ML17309A555

Transmits Requested Changes to 940513 Lar,Revising TS Section 6.0, Administrative Controls & Ack Set of Revised TS Requirements Discussed in LAR Which Will Be Reviewed by NRC at This Time,Per 940803 Telcon W/Nrc

ML17309A555
Person / Time
Site:	Ginna
Issue date:	09/27/1994
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML17263A791	List: ML17263A790 ML17309A555
References
NUDOCS 9409290181
Download: ML17309A555 (11)

Text

Fmxaa.X~rV (ACCELERATED RIDS PROCESSING i

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9409290181 DOC.DATE: 94/09/27 NOTARIZED: YES DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R. Project Directorate I-3

SUBJECT:

Transmits requested changes to 940513 LAR,revising TS Section 6.0, "Administrative Controls" & ack set of revised TS requirements discussed in LAR which will be reviewed by NRC at this time,per 940803 telcon w/NRC.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR I Submittal: General Distribution ENCL L SIZE:

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 LA 1 1 PD1-3 PD 1 1 JOHNSON,A 1 1 INTERN  : FILE CENTER 0 1 1 NRR/DE/EELB 1 1 ARCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 1 NRR/DS SA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 0 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE IVASTE! CONTACT TIIE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELlih!INATE YOUR NAlIE PRO~I DISTRIBUTION LISTS I'OR DOCI;MENTS YOU DON "I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL 12

AND ROCHESTER GAS AND ELECI1C CORPORAT1ON ~ 89 EASTAVENUE, ROCHESTER, N. Y 1d6d9-OOOI AREA CODE716 5'.27OO ROBERT C MECREOY Vice President September 27, 1994 Cinna Nudear Production U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555

Subject:

Application for Amendment to Facility Operating License Upgrade of Administrative Controls Section 6.0 Rochester Gas & Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244

References:

a. Letter from R.C. Mecredy, RG&E, to A.R. Johnson, NRC,

Subject:

Application for Amendment to Facility Operating License, Upgrade of Administrative Controls Section 6.0, dated Hay 13, 1994.

b. Letter from R.C. Hecredy, RG&E, to A.R. Johnson, NRC,

Subject:

Conversion to Improved Technical Specifications, dated February 28, 1994.

Dear Hr. Johnson,

Rochester Gas and Electric (RG&E) previously submitted a License Amendment Request (LAR) which proposed to revise the Ginna Station Technical Specifications (TS) Section 6, Administrative Controls (Ref. a). On August 3, 1994, a conference call was conducted between the NRC and RG&E at which time several changes to the LAR were requested by the NRC. This document transmits the requested changes and acknowledges the set of revised TS requirements discussed in the LAR which will be reviewed by the NRC at this time. The remaining TS changes will be deferred until the conversion of the entire Ginna Station TS during the Technical Specification Improvement Program (Ref. b).

The following changes as discussed in Attachment A to Reference a are being requested at this time:

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a. Section C. 1, change iv (except for the proposed deletion of Ginna TS 6.8.1.f).

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b. Section C.2, changes i, ii (except for the proposed deletion of TS 6.2.2.b and 6.2.2.c), iii, iv, v, vii (revise the submittal of Radiological Effluent Release Report from semiannual to annual only), ix, and x.

c. Section C.3, changes iv, vi, and vii.

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d. Section C.4, change v.

e. Section C.7, changes iii and v.

These changes are reflected in the enclosed Attachment 8 and C to this letter.

Similar to Reference a, Attachment B provides the marked-up Ginna Station TS which documents the requested changes while Attachment C provides the proposed new TS following the changes.

Since the above changes are only a subset of those originally requested in Reference a, several additional changes are now necessary to ensure a complete specification. These additional changes and their justification are provided in Attachment A. The remaining justification of changes, safety evaluation, and no significant hazards and environmental considerations provided in Attachment A of Reference a remain unchanged.

We request that upon NRC approval, this application should be considered effective immediately and implemented within 60 days, or upon NRC approval and implementation of the gA Program changes, whichever is later.

Ver uly yours, Robert C, Mecred Subscribed and sworn to before me on this 27th day of September 1994.

