ML20236F794

Safety Evaluation Supporting Amends 128 & 113 to Licenses NPF-11 & NPF-18,respectively

ML20236F794
Person / Time
Site:	LaSalle
Issue date:	06/26/1998
From:	NRC (Affiliation Not Assigned)
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Download: ML20236F794 (7)

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4 UNITED STATES s

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 l

4 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.128TO FACILITY OPERATING LICENSE NO. NPF-11 AND AMENDMENT NO.113 TO FACILITY OPERATING LICENSE NO. NPF-18 COMMONWEALTH EDISON COMPANY LASALLE COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

1.0 INTRODUCTION

By letter dated May 27,1997, as supplemented on August 1,1997, and March 24,1998, Commonwealth Edison Company (Comed, the licensee) proposed to modify the LaSalle County Station, Units 1 and 2, Technical Specifications (TS). The proposed changes would revise Technical Specification Section 6, " Administrative Controls," to incorporate revised organizational titles and delete Facility Operating License Condition 2.C.(30)(a). In addition, the licensee proposed to change the submittal frequency of the Radiological Effluent Release Report from semiannually to annually and make several administrative and editorial changes. Additional editorial changes that were not requested in the May 27,1997, August 1,1997, or March 24, 1998, letters are included. These changes correct typographical errors in the TS pages that were transmitted to Comed with previous license amendments. The August 1,1997, submittal did not change the initial proposed no significant hazards consideration determination. The March 24,1998, submittal changed the scope of the original Federal Register Notice and the proposed amendment was renoticed on May 20,1998.

2.0 EVALUATION

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2.1 Changes to organizational titles TS Section 6.0, " Administrative Controls" contains the roles and responsibilities of plant organizations and management. The licensee has proposed several changes to this section to reflect a revision to the station organization and resulting new titles for the positions discussed below.

Plant General Manaaer The current TS 6.1.A.2 states 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 position is titled Plant General Manager. The licensee has requested that the title in TS 6.1.A.2 be replaced with the phrase "The individual filling the ANSI N18.1-1971 Section 4.2.1 position of Plant Manager

(" Plant Manager")." The proposed wording will give the licensee the flexibility to revise the title of the individual filling this position in the future. The current Plant General Manager meets the qualifications defined for

• Plant Manager"in Section 4.2.1 of ANSI N18.1-1971. Plant procedures and the Comed Quality Assurance Program (Topical Report CE-1-A) will reflect the current title P

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2 of the individual filling this position. TS Sections 6.1.C.5 and 6.2.C are modified to change Station Manager to Plant Manager, as defined in TS 6.1.A.2.

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Shift Manacer Current TS 6.1.B states that the Shift Supervisor shall be responsible for directing and commanding the overall operation of the facility on his shift. In the revised organization, the person with this responsibility is titled the Shift Manager. The Shift Supervisor / Engineer position and Shift Manager position both meet the qualifications defined for" Supervisors Requiring AEC Licenses"in Section 4.3.1 of ANSI N18.1-1971. Other TS affected by this title change are 6.1.C.1,6.1.C.4, Figure 6.1-3, and 6.1.1.3. Current TS 6.5.A.6 requires that Shift Engineers' logs must be retained for at least 5 years. The Shift Engineer position in the current TS is equivalent to the Shift Supervisor as stated in the Notes to current TS Figure 6.1-3. Therefore, TS 6.5.A.6 will be revised to require that the Shift Manager logs be retained for at least 5 years.

Manaoer of Quality and Safety Assessment The current TS include the term " Site Quality Verification Director." TS 6.1.C.5 requires that the independent Safety Engineering Group shall make recommendations to the Site Quality Verification Director, in the revised organization, this position is called the Manager of Quality and Safety Assessment. The licensee proposes to change this title in TS 6.1.C.5.

Shift Technical Advisor Current TS 6.1.C.6 states that the Station Control Room Engineer (SCRE) may serve as the Shift Technical Advisor (STA) during abnormal operating and accident conditions and states the duties of the SCRE or STA during these conditions. The SCRE position consisted of an individual licensed at the SRO level who also served as the STA. The SCRE was included as part of the control room staff to serve as the designated SRO to assume the control room direction function (as required by TS) and serve as the STA. In the revised organization the control room direction function is fulfilled by a Unit Supervisor. The licensee has eliminated the SCRE position. The revised TS 6.1.C.6 will state the duties of the STA during abnormal operating or accident conditions. The current TS allows for either an on-duty STA or a SCRE to fulfill the TS minimum shift crew composition. The proposed TS does not add any new requirements or delete existing requirements. The proposed wording of the revised TS is consistent with the BWR/6 Standard Technical Specifications. The TS requirement to have a SCRE included in the control room staff will be changed to an STA. Proposed TS Figure 6.13 will add the requirement that the STA position shall be filled by an individual who meets the qualifications specified in the Commission Policy statement on Engineering Expertise on Staff. This is consistent with the Standard Technical Specifications and with the guidance in Regulatory Guide 1.8, " Qualification and Training of Personnel for Nuclear Power Plants."

