ML20246A550

Application for Amends to Licenses NPF-72 & NPF-77,revising Tech Specs Re Number of Members of Onsite Nuclear Safety Group

ML20246A550
Person / Time
Site:	Braidwood
Issue date:	08/14/1989
From:	Chrzanowski R COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20246A552	List: ML20246A550 ML20246A554
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8908230011
Download: ML20246A550 (3)

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[ X ; 72 West Adarns Street, Chicago, lihnois Comm:nwrith Edison V ddiess Reply to: Post Office Box 767-Chicaga, minois 60690 - 0767 August 14, 1989' Dr. Thomas E. Murley, Director Office of' Nuclear Reactor. Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Braidwood Station Units 1 and 2 Application for Amendment to Facility Operating Licenses NPF-72 and NPF-77 ERC_ Docket' Nos. 40 '54 and 40-4';'i-

Dear Dr. Murley:

Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend .

-Appendix A, Technical Specifications of Facility Operating Licenses NPF-72 and

'NPF-77. The proposed amendment requests a change in the number of members of the On-Site Nuclear Safety Group. The detailed description is contained in Attachment A. the revised Technical Specification page is contained in Attachment B.

The proposed changes have been reviewed and approved by both on-site and off-site review in accordance with Commonwealth Edison procedures.

Commonwealth Edison has reviewed this proposed amendment in accordance with 10  :

CFR 50.92(c) and has determined that no significant hazards consideration exists. This evaluation is documented in Attachment C.

Commonwealth Edison has evaluated the proposed amendment with the requirements of 10 CFR 51.21. Attachment D contains the corresponding ,

Environmental Assessment Statement.

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Commonwealth Edison is notifying the State of-Illinois of our application for this amendment by transmitting a copy of this letter and its attachments to the designated State Official. )

Please direct any questions on this matter to this office.

L Very truly yours, j k V' R. A Chrzanowski Nuclear Licensing Administrator Attachments: A) Detailed Description B) Proposed Technical Specification Changes l C) Evaluation of Significant Hazards Consideration '

D) Environmental Assessment Statement cc: Resident Inspector Braidwood S. P. Sands - NRR Regional Administrator - RIII Office of Facility Safety - IDNS 0245T:1 .

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4 AIIACHMENT A Following the accident at Three Mile Island Unit 2, the NRC Staff developed the Action Plan, NUREG-0660, to provide a comprehensive and integrated plan to improve safety at power reactors. In November, 1980 a set of TMI related actions from NUREG-0660, which were approved for implementation by the Commission, were published in the document NUREG-0737. Included in this NUREG was Item I.B.l.2 - Independent Safety Engineering Group (ISEG).

Under the heading of " Position", the following requirements for the ISEG were provided:

"The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety. The ISEG is to perform independent review and audits of plant activities including maintenance, modifications, operational problems, and operational analysis and aid in the establishment of programmatic requirements for plant activities."

"Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable. ISEG will then be in a position to advise utility management on the overall quality and safety of operations."

In NUREG-0800 Item II.3.6., it is further stated that "That group shall be comprised of a minimum of five dedicated, full-time engineers, located on-site, but reporting off-site to a corporate official who holds a high-level, technically oriented position who is not in the management chain for power production. For utilities with multiple sites, it may be possible to perform portions of the independent safety assessment function in a centralized location for all the utility's plants. In such cases, on On-site Group still is required, but it may be slightly smaller than would be the case if it were performing the entire independent safety assessment."

The requirement for establishing an ISEG was applied only to

) applicants for operating licenses. Therefore, LaSalle County Station was the first Edison station to hLve (NT0L) an ISEG followed closely by Byron and ,

Braidwood. The size of the ISEG at each of these three stations initially consist of four full-time engineers; presently only Braidwood has 4 full-time engineers as the other two stations have requested and have had approved Technical Specification changes reducing the size of the groups to 3 full-time engineers. Also, an ISEG has been added to Dresden. It is not required by the Technical Specification and its size is 2 full time engineers. These groups are administered by the Safety Assessment Manager who is located in the Company corporate offices. The Safety Assessment Manager reports directly to Assistant V.P. Quality Programs & Assessment. Zion and Quad Cities Stations do not have an ISEG; plans are to add groups at these 2 Stations as soon as personnel are available.

Commonwealth Edison's nuclear program is large; there are six, two-unit nuclear stations. The completion of Braidwood Unit 2 marks the end of the construction program in the nuclear division. In March of 1989, there was a major reorganization of the Commonwealth Edison Company.

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ATTACHMENT A (continued)

The new organization includes the Nuclear Operations Quality Programs {

and Asse!sment (QP&A) organization. This group is headed by an Assistant Vice President (AVP) who reports directly to the Senior Vice President Nuclear Operations and is independent of plant operations. Some of the responsibilities and functions of this organization duplicate the efforts of the ISEG. The new corporate support groups interface with six stations; whereas, the ISEG only covers the four stations at present. The QP&A organization has responsibility for performance assessment of the six stations. They monitor station performance utilizing data trending and assessing work procedures and work practices. Among other things, they assess appropriateness of station programs in meeting regulations, standards and guidelines. In addition, they apprise station and corporate management of performance problems including identification of underlying causes and timely resolution to problems. Another function of QP&A is the implementation'of the Operation Experience Assessment Program, which includes the coordinated development of corrective actions which are uniform across the six stations.

At the station level, the On-site Regulatory Assurance Department is is under the functional control of the Nuclear Licensing Department which is in QP&A. This control provides consistency in the review of NRC licensing, inspection and enforcement correspondence, the tracking of commitments and evaluation of NRC policies and regulations and their impact on he operating stations.

Another department that impacts on the functions of ISEG is the operational section of the On-site Quality Assurance Group. Like the Department of Nuclear Safety, the Quality Assurance Department is entirely independent of tiie Nuclear Operatior.s area and reports to the AVP of QP&A.

The operational section of the on site Quality Assurance Group at each of the six stations has one in two people licensed at the SR0 level. Hith their knowledge of plant system > aria the technical specifications they are able to perform a knowledgeable independent review and assessment of plant operations.

Since the ISEG is part of the technical specifications, the Quality Assurance Department conducts periodic audits of the ISEG to determine if they are in compliance with the requirements of the applicable section of the Technical Specifications.

The technical specification required functions of the ISEG are not changed by this proposed amendment. Those review items listed in Technical Specification 6.2.3.1 will continue to be reviewed by the ISEG, however, the ISEG will make further use of the corporate level independent review work in performing on-site reviews.

Based on the above information, it has been concluded that the ISEG size could be reduced from four to three people without any loss in meeting the requirements of the technical specifications. Using the material developed by all these other support groups in the Nuclear Operations area as a base, the ISEG can perform their functions in a more effective manner with a lower investment in manhours, and hence fewer people. The option for a lower number'of personnel is permitted under NUREG-0800.

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