ML20126A748

Amend Applications 124 & 108 to Licenses NPF-10 & NPF-15, Respectively,Consisting of Proposed Change Number 364 to Revise Section 6.0, Administrative Controls & OL Condition 2.E, Physical Security

ML20126A748
Person / Time
Site:	San Onofre
Issue date:	12/16/1992
From:	Ray H SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML13311A310	List: ML20126A748
References
NUDOCS 9212210209
Download: ML20126A748 (39)

Text

1 l

UNITED STATES 0F AMERICA ,

~

NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNI'A Docket No. 50-361 EDISON COMPANY, H AL. for a Class 103 License to Acquire, Possess, and Use a utilization facility as Part of Amendment Application Unit No. 2 of the San Onofre Nuclear No. 124 Generating Station SOUTHERN CAllFORNIA EDISON COMPANY, U AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 124.

This amendment application consists of Proposed Change Number (PCN)-364 to Facility Operating License No. NPF-10. PCN-364 is a request to (1) reflect the latest changes in the Southern California Edison nuclear division organization, (2) incorporate the guidance provided in Generic Letter (GL) 83-43, " Reporting Requirements of 10 CFR Part 50, Sections 50.72 and 50.73 . and Standard Technical Specifications," (3) transfer the Control Room command function from the Shift Superintendent to the Control Room Supervisor and expand the Control Room Area, and (4) make editorial changes to resolve inconsistencies between Units 2 and 3 Section 6.0 Technical Specifications l (TSs). PCN-364 also proposes to 1) revise License Condition 2.E, " Physical

! Security," to delete the specific dates for the revisions to the specified documents, 2) revise TS Section 1.26, " Reportable Occurrences," and the TS Index as a result of Section 6.0 changes, 3) revise the TS Index due to the addition of Table 4.7-2, " Snubber Visual Inspection Interval," and the removal y from'the Index of certain sections which were deleted by previous license-l amendments, 4) delete License Condltions 2.C.(19)a and 2.C.(19)c as the requirements are existing in TSs 6.2.t and 6.2.3, respectively, and 5) delete Section 7.0, "Special Test Program."

I I

l l 9212210209 921216 l: PDR ADOCK 05000361 p PDR-

I l

Subscribed on this /6 TN day of- DEcendEA .1992.

Respectfully submitted, SOUTHERN CALIFORNIA EDIS0N COMPANY By: , ,

V HaroWB. Eay' '

Senior Vice Pre de t State of California -

of Orange County on /,2 / /(,/91 before me, EARBAA'A A. MC CARTHYj/gdrA AY PdB4/G ,

persorfally appeared NAAcLb 8, AMy , personall) known to me to be the person whose name is subscribe Tto the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

WITNESS my hand and official seal.

Signature 48a/ u d . OFRCIAL SEAL .

nuMRA A. MC CARM

\

NoMrY Ptsc Contomio ORANGE COUNTY

, My Commbdon E**es Meuch 31,1995 James A. Beoletto-

. Attorney for Southern California Edison Company By: ,

D g is A.'Be61etto T

i I

UNITED STATES OF AMERICA NUCLGP REGULATORY CMMISSION i

Application of SOUTHERN CALIFORNIA Docket No. 50-362. -I EDIS0N COMPANY, H R. for a Class 103 .

License to Acquire, Possess, and Use I a Utilization Facility as Part of Amendment Application Unit No. 3 of the San Onofre Nuclear No. 108 Generating Station SOUTHERN CALIFORNIA EDISON COMPANY, H R . pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 108.

ThisamendmentapplicationconsistsofProposedChangeNumber(PCN)-364to Facility Operating License No. NPF-15. PCN-364 is a request to (1) reflect the latest changes in the Southern California Edison nuclear division organization, (2) incorporate the guidance provided in Generic Letter (GL) 83-l 43, " Reporting Requirements of 10 CFR Part 50, Sections 50.72 and 50.73, and Standard Technical Specifications,"- (3) transfer the Control Room command function from the Shift Superintendent to the Control Room Supervisor and expand the Control Room Area, and (4) make editorial changes to resolve inconsistencies between Units 2 and 3 Section 6.0 Technical Specifications (TSs). PCN-364 also proposes to revise 1) License Condition 2.E " Physical Security," to delete the- specific dates .for- the revisions to the specified -

documents, 2) TS Section-1.26, " Reportable Occurrences," and the TS Index as a result of Section 6.0 changes, 3) the TS Index due to the addition of Table 4.7-2, " Snubber Visual Inspection Interval," and 4) removal from the index of- - -

certain secticas which were deleted by previous license amendments.

Subscribed on this /f rA -day of- 8Ec.Em BE/L. ,1992.

Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By: .

VHarold 8. rey -[]

Senior Vice Presi Mnt State of California t / (. 9 before me, BAA8AAA A. AfWM personally appeared J /.4 4 b B , g fs V , personally known to

1. me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

WITNESS my hand and official seal. -- -- -

signature k BAR CARIH Notory PutAc Colifono ORMGE COUNTY -

.My ComWen Egese bkuch 31,1995 ,

__m.

l James A. Beoletto Attorney-for Southern California _ Edison Company By:

Ja s A: Teoletto 1 W-l :-

l-l l:

I~

l-

i l

-l ,

i ENCLOSURE 1 PCN-364 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS SECTION 6.0, " ADMINISTRATIVE CONTROLS" 4

4

~ , .

h DESCRIPTION AND SAFETY ANALYSIS 0F PROPOSED CHANGE NPF-10/15-364 This is a request to revise Appendix A, Technical Specifications (TSs) Section 6,0, " Administrative Controls," facility Operating License Condition 2.E TS 1.26, " Reportable Occurrence," and TS index for San Onofre Units 2 and 3.

This is also a request to delete Unit 2 '.icense Conditions 2.C.(19)a, " Station Technical Advisor (l.A.1.1, SSER #1)," 2.C.(19)c, " Independent Safety Engineering Group (1.B.1.2, SSER #1)," and Section 7.0, "Special Test Program."

[xistina License Conditions:

The Unit 2 Facility Operatino License Condition 2.C.(19) Parts a. and c. read:

"Each of the following conditions shall be completed to the satisf action of the NRC. Each item references the related subpart of Section 22 of the SER and/or its tupplements.

a. Shift Technical Advisor (l.A.1.1. SSER #1)

SCE shall provide a fully trained on-shift technical advisor to the shiftsupervisor(watchengineer).

c. Independent Safety Engineerina Group (1.B.1.2. SSER #1)

SCE shall have an on-site independent safety engineering group."

The Units 2 and 3 Facility Operating License Condition 2.E reads:

"E. SCE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: " San Onofre Nuclear-Generating Station, Units 1, 2, and 3 Physical Security Plan," with revisions submitted through April 22, 1988; " San Onofre Nuclear Generating Station, Units 1, 2, and 3 Security force Training and Qualification Plan," with revisions submitted through October 22, 1986; and " San Onofre Nuclear Generating Station, Units 1, 2, and 3 Safeguards Contingency Plan," with revisions submitted through December 29, 1987. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein."

1

Existina Specifications Attachme'At A - Existing Specifications, Unit 2 Attachment B - Existing. Specifications, Unit 3 Proposed License Conditions 1 The Unit 2 Facility Operating License Conditions 2.C.(19)a, " Shift Technical  ;

Advisor (l.A.1.1, SSER #1)," and 2.C.(19)c, " Independent Safety Engineering l Group (1.8.1.2, SSER #1)," are deleted.

The Units 2 and 3 Facility Operating License Condition 2.E is revised to read:

"E. SCE shall fully implement and maintain in ef fect all provisions of l the Comission-approved phyFMal security, guard training and '

qualification, and safegt.ards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR

~

50.54(p). The plans including theirflatestirevisions,-which l contain Safeguards Information protected under~10"CFR 73.21, are entitled: " San Onofre Nuclear Generating Station, Units 1, 2, and 3 Physical Security Plan," wkh revi+1cn: cubmit4ed-through Ape %

M8&t " San Onofre Nuclear Generating Station, Units 1, 2, and 3 Security Force Training and Qualification Plan," with revision; wb-!tted thv0 ugh October 22, M88t and " San Onofre Nuclear Generating Station, Units 1, 2, and 3 Safeguards Contingency Plan."* with revi;ien; subsM4ed-threugh December 29, 1987. -l Change's made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein."

