ML20081E248

Application for Amend to License DPR-35,proposing Change 83-12 to Clarify Tech Specs Re Periodic Review of Station Procedures

ML20081E248
Person / Time
Site:	Pilgrim
Issue date:	10/31/1983
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20081E250	List: ML20081E248 ML20081E379
References
83-271, NUDOCS 8311020037
Download: ML20081E248 (3)

Text

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. =1 BOSTON EDISON COMPANY GOD BOvLsTON STRgtT BOSTON, M ASSACHUSETTs 0 219 9 WILLIAM D. HARRINGTON October 31, 1983 BECo 83-271 Proposed Change No. 83-12 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 License No. DPR-35 Docket No. 50-293 Proposed Administrative Technical Specification Change

Dear Sir:

Pursuant to 10CFR50.90, Boston Edison Company (BECo) hereby proposes the follow-ing modifications to Facility Operating License No. DPR-35, Appendix A.

Proposed Changes Reference is made to Section 6.8, " Procedures."

Currently, Item 6.8.B states:

"Each procedure and administrative policy of 6.8.1 above, and changes there-to, shall be reviewed by the ORC and approved by the ORC Chairman prior to implementation and periodically as set forth in station procedures."

The desired revision shall state:

"Each procedure of 6.8.A above, and changes thereto, shall be reviewed by the ORC and approved by the ORC Chairman prior to implementation. These procedures shall be reviewed periodically as set forth in administrative procedures.

NOTE: ORC review and approval of procedures for vendors / contractors, who have a QA Program approved by Boston Edison Company, is not required for work performed at the vendor / contractor facility.

This revision substitutes "6.8.A" for "6.8.1" to enhance specificity. Also, the word " reviewed" will precede the word " periodically", to clarify the mean-ing of the specification. The " NOTE" is added to clarify the role of ORC regard-ing the review and approval of vendor / contractor procedures. The basis for this 8311020037 831031 PDR ADOCK 05000293

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CD; TON ED20N COMPANY Mr. Domenic B. Vassallo, Chief Paga 2 section is to require Operations Review Committee (0RC) review and approval for i new and revised procedures prior to their implementation, and for the periodic review of existing procedures. The basis for the " NOTE" is that only those procedures that apply to safety related activities occurring at the facility (as described in Facility Operating License No. DPR-35, Section 2) are subject to ORC review.

Refer to the Attachments to this letter for the proposed marked-up Technical Specification pages.

Reason for Change The intention of the existing specification is to provide a periodic review of station procedures by those most qualified in the purview of the particular pro-cedure reviewed, and for those individuals to then determine what, if any, pro-cedural changes are required.

However, the current specification does not make this clear. A literal inter-pretation would create an extremely onerous and counterproductive burden for the ORC and its Chairman. The desired revision serves to clarify the speci*ication's intent, and removes any unnecessary burden from the ORC. Further, the revision more closely corresponds to the Standard Technical Specifications for BWR's (STS Administrative Controls, Section 6.8.2, Pg. 6-13).

The " NOTE" is added to further clarify the intent of paragraph 6.8.A and respond to the concerns raised in Item of Non-Compliance (INC) 83-13-02. INC 83-13-02 alleged that vendor procedures were not reviewed and approved as required by Technical Specifications Section 6.8. This change specifies which procedures shoald be reviewed and approved by ORC, and should eliminate confusion in this area in the future.

Acceptance of a contractor / vendor by our Quality Assurance Department as an approved supplier denotes that the supplier has an approved QA Program in place and is capable of performing safety-related or "0" activities. ANSI N45.2.13 and Regulatory Guide 1.123, to which BECo is committed by the Quality Assurance Program, provide guidelines to be used in selecting suppliers of items and ser-vices that affect the quality of Nuclear Power Plants. Once this selection is made further review and approval by the ORC is not deemed necessary.

Safety Considerations This proposed Technical Specification is not safety related. It has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Significant Hazards Considerations It has been determined that the amendment request involves no significant hazards consideration. Under the NRC's regulations in 10CFR50.92, this means that opera-

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COLTON EDCON COMPANY Mr. Domenic B. Vassallo, Chief Page 3 tion of the Pilgrim Nuclear Power Station in accordance with the proposed amend-ment would not (1) involve a significant increase in the probability or conse-quences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. -

The NRC has provided guidance concerning the application of standards for deter-mining whether license amendments involve significant hazards considerations by providing certain examples (48 FR 14870). One example of an amendment that is considered not likely to involve a significant hazards consideration is "...(i)

A purely administrative change to technical specifications:..." This proposed change is administrative in that it defines more clearly the intent and improves the efficacy of Section 6.8.B. as well as amending the wording to that of the Standard Technical Specifications. The addition of the clarifying " NOTE" does not decrease any margin of safety as defined in the Technical Specifications, therefore no significant hazards consideration is involved with this change.

Schedule of Change This change will be put into effect upon Boston Edison Company receipt of approval by the Commission.

Fee Determination Boston Edison Company proposes that pursuant to 10CFR170 this change is a Class II amendment. BECo Check No. 830426 in the amount of $2,400 was submitted to NRC in BECo Letter 83-254, dated October 11, 1983. Of that amount $1,200 was desig-nated toward this change and should be applied accordingly.

Should you have any questions or concerns regarding these proposed changes, please do not hesitate to contact us.

Very truly yours,  ;

TFF/ mat Attachments 1 signed original and 39 copies cc: Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Dept. of Public Health 600 Washington Street, Room 770 Boston, MA 02111

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