ML20062H150

Proposed Tech Specs Re Phoenix-P & Anc Computer Codes

ML20062H150
Person / Time
Site:	Byron, Braidwood
Issue date:	11/28/1990
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20062H148	List: ML20062H145 ML20062H150
References
NUDOCS 9012040122
Download: ML20062H150 (21)

Text

{{#Wiki_filter:' l. ATTACHMENT B PROPOSED CHANGES TO APPENDIX A, TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72 and NPF-77 BIRON STATION BRAIDHOOD STATION Revised Pages: Revised Pages: XX 6-5 6-5 6-5a 6-7 6-7 6-8 6-8 6-9 6-9 6-13 6-13 6-14 6-14 6-21 6-21 /scl:ID635:5 9012040122 901128 PDR ADOCK 05000434 p PDC

NTABLE6.2-1 '( MINIMUM SHIFT CREW COMPOSITION ) IOSITION. NUMBER'0F INDIVIDUALS REQUIRED TO FILL POSITION ') ~ P.0TH UNITS IN BOTH UhiT5 IN ONEvrCT1ht00t1,2,408$ b H0DE 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" AD 3 3 3" STA or SCRE 1 None 1 Shift Supervisor (Shift Engineer) with a Senior Operator ( SE J license Shift Foreman with a Senior Operator li ense ( SF RO Individual with an Operator license Auxiliary Operator ( AO STA Shift Technical Advisor ) SCRE - Station Control Room Engineer with a Senior Operator License ( The Shift Crew Composition may be one less than the minimum requirements of ) l Table 6.2-1 for a period of time not to exceed 2 hours in order to accommodate ( unexpected absence of on-duty shif t crew members provided immediate action is 7 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 shift change due to an oncoming shift crewman being late or absent. During any absence of the Shift Supervisor from the control room while the Unit ) I is in MODE 1, 2, 3 or 4, an individual with a valid Senior Operator license chall be designated to assume the control room command function. During any ( ~ absence of the Shift Supervisor from the control-room while the Unit is-in assume the control room command function. -7 MODE 5 or.6, an individual with a valid Operator license shall be designated to {

1. At least one of the required individuals must be assigned to the designated

/ position for each unit. (

1. 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. [

• Tel: A 2-1 U 1' rcplaue Tavle 0.2-la woen Unii Z icucivc=

( ou vge r a w org E li;: = } { BYRON - UNITS 1 & 2 6-5 )

ADMINISTRATIVE CONTROLS s 0FFSITE (Continued) and investigative tunction, (5) approve and report in a timely manner all findings of non-cMplia."cc with NRC requirc:aents;to the neM Mumh M 9"a+ Station Mcupr. Vice Pras' dent PWR Operations, %ager of QWe, i "':; Pr;;i on;. (;e ) Quality Programs and Assessment,- 'I and the Senior Vice President - Nuclear Operations. During periods when the Superintendent of Offsite Review and Investigative Function is. unavailable, he shall designate this responsibility to an established ) a? ternate, who satisfies the formal training and experience for the Superintendent of the Offsite Review and Investigative Function. The respoi sibilities of the personnel performing this function are stated below. The Offsite Review and Investigative Function shall review: 1) The safety evaluations for: (1) changes to procedures, equip-ment, or systems as described in the safety analysis report, and (2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question. Proposed changes to the Quality Assurance Program description shall be reviewed and approved q -by the Manager of QA/NS; 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; 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 repo'rt findings and recommendations regarding all changes to the Generating Stations Emergency Plan prior to implementation of such change; and L BYRON - UNITS 1 & 2 6-7 '3ENOMENT N0 1 A

-ADMINISTRATIVE CONTROLS OFFSITE (Continued)

10) Review and report findl.$95 and recor. endctions regaroing:

all items referred by the Technical Staff Supervisor, Station Manager, Vice President PWR Operations and Quality Programs , l' and As.n sment. b. Station Audit Function / The station audit function shall be the responsibility of the AYP l Quality Programs and Assessment independent of PWR operations, Such responsibility is delegated to the Nuclear Quality Programs t 7