Proposed Soegifir.ations Attachment C - Proposed Specifications, Unit 2 Attachment 0 - Proposed Specifications, Unit 3 References

1. October 15, 1985, letter from J. A. Zwolinski (NRC) to K. P. Baskin (SCE),AmendmentNo.91,

Subject:

Technical Specifications -

Administrative Controls, San Onofre Nuclear Generating Station, Unit 1

2. May 15, 1992, letter from George Kalman (NRC) to Harold B. Ray (SCE).

Amendment No.145,-

Subject:

Issuance of Amendment for the San Onofre Nuclear Generating Station, Unit 1 (TAC Nos. M67932 and M75527)"

2

. . _ _ _ . .. . _ _ _ .. _ . _ . _ _ _ - , _ . . , . - . _ , , ~

DESCRIFTION CHANGES -T0 LICENSE CONDITIONS 2.C.(19)a and 2.C.(19)c Facility Operatin -License Conditions 2.C.(19)a,'" Shift: Technical Advisor I;A.1.1, SSER #1 ." and 2.C.(19)c, " Independent Safety Engineering Group I.B.1.2, SSER #1 ." are deleted from Unit 2. The requirements from both .,*

license conditions are in TSs 6.2.4 and 6.2.3, respectively.

CHANGES TO LICENSE CONDITION 2.E, " Physical Security" The Physical Security Plan, Security Force Training and Qaalification Plan,-

and Safeguards Contingency Plan are constantly revised such that the specific-dates reflected in the existing license condition would not always be the-latest revision of the plans. Therefore, the specific-dates are deleted and the vrbiage revised to make the license condition reflect current revisions to the plans.

CHANGES TO TS SECTION 1.26,'" Reportable Occurrence," AND TS INDEX T3 Section 1.26 and TS index are revised as a result of incorporating in -

Section 6.0 the guidance provided in' Generic Letter (GL) 83-43 " Reporting-Requirements of 10 CFR Part 50, Sections 50.72 and 50.73, and Standard Technical. Specifications." Similar changes related to reporting _ requirements were made to San Onofre Unit 1-and were accepted by the NRC as documented in'-

Reference 1. J Other revisions to the TS index include:-1) the renumbering.of Section 6.0 lpages due to the proposed removal of the-Offsite and Onsite Organization (Figures 6.2-1 and 6.2-2) pa Amendment Nos. 68 and 57, the2)ges which were 4.7-2,:"

deletedSnubber from theVisual TS previously by addition of Table

-Inspection ; Interval," which was inadvertently omitted from the index during.

the license amendment request for Amendment Nos._95 andL85, and 3) the removal of 'certain-TS sections which were deleted previously by Amendment Nos. 83 and - -

-73.

CHANGES TO TS SECTION 6.0, " ADMINISTRATIVE CONTROLS" Organizational Section 6.0:is revised.to reflect the latest changes in-the Southern [

California Edison -(SCE) nuclear organization-and clarify personnel _

- responsibilities within the nuclear organization as a' result of: the-changes.

These organizational changes' increase executive level attention and oversight 1 of nuclear-activities.- Similar changes were made to Unit 11and were acceptedt

.by'the NRC as documented in-Reference 1.

Reporting. Requirements 7

Section:6.0.TS'changesirelated to reporting requirements' incorporate the' guidanceL provided in GL 83-43, '_" Reporting Requirements of 10 CFR Part 50,-

Sections 50.72 and 50.73, and Standard Technical Specifications." Similar.

3-

i l

changes related to reporting requirements were made to San Onofre Unit 1 and  !

were accepted by the NRC as documented in Reference 1. '

The chan}e to Subsection 6.9.1.8, . " Semiannual Radioactive Effluent Release Report," ensures that the report appropriately reflects the quantity of solid radioactive waste that is ultimately shipped to the disposal site.

Other Changes Including Editorial Changes The transfer of the responsibility for the Control Room command function from the Shift Superintendent (SS) to the Control Room Supervisor (CRS) is made to be more consistent with the regulations and the specific duties and responsibilities of the SS and the CRS. Section 6.0 editorial changes are made to provide consistency with Unit 1 ar,d resolve inconsistencies within Unitt 2 and 3.

CHANGES TO TS SECTION 7.0, "SPECIAL TEST PROGRAM" This section specifically permits exceptions to certain TSs affected during the conduct of natural circulation testing. Because the natural circulation testing program was required only during the initial startup testing program and the test was successfully completed, this section is no longer applicable.

BACKGROUND By letter dated Ma'ch 7, 1984, SCE submitted Liccnse Amendment Application Nos. 24 and 10 contisting of PCN-083 for San Onofre Units 2 and 3, respectively. On lay 1, 1984 SCE submitted Amendment Application No. 117 (PCN-130) for San Onofre Unit 1. Both PCN-083 and PCN-130 requested revisions to TS Section 6.0, ' Administrative Controls," to 1) reflect changes in SCE's organizational struc ture, review and approval responsibilities, 2) incorporate the NRC reporting requirements guidance provided in Generic Letter 83-43, and

3) incorporate minor clarifications to Section 6.0 requirements to make the units consistent.

On April 12, 1985, SCE made a combined resubmittal of PCN-083 and PCN-130 and responded to NRC staff auestions on the proposed Section 6.0 changes.

Followup submittals on PSN-083 were made by SCE letters dated August 2,1985, August 15, 1985, and May 3, 1988.

On February 7, 1986, SCE submitted PCN-214 as Amendment Application Nos. 33 and 19 for Units 2 and 3. PCN-214 deleted the Special Report and Licensee Event Report requirements f rom TS 3/4.4.7, " Specific Activity." The Special Reporting requirement was transferred to TS 6.9.1.5 " Annual. Reports." PCN-214 was approved on June 25, 1986, as Amendment Nos. 50 and 39.

On September 13, 1988, SCE made a combined submittal of PCN-273 (Amendment Application Nos. 62 and 48 for Units 2 and 3) and PCN-195 (Amendment Application No. 153 for Unit 1). PCN-273 deleted the organization charts and revised tLe Nuclear Safety Group (NSG) and Independent Safety Engineering Group (ISEG) reporting responsibility in response to GL 88-06, " Removal of 4

Organization Charts from Technical Specification Administrative Control Requirements." PCN-195 deleted the organization charts and revised the NSG reporting responsibility.

PCN-273 specifically revised Section 6.2.1 " Unit Staff," and added subsections 6.2.1.a through 6.2.1.d to establish lines of authority, responsibility, and consnunication from the highest management levels through the intermediate levels to all operating organization personnel. Subsection 6.2.2.g was added to designate positions in the onsite organization that require a Senior Reactor Operator's (SRO) license or a Reactor Operator's (RO) license.

Figures 6.2-1, "Offsite Organization," and 6.2-2, " Unit Organization," were deleted. ISEG-related Sections 6.2.3.4, " Authority," and 6.2.3.5, " Records,"

were revised. Section 6.5.3.6 revised the reporting responsibility of the NSG. Both PCN-273 and PCN-195 were approved on October 18, 1988, as Amendment Nos. 68 and 57 for Units 2 and 3, and Amendment No. 110 for Unit 1, respectively.

On February 14, 1989, SCE submitted PCN-285 as Amendment Application Nos. 77 and 63 for Units 2 and 3, respectively. PCN-285 revised TS 6.2.2.g " Unit Staff," to explicitly require the Assistant Plant Superintendent to maintain a Senior Reactor Operator's license. PCN 285 was approved on Hay 9, 1989, as Amendment Nos. 71 and 59.

By telephone on April 4,1989, WE agreed to withdraw Amendment Application Nos. 24 and 10 (PCN-083) because SCE considered PCN-083 no longer appropriate.

By letter dated April 12, 1989, the NRC informed SCE that the NRC would consider PCN-083 to be withdrawn unless SCE notified the NRC within-10 days that PCN-083 was still valid. By letter dated April 25, 1991, the NRC infonned SCE that PCN-083 was officially withdrawn.

On September 11, 1989, SCE submitted PCN-293 as Amendment Application Nos. 81 and 67 for Units 2 and 3, respectively. PCN-293 requested in part to revise Section 6.0 TS to incorporate the guidance provided in _GL 89-01,

" Implementation of Progransnatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications...or to the -Process Control Program." PCN-293 included changes-to Sections 6.8.4, 6.9.1.6, 6.9.1.7, 6.9.1.9, 6.10.2, 6.13, 6.14, and 6.15.

PCN-293 was approved on January 12, 1990, as Amendment Nos. 83 and 73.

The effort to incorporate numerous changes to Section 6.0, " Administrative Controls," and maintain consistency among Units 1, 2, and 3 has been_a complicated task. The numerous organizational and administrative changes that have:been implemented _at San Onofre and the existing differences among the three units have contributed to the-difficulty-of applying Section 6.0 TS in a consistent manner. To resolve these inconsistencies, a proposed change request is needed.

5

I l

l l

plSCUSSION To facili' tate the review of PCN-364, the affected TS sections and a discussion of each. change are provided below:  ;

CHANGES TO LICENSE CONDITIONS 2.C.(19)a and 2.C.(19)c Facility Operatin License Conditions 2.C.(19)a, "Shif t Technical Advisor (I. A.1.1, SSER #1." and 2.C.(19)c, " Independent Safety Engineering Group :

(I.B.1.2, SSER #1 " are deleted from Unit 2. The-requitements of both license conditions are in TS Sections 6.2.4 and 6.2.3, respectively. These changes make Unit 2 identical to Unit 3.

