ML20138D747

Requests Approval to Extend Completion Dates of Six Milestones Contained in Radiological Improvement Plan. Current Status of Late Milestones Listed

ML20138D747
Person / Time
Site:	Pilgrim
Issue date:	11/07/1985
From:	Harrington W BOSTON EDISON CO.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20138D720	List: ML20138D714 ML20138D747
References
85-199, NUDOCS 8512130292
Download: ML20138D747 (4)

Text

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- e BOSTON EDISON COMPANY B00 SOvLsTON L!TRErr 30sTON MAssACHusnis 02199 WILLIAM D. HARRINGTON OEnsenviss passioamt N] S uMg l November 7, 1985 BECo Ltr.85-199 Dr. Thomas E. Murley Regional Administrator Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission l i

Region I 631 Park Avenue King of Prussia, Pa. 19406 Docket Number 50-293 License DPR-35

SUBJECT:

Extension Request for Radiological Improvement Plan (RIP) Milestones 8.1.2/8.1.3/8.1.4/

6.2.lk/10.2.la/6.

1.1 REFERENCES

(A) Order Mcdifying License: Review of Radiological Controls Program - NRC Ltr. EA84-ll2 dated November 29, 1984 (B) Boston Edison Company Ltr. (W. D. Harrington) to NRC (T. E. Murley), BECo Ltr. #85-042 dated February 28, 1985 (C) Boston Edison Company Ltr. (H. D. Harrington) to NRC (T. E. Murley), BECo Ltr. #85-042

Dear Dr. Murley:

In accordance with the Reference (A) " Order",Section IV.C, I am requesting your approval to extend the completion dates of six (6) milestones contained in Boston Edison Company's Radiological Improvement Plan (Reference (B)).

Three (3) of these milestones involve improvements to Pilgrim Station's radioactive materials control system; two (2) pertain to equipment purchases for improvements to the Whole Body Counting (HBC) program; and one (1) pertains to approval of an in-vitro process sampling procedure.

The following describes the current status witi. respect to the late

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milestones.

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BOSTON EDISON COMPANY  !

November 7, 1985 Or. T. E. Murley e RIP 8.1.2, Milestone #2 - Due September 30, 1985 The intent of this milestone is to designate and establish consolidation of radioactive material storage areas.

This work is estimated to be 25% completed in that storage areas have been designated by management. The following items also pertain to consolidation activities and are pending:

Procedures regarding storage areas.

Establishing staging areas.

Relocation of materials to designated areas.

A revised schedule for completion of this milestone has been prepared designating completion on or before December 30, 1985.

_ e RIP 8.1.3, Milestone #3 - Due September 30, 1985 This milestone addresses protective enclosures for radioactive materials stored outside and is estimated to be 20% complete in that some enclosures such as Sea-Vans are available for outside storage and polyethelene, herculite and pallets are used to protect material from adverse weather conditions.

An estimated 80% of the radioactive .. terials presently stored outside are enclosed in recommended en losure-type packages.

Items to be addressed are:

Procedures regarding the use of enclosures.

Additional enclosures and possible modifications such as adding structures with roofs, culverts, LSA boxes, etc.

A revised schedule for completion of this milestone has been prepared designating completion on or before November 30, 1985.

e RIP 8.1.4, Milestone #4 - Due September 30, 1985

@ .This milestone is intended to address BECo's needs for near and long term shielding in concert with the radioactive materials storage.

consolidation effort and is estimated to be 20% complete.

This shielding task is planned to proceed in parallel with the consolidation task and, therefore, is also scheduled to be complete on or before December 30, 1985.

SOSTON EDISON COMPANY November 7, 1985 Dr. T. E. Murley As previously communicated in Reference (C) the evaluation and program improvements proposed for the radioactive materials control system proved to be much more complex than originally realized and this has accordingly prompted a re-evaluation of the scheduled activities related to the radioactive material storage consolidation (Milestones 8.1.2/8.1.3/8.1.4 above).

e RIP 6.2.lk and 10.2.la both Milestone #2 - Due September 30, 1985 These milestones both pertain to procurement (i.e., hardware and software respectively) to improve the quality and reliability of the Whole Body Counting (HBC) program.

This effort has extended beyond scheduled completion due to unexpected delays in establishing proper scope definition and project justification to allow timely authorization of capital.

In this case, the capital authorization documents required recycling because they were not accompanied by an up-front implementation plan identifyh.g key activities and interdepartmental support. This process change was very recently implemented and mistakenly cverlooked by the proponent. The RIP Program Manager has since emphasized to the organizational managers the need to provide the up-front planning documentation inclusive with any capital authorization documents.

At this time, the capital authorization documents supporting procurement of the HBC equipment is approved and purchase orders are expected to be issued by November 30, 1985.

g e RIP 6.1.1, Milestone #1 - Due September 30, 1985 This milestone provides procedural guidance for enhancing the in-vitro bloassay program, including a requirement for random selection of personnel for obtaining samples. Although the task was completed within the original schedule, an unanticipated legal question was raised during ORC committee review of the procedure and, therefore, additional time was necessary to resolve this with our Legal Department. This milestone will now be completed on or before November 7, 1985.

e It should be noted that none of the above delays will have an impact on upcoming RIP milestones nor will they compromise the overall program goal of completion by year's end.

This request brings the total number of extended RIP milestones to ten (10) out of an original 209.

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BOSTON EDISON COMPANY November 7, 1985 IDr. T. E. Murley Notification regarding September's milestones 8.1.2, 8.1.3 and 8.1.4 was communicated to your office on October 1, 1985. Subsequently, the delays encountered with September's milestones 6.2.1k, 10.2.la

' and 6.1.1 were communicated on October 17, 1985 followed with a status and explanation telecon to Mr. Nimitz on Octobcr 31, 1985.

This letter confirms the agreement between Mr. Nimitz and Boston Edison's Program Manager and provides new milestones dates.

Very truly yours, iO*9 '

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