Manager, g.g man g c

The Nuclear Quality Programs Manage _r?j or designated corporate ~ staff or supervision approved by the AV9 Tuality Programs and Assessment b ~I 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: 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 cr.iteria of Appendix B, 10 CFR Part 50, at least once per 24 months; 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; 8) The Facility Fire Protection programmatic controls including the implementing procedures at least once per 24 mor.ths by qualified QA personnel; 9) The fire protection equipment and program implementation at-least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire pro-tection consultant shall be used at least every third year;

ADMINISTRATIVE CONTROLS OFFSITE (Continued)

10) The Radiologit.al EnvironmentW Manitneing Progron. and tiie iesults thereof'at least once per 12 months; The OFFSITE $GE: CALCULATION MAliUAL and 1r@lementing'proceoures 11)

-at least once per 24 months;

12) The PROCESS CONTROL PROGRAM and implementing procedures for solidification of radioactive wastes at least once per 24 months; and

13) The performance of activities required by the Company Quality Assurance Program for effluent and environmental monitoring at-least once per 12 months.

Report all findings of noncompliance with NRC requirements and recommendations and results of each audit to the Station Manager, _2 l Manager of QA/NS, the Vice President PWR Operations, AYP ualit / Programs and Assessment, the Senior Vice President - Nuclear L Operations, and the Chief Operating Officer. c. Authority The Manager of QA/NS reports to the Chief Executive Officer. The Manager of QA/NS has the authori.ty to order unit shutdown or request C any other action which he deems necessary to avoid unsafe plant j conditions. 6 - il h d E*W M**@ The MVP qua y Programs and Assessmentireports to the Senior Vice 1 President - Nuclear Operations. The AYP Quality Programs and j

Assessment has the authority to recommend unit shutdown or request

( any other action which he deems necessary to avoid unsafe plant ? conditions. All such disagreements shall be reported immediately to [ the Manager of QA/NS and the Chief Operating Officer. 4 BYRON - UNITS 1 & 2 6-9 l

ADMINISTRATIVE CONTROLS ONSITE (Continued) 3) Review of sll proposed changes to the Technical Specifications; 4) . Review of all.propocod changes or m dific4 Lions +.o plant syst es or. equipment that affect nuclear safety; 5) Investigation of all violations of the Technical Specifications including the preparation and forwarding of reperts covering evaluation and recommendations to prevent recurrence; 6) Review of all REPORTABLE EVENTS; 7) Performance of special reviews and investigations and reports thereon as requested by the Superintendent of the Offsite Review and Investigative Function; 8) Review ~of the Station Security Plan and implementing procedures and submittal of recommended changes to the Station Security Plan to the Director of Corporate Security and the Quality ( f with Specification 6.5.2d.1;-Programs and Assessment in lieu of d genedance-. .k 3 9) Review of.the Emergency Plan and station implementing procedures and identification of recomended changes; k

10) Review of Unit operations to detect potential hazards to nuclear safety;

'll) Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation and forwarding of reports d covering evaluation, recommendations and disposition of the 5 corrective action to prevent recurrence;

12) Review of changes to the PROCESS CONTROL PROGRAM, the 0FFSITE DOSE CALCULATION MANUAL, and the Radwaste Treatment Systems; and

13) Review of the Fire Protection Program and implementing instruc-tions and identification of recommended changes.