CHANGES TO LICENSE CONDITION 2.E In the second sentence of the paragraph, the changes are:

After "The alans," " including their latest revisions" is added. This 1.

change makes the license condition accurately reflect- the latest revisions to the plans.

2. The phrase "with revisions submitted through April 22, 1988;" after

" Physical Security Plan," is deleted. The phrase "with revisions submitted through October 22, 1986;" after " Security Force training and Qualification Plan," is deleted. The phrase "with revisions submitted through December 29, 1987;" after " Safeguards continoency Plan," is deleted. Thesephrasesarereplacedbythephrase"includingtheir-latest revisions," as discussed in item 1 above.

3. An "*" is added af ter " Safeguards Contingency Plan," to indicate the part referenced by the existing footnote which reads, "On September 29, 1983, the Safeguards Contingency Plan was made a separate, companion document to the Physical Security Plan pursuant to the authority of 10 CFR 50.54."

CHANGES-TO TS SECTION 1.26 AND TS INDEX TS Section 1.26 The changes are:

1. The TS Sert'on title is changed to " REPORTABLE EVENT" from " REPORTABLE OCCURRENCEJ

2. In the first line of the paragraph, "0CCURRENCE" is changed to " EVENT."

3. In the second line of the paragraph, " Specifications 6.9.1.12.and 6.9.1.13" is changed to "Section 50.73 to 10 CFR Part 50."

l 6

i

The above Section 1.26 changes implement the guidance provided in GL 83-43 which wer.e made to the Unit 1 TSs and were approved by the NRC as documented in Reference 1. These changes-make the units consistent.-

TS Index The changes are:

1. In Page I Section 1.26, "0CCURRENCE" is changed to " EVENT." This change implement the guidance provided in GL 83-43 which.was made to Unit 1 and was approved by the NRC as documented in Reference 1. This change makes the units consistent. l

2. In Page XV for Unit 3 and XVI for Unit 2, the changes are: j

a. Section 6.2.1 "AND ONSITE ORGANIZATION" is added after "0FFSITE."

This change makes the units consistent.

b. For both Units 2 and 3, the page numbers for Sections 6.2.2, " UNIT STAFF," through 6.5.3, " NUCLEAR SAFETY GROUP," are renumbered.

Item 2.b changes are due to the renumbering of TS Section 6.0.

l

3. In Page XVI for Unit 3 and XVII for Unit 2 the changes are:  :

l .

l a. Section 6.6 " REPORTABLE OCCURRENCE ACTION"-is changed to l

" REPORTABLE EVENT ACTION."

i

b. Section 6.9.1 "ROVIINE REPORTS AND REPORTABL2 OCCURRENCES is changed to " ROUTINE REPORTS."

c. " REPORTABLE OCCURRENCES," " PROMPT NOTIFICATION WITH WRITTEN .

FOLLOWUP," and " THIRTY DAY WRITTEN REPORTS" under Section 6.9.1 are deleted.  ;!

L

': Items 3.a through 3.c changes above implement the guidance provided in GL 83-43 which were made to Unit I and were approved by-the NRC as i documented in Reference 1. These changes make the units consistent.

d. Section 6.15 - is deleted from the Index. This section was deleted from the TS previously by Amendment Nos. 83 and 73.

e. For both Units 2 and 3, the page numbers for " AUTHORITY" through Section 6.14. "0FFSITE DOSE CALCULATION MANUAL," are renumbe,ed.

This change.is due to the renumbering of TS Section 6.0.

4. In Page XVIIa for Unit 3 and XXI for Unit 2_the changes are:

a. Figures 6.2-1 and 6.2-2 are deleted from the Index. -These figures-were deleted from the TS previously by Amendment Nos. 68 and 57.  ;

l-I i

l 1 l

l

z

)

l

-J

b. The page location of figure'6.2-3, " Control Room Area," is -

renumbered. This is due to the renumbering of the TS Section 6.0.

c. Figures 5.6-1, 5.6-2, 5.6-3, 5.6-4, and 6.2-3 are relo'cated to the new.Index Page XXII for Unit.2.

5. In.Page XX the changes are:

a. " Table 4.7-2, SNUBBER VISUAL INSPECTION INTERVAL" is added._ This table was implemen_ted by Amendment Nos. 95 and 85~in TS 3/4.7.6,

" Snubbers." However, the corresponding Index for this table was not updated in the license amendment request.-

b. For Unit 3. Tables 4.11-1, 4.11-2, 3.12-1, 3.12-2, and 4.12-1 are deleted from the.Index. For Unit 2. Tables 3.10-1, 4.11-1, 4.11-2, 3.12-1, 3.12-2, and 4.12-1 are deleted from the Index. These _

changes remove the Index reference for TS tables which were deleted previously by. Amendment Nos. 83 and.73,

c. For Unit 2 the page number for Section 6.2-1, " Minimum Shift Crew )

Composition," is changed. This is due to the renumbering of Section 6.0 pages..

CHANGES TO SECTION 6.0, ADMINISTRATIVE CONTROLS ITEM TS Section

1 TS Sections- 6.1.1, 6.5,1.7.b, 6.5.2.1, 6.5.2.3, 6.5.2.4, 6.5.2.5, 6.5.2.6, 6.5.2.7, and 6.5.3.7 In these TS sections, " Station Manager" is replaced with "Vice President and Site Manager, Nuclear Generation Site."

The site management has been re-organized such tiiat the Vice President-and Site Manager, Nuclear Generation Site-is responsible for the overall

- operation and maintenance of the San Onofre Nuclear Generating Site as well as all site support functions. ,

The Station Manager reports directly to the Vice President an'd Site.

Manager, Nuclear Generation Site. The following responsible Nuclear-Division Managers .(Station) report directly to the Station Manager: .

l' Deputy Station Manager 2 Manager.-Chemistry

-3 Manager, Maintenance-4 = Manager,-Operations-5 Manager, Health Physics G Manager, Technical.

F 8 l

. . . ._ , 4 - .- u ,

i I

i The following responsible Nuclear Division Managers (Site) report dire.ctly to the Vice President and Site Manager:

1 Manager, Site Support Services 2 Manager, Nuclear Training 3 Manager, Industrial Relations 4 Manager, Site Security 5 Manager, Site Emergency Preparedness 6 Manager, Site Technical Services The proposed change makes the units consistent and reflects a stronger senior management involvement in nuclear generation site activities.

2 TS Section 6.1.1 The proposed changes are:

! a. As stated in item 1 above, " Station Manager" is replaced with "Vice l

President and Site Manager, Nuclear Generation Site."

b. In the first sentence of the paragraph after 'overall unit operation and," the phrase " maintenance of Units 2 and 3 at the San Onofre Nuclear Generating Site, and all site support functions" is added.

c. In the second sentence "He" is added before "shall delegate."

As discussed in Item 1 above, the Vice President and Site Manager, ,

y Nuclear Generation Site has assumed responsibility for all site support i

functions which allows the Station Manager to focus on the safe l

operation of the generating stations. These changes make the units consistent.

3 TS Section 6.1.2 1

l The proposed changes are:

a. In the first sentence of the paragraph, change " Supervisor" to

" Superintendent," delete "(or durin Room Area, a designated individual)g ,

his"absence

" and change from the Contro Control Room command function" to " ultimate comand decision authority over all unit activities and operations which affect the safety of the plant, site personnel, and/or the general public."

The change from " Supervisor" to " Superintendent" reflects 'the correct position title. The other changes are related to the transfer of the " Control Room command function" from the Shift Superintendent (SS) .to the Control Room Supervisor (CRS) as appropriate. However, the SS is still the senior position in the operating shift crew and has the ultimate command decision authority and responsibility to direct the overall operation of the I

9

unit (s). The SS maintains a broad perspective of the' condition and status.of the plant and ensures the conduct of plant activities

.. will not compromise the health and safety of the operating crew, site 3ersonnel, and the general public. The SS must not be encum>ered with responsibilities to the extent-that his shift l oversight functions will prevent free movement about the plant. In i addition, the duties and responsibilities specified in the Station i Emergency _ Plan direct the attention of the SS to those activities which coordinate site, local, state, and federal agencies response to any accident at the plant which may challenge radiation release boundaries. The SS is required to be onsite at all times when any unit is loaded with fuel. The ultimate comand decision authority-of the Shift Superintendent is in accordance with the Justification for the Provisions of the Rule published in the Federal Register /Vol. 46, No. 133/ Monday, July 11, 1983* Rules and Regulations,10CFR50.54(m)(2)(ii),and10CFR50.47(b)(2),

b. In the second sentence of the paragraph, "Vice President of Nuclear Operations" is changed to "Vice President and Site Manager, Nuclear Generation Site."

