ML20141L031
| ML20141L031 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/27/1997 |
| From: | Subalusky W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20141L032 | List: |
| References | |
| NUDOCS 9706020253 | |
| Download: ML20141L031 (13) | |
Text
3 (lOntn)Ofl% e.tlih Edisin ( k niitting Lisalle Generating St.nion
.Wil North list Road Marsedles, If.613 n 1375' Tel H lid 57 WI May 27,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 l
Subject:
Technical Specifications, Section 5, Design Features, and Section 6, Administrative Controls LaSalle County Station, Units 1 and 2 Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Pursuant to 10 CFR 50.90, Commonwealth Edison Company (Comed) proposes to revise Facility Operating License NPF-11, and Appendix A, i
Technical Specifications of Facility Operating Licenses NPF-11 and NPF-18, LaSalle County Station Units 1 and 2. The changes include incorporation of a restructured station organization, a change to the submittal frequency of j
the Radiological Effluent Release Report, and other administrative changes.
This proposed amendment request is subdivided as follows:
1.
Attachment A gives a description and safety analysis of the proposed changes in this amendment.
2.
Attachment B includes the marked-up License / Technical Specifications pages for LaSalle Units 1 and 2 with the requested changes indicated.
3.
Attachment C describes Comed's evaluation performed in accordance with 10 CFR 50.92 (c), which confirms that no f
significant hazard consideration is involved.
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Attachment D provides an Environmental Assessment Applicability Review per 10 CFR 51.21.
This proposed amendment has been reviewed and approved by Comed Onsite and Offsite Review in accordance with procedures.
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Comed requests NRC approval of this amendment request within approximately six months. ;There are no specific schedule requirements associated with this amendment proposal. This amendment will be l
implemented within 90 days of issuance of the amendment. LaSalle County Station has already implemented the new organization, therefore, it is requested that the amendment be issued in a timely manner so that the Technical Specifications, as amended, be consistent with LaSalle's i
organization.
Comed is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated state official.
If there are any questions or comments concerning this letter, please refer them to Perry Barnes, Regulatory Assurance Supervisor, at (815) 357-6761, extension 2383.
Respectfully, j
W. T. Subaluskp Site Vice President L
LaSalle County Station Enclosure e
l cc:
A. B. Beach, NRC Region ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle l
D. M. Skay, Project Manager - NRR LaSalle F. Niziolek, Office of Nuclear Facility Safety - lDNS I
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e 1
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STATE OF ILLINOIS
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COUNTY OF LASALLE
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i Docket Nos. 50-373 50-374 IN THE MATTER OF
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COMMONWEALTH EDISON COMPANY
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LASALLE COUNTY STATION - UNITS 1 & 2
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AFFIDAVIT I affirm that the content of this transmittalis true and correct to the best of my knowledge,information and belief.
\\
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William T. Subalusky Site Vice President LaSalle County Statio.
Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 27C day of ff7cw 199 7. My Commission expires on OdirfA I
. 20to.
1 0FFrML SEAL DEBRAJ.FEENEY NOTARY PU9uC. STATE OFILUNOIS y (q
_' m g MY COMMIS$10N EXPIRES 1014000 Notal) Public
(
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i ATTACHMENT A
{
DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES j
Description of the Proposed Change
}
This is a proposed change to LaSalle County Nuclear Station (LaSalle) Unit 1 l
License Condition 2.C.(30)(a)., and Unit 1 and 2 Technical Specifications, Section 5, Design Features, and Section 6, Administrative Controls.
4 The proposal includes (1) Incorporation of the revised organizational titles, (2) a change to the submitta! frequency of the Radiological Effluent Release Report, and (3) other administrative changes.
1.
Proposed Revised Organizational Changes Description of the Current Operatina License / Technical Specification Reauirement Throughout Technical Specification Section 6, management and operational roles, responsibilities and position qualifications (i.e., ANSI N18.1-1971 "
Selection and Training of Nuclear Power Plant Personnel") are delineated.
