ML20012C650

Responds to Generic Ltr 90-01 Re Request for Voluntary Participation in NRC Regulatory Impact Survey.Completed Questionnaire for Applicable Areas Delineated in Survey Encl

ML20012C650
Person / Time
Site:	Pilgrim
Issue date:	03/15/1990
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-90-040, BECO-90-40, GL-90-01, GL-90-1, NUDOCS 9003230001
Download: ML20012C650 (14)

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Le 80570NEDd50N Pilgrim Nuclear Power Station

. Rocky Hill Road Plymouth. Massachusetts 02360 1

Ralph G. Bird SeniorVice President - Nuclear BECo 90-040 March 15 199'O U.S. Nuclear Regulatory Commission Document Control Desk )

Hashington -DC 20555 1 License DPR-35 Docket 50-293 RESPONSE TO GENERIC LETTER 90-01 REQUEST FOR VOLUNTARY PARTICIPATION IN NRC REGULATORY IMPACT SURVEY This letter submitts Boston Edison's response to Generic Letter 90-01. Our response incorporates guidance provided by NUMARC in a letter to the NUMARC Board of Directors dated February 16, 1990.

Attachment 1 is a completed questionnaire for the applicable areas delineated in the survey. Some of the areas were grouped together because the inspections occur concurrently while others were listed separately depending on the nature of the inspection. For example the U. S. EPA National Pollutant- a Discharge Elimination System Permit inspection takes place in conjunction with the Massachusetts. Division of Hater Pollutant Control inspection.  !

He appreciate the opportunity to provide this information to the_NRC to aid in the regulatory process. If there are any questions regarding our response please contact our Licensing Staff.

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. . rd .1 BRS/jcp/4128 I cc: Mr. M. Fairtile, Project Manager 4fE23 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation n Mail Stop: 14D1 oso U. S. Nuclear Regulatory Commission CE@ 1 White Flint North Q8 11555 Rockville Pike gug Rockville, MD 02852 f(3 U. S. Nuclear Regulat]ry Commission oo Region I P90 475 Allendale Road f9 King of Prussia, PA 19406 o ct ,

1 S$a. Senior NRC Resident Inspector l Pilgrim Nuclear Power Station f l Il I

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ATTACHMENT 1 Questionnaire Sheets (12 pages) i i

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Attachment 1 j" Page 1 of 12 NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

INPO Plant Evaluation

2. Based on actual experience over the past several years, about how often is this activity conducted? Annually

3. Operations / Construction areas covered:

Standard INPO evaluation areas.

4. Extent of the activity (how may people, for how long)

Twenty evaluators for ten workina days.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours

a. Plant Department Heads 2000_ (number involved) 10

b. Plant Manager ]lL

c. Corporate Department Heads .,_10_ (number involved) 1

d. Corporate Vice Presidents 100_ (number involved) 3_

e. Chief Nuclear Officer lfiO_

f. Managers / Supervisors 32fiO_ (number invohed) .,_?Ji_

Attachment 1 Page 2 of 12 NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation: NRC-Reauired OA Audit

2. Based on actual experience over the past several years, about how often is this activity conducted? Four times averaae oer year

3. Operations / Construction areas covered: Radioloaical. Fire Protection.

Health Physics. Emergency ODeratina Procedures.

4. Extent of the activity (how may people, for how long) 2 insocetors oer insoection.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours

a. Plant Department Heads 50 (number involved) I

b. Plant Manager -

c. Corporate Department Heads 4 (number involved) 1

d. Corporate Vice Presidents 4 (number involved) 1

e. Chief Nuclear Officer -

f. Managers / Supervisors 64 (number involved) 2 l

l Attachment 1 Page 3 of 12 HRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation: ANI inspection ,

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2. Based on actual experience over the past several years, about how often is this activity conducted? Twice a year

3. Operations / Construction areas covered: Inservice Insoection. Fire Protection ,

4. Extent of the activity (how may people, for how long) 1 inspector oer inspection for two days for the Inservice Insoection.