The license for LaSa!!e Unit 1 currently contains a license condition 2.C.(30)(a) that states: "The Shift Technical Advisor (STA) function shall be fulfilled by the Station Control Room Engineer (SCRE) who will be a designated SRO. However, if a SCRE is not available, the licensee shall provide a fully-trained on-shift technical advisor to the shift engineer (shift supervisor)." This license condition was included because a SCRE was normally used to fill the STA function rather than a dedicated STA. The license condition ensured that the SCRE held an SRO license because he was not specifically trained as an STA. Because the SCRE position is being eliminated, the licensee proposes to delete this license condition. The STA position in the revised organization is not required to hold an SRO license. The proposed TS ensure that the

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. de.fgnated STA will meet the NRC-required training and qualifications. Therefore, the license condition is no longer necessary and its deletion is acceptable.

- The licensee also proposes to delete TS 6.1.C.6.a-c. These specifications describe the requirements for SCRE tumover and communications between the shift engineer, shift foreman, and the SCRE regarding plant status. These requirements were included in the TS to address possible disadvantages of the combined SCRE/STA position as described in the LaSalle Safety Evaluation Report, NUREG-0519, dated March 1981. Because the licensee no longer utilizes a SCRE, these requirements are not necessary and may be deleted.

Shift Crew Composition TS Figure 6.1-3 provides the requirements for minimum shift crew composition. The proposed TS will replace the current figure with a revised table. The revised table reflects the total requirements for both units whereas the current TS reflect staffing for only one unit. The requirements are consistent with the current TS, however, the titles have been changed to reflect the revised organization as discussed above. An additional title change, shift foreman to Unit supervisor, does not affect any other TS, but is included in Figure 6.1-3. The proposed staffing requirements are consistent with the requirements of 10 CFR 50.54(m)(2). The proposed TS is an enhancement of the current TS as it provides an additional requirement that relief operators be trained for both units or a relief operator must be provided for each unit.

Conclusion All individuals filling positions within the revised organization satisfy the required educational and i

experience qualifications commensurate with their responsibilities. The titles in the proposed TS are consistent with those listed in the Comed Quality Assurance Program Topical Report CE-1-A Revision 65h which was submitted to the NRC by letter dated January 26,1998. Therefore, these proposed changes to the TS are administrative and are acceptable.

2.2 Radioactive Effluent Report Submittal Frequency TS 6.6.AA provides the requirements for submittal of a Semiannual Radioactive Effluent Release 1

Report. The licensee proposes to submit this report annually as opposed to semiannually. The i

i current TS is based on the requirements of 10 CFR 50.36a that were in effect prior to August 31, l-1992. On August 31,1992, a rule was published in the Federal Renister revising 10 CFR l

50.36a to relax the frequency at which radiological effluent reports are required to be submitted.

l 10 CFR 50.36a currently requires that licensees submit a report annually that specifies the

- quantity of each of the prine,ipal radionuclides released to unrestricted areas during the previous i

12 months. The current TS 6.6.A.4 requires that the report be submitted within 60 days after January 1 and July 1 of each year. The licensee proposes to revise the TS to require that the annual report be submitted prior to May 1 of each year. The report title change from

" Semiannual" to " Annual" also affects TS definition 1.27 and TS 6.8.2.c. The proposed change is consistent with the requirements of 10 CFR 50.36a and is, therefore, acceptable.

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e e 2.3 Miscellaneous Changes to Section 6.0 A. Duties of Shift Supervisor Technical Specification 6.1.B states that a management directive which emphasizes the primary responsibility for safe operation and clearly establishes the command duties of the Shift Supervisor shall be issued to all station personnel on an annual basis. This requirement resulted g

from LaSalle's implementation of the requirements in NUREG-0737," Clarification of TMI Action Plan Requirements" section I.A.1.2, Shift Supervisor Administrative Duties. The TS will continue to require that the Shift Supervisor (with the title changed to Shift Manager per this amendment) be responsible for directing and commanding the overall operation of the facility on his shift and that his primary responsibility shall be for safe operation of the nuclear facility on his shift. The requirement to issue an annual management directive is an administrative requirement which has no effect on the safe operation of the facility and its removal from the TS is acceptable. This change is consistent with the Standard Technical Specifications for General Electric Plants, B W R/6.