Additionally, Unit 1 License Condition 2.C.(30)(a) specifies that the Shift Technical Advisor (STA) function is usually fulfilled by the Station Control Room Engineer (SCRE).
Bases for the Current Reauirement Technical Specifications Section 6, Administrative Controls, describes responsibilities and key roles of management and operating personnel and 1
associated qualification requirements.
Unit 1 License Condition 2.C.(30)(a) and Technical Specification 6.1.C.6 ensure that the STA function as an on-shift technical advisor to the Shift Supervisor is fulfilled by qualified Individuals.
Description of the Need for Amendina the Technical Specification Comed proposes to revise Section 6 to incorporate revised organizational titles.
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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES 1
1 i
Description of the Amended Technical Specification Reauirement l
The following reaect the revised organizational titles.
a.
Station Manager - The LaSalle Technical Specifications state that the Station Manager "shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant." In the revised organization, the equivalent
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position is titled Plant General Manager. The Technical Specification Station Manager position and Plant General Manager position are f
equivalent in that both positions meet the qualifications defined for " Plant Manager" In Section 4.2.1 of ANSI N18.1-1971.
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b.
Shift Supervisor / Shift Engineer - The LaSalle Technical Specifications state that the Shift Supervisor la responsible for " directing and commanding the overall operation of the facility on his shift." The revised organization's equivalent position is titled Shift Manager. The Technical Specification Shift Supervisor / Engineer position and current Shift Manager position are equivalent in that both positions meet the qualifications defined for
" Supervisors Requiring AEC Licenses" in Section 4.3.1 of ANSI N18.1-1971.
c.
Shift Foreman - The LaSalle Technical Specifications require a Shift Foreman (SRO) to meet minimum shift crew composition and, when necessary, to participate in Station Control Room Engineer (SCRE) turnover to assure capability for performance of all Shift Technical Advisor (STA) functions. In the revised organization, the equivalent position is titled Unit Supervisor. The Technical Specification Shift Foreman position and the current Unit Supervisor position are equivalent in that both positions meet the qualifications defined for " Supervisors Requiring AEC Licenses"In Section 4.3.1 of ANSI N18.1-1971.
d.
Station Control Room Engineer (SCRE)- The LaSalle Technical Specifications require that an Individual with a valid SRO be designated to assume the control room direction function while the unit is in operational condition 1,2, or 3 (in operational condition 4 or 5 the Individual is required to have either an SRO or RO). The SCRE fulfills this requirement. In the revised organization the control room SRO function is fulfilled by a Unit Supervisor as described in c. above.
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I ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Unit 1 License Condition 2.C.(30)(a) specifies that the Shift Technical Advisor (STA) function is usually fulfilled by the Station Control Room Engineer (SCRE). The STA function will be fu' filled by another Individual 1
fully trained and qualified as a STA.
The SCRE position and title are eliminated since the requirement for a control room SRO is being fulfilled by the Unit Supervisor and the STA function is fulfilled by another STA qualified Individual.
e.
Minimum Shift Crew Composition, Figure 6.1 Figure 6.1-3 is revised to reflect the organizational title changes. Minimum shlM staffing requirements (3 SROs during operational conditions 1,2 and 3, and 2 SROs during operational conditions 4,5, or defueled) are maintained in the revised organization. The revision to Figure 6.1-3 is consistent with 10 CFR 50.54 (m)(2)(li), Minimum Requirements Per Shift for Onsite Staffing of Nuclear Power Units by Operators and Senior Operators Licensed Under 10 CFR Part 55.
Bases of the Amended Technical Soecification Reaulrement This submittal reflects the changes to clarify the appropriate revised organizational positions. Allindividuals filling positions within the revised organization satisfy the requisite educational and experience qualification commensurate with their responsibilities.
Pending a Technical Specification change, the individuals filling the positions of Plant General Manager, Shift Manager, and Unit Supervisor have been issued letters informing them that their positions have dual titles, and that they fulfill the requisite Technical Specification responsibilities in their positions in the revised organization.
