BECO-89-116, Application for Amend to License DPR-35,consisting of Changes to Tech Spec Section 6.0, Administrative Controls, Deleting Organization Charts & Specifying General Requirements,Per Generic Ltr 88-06

Application for Amend to License DPR-35,consisting of Changes to Tech Spec Section 6.0, Administrative Controls, Deleting Organization Charts & Specifying General Requirements,Per Generic Ltr 88-06

ML20248A883
Person / Time
Site:	Pilgrim
Issue date:	07/31/1989
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248A887	List: BECO-89-116, Application for Amend to License DPR-35,consisting of Changes to Tech Spec Section 6.0, Administrative Controls, Deleting Organization Charts & Specifying General Requirements,Per Generic Ltr 88-06 ML20248A898
References
BECO-89-116, GL-88-06, GL-88-6, NUDOCS 8908090047
Download: ML20248A883 (5)

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10CFR50.90 .

nosnwasm Pilgrim Nuclear Power station Rocky Hill Road Plymouth, Massachusetts 02360 I

l Ralph G. Bird BECo 89- 116 senior Vice President - Nuclear

.Tuly 31, 1989 U.S. Nuclear Regulatory Commission Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 L PROPOSED TECHNICAL SPECIFICATION CHANGE l TO SECTION 6.0: ADMINISTRATIVE CONTROLS Boston Edison proposes the attached changes to Section 6.0, " Administrative Control", of the Pilgrim Nuclear Power Station Technical Specifications in accordance with 10CFR50.90. The proposed change deletes onsite and offsite organization. charts, and specifies general requirements in place of the deleted charts. This proposed change is made in accordance with the guidance of NRC Generic Letter 88-06 of March 22, 1988.

The requested changes are described in Attachment A, the revised Technical Specification pages are in Attachment B, and the current Technical Specification pages, with the material deleted by the revision identified by

" balloons", are in Attachment C.

PMK/jcp/3134 Attachments 1 Signed Original and 37 Copies cc: See next page Commonwealth of Massachusetts)

County of Plymouth )

Then personally appeared before me, Ralph G. Bird, who being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company and that he is duly authorized to execute and file the submittal 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.

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U. S. Nuclear Regulatory Commission Page 2

• cc: Mr. D. Mcdonald, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission.

L1 White Flint North 11555 Rockville Pike Rockville, MD 02852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Robert M. Hallisey, Director

• Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Boston, MA 02111

ATTACHMENT A Prooosed Chanae The changes proposed to the Pilgrim Technical Specifications are made in accordance with the guidance provided in NRC Generic Letter 88-06 of March 22, 1988. The changes remove the Figures 6.2-1 and 6.2-2 in Section 6 depicting corporate and plant organizational charts, and specify general requirements in lieu of the deleted charts. These general requirements capture the essential aspects of the organizational structure defined by existing onsite and offsite organization charts.

Reason for Chance

.This change reflects the guidance of NRC Generic Letter 88-06 for the removal of onsite and offsite organization charts from Technical Specifications. It involves the addition of general requirements that capture the essential aspects of the organizational structure that are defined by existing organization charts.

Regulatory requirements for administrative controls in Technical Specifications are provided in 10CFR50.36. This regulation states that administrative controls are the provisions relating to organization and management necessary to ensure operation of the facility in a safe manner.

Boston Edison's experience has been that organization charts by themselves are of little help in ensuring the objectives of administrative control requirements are met. Specific operational requirements are required elsewhere in Technical Specifications that bear more directly on operational safety than organization charts. As examples, the organizational element responsible for the control room command function is identified separately in Technical Specifications, as are the requirements for minimum staffing under various operating conditions.

Details shown on the onsite and offsite organization charts are not essential to the safe operation of the facility and can be modified in many ways while maintaining adequate operational safety. Retaining only those items important to safety that are not covered by other specifications reduces the volume of Technical Specifications while maintaining safety. The change also reduces Boston Edison and NRC staff time and expense spent on processing changes to Technical Specifications when the organization changes.

Determination of No Significant Hazards The proposed amendment deletes organization charts 6.2-1 and 6.2-2 and makes administrative changes related to their deletion in accordance with the guidance provided by NRC Generic Letter 88-06 of March 22, 1988.

The Code of Federal Regulations, 10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis, using the standards in 10CFR50.92, about the issue of no significant l hazards consideration. Therefore, in accordance with 10CFR50.91 and '

10CFR50.92 the following analysis has been performed.

1. The operation of Pilgrim Station in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated. I

______________-___2._ . _ _ _ _ _

i The changes proposed to remove corporate and plant organization charts from the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated.

As stated in NRC Generic Letter 88-06, the requirements necessary for safe operation of the plant have been retained in the Technical Specifications; the changes do not eliminate or alter the functions previously reviewed; and the changes do not affect plant operation and design or create a new accident mode. The changes proposed were modeled after Enclosure 2 to NRC Generic Letter No. 88-06 in conformance with Commission requirements.

2. The operation of Pilgrim Station in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated because the proposed change is administrative in nature and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.

3. The operation of Pilgrim Station in accordance with the proposed amendment will not invo1~e a significant reduction in the margin of safety.

The proposed amendment does not involve a significant reduction in a margin of safety because Boston Edison, through its quality assurance programs, its commitment to maintain only qualified personnel in positions of responsibility, and other required controls, assures that safety functions will be performed at a high level of competence.

Therefore, removal of the organization charts from the Technical Specifications will not affect the margin of safety.

This change has been reviewed and approved by the Operations Review Committee, and reviewed by the Nuclear Safety Review and Audit Committee.

1Chedule of Change This change will be implemented within 30 days following Boston Edison's receipt of its approval by the Commission. ~

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ATTACHMENT B L

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