adequacy and implementation of Comed nuclear safety policies and programs.

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3.1.2 The NSRB Chairperson is responsible for complying with the requirements of l ANSI N18.7-1976 (ANS 3.2). The Chairperson is also responsible for ensuring that the quality assurance requirements established by this Topical Report related to NSRB functions are either included or referenced (as appropriate) in related procedures or instructions.

I 3.1.3 The NSRB Chairperson shall be appointed in writing by the President, NGG l and Chief Nuclear Officer.

3.1.4 The NSRB Chairperson shall have experience and training that satisfies ANSI N18.1-1971 requirements for " Plant Managers."

Page 20A-1 REVISION 66 l

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V NUCLEAR SAFETY REVIEW BOARDS SECTION 20A 3.1.5 The NSRB Chairperson shall approve and report in a timely manner all l findings of non-compliance with NRC requirements to the Station Manager / General Plant Manager, Site Vice President, BWR or PWR Vice l President, Vice President, Nuclear Oversight and the President, NGG and 4 Chief Nuclear Officer.

3.2 NSRB MEMCERSHIP 3.2.1 The NSRB shall be composed of at least six members, including the Chairperson. Members are typically senior NGG managers, senior site management, and non-Comed persons. The use of alternates shall be restricted to legitimate absences of members. No more than a minority of the membership shall have line responsibility for operation of the plant. No more than two alternate members shall participate as voting members in NSRB activities at one time.

l 3.2.2 Members and alternate members shall have a minimum of nine years technical experience in one or more of the disciplines specified in ANSI N18.7-1976 (ANS 3.2), as appropriate for the subject or subjects being reviewed and investigated. A maximum of four of these nine years may be fulfilled through academic training in the pursuit of a degree in engineering or the physical sciences.

3.2.3 Members, and alternate members of the NSRB shall be appointed by the President, NGG and Chief Nuclear Officer.

3.3 NSRB FUNCTIONS l The NSRB shall, as a minimum:

3.3.1 Advise the President, NGG and Chief Nuclear Officer, on all matters'that might l affect nuclear safety, within its purview; 3.3.2 Recommend to the President, NGG and Chief Nuclear Officer, actions to improve nuclear safety; 3.3.3 Notify the President, NGG and Chief Nuclear Officer, of any safety significant  ;

disagreement between the NSRB and the organization or function being l reviewed; '

3.3.4 Provide an independent review of findings and recommendations resulting from station reviews of programs, processes, and activities delineated in 3.4; l and Page 20A-2 REVISION 66 l

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NUCLEAR SAFETY REVIEW BOARDS - SECTION 20A I l

1 3.3.5 Determine the satisfactory completion of action required based on approvad  !

l findings and recommendations resulting from NSRB proceedings.

3.4 NSRB REVIEW RESPONSIBILITIES The NSRB shall review 3.4.1 Written safety evaluations of (a) changes in procedures, structures, systems, or components and (b) tests or experiments completed under the provision of 10CFR50.59, to verify that such actions do not constitute an unreviewed safety question.

3.4.2 Proposed changes to procedures, equipment, or systems that involve an unreviewed safety question as defined in 10CFR50.59; 3.4.3 Proposed tests or experiments that involve an unreviewed safety question as defined in 10CFR50.59; 3.4.4 Proposed changes to Technical Specifications or NRC operating license; l 3.4.5 All reportable events, per 10CFR50.73; l 3.4.6 Responses to violations of applicable codes, regulations, orders, technical 3

specifications, license requirements, or internal procedures or instructions i having nuclear safety significance; 3.4.7 Significant operating abnormalities or deviation from normal and expecterf l performance of station equipment that affects nuclear safety; 3.4.8 All recognized indications of an unanticipated deficiency in some arpect of design or operation of safety-related structures, systems, or components; 3.4.9 All changes to the Generating Stations Emergency Plan prior to l implementation of such change; and 3.4.10 All items referred by the Site Vice President; the Station Manager / Plant ,

General Manager; the PORC Chairperson or the Vice President, Nuclear Oversight.

