RS-14-128, LaSalle, Units 1 & 2, Updated Final Safety Analysis Report, Revision 20, Chapter 13.0, Conduct of Operations

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LaSalle, Units 1 & 2, Updated Final Safety Analysis Report, Revision 20, Chapter 13.0, Conduct of Operations
ML14113A114
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 04/11/2014
From:
Exelon Generation Co
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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ML14113A099 List:
References
RS-14-128
Download: ML14113A114 (43)


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LSCS-UFSAR 13.0-i REV. 15, APRIL 2004 CHAPTER 13.0 - CONDUCT OF OPERATIONS TABLE OF CONTENTS PAGE 13.0 CONDUCT OF OPERATIONS 13.1-1 13.1 ORGANIZATIONAL STRUCTURE OF LICENSEE 13.1-1 13.1.1 Management and Technical Support Organization 13.1-1 13.1.1.1 Operating Responsibilities 13.1-1 13.1.1.2 Organizational Arrangement 13.1-1 13.1.1.3 Qualifications 13.1-1 13.1.2 Operating Organization 13.1-2 13.1.2.1 Plant Organization 13.1-2 13.1.2.2 Plant Personnel Responsibilities and Authorities 13.1-2 13.1.2.3 Operating Shift Crews 13.1-4 13.1.3 Qualifications of Nuclear Plant Personnel 13.1-4

13.1.3.1 Qualification Requirements 13.1-4 13.1.3.2 Qualifications of Plant Personnel 13.1-4 13.2 TRAINING 13.2-1 13.2.1 LSCS Training Program 13.2-1 13.2.1.1 Program Description 13.2-1 13.2.1.1.1 Plant Staff Training 13.2-1 13.2.1.1.2 Non Licensed Operator Training 13.2-2 13.2.1.1.3 General Employee Training (N-GET) Course 13.2-2 13.2.1.1.4 Equipment Operator Training 13.2-3 13.2.1.1.5 Licensed Operator Training 13.2-3 13.2.1.1.5.1 Deleted, Rev. 5 - 1989 13.2.1.1.6 Radwaste Operator Training 13.2-3 13.2.1.2 Program Schedule for Preoperational Test, Fuel Loading, and Power Operations 13.2-4 13.2.1.2.1 Evaluation of Training Program 13.2-4 LSCS-UFSAR TABLE OF CONTENTS (Cont'd)

PAGE 13.0-ii REV. 15, APRIL 2004 13.2.2 Replacement and Retraining 13.2-4 13.2.2.1 Licensed Operator Requalification 13.2-4 13.2.2.2 Refresher Training for All Station Employees 13.2-5 13.2.2.3 Replacement Training of Certain Specialties 13.2-5 13.2.2.3.1 Specialist Refresher Training 13.2-8 13.2.2.4 Training Programs Level Due to Previous Experience 13.2-8 13.2.3 Applicable NRC Documents 13.2-9

13.3 EMERGENCY PLANNING 13.3-1 13.4 REVIEW AND AUDIT 13.4-1 13.5 PLANT PROCEDURES 13.5-1 13.5.1 Administrative Procedures 13.5-1 13.5.1.1 Conformance with Federal Guidelines 13.5-1 13.5.1.2 Preparation of Procedures 13.5-1 13.5.1.3 Procedures 13.5-2 13.5.1.3.1 Standing Operating Orders 13.5-2 13.5.1.3.2 Special Operating Orders 13.5-3 13.5.1.3.3 Equipment Control Procedures 13.5-3 13.5.1.3.4 Control of Maintenance and Modification 13.5-4 13.5.1.3.5 Master Surveillance Testing Schedule 13.5-4 13.5.1.3.6 Procedures for Logbook 13.5-4 13.5.1.3.7 Temporary Procedures 13.5-4 13.5.2 Operating and Maintenance Procedures 13.5-5 13.5.2.1 Control Room Operating Procedures 13.5-5 13.5.2.1.1 Systems Operating Procedures 13.5-5 13.5.2.1.2 General Operating Procedures 13.5-5 13.5.2.1.3 Abnormal Operating Procedures 13.5-5 13.5.2.1.4 Emergency Procedures 13.5-5 13.5.2.1.5 Annunciator Response Procedures 13.5-6 13.5.2.1.6 Temporary Procedures 13.5-6 13.5.2.2 Other Procedures 13.5-6 13.5.2.2.1 Plant Radiation Protection Procedures 13.5-6 13.5.2.2.2 Emergency Preparedness Procedures 13.5-6 13.5.2.2.3 Instrument Calibration and Test Procedures 13.5-6 13.5.2.2.4 Chemical/Radiochemical Control Procedures 13.5-6 LSCS-UFSAR TABLE OF CONTENTS (Cont'd)

