ML20246A554

Proposed Tech Specs Revising Number of Members of Onsite Nuclear Safety Group

ML20246A554
Person / Time
Site:	Braidwood
Issue date:	08/14/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20246A552	List: ML20246A550 ML20246A554
References
NUDOCS 8908230013
Download: ML20246A554 (4)

Text

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' ATTACHMENT B PROPOSED CHANGE TO APPENDIX A.

l TECHNICAL SPECIFICATIONS. OF FACILITY OPERATING LICENSES NPF-72 AND NPF-77 .j i

I Revised Page: 6-2 j i

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8908230013 890814 PDR ADOCK 05000456 P PDC I

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' ADMINISTRATIVE CONTROLS UNIT STAFF (Continued) l 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; j

c. A Radiation Protection Technician,* qualified in radiation protection -l[ l 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 l j

to Fuel Handling who has no other concurrent responsibilities during i this operation; l

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 NRC Policy Statement on working hours (Generic Letter No. 82-12);

f. The Assistant Superintendent Operating shall hold a Senior Reactor Operator License. /

6.2.3 ONSITE NUCLEAR SAFETY GROUP (ONSG)

FUNCTION 6.2.3.1 The ONSG serves as au 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 ONSG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, opera-tions activities or other means of improving plant safety to the Safety .P Assessment Manager, and the Station Manager, Braidwood Station. '

COMPOSITION three 6.2.3.2 The ONSG shall be composed of at least 4 ewe, dedicated, full-time engineers located on site.

• The Radiation Protection Technician may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate enexpected

. P' absence provided immediate action is taken to fill the required positions.

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

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. W - ' ' ATTACHMENT C Evaluation of Significant Hazards Consideration Commonwealth Edison has evaluated this proposed amendment.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 significant hazards consideration if operation of.the facility in accordance

' with 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 purpose of this amendment is to reduce the On-site Nuclear Safety Group minimum staffing requirement from four engineers to three engineers.

The proposed amendment will have no effect on the consequences of an accident previously evaluated because it will not involve any physical change-in the plant or. operating procedures. The proposed amendment may have some effect on the probability of an accident previously evaluated since there will be fewer people performing the independent safety assessment function within the On-site Nuclear Safety Group (ONSG). However, any increase in this probability will not be significant and will be compensated for by the activities of several corporate level groups that are independent of the immediate management chain for power production. These groups perform independent assessments of operating characteristics and safety issues that are often redundant to the technical specification responsibilities of the ONSG. This proposed amendment does.not change 0NSG areas of review as described in the-Technical Specifications. The ONSG retains responsibility for review of those items listed in Technical Specification 6.2.3.1, but will make additional use of the independent review-work done by the above noted corporate level groups.

There will be no change in the physical plant or in the way the plant

.is operated. No new accidents are postulated. As a result, operation of the 1 plant in accordance with the proposed amendment will not create the i possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment will not involve any physical change in the margin of safety because there will be no physical change in the plant or change in operation cf the plant. There may be some effect on the margin of safety in terms of the amount of review of operating characteristics and )

safety issues, but this change will not be significant due to the independent  !

assessment activities of-corporate level groups. These groups have j responsibilities that often overlap the technical specification J responsibilities of the ONSG. When performing thei on-site reviews, the ONSG will in create their use of corporate level independent review work performed by new departments.

Based on the preceding discussion, Commonwealth Edison believes this i proposed amendment involves no significant hazards consideration. l

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l-AIIAC!! MENT D EtuflRONMENTAL ASSESSHENT STATEMENI This proposed Amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, Commonwealth Edison believes this Amendment meets the eligibility criteria for

- categorical exclusion set forth in 10 CFR 51.22 (c) (10). Therefore, pursuant to 10 CFR 51.22 (b) no environmental impact statement or environmental assessment is necessary in connection with this proposed amendment.

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