ML20080H534

Responds to NRC Re Violations Noted in IE Insp Rept 50-293/83-21.Corrective Actions:Schedule for External Audits Compiled & Formally Issued on 831007 & Personnel Instructed in Importance of Audits

ML20080H534
Person / Time
Site:	Pilgrim
Issue date:	01/19/1984
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20080H498	List: ML20080H534
References
BECO-#84-013, BECO-#84-13, NUDOCS 8402140234
Download: ML20080H534 (3)

Text

w BOSTON EDisDN CGMPANY 800 BOYLsTON STREET BQsTON. MAssACHUerns 02199 Wild. LAM O. HARRINGTON es: son west essessent January 19, 1984 BEco #84-013 Richard W. Starostecki, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Subject:

Inspection 83-21 Reference. (a) HRC letter, 12/29/83 (BECo # 1.83.313), " Inspection No. 50-293/83-21."

Dear Sir:

This letter is in response to two (2) violations identified during a routine safety inspection conducted by Mr. Glenn Meyer of your office on August 22-26, 1983, and communicated to Boston Edison Company in Appendix A of the Ref-crence.

Notice of Violation A (INC 83-23-01) 10 CFR 50, Appendix B, Criterton XVIII, Audits, states in part, "A comprehensive system of plannad and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program."

The Boston Edison Quality Assurance Manual commits Pilgrim to meet ANSI N45.2.12-1977. ANSI N45.2.12-1977, section 3.4 states, "The audit system, including both internal and external audits, shall be planned, documented, and conducted to assure coverage of the ap-plicable quality assurance program, and overall coordination and scheduling of audit activities."

Quality Assurance Department Procedure 18.01, Audits, Revision 7 paragraph 5.1.b states, "The Quality Assurance Manager is respon-sible for review and approval of audit schedules," and paragraph 5.2.a states, " Quality Assurance Group Leaders shall prepare audit plans and schedules."

Contrary to the above, on August 24, 1983, there was no schedule for external (outside of Boston Edison Company, for example, Bech-tel's modification work on site) audits.

Responee As immediate corrective action, the subject audit schedule was com-8402140234 840206 1

PDR ADOCK 05000293 G ,PDR

BOSTON EDIEDN COMPANY Richard W. Starostecki Jcnuary 19, 1984 Pzge 2 piled and formally issued on 10/7/83. To prevent recurrence, Quality Assurance Department personnel were instructed on 12/17/83, in the im-po.tance of identifying external audit needs and maintaining the sche-dule up to date.

Full compliance was echieved on 10/7/83.

Notice of Violation B (INC 83-21-02) 10 CFR 50, Appendix B, Criteria V, states, in part, " Activities affect-ing quality shall be prescribed by documented instruction, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or draw-ings."

Bostcn Edison Quality Assurance Manual, Paragraph 18.3.3 states, " Audit deficiencies are recorded on a Deficiency Report and are entered into the Deficiency Follow Program to be dispositioned."

Contrary to the above, numerous deficiencies found during Audit 82-17, High Pressure Coolant Injection (HPCI) Configuration were recorded as Action Items, an informational system appropriate for audit corrective actions, not Deficiency Reports. The audit deficiencies recorded as Action Items including drawing errors, set point inconsistencies be-tween the Technical Specification and Final Safety Analysis Report, missing records, and inconsistencies between piping, instrumentation, and wiring drawings and the installed plant conditions.

Response

The immediate corrective action was to conduct a review of all open

" Action Items" as of August 1,1983, to determine if any constituted deficiencies; that is, departures from specified requirements. Pre-liminary review indicated that four of the action items should be re-issued as deficiencies and, accordingly, four deficiency reports were issued for these action items as of October 4, 1983. Review of all Action Items was completed on 12/30/83 and no additional deficiencies were identified.

To prevent recurrence, the Quality Assurance Manager, instructed all personnel in the department on November 18 and 22, 1983, that action items were deleted from the BEQAM and that, in the future, action items would only be limited to use within the department for tracking of potential deficiencies.

Full compliance was achieved on December 30, 1983.

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Bos7aN EnesoM COMPANY .l

- Richard W. Starostecki Jcnuary 19, 1984 .

Page 3 If.you have any questions or concerns regarding the above responses,

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' you are requested to direct them to the undersigned.

Respectfully submit ed, J

J.lliam D. Harrington

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