PAGE 13.0-iii REV. 20, APRIL 2014 13.5.2.2.5 Radioactive Waste Management Procedures 13.5-7 13.5.2.2.6 Maintenance Procedures 13.5-7 13.5.2.2.7 Materials Control Procedures 13.5-7 13.5.2.2.8 Plant Security Procedures 13.5-7 13.5.2.2.9 Surveillance Procedures 13.5-7 13.5.2.2.10 Process Control Program 13.5-7 13.5.3 Process Review 13.5-7 13.6 PLANT RECORDS 13.6-1 13.6.1 Operating Records 13.6-1 13.6.2 Event Records 13.6-1 13.7 INDUSTRIAL SECURITY 13.7-1 LSCS-UFSAR 13.0-iv REV. 19, APRIL 2012 CHAPTER 13.0 - CONDUCT OF OPERATIONS LIST OF TABLES NUMBER TITLE 13.1-1 Deleted 13.2-1 Operational Training of Personnel

13.5-1 Responsibility for Preparation of Plant Procedures

LSCS-UFSAR 13.0-v REV. 15, APRIL 2004 CHAPTER 13.0 - CONDUCT OF OPERATIONS LIST OF FIGURES NUMBER TITLE 13.5-1 Diagram of "At the Controls" Area

LSCS-UFSAR TABLE 13.2-1 TABLE 13.2-1 REV. 13 OPERATIONAL TRAINING OF PERSONNEL TITLE N-GET NEO LOT LRO SPEC Shift Operations Supervisor X X X X Shift Manager X X X X X Field Supervisor X X X Unit Supervisor X X X X Work Control Center Operations SRO X X X X Nuclear Station Operator X X X X X Equipment Operator X X X Equipment Attendant X X X Auxiliary Operator X X X Engineering Staff X X X Instructor Staff X X X Radiation Protection X X X Maintenance Personnel X X X Station Laborer X X X Administrative X X Storeroom X X Security Contract Personnel X X N-GET - General Employee Training Course NEO - New Employee Orientation LOT - Licensed Operator Training LRQ - Licensed Requalification Training SPEC - Specialist Training as applicable to job classification

LSCS-UFSAR 13.3-1 REV. 15, APRIL 2004 13.3 EMERGENCY PLANNING Plans for coping with emergency situations are contained in the Exelon Nuclear Radiological Emergency Plan. The Emergency Plan dated December 1977 was filed on September 11, 1978, for LaSalle County Station Dockets 50-373 and 50-374. That filing also applied for Dresden Units 1, 2, and 3; Quad Cities Units 1 and 2; and Zion Units 1 and 2 (Dockets50-010, 50-237, 50-249, 50-254, 50-265, 50-295, and 50-304). Revisions to the Emergency Plan are filed with the Nuclear Regulatory Commission (NRC). NRC's evaluation of the Emerge ncy Plan are provided in the Safety Evaluation Report (NUREG 0519) date d March 1981, and in its Supplements.

The Exelon Nuclear Standardized Radiological Emergency Plan is a written emergency plan that establishes the concep ts, evaluation and assessment criteria, and recommended protective actions necessary to limit and mitigate the consequences of potential or actual nuclear power plant emergencies. The Emergency Plan provides the necessary prearrangements, directions, and organization to ensure nuclear emergencies can be effectively and e fficiently resolved in order to safeguard station personnel, property, and the general public.

The Emergency Plan has been developed based on the emergency planning and preparedness requirements specified in Appendix E to 10 CFR Part 50 and Regulatory Guide 1.101, Revision 3 of August 1992. The Emergency Plan has been submitted to and approved by the NRC.

It is reviewed annually, any changes or revisions that pertain to regulatory requirements are submitted to the NRC for approval.

The Emergency Plan includes site-speci fic Annexes which contain additional information and guidance that are unique to each nuclear generating facility. The site-specific Annexes are not independent of the Emergency Plan. Each site has Standardized Emergency Plan Implementing Procedures which implement the Emergency Plan appropriately.