The revision to Unit 1 License Condition 2.C.(30)(a) Technical Specification 6.1.C.6 reflects that the STA function may be fulfilled by someone other than a designated SRO. The requirements of NUREG-0660, Action item I.A.1.1, as clarified by NUREG-0737, remain satisfied.
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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES 2.
Proposed Change to the Submittal Frequency of the Radiological Effluent Release Report Description of f.he Current Technical Specification Reautrement The Hadiological Effluent Release Report is currently submitted semiannually per Definition 1.27, and Specifications 6.6.A.4 and 6.8.2.c.
Bases for the Current Reauirement The Radiological Effluent Release Report is currently submitted semiannually, which reflects the requirements of 10CFR50.36a that were in effect prior to August 31,1992.
Description of the Need for Amendina the Technical Specification A rule to reduce the regulatory burden on nuclear licensees with respect to effluent reporting was published in the Federal Register on August 31,1992.
The rule change includes a revision to 10CFR50.36a, relaxing the frequency by which licensees are required to submit radiological effluent reports. This change serves to reduce an administrative burden without reducing the protection of the public health and safety. The revised 10CFR50.36a requires that effluent reports be submitted on an annual frequency. A submittal due date of May 1 of each year is proposed.
i Description of the Amended Technical Specification Requirement LaSalle's future Radiological Effluent Release Reports shall be issued annually following approval of the amendment. The amendment will also correspondingly revise Definition 1.27, as well as Specifications 6.6.A.4 and 6.8.2.c.
Bases for the Amended Technical Specification Reauest This change makes the Technical Specifications consistent with the amended requirement of 10CFR50.36a. The change does not adversely impact the ability to meet applicable regulatory requirements related to liquid and gaseous effluents.
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l ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES 3.
Other Administrative Changes Ceess'.. tion of the Current Technical Specification Reautrement The Exclusion Area and the site boundary for Gaseous and Liquid Effluents a.
are shown in Figure 5.1.1-1. Technical Specification 6.5.1 states "Tne 1
meteorological tower shall be located as shown on Figure 5.1.11.".
b.
Technical Specification 6.1.B states that the Shift Supervisor shall be responsible for directing and commanding the overall opc<ation of the facility on his shift, and the primary manage.nent responsibility of the Shift Supervisor shall be for safe operation of the nuclear facility on his shift under all conditions. It also requires that a management directive signed by the Site Vice President emphasizing this primary management responsibility and that clearly establishes the command duties of the Shift Supervisor be reissued to all station personnel on an annual basis.
c.
Technical Specification 6.1.C in part states the ANSI N18.1-1971 qualification requirements for the Systems Engineering Supervisor and the Operations Manager.
d.
The independent Safety Engineering Group (ISEG) surveils assorted unit activities to independently assess performance and the incidence of human errors in those activities. Technical Specification 6.1.C.5 in part requires that the ISEG provide various recommendations to the Site Quality Verification Director as a result of the surveillances, e.
Technical Specification 6.2.C.2. requires that personnel performing technical reviews of procedures identified in Technical Specification 6.2.C.
shall meet the applicable experience requirements of ANSI N18.11971, Sections 4.2 (Managers) and 4.4 (Professional - Technical), and be approved by the Station Manager.
f.
Technical Specification 6.2.E requirs:: that drills of the emergency procedures described in Technical Specification 6.2.A.4 be conducted at frequencies specified in the Generating Stations Emergency Plan (GSEP).
g.
Technical Specification 6.6.A.5, Monthly Operating Report, requires routine reports be submitted on a monthly basis to the Director, Office of Nuclear Reactor Regulation, Mail Station P1-137, with a copy to the appropriate A-5
ATTACHMENT A l
DEECRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l
Regional Office.
Technical Specification 6.6.A.5. requires that changes to the Offsite Dose Calculation Manual (ODCM) be submitted with the Monthly Operating Report within 90 days of when the change was made effective.
h.