The "Vice President of Nuclear Operations" title no longer exists.

As indicated in item 2, the Vice President and Site L.tager is responsible for overall unit operation. The proposen .hange makes '

the units consistent.

c. In the second sentence of the paragraph, " site /" is added before

" station." This change makes the units consistent.

4 TS Section 6.1.3 Add this new TS section to read: "The Control-Room Supervisor (or during his absence from the Control Room Area, a designated individual with a valid SR0 license) shall be responsible for the Control Room command function. The Control Room Supervisor should nomally be present in the Control Room and shall be within the Control Room Area defined in Figure 6.2-3."

This change is made to require the CRS to be responsible for-the Control' Room command function instead of the SS. The position'of CRS at San Onofre meets a portion of the reouirements of 10 CFR'50.54(m)(2)(iii) which states:

"When a nuclear power unit is in an operational mode other than cold shutdown er refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at_ al?

times. In addition'to this senior operator, a licensed operator or senior operator shall be present at the controls at all times..."

10

. - _ _. ~_

The CRS maintains a broad perspective of the condition and status of the l unit,(s) he is assigned to. The CRS provides direction to and assessment of the licensed operator's activities and is not required to be "at the controls,"

described in which 10 CFRis normally(the function of the licensed operator asThe CRS i 50.54(m) 2)(iii).

spent most of the time in the portion of the Control Room where 1) there is direct and prompt access to information on current unit (s) conditions -]

and 2) the CRS can directly supervise and communicate with the operator i at the controls, in accordance with the guidance )rovided in Regulatory l Guide 1.114. However, the CRS should also have tie flexibility to periodically move for a brief period of time to other parts of the control room, but within the Control Room Area defined in Figure 6.2-3, to perfom his designated duties.

The CRS and his normally continuous presence in the Control Room 1) provides the oversight function of a supervisor so that the probability h

of correctly potential detecting adverse abnonnal events consequences early enou5 will be increased, )to mitigate 2 provides the awareness of plant conditions prior to and resulting from an abnormal event so that his extra experience, knowledge, and training . n be used to act ]romptly to mitigate that event, 3) allows the reactor operator to be a)le to direct attention to performing the immediate actions necessary to mitigate that event rather than having to brief the CRS about the background of the event if the CRS was absent from the Control Room, 4) allows the continuous monitoring of the conditions of the unit (s), makes decisions based on those conditions, directs operator actions as appropriate to mitigate the consequences of such event, and 4 provides the SS, who will be acting as the Emergency Coordinator for such an event, updated infonnation on the status of the unit (s) during such an event. Therefore, this change is acceptable.

5 TS Section 6.2 In the section heading "AND ONSITE ORGANIZATION" is added after "0FFSITE." This change makes the units' TSs consistent. ,

6 TS Subsection 5.2.1.c The changes are:

a. In the first and third sentences of the paragraph, " Senior" is added before "Vice President," and " Nuclear Engineering, Safety, and Licensirg" is deleted after "Vice President." These changes reflect the correct position title of the highest level of management in the nuclear organization,

b. In the first and second sentences of the paragraph ", Nuclear Generation Site" is added af ter "Vice President and Site Manager."

This change reflects the correct position title.

11

~7 TS Section 6.2.2 For" Unit 3 only, "The Unit organization shall be as shown in Figure 6.2-2 and:" is-deleted. This-figure was deleted by Unit 2 and 3 Amendment Nos. 68 and 57, respectively. This change makes the units consistent.

8 TS Subsection 6.2.2.e in the second sentence of the paragraph, " Supervisor"-is changed-to

" Superintendent." This change reflects the correct title for the senior position in the operating shift crew at San Onofre.

9 TS Section 6.2.2.f There are no other changes to Section 6.2.2.f except for the renumbered pages and the reserved spaces for the anticipated changes to-this section. The changes to Section 6.2.2.f will be submitted shortly after submittal of PCN-364. ,

10 TS Section 6.2.2.g For Unit 2, the changes are:

a. In the first sentence, add "the Assistant Plant Superintendent-Operations." This change requires the Assistant Plant Superintendent-0pcra.tions to have a Senior Reactor Operator's (SRO)-

license. Consistent with this change, the Assistant Plant "

Superintendents 'or Equipment Control and Operations-Procedures are not required to have an SRO license. Next, change " senior reactor operator" to " Senior Reactor Operator's." This change is.

editorial,

b. In the second sentence, change " reactor operator" to " Reactor Operator's." This change is editorial. Next, add "or Senior Reactor Operator's license" after " license." This _ change .clari fies that the Control Operator or the Assistant Control Operator can

-have a Senior Reactor Operator's license.

For Unit 3, the changes are:

a. In the first sentence, add "-Operations" after " Assistant Plant Superintendent" to clarify only this Assistant Plant Superintendent posi$ ion requires an SR0 license.and that the Assistant Plant Superiritendent positions for i.quipment Control and Operations Procedures do not require SR0 licenses. Next, change'" senior reactor operator' to " Senior Reactor Operator's." This change is l

editorial.

p

b. In the second sentence _ change " reactor operator" to " Reactor l' Operator's." This change is editorial. Next, add "or Senior L Re6ctor Operator's license" after " license." This change clarifies l'

12 i

p

that the Control Operator or the Assistant Control Operator can

,,have a Senior Reactor Operator's license.

11 Two existing " intentionally blank" pages, 6-2 and 6-3 for Unit 2 and 6-3 and 6-4 for Unit 3, are deleted. This change cleans up the TS by removing pages that were deleted by previous amendments. These changes are editorial.

12 TS Section 6.2 - Table 6.2-1 The proposed changes are: .

In the " POSITION" column, "SR0" is changed to "CRS." "R0" is changed to "C0/ACO," and "A0" is changed to "NPEO." These changes reflect the appropriate operating shift crew position titles and make the units consistent. San Onofre uses:

a. Control Room Supervisor (CPS) who holds a Senior Reactor _0perator's (SRO) license for the senior operator in the Control Room.

b. Control Operator (CO)/ Assistant Control Operator (ACO) for the two Reactor Operator (RO) positions required for the minimum shift crew composition. The CD or the AC0 mu:t have a Reactor Operator'.s license but they could have a Senior Reactor Operator's license.

c. Nuclear Plant Equipment Operator (NPE0) who is not required to hold an R0 license. However, an operator with an R0 license is allowed to fill the NPE0 position. Therefore, the "NPE0" position title is more appropriate.

In the explanation of position titles for Table 6.2-1, the changes are:

a. For SS,_" Supervisor"-is changed to " Super _intendent." San Onofre uses the title " Shift Superintendent" for the most senior position in the operating shift crew. This change makes the units consistent.

" Operator" is changed to " Operator's" and " License" is changed to

" license." These changes are editorial.

" San Onofre" is added before " Units 2 and 3." This change makes the units consistent,

b. "SR0" is changed to "CRS" and " Individual" is changed to " Control Room Supervisor" as the title for the senior operator in the Control Room. These changes make the units consistent.

-Next " Operator License" is changed to " Operator's license." This change is editorial.

-13

i Next " San Onofre" is added before " Units 2 and 3." This change

_ makes the units consistent.

c. "R0" is changed to "C0/ACO," and " Individual" is changed to

" Control Operator / Assistant Control Operator. Then " Operator License" is changed to " Operator's license" and, "or a Senior Reactor Operator's license" is added af ter " Operator's license."

The two Reactor Operator (RO) positions required for the minimum shift crew at San Onofre are filled by a " Control Operator (CO)/

Assistant Control Operator (ACO)." The CO or ACO must have a Reactor Operator's license, but the C0 or ACO could have a Senior Reactor Operator's license.

Next, " San Onofre" is added before " Units 2 and 3." This change makes the units consistent.

d. "A0" is changed to "NPEO," and " Auxiliary Operator" is changed to

" Nuclear Plant Equipment Operator (Reactor Operator's license not required)."

San Onofre uses NPE0 as the title for the additional operators required for the minimum shift crew. This change makes the Units consistent.

e. In the first and second paragraphs of proposed page 6-6,

" Supervisor" after "Shif t" is changed to " Superintendent." This change reflects the correct position title for the most senior position in the operating shift crew.

13 Figure 6.2 Control Room Area This change adds the Operations Support Office, a washroom facility for the male operating crew (the existing washroom is designated for the female operating crew), lunch room, kitchen, Unit 2 and Unit 3 computer rooms, and the turbine laboratory to the boundary of the " Control Room Area" in Figure 6.2-3. This change allors the Control Room Supervisor, who holds the Control Room command function and normally remains in the Control Room, to have the flexibility to tccess the operations support staff, technical materials area, comfort areas, and other areas required to monitor unit operations for a brief period of time. Therefore, it is appropriate that these rooms be part of the " Control Room Area" in Figure 6.2-3.