B. Changes to ODCM Technical Specification 6.6.A.5,

• Monthly Operating Report," 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. The licensee proposes to delete this requirement from TS because it conflicts with another TS requirement. TS 6.8.2.c requires that licensee initiated changes to 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 Semiannual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made effective. The requirement to submit changes to the ODCM concurrent with the Semiannual Radioactive Effluent Release Report is consistent with the guidance of Generic Letter 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications." Because there are no regulations that specify that changes to the ODCM be submitted monthly and the current requirement in TS 6.8.2.c is consistent with the Standard Technical Specifications, the proposed change is acceptable. It is noted that, per the previous change to TS 6.6.A.4, the Radioactive Effluent Report will now be submitted annually as opposed to semiannually and, therefore, changes to the ODCM will also be submitted annually. This change meets the intent of GL 89-01 to have these reports submitted concurrently and is, therefore, acceptable.

C. Qualifications of Station Personnel Technical Specification 6.1.C specifies the required ANSI qualifications for the Systems Engineering Supervisor and Operations Manager. The TS states that the Systems Engineering Supervisor must meet the minimum acceptable level for " Technical Manager" and the Operations Manager must meet the minimum acceptable level for " Plant Manager" as described in ANSI N18.1-1971. The licensee proposes to delete this por: ion of the TS and relocate the requirements to the Updated Final Safety Analysis Report (UFSAR) and station administrative procedures. TS 6.1.D will continue to require that station management and operating staff meet the minimum acceptable levels as described in ANSI N18.1. The ANSI N18.1 equivalent titles for LaSalle positions are specified in UFSAR section 13.1 and will be contro!!ed by the provisions of 10 CFR 50.59. The UFSAR states that the Operations Manager meets the ANSI N18.1

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. qualifications for Plant Manager and that either the Operations Manager or the Shift Operations Supervisor will meet the qualifications of Operations Manager. ANSI N18.1-1971, Section 4.2.2, states that the Operations Manager shall hold a Senior Reactor Operator's License while the

' ANSI N18.1 qualifications for Plant Manager do not require an SRO license. Although the TS 6.1.D requirement that the licensee meet ANSI N18.1 would require that the Operations Manager hold an SRO license, the staff approved a change to the TS (TS 6.1.C.8) on October 20,1995, that allows either the Operations Manager or the Shift Operations Supervisor to hold an SRO license. The staff had concluded that the holding of an SRO license by either the Operations Manager or Shift Operations Supervisor ensures that a licensed off-shift senior operator is directing the licensed activities of the licensed operators. Therefore, the proposed TS will require that the Operations Manager meet the qualifications of Operations Manager in ANSI N18.1, but does not require an SRO license provided the Shift Operations Supervisor holds such a license.

This change is acceptable.

D. Qualifications of Procedure Reviewers - TS 6.2.C.2 Technical Specification 6.2.C.2 requires that personnel performing technical reviews of procedures identified in TS 6.2.C shall meet the applicable experience requirements of ANSI N18.1-1971, Sections 4.2 (Managers) and 4.4 (Professional-Technical) and be approved by the Station Manager. The licensee proposes to revise this TS to permit individuals meeting the requirements of ANSI N18.1-1971, Sections 4.3,4.5.1, and 4.6 to perform these reviews as well.

This change would allow supervisors, operators, and technical support personnel, in addition to the currently allowed positions, to perform technical reviews of procedures identified in TS 6.2.A and 6.2.B, thereby providing for additional expertise at the station to be utilized. 10 CFR 50 Appendix B, Criterion VI, requires that changes to procedures be reviewed for adequacy and approved for release by authorized personnel and that the changes be reviewed and approved by the same organization that performed the original review and approval unless the licensee

- designates another responsible organization. The regulations do not specify the qualifications of personnel performing these reviews, therefore, it is the licensees' responsibility to determine which positions it will utilize. The remainder of TS 6.2.C will not be changed and the requirements for the content of the reviews, approval authority, and records of reviews will continue to ensure that procedures receive adequate reviews. The proposed change will allow additional expertise to be utilized in the procedure review process and will not affect plant safety.

Therefore, the proposed change is acceptable.

E. Fire Brigade Members - TS 6.1.C.4 Technical Specification 6.1.C.4 states that the Fire Brigade shall not include the Shift Supervisor, the SCRE and the two other members of the minimum shift crew necessary for safe shutdown of the unit. The licensee proposes to revise this TS based on the revised organizational titles.