The Emergency Plan identifies onsite and offsite facilities and equipment available for emergency assessment, communications, first aid and medical care, and damage control. The Emergency Response Facilitie s (ERFs) consist of the: Control Room (CR), Technical Support Center (TSC), Operational Support Center (OSC), Emergency Operations Facility (EOF), an d the Joint Public Information Center (JPIC). The Emergency Plan provides for classificati on of emergencies into five categories (listed in order of increasing severity):

Unusual Event, Alert, Site Emergency, General Emergency, and Recovery. Unusual Event classifications are events that are in progress or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Alert classifications are events that are in progress or have occurred which involve an LSCS-UFSAR 13.3-2 REV. 15, APRIL 2004 actual or potential substantial degradation of the level of safety of the plant. Any radioactive material releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline exposure levels. Site Emergency classifications are events that are in progress or have occurred which involve actual or likely major failures of the plant functions needed for protection of the public. Any radioactive material releases are not expected to exceed EPA Protective Action Guideline exposure levels except near the site boundary. General Emergency classifications are events that are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containm ent integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels for more than the immediate site area.

Recovery is that period when the emergency phase is over and actions are being taken to return the situation to a non-emergency state. The plant is under control and no potential for further degradation of the plant or the environment is believed to exist.

The Emergency Plan includes notification requirements for classified events, including prompt and accurate notifica tions to Federal, State, and local governments.

Training is conducted for all emergency response personnel to ensure their proficiency. The training programs for emergency response personnel are based on the requirements of Appendix E to 10 CFR Part 50.

Evaluated Exercises are conducted biennially at each nuclear station to demonstrate the adequacy of timing and content of the Standardized Emergency Plan Implementing Procedures and meth ods; to test emergency equipment and communication networks; and to ensure that emergency response personnel are familiar with their duties. Each Exercise involves participation by Federal, State, and/or local personnel as prescribed by regulatory requirements.

The Emergency Plan manuals and Station Annexes are distributed on a controlled basis to all stations and emergency facilities requiring them, including appropriate Federal, State, and local agencies.

LSCS-UFSAR 13.4-1 REV. 15, APRIL 2004 13.4 REVIEW AND AUDIT The review and audit program for LaSa lle County Station is conducted in accordance with Quality Assurance Topical Report NO-AA-10.

LCSC-UFSAR 13.5-1 REV. 15, APRIL 2004 13.5 PLANT PROCEDURES The LaSalle County Station (LSCS) day-to-day operations are governed by procedure manuals within assigned areas of responsibility which govern employees' actions and establish standards for plant operation.

A formalized system of written procedur es which contains administrative and operating instructions in conformance with ANSI N18.7-1976, and which acknowledges the safety provisions of the facility license and Technical Specifications, is employed to ensure that all normal and reasonably foreseeable abnormal or emergency activities are conducted in a safe manner.

Detailed station/site procedur es (i.e., plant procedures), administrative procedures, and safety-related operating procedures, are approved by members of the site management staff. Technical Specifications provide a list of it ems for which written procedures are required to established, implemented, and maintained.

Planned safety-related operations are conducted in accordance with these detailed site procedures.

The site reviews all site procedures as required by the Quality Assurance Topical Report NO-AA-10 for LSCS.

13.5.1 Administrative Procedures 13.5.1.1 Conformance with Federal Guidelines The LSCS site procedures are written to conform to applicable federal guidelines.

13.5.1.2 Preparation of Procedures The LSCS administrative procedures ar e prepared by members of the site management organization and/or the nuclear generation organization. The responsibility for writing and preparing procedures is assigned to the appropriate department heads of the site administrative organization as indicated in Table 13.5-1. When procedures are comm on for all nuclear sites, the nuclear generation organization writes and prepares generic procedures for approval at all sites. Operating and maintenance procedures an d necessary changes are reviewed and approved by a Shift Operations Supervisor in areas of operation or fuel handling and by the Maintenance Manager in areas of plant maintenance, instrument maintenance, and plant inspection.

LCSC-UFSAR 13.5-2 REV. 15, APRIL 2004 Radiation control procedures are reviewed and approved by the Radiation Protection Manager. All procedures enumerated in this sectio n must be authorized by the responsible approval authority as required by Quality Assurance Topical Report NO-AA-10 before being implemented.

Revisions to these procedures which change the intent or are more than clarifications or corrections to typograp hical errors, must be authorized by the responsible approval authority as required by Quality Assurance Topical Report NO-AA-10 before being implemented.

