ML20065J541
| ML20065J541 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/05/1990 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 90-131, NUDOCS 9011140027 | |
| Download: ML20065J541 (5) | |
Text
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' Pilgrim Nuclear Poer Station i
Rocky Hill Road -
Plymouth, Masse.husetts 02360 -
Ralph G. Bird Senior Vice President - Nuclear November
'5, 1990 BECo Ltr. 131.
U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Hashington, D.C.
20555
-Docke't No. 50-293
-License No." DPR-35
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SUBJECT:
Response to Systematic Assessment of. Licensee Performance Board'Renort No.'50-293/89-99 o
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Dear Sir:
Attached is Boston Edison Company's response to the Systematic' Assessment'of I
Licensee Performance (SALP) Board Report for Pilgrim Nuclearc Power Station 1
(PNPS) covering the period July 1, 1989 through August 15, 1990.-
j In general, the report provides an assessment of Pilgrim that is: consistent-with our internal assessments.. An exception to.your assessment of Emergency Preparedness is included in the attachment.
Please do not hesitate.to contact me if there are any questionsf or-comments i
regarding the attached response, a
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b R. G. Bird RLC/bal : Response to Systematic Assessment of Licensee Performance Board Report No. 50-293/89-99
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cc:
'Mr. Thomas T. Martin Regional Administrator, Region I U.S; Nuclear Regulatory, Commission 475 Allendale Rd.
1 King of Prussia,.PA_--19406:.
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9011140027 901105 s
PDR ADOCK 05000293 Jq Q
PDC j.
Page 2 Mr. Ronald Eaton Project Manager DivisionofReactorProjectsI/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conr.ission '
Mail-Stop: 1401 1
One White Flint North i
11555 Rockville Pike Rockville, MD 20852 Sr. NRC Resident Inspector - Pilgrim Station i
Standard BECo Distribution
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ATTACHMENT'l
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Boston Edison Company
- BECo Ltr. #90- 131 Pilgrim Nuclear Power Station Docket'No. 50-293 License No',DPH-35' RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE BOARD PEPORT NO. 50-293/89-99
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In response to SALP Board Recommendation III.D.3 and with respect to-Emergency Preparedness, we concur with the overall: assessment and-believe that the report accurately. reflects the current excellent state
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of the Station's Onsite Preparedness. Program-In addition, with the continued cooperation of Commonwealth'of Massachusetts and local officials, we are committedLto the long-term maintenance of offsite preparedness.for emergencies:at. Pilgrim Station.
The company has dedicated significant ts.ources in terms of management oversight, staff support, and financial. support to assure success in this area.
However, we take exception to.one area of.the report that states:~";..It is not clear that sufficient action'has been-taken to resolve incomplete and longstanding offsite issues."
j Boston Edison was recently requested (NRC letter dated September-14, 1990), to provide a review of offsite issues as outlined in'the transcript to the NRC's Public Meeting held in Plymouth, Massachusetts on September 6, 1990.
The result of our. review was documented in a(report that-h'as'been-forwarded to the NRC's-Document Control Desk (via Boston Edison letter i
dated October 4, 1990).
l The conclusions reached in-our report' state: "He believe'that a careful
- i review of the items discussed in this report (including those identified as requiring corrective action) will: demonstrate'.that a comprehensive'-
and effective offsite response program has been established," The~
conclusion goes on to state: "In:short,.the information-contained in this report demonstrates;that there is reasonable assurance that public 1
health and safety will be adequately protected in the event ofcan emergency at Pilgrim Station."
As Boston Edison has demonstrated, the Company is dedicate'd>to ensuring an adequate, implementable offsite program isi n: place for Pilgrim i
Station.
Boston Edison believes such a' program currently exists..
Regarding the SALP Report's specific. comments, the company, isiworking with Commonwealth and local officials to incorporate.."lessonsilearned" from the =0ctober 1989 Exercise, as well. as making other~ improvements _ and.
t refinements. The shortcomings in the Commonwealth'and' local programs
' hat FEMA identified in its August 1987 self-initiated review have been i
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-addressed.
Boston Edison is confident that the' current joint NRC/ FEMA: Task Force -
investigating the offsite program will. confirm the. Company's: conclusions.-
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. ATTACHMENT 1 (CON'T) l c-Boston Edison Company BECo Ltr. #90-131-Pilgrim Nuclear Power Stction Docket No. 50-293 License No. DPR-35'
.i II.
ELANT OPERATIONS
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Paragraph 2 of the Analysis Section_III.A.I. states:
... A total of.
l thirteen safety system actuations were experienced this' period'." Bostoni Edison recommends this sentence be reworded to say a total of fourteen Engineered safety feature actuations were experienced this period.. The-proposed change is in keeping with the NRC definition of. safety system:
actuations and Engineered safety feature actuations..
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III. RADIOLOGICAL CONTROLS 1
Paragraph 4 (page 9) of the Analysis ~Section.III.B.1 states:
"...Howeh ', the frequency of surveillance in the radwaste area needed' to be increased as none were conducted during the first three months:of 1990." The following summarizes the Quality Assurance Department +
l activities in the Radwaste functional area in' the' first three months of; 1
1990:
l QA Audit.90-04, "Radwaste Shipping" was. performed.from February 13,.
through' February 27, 1990.
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QA Surveill'ance 90-2.3-3, "Radwaste/ Hater Quality" was' performed on March 14 and March 18, 1990 and the report was issued on 3/29/90 (just after an NRC Region 1 inspection had ended);. No deficiencies' were identified, j
18 Radwaste shipments were witnessed by QC (full time inspector.
assigned to Radwaste shipments).
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Additionally, a QAD 'self assessment of,QC oversight of Radwaste was.
performed for the 4th quarter 1989 (QAD 90-026 issued January 8, 1990).
I Apparently, this information was not properly communicated to the NRC' during the SALP period.
He request that this information be considered '
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in the final SALP report.
l IV.
MAINTENANCE /SURVEILLANCI In response to SALP Board recommendation III.C.3?and~to improve the effectiveness of failure. mechanism and causal' analysis determinations, the-following enhancements were' implemented:
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ATTACHMENT'1 1
(CON'T)-
Boston-Edison Company.
BECo Ltr. #90-~131 Pilgrim Nuclear Power Station Docket.No. 50-293.
4 License No. DPR-35 j
The concept of Multi-Disciplined Analysis Team (MDAT) has been-
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e adopted to fully investigate failures of the type experienced _after the feedwater event and manual scram in September 1990. MDATs have been staffed with experts,. technical and managerial, and have i
proved their effectiveness in determining root ::auses and providing l
technically correct and effective recommcr.3dions for corrective action.
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The root cause analysis instruction has been revised to incorporate the guidance of'INP0 Good Practice OE-907 and.'to~ strengthen the:
requirements validating the-effectiveness of each cause and 1
corrective measures determination.
V.
CONCLUSION We will continue to raise the standards of=the Nuclear Organization.
Our self-assessment practices have made a major contribution to,this result and will contribute to.further improvement. Our commitment to improve has the support of.the highest ; levels of.the: company and extends throughout the Nuclear Organization.
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