3.5 NSRB Procedures i i

l Written administrative procedures shall be prepared and maintained for the NSRB. l These procedures will include the following: l l

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" l NUCLEAR SAFETY REVIEW BOARDS SECTION 20A l l l 3.5.1 Preparation of meeting agenda, meeting minutes, and transmittal of information to the NSRB; 3.5.2 Use of committees and consultants; l l

l 3.5.3 Detailed listing ofitems to be reviewed; l 3.5.4 Review and recommendation for approval or disapproval of items reviewed ; I and 1 3.5.5 Method of appointing personnel, performing reviews and investigations, reporting findings and recommendations of reviews and investigations, self- l assessment, approving reports, and distributing reports. I 3.6 NSRB RECORDS i

Records documenting the actions of the NSRB will be produced and maintained as follows:

3.6.1 Minutes of each NSRB meeting shall be disseminated promptly to the l President, NGG and Chief Nuclear Officer and to appropriate members of management having responsibility in the area reviewed; and 3.6.2 Copies of documentation, reports, and correspondence shall be kept on file at the appropriate station.

3.7 MEETING FREQUENCY l 3.7.1 Formal NSRB meetings shall be scheduled as needed but no less frequent I than twice in a year. i 1

3.8 NSRB Effectivess 3.8.1 NSRB activities will be periodically reviewed for effectiveness.

! 4. REFERENCES I

l The following references were used in the generation of this Section.

i . Facility Operating Licenses (Technical Specifications) l . Letter dated October 20,1994 from G.F. Dick (NRC) to D.L. Farrar (Comed) i

. ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel"

. ANSI N18.7-1976 (ANS-3.2), " Quality Assurance for the Operational Phase of Nuclear Power Plants" Page 20A-4 REVISION 66 r

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PLANT REVIEW FUNCTIONS SECTION 20B

1. POLICY Reviews of plant operations are conducted to ensure that day-to-day activities are performed in a safe manner. Technical reviewers review procedures, procedure changes, and proposed changes to structures, systems, and components that affect a nuclear safety in the area of their expertise. The Plant Operations Review Committee (PORC) is a multi-disciplined committee responsible for providing an oversight review of documents required for safe operation of the plant. PORC advises the Station Manager / Plant General Manager on all matters related to nuclear safety, within its purview. l l

2. RESPONSIBILITIES The following persons are responsible for carrying out the requirements of this section:

Station Manager / Plant General Manager Technical Reviewers Plant Operations Review Committee Members

3. REQUIREMENTS 3.1 GENERAL 3.1.1 The items in Article 3.4.7 receive varying degrees of review before final approval or use as specified in approved administrative procedures. The degree of review shall be commensurate with the potential to affect nuclear l:

safety. As a minimum, each item shall be reviewed by at least one individual knowledgeable in the subject matter and cross-disciplinary review (s) shall be l obtained as needed, before approval.

3.1.2 Qualified reviewers shall conduct the required technical and cross-disciplinary l reviews.

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PLANT REVIEW FUNCTIONS SECTION 20B 3.2 STATION MANAGER / PLANT GENERAL MANAGER The Station Manager / Plant General Manager shall:

3.2.1 Provide supervisory direction for the Technical Review program and the PORC. l 3.2.2 Appoint individuals to provide appropriate coordination of the PORC. l 3.2.3 Approve individuals as technical reviewers and for the PORC function.

3.2.4 Independently review and approve the findings and recommendations of the PORC.

3.2.5 Report all findings of non-compliance with NRC requirements %d provide recommendations.

3.2.6 Submit to the Nuclear Safety Review Board (NSRB) for review, in a timely manner, those items described in Section 20A, Article 3.4.

3.3 PLANT TECHNICAL REVIEW PROCESS 3.3.1 Qualifications Technical reviewers shall be qualified to perform technical reviews based on the individual's training, experience, and knowledge level. Technical j reviewers, assigned the responsibility for reviewing 10CFR50.59 safety j evaluations, shall receive training in this process. Technical reviewers shall I meet the applicable experience requirements of ANSI N18.1-1971, Sections 4.2 and 4.4.

3.3.1.1 Personnel shall have expertise in one or more of the following disciples as appropriate for the subject or subjects being reviewed and investigated: 1 3.3.1.1.1 Nuclear Power Plant Technology 3.3.1.1.2 Reactor Operations l 3.3.1.1.3 Reactor Engineering 3.3.1.1.4 Chemistry 3.3.1.1.5 Radiological Controls 3.3.1.1.6 Instrumentation and Controls 3.3.1.1.7 Mechanical and Electrical Systems Page 20B-2 REVISION 66 l l

PLANT REVIEW FUNCTIONS SECTION 20B 3.3.2 Functions 1

i The technical reviewer (s) shall:

3.3.2.1 Not review their own work. '

3.3.2.2 Advise their supervisors and/or PORC on all matters related to nuclear safety identified during reviews.

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3.3.2.3 Determine the need for additional reviews by other disciplines and ensure that identified reviews are conducted for items considered under Article 3.3.3 prior to their implementation.