Temporary changes to procedures listed in the Technical Specifications may be made provided:

a. The intent of the original procedure is not altered.
b. The change is approved by two members of the site management staff, at least one of whom ho lds a Senior Reactor Operator's License on the unit affected.
c. The change is documented, reviewed and approved in accordance with the Quality Assurance Topical Report NO-AA-10 within 14 days of implementation.

13.5.1.3 Procedures The LSCS Administrative Procedures identify site organization and responsibilities, control room procedures, operating criteria, requirements for records, a summary of required tests, analyses, and calibrations to be performed, their frequency of performance, and the group responsible for this work.

Format of the Administrative procedures is controlled through an administrative writers guide.

13.5.1.3.1 Standing Operating Orders Standing operating orders are issued to delineate the authority and responsibility of the operations shift supervisors and shift crews and include the following:

a. The reactor operator's authority and responsibility to shutdown the reactor when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection circuit setpoints and automatic shutdown does not occur.

LCSC-UFSAR 13.5-3 REV. 13 b. The responsibility to determin e the circumstances, analyze the cause, and determine that operation can be safely resumed before the reactor is returned to power following a trip or an unscheduled or unexplained power reduction.

c. The senior reactor operator's re sponsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.
d. The responsibility to review and respond conservatively to instrument indications unless they are proved to be incorrect.
e. The responsibility to adhere to the LaSalle County Station Technical Specifications.
f. The responsibility to review ro utine operating data to assure safe operation.
g. The responsibility to meet the requirements of 10 CFR 50.54(i), (j), (k), (l), and (m).
h. The responsibility to adhere to plant operating procedures, and the requirements for their use. (However, in case of emergency, operations personnel shall be authorized to depart from approved procedures where nece ssary to prevent injury to personnel, including the public, or damage to the facility. Such changes are to be documented and incorporated into the revision

to the affected procedure.)

i. The area designated for the "at the controls" area of the control room (Figure 13.5-1).

13.5.1.3.2 Special Operating Orders

Special operating orders contain nonroutine station operating limits with specific explanations and clarifications of definitions or terms. Special orders are also used to explain temporary operations that may apply to a particular unit.

Special orders are typically used for it ems which have a short-term applicability and as such include an effective date and a cancellation date. A special operating order is not used as a substitute for a revised procedure or a temporary change to a

procedure.

13.5.1.3.3 Equipment Control Procedures

LCSC-UFSAR 13.5-4 REV. 15, APRIL 2004 Equipment control procedures are established to provide for the necessary control of equipment to maintain plant equipment and personnel safety and to avoid unauthorized operation of equipment. These instructions utilize the control measure of tagging to secure and identify equipment in a controlled status. Independent verification is employed to ensure that tagging has been implemented correctly.

The use of equipment locks is employed in certain circumstances in conjunction with the tagging procedure or in the absence of the tagging procedure to ensure that the safety of plant equipment and personnel is not jeopardized. Verification and control procedures are utilized when equipment locking is necessary.

13.5.1.3.4 Control of Maintenance and Modification Control of maintenance and modification is provided for in the Quality Assurance Topical Report. Prescribed procedures are found in Sections 3, 5, 6, 9 and 10 of this quality assurance manual.

13.5.1.3.5 Master Surveillance Testing Schedule A master surveillance testing schedule is prepared which prescribes the surveillance to be performed and the frequency as outlined in the Technical Specifications.

13.5.1.3.6 Procedures for Logbook Procedures for logbook usage and control are provided to ensure adequate documentation of various unit operations and conditions. Logbooks are maintained in the control area and shift supervisor's office. Entry items in these books include unit or plant equipment status, malfuncti on, scrams (including the reasons), changes in operating conditions, test and measurements performed, and other significant information noted by the operating crew or supervisors. Review of the appropriate logs shall be performed as a function of shift change activities as directed by the shift change administrative procedure.

13.5.1.3.7 Temp orary Procedures Temporary procedures may be issued to direct specific operator actions during testing and maintenance, to provide guidan ce in unusual situations not within the scope of the station operating procedures, and to ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner such that portions of existing procedures do not apply.

Temporary procedures require review and approval according to the station review process and must be authorized by the appropriate management representatives prior to implementation. (See Subsection 13.5.1.2)

LCSC-UFSAR 13.5-5 REV. 13 13.5.2 Operating and Maintenance Procedures 13.5.2.1 Control Room Operating Procedures The procedures described in this section are performed primarily by licensed operators or reflect licensed operator acti ons in the performance of the procedure.