4 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 maintenance, operation, and administrative procedures relating to facility operations and shall have the authority to request the action necessary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Manager shall' follow such recommendations or select a course 1 BYRON - UNITS 1 & 2 6-13 /

s -ADMINISTRATIVE CONTROLS ONSITE (Continued) . of actior. + hat is mer e f.ur.:crictive re;;arding safe operstion of the ~ m; facility. All such disagreements shall be reported immediately to the Vice President PWR Operations and the,Superintenaent of'the Offsite Review and Iwestigative runction. l d. Records 1) Reports, reviews, investigations,.and recommendations prepared c and performed for Specification 6.5.2b shall be documented with copies to the Vice President PWR Operations, the Superintenden M 7 ( of the Offsite Review and Investigative Function, and the MF 6*% Quality Programs and Assessment, unless otherwise specified. M 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: t 1) . Content and method of submission and presentation to the' Station e Manager, Vice President PWR Operations, and the Superintendent h of'the Offsite Review and Investigative Function, 6 2) Use of committees, 3) -Review and approval, i 4) . Detailed listing of items to be reviewed, 5) Procedures for administration of the quality control activities, and 1 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: 3 ' a) Nuclear power plant technology, b). Reactor operations, rT Reactor engineering, di Chemistry e) Radiological controls, f). Instrumentation and control, and g)- Mechanical and electrical systems. BYRON - UNITS 1 & 2 6-14 AMENOMENT--N0r27,

a.. -...w - J.-.% %- - .L .' T "C ..x.._.-..,,- w, %.. u. a:...- ? cw ~- - - ~ ~ - - - s i ADMINISTRATIVE CONTROLS REPO,qING R,E,0,UIREMENTS (4 nti_nued L ~ " Measuring, Evaluating, and Reporting Radiosctivity in Solid Wutes and - . -- '"<<e Re19ases of Radioactivi. Mnerials in !wid and dacccus C/tiueni., from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof. For solid wastes, the format.for Table 3 in Appendix B shall be supplemented with three additional categories: class of solid wastes (as defined by 10 CFR Part 61), type of container (e.g., LSA, Type A, Type 8, large Quantity), and SOLIDIFICA-TION agent or absorbent (e.g., cement, urea formaldehyde). The Semiannual Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period. L The Semiannual Radioactive Fffluent Release Reports shall include any changes made during the reporting period to the PCP, pursuant to Specifications 6.13, as well as any major changes to Liquid, Gaseous or Solid Radwaste Treat-ment Systems, pursuant to Specification 6.15. The Semiannual: Radioactive Effluent Release Reports shall also include the following: an explanation as to why the inoperability of liquid or gaseous effluent monitoring instrumentation was not corrected within the time specified in Specifications 3.3.3.9.or 3.3.3.10, respectively; and description of the events leading to liquid holdup tanks or gas storage tanks exceeding the limits of. Specification 3.11.1.4 or 3.11.2.6, respectively. 2 MONTHLY OPERATING REPORT 6.9.1.8. Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or RCS safety valves, shall be submitted on a' monthly basis to the Director, Office of Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Regional Administrator of the NRC Regional Office, no later than the 15th of each month'following the calendar month covered by the report. OPERATING LIMITS REPORT / -{ 6.9.1.9 Operating limits shall be established and documented in the OPERATING ) LIMITS. REPORT before each reload cycle or any remaining part of a reload cycle. ( l The analytical methods used to determine the operating limits ^ " " e N gev4~nly rai:,;cd er,d cpprc;cd by tmC ja Teg;s.1 n; pen. !TSR-0015, "L.6 ark / ef W L uiear D 4 n L uive. daisu A ly 100. The operating limits shall be / determined so that all applicable limits (e.g., fuel thermal mechanical limits, k l core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown ) margin,.and transient and accident analysis limits) of the safety analysis are ( _j-met. ~The OPERATING LIMITS REPORT, including an

ments-thereto, shall be providad upon issuance,y mid-cycle revisions or supple-for each reload cycle, to the

( NRC Document Control Desk with copies to the Regional Administrator and Resident ) t Inspector. -+ R ce &WL DYRON - UNITS 1 & 2 6-21 A N0(E,NTNO^26\\ \\

