ML20137A390

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Safety Evaluation Supporting Amend 88 to License DPR-35
ML20137A390
Person / Time
Site: Pilgrim
Issue date: 08/14/1985
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20137A345 List:
References
NUDOCS 8508210399
Download: ML20137A390 (4)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 88 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

Effective January 1,1984, the Comission revised Section 50.72 of its regulations in 10 CFR Part 50, thereby modifying the immediate notification requirements for operating nuclear power reactors. At the same time, the Comission also added a new Section 50.73 which provides for a revised Licensee Event Report System.

Guidance concerning implementation of the requirements of these sections was provided to the licensees in Generic Letter 83-43, which was issued by the staff on December 19, 1983. Enclosed with the generic letter were model Technical Specifications showing the revisions to be made to the licensees' Technical Specifications.

In response to the Generic letter, the Boston Edison Company (BECo) has proposed appropriate changes to the Technical Specifications (TS) for the Pilgrim Station in a letter dated October 16, 1984.

. Additional changes to the TS Administrative Controls section were then proposed by BECo in a letter dated November 9,1984 to be consistent with several recent changes in the BECo organization and position titles. This request was modified by a letter dated February 8,1985, following discussions with the NRC staff.

We have reviewed the two above requests together in this Safety Evaluation because they both affect certain TS pages.

2.0 EVALUATION The following changes in the Pilgrim Technical Specifications are proposed:

1.

The term " reportable occurrence" would be replaced by " reportable event" in accordance with NRC guidance in GL 83-43.

2.

The reporting requirements in Sections 3.6.D.3, 3.9.B.1, 3.9.B.4 and 3.9.B.5 would be deleted. This is acceptable since these requirements are adequately addressed by 10 CFR 50.72 and 10 CFR 50.73.

3.

Section 3.9.B.2 would also be changed to delete the reporting requirement, but would require NRC notification within one hour when incoming power is not available form both startup and shutdown transformers and reactor operation is continuing at a reduced power level. This change is consistent with the requirenrnts of 10 CFR 50.72 and is, therefore, acceptable.

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. 4.

Throughout Section 6, the references to " Station Manager" have been changed to " Nuclear Operations Manager" to be consistent with a change in title for the on-site individual-in charge of the station.

We find this acceptable as there has been no change in responsibility for this position.

5.

Section 6.2.A - BECo has revised the company organization under the Senior Vice President Nuclear by deleting the functions of the Director of Operations Review and the On-Site Safety and Performance Group Leader. The staff previously reporting to On-Site Safety &

Performance Group Leader has been transferred to the Nuclear Operations Manager (see item 7 below). We find these changes acceptable as other organizational changes have obviated the need for these positions (see letter dated December 30, 1983, from William P.

Harrington, BECo to Dr. Thomas E. Murley, NRC Region I).

6.

Section 6.2.B - BEco has revised the Pilgrim Station Organization by establishing the new positions of Technical Section Head, to whom the Chief Technical Engineer and the On-Site Safety and Performance Group Leader now report, and of Chief Chemical Engineer. The Technical Section Head and the Chief Chemical Engineer report to the Nuclear Operations Manager. Figure 6.2.2 shows these changes and we find them acceptable.

7.

A new TS Section 6.2.C would be added which states that "changts may be made to the organization without prior license amendment provided that a revision to Section 6.2 is included in a subsequent license amendment request." The licensee currently is allowed by Sectim 6.9.B.2.e to report within 30 days "any changes in corporate or station organization as described in Section 6.2."

We find the change acceptable since that provision is-currently in the Technical Specification. However, the 30-day reporting of such changes should be retained. The licensee has agreed to insertion of the words "The NRC is notified in writing within 30 days and" following the word "that" in the proposed section 6.2.C.

8.

Section 6.5.A.2 - BECo proposes to revise the membership of the Operations Review Connittee (ORC). The Technical Section Head would be the Chairman instead of the Nuclear Operations Manager (formerly Station Manager), and the new position of Chief Chemical Engineer would be added to the committee composition. This change is acceptable as it meets the acceptance criteria of Section 13.4 of NUREG-0800 (Standard Review Plan).

