ML20054F773
| ML20054F773 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/08/1982 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-2.E.4.2, TASK-2.K.3.18, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-TM 82-168, GL-82-10, NUDOCS 8206170309 | |
| Download: ML20054F773 (5) | |
Text
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BOSTON EOlsON COMPANY DENERAL OFFICES S00 SOYLSTON STREET SO BTON. Mass ACN us ETTS O219 9 A. V. M O RISI MANAGER NUCLEAR OPERATIONS SUPPORT DEPARTMENT BECo. Ltr. #82-168 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conmission Washington, D. C.
20555 License No. DPR-35 Docket No. 50-293 Response to NRC Generic Letter No. 82-10 Post TM1 Requirements
Dear Sir:
The subject letter requested Boston Edison Company to establish firm schedules or reconfirm previously submitted schedules concerning implementation of the NUREG 0737 items identified in your letter as Enclosure.
For those items already com-pleted, no further information other than the date of completion was requested.
Conversely, proposed dates for completion of remaining items were requested along with the following information:
a) justification for proposed schedule, b) demonstration of need for proposed schedule and i
c) description of compensatory measures to be taken in the interim.
Attachment B outlines our response to the Subject NUREG items.
It must be noted that Boston Edison has previously responded on these items. Those responses are incorporated, by reference, in this letter as outlined in Attachment A.
Should you require additional information, beyond that provided in Attachment B to this letter, please contact us.
Very truly yours, s
Commonwealth of Massachusetts)
County of Suffolk
)
Then personally appeared before me A. Victor Morisi, who, being duly sworn, did state that he is Manager - Nuclear Operations Support of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the sub-f mittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
My Commission expires:d M F) M E _i Notary'(I'ublic 8206170309 820608 PDR ADOCK 05000293 Attachments A&B P
ATTACHMENT A REFERENCES (A)
BECo letter 80-318 dated December 31, 1980 (B) NRC Ltr. From D. B. Vassallo Dated March 31, 1982 (C) BBCo. Ltr. 82-56 to NRC Dated Feb. 15, 1982 (D) NBC LTR. Dated Jan. 7, 1982 to A. V. Morisi (E) BDCo. Ltr.81-200 Dated Aug. 24, 1981 (F)
BEro. Ltr. '80-57 Dated April, 7,1980 l
(G) NRC Ltr. Dated May 12, 1980 to G. C. Angdognini (II) BECo. Ltr. 81-99 Dated Aug. 20, 1981 (I)
BDCo. Ltr. 81-92 Dated May 8,1982 (J) BDCo. Ltr.82-158 Dated June 3, 1982 (K) BEro. Ltr.81-121 Dated June 1,1981 (L) BEro. Ltr. 81-37 Dated Feb. 11, 1981 1
1 1
e
ATDCINENT n Item I. A.l.3(1)
Limit Overtime Ref. A provided clarification to BECo's position regarding overtime restric-tions at PNPS. Ref. B acknowledged your staff's review and acceptance of BECo's position, however, this was based on a review of quoted correspondence prior to the Reference A clarification. Assuming this is merely an administrative over-sight on the part of your staff, we consider this item complete and plan no further action at this time.
In addition, please be advised that PNPS Procedure 1.3.17, which contained PNPS's overtime policy, was retired with the intention of incorporating PNPS's overtime policy into PNPS Procedure 1.3.34, however, the PNPS ovartime policy was inadvertantly omitted from Procedure 1.3.34.
Procedure 1.3.34 is being revised to reflect the overtime requirements of Procedure 1.3.17 and although the overtime policy is not currently procedurally addressed, the policy has remained in effect since its inception.
Its I. A. l. 3 (2)
Minimum Shift Crew Ref. D requested Boston Edison to respond to our ability to meet the implenentation schedule of July 1,1982. Based on our Review of Ref. C, we identified the need for a 12 week relief on our ccurmitment. It is now anticipated that Boston Edison will be able to meet the NBC Shift Manning Requirements by Sept. 17, 1982 Justificaticn and ccInpensatory measures have been outlined via Ref. C.
i It s I.C.1 Emergency Procedures Ref. E provided Boston Edison's Comnitment for implementation of the Revised Emergency Operating Procedures. We stated implementation will be met by the first refueling ccxmencing after Jan 1,1982. It is Boston Edison's intent to meet that ccrimitment.
It must be noted, however, our implementation is constrained by the guidance provided in NUREG 0737 which states:
"Ihe NRC staff will review the analysis and guidelines and determine l
their acceptability by July 1, 1981, and will issue guidance to licensees l
on preparing emergency procedures fran the guidelines. Following NRC approval of the guidelines, licensees and applicants for operating licenses issued prior to Jan. 1, 1982, should revise and impl ment their emergency procedures at the first refueling outage after Jan. 1, 1982."