14 TS Section 6.2.4 In the first sentence of the paragraph, " Supervisor" af ter " Shift" is changed to " Superintendent." This change is consistent with the proposed change to TS Section 6.1.2 above.

14

I i

15 TS Section 6.4 l 1

The" changes are:  !

a. Section 6.4.1 - In the paragraph, " Appendix A of" is deleted. This change is appropriate because Appendix A was deleted from 10 CFR Part 55.

b. Section 6.4.2 - This new section "A training program for the Fire brigade shall be maintained by the direction of the Manager, Site Emergency Preparedness and shall meet or exceed the requirements of National Fire Protection Association Standard No. 27-1975. This change makes Units 2 and 3 consistent with Unit 1.

16 TS Section 6.5.1.2 The changes are:

a. " Supervisor of" before " Chemistry "is replaced with "Hanager."

This change reflects the new position title of the head of Chemistry,

b. "Hanager/" is added before " Supervising Engineer." Also (NSSS.

NSSSSupport, Computer,orSTA"isreplacedwith"(NuclearSystems Engineering, Electrical Systems Engineering, or Power Generation)."

This change reflects the recent reorganization of the Station -

Technical Division.

17 TS Section 6.5.1.6 The changes in this section are:

a. Subsection 6.5.1.6.b " Review of events requiring 24-hour written notification to the Commission" is changed to " Review of all REPORTABLE EVENTS." This change incorporates the guidance provided in Generic Letter 83-43, related to reporting requirements. A~

similar change was made to Unit 1 TS and was -accepted by the NRC as documented in Reference 1.

b. Subsection 6.5.1.6.d " Supervisor" is added after "NSG." This change reflects the correct position title.

18 TS Section 6.5.1.7 The changes in this section are:

a. Subsection 6.5.1.7.a "6.5.1.6(a)" is changed to "6.5.1.6.a."

This change is editorial.

l 15-

b. Subsection 6.5.1.7.b - In the first line of the paragraph, "Hanager of Nuclear Operations" is changed to "Vice President and Site Manager, Nuclear Generation Site." In the third line, "the" is-added before "NSG" and " Supervisor" is added af ter "NSG." In the fourth line, " Station Manager" is changed to "Vice President and Site Manager, Nuclear Generation Site" as stated in Item 1..

The above changes reflect the correct position titles.

19 TS Section 6.5.1.8  !

The changes are:

a. In the first sentence of the paragraph, " technical specifications" '

is capitalized and reads " Technical Specifications." This change is editorial.

b. In the second sentence, " Supervisor" is added after " Nuclear Safety Group." This change reflects the position title instead of the organization title.

20 TS Section 6.5.2.1 The changes are:

a. In the first sentence of the paragraph, " Station Manager" is changed to "Vice President and Site Manager, Nuclear Generation Site" as stated in Item 1. This change reflects the correct position title. This change was made to Unit 1 and was accepted by the NRC as documented in Reference 1.

b. " Documentation of these activities shall be provided to the NSG Supervisor"isaddedasthelastsentenceoftheparagraph. Except for the word " Supervisor," this change was made to Unit 1 and was accepted by the NRC as documented in Reference 1.

21 TS Sections 6.5.2.2 and 6.5.2.3 The changes are:

a. In both TSs " Documentation of these activities shall be provided to the Vice President and Site Manager, Nuclear Generation Site and to the NSG Supervisor" is added as the last sentence. Except for the:

. word " Supervisor" after "NSG," this change was made to Unit 1 and was accepted by the NRC as documented in Reference 1.

b. In Section 6.5.2.3 " Station Manager" is changed to "Vice President and Site Manager, Station. Generation Site" as stated in Item 1.

This change makes the units consistent.

16

22 TS Section 6.5.2.4 The" changes are:

a. In the first sentence of the paragraph, " station supervisory"  !

before " staff" is replaced with " nuclear division management." l Next, " Station Manager" is changed to "Vice President and Site Manager, Nuclear Generation Site." These changes allow other members of the nuclear division management staff, who are not members of the station management staff and do not report directly  ;

to the Vice President and Site Manager, to be responsible for Specifications 6.5.2.1 through 6.5.2.3 reviews as they have been previously designated by the Vice President and Site Manager,

b. In the second sentence, "and a verification that the proposed actions do not constitute an unreviewed safety question." is added.

This change makes the units consistent.

23 TS Section 6.5.2.5 The changes are:

a. In the first sentence of the paragraph "the Manager, Technical, the Manager, Operations, the Manager, Maintenance, the Deputy Station Manager or the Manager, Health Physics as" is replaced with "or members of the nuclear division management staff." Next, " Station Manager" is changed to "Vice President and Site Manager, Nuclear Generatian Site."

These changes allow other members of the nuclear division management staff or designees, who are not members of the station management staff and do not report directly to the Station Manager or the Vice President and Site Manager, to )erform reviews of proposed tests and experiments as long as t1ey are previously designated by the Vice President and Site Manager. These changes require that reviewers shall be nuclear division manager level position or their designated alternates be fonnally designated by the most senior management at the site (the Vice President and Site Manager,NuclearGenerationSite).

b. " Documentation of these activities shall be provided to the Vice President and Site Manager, Nuclear Generation Site and the NSG Supervisor" is added as the second sentence of the paragraph.

Except for the word " Supervisor" after "NSG," this change was made to Unit I and was accepted by the NRC as documented in Reference 1.

17

24 TS Section 6.5.2.6 The" changes are:

a. In the first sentence of the paragra)h, " station" is changed to

" Site," because " Site" encompasses tie station, and is therefore more appropriate than " station." Also, the Manager Site Security reports to the Vice President and Site Manager, Nuclear Generation Site. Therefore, the use of " Site" correctly reflects the reporting responsibilities within the existing organization.

Also, " security program" is changed to " Security Plan." The Site Security Plan is a distinct and separate document with its own implementing procedures. This change distinguishes the Site Security Plan from the general security program for the site,

b. In the second sentence "to the Site Security Plan" is added after

" Recommended changes." " Station Manager" is replaced with "Vice President and Site Manager, Nuclear Generation Site."

Next, after "and transmitted," the phrase "to the Manager of Nuclear Operations and" is deleted. The position " Manager of Nuclear Operations" no longer exists and the Manager, Site Security now reports to the Vice President and Site Manager, Nuclear Generation Site, who is the most senior management level at the site. Therefore, approved changes to the Site Security Plan are transmitted to the NSG Supervisor only.

The responsibility for approval of recommended changes to the Site Security Plan has been shifted from the Station Manager to the Vice President and Site Manager, Nuclear Generation Site. The Manager, Site Security has primary responsibility for Site Security Plan implementing procedures. These changes correctly reflect the responsibilities within the organization.

" Supervisor" is added after "NSG." This change reflects the position title instead of the organization title.

c. To define the preparation and approval process for implementing procedures, the phrase "; implementing procedures shall be prepared and approved in accordance with Specification 6.8." is added as the last sentence of the paragraph. This change makes the units consistent.

25 TS Section 6.5.2.7 The changes are:

a. In the first sentence of the paragraph, " station" is changed to

" Site," because " Site" encompasses the station, and is therefore more appropriate than " station." Also, the Manager, Site Emergency 18 I

i Preparedness, reports to the Vice President and Site Manager,  !

.. Nuclear Generation Site. Therefore, the use of " Site" correctly ref.lects the reporting responsibilities within the existing _

organization.

Next " emergency plan" is changed to " Emergency Plan." This change is editorial,

b. In the second sentence "to the site Emergency Plan" is added after

" Recommended changes." This change is editorial.

" Station Manager" is .eplaced with "Vice President and Site Manager, Nuclear Generation Site." This change is due to the transfer of responsibility.

Next, after "and transmitted," the phrase "to the Manager of Nuclear Operations and" is deleted. The position title "Hanager of Nuclear Operations" no longer exists and the Site Emergency Preparedness now reports to the Vice President and Site Manager, Nuclear Generation Site who is the most senior management level at the site. Therefore, approved changes to the Site Emergency Plan are transmitted to the NSG Supervisor only.

The responsibility for approval-of changes to the Site Emergency Plan has been shifted from the Station Manager to the Vice President and Site Manager, Nuclear Generation Site. The Manager, Site' Emergency Preparedness has primary responsibility for the Site Emergency _ Plan implementing procedures. This change correctly l

reflects the respon;ibilities within the existing organization.

l l

Next " Supervisor" is added after "NSG." This change reflects the '

position title instead of the organization. title,

c. To define the preparation and approval process for implementing procedures, the phrase "; implementing Procedures shall be prepared and approved in accordance with Specification 6.8" is added as the last sentence of the paragraph. This change makes the units consistent.

