ML20248E905
| ML20248E905 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/25/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20248E903 | List: |
| References | |
| NUDOCS 8910060098 | |
| Download: ML20248E905 (3) | |
Text
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UNITED STATES g
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.125 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By [[letter::BECO-84-116, Forwards Response to 840529 Request for Addl Info Re Multi- Plant Action F-55 (TMI Item II.K.3.28), Qualification of Automatic Depressurization Sys Accumulators, Per 10CFR50.54(f).GE Will Provide Addl Info by 841001|letter dated July 31, 1984]], the Boston Edison Company (the licensee) proposed changes to Technical Specifications (TS) 6.2.A, Offsite Organization, and 6.2.B, Facility Organization. The proposed changes would remove Figure 6.2-1, Boston Edison Company Organization for Management and Technical Support of Pilgrim Station, and Figure 6.2-2, Pilgrim Station Organization, and replace them with a narrative description of the offsite and onsite organizations functional requirements in TS 6.2.,A and facility staff qualifications in 6.2.B.
TS 6.2.C, changes to organization, which defines requirements for changing the organization and requesting a sub-sequent amendment is also deleted. Guidance for,these propcsed changes to the TS was provided to licensees and applicants by Generic Letter 88-06, dated March 22, 1988.
2.0 BACKGROUND
Consistent with the guidance provided in the Standard Technical Specifications 6.2.1 and 6.2.2 of the administrative control requirements have referenced offsite and unit (onsite) organization charts that are provided as figures to these sections. On a plant specific basis, these organization charts have been provided by applicants and included in TS issued with the operating license. Subsequent restructuring of either the offsite or unit organizations, following the issuance of an operating license, has required licensees to submit a license amendment for NRC approval to reflect the desired changes in these organizations. As a consequence, organizational changes have necessitated the need to request an amendment of the operating license.
The Pilgrim TS allowed changes to be made without prior license amendment provided that the NRC is notified in writing within 30 days and a revision to Section 6.2 is included in a subsequent license amendment request.
Because of these limitations on organizational structure, the nuclear industry has highlighted this as an area for improvement in the TS. The Shearon Harris licensee proposed changes to remove organization charts from its TS under the lead-plant concept that included the endorsement of the proposed changes by the Westinghouse Owners Group.
In its review of the Shearon Harris proposal, the staff concluded that most of the essential elements of offsite and onsite organization charts are captured by other regulatory requirements, notably, Appendix B to 10 CFR 50.
However, there 891006009s 890925 PDR ADDCK 05000293 f#
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i were aspects of the organizational structure that are important to ensure that the administrative control requirements of 10 CFR 50.36 would be met and that would not be retained.with the removal of the organization charts.
The applicable regulatory requirements are those administrative controls that are necessary to ensure safe operation of the facility. Therefore, those aspects of organization charts for Shearon Harris that were essential for conformance with regulatory requirements were added (1) to Specification 6.2.1 to define functional requirements for the offsite and onsite organi-zations and (2) to Specification 6.2.2 to define qualification requirements of the unit staff.
1 By letter dated Januar;r 27, 1988, the staff issued Amendment No. 3 to Facility Operating License NFP-63 for the Shearon Harris Nuclear Power Plant that incorporated these changes to their TS. Subsequently the staff developed guidance on an acceptable format for license amendment requests to remove the organization charts from TS. Generic Letter 88-06 provided this guidance to all power reactors.
3.0 EVALUATION The licensee's proposed changes to its TS are in accordance with the guidance provided by Generic Letter 88-06 and addressed the items listed below.
(1) Specifications 6.2.A and 6.2.B were revised to delete the references to Figures 6.2-1 and 6.2-2 that were removed from the TS. Specification 6.2.C changes to the organization, was deleted since changes in the organization will no longer require an amendment to the TS.
(2) Functional requirements of the offsite and onsite organizations were
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defined and added to Specification 6.2.A, and they are consistent with the guidance provided in Generic Letter 88-06. The specification notes that implementation of these requirements is documented in the Pilgrim Final Safety Analysis Report (FSAR).
(3) The senior reactor operator and reactor operator license qualified positions of the unit staff were added to Specification 6.2.B.
Therefore, this requirement that was identified on the organization chart for the unit staff will be retained. Therefore, this require-ment will be retained as a requirement following the removal of the organization chart for the unit staff.
(4) Consistent with requirements to document the offsite and onsite I
organization relationships in the form of organization charts, the licensee has confirmed that this documentation has been designated for inclusion to the next update of the FSAR.
1 (5) The licensee has confirmed that no specifications, other than those l
noted in item (1) above, include references to the figures of the I
organization charts that are being removed from TS for their plant.
Hence, this is not an applicable consideration with regard to the need to redefine referenced requirements as a result of the removal of these figures.
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3 ir On the basis of its review of the above items, the staff concludes that 1
the licensee has provided an acceptable response to those items as
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addressed in'the NRC guidance on removing organization charts from the administrative control requirements of the TS. Accordingly, the staff-
' finds the proposed changes to be acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S This amendment involves a change in administrative procedures or require-ments. The Comission has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in.10 CFR 651.22(c)(10).
Pursuant to 10 CFR $51.22(b), no environmental impact statement or environmental assessment need be prepared in. connection with the-issuance of the 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 the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission'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 Contributors:
T. Dunning D. Mcdonald Dated: SEP 2 5 1999
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