ML20063C224
| ML20063C224 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/08/1982 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20063C215 | List: |
| References | |
| 82-98, NUDOCS 8205040610 | |
| Download: ML20063C224 (3) | |
Text
'
I s
BOSTON EDISON COMPANY 800 BOYLETON STREET BOSTON. MA55ADHUBETT5 02199 WILLIAM D. HARRINGTON
~~~
April 8,1982 BECo. Ltr. #82-98 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19405 Docket Number 50-293 4
License No. DPR-35 References :
(a) NRC Region I Letter (T. T. Martin to W. D. Harrington),
dated 3/9/82 with enclosure, " Inspection Report 50-293/82-05" (b) BECo Letter (W. D. Harrington to R. Haynes), dated 3/24/81, File Reference #82-84
Subject:
Inspection Report 50-293/82-05
Dear Sir:
This letter is being submitted in response to the Notice of Violation, Appendix A, which was fonvarded with Reference (a).
Appendix A stated:
i "10 CFR 50, Appendix B, Criterion II, requires that a quality assurance program be established and that the program policies and procedures be carried out during operation. The Foreword to the Boston Edison Quality Assurance Manual, Volume II, states that the quality assurance program I
is defined within the manual is the governing document. Section 18, Paragraph 18.5.1 of the manual states, " Appropriate action to resolve deficiencies identified during Internal Audits conducted by BECo QA is taken by the cognizant BECo Manager before the scheduled resolution date."
" Contrary to the above, approximately 31 of 65 responses to Deficiency Reports (the corrective action system for deficiencies identified during audits) whose scheduled (due) resoltuion dates were between October 15, 1981 and January 30, 1982, had either not been responded to or had exceeded their due dates. Specific examples are Deficiency Reports (DRs)
[
Nos. 671, 778, 795, 800, 801."
l l
"This is a Severity Level V violation (Supplement 1)."
8205040610 820427
~
G
F C= TON EDCON COMPANY lir. Thomas T. Martin, Director April 8,1982 Page 2 Response to Item A (INC 50-293/82-0501) 1.
Corrective Actions Taken and Results Achieved As reported in Enclosure D of Reference (b), Boston' Edison formed a committee consisting of representatives from the Operations, Engineering, and Quality Assurance Departments and an independent consultant, developed a set of criteria for determining which QA audit deficiencies had safety significance. Using that criteria and the Quality Assurance Department (QAD) " Unresolved Deficiency Summary," the committee prepared a list of Deficiency Reports (DR's) which would require action prior to startup.
This list was submitted to the responsible Department Managers for their review and immediate action.
Initial emphasis was placed on reaching agreement with QAD personnel on the proposed corrective action plans for each DR. Then, as corrective actions were completed, emphasis shifted toward verification of the corrective action by QAD personnel.
To satisfy'the requirements of Confirmatory Action Letter 82-05, Boston Edison determined that, as a minimum, either the deficient condition (s) would be completed prior to startup or a valid explanation would be reviewed / discussed regarding why it need not be completed prior to startup. Boston Edison presented the approach utilized for resolution of audit deficiencies to the inde endent review group, the Nuclear Safety Review and Audit Committee (NSRAC.
The NSRAC reviewed and accepted, with only minor changes, the explanations presented and the method used. Based on the presentations given to the NSRAC concerning deficiencies as recorded, the NSRAC found no safety con-cerns which would preclude startup.
Boston Edison believes that this conservative approach ensured that all ~
substantive safety issues were addressed and corrected and that the actions taken satisfied Item 4 of the CAL. Accordingly, Boston Edison believes that the actions taken were adequate and assured a safe restart.
I 2.
Corrective Actions to Avoid Further Violations The efforts by this committee and responsible Department flanagers to resolve all current open Deficiency Reports, including those not considered by the committee to have safety significance will be sustained.
The resources, utilized to take action in responding to Item 4 of the CAL, l
have been used as guidance to determine the resource requirements needed to develop an action plan for resolution of the remaining unresolved Deficiency Reports. This action plan will be completed within four (4) to six (6) months.
f
...g.,,
i av b
CD] TON E'DC O N CO M PANY Mr. Thomas T. Martin, Director April 8,1982 Page 3 In a continuing effort to upgrade our corrective action program, BEco is extensively revising Section 16, " Corrective Action," of the BEQAM.
Requirements for responses to, and corrective action resulting from, Deficiency Reports have been strengthened and clarified. These require-ments include specific time limits to ensure that responses are made and corrective actions are taken in a timely manner.
3.
Date When Full Compliance Will Re Achieved a) Resolve safety significant Unresolved Deficiency Reports - complete b) Revise BEQAM Section 16 - flay 1,1982 c) Complete Action Plan to resolve all unresolved Deficiency Reports -
August 1, to October 1,1982.
Please be assured of our willingness to provide any additional information you may need concerning our responses to Reference (a).
Very truly yours,
h N
d Commonwealth of Massachusetts)
County of Suffolk
)
Then personally appeared before me William D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the sub-mittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
dy)/If' My Commission expires:gg, gg {
Nota y Public R
+
b f-e s
4 miP
.[/ T 3
.... i.[ 4
.Q b
t LtCc
.