For fire protection the insoection consists of 2 insoectors for anorox- ,

imately 6 days Der year.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours l a. Plant Department Heads _2Q__ (number involved) 2

b. Plant Manager -

c. Corporate Department Heads 18 (number involved) 2 l

L d. Corporate Vice Presidents 2 (number involved) 1 l

l e. Chief Nuclear Officer -

Managers / Supervisors

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f. 398 (number involved) 9 l

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Attach:ent 1 Page 4 of 12 NRC REGULATORY IMPACT SURVEY WESTIONNAIRE SHEEI

1. Type of inspection, audit or evaluation: Unannounced U.S. EPA and Massachusetts Division of Water Pollution Control for National Discharae Elimination System (NPDES) _.

2. Based on actual experience over the past several years, about how often is this activity conducted? 1.) Environmental monitorina conformance is evaluated annually and 2 unannounced insoettions in last ten years.

2.) OA of chemistry analvtical accuracy _Derformed annually.

3. Operations / Construction areas covered: Marine environmental monitorina.

liauid/chemistrv discharoe. Chemical analysis.

4. Extent of the activity (how may people, for how long) 1.) Environmental monitorina consists of an annual evaluation with two evaluators for one week and an annual unannounced insoection by 2 insoectors for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each. 2.) OA of chemistry analvtical accuracy is performed by mail.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Houti

a. Plant Department Heads 2 (number involved) 1 l b. Plant Manager 1

c. Corporate Department Heads 2 (number involved) __.1 l

d. Corporate Vice Presidents 2 (number involved) 2 l e. Chief Nuclear Officer -

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f. Managers / Supervisors 48 (number involved) 3

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l Attachment 1 l Page 5 of 12 l

NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET j I

1. Type of inspection, audit or evaluation: OSHA inspections. emolovee  !

comolaints etc. .

2. Based on actual experience over the past several years, about how often is this activity conducted? Averace once every 18 months  !

3. Operations / Construction areas covered: All NUORG areas are affected.

4. Extent of the activity (how may people, for how long) ,

Averaae 2 oersonnel for 2 days for a total of 32 manhours.  ;

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours

a. Plant Department Heads 8 (number involved) 2

b. Plant Manager 8

c. Corporate Department Heads 16 (number involved) 1

d. Corporate Vice Presidents 8 (number involved) i

e. Chief Nuclear Officer 2

f. Managers / Supervisors 30 (number involved) 2 ,

Attachment i Page 6 of 12 NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation: EPA / Mass Denartment of Environmental Protection (DEP) Suoerfund Amendment Reauthorization A1 SARA Title III. S30. (Community Riaht to know submittal)

2. Based on actual experience over the past several years, about how often is this activity conducted't Once every 2 years.

3. Operations / Construction areas covered: Pilarim Station.

4. Extent of the activity (how may people, for how long) 1 Department Representative from Lakeville Office for i day.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1, Total Hours

a. Plant Department Heads 1 (number involved) 1

b. Plant Manager -

c. Corporate Department Heads 4 (number involved) 1

d. Corporate Vice Presidents 1 (number involved) 1

e. Chief Nuclear Officer -

f. Managers / Supervisors 24 (number involved) --2 w a

Attachment 1 Page 7 of 12 -

NRC REGULATORY IMPACT SURVEY  :

OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation: Local insoectors - Health.

Construction. Fire Protection etc..

2. Based on actual experience over the past several years, about how often is this activity conducted? 2 Der year. ,

3. Operations / Construction areas covered: Pilarim Station i

4. Extent of the activity (how may people, for how long) 1 oerson for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours

a. Plant Department Heads 4 (number involved) 1 l

l b. Plant Manager 1

c. Corporate Department Heads _8 (number involved) 1

d. Corporate Vice Presidents -

(number involved)

e. Chief Nuclear Officer -

f. Managers / Supervisors .30__ (number involved) 2

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Attachment 1 Page 8 of 12 j 1

NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET 1

1. Type of inspection, audit or evaluation: EPA / Department of I

Environmental Protection (DEP) and Division of Labor and Industries (DLI) Asbestos Permits /Licensina/ Surveys recuired to maintain blanket asbestos removal oermits.  !