Operating procedures are arranged categorically and include a descriptive title for each procedure identified within the classification.

13.5.2.1.1 Systems Operating Procedure The procedures identified in this classification provide step-by-step instructions for energizing, filling, venting, draining, star tup, shutdowns, and changing modes of operation. Each procedure in this classification is written following the format outlined in the station procedure writers guide.

13.5.2.1.2 General Operating Procedures The general operating procedures provide instruction for the integrated operations of the plant. They are written in the degree of detail necessary to perform the evolution. Where appropriate, reference is made to detailed system procedures.

Format and content of the general operating procedures is controlled through an administrative writers guide.

13.5.2.1.3 Abnormal Operating Procedures

This procedure section is composed of systems abnormal operating procedures, which are directed to system and subsystem conditions.

Format and content of the Abnormal Operating Procedures is contro lled through an administrative writers guide. Conditions for entry into the General Abno rmal Operations procedures are required to be memorized.

13.5.2.1.4 Emer gency Procedures General Abnormal Operating Procedures are directed to plant conditions. The General Abnormal Operating Procedures are based on the BWR Owners Group Emergency Procedure Guidelines and are produced in flow chart form, with supporting documents produced in a format approved by the station.

Format of the General Abnormal Operating Procedure Flowcharts and support procedures are controlled through an admini strative writers guide. Conditions for LCSC-UFSAR 13.5-6 REV. 13 entry into the General Abnormal Operations procedures are required to be memorized.

13.5.2.1.5 Annunciator Response Procedures Annunciators in control areas are identified by an alphanumeric designation on the control panel which coincides with the al phanumeric designation of the annunciator response procedure in the appropriate procedure manual. The format and content of the annunciator procedures are contro lled through an administrative writers guide. 13.5.2.1.6 Temp orary Procedures Temporary procedures are described in Subsection 13.5.1.3.7.

13.5.2.2 Other Procedures This subsection describes how other operating and maintenance procedures are classified and what group within the operating organization has the responsibility for following each class of procedures and outlining the general objectives and character of each class.

13.5.2.2.1 Plant Radiation Protection Procedures These procedures are described in Chapter 12.0.

13.5.2.2.2 Emergency Preparedness Procedures These procedures are desc ribed in Section 13.3.

13.5.2.2.3 Instrument Calibration and Test Procedures The instrumentation procedures section governs operation at checkout and calibration of instrumentation. These pr ocedures apply to nuclear, process, area radiation monitoring, reactor protection and rod worth minimizer instrumentation. Checkoff lists are provided and completed for the more complex operations.

The instrument maintenance department prepares and follows these procedures.

13.5.2.2.4 Chemical/Radioch emical Control Procedures The chemical control procedures section states the operating limits or ranges for chemical and radiochemical control and prescribes the personnel to be notified if

these limits are approached.

LCSC-UFSAR 13.5-7 REV. 15, APRIL 2004 The Chemistry Technicians are provided with a schedule which describes the types of analysis to be performed and the freque ncy at which samples are taken. Step-by-step procedures are provided. In addition, a copy of these procedures is kept in the radiochemical laboratory for ready reference. Other copies are available per the controlled distribution of station procedures.

The Chemistry department prepares and follows the procedures described in this section. 13.5.2.2.5 Radioactive Waste Management Procedures The radioactive waste management procedures prescribe the methods and modes of operation employed to collect, treat, store, and dispose of liquid and solid radioactive waste materials resulting fr om plant operations. The operations department prepares and follows the procedures described in this section.

13.5.2.2.6 Maintenance Procedures The maintenance procedures prescribe the techniques, tools, and equipment used to

perform inspection, repair, and overhaul of unit equipment. The maintenance department prepares and follows the procedures in this category.

13.5.2.2.7 Materials Control Procedures Materials control requirements and procedures are identified in Sections 4, 7, 8, 13 and 15 of the Quality Assurance Topical Report.

13.5.2.2.8 Plant Security Procedures The plant security procedures are acknowledged in the industrial security section of this UFSAR (Section 13.7).

13.5.2.2.9 Surveillance Procedures The surveillance procedures prescribe th e frequency at which major components and systems are inspected and tested.

This includes unit equipment, the surveillance of which is not included in the Technical Specifications or instrumentation procedures.