3.3.2.4 Determine whether each item considered under Articles 3.3.3.1 through 3.3.3.3 constitutes an unreviewed safety question as defined in 10 CFR 50.59. i I

3.3.3 Responsibilities l The technical reviewers shall be responsible for the technical review of:

3.3.3.1 Proposed programs and procedures required by Section 5, Article 3.3.1 (Dresden Units 2 and 3 and Quad Cities), or Technical Specification Section 6.8.1 and 6.8.2 (Braidwood and Byron), or Technical Specification Section 6.2.A, B and C (LaSalle) and Section l 208, Article 3.4.7.1 and changes thereto. l 3.3.3.2 Proposed changes and modifications to unit systems or equipment I that affect nuclear safety.

3.3.3.3 Proposed tests and experiments that affect nuclear safety.

3.3.3.4 ~ Proposed changes to Technical Specifications. their Bases, and the Operating License.

3.4 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

The Plant Operations Review Committee shall function as a multi-disciplinary review body for items that affect plant nuclear safety.

PORC shall be organized and shall conduct business as follows:

Page 208-3 REVISION 66 l l

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PLANT REVIEW FUNCTIONS SECTION 20B 3.4.1 Qualifications 3.4.1.1 Personnel shall meet the applicable qualification levels described in ANSI N18.1-1971, Sections 4.2.3.4.1.2. Personnel shall have expertise in one or more of the following disciplines as appropriate for the subject or subjects being reviewed and investigated:

3.4.1.2.1 Nuclear Power Plant Technology 3.4.1.2.2 Reactor Operations 3.4.1.2.3 Reactor Engineering 3.4.1.2.4 Chemistry 3.4.1.2.5 Radiological Controls 3.4.1.2.6 Instrumentation and Controls 3.4.1.2.7 Mechanical and Electrical Systems 3.4.2 Composition 3.4.2.1 The membership of the PORC consists of:

Chairperson: Personnel appointed to this position will be a station l organization department manager or senior staff manager Member: Operations Representative Member: Maintenance Representative Member: Site Engineering Representative Member: Site Nuclear Oversight Representative Member: Regulatory Assurance Representative Member: Health Physics i' representative Member: Chemistry Representative 1

3.4.2.2 Alternates All alternate members shall be appointed in writing by the Station Manager / Plant General Manager to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

I 3.4.3 Meeting Frequency The PORC shall meet on an as needed basis as convened by the PORC l Chairperson or designated alternate.

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PLANT REVIEW FUNCTIONS SECTION 20B j 3.4.4 Quorum

, The PORC quorum shall consist of the Chairperson and four members of whom no more than two may be alternates. l 3.4.5 Reporting The PORC reports to the Station Manager / Plant General Manager on all activities and findings. The meeting minutes shall serve as the official correspondence from PORC to the Station Manager / Plant General Manager.

PORC recommendations shall be recorded in the minutes and submitted to I the Station Manager / Plant General Manager and NSRB. l 3.4.6 Functions PORC shall, as a minimum: l 3.4.6.1 Advise the Station Manager / Plant General Manager on all matters related to nuclear safety within its purview. l 3.4.6.2 Recommend to the Station Manager / Plant General Manager, or his designee, approval or disapproval of items considered under Article 3.4.7 prior to their implementation.

3.4.6.3 include among its review conclusions for each item considered under Articles 3.4.7.1 through 3.4.7.3 a determination of whether or not the item involves an unreviewed safety question.

l 3.4.6.4 Provide prompt notification to the Site Vice President and the NSRB of any safety significant disagreement between the PORC and the Station Manager / Plant General Manager. The Station Manager / Plant General Manager shall follow the recommendations of PORC or select a course of action that is more conservative regarding safe operation of the facility.

3.4.7 Responsibilities The PORC shall be responsible for the review of:

3.4.7.1 Administrative procedures, program descriptions, and changes thereto, other than editorial changes, for the following:

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L PLANT REVIEW FUNCTIONS SECTION 20B i

3.4.7.1.1 All applicable station Administrative Procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

3.4.7.1.2 Emergency operating procedures required to implement ,

NUREG-0737 and NUREG-0737, Supplement 1 as stated in Section 7.1 of Generic Letter 82-33. l 3.4.7.1.3 Station Security Plan.