L 26 TS Section 6.5.2.8

! The changes are:

a. In the second line of the paragraph, " uncontrolled or" is inserted between "every" and " unplanned." This change makes the units I consistent,

b. In the fifth line, "Hanager of Nuclear Operations" is changed to-

"Vice President and Site Manager, Nuclear Generation Site;". This

-change reflects the correct position title.

l 19 l

Also "to the Station Manager;" is added. This change is similar to that requested for Unit 1 and was approved by the NRC as

- documented in Reference 2.

c. In the sixth line, " Supervisor" is added after "NSG." This change reflects the position title.

27 TS Section 6.5.2.9 The changes are:

a. In the second line of the paragraph, "and may designate the approval" is added after " individual / organization." This change makes the units consinent.

b. In the fourth line, " Documentation of these activities shall be provided to the Vice President and Site Manager, Nuclear Generation Site; to the Station Manager; and to the NSG Supervisor." This change is similar to that requested for Unit 1 and was approved by the NRC as documented in Reference 2.

28 TS Section 6.5.2.10

a. In the first sentence of the paragraph, " Reports documenting" is <

deleted and replaced with " Documentation of." This change is editorial and makes the units' consistent.

Next, "in accordance with Specification 6.10" is added after "shall be maintained." This provides a reference to clarify how long the documentation for Specifications 6.5.2.1 through 6.5.2.9 are maintained.

b. The'last sentence " Copies shall be provided to the Manager of Nuclear Operations and the Nuclear Safety Group" is deleted. The requirements for documentation are now described in each of Sections 6.5.2.1 through 6.5.2.9. Therefore, this last sentence is no longer required. This change makes the units consistent.

29 TS Section 6.5.3.2 The changes are:

a. "The" is added to start the first sentence of the paragraph. This change makes the units consistent.

For Unit 2 "six" is changed to "6" 'n the second sentence and "five" is changed to "5 in the third sentence. These changes are editorial and make the units consistent.

b. In the first sentence of the second paragraph, "6.5.2.1" is changed to "6.5.3.1." TS 6.5.3.1, not TS 6.5.2.1, describes the areas for l 20 L

l

which NSG is responsible to provide reviews. This change is

,, editorial.

30 TS Section 6.5.3.4 The changes are:

a. Subsection 6.5.3.4.a - In the third line of the paragraph,

" provision" is made plural to read " provisions." This change is editorial and makes the units consistent.

b. Subsection 6.5.3.4.g " Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission" is deleted and replaced with "All REPORTABLE EVENTS." This change incorporates the guidance provided in Generic Letter 83-43 and makes the units consistent.

This change was made to Unit 1 and was accepted by the NRC as documented in Reference 1.

c. Subsection 6.5.3.4.1 " meetings" before " minutes" is made singular to " meeting." This change is editorial.

31 TS Section 6.5.3.5 The changes are:

a. Subsection 6.5.3.5.d - In the first line of the paragraph,

" Operational" before " Quality Assurance Program" is deleted. This change reflects the correct title for the SCE Quality Assurance Program. This change makes the units consistent.

b. Subsection 6.5.3.5.e - In the second line of the paragraph,

" Supervisor" is added af ter " Nuclear Safety Group.* -This change reflects the correct position title.

" Manager of Nuclear Operations" is replaced with "the Vice President and Site Manager, Nuclear Generation Site." This change reflects the correct position title and makes the units con-istent.

c. Subsection 6.5.3.5.h - Beginning in the second line of the paragraph, "an outside qualified" is changed to "a qualified outside," and "3 years" is thanged to "36 months." These editorial changes make the units consi d ent.

32 TS Section 6.5.3.7 The chang are:

It ite second line of the paragraph, " Station Manager" is replaced with "Vice President and Site Manager, Nuclear Generation Site." This change makes the units consistent.

21

l l

33 15 Sections 6.6, 6.6.1, and Subsection 6.6.1.b The" changes are:

l

a. Section 6.6 "0CCURRENCE" is replaced with " EVENT."

1

b. Section 6.6.1 "0CCURRENCES" is changed to " EVENTS."

I The changes above are consistent with the guidance provided in Generic Letter 83-43 and make the units consistent. These changes were made to Unit 1 and were accepted by the NRC as documented in Reference 1.

c. Subsection 6.6.1.a - In the first line of the paragra >h, "and/or" is changed to "and." This change is editorial and maces the units i consistent.

In the second line " Specification 6.9" is changed to "Section 50.73, 10 CFR Part 50, and." This change is consistent with the guidance provided in Generic Letter 83-43 and makes the units consistent. This change was made to Unit I and was accepted by the NRC as documented in Reference 1.

d. Subsection 6.6.1.b - In the first line of the paragraph, "0CCURRENCE requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission" is replaced with " EVENT " This change is consistent with the guidance provided in Generic letter 83-43 and-makes the units consistent. This change was made to Unit I and was accepted by the NRC as documented in Reference 1.

In the second line. "the results of this review shall be" is added before " submitted." This change makes the units consistent.

In the third line, "to the Vice President and Site Manager, Nuclear Generation Site and" is added af ter " submitted." This change reflects a high level of management involvement in nuclear activity oversight and makes the units consistent.

in the fourth line " Supervisor" is added af ter "NSG." This change reflects the correct position title. Next "and the Manager of Nuclear Operations" is deleted because the position no longer exists.

34 TS Subsection 6.7.1.a The changes are:

In the second sentence of the paragraph, " Manager of Nuclear Operations" is replaced with "Vice President and Site Manager, Nuclear Generation.

Site." This change makes the units consistent.

" Chairman" is replaced with " Supervisor." This change reflects the correct position title.

22 t

35 TS Subsection 6.7.1.c The changes are:

a. In the second line of the paragraph, "Hanager of Nuclear Operations" is deleted and replaced with "Vice President and Site Manager, Nuclear Generation Site." This change reflects the correct position title,

b. In the third line " Supervisor" is added after "NSG." This change reflect the correct position title.

36 TS Section 6.8 The changes are:

a. Subsection 6.8.1.g - The footnote symbol "*" after " implementation" and the corresponding footnote "* See Specification 6.13.1" is deleted.

The footnote referencing the associated TS is inconsistent with the format used throughout Units 2 and 3 TS 6.8.1 (e.g., "6.8.1.d.

Security Plan," "6.8.1.e. Emergency Plan," and "6.8.1.h Offsite .

DoseCalculationManual,"etc.arenotfootnoted). These changes make the units consistent.

b. Subsection 6.8.1.1 in the second line of the paragraph, " Regulatory Guide 4.15 Rev.

1," is changed to " Regulatory Guide 4.15, Revision 1,". This change is editorial and makes the units consistent.

37 TS Section 6.8.2 The changes are:

a. Beginning in the second line of the paragraph, "the Vice President and Site Manager, Nuclear Generation Site or by;" is added after "

approved by." This change makes the units consistent.

b. "(1) the Deputy Station Manager, i After"StationManager;orby,")theManager, (2) the Manager Operations, (3 Maintenance,(4)the Manager, Technical, or (S) the Manager, Health Physics" is replaced with "the responsible Nuclear Division Manager: or by their designees." Nuclear Division Managers include division managers reporting to the Station Manager, the Vice President and Site Manager, and the Senior Vice President. ,

This change allows nuclear division managers or designees to approve procedures and changes to 3rocedures in their specific area and unit of responsibility where taey have been previously 23

designated by the Vice President and Site Manager, Nuclear Generation Site.

c. In line six of the paragraph, " Station Manager;" is changed to "Vice President and Site Manager, Nuclear Generation Site." This change reflects the correct position title.

38 TS Section 6.8.3 The changes are:

a. Subsection 6.8.3.b - in the first line of the paragraph, " plant" is replaced with " nuclear division." Also, " exercising responsibility in the specific area and unit or units addressed by the change, and" is added after " staff."

These changes allow nuclear division management staff, that do not report directly to the Station Manager or Vice President and Site Manager, Nuclear Generation Site to approve temporary changes to procedures in their specific area and unit or units of responsibility. At least one of the two individuals approving the temporary change holds a valid (active or inactive) Senior Reactor Operator's (SR0's) license on the unit affected. SR0s with active licenses are those individuals who are fully licensed on Units 2 and 3 and are members of the Minimum Shift Crew Composition in TS Table 6.2-1. SR0s with inactive licenses are those individuals who are fully licensed on Units 2 and 3 and attend 100% requalification training but are not members of t'e Minimum Shift Crew Composition.

! In the last line of the paragraph, " License" is changed to lower case and reads " license." This change is editorial.

