ML20052F157
| ML20052F157 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/04/1982 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0519, RTR-NUREG-519 3997N, GL-82-02, GL-82-2, NUDOCS 8205120180 | |
| Download: ML20052F157 (3) | |
Text
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s N Commonwealth Edison
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) one Fust National Plaza. Chicago. Ilknois 7 Address Reply to: Post Ofhco Box 767 Chicago, Ilhnois 60690 May 4, 1982 aa e
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Mr.
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Washington, DC 20555 N,r.
Subject:
LaSalle County Station Units 1 and 2 Interpretation of Technical Specifications - Plant Staf f Working Hours NRC Docket Nos. 50-373 and 50-374 References (a):
LaSalle County Station License NPF-11, Appendix A, Technical Specifications, Section 6.1.C.
(D):
NUREG 0519, LaSalle County Station SER, Chapte r 22, Item I.A.l.3.
(c):
D.
G.
Eisenhut letter dated February 8, 1982, " Nuclear Power Plant Staf f Working Hours" ( Generic Le tter No. 82-02).
Dear Mr. Schwencer:
The purpose o f this letter is to provide Commonwealth Edison Company's interpretations o f the Technical Specification requirements regarding staf f working hours (Reference a).
It is requested that you review these interpretations and provide Common-wealth Edison with an of ficial NRC interpretation of this subject.
Item 1, Applicability - Plant Conditions In Re ference (b), the Staf f specifically stated that overtime restrictions applied, (excluding extended periods of shutdown for refueling, major maintenance, or major plant modifications)
The attachment to Reference (c), " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors" sets the tone for the policy in its introductory statement that " Licensees of operating plants and applicants for operating licenses shall esta-blish controls to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe
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condition."
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//O 8205120100 820504 PDR ADOCK 05000373 A
A A. Schwencer May 4, 1982 Based on the above two statements of applicability, Commonwealth Edison Company concludes that the Commission intends for the overtime restrictions to apply when operating personnel ability is required "to keep the reactor in a safe condition."
Thus, Commonwealth Edison Company plans to enforce the limitations on working hours, as described in Technical Specification Section 6.1.C.7, during Operational Conditions 1, 2, and 3.
Item 2, Applicability - Personnel whose working hours are restricted Reference (c) states that, "The controls shall apply to the plant staf f who perform safety-related functions (e.g., senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel).
Similarly, Re ference (a) states that, " Administrative procedures sh811 be developed and implemented to limit the working hours o f unit staf f who perform safety-related functions; e.g.,
senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel."
For clarification purposes, Commonwealth Edison Company has determined that the positions for which these restrictions apply are as follows:
Senior reactor operator - Individuals with SRO fulfilling positions identified in Figure 6.1-3 and its notes.
Reactor operator
- Individuals with R0 license fulfilling positions identified in Figure 6.1-3 and its notes.
Health Physicists
- Individual fulfilling the position designated as health physics technician in Technical Specification Section 6.1.C.2 ( Also known as Rad /
Chem technician in Commonwealth Edison stations)
Auxiliary Operator
- Individuals fulfilling positions identified as Auxiliary Operator ( AO) in Figure 6.1-3 and its notes.
Key Maint. Personnel
- Individuals fulfilling maintenance positions specified in ANSI N18.1 -
1971Property "ANSI code" (as page type) with input value "ANSI N18.1 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as Repairmen or Technicians.
Specifically, the Commonwealth Edison positions are:
Control Systems Technician, "A"
Ins trument Mechanic,
Senior Nuclear Electrician, "A"
Electrician, Senior Nuclear Mechanic, "A" Mechanic.
F 6
A. Schwencer May 4, 1982 The above positions reflect Commonwealth Edison Company 's -
interpretations o f applicability.
It is also our understanding that
-there have been some discussions between Region III personnel and NRR staff in this matter.
The clarifications promised in Reference (c), however, appear to be lacking.
In our view, the record, including the LaSalle County Station SER (Reference (b)), provides no basis for interpreting the LaSalle County Station Technical Specification in a manner other than as indicated in this letter.
Because this new policy has, to the best of our knowledge, been unilaterally imposed at this time at LaSalle, thus obviating poten-tial reference to interpretations at other licensed stations, your prompt response to our request for an official NRC interpretation is all the more important.
If there are any further questions in this matter, please contact this office.
One (1) signed original and thirty-nine (39) copies of this letter are provided for your use.
Very truly yours, s/+/92.
C.
W.
Schroeder Nuclear Licensing Administrator im cc:
NRC Resident Inspector - LSCS V. Stello, Deputy Executive Director, Committee to Review Generic Requirements l
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