3.4.7.1.4 Fire Protection Program.

3.4.7.1.5 Process Control Program (PCP).

3.4.7.1.6 Offsite Dose Calculation Manual (ODCM).

3.4.7.1.7 Generating Station Emergency Plan and Site Annexes. '

3.4.7.1.8 Changes to the Inservice Inspection Program for Post Tensioning Tendona (LaSalle only).

3.4.7.2 Proposed changes and modifications to unit systems or equipment i that affect nuclear safety.

3.4.7.3 Proposed tests and experiments that affect nuclear safety.

3.4.7.4 Proposed changes to Technical Specifications and the Operating License and any proposed change which involves an unreviewed safety question that is to be submitted to the Nuclear Regulatory Commission for approval.

3.4.7.5 Results of investigation results for all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence.

3.4.7.6 Results of investigation results for License Event Reports and other l significant cporational abnormalities including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence. l 3.4.7.7 Review of unit operations to detect hazards to nuclear safety. l Page 20B-6 REVISION 66 l

PLANT REVIEW FUNCTIONS SECTION 20B l 3.4.7.8 Review of investigation results for any accidental, unplanned, or uncot + rolled radioactive release including the preparation and forwarding of reports covering evaluations and recommendations to

prevent recurrence.

3.4.7.9 Performance of special reviews and investigations and reports

thereon requested by the Nuclear Safety Review Board.

l 3.5 Procedures l

l Written procedures shall be prepared and maintained for conduct of the PORC.

l These procedures shall include the following:

t 3.5.1 Preparation of meeting agenda, meeting minutes and transmittal of l

information to the Station Manager / Plant general Manager, Site Vice

President, and NSRB.

3.5.2 Use of committees.

I l 3.5.3 - Detailed listing of items to be reviewed.

l 3.5.4 Review and recommendation for approval or disapproval of items reviewed.

3.5.5 Assignment of responsibilities.

! 3.6 Records

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l Written records of reviews shall be maintained. As a minimum these records shall )

include:

l 3.6.1 Results of the activities conducted under the provisions of Articles 3.3 and 3.4.

l 3.6.2 Recommended approval or disapproval of items considered under Articles l 3.3.3 and 3.4.7.

3.6.3 The determination of whether or not each item considered under Articles l 3.3.3.1 through 3.3.3.3 and Articles 3.4.7.1 through 3.4.7.3 constitutes an unreviewed safety question as defined in 10 CFR 50.59, i

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PLANT REVIEW FUNCTIONS SECTION 20B {

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4. REFERENCES l The following references were used in the generation of this Section.

l l . Facility Operating Licenses (Technical Specifications) l . Letter dated October 20,1994 from G.F. Dick (NRC) to D.L. Farrar (Comed) l . ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel" l . ANSI N18.7-1976 (ANS-3.2), " Quality Assurance for the Operational Phase of l'

Nuclear Power Plants" i

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I Page 20B-8 REVISION 66 l

OFFSITE cnd ONSITE REVIEWS SECTION 20C

1. POLICY l

j This Section is only applicable to independent safety reviews of plant operations for permanently shutdown facilities (i.e., facilities where the NRC has acknowledged )

cessation of operations). The reviews are performed to ensure that day-to-day l l activities are conducted in a safe manner. Senior management is provided with overall l

assessments of facility storage operations and recommendations to improve nuclear

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l l safety. )

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2. RESPONSIBILITIES l

i l The following organizations are responsible for carrying out the requirements of this

! Section: ]

l l Nuclear Generation Group, Headquarters l j Nuclear Stations Nuclear Oversight

3. REQUIREMENTS j l

3.1 General l

i The Offsite Review senior participant fulfills the function of the Director Safety Review l and shall be appointed by the Vice President, Nuclear Oversight.

The Offsite and Onsite Review processes will be used by permanently shutdown facilities (Dresden Unit 1 and Zion Units 1 and 2). This process has been the historical independent review process used for all Comed facilities and will be maintained for Dresden Unit-1 and Zion Units 1 and 2. l 3.2 Offsite Review l I

The senior participant for Offsite Review shall: l l

l 1. Provide directions for Offsite Review,

2. Select each participant for this function.

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. OFFSITE cnd ONSITE REVIEWS SECTION 20C

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 Offsite Review.

