ML20149G441
| ML20149G441 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/11/1997 |
| From: | Boulette E BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-293-97-02, 50-293-97-2, BECO-LTR-2.97.0, NUDOCS 9707230224 | |
| Download: ML20149G441 (5) | |
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Boston Edison i
Pdgrim Nucioar Power Staton Rocky Hdi Road
. Plymouth, Massachusetts 02360 July 11,1997 E. T. Boulette, PhD Senior Vice President - Nuclear ^
7 U.S Nuclear Regulatory Cornmission Document Control Desk Washington, D.C. 20555 License DRP-35 Docket 50-293 l
SUBJECT:
SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION (REFERENCE NRC INSPECTION REPORT NO. 50-293/97-02)
Enclosed is Boston Edison Company's supplemental reply to the Notice of Violation contained in the subject inspection report, in the initial reply to the Notice of Violation (97-02-02), documented in BECo letter 2.97.065 dated June 20,1997, we committed to submit a supplemental response to address vendor interface issues by July 11,1997. This letter describes the status of actions taken or ongoing to address vendor interface issues.
The following commitment is made in this letter:
i Develop criteria that identifies categories of vendor interface (e.g., Specialty skills, proprietary l
Information used for analyses or calculations, atypical or prototype design) that will require additional controls. Create a checklist or matrix for determining additional controls when special vendor oversight / interface is required. This commitment will be completed by l
December 31,1997.
Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
LLb E.T. Boulette, PhD KRD/dmc/297073
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. Enclosure 1: Supplemental Reply to Notice of Violation Oi 5
9707230224 970711 T'
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cc:
Mr. Alan B. Wang, Project Manager Project Directorate 1-3 l
Office of Nuclear Reactor Regulation Mail Stop: OWF14B2 l
U, S. Nuclear Regulatory Commission l
1 White Flint North 11555 Rockville Pike Rockville, MD 20852
. U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector l
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Besten Edison Docket No. 50-293 l
Pilgrim License No. DPR-35 i
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Supplemental Reply to Notice of Viols. tion l
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- The cover letter of Inspection Report 97-02 states, in part, "... additional problems with the l
interface / oversight of vendor activities were observed during RFO #11 including rework of the L
ECCS suction strainer slip joint clearances and the physical damage to the main steam line plugs that occurred when lowering the steam separator into the vessel. Both examples involved over-reliance on vendor communications. Also, continuing problems were experienced with RWCU pump mechanical seals. The adequacy of the interface with vendors was documented in NRC inspection Report No. 50-293/95-22."
Adecuacy of Interface with Vendors Documented in IR 95-22/lFl 95-22-02 in NRC Inspection Report 95-22, an inspector follow item, IFl 95-22-02, was opened conceming vendor services. The inspector considered the area of root cause analysis of supplier / vendor-
~ related problem reports to be a potential program weakness, and ownership of related corrective action items (related to vendor controls) regarding measures to preclude problem recurrence was not clear.
I Since Inspection Report 95-22 was issued, significant changes were made in the Problem Report L
' (PR) program to strengthen the root cause analysis process.. Fundamental to the change is the classification of a problem report into one of two levels, significant conditions adverse to quality (SCAQ) or non-SCAQ.
A SCAO level problem undergoes a detailed root cause analysis. The group-level marager responsible for the analysis approves the cause and corrective action to preclude recunence.
Corrective actions to preclude recurrence must meet 3 criteria to be considered valid:
e ~ The problem would not have occurred had the noted cause not been present.
The problem will not recur due to the same cause if the noted cause is corrected or eliminated.
' Correction or elimination of the noted cause will prevent recurrence of similar conditions e
which could occur due to the same cause, in addition to group-level manager approval, a root cause analysis and its corrective actions must be approved by the Corrective Action Review Board (CARB). The CARB reviews all PR root
. cause analyses for technical content, accuracy, adequacy of all corrective actions, and administrative completeness / acceptability.
- If a vendor-related problem is designated as a SCAQ, then the cause and corrective action l
undergoes the analysis and approval process. Therefore, ownership of corrective action items related to vendor controls regarding measures to preclude recurrence is clear and within the framework of the corrective action process.
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Discussion Historical vendor interface issues including these examples served as a basis for developing preliminary criteria regarding vendor oversight / interface:
ECCS Suction Strainer Slip Joint f
Main Steam Line Plugs Regulating Transformers
. Fuel Shutdown Margin n
There are two general types of vendors / contractor support augmentation and specialty. The -
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. work force must be augmented for maintenance,- projects and engineering because of the
.l increased workload and shift coverage during outages. In these cases, we are able to monitor performance and its effectiveness because we possess the expertise ourselves. This has not proved to be an area of significant concern relative to vendor interface.
_i There is, also, heavy reliance on contractors who possess, for example: specialty skills and 3
knowledge, proprietary information used for analyses or calculations