Technical Specification 6.6.C.1.," Unique Reporting Requirements", requires that Special Reports be submitted to the Director of the Office and Inspection and Enforcement (Region Ill) within the time period specified for each report.
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The headers of Unit 2 Technical Specifications Chapter 6 pages 6-2,3,15, 22,23,24,27, and 28 state " Administration Controls" to identify the section of the technical specifications that they are associated with.
Bases for the Current Requirement Design features of Technical Specifications are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety.
Administrative controls of Technical Specifications are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
l Each licensee shall submit any reports to the Commission pursuant to approved Technical Specifications.
Description of the Need for Amendina the Technical Specification a.
Technical Specification Section 5.5.1 contains an editorial error. It currently states "The meteorological tower shall be located as shown on Figure 5.1.1-1.". The tower location is not represented on Figure 5.1.1-1. The Figure showing the meteorological tower was relocated to the LaSalle site specific annex of the Offsite Dose Calculation Manual (ODCM) per a previous licensing amendment. Proposing to delete the text in 5.5.1 was not included in the amendment request.
i b.
The Technical Specification 6.1.B requirement to lasue an annual executive management directive stating the responsibility of the Shift Manager is being eliminated, it is an administrative requirement which has no effect on i
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l ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l
the safe operation of the facility.
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c.
The ANSI qualification requirements for station personnel are maintained l
within the UFSAR and station administrative procedures. The requirement i
to maintain qualification levels need not have to be stated in the Technical Specifications in order to meet applicable regulatory requirements.
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d.
Technical Specification 6.1.C.5 is to be revised to reflect that the function of i
the Site Quality Verification Director is being fulfilled by the Safety l
Assessment / Site Quality Verification Manager. This is a title change to j
reflect the current organization.
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e.
Personnel presently performing technical reviews of procedures identified in Specification 6.2.C. shall meet the applicable experience requirements of i
and be qualified to ANSI N18.1-1971, Sections 4.2 (Managers) and 4.4 (Professional-Technical). Specification 6.2.C.2. is to be revised by permitting individuals who meet the applicable experience requirements of ANSI N18.1-1971 Sections 4.3 (Supervisors),4.5.1 (Operators), or 4.6 (Technical Support Personnel) to perform technical reviews of procedures identified in Specification 6.2.C. This provides for additional expertise available at the station to be utilized in the technical review process, f.
Technical Specification 6.2.A.d. requires that written procedures shall be established, implemented, and maintained covering Generating Station Emergency Response Plan implementation. Technical Specification 6.2.E requires that drills of the emergency procedures described in Technical Specification 6.2.A.4 be conducted at frequencies specified in the Generating Stations Emergency Plan (GSEP). The reference to 6.2.A.4 is in error; the correct reference is 6.2.A.d.
g.
10CFR50.4, " Written Communications", promulgates the addressing requirements of various reports. Revising the first paragraph of Technical Specification 6.6.A.5. to distribute reports per 10CFR50.4 ensures that reports are sent to the appropriate parties. The proposed change is also cost effective as it eliminates the need for future license amendments to reflect any futher changes incorporated in 10CFR50.4.
Paragraph 2 of Technical Specification 6.6.A.S. requires that any changes to the Offsite Dose Calculation Manual be submitted with the Monthly Operating Report within 90 days of when the change was made effective.
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l ATTACHMENT A j
DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES 1
l This conflicts with the requirements of Technical Specification 6.8.2.c. and should be deleted.
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Technical Specification 6.8.2.c. requires that licensee Initiated changes to j
the ODCM be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the i
Semiannual Radioactive Effluent Release Report for the period of the report j
in which any change to the ODCM was made effective (Note that i
" semiannual" here is being changed to " annual" per previous discussion).
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This is consistent with the Standard Technical Specifications (NUREG i
1433/1434).
j h.
Technical Specification 6.6.C.1., " Unique Reporting Requirements", requires j
revision because the title " Director of the Office and Inspection and j
Enforcement (Region Ill)" is not currently used and will be changed to j
" Regional Administrator of the NRC Regional Office".