Because this section of the TS was deleted by amendment numbers 127 and 112 on June 10, 1998, the proposed changes are not necessary.

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e l 2.4 Editorialchanges A. Meteorological Tower Location - TS 5.5 Technical Specification 5.5.1 states that the meteorological tower shall be located as shown on Figure 5.1.1-1. Figure 5.1.1-1, " Exclusion Area and Site Boundary for Gaseous and Liquid Effluents," does not include the location of the meteorological tower. This error has existed since initial licensing. The figure showing the tower location is located in the Offsite Dose Calculation Manual. The licensee proposes to delete TS 5.5.1 since it has determined that the requirements for the tower are not a TS requirement. A description of the meteorological measurements program is included in UFSAR Section 2.3.3.1, which states that the tower conforms with the recommendations of Regulatory Guide 1.23 and ANSI /ANS 2.5. The proposed change is consistent with the Standard Technical Specifications which does not include requiremer,ts for the meteorological tower. The location of the meteorological toweris adequately controlled by the provisions of 10 CFR 50.59 and, therefore, the deletion of this TS is acceptable.

B.' Reference to Emergency Procedures - TS 6.2.E Technical Specification 6.2.E requires that drills of the emergency procedures described in TS 6.2.A.4 shall be conducted at frequencies as specified in the Generating Stations Emergency Plan. The reference to TS 6.2.A.4 is incorrect as there is no Specification 6.2.A.4. The correct reference is TS 6.2.A.d which requires that written procedures be established, implemented, and maintained covering Generating Station Emergency Response Plan implementation. This change corrects a typographical error and is acceptable.

C. Technical Specification Headers The headers of Urtit 2 Technical Specification Chapter 6 pages 6-2,6-3,6-15,6-22,6-23,6-24, 6-27, and 6-281 fohectly c'de, " Administration Controls." The headers should state

" Administrative Controls." Tn'is change corrects a typographical error and is acceptable.

D. Submittal of Special Reports - TS 6.6.C.1 Technical Specification 6.6.C.1, " Unique Reporting Requirements," requires that special reports be submitted to the Director of the Office of Inspection and Enforcement (Region Ill). Because the title " Director of the Office of Inspection and Enforcement is no longer used, the licensee proposes to revise this TS to require the reports to be submitted to the Regional Administrator of the NRC Regional Office. This change is administrative in nature and is acceptable.

E. Distribution of Monthly Reports - TS 6.6.A.5 Technical Specification 6.6.A.5, " Monthly Operating Report," requires that 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 Regional Office. The licensee proposes to revise this TS 1

to require that the report be submitted to the addressees specified in 10 CFR 50.4.10 CFR 50.4(b) requires that all applications for amendments, reports, and other written communications from the licensee to the NRC must be addressed to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, DC 20555 with one copy to the appropriate Regional

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Office and one copy to the NRC Resident inspector. The requirement that the monthly report be i

distributed in this way is consistent with Standard Technical Specifications. This change will ensure that reports are sent to the appropriate parties and eliminates the need for future license amendments to reflect future changes to 10 CFR 50.4. This change is acceptable.

F. Corrections to Previously issued Amendments By letter dated September 14,1988, the licensee requested a change to the TS for LaSalle, Unit 2, that was approved on January 6,1989. The licensee's submittal contained a proposed l

change to TS 3.3.4.2 action e. As indicated in the licensee's mark-up, the words *Otherwise, I

either;" should have been inserted after the directions to restore at least trip system to operable l

status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The TS page that was issued with the amendment inadvertently left out I

these words. The staff approved the changes as proposed by the licensee as indicated by the i

associated safety evaluation.

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Index page XIV for Units 1 and 2 contain incorrect page numbers for Bases Section 3/4.6.4,

' Vacuum Relief" The correct page number is B 3/4 6-4a. Also, the correct page for Bases Section 3/4.6.1, " Primary Containment Air Locks"is B 3/4 6-1a for Unit 1. These changes are editorial errors in pages that were transmitted with previous license amendments.

3.0.

STATE CONSULTATION I

in accordance with the Commission's regulations, the Illinois State official was notified of the-l proposed issuance of the amendments. The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

i The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff i

has determined that the amendments involve no significant increase in the amounts, and no l

significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding I

(63 FR 27759). Accordingly, the amendments meet the eligibility criteria for categorical exclusion i

set forth in 10 CFR 51.22(c)(9). This amendment also relates to changes in recordkeeping reporting or administrative procedures or requirements. Accordingly, with respect to these items, j

the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: D. Skay Date: June 26, 1998 i

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