BECO-88-121, Revised Application for Amend to License DPR-35,consisting of Proposed Change 88-15,updating Administrative Controls Section of Tech Specs to Conform to Current Nuclear Organization

Revised Application for Amend to License DPR-35,consisting of Proposed Change 88-15,updating Administrative Controls Section of Tech Specs to Conform to Current Nuclear Organization

ML20151S526
Person / Time
Site:	Pilgrim
Issue date:	08/06/1988
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151S530	List: BECO-88-121, Revised Application for Amend to License DPR-35,consisting of Proposed Change 88-15,updating Administrative Controls Section of Tech Specs to Conform to Current Nuclear Organization ML20151S533
References
BECO-88-121, NUDOCS 8808150251
Download: ML20151S526 (6)

Text

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10CFR50.90

• < d BOSTON EDISON Pdgnm Nuciear Pov,er station Rocky Hill Road Plymouth, Massachusetts o2360 Ralph G. Bird BECo 88- 121 senior Vice President - Nuclear Proposed Change 88 '

U. S. Nuclear Regulatory Commission Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 -

PROPOSFD ADMINISTRATIVE TECHNICAL SPECIFICATION CHANGE CONCERNING PILGRIM STATION ORGANIZATI0ff

Dear Sir:

Pursuant to 10CFR50.90, Boston Edison Company proposes the attached amendment to Appendix A of Facility Operating License DPR-35 for the Pilgrim Nuclear Power Station. This proposed administrative change updates the administrative controls section of the Technical Specifications to conform with the current nuclear organization.

This proposed license amendment is a revision to the proposed amendment submitted by letter dated October 27, 1987 (TAC #665261, which is superseded in its entirety. As such, no additional license amendment application fee is provided.

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R. G. Bird DMV/amm/2141

Attachment:

Proposed Administrative Technical Specificas:on Change i Description Concerning Pilgrim Station Organization -

1 signed original and 37 copies I cc: See next page

! Commonwealth of Massachusetts)

County of Ply.nouth )

Then personally appeared bc ;re me, Ralph G. B1rd, who being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company and l that he is duly authorized to execute and file the submittal contained herein in the nama and on behalf of Boston Edison Ccmpany and that the statements in said submittal are true to the best of his knowledge and belief.

My commission expires: dAab//ff2 V/f6/). l

/ DATE' g(/ ' NOTARY PLIBLUT 8808150251 880806

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... .' BOSTON EDISON COMPANY U.LS. Nuclear Regulatory Commission e

Page 2-cc: Mr. D. G. Mcdonald, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Station Pl-137 Hashington, DC 20555 ,

U. S. Nuclear-Regulatory Commission Region I-475 Allendale Road-

-King of Prussia, PA 19406 -

Senior.NRC Resident Inspector Pilgrim Nuclear.. Power Station Mr. Ro'oert H. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Boston,~MA 02111

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- AiTACHHENT TO BECO LETTER 88- 121 PROPOSED ADMINISTRATIVE TECHNICAL SPECIFICATION CHANGE CONCERNING PILGRIM STATION ORGANIZATION Procosed Changes It is proposed that Pilgrim Nuclear Power Station (PNPS) Technical Specification Pages iii, 208, 208a, 209, 210, 212, 213, 216, 217, 226, and 227 be revised as shown on the attached pages and described below:

1. Technical Specification Figures 6.2-1 and 6.2-2 are to be revised to conform with the current nuclear organization at PNPS. These changes include the replacement of the Vice President - Nuclear Operations and Nuclear Operations Manager positions with a Station Director who holds overail responsibility for the safe operation of the facility, as stated in Technical Specification 6.1. The Operations Review Committee (ORC) reports to the now Station Director and the Quality Assurance and Emergency Preparedness Departments report directly to the Senior Vice President - Nuclear. In addition, the responsibilities of the departments reporting to the Station Director and the Vice President - Nuclear Engineering are restructured.

E. The ORC composition in Technical Specification 6.5.A.2 is revised to allow the Station Director to appoint in writing the ORC membership from appropriate plant disciplines, instead of listing the membership in Technical Specifications. The Pilgrim Station Organization in Technical Specification Figure 6.2-2 is revised accordingly to remove references to specific ORC members.

3. The canagement titles throughout Technical Specification 6.0 are revised to adopt those currently in in the nuclear organization.

Specifically, the following title c ,es are incorporated:

Former Title Ch m ed to New Title Vice President - Nuclear Operations Station Director or Nuclear Operations Manager Training Manager Nuclear Training' Department Manager Vice President - Nuclear Engineering Vice President - Nuclear and Quality Assurance Engineering Technical Section Pead Technical Section Manager Nuclear Operating Supervisors Nuclear Operations Supervisors Nuclear Plant Operators Nuclear Plant Reactor Operators Chief Operations Engineer Chief Operating Engineer Unit Health Physicist Radiation Protection Hanager Shift Foreman Nuclear Hatch Engineer 1 of 4 l

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4. The reporting requirements given in Specifications 6.5.A.6.i and 6.5.A.7.c for Technical Specification violations and ORC disagreements, respectively, are changed from the obsolete positions, Nuclear Operations Manager and Vice President - Nuclear Operations, to the Station Director and the Senior Vice President - Nuclear.