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1.
The headers of Unit 2 Technical Specifications Chapter 6 pages 6-2,3,15, 1
1 22,23,24,27, and 28 erroneouMy state " Administration Controls" to i
identify the section of the technical specifications that they are associated with. The headers of these pages should state " Administrative Controls".
Description of the Amended Technical Specification Reauirement j
a.
The text " METEOROLOGICAL TOWER LOCATION" in Specification 5.5 is i
being replaced with " DELETED". Technical Specification 5.5.1 is to be l
deleted.
b.
The requirement to distribute an annual executive management directive l
stating the responsibility of the Shift Manager is deleted from Technical l
Specification 6.1.B.
i c.
Technical Specification 6.1.C is revised by deleting the text stating the ANSI j
N18.1-1971 qualifications requirements for the Operations Manager and j
Systems Engineering Supervisor. The ANSI qualification requirements for station personnel are maintained within the UFSAR and station j
administrative procedures.
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ATTACHMENT A j
DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES a
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d.
Technical Specification 6.1.C.5 is revised to incorporate the position of the
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l Site Quality Verification Director to the Safety Assessment / Site Quality Verification Manager. The Safety Assessment / Site Quality Verification
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Manager shall retain sufficient organizational freedom, authority, and responsibility presently afforded to the Site Quality Verification Director.
1 e.
Technical Specification 6.2.C.2. is revised to permit individuals qualified to ANSI N18.1-1971 Sections 4.3 (Supervisors),4.5.1 (Operators), or 4.6 j
(Technical Support Personnel) to perform technical reviews of procedures j
identified in Specification 6.2.C. This is in addition to those personnel qualified to ANSI N18.1-1971 Sections 4.2 and 4.4. This provides other j
appropriate expertise to be utilized in the technical review process.
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f.
Technical Specification "6.2.A.4" referenced in Technical Specification i
6.2.E is changed to "6.2.A.d.". Technical Specification 6.2.A.4 does not exist. This corrects a typographical error.
l g.
Paragraph 1 of Technical Specification 6.6.A.5 is changed to read:
" Routine reports of operating characteristics and shutdown experience, including documentation of all challenges to safety / relief valves, shall be 4
submitted on a monthly basis to the addressees specified in 10CFR50.4, no later than the 15th of each month following the calendar month covered by the report."
Paragraph 2 of Specification 6.6.A.5 is changed to read:
"A report of any major changes to the radioactive waste treatment systems shall be submitted with the Monthly Operating Report for the period in which the evaluation was reviewed and accepted by Onsite Review and investigative Function."
h.
In Technical Specification 6.6.C.1 the following text change is made:
" Director of the Office of Inspection and Enforcement (Region Ill)" is a
replaced with " Regional Administrator of the NRC Regional Office".
l.
The headers of Unit 2 Technical Specifications Chapter 6 pages 6-2,3,15, 22,23,24,27, and 28 are revised to replace " Administration Controls" with 4
" Administrative Controls".
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ATTACHMENT A DESCRIPTION OF UAFETY ANALYSIS OF THE PROPOSED CHANGES Bases for the Amended Technical Specification Reauest The proposed changes are administrativeleditorial in nature, do not reduce the requirements of the Technical Specifications, and do not relax the protection of the public health and safety.
The specific changes are proposed to improve readability, provide consistency within the Technical Specifications and station procedures, company programs, and present distribution requirements, to better utlitze personnel resources, serve to eliminate unnecessary items from the Technical Specifications, aid in minimizing the need for future license amendments and to relieve the associated administrative burden, and, to improve overall plant safety by allocating resources to areas warranting increased attention.
Schedule Comed requests NRC approval of this amendment request within approximately six months. There are no specific schedule requirements associated with this amendment proposal. This amendment will be implemented within 90 days of issuance of the amendment. LaSalle County Station implemented the revised organizational titles. We request that the amendment be issued in a timely manner so that the Technical Specifications, as amended, are consistent with LaSalle's organization.
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