2. Based on actual experience over the past several years, about how often is this activity coiducted? Monthly r

3. Operations / Construction areas covered: PNPS

4. Extent of the activity (how may people, for how long) 1-2 Hours each

5. Approxin9te percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

l Total Hours

! a. Plant Department Heads -

(number involved)

b. Plant Manager -

l c. Corporate Department Heads 8 (number involved) 2

d. Corporate Vice Presidents -

(number involved)

e. Chief Nuclear Officer -

f. Managers / Supervisors 8 (number involved) 2

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Page 9 of 12 l 1

i NRC REGULATORY IMPACT SURVEY i OUESTIONNAIRE SHEET j I

1. Type of inspection, audit or evaluation: Mass. Division of Labor l and Industries (DLI) Division of Occupational Health and Division of  !

Occupational ~ Safety insoections. j

2. Based on actual experience over the past several years, about how often  ;

is this activity conducted? Once everv 2 vears l

3. Operations / Construction areas covered: PNPS

4. Extent of the activity (how may people, for how long)

One oerson for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours ,

a. Plant Department Heads 2 (number involved) 1

b. Plant Manager -

c. Corporate Department Heads _4__ (number involved) 1

d. Corporate Vice Presidents -

(number involved)

e. Chief Nuclear Officer -

f. Managers / Supervisors 8 (number involved) 2

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l Attachment 1 Page 10 of 12 NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

INPO Trainino Proaram Accreditation.

2. Based on actual experience over the past several years, about how often is this activity conducted? Annually

3. Operations / Construction areas covered:

Trainina Denartment and all deoartments served.

4. Extent of the activity (how may people, for how long)

Ten evaluators for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> each.

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1, Total Hours

a. Plant Department Heads 50 (number involved) 4

b. Plant Manager 30

c. Corporate Department Heads -

(number involved)

d. Corporate Vice Presidents 50 (number involved) 1

e. Chief Nuclear Officer 50

f. Managers / Supervisors 2000 (number involved) 10

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Attachment 1 Page 11 of 12 NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

REC Team Insoections (1986.1987.1988.1989)

2. Based on actual experience over the past several years, about how often is this activity conducted?

2.5 Team Insoections Der year.

3. Operations / Construction areas covered: NA

4. Extent of the activity (how may people, for how long) On averaae 8 people. 2 weeks. 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> /insoection

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Total Hours

a. Plant Department Heads 40 (number involved) 4

b. Plant Manager _ZaQ.

c. Corporate Department Heads 230 (number involved) 3

d. Corporate Vice Presidents 170 (number involved) 4 1

e. Chief Nuclear Officer 200

f. Managers / Supervisors 10.000 (number involved) 375

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NRC REGULATORY IMPACT SURVEY OUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation: NRC Reaional and Headauarters Inspections / Audits (1986. 1987. 1988. 1989)

2. Based on actual experience over the past several years, about how often is this activity conducted? Resident Insoections 8.75/vear Other insoettions - 21/vear.

3. Operations / Construction areas covered: NA

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4. Extent of the activity (how may people, for how long)  ;

Resident Inspections - 7 insoectors. 6 weeks. 635 hour0.00735 days <br />0.176 hours <br />0.00105 weeks <br />2.416175e-4 months <br /> /insoection Other insoettions - 2 insoectors. 1 week. 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> /insoection

5. Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and ,

in response to the activity described in Item #1. ,

Total Hours

a. Plant Department Heads _10_ (number involved) 4

b. Plant Manager 510

c. Corporate Department Heads 450 (number involved) 4 1

d. Corporate Vice Presidents 260 (number involved) 4 l e. Chief Nuclear Officer 400

f. Managers / Supervisors 33.000 (number involved) 375 l

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