5. The authority for the approval of procedures in Specification 6.8 is changed from the obs'olete position, Nuclear Operations Manager, to the "responsible department manager."

6. Several editorial changes are made to correct the Table of Contents page numbers, correct punctuation, add appropriate page headers, spell out the acronym "NSRAC," renumber the items listed under Specification 6.10.8, and correct the spelling of "preset" in Specification 6.13.1.b.

Reason for Chances The current organization for the management and technical support of PNPS serves to strengthen plant operation by providing clearly-defined reportability and accountability. Specifically, the new Statica Director position provides clear accountability for the safe operation of Pilgrim Station, with direct control over the necessary station resources. This is balanced with an independent line of responsibility and authority through the Vice President - Nuclear Engineering for design evaluation and engineering.

The Quality Assurance and Emergency Preparednass Departments report directly to the Senior Vice President - Nuclear to ensure independence and the proper degree of management attention. Also, the departments reporting to the Station Director and the Vice President - Nuclear Engineering were restructured to provide for more even distribution of responsibilities and to provide the depth of managers needed to ensure the continuity of management.

Specifically, the organization supporting the Station Director was divided into four departments.

The Plant Department is responsible for operating and maintaining the plant, including plant operations, chemistry, maintenance, technical support, surveillance, and post-work testing.

The Plant Support Departmert is responsible for supporting the Plant Department in special activities, such as radiological control, security, industrial safety, fire protection, station facilities, and materials management.

The Planning and Outage Department also supports the Plant Department by managing major maintenance and modifications, post-modification testing, construction, scheduling, planning, and estimating.

The Nucitar Training Dapartment is responsible for the training of nuclear organization personnel, including general, technical, and operations training.

The organization supporting the Vice President - Nuclear Engineering consists of two departments.

The Nuclear Engineering Department provides engineering analysis and design support to the FNPS nuclear organization. It also provides support in the areas of site engineering, regulatory compliance, and licensing.

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., 1 The Nuclear Management Services Department is responsible for the management of all records produced by the nuclear organization.  !

l Technical Specification Figures 6.2-1 and 6.2-2 are revised to reflect the new nuclear organization currently in place at Boston Edison Company. The figures are revised to include only the same level of detail previously pro ~vided in the Technical Specifications and are not intended to depict the comp 1 Ce nuclear organization at Boston Edison Company. The Radiation Protection Manager was added to Figure 6.2-? to indicate reportability to the Radiation Section Manager, but with direct access to the Station Director. The dotted line of authority that linked the ORC and NSRAC on Figure 6.2-1.was deleted because it was ambiguous. The interface between the ORC and NSRAC is defined in Technical Specification 6.5 and remains unchanged. The title of Figure 6.2-1 was revised to agree more closely with Specification 6.2.A.

The ORC composition in Technical Specification 6.5.A.2 is revised to allow the Station Director greater flexibility in appointing ORC members, without affecting the range of expertise of ORC members. Technical Specification Figure 6.2-2 is revised accordingly to agree with this change.

Throughout Technical Specification Section 6.0, the management titles are revised as listed above to conform with the current nuclear organization at Boston Edison. The reporting requirements for Technical Specification violations and. ORC disagreements are expanded to includa both the Station Director and the Senior Vice President - Nuclear to encure the proper level of management attention. The authority for the approval of procedures in Specification 6.8 is revised to the "responsible department manager" to increase the accountability of individual managers for procedures in their functional areas. The editorial changes are made to correct previous errors and improve readability.

Safety Evaluation and Determination of No Sianificant Hazards Considerations In accordance with 10CFR50.91, the following analysis has been performed using the standards in 10CFR50.97, concern.ig the issue of significant hazards considerations.

1. Operation of PNPS in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment is an administrative change to the organization structure of PNPS management and technical support. The overall safety responsibilities and functions of the management staff are unchanged. The additional flexibility given the Station Director in appointing ORC members does not affect the overall qualifications and range of expertise of the ORC membership. Additional proposed changes serve to conform management titles to the current nuclear organization, ensure the proper level of management attention, increase the t.ccountability of individual managers for procedures in their functional areas, and improve readability through editorial corrections. Because no aspects of the nuclear organization that are important to safety are removed or diminished, the proposed amendment will not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Operation of PNPS in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

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The proposed amendment is administrative in nature and does not involve any changes to plant design or configuration. For this reason, it will not create the possibility of a new or different kind of accident.

3. Operation of PNPS in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The - proposed amendment does not remove or diminish any elements of the nuclear organization that are essential to the safe operation of PNPS. It does not involve any changes to plant operating systems or associated safety analyses. For these reasons, the proposed amendment will not involve a significant reduction in the margin of safety.

This change to the PHPS Technical Specifications does not present an unreviewed safety question as defined in 10CFR50.59. It has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Schedule of Chansa It is requested that the proposed amendment become effective immediately upon approval by the Commission, t

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