-j nSted i shalI be thr,se previcusi y revi oWod cnd approve by thc NRC in Topical Reports: 1) WCAP C272-P-4 "Westingnouse Reload Saf ety Evaluations Methocology" dated July loe5, 2) j WCAP-SC55 "PcWer Distributton Control and L ad r l 1 :nu n g Procedures" dated Seotember 1974, 3' N T' E R - C '.31 - Ber c hmar k ai PWR Nuclear Design Methods dated July 1993, and/cr 4) ";F 9R - .> 0 8 1, "Denchmirt of FWR Nuclear Design Methods using the CHOEMIX-P and ANC 'omputer Codes" dated July, 1970. t 1 i ) i i e f i f i s I

1 I

) [

ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RE5/0NSIBILITY................................................ 6-1 6.2 ORGANIZATION....................... _.......................... 6-1 FIGURE 6.2-1 (THIS FIGURE NOT USED)............................... 6 ' FIGURE 6.2-2 (THIS FIGURE NOT USED)............................... 6-4 TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION........................ 6-5 T.numm..6_1 Um.TMILM P u.f fT. PR EL.) _vom.hS.P T T. T AM AntP P PAu o mon ,o m m n....................... .f W. 6.3 UNIT STAFF QUALIFICATIONS..................................... 6-6 6.4 TRAINING...................................................... 6-6 n 6.5 REVIEW INVESTIGATION AND AU0IT................................ 6-6 6.5.1 0FFSITE..................................................... 6-7 L Offsite Review and Investigative Function................... 6-7 l Station Audit Function...................................... 4 6-8 IL Authority................................................... 6-9 t' Records..................................................... 6-10 Procedures.................................................. 6 Personnel................................................... 6-10 l 15.5.2. 0NSITE...................................................... L 6-12 Onsite Review and~ Investigative Functions................... u 6-12 Responsibility.............................................. 6-12 Au t h o r i ty................................................... 6-13 Records..................................................... 6-14 Procedures.................................................. 6-14 Personnel................................................... 6-14 6.6 REPO RTAB LE EVENT ACTI0 N....................................... 6-15 BRAIDWOOD - UNITS 1 & 2 XX LAmendment.Nos 16 - s

TABLE 6.2-1 ~ MINIMUM SHIFT CREW COMPOSITION -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 R0 Auxiliary Operator A0 Shift Techni.'al Advisor i STA SCRE - Station control Room Engineer with a Senior Operator License The Shift Crew Composition may be one less than the minimum requirements of Table 6.2-l'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 l unmanned upon shift change due~ to an oncoming shift crewman being le,e or absent.

0uring any absence of. the Shift Supervisor _ from the control room while the Unit

] is in MODE 1,L2, 3 or 4, an individual with a valid Senior Operator license shall be designated 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.
   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 concurreat responsibilities.

• Teble-672-1-wi41-rep) ace-Tabl e-6r2-la-when -Uni t-2-rec el ves-an-operati ng

-license,-

l'E.L.126 Pat /

• TABLE 6.2-la

,i MINIMUM SHIFT CREW COMPOSITION / / POSITION NUMBFR OF INDIVID*JALS REQUIRED.TO FILL POS,ITION MODES 1, 2, 3 & 4 MODES S &.6 SE 1 1/ SF 1 None -A0 2 j'/1 R0 2 1 None SCRE 1 / / or, whenever a SCRE (SRO/STA) is not included in the shift crew composition, the minimum shif t crew shall be a's follows: .l POSITlun NUMBER OF INDIVIOUALS' REQUIRED TO FILL POSITION-MODES 1, 2, 3 & V MODES S & 6 SE 1 1 SF 1 None RO 2 1 1 A0 j2 None STA /1 Shift Superviso/ (Shif t Engineer) with a Senior Operator r SE license on Upit 1 Shift Foreman with a Senior Operator license en Unit 1 SF-Individual /with a Reactor Operator license on Unit 1 R0 ~ Auxiliary' Operator A0 SCRE - Station' Control-Room Engineer with a Senior Reactor Operat'or's License on Unit 1 STA' - Shift Technical Advisor /. The Shift Crew pomposition may be one less than the minimum requirements of Table 6.2-la f,or a period of time not to exceed 2 hours in order to accommodate ur, expected 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-la. :This provision does not permit any shift crew position to be unmanned /upon shift change due to an oncoming shift crewman being late or absent. ./. During'any absence of the Shift Supervisor from the control room while-the Unit is jri MODE 1, 2, 3 or' 4, an, individual with a valid Senior Operator license DuringLany. - shall be designated to. assume the control room command function. absence of the Shift Supervisor from the control room while the Unit.is in < MODE S or 'i, an individual with a valid Operator license shall be designated to assume the control room command function.

