ML19262C707
| ML19262C707 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/04/1980 |
| From: | Gammill W Office of Nuclear Reactor Regulation |
| To: | Andognini G BOSTON EDISON CO. |
| Shared Package | |
| ML19262C708 | List: |
| References | |
| NUDOCS 8002150463 | |
| Download: ML19262C707 (4) | |
Text
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UNITED STATES f
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NUCLEAR REGULATORY CCMMISSION WASHINGTON, D. C. 20555
- j February 4,1980 Ihcket No. 50-293 Mr. G. Carl Andognini Boston Edison Company M/C NUCLEAR 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Andognini:
The Commission has issued the enclosed Amendment No. 40 to Operating License No. DPR-35 for the Pilgrim Nuclear Power Station.
This amendment consists of changes to the Technical Specifications in partial response to your requests dated July 6 and September 27, 1979. A related request dated December 27, 1977 was denied, as discussed below.
This amendment changes the Technical Specifications to (1) update Table 3.6.1 for safety related snubbers, (2) revise the station organization chart and the Operations Review Comittee (ORC) composition, (3) reduce the response time requirement for ADS, (4) provide an alternate method of demonstrating reactivity margin, (5) add calibration and test f requencies to the IRM, Hi.gh Flux Instrument Channels, and (C remove the power restriction requirement for testing MSIV closure times.
Also included in your submittals were requests to (1) change the method of calibrating the average power range monitoring ( APRM) system, and (2) reduce the duration of the Integrated Primary Containment Leak Rate Test (IPCLRT) f rom 24 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. These two requests cannot be approved at this time.
The ba_is for our decision is detailed below.
The essential change in the method for calibrating the APRM system was to introduce a f alse gain characteristic to compensate for core peaking f actors.
We found that your submittal did not provide sufficient information to demonstrate how the revised APRM calibration procedure satisfies Paragraph 4.20 of IEEE Std. 279-1971.
Specifically, the staff is concerned that the proposed practice of purposely introducing a f alse calibration may result in a condition where-in the operator will not be provided with accurate, complete, and timely information pertinent to APRM status and generating station safety.
Therefore, this change cannot be supported by the staff.
The staff is presently in the process of developing criteria for reviewing the change concerning duration of IPCLRT.
At this point, a schedule for developing the criteria is not available, due to the relatively low priority of this task.
However, personnel are Deing assigned and a schedule will be developed. We will advise you of the schedule when it is available, and will provide you with the criteria when it is developed. A Technical Specification chang will be issued when we have determined your submittal meets the review cri teri a.
8002150 i
Mr. G. Carl Andognini Your letter dated December 27, 1977 requested a change to the Administrative Controls Section of the Technical Specifications to allow the individual performing the function of the Radiation Protection Manager to be located either on-site or off-site. We have reviewed your submittal and determined that your request cannot be approved, for the following reasons.
Regulatory Guide 8.8, Revision 2, Section C.l.b.(3) states that the Radiation Protection Manager (onsite) should have qualifications as presented in Regulatory Guide 1.8.
The word "onsite" was purposefully added to the section on " Personnel Qualification and Training" of Regulatory Guide 8.8, Revision 1 so that the staff would have some basis for confidence that well trained and experienced radiation protection personnel (as described in Regulatory Guide 1.8) would be imediately available to onsite personnel to ensure that their exposures under normal and accident conditions were kept "as low as reasonably achievable" ( ALARA).
Although the qualifications of the RPM in Regulatory Guice 1.8 does not attest to his competency or expertise, it does provide a basis for assuHng that the individual assigned that job responsibility is a knowledgeable arofessional who can provide the supervision necessary to implement the Jrogram required for radiation protection.
The practical requirement for "onsite" RPM management is that radiation protection management, surveillance, and dose monitoring may be maintained.by qualifiea health physics pcysonnel during day-to-day plant operations."Tne onsite Radiation Protection Manager is also supported by onsite plant management.
Together they must have a day-to-ddy working relationship in order to (1) implement the station ALARA program effectively, (2) resolve site specific questions relating to the ALARA program, (3) effectively handle emergency situati:;rs involving overexposed or contaminated site personnel, and (4) provide expertise in decision-making with respect to accidents that may have a potential for release of radioactive materials to the environment.
The onsite RPM must be reac(y to imediately advise plant management on dach of the aforementioned items with little or no offsite interaction. The onsite RPM would also have a " feel" for difficult operational / maintenance programs of which an offsite person would have only secondhand knowledge.
- Finally, Regulatory Guide 8.8 has recently been reviewed by industry at which time no coment was made with respect to the "onsite" RPM meeting the qualifications of Regulatory Guide 1.8.
Accordingly, your request regarding the location of the RPM is denied.
This position has been discussed with and understood by members of your staff.
Mr. G. :arl Andognini Copies :f t e Safety Evaluation and the Nr. ice of Issuance are also enclose:.
Si ics ely, hb.
Willinn P. Garrnill, Acting Assistant Jirictor for Operating Reactor Projects Di vis or. cf Operating Reactors Enclost es:
1.
Anecce-t No. 40 to OPR-35 2.
Safity Ivaluation 3.
Norce cc w/etcl os.res:
see ner. ca;e e :L ~
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Mr. G. Carl A'ndognini Boston Edison Company
-4 cc:
Mr. Paul J. McGuire U. S. Environmental Protection Pilgrim Station Acting Manager Agency Boston Edison Company Region I Office RFD #1, Rocky. Hill Road ATTN:
EIS C0ORDINATOR Plymouth, Massachusetts 02360 JFK Federal Building Boston, Massachusetts 02203 Anthony Z. Roisman Natural Resources Defense Council Energy Facilities Siting Council 91715th Street, N. W.
14th Floor Washington, D. C.
20005 One Ashburton Place Boston, Massachusetts 02108 Henry Herrmann, Esquire Massachusetts Wildlife Federation 151 Tremont Street Boston, Massachusetts 02111 Plymouth Public Library North Street Plymouth, Massachusetts 02360 Massachusetts Department of Public Health ATTN:
Commissioner of Public Health 600 Washington Street
' Boston, Massachusetts 02111 Water Quality & Environmental Commissioner Department of Environmental Quality Engineering 100 Cambridge Street Boston, Massachusetts 02202 Mr. David F. Tarantino Chaiman, Board of Selectmen 11 Lincoln Street Plymouth, Massachusetts 02360 Director, Technical Assessment Division i Office of Radiation Programs (AW 459) i US EPA Crystal Mall #2 Arlington, Virginia 20460 hW