! b. Subsection 6.8.3.c

" Station Manager; or by (1) the Deputy Station Manager, (2) the Manager, Operations,(3)theManager, Maintenance,(4)theManager, Technical, or (5) the Manager, Health Physics' is replaced with

" responsible nuclear division management staff." Then "previously" before, and "by the Station Manager" af ter " designated," are deleted and "in accordance with 6.8.2 above" is added before "within 14 days."

The existing TS 6.8.3.c lists 5 nuclear division managers reporting to the Station Manager who are authorized to review and approved temporary changes to procedures. The specific list will be replaced with " responsible nuclear division management staff."

l These change allows other nuclear division management staff that do not report directly to the Station Manager or the Vice President l and Site Manager, Nuclear Generation Site, e.g., Nuclear Construction Manager, Nuclear Engineering Design Organization Manager, Manager of Nuclear Regulatory Affairs, etc., to approve 1

24 l

procedures and changes to procedures in their specific area and

,, unit of responsibility.

Next, the 15 references Specification 6.8.2 for the individuals responsible for the reviews.

39 TS Section 6.8.4 The changes are:

a. Subsection 6.8.4.b - for Unit 2 only, the "*" following " program" in lines 1 and 3 and the corresponding footnote "* Not required to be implemented until September 1, 1983" are deleted. This change is a)propriate because the In-Plant Radiation Honitoring Program has )een implemented. These changes make the units consistent.

b. Subsections 6.8.4.c.(i) and 6.8.4.c(li) - in these TSs, " variables" is changed to " parameters." This change makes the units consistent.

c. Subsection 6.8.4.c.(iii) - The text " including monitoring the discharge of condensate pumps for evidence of condenser in-leakage" is deleted because the program describes the appropriate indication of sampling points. This change makes the units consistent.

d. Subsection 6.8.4.d - In the first and second sentcnces the "*" on

" program" is deleted and the footnote "* Not required to be implemented until September 1, 1983" is deleted. Because the Post Accident Sampling Program has been implemented, this footnote is no longer appropriate. This change makes the units consistent.

The text for this TS is revised for format consistency as shown:

"A program which will ensure... containment atmosphere samples under accident conditions. The program shall include:

(i) Training of personnel, (ii) Procedures for sampling and analysis, and (iii) Provisions for maintenance of sampling and analysis equipment."

This change is editorial and makes the units consistent.

40 TS Section 6.9 The changes are:

a. in the sub-title, "AND REPORTABt.E OCCURRENCES" is deleted. The revised sub-title now reads " ROUTINE REPORTS." This change is >

25 1

3 l

1 I

m.sistent with the guidance in Generic Letter 83-43. This change was made to Unit 1 and was accepted by the NRC as documented in

Reference 1. This change makes the units consistent.

b. Section 6.9.1 - Beginning in the second line of the paragraph, "U.

S. Nuclear Regulatory Commission, Attention: Document Control Desk.

Washington, D.C. 20555 with a copy to the" is added. In the fourth line, "NRC" before " Regional Administrator" is deleted and "of the Regional Office of the NRC" is added after " Regional Administrator".

These changes reflect the current NRC addressee for routine reports una r Section 6.9.1.

c. Subsection 6.9.1.4 - The last sentence, "The initial report shall be submitted prior to March 1 of the year following initial criticality" is deleted. This change is made because both Units 2 and 3 have long surpassed initial criticality. Therefore, the requirement is no longer appropriate.

d. Subsection 6.9.1.5 - In the second sentence of the second paragra>h for both Units 2 and 3 TSs, "the" is added before " limit." For tie Unit 2 TS, " exceed" is changed to " exceeded." For both Units 2 and 3 TSs, "the" is added after "less than." In the third sentence for the Unit 2 TS, "the" af ter "(5)" is capitalized to "The." These changes are editorial and make the units consistent,

e. Stbsection 6.9.1.8 - In the second sentence of the paragraph "and solid waste" is deleted. Next, a new third sentence is added which reads "The report shall also include a summary of the quantities of solid radioactive waste shipped from the unit directly to the disposal site and the quantities of solid radioactive waste shipped from the unit's intermediary processor to the disposal site."

Both industry goals and utility practices acknowledge the common practice of solid radioactive waste volume reduction. Offsite volume reduction is merely an extension of the utility's radioactive waste processing capabilities. The final volume shipped to a disposal site is reported in the Semiannual Radioactive Effluent Release Report (SRERR). One aspect of the unit's performance is evaluated on the volume of solid radioactive waste received by a dis >osal operator. Because solid radioactive waste is often reduced )y a factor of 100, it is the quantity of solid radioactive waste after reduction by an intermediary processor that should be reported in the SRERR. This change ensures the SRERR reports the quantities of solid radioactive waste tnat are ultimately shipped to the disposal site.

f. Subsection 6.9.1.10 - In the second line of the first )aragraph,

" pressurizer" is added before " safety valves." This c1ange clarifies the valve challenges to be reported in the Monthly Operating Report. This change is consistent with the intent of the 26

Standad Technical Specifications.

" In the third line of the same paragraph, " Director Office of ,

Resource Hanagement," is deleted. " Attention: Document Control Desk," is added af ter "U. S. Nuclear Regulatory Comission." This change corrects the NRC addressee for the Monthly Operating Report.

The second paragraph of 6.9.1.10, which concerns the submittal with the Monthly Operating Report (MOR) of change (s) to the ODCM or major changes to the radioactive waste treatment systems, is deleted. The ODCH reporting duplicates TS 6.14 which require, ODCH change (s) to be submitted with or concurrent to the submittal of the Semiannual Radioactive Effluent Relea:,e Report. The radioactive waste treatment system reporting also duplicates ODCM Section 6.3, "Hajor Changes to Radioactive Waste Treatment Systcris (LiquidsandGases)." The radioactive waste treatment system reporting was deleted from Section 6.0 TS by Amendment Nos. 83 and 73 for Units 2 and 3, respectively, and relocated to the administrative section of the ODCH as permitted by Generic letter 89-01. This change makes the units consistent,

g. Subsections 6.9.1.11, 6.9.1.12, and 6.9.1.13 These TS subsections " REPORTABLE OCCURRENCES, " PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP," and " THIRTY DAY WRITTEN REPORTS,"

respectively, are deleted.

These changes are consistent with the guidance provided in Generic Letter 83-43. These changes were made to the Unit 1 TS and were accepted by the NRC as documented in Reference 1.

h. Section 6.9.2 - In the first line of the paragraph " reports" is capitalized and reads " Reports." This change is editorial.

"U. S. Nuclear Regulatory Commission, Attention: Document Control Desk, Washington, D.C. 20555, with a copy to the" is added after "to the." "NRC" before " Regional Administrator" is deleted and "of the Regional Office,of the NRC," is added after " Regional Administrator." These changes correct the NRC addressee for Special Reports.

41 TS Section 6.10 The changes are:

a. Subsection 6.10.1.c "0CCURRENCES" after " REPORTABLE" is changed to " EVENTS." This change is consistent with the guidance provided in Generic Letter 83-43. This change was made to the Unit 1 TS and was accepted by the NRC as documented in Reference 1.

57 i

l

b. Subsection 6.10.1.d After " activities" replace ";" with ",". I

,,This change is editorial.  !

c. Subsection 6.10.2.i - After "QA Manual" "not included in Specification 6.10.1" is added. This change ensures only records of activities required by the QA Manual that are not covered under 6.10.1 be retained for the duration pursuant to this specification,

d. Subsection 6.10.2.k "0SRC" is added before " meetings" and "of the OSRC" is deleted. Next, "the" before "NSG" is deleted and

" reports" is added after "NSG." These changes make the units consistent.

42 TS Subsection 6.12.2 The changes are:

a. In the first sentence of the paragraph, " Supervisor" is changed to

" Superintendent." This change makes the units consistent.

b. In the third sentence, " " is added after " posted" and "unless a health physics technician is in continuous attendance," is added before "a flashing light." The existing TS requires areas accessible to personnel where a major portion of the body could receive a 1,000 mrem dose in one hour and no enclosure for locking aurposes exists and no enclosure can be reasonably constructed, to ae roped off, conspicuously posted, and a flashing light activated as a warning device.

This change allows the use of flashing lights or the continuous attendance of a health physics technician to identify areas where dose rates are in excess of 1000 mrem / hour. A health physics technician would be in continuous attendance only when the greater than 1000 mrem /hr dose rates would be temporary or the flashing light would not be working. A similar change was requested for Unit 1 and was approved by the NRC on August 11, 1982 as Amendment No. 61. This change makes the units consistent.

43 TS Section 6.13 The changes are:

a. Subsection 6.13.2.1 - In the first sentence, "6.10.2n." is changed to "6.10.2.n." This change is editorial.

A second sentence which reads "This documentation shall contain:"

is added to the paragraph. This change is editorial.

b. Subsection 6.13.2.1.b - At the end of the paragraph, "." 13 deleted and "; and" is added. This change is editorial and makes the units consistent.