• Table 6.2-la will be replaced by Table 6.2-1 when Unit 2 r.ceives an operating license.

f BRAIDWOOO - UNITS 1 & 2 E-Sa

ADMINISTRATIVE CONTROLS 6.5 REVIEW INVESTIGATION AND AUDIT (Continued) 1 OlFSITE 6.5.1 The Superintendent of the Offsite Review and Investigative Function I shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS) responsible for nuclear activities. The corporate audit function shall be the responsibility of the Manager of QA/NS and shall be independent of operations. 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 committee 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. a. Offsite Review and Investigative Function The Superintendent of the Offsite Review and Investigative Function shall: (1) provide directions for the ' review and investigative function and a direction, (2)ppoint a senior participant to provide appropriate 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 rec-ommendations developed by personnel performing the review and inves-tigative Function, (5) approve and report in a timely man.ier all findings of non-compliance with NRC requirements to the Station Manager, ! ~s b " p h (AVP)-Quality Programs and Assessment, and the Senior Vice P 5 /, 1 Aqw / dent - Nuclear Operations. During periods when the Superintendent of m ~' the Offsite Review and Investigative Function is unavailable, he shall designate this responsibility to an established alternate, who satisfies the fomal training and experience for the Superintendent of the Offsite Review and Investigctive Function. The responsibilities of the personnel performing this function are stated below. The Offsite Review and Investigative ~ Function shall review: 1) The safety evaluations for: (1) changes to procedures, equip-ment, or systems as described in the safety analysis report, and (2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question. Proposed changes to the Quality Assurance Program description shall be reviewed and approved by the Manager of QA/NS; ,I 2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defiaed in 10 CFR 50.59; 3) Proposed tests or experiments which involve ". unreviewed safety question as defined in 10 CFR 50.59; 4) Proposed changes in Technical Specifications )r this Operating License; BRAIDWOOD - UNITS 1 & 2 6-7, vAMENOMENT N0;16-

t ADMINISTRATIVE CONTROLS OJFSITE(Continued), 5) Noncompliance with Coaes, regulations, orders, Technical Speci-fications, license requirements, or of internal procedures, or instructions having nuclear safety significance; 6) Significant operating abnormalities or deciatien from normal and expected performance of plant equipment tha; affect nuclear safety as referred to it by the Onsite Review ard Investigative Function; 7) All REFORTABLE EVENTS; 8) All recognized indications of an unanticipated deficiancy in some aspect of design or operation of safety-relatt d structures, systems, or components; 9) Review and report findings and recommenaations regarding all charges to the Generating Stations Emergency Plan prior to-implementation of such change; and

10) Review and report findings and recommendations regarding all items referred by the Technical Staff Supervisor, Station Manager, Vice President PWR Operations, and-AVP-Quality Programs and Assessment, d

?g g b.- Station Audit Function 3_gq The station audit function shall be the-responsibilit'y~ofths~AVNT' q~ Quelity Programs and Assessment independent of the PWR Operations. Suen res Manager.ponsibility is delegated _to_the, Nuclear _ Quality Programs ,mg Wg., ~) The Nuclear Quality Programs NanageFTF'de~sT@iiEeWorporate Staff or Supervision approved by the-AVP-Quality Programs and Assessment shall .. l. _. 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: 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 ;riteria of Appendix 8, 10 CFR Part 50, at least once~per 24 months; BRAIDWOOD - UNITS 1 & 2 6-8 AEN0 MENT-N0d6

l r, 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 leas'. once per 12 months; 7) Onsite and offsite reviews; 8) The Facility Fire Protection programmatic controls including the implementing procedures at least once per 24 months by qualified QA personnel; 9) The fire protection equipment and program implementation at least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent ( fire protection consultant. An outside independent fire pro-L. 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 OFFSITE DOSE CALCULATION MANUAL and implementing procedures 1

i at least once per 24 months; '12) The PROCESS CONTROL PROGRAM and implementing procedures'for solidification of radioactive wastes at =least-once per 24 months;. and

13) The performance of activities required by the Company Quality Assurance Program for effluent and environmental monitoring at least once per 12 months.