9.

Section 6.5.A.3 - The statement concerning alternate members to the ORC would be revised deleting the phrase "However, no more than two alternates shall participate in an ORC quorum at any one time."

We find tnis change acceptable as the substance of the phrase is reinserted in Section 6.5.A.5 (see below).

. 10. Section 6.5.A.5 - The quorum requirements would be revised to read "a quorum of the ORC shall consist of the Chairman or designated alternate and a majority of members / designated alternates; however, no more than two alternates shall be allowed to meet quorum requirements."

We find this change acceptable as it meets the acceptance criteria of Section 13.4 of NUREG-0800 (Standard Review Plan).

11. Section 6.5.A.6 - BECo proposes:

(1) to revise the responsibilities of the ORC to include reports to the Nuclear Operations Manager; (2) to renumber some of the subsections; and (3) to add a new paragraph that states "The ORC Chairman may appoint subcommittees composed of personnel who are not members of ORC to perfonn staff work necessary to the efficient functioning of ORC."

We find these changes acceptable as they meet the acceptance criteria of Section 13.4 of NUREG-0800 Standard Review Plan.

12. Section 6.5.A.7 - BEco proposed to revise the authority of the ORC to read as follows:

Recomend in writing to the Nuclear Operations Mana or disapproval of items considered under 6.5.A.6(a)ger approvalthrough(d) a.

above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.A.6(a) through (d) above constitutes an unrevi.ewed safety question.

c.

Provide immediate written' notification to the Nuclear Operations Manager, the Nuclear Safety Review and Audit Committee and the Vice President - Nuclear Operations, of disagreement-between the ORC Members and the ORC Chairman. The Nuclear Operations Manager shall have ' responsibility for resolution for such disagreement.

We find this change acceptable as it conforms to ORC authority as described in the Standard Technical Specifications.

13. Section 6.5.A.8 - The records requirement for the ORC would be revised to add distribution to the Nuclear Operations Manager and the Nuclear Safety Review and Audit Comittee Chairman. We find this change acceptable as it increases the distribution of ORC records to important individuals.
14. Section 6.5.B.7.g - The responsibilities of the Nuclear Safety Review I

and Audit Committee (NSRAC) would be revised to include the review of "all events which are required by 10 CFR 50.73 to be reported to the NRC in writing." We find this change acceptable as it reflects changes to 10 CFR 50 and is consistent with the Standard Technical Specifications.

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r e 15. Section 6.6 - The reportable occurrence notification would be changed to be " pursuant to tha requirements of 10 CFR 50.72 or 10 CFR 50.73" and the title of this section would be changed to " Reportable Event Action". We find these changes acceptable as they reflect current regulations and the revised organization.

16. Section 6.7.B - Part 8 of this section on Safety Limit Violation would be revised to read "The Safety Limit Violation shall be reported to the Comission within one hour per 10 CFR 50.36(c)(6) and 50.72 and to the Nuclear Operations Manager and the NSRAC Chairman immediately."

We find this change acceptable as it provides the reporting described in Section 6.7 of the Standard Technical Specifications.

17. Section 6.7.D - Part D of this section on Safety Limit Violations would be revised to "the Safety Limit Violation. Report shall be submitted to the Commission within 30 days in accordance with 10 CFR 50.36(c)(7) and 50.73 and to the NSRAC Chairman and the Nuclear Operations Manager." We find this change acceptable since it confonns to the regulations cited.
18. Section 6.9.B concerning reporting requirements for reportable occurrences (events) would be deleted since it has been superseded by 10 CFR 50.73 which provides for a Licensee Event Report System.

3.0 Summary All of changes proposed by the licensee, as modified by the February 8, 1985 submittal, have been reviewed and we have found them acceptable, with the exception noted in item 7 above. As indicated in the evaluation of the proposed change therein, the 30-day notification of organizational changes will be retained.

4.0 ENVIRONMENTAL CONSIDERATION

S This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, this amendment meets 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 l

'of this amendment.

5.0 CONCLUSION

We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of th' public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

F. Allenspach and P. H. i.'ech Dated: August 14, 1985

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