ML20052B282
| ML20052B282 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/23/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harrington W BOSTON EDISON CO. |
| References | |
| NUDOCS 8204300252 | |
| Download: ML20052B282 (3) | |
Text
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APR 23 at j u o>
Boston Edison Company M/C Nuclear
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9 ATTN: Mr. William D. Harrington Senior Vice President, Nuclear 7
800 Boylston Street
,3 p9 Boston, Massachusetts 02199
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Dear Sir:
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We have reviewed your March 18, 1982 response to the NRC O'rder Modi, License Effective Immediately (the Order) which was issued to Boston-Edison' Company (BECo)onJanuary 18, 1982. Furthemore, we have considered the recent steps taken by BECo regarding the new organizational structure for managing activities related to the operation of the Pilgrim facility. The proposed BECo plan includes several steps and milestones, and incorporates the capability for modifying your approach based on the results of the ongoing independent study. We recognize the need for the BEco plan to be an iterative one requiring periodic modifications.
The timetable you have established for the first increment in July 1982 is reasonable. Milestones for subsequent increments also appear to be realistic based on available information.
In light of these considerations we find that your proposed Performance Improvement Plan (the Plan) is acceptable subject to periodic meetings with us to discuss the status of your efforts and to enable us to periodically assess the effectiveness of your Plan. Therefore, you and your staff should be prepared to meet with me and my staff at the Region I Office on a periodic basis to discuss these aspects and other factors that relate to the safe operation of the Pilgrim facility. At the present time, we believe that these meet.ings should be held at six week intervals with the first meeting taking place next month. We will infom you of the meeting date at least two weeks in advance of the meeting.
Your Plan includes a July 1982 milestone at which time you are scheduled to provide proposed program revisions, a description of required staffing to imple-ment specific requirements, documentation requirements, and further definitions of your detailed schedule. Prior to this milestone, additional infomation is required to more fully define the Plan. The initia) meeting in May 1982 will be scheduled to address these matters.
In particular, several aspects of the Plan have completion dates that are pmjected into late 1983. We consider it necessary that you clearly describe the interim measures you are taking for such aspects. The specific information required is described in the following para-graphs.
In the Corrective Action Program described in paragraph III.1.C of your letter, several program revisions are stated to be undergoing management review, but a completion date is not specified. Moreover, it is not clear whether any of these program revisions will be included in the short tem improvements that are to be implemented by July 1982. Accordingly, the short tem improvements need 8204300g;L M__
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It is also stated that the conplete revised system will not be irplemented until October 1983. Eecause of the inportance of an effective Corrective Action Program, this corapletion schedule seens unduly protracted.
i Therefore, you are hereby requested to pmvide infomation regarding the planned interim program and steps to be taken to impmve corrective action performance after July 1982.
In the revised Preventative Haintenance Systen described in paragraph III.3.0, the final c:11cstone includes the developent of a plan to inplement the integraf ed preventative maintenance program but no date is specified for scheduled comple-tion. You are requested to provide information as to how this program differs from that scheduled for developnent and implementation in August 1932 identified i
in the previous n11estone.
Additional questions also exist regarding responses to Section V of the Order.
Item V.4 of the Order requires that all changes resulting from previous rodifications be reviewed to insure that these modifications have been appropriately addressed in procedural and drawing changes.
In paragraph III.3.A of your letter, you indicate that a review of nodifications in-stalled during the refueling outage just conpleted has been done; however.
the program or scheduled coripletion date for review of all previous nodift-cations as required by the Order was not addressed. Further, paragraph 111.3.B which describes the Plant Procedum and Drawing Evaluation Program indicates that physical walkdowns of safety systems using current piping and instrument drawings will be conducted and identified discrepancies will be resolved by appropriate corrective action. However, this program ray not uncover a failure to make a required procedure or drawing change during the implementation of prior plant nodifications. Also, in light of the progress nade in conducting system walkdowns prior to the plant startup in Harch-April 1982, it is not apparent completion of this program will require an additional 16 months. You are requested to provide more specific infomation on the natum and timetab e of the program to review previous modifications.
Item V.7 of the Order requires develoneent and implementation of a system of audits by management representatives to assure conformance to procedures and continued adherence to changes which result from the reviews identified in items V.2 thmugh 6 of the ONer.
In paragraph III.2.B of your letter you indicate that the Duality Assurance Program will be upgraded to include management systems; but the above requirenents are not specifically addressed.
i furthemore, you state that this change will be implemented three months after inplementation of a revised system. You are requested to provide additional inforeation concerning the revised system and the anticipated i
inplementation schedule.
The additional information on the preceding iters should be provided in writing l
to this office by May 7,1982.
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i Boston EHson Cor.pany N/C Nuclear 3
APR 23 582 Based on the considerations discussed in this letter and subject to satisfactory resolution of the above concerns, the approach you have proposed is acceptable.
The scheduled reeting in May 1982 should provide us with the opportunity to gain further insight into the progress of the BEco Plan. In this regard we are continuing to maintain an expanded inspection program to ronitor on-site activi-tics at the Pilgrim facility and to evaluate your progress in frpmving the management of safety related activities for the Pilgrim facility.
Sincerely original Signed 1977 Ronald C. Ilaynes Regional Administrator cc:
A. V. Morisi, Manager, Nuclear Operations Support R. D. Machon, Nuclear Operations Manager - Pilgrim Station Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Connonwealth of Massachusetts (2)
S J. Shotwell, Assistant Attorney General J. Bonsall, Chairman, Department of Public Utilites D. Tarantino, Chairman of the Board of Selectman bcc:
S. Burns, ELD J. Lieberman, IE R. Starostecki E. Brunner T. Elsasser NV
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agt Haynes
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$\\W S. B ns/ ELD: via telecon 4/23/82
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