ML20052D870

Provides Interpretation of Encl Tech Spec Page 3/4 11-20 for Situations in Which Action Statements Indicate Special Repts.List of Tech Specs Having Similar Wording Encl. Official Position on Reporting Requirements Requested

ML20052D870
Person / Time
Site:	LaSalle
Issue date:	04/29/1982
From:	Schroeder C COMMONWEALTH EDISON CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML20052D871	List: ML20052D870 ML20052D942
References
4014N, NUDOCS 8205070272
Download: ML20052D870 (3)

Text

_

, 'N Commonwealth Edison

, [, ~

) One First N tion:1 Piars. Chicago. tilinois l Addr ss R ply to: Post Offica Box 767

( ,/ Chicago. Illinois S0690 April 29, 1982 s

\.

RECEIVED, p Mr. A. Schwencer, Chie f D MAY S Z 1982 >

Licensing Branch #2 Division of Licensing 3 , g '

E maan nemuc a U. S. Nuclear Regulatory Commission at Washington, DC 20555 g '/

4

Subject:

LaSalle County Station Units 1 and 2 Interpretation o f Technical Specifications - Reporting Requirements when Special Reports are Indicated in Action Statement s NRC Docket Nos. 50-373 and 50-374 Re ference (a): LaSalle County Station License NPF-ll Appendix "A", Technical Specifications.

Dear Mr. Schwencer:

The purpose o f this letter is to provide Commonwealth Edison Company 's interpretation o f the Technical Specification reporting requirements for situation in which a Special Report is indicated in Action Statements. It is requested that you review this interpretation and provide Commonwealth Edison with an o f ficial NHC interpretation o f this subject. LaSalle County Station will continue operations based on the following interpretation until we receive your of ficial position.

There are numerous Technical Specifications which contain action statements such as:

"If the system is not returned to operable within x days, in lieu of any other report required by Specification 6.6.A or 6.6.8, prepare and submit to the Commission within the nex t 30 days, pursuant to Specification 6.6.C, a Special Report outlining certain information. The provisions o f Specifications 3.0.3 and 3.0.4 are not applicable."

Attachment A is a list of examples of specifications that are worded in this fashion. A review o f Attachment A reveals that these are Technical Specifications related to Non-Sa fety Related systems or programs.

Ok 8205070272 820429 ti t

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PDR ADOCK 05000373 p PDR

A. Schwencer April 29, 1982 In various meetings with the NRC Staff over the last several sion that,years, Commonwealth Edison personnel were given the impres-although these systems were not safety-related, the NRC Staf f wanted to assure that they would be operable and generally avullable if required. One method of accomplishing this was to reporting requirements. Special require the writing of a Report in lieu of any other The s ta f f considered such reports "suffi-ciently onerous" as to persuade the licensee to maintain his equipment and programs operable wichout need or justification for limitation of plant operations (thus Specifications 3.0.3 and 3.0.4 are not applicable).

Commonwealth Edison Company interprets this wording to mean

'that, if a system is inoperable but is restored to operation within the is NRC specified required. time period in the action statement, no report to the the specified timeI'period,the system is not returned to operaDie within a Special Report shall be submitted by bpecification 6.6. A or 6 6.B. in lieu of any other report required within the specified timeframe As an example, refer to Specification 3.11.3 (which is enclosed as Attachment B to this letter) . If the radwaste solidi-fication system was inoperable for no report o f any kind would be required. 25 days and returned to service, fication system was inoperable for 32 days, a 30 day time clockIf the radwaste solid a Special Report, pursuant to Specification 6.6.C.would have start contact this o f fice.If there are any further questions in this matter, please letter are provided for your use.One (1) signed original and thirty-nine (39) copi Very truly yours, Y f36/8t,.

C. W. Schroeder

~1m Nuclear Licensing Administrator Attachment cc: _ Resident Inspector - LaSalle 4014N

ATTACHMENT A 3.3.7.2 Seismic Monitoring Instrumentation 3.3.7.3 Meteorological Monitoring Instrumentation 3.3.7.9 Fire Detection Instrumentation 3.3.7.12 Loose-Part Detection System 3.7,5.1 Fire Suppression Water System 3.7.5.2 Deluge and/or Sprinkler System 3.7.5.3 CO2 Systems 3.7.5.4 Fire Hose Stations 3.7.6 Fire Rated Assemblies 3.7.7 Area Temperature Monitoring 3.11.1.2 Radioactive Er#1uents - Dose 3.11.1.3 Liquid Waste Treatment System 3.11.2.2 Dose - Noble Cases 3.11.2.3 Dose - Radioactive 3.11.2.4 Gaseous Radwaste Treatment System 3.11.2.5 Ventilation Exhaus t Treatment System 3.11.3 Solid Radioactive Waste 3.11.4 Total Dose 3.12.1 Radiological Environmental Monitoring Program 3.12.2 Land Use Census 4014N