N ary ublic MDFX634 Nsr hRPin es sgs g NNROE COUNY

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@g, Attachments xc: Mr. Allen R. Johnson (Mail Stop 14DI)

PWR Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

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Hr. Gene Eckholt Northern States Power Company Prairie Island Nuclear Generating Plant Route 2 Welch, HN 55089 Hr. Thomas Halanowski Wisconsin Electric Power 231 West Michigan Milwaukee, WI 53201 Hs. Sherry Bernhoft Wisconsin Public Service P.O. Box 19002 700 North Adams Green Bay, WI 54307-9002 Mr. Jack Stringfellow Southern Nuclear Operating Company P.O. Box 1295 40 Inverness Center Parkway Birmingham, AL 35201 Hr. Lee Bush Commonwealth Edison Company Zion Nuclear Station 101 Shiloh Boulevard Zion, IL 60099

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ATTACHMENT A Justification of Changes The justification for all changes to the current Ginna Station TS are provided in Attachment A, Section C to the letter from R.C. Mecredy, RGKE, to A.R.

Johnson, NRC,

Subject:

Application for Amendment to Facility Operating License,

. Upgrade of Administrative Controls Section 6.0, dated May 13, 1994. The justification for additional changes not discussed in the May 13, 1994 letter are provided below:

Revised the Table of Contents to support the requested changes.

2. The following specifications have been revised to provide a footnote which allows for an alternate title to be designated for the specified position:

a. TS 6.2. l.b, 6.7.b and 6.7.d - Senior Vice President, Production and Engineering.

b. TS 6.4. 1 - Division Training Manager

c. TS 6. 13. 1 - Health Physicist Specifying management positions by title within the technical specifications creates a licensee and NRC burden when titles are changed or responsibilities are shifted. The current Ginna Station TS 6.2. l.a requires that "lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all Plant management positions." The footnote requires that the alternate titles be specified in the Updated Final Safety Analysis Report (UFSAR) and that all the technical specification requirements apply to the alternate title.

The title of the Senior Vice President, Production and Engineering has also been revised to Senior Vice President, Customer Operations. This is an individual's title change only. This Senior Vice President continues to have corporate responsibility for overall Plant nuclear safety and is chairman of the offsite review function (i.e., Nuclear Safety Audit and Review Board). The footnote for the Senior Vice President, Customer Operations further specifies that the use of an alternate title for this position must be performed in accordance with 10 CFR'0.54(a)(3). The responsibilities of key organization positions, including the Senior Vice President, Production and Engineering are specified in the Ginna Station gA Program. Since changes to the gA Program are controlled by 10 CFR 50.54(a)(3), equivalent control is provided.

3. TS 6.2.2.a and 6.2,2,d and Table,6.2-1 were removed from the technical specifications since they duplicate current regulations as specified in 10 CFR 50.54(k), (1), and (m). However, the following shift crew requirements as specified in TS Table 6.2-1 are not contained within the I

current regulations and must be added to TS 6.2.2:

a. An auxiliary operator with fuel in the reactor,

b. A second auxiliary operator above Cold Shutdown, and

.9409290181

I (ii,

c. A Shift Technical Advisor (STA) above Cold Shutdown.

In addition, the exception provided in TS Table, 6.2-1 with respect to unexpected absences of on-duty shift crew members was also added to TS 6.2.2. Also, TS 6.2.2.b and 6.2.2.c are revised consistent with NUREG-1431 (ITS 5.2.2.b).

4, TS 6. 13. 1 was revised to replace "health physicist" with "radiation protection" in those places where health physicist was a generic reference since this department is currently identified as radiation protection.

Specific functions performed by a health physicist were not revised. This is not a technical change.

5. A submittal date of Hay 1 of each year was selected for the Radioactive Effluent Release Report since 10 CFR 50.36a only requires an annual submittal but does not identify a specific submittal date. The last RGEE submittal. of this report was on August 30, 1994. Therefore, the next report on May 1, 1995 is less than the required annual submittal frequency and is consistent with the submittal date of the Annual Radiological Environmental Operation Report (TS 6.9. 1.3).

A cross reference to the justification of each proposed change is provided in the left margin of each Ginna Station TS that has been changed by use of a circle containing section numbers from either Attachment A, Section C of the Hay 13, 1994 letter (e.g., C. l.iv) or the above justifications (e.g., A. 1).