Boston Edison endorses that staff's position for implementation and will not inpiment until NRC approval on the acceptability of the revised emergency l
procedure guidelines is provided. Dates for ccrupletion can not be deternuned until NRC staff approval is provided.
II.E.4.2 Containment Isolation Boston Edison inadvertently did not respond on this item in response to Generic Ietter 82-05. We are now providing the following information.
l
II.
E.4.2 (Continued)
~
Position 5 Ref. G Ref. F completeprovidedprcnided our the since my staff 's response rosition 7 15,1980 aconcurranceand justification f rbf. H nd no furtherwith this positionor the at set pri this time. providcd c action is planne. 'Ihis item has bent chang ur position d.
Jtem II.K.3.18 on this iten, and n en Ac tua tion o further ADS action is planned Ref.
satisfies the Subject NI provided our with UREG i tem. response on this it the BWR Owner's Gro II.K.3.30 and ll v 3 up which is Addi tiona lly, Bos toAccordingly, we beli em.
re evaluating th i SBL 0rp u,de ls.
31 n Edison is narticipati eve this e r posi s
tion n
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no further J provided our on this item.g Ref.
action response t
at Ill.A.l.2 this time on this item.
Iter i
until
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Sta f fing Levels fo review isThis item is your complete. complete, we plan Despite
_ r Em ergency Bos ton Edison 'the fact Situations s
tha t response to the response to this ithis is not a NUREG Upgrade Emergencacceptability of our 0737 ssue.
s ta ted pos i t ion.The licensee isitem, Referen Since theReference E y Support Facilities s till awaiting an NRC v ded capabilities havesubmissionprovided Boston Edi of advisory bodies.
undergonethat response the s on 's resoonse to the has iss82-111 which retoo i The culmina tionconsiderable review brequirements for subject NUR n
need forued in regards to thiszes the broad range of this review y the NRC, itsemergency response.
coordina t ion r
esponse initiatives and integrationcomplex issue. guidance documents thwas th of approach recommended i of SECY 82 SECY approval of Bos ton Edison the emergency preparednes111 also recognizes th at the NRC SEC Y 82-111 and a fin SECY 82-111 and awai response concurs with priate canabilities schedule for ities.
orovide ties nalizationts i s the flexible yet iand emergency s
e at current capabilthis time to and facili t
approval Bos ton Edison submitof requirem by the NRC.ntearated a prop,0 sed completio Upon tha t i t m ents for Absent a in ta insup rading if necessa g
approva l of emeraency SEC Y 82-111 n da te fors tha t it is inaporo-acceptable m item III. A ry,
- 2. 2 eans for in the interim the licensee upgrading our m
Me teo ro looical eeting this itemthe licensee has dprovide will a
Data As emon s t ra ted e3sur was described ement pro at PNPS-1to you in Referen 0 ft.s t rumen ta t ion,g ram ce K.
da ta acquisition hardwarethat includes twoBos ton Edison maint guy-wired meteorolo i tower and sofmeteoro locica l ains g cal e.
towersa meteorological which twar on the following measTh is pronrar, associated includes ure ents a
are m de:
a
III. A.2.2 (Continued)
Wind speed 33 ft. and 220 ft. elevations Wind direction 33 f t. and 220 f t. elevations Temperature 33 ft. elevation Delta Temperature 220 ft. - 33 ft. elevation The program also includes a 160 ft. free-standing tower on which similar i
measurements are made.
This tower serves as a backup to the 220 ft. tower.
Data processing equipment and backup calculation aids are provided in the Main Control Room and the Emergency Operation Facility that allow plant personnel to make rapid estimates of offsite dose rates and projected dosts based on real time meteorology (15 minute averages) and information on the magnitude of releases.of radioactive material from the plant as provided by effluent radiation monitors.
This system uses a Class A atmospheric dispersion model (straight-line Caussian dispersion) which includes terrain and building wake effects.
The ability to access the system from remote locations is provided so that offsite personnel can determine average atmospheric dispersion parameters, atmos-pheric dispersion estimates and estimated dose rates and doses.
The primary data processing system is capable of providing offsite dose estimates within 1 minute after input of effluent flow rates and radiat, ion monitor readings.
Two backup data processing methods are provided which are capable of using data from either the primary or secondary meteorological towers thereby providing high reliability.
The installation described above has been employed and evaluated during the PNPS emergency plan appraisal conducted from 7/13/81 to 7/21/81 and during the Joint Emergency Plan Exercise conducted on 3/3/82.
l It is the. position of Boston Edison that the installed systems provide adequate emergency response capability to ensure the protection of the health and safety of the pubiic in the event of an emergency situation at the Pilgrim Station.
BECo intends to defer additions to our present capability until the criteria recommended in SECY 82-111 are established as the definitive criteria by which emergency response capabilities will be intergrated, implemented, and eventually assessed.
III.D.3.4 Control Room Habitability l
Ref. L provided the details of the study for the Subject NUREG item. We feel adequate response has been provided and plan no further action at this time.
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