5. Approve and report in a timely manner all findings of non-compliance with NRC requirements to ths decommissioning Plant Manager, Vice President, Nuclear Oversight, the Corporate Vice President responsible for decommissioning activities, and the President, NGG and Chief Nuclear Officer.

During periods when the senior participant is unavailable, he shall designate this responsibility to an established alternate, who satisfies the formal training and

- l experience per Article 3.2.4 as applicable. The responsibilities of the personnel performing this function are stated below.

3.2.1 Required Offsite Reviews The Offsite Review and investigative Function shall review-

a. Safety evaluations for:

l 1. Changes to procedures, equipment, or systems that affect the description in the safety analysis report, and

2. Tests or experiments completed under the provision of 10CFR50.59 to verify that auch actions did not constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment, or systems which involve an unreviewed safety question as defined in 10CFR50.59.

c. Proposed tests or experiments which involve an unreviewed safety question as defined in 10CFR50.59.

l d. Proposed changes in Technical Specifications or NRC Operating License.

l l e. Responses to violations of applicable codes, regulations, orders, technical specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f. Significant operating abnormalities or deviation from normal and expected performance of plant equipment that affect nuclear safety as referred to it by Onsite Review.

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-f OFFSITE cnd ONSITE REVIEWS SECTION 20C I

g. All reportable events, per 10CFR50.73.  ;

h. All recognized indications of an unanticipated deficiency in some aspect of l design or operation of safety related structures, systems, or components.

i. All changes to the Generating Stations Emergency Plan prior to implementation of such change.

J. All items referred by the Corporate Vice President; the Decommissioning Plant Manager; the site Engineering Manager; the Vice President, Nuclear Oversight; or Onsite Review.

3.2.2 Records Records documenting the actions of Offsite Review will be produced and maintained as follows:

a. Reviews, audits, and recommendations shall be documented and distributed to the Corporate Vice President, Decommissioning Plant Manager and the Vice I President, Nuclear Oversight. .

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b. Copies of documentation, reports, and correspondence shall be kept on file at the appropriate station.  ;

3.2.3 Procedures Written administrative procedures shall be prepared and maintained for Offsite Review.  ;

These procedures will include the following:

a. Content and method of submission of presentations to the senior participant of Offsite Review.

b. Use of committees and consultants.

c. Review and approval.

d. Detailed listing of items to be reviewed.

e. Method of:

1. Appointing personnel.

2. Performing reviews and investigations.

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I OFFSITE and ONSITE REVIEWS SECTION 20C l

3. Reporting findings and recommendations of reviews and investigations. 3

4. Approving reports.

5. Distributing reports.

f. Determining satisfactory completion of action required based on approved l findings and recommendations resulting from Offsite Review proceedings.

! 3.2.4 Personnel r The persons, including consultants, performing Offsite Reviews, in addition to the

! l senior participant, shall have expertise in one or more of the following disciplines as l_ 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 f g. Reactor safety analysis -

h. Instrumentation and control

1. Metallurgy J. Any other appropriate disciplines required by unique characteristics of the l facility L Individuals performing the Offsito Reviews shall possess the minimum formal training l and experience, as listed below, for each discipline.

a. Nuclear Power Plant Technology - Engineering graduate or equivalent with 5 years experience in the nuclear field design and/or operation.

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b. Reactor Operations - Engineering graduate or equivalent with 5 years l l experience in nuclear power plant operations.

l l c. Utility Operations - Engineering graduate or equivalent with at least 5 years of experience in utility operation and/or engineering.

d. Power Plant Design - Engineering graduate or equivalent with at least 5 years of experience in power plant design and/or operation.

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W 5 OFFSITE and ONSITE REVIEWS SECTION 20C

e. Reactor Engineering - Engineering graduate or equivalent. In addition, at least 5 years of experience in nuclear plant engineering, operation, and/or graduate work in nuclear engineering or equivalent in reactor physics is required.  !

f. Radiological Safety - Engineering graduate or equivalent with at least 5 years of experience in radiation control and safety,

g. Reactor Safety Analysis - Engineering graduate or equivalent with at least 5 years of experience in nuclear engineering.