Report all findings of noncompliance with NRC requirements and recom-mendations and results of each audit to the< Station Manager, Manager of QA/NS, the Vice President ~PWR Operations,' AVAQuality: Programs and Assessment, the Senior Vice President - Nuclear? Operations, and the ^ Chief Operat. lng Officer, i 'Gmea\\ Map c. Authority ~~ ' ~~~ The Manager of QA/NS reports to the Chief Executive Officer. -The r, Manager of QA/NS has the authority to order unit shutdown or request C t any other action which he deems necessary to avoid unsafe plant . condition ]7; - T ] The-AVP-Quality Programs and Assessmenttreports.to the Senior Vice 5 President - Nuclear Operations. The-AVP-Quality Programs and Assessment has the authority to recomma'.d unit shutdown or request e any other action which he deems necessa y to avoid unsafe plant c conditions. All such disagreements shall be reported immediately to 4. the Manager of QA/NS and t.he Chief Operiting Officer. BRAIDWOOD - UNITS 1 & 2 6-9 LAMENDMENT-NO.-16 % y

' 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 recomendations to prevent recurrence; ,J 6) Review of all REPORTABLE EVENTS; 7) Performance of special reviews and investigations and reports i thereon as requested by the Superintendent of the Offsite Review and Investigative Function; 1 8) Review of the Station Security Plan and implementin and submittal of recomended Security Plan changes g procedures to the Director of Corporate Security and the -Quality Pro Assessment in lieu of distributfort i,ccordanceMith _ grams and - 1 Specification 6.5.2d.1; Gwn y] ~9) Review of the Emergency Plan and' station im and identification of recommended changes; plementing proceduresi

10) Review of Unit operations to detect potential hazards to nuclear safety;.

'll) ! Review of any accidental, unplanned, or uncontrolled radioactive release including the preparatioa and forwarding of reports i . covering evaluation, recommendations and disposition of the corrective action to prevent recurrence; 4

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

- DOSE CALCULATION MANUAL, and the Radwaste-Treatment Systems;

13) Review of the Fire Protection Program and implementing instruc-

.tions and identification of recommended changes. I c.. Authority -The Technical Staff Supervisor is responsible to the Station Manager and shall make recomendations 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-sary to ensure compliance with rules, regulations, and procedures t when in his opinion such action is necessary. The Station Manager shall follow such recomendations or select a course of action that-BRAIDWOOD - UNITS 1 & 2 6-13 JWENDMENT-NO.-16 i

ADMINISTRATIVE CONTROLS ONSITE (Continued) is more conservative regarding safe operation of the facility. All 'such disagreements shall be reported immediately to the Vi e President PWR Operations and the Superintendent of the Offsite P and 4 Investigative Function. d. Records 1) Reports, reviews, investigations, and recommendations prepared and performed for Specification 6.5.2b shall be documented with copies to the Vice President PWR Operations, the Superintendent of the Offsite Review and Investigative Function, and the-AV Quality Programs and Assessment, unless otherwise specified. -2) Copiesof_allrecordsanddocumentationshallbekeptonfile[b.e( ~ at the station, e. Procedures Mwyr Written administrative procedures shall he prepared and maintained for conduct of the Onsite Review and Investigative Function. These procedures shall include the following: + 1) Content and method of submission and presentation to the Station Manager,-Vice President PWR Operations and the Superintendent of- [- the Offsite Review and 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 l . activities,: and 6) Assignment of responsibilities. f. LPersonnel 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 piant technology, b) Reactor operaticas, c) Reactor. engineering, d) Chemistry e) Radiological controls,. f) Instrumentatien and control, and g) Mechanical and electrical systems. BRAIDWOOD - UNITS 1 & 2 6-14 AMENDMENT-N0716-i

