ML20112F779
| ML20112F779 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/21/1984 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 84-212, NUDOCS 8501160038 | |
| Download: ML20112F779 (3) | |
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EOSTON EDISON COMPANY B00 BOvLaTON STRet?
30sTON. MAssACHUstTTs 02199 WILLIAM O. HARRINGTON December 21, 1984 BECo Ltr. #84-212 Mr. Edward C. Wenzinger Chief. Projects Branch No. 3 Division of Project and Resident-Programs U.S. Nuclear Regulatory Comission Region I - 631 Park Avenue King of Prussia, PA 19406 Docket Number 50-293 License DPR-35
Subject:
NRC Notice of Violation 84-26-04
References:
(a) NRC Letter 1.84.345, E. C. Wenzinger (NRC) to W. D. Harrington (Sr. VP-Nuclear-BECo), 11/21/84 Jear Mr. Wenzinger:
This letter responds to the violation identified during a routine safety inspection by Mr. J. Johnson of your office between August 28, 1984 and October 8, 1984 and communicated to Boston Edison Company in Appendix A of Reference (a).
Notice of Violation (84-26-04) 10CFR50, Appendix B, VI, requires that measures be established to assure that documents including procedures are reviewed for adequacy and approved for release. Boston Edison Co. Quality Assurance Manual (BEQAM), Section 5
" Instructions, Procedures, and Drawings," Revision 11, dated May 14, 1984, requires that the quality assurance program-related procedures listed in Exhibit 11-5-1 be reviewed and approved by the Quality Assurance Manager.
Contrary to the above, on September 14, 1984, four procedures listed in Exhibit 11-5-1 of the BEQAM were not reviewed and approved by the Quality Assurance Manager.
Corrective Steos Taken and Results Achieved Corrective steps have been taken to assure that all quality assurance program-related procedures are identified, reviewed, and approved by'the Quality Assurance Manager. These steps include the following:
1.
8EQAM II. Section 5, was clarified in Revision 12, dated 10/26/84.
The clarification requires identification of quality program-related procedures (as defined in BEQAM II, Paragraph 5.2.1) in the "Index of QA Program-Related Procedures to 10CFR50, Appendix 8 Criteria." This index is a controlled document, and supersedes Exhibit 11-5-1.
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- BOSTON EDISON COMPANY Mr. Edward C. Wenzinger O.S. Nuclear Regulatory Commission December 21, 1984 Page Two 2.
The following four PNPS procedures, identified as not reviewed and approved by the QA Manager in Reference (a), have been reviewed by the QA Department:
o PNPS 3.M.1-1, " Preventive Maintenance" o
PNPS 3.M.1-8, " Disposition of Nonconforming Materials" o
PNPS 3.M.1-10.1, " Torque Wrench Calibration" o
PNPS 3.M.1-10.3, " Calibration of Noncontrolled Lab Equipment" j
Our review revealed that PNPS 3.M.1-1 was not required to be listed in the
. index; therefore, it does not require QA Manager approval. The other three procedures were found to need revisions before QA Manager approval.
The subject revisions were made by the Station, and QA Manager approval was subsequently obtained.
It is expected the procedures will be reviewed and approved by the ORC Chairman by 1/15/85.
3.
PNPS personnel have conducted an additional review of procedures in the controlled index to ensure that the current versions of those procedures contain a QA Manager approval signature.
Procedure 6.1-022 was the only exception found, and we have since obtained QA Manager
[
approval.
l Corrective Steps to Avoid Further Violations i
The clarification of BEQAM II, Section 5, mentioned above provides -
identification control of QA program-related procedures through use of a -
- controlled index. This index is to be updated, as needed, according to-Section 5 requirements.
In addition, the QA Department will periodically review issued procedures against the "Index of QA Program-Related Procedures to 10CFR50, Appendix B Criteria" to assure that all QA program-related procedures are reviewed and approved by the QA Manager. The first review will l-be complete by 1/31/85.
I L.
Additionally -the station procedure used as guidance to station personnel in l
- obtaining required QA Manager reviews and approvals will be revised to ensure implementation of Section 5 of the BEQAM. The subject revisions will be completed by 4/1/85.
(
Until the station procedure is revised, however, our interim corrective action L
~ is that the appropriate station personnel have been instructed in following.
the requirements of BEQAM II, Section 5.
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4 BOSTON EDISON COMPANY Mr. Edward C. Wenzinger U.S. Nuclear Regulatory Commission December 21, 1984 Page Three Date When Full Compliance Will be Achieved Full compliance will be achieved on 1/15/85, the date by which the four above-mentioned procedures will have been approved by the ORC Chairman.
If you have any further questions or require additional information regarGing the above issue, please do not hesitate to contact me.
Respectfully submitted, W. D. Harrington
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