13.5.2.2.10 Process Control Program The Process Control Program procedures prescribe and or contain the current formulas, sampling, analysis, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR parts 20, 61, and 71, State regulation, burial ground requirements, and other requ irements governing the disposal of solid radioactive waste.

LCSC-UFSAR 13.5-7a REV. 14, APRIL 2002 13.5.3 Procedure Review It is the responsibility of the appropriate department requiring surveillance items to prepare and follow surveillance procedures.

LCSC-UFSAR 13.5-8 REV. 18, APRIL 2010 LaSalle Station has adopted the procedure review requirements of ANS 3.2, ANSI N18.7-1988, sections pertaining to biennial review of procedure, as in the Quality Assurance Topical Report, NO-AA-10, in Chapter 6, Document Control, Section 2.1.

All other procedures related activities will continue to be performed in accordance with the requirements of ANS 3.2, ANSI N18.7-1976 as required by Reg Guide 1.33.

LSCS-UFSAR TABLE 13.5-1 TABLE 13.5-1 REV. 12 RESPONSIBILITY FOR PREPARATION OF PLANT PROCEDURES PROCEDURE GROUP RESPONSIBLE DEPARTMENT HEADS Administrative procedures Cognizant Department Head Operating/Surveillance procedures Shift Operations Supervisor Technical/Surveillance procedures System Engineering Supervisor Support Engineering Supervisor

Design Engineering Supervisor Mechanical Maintenance/Surveillance procedures Mechanical Maintenance Supt.

Electrical Maintenance/Surveillance procedures Electrical Maintenance Supt.

Instrumentation/Surveillance procedures Instrument Maintenance Supt. Radiation Control procedures Radiation Protection Manager Chemical Control procedures Chemistry Manager Emergency Procedures EOP Coordinator

LSCS-UFSAR 13.6-1 REV. 15, APRIL 2004 13.6 PLANT RECORDS Records of plant history are kept in accord ance with 10 CFR 50, Appendix B, Section 17, April 30, 1975.

Operating logbooks, reviews, inspections, tests, audits, monitoring of work performance, analyses of materials, procedures, qualification of personnel records, and equipment records are microfilmed and retained in the plant archive room and the central file.

Records contain appropriate identification of inspectors, types of observation, acceptance, deficiencies, results, and action taken to correct deficiencies.

All records are indexed for identification and retrievability within a reasonable time.

All archive records are stored and retained in a manner consistent with regulatory requirements and Company Policy.

The Station Manager has overall responsibility for plant records. The office supervisor is assigned the responsibility of maintaining the records consistent with regulatory requirements and company policy.

13.6.1 Operating Records Operating records as well as records of principal maintenance activities and abnormal occurrences during the life of the plant are microfilmed and retained in the plant archive room and the central file.

All operating records are indexed for identification and retrievability within a reasonable time.

Operating records are stored and retained in a manner consistent with regulatory requirements and Company Policy.

13.6.2 Event Records Records pertaining to events such as radioactive releases and environmental surveys during the life of the plant are microfilmed and retained in the plant archive room and the central file.

All event records are indexed for identifica tion and retrievability within a reasonable time.

LSCS-UFSAR 13.6-2 REV. 15, APRIL 2004 Event records are stored and retained in a manner consistent with regulatory requirements and Company Policy.

LSCS-UFSAR 13.7-1 REV. 18, APRIL 2010 13.7 INDUSTRIAL SECURITY LaSalle County Station implements and maintains in effect all provisions of the NRC-approved physical security, guard training and qualification, and safeguards contingency plans for LaSalle County Station in accordance with the operating licenses. The plans are specified in the following documents, as revised and filed with the NRC:

LaSalle County Station Security Plan LaSalle County Station Security Personnel Training and Qualification Plan LaSalle County Station Safeguards Contingency Plan These plans meet the requirements of 10 CFR 73.55, NRC Regulatory Guide 1.17, Appendices B and C to 10 CFR 73 and ANSI N18.17, - 1973.

Procedures to implement the LaSalle County Station Security Plan are developed to establish administrative requirements and responsibilities for the plant security program and to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant. These procedures are Security Manager written and remain under the cognizance of the Manager, Nuclear Security and the procedur es that contain Safeguards Information shall be withheld from public disclosure.

The security plan documents Safeguards Information protected under 10 CFR 73.21 and are, therefore, withheld from public disclosure.

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