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

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

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The Senior Participant shall have experience and training, which satisfy ANSI N18.1- l 1971 requirements for" Plant Managers" 3.3 Onsite Review l 3.3.1 General.

l Onsite Review shall be supervised by the Decommissioning Plant Manager, or designee. The Decommissioning Plant Manager shall:

1. Provide directions for Onsite Review and appoint the site Engineering Manager or other comparably qualified individual as the senior participant to provide appropriate directions.

2. Approve participants for this function.

l 3. Assure that at least two participants who collectively possess background and l qualifications in the subject matter under review are selected to provide comprehensive interdisciplinary review coverage under this function.  ;

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4. Independently review and approve the findings and recommendations j developed by personnel performing Onsite Reviews. l

5. Report all findings of noncompliance with NRC requirements and provide l recommendations.

REVISION 66 Page 20C-5 l

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6. Submit to Offsite Review, for concurrence in a timely manner, those items described in Section 20C, Article 3.2.1 which have been approved by Onsite Review.

3.3.2 Authority Onsite Review shall:

a. Advise the Decommissioning Plant Manager on all matters related to nuclear l safety within its purview.

b. Recommend to the Decommissioning Plant Manager the disposition of items considered under Section 20C, Article 3.3.3, items 1 through 9 prior to their implementation.-

c. Include among its review conclusions for each item considered under Section 20C, Article 3.3.3, items 1 through 4 a determination of whether or not the item involves an unreviewed safety question.

d. . Provide prompt notification to the appropriate Corporate Vice President and the Offsite Review senior participant of disagreement between Onsite Review and the Decommissioning Plant Manager. The Decommissioning Plant Manager shall follow the recommendations of Onsite Review or select a course l of action that is more conservative regarding safe storage operations of the facility.

3.3.3 Responsibility i

Onsite Review shall be responsible for conducting the following: I

1. Review of all applicable Plant Administrative Procedures recommended in Appendix A of Regulatory Guide 1.33; Revision 2, February 1978 and changes l thereto.

2. Review of Emergency Operating Procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Section 7.1 of Generic Letter No. 82-33 and changes thereto.

3. Review of all proposed tests and experiments that affect nuclear safety.

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

5. Review of proposed changes to the Fire Protection Program.

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ug, OFFSITE and ONSITE REVIEWS SECTION 20C

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6. Review of the Station Security Plan and submittal of recommended changes to the Station Security Plan in accordance with station procedures.

7. Review of Emergency Plan and identification of recommended changes.

8. Review of changes to the Process Control Program and the Offsite Dose Calculation Manual.

9. Review of all proposed changes to the Technical Specifications or operating license, and any proposed change which involves an unreviewed safety question that is to be submitted to the Nuclear Regulatory Com, mission for approval. ,

10. Review of investigation results for all violations of the Technical Specifications, including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence

11. Review of investigation results for all Reportable Events and other significant operating abnormalities including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence.

~ 12. Review of investigation results for any' accidental, unplanned, or uncontrolled radioactive release including the preparation and forwarding of reports covering evaluations and recommendations to prevent recurrence.

13. Review of unit operations to detect potential hazards to nuclear safety.

14. Performance of special reviews and investigations and reports thereon as requested by the Offsite Review senior participant.

3.3.4 Records Reports, reviews, investigations, and recommendations prepared and performed for Section 200, Article 3.3.3 shall be documented and forwarded to the Offsite Review senior participant unless otherwise specified.

Copies of all records and documentation shall be kept on file at the station.

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

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c d OFFSFTE rnd ONSITE REVIEWS SECTION 20C 4

a. Content and method of submission and presentation to the Decommissioning Plant Manager, Corporate Vice President, and Offsite Review senicr participant.

b. Use of committees. .

c. Review and approval, ,

d. Detailed listing of items to be reviewed.

l e. Assignment of responsibilities.

3.3.6 Personnel The personnel, including consultants, performing Onsite Reviews, in addition to the Decommissioning Plant Manager, 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. Reactor engineering

d. Chemistry

e. Radiological controls

f. Instrumentation and control

. g. Mechanical and electrical systems Personnel performing Onsite Reviews shall meet minimum acceptable levels as described in ANSI N18.1-1971, Sections'4.2 and 4.4.

4. REFERENCES ,

The following references were used in the generation of this Section.

Facility Operating Licenses (Technical Specifications)

- Letter dated October 20,1994 from G.F. Dick (NRC) to D.L. Farrar (Comed) l Page 20C.g REVISION 66