28 l

l

c. Subsection 6.13.2.2 " acceptance" is changed to " approval." This

. change makes the units consistent.

Also, "by the Station Manager" is added after "6.5.2". This change was requested in Unit 1 as documented in Reference 2.

44 TS Section 6.14 The changer. are:

a. Subsection 6.14.2.1 - In the first sentence of the paragraph, "6.10.20." is changed to "6.10.2.n." This change is editorial.

Next, a second sentence "This documentation shall contain: is added to the paragraph. This change is editorial.

b. Subsection 6.14.2.1.b - At the end of the paragraph, "." is deleted and replaced with "; and." This change is editorial and makes the units consistent,

c. Subsection 6.14.2.2 - Change " acceptance" to " approval." This change makes the units consistent.

Also, add "by the Station Manager" after "6.5.2." This change was requested in Unit .' as documented in Reference 2.

45 TS Section 6.15 For Unit 2, the existing " Intentionally Left Blank" page is removed from the TS.

For Unit 3, the section "6.15 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS -- DELETED" is removed from the TS.

Section 6.15 was deleted previously by Amendment Nos. 83 and 73, and the proposed changes will help clean up Section 6.0.

CHANGES TO TS SECTION 7.0, "SPECIAL TEST PROGRAM" TS Section 7.0 is deleted from the Unit 2 TSs because the natural circulation testing program was applicable only during the initial startup testing for Unit 2. There is no change in the Unit 3 TSs because Unit 3 does not have Section 7.0.

SAFETY ANALYSIS The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any one of the following areas:

1. Will operation of the facility in accordance with this proposed change 29

1 l

involve a significant increase in the probability or consequences of an accident previously evaluated?

Re ponset No Changes to Unit 2 License Conditions 2.C.(19)a and 2.C.(19)c The deletion of License Conditions 2.C.(19)a, " Shift Technical Advisor (I.A.1.1, SSER #1)," and 2.C.(19)c, " Independent Safety Engineering Group (1.B.1.2, SSER #1)," are administrative in nature and do not impact probabilities or consequences of an accident previously evaluated. These license conditions have been implemented and presently incorporated in TS Sections 6.2.3 and 6.2.4, respectively. Therefore, operation of facility in accordance with these proposed changes will nct increase the probability or consequences of an accident previously r evaluated, Changes to License Condition 2.E The changes to reflect the most recent submittal dates for the Physical Security Plan, Security force Training and Qualification Plan, and Safeguards Contingency Plan are administrative and do not impact probabilities or consequences _ of an accident previously evaluated.

Therefore, operation of the facility in accordance with these proposed changes will not increase the probability or consequences of an accident previously evaluated.

Changes to TS Section 1.26 and TS Index Changes to Section 1.26 and TS indices a)e administrative in nature and do not impact probabilities or consequences of an accident previously evaluated. Therefore, operation of facility in accordance with these  ;

proposed changes will not increase the probability or consequences of an accident previously evaluated.

Organizational-Changes Theproposedchanges1)increaseexecutivelevelattentionandoversight of all nuclear activities, and 2) clarify personnel responsibilities as a result of the organization change within Southern California' Edison's nuclear organization. These changes are administrative and will not-impact the probabilities or consequences of an accident previously evaluated. Therefore, operation of' facility in accordance with these proposed changes will not increase the probability or. consequences of an

! accident previously evaluated.

Changes to Reporting Requirements The changes in reporting requirements are consistent with the guidance provided in GL 83-43. The changes are administrative in nature and will not impact the probabilities-or consequences of an accident previously-evaluated. Therefore, operation of facility in accordance with these-30 L.

_. .. _ _ _ _ . _ . . ~ _ _ . - _ .__ _ _ _ _ _ _ _ , _ _ . - _ .___ _

1 proposed changes will not increase the probability or consequences of an acclient previously evaluated.

The change to TS 6.9.1.8 does not impact the probabilities or consequences of an acc'ident previously evaluated. The change is administrative in nature because the program for reporting radioactive waste would continue to be controlled by 10 CFR 50 Ap>endix 1.

Therefore, operation of facility in accordance with tie proposed change will not increase the probability or consequences of an accident previously evaluated.

Other Changes Including Editorial Changes These changes are administrative and will not impact the probabilities or consequences of an accident previously evaluated. Therefore, operation of facility in accordance with these proposed changes will not increase the probability or consequences of an accident previously evaluated.

Change to Section 7.0 The change to delete Section 7.0 from the Unit 2 TSs is appropriate because this section is no longer applicable. This change is administrative and will not impact the probabilities or consequences of an accident previously evaluated. Therefore, operation of facility in accordance with these proposed changes will not increase the probability or consequences of an accident previously evaluated.

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No Changes to Unit ? License Conditionc 2.C.(19)a and 2.C.(19)c The deletion of these two license conditions are administrative in nature and do not impact any equipment, system, or plant configuration.

Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Changes to License condition 2 E The propos M changes are administrative in nature and do not impact any equipment, systems, or plant configuration. Therefore, the proposed changes will not create the possibility of a new or different kind of accicent from any accident previously evaluated.

Changes to TS Section 1.26 and TS Index The proposed changes are administrative in nature and do not impact any equipment, systems, or plant configuration. Therefore, the proposed 31

changes will not create the possibility of a new or different kind of accident from any accident presiously evaluated.

Organizational Changes The proposed organizational changes are administrative in nature and do not impact any equipment, systems, or )lant configuration. Therefore, the proposed changes will not create tie possibility of a new or different kind of accident from any accident previously evaluated.

Changes to Reporting Requirements The proposed changes concerning the TS reporting requirements are administrative in nature and do not impact any equipment, systems, or plant configuration. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The change to TS 6.9.1.8 does not impact any equipment, systems, or I plant configuration. The change is administrative in nature and the program for reporting radioactive waste wouid continue to take credit l

for the final volume of radioactive waste shipped to the disposal site.

Therefore, the proposed change will not create the probability of a new or different kind of accident previously evaluated.

Other Changes Including Editorial Changes The editorial changes are administrative in nature and do not impact any equipment, systems, or plant configuration. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Changes to Section 7.0 The deletion of Section 7.0 from the Unit 2 TSs is administrative in nature and do not impact any equipment, systems, or plant-configuration.

Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.- Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

l Response: No Changes to Unit 21.icerse Conditions 2.C.(19)a and 2.C.(19)c The proposed changes are administrative in nature and will not impact any design basis events or margin of safety associated with these events. Therefore, operation of the facility with th% proposed changes will not involve a significant reduction in a margin of safety.

32 l

l

\

Changes to C cense Condition 2.E The~ proposed changes are administrative in nature and will not im)act 2

-any design basis events or the margin of safety associated with t1ese i events. Therefore, o eration of the facility with this proposed changes will not involve a si nificant reduction in a margin of safety.

Changes to TS Section 1.26 and TS Index  ;

The proposed Section 1.26 and TS indices changes are administrative in nature and will not impact any design basis events or the margin of safety associated with these events. Therefore, operation of the facility with this proposed changes will not involve a significant reduction in a margin of safety. >

Organizational Changes The proposed organizational changes are administrative in nature and will not impact any design basis events or the margin of safety associated with these events. Therefore, operation of the facility with this proposed changes will not involve a significant reduction in a margin of safety.

Changes to Reporting Requirement The proposed changes to the Section 6.0 reporting requirements are administrative in nature and will not impact any design basis events or the margin of safety associated with these events. Therefore, operation-of the facility with this proposed changes will not involve a significant reduction in a margin of safety.

The change to TS 6.9.1.8 would only ensure the reporting of the final . ,

solid radioactive waste shipped to the disposal site is appropriate. l, The change is administrative in nature and will.not impact any design basis events or margin of safety associated with these events.

Therefore, the proposed change will not involve a significant reduction in a margin of safety.

Other Changes Including Editorial _ Changes -

The editorial changes are administrative in nature and will not impact any design basis events or the margin of safety associated with these- +

events. Therefore, o eration of the facility with this proposed changes will'not. involve a-si nificant reduction in a margin of safety. 4 Changes to Section-7.0 The deletion of Section 7.0 from the Unit 2 TSs is' administrative in nature and will not impact any design basis. events or the margin of safety-associated with these events.. Therefore, operation of-the facility with this proposed changes will not involve a significant .

reduction in a margin of safety.

33- -

Y )

c. - , . . - . ._ _

Safety and Stanificant Harards Determination Based on the above Safety Analysis, it is concluded thatt 1) the proposed ,

change does not constitute a significant hazards consideration as defined by i 10 CFR 50.92; 2) there is reasonable assurance that the health and safety of  :

the public will not be endangered by the proposed change; and 3) this action  !

will not result in a condition which significar.tly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

l 1

34 f

,