ML20056E113

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Responds to NRC Re Violations Noted in Insp Rept 50-443/93-11.Corrective Actions:Improvements to Radiological Occurrence Rept (Ror) Program.C/A Program Recently Revised. Ror Procedure RP 2.2 Will Also Be Revised
ML20056E113
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 08/18/1993
From: Feigenbaum T
NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-93115, NUDOCS 9308200035
Download: ML20056E113 (6)


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Telephone (603)474 9521

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Facsimile (603)474-2987 Energy Service Corporation Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer I

NYN-93115 1

August 18,1993 I

l United States Nuclear Regulatory Commission Washington, D.C. 20555 i

Attention:

Document Control Desk 1

References:

(a)

Facility Operating License No. NPF-86, Docket No. 50-443 L

i (b)

USNRC Letter dated July 14,1993, " Inspection Report No. 50-443/93-11,"

i J. H. Joyner to T. C. Feigenbaum

Subject:

Reply to NRC Inspection Report No. 50-443/93-11 Gentlemen:

j in a letter dated July 14,1993 [ Reference (b)], the NRC transmitted to North Atlantic Energy Service Corporation (North Atlantic) Inspection Report No. 50-443/93-11, which expressed concerns over the lack of timeliness of some long-term corrective actions developed under the North Atlantic Radiological Occurrence Report (ROR) program. It was also noted that a recently conducted North Atlantic audit identified similar findings concerning many of the deficiency tracking systems used at Seabrook Station. In response to the ROR concerns, the transmittal letter requested a written reply within 30 days of receiving the inspection report on any planned actions and completion schedules associated with improving the ROR program. Accordingly, Enclosure 1 describes planned improvements to the ROR program.

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l Should you have any questions concerning this response, please contact Mr. James M. Peschel, i

Regulatory Compliance Manager, at (603) 474-9521, extension 3772.

Very truly yours, Ted C. Feigenb m TCF:JES/jes Enclosure l

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PDR ADOCK 05000443

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United States Nuclear Regulatory Commission August 18,1993

' Attention:

Document Control Desk Page two cc:

Mr. Thomas T. Martin i

Regional Administrator U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 i

Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects i

U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box !!49 Seabrook, NH 03874 l

Mr. James H. Joyner, Chief Facilities Radiation Safety and Safeguards Branch i

Division of Radiation Safety and Safeguards l

U.S. Nuclear Regulatory Commission f

l Region I v

475 Allendale Road i

King of Prussia, PA 19406

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North Atlantic August 18,1993 ENCLOSURE 1 TO NYN-93115 I

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I REPLY TO NRC INSPECTION REPORT NO. 50-443/93-11 in a letter dated July 14,1993 [ Reference (b)], the NRC transmitted to North Atlantic Energy Service Corporation (North Atlantic) Inspection Report No. 50-443/93-11, which expressed concerns over the l

lack of timeliness of some long-term corrective actions developed under the North Atlantic Radiological Occurrence Report (ROR) program. It was also noted that a recently conducted Nonh Atlantic audit identified similar findings concerning many of the deficiency tracking systems used at Seabrook Station.

In response to the ROR concerns, the transmittal letter requested a written reply within 30 days of receiving the inspection report on any planned actions and completion schedules associated with improving the ROR program. Planned improvements to the ROR program, and a schedule for completing these improvements are described below.

A.

Planned improvements to the ROR Procram Independent of the ROR issue, North Atlantic has recently revised the Corrective Action Program described in North Atlantic procedure NAhihi 12700 by ennsolidating deficiency reporting methods and i

standardizing the problem evaluation and resolution process. The revised procedure NAhihi 12700 was i

issued on June 30,1993. North Atlantic is currently in the process of revising the ROR procedure RP 2.2 to be consistent with the guidance provided in NAhihi 12700.

l Specifically, the ROR will only be utilized for those radiological events that do not meet the threshold criteria for inclusion in a Station Information Report (SIR) (Procedure OE 3.1), Operational Occurrence Report (OIR) (Procedure OE 3.2), or a Condition Report (CDR) (Procedure OE 3.2). SIRS are utilized l

for all events that have the potential to be reportable to the NRC or other regulatory agencies. Therefore, l

RORs will only document those radiological occurrences that are not reportable.

The ROR procedure RP 2.2 will also be revised to:

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Create two categories of RORs to prioritize processing of RORs conunensurate with the significance of the event. Additionally, time guidelines will be established for completing the ROR root cause evaluation and implementation of corrective actions. These time guidelines, which will be based on the category of RORs, are summarized in Attachment 1.

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Ensure that the action of completing the ROR root cause evaluation, and the resultant corrective actions, are tracked on North Atlantic's Integrated Commitment Tracking System (ICTS).

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Clearly delineate responsibilities for completing ROR root cause evaluations and determining l

l corrective actions.

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Add examples of radiological occurrences to the procedure for each possible report and for each category of RORs.

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Add a review of RORs as indicated in Attachment 1 prior to management approval. The review l

will include a determination of the adequacy of the root cause determination and the recommended corrective actions.

l The above described actions will ensure that RORs are resolved and corrective actions are implemented in a timely manner.

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- Schedule for Completine Planned Improvements to the ROR Procram j

The aforementioned planned improvements to the ROR program are expected to be implemented by September 30,1993.

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ATTACliMENT 1 t

ROR CATERGORY ROOT CAUSE CORRECTIVE ADDITIONAL REVIEW EVALUATION ACBONS COMPLETE COMPLETED or SCllEDULED (for long term corrective actions) l Category 1 1 week I month IIP ROR Subcommittee, Most Severe consisting of at least one operations supervisor and one Ilealth Physicist Category 2 1 month 3 months 11P ROR Coordinator, Less Severe llP ROR subcommitee review optional i

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