ML20132G472
| ML20132G472 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/07/1996 |
| From: | Boulette E BOSTON EDISON CO. |
| To: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20132G452 | List: |
| References | |
| 96-095, 96-95, NUDOCS 9612260266 | |
| Download: ML20132G472 (2) | |
Text
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G Boston Edison Pdgran Nuclear Power staten Rocky Hdi Road Plymouth. Massachusetts 02360 E. T. Boulette, PhD E
8 6
Sen' r Vce Presdent-Nuclear o
Richard W. Cooper, Director Division of Reactor Projects Region I 475 Allendale Road King of Prussia, PA 15406-1415 Docket No. 50-293 License No. DPR-35
Subject:
DOL Case No. 94-ERA-34
Reference:
NRC letter from Mr. Cooper to Mr. Boulette, May 13,1996
Dear Mr. Cooper:
This letter provides formal closure to the issue raised in your May 13,1996, letter to us. As explained in the enclosure (BECo letter to Ms. Claro, September 6,1996), the information presented by BECo in the subject case is consistent with NRC inspection findings referenced in your letter. Furthermore, the letter to Ms. Claro asserts the information presented by BECo in testimony and brief is accurate and complete.
Should you require any further information, please contact me directly at 508-830-8814.
E. T. Boulette, PhD JWK/dmc/94 ERA-34
Enclosure:
BECo letter from Mr. Fulton to Ms. Claro, September 6,1996 cc:
Mr. Alan B. Wang, Project Manager Project Directorate I-1 Office of Nuclear Reactor Regulation Mail Stop: 1482 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 9612260266 961217 PDR ADOCK 05000293 P
Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of. Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station
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l T$$IN i wcw i. September 6,1996 i 4 i l Joyce Claro,Esq. i Office of Administrative Appeals U. S. Department of Labcr i 200 Constitution Avenue,N. W. Washington D. C. 20210 t,
Subject:
Case NO. 94-ERA-34 j. 1 i
Dear Ms. Claro,
On May 6,1996, the U. S. Nuclear Regulatory Commission's (NRC) Office of i' Enforcement notified your office that Boston Edison Company may have provided inaccurate or inccmplete information to the Department of Labor in the Company's br l dated October 31,1994, in the above captioned proceeding. The basis for this conclusio is an apparent inconsistency between the findings of a recent NRC inspection c i at Boston Edison Company's Pilgrim Nuclear Pcwer Station, NRC Inspection Report { No. 50-293/95-22 (Section 4.3.4) and a statement contained within the Company's b l Argument EG "The June,1994 Memorandum Regarding Manuals for Safety-R Systems Had No Safety Significance," (page 14). De purpose of this letter is i { the Secretary that, in all instances, the infonnation provided by Boston Edison Com l m testimony and briefis accurate and complete. i At issue is the use of the term " vendor manuals" and whether or no b documents discussed by the Company in Argument EG of the Company's brid are t i same documents relied upon to conduct maintenance as concluded by the NRC in it j recent inspection. Dere are different categories ofvendor manuals at Pilgrim j i therein may lie the source of the apparent inconsistency. t i i
l 3 j 94-ERA-34 i l A vendor manual is a documen,t provided by the supplier (vendor) of a plant i system, sub-system, or component. The vendor manuals referenced in brief are the l " system level" vendor manuals. Claimant Exhibit 2. De system level vendor manuals are j used solely as a reference for a general systen description and, due to their age and the cost to update them, the system vendor manuals have been classified as " Exception" l category manuals and are not maintained as current. De vendor manuals that were the focus of the NRC's recent inspection are the sub-system or component level manuals that i are active and relied upon to maintain the plant. The system vendor manuals are not j relied upon to perform this function. Company procedures explain the differences in the j categories and control their specific treatment and use. l It is the Company's position that the information provided in its testimony and i briefin the captioned proceeding and the results of the NRC referenced inspection are consistent. Most importantly, the information provided by the Company is both l accurate and complete. The Company shall provide any documents or additional l information that you may need regarding this matter. Please contact me directly at the above number. 4 i Sincerely, i A b k //k. l l 1 oc Richard Cooper Karta Smith, Esq. - -. -}}