ADMINISTRATIVE CONTROLS ~ REPORTING REQUIREMENTS (Continued) " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof. For solid wastes, the format for Table 3 in Appendix B shall be supplemented with three additional categories: class of solid wastes (as defined by 10 CFR Part 61), type of container (e.g., LSA, Type A, Type B, Large Quantity), and SOLIDIFICA-TION agent or absorbent (e.g., cement, urea formaldehyde). The Semiannual Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period. The Semiannual Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PCP, pursuant to Specifications 6.13, as well as any major changes to Liquid, Gaseous or Solid Radwaste Treat- ~ ment Systems, pursuant to Specification 6.15. The Semiannual Radioactive Effluent Release Reports shall also include the following: an explanation as to why the inoperability of liquid or gaseous effluent monitoring instrumentation was not corrected within the time specified in Specifications 3.3.3.9 or 3.3.3.10, respectively; and description of the 'I events leading to liquid holdup tanks or gas storage tanks exceeding the limits of Spec lfication 3.11.1.4 or 3.11.2.6, respectively. MONTHLY OPERATING REPORT 6.9.1.8. Routine reparts of operating statistics and shutdown experience, including documentation of all challenges to the PORVs.or RCS safety valves, shall be' submitted on a_ monthly basis to the Director, Office of Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to.the Regional Administrator of the NRC Regional Office, no later than the 15th of each month following the calendar month covered by the report. OPERATING LIMITS REPORT

6. 9.1. 9 Operating limits shall be established and documented in the OPERATING j

LIMITS REPORT before each reload cycle or any remaining part of a reload cycle. The analytical methods used to determine the operating limits sheH-be-those-(~'$,-previously-reviewed-and-approved-by-NRC-4 n-Topical-Report-NFSR-0016 r " B 1_ (, -of-PWR-Nuclea& design-methods' dated,)uly-1983. The operating limits shall be ) determined so that all applicable limits (e.g., fuel thermal-mechanical limits, 1 acre thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown d l .nargin, and transient and accident analysis limits) of the safety analysis are met. The OPERATING _ LIMITS REPORT, including any mid-cycle revisions or supple-j s ments thereto, shall be provided upon issuance, for each reload cycle, to the I l NRC Document Control Desk with copies to the Reiional Administrator and Resident Inspector, l N 'Rr_hc-c LATA E5eM 1-BRAIDWOOD - UNITS 1 & 2 6-21. -Amendment-Nor15 -

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ATTACHMENT C EVALUATION OF SIGNIFICANT HAZARDS CONS 10ER&Il085 Consnonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment 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 change does not result in a significant increase in the probability or consequences of accidents previously evaluated. The changes are administrative in nature, and as such are not considered in any Chapter 15 analysis. The changes do not affect any administrative process which could -impact the assumptions or results of the analyses. The proposed change does not create the possibility for a new or different . kind of accident from any accident previously evaluated. The proposed changes do not result in the introduction of ar.y new or different equipment, and they will not cause the operation of installed equipment in a new or different manner. The changes will not result in the introduction of any new procedure or process which could create a new or different kind of accident. The proposed change does not involve a significant reduction in margin of safety. Because the changes are purely administrative in nature, no margin of safety is affected. I ' l /scl:ID635:6 l l

ATTACHMENT D ENVIRONMENTAL ASSESSMENT STATEMENT APPLICABILITY REVIEW Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed change meets the criteria for a categorical exclusion as provided for under 10 CFR 51.22(c)(10). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, and the change is aduinistrative in nature, and the change involves no significant hazards considerations. There is no significant increase in individual or cumulative occupational radiation exposure. i l l l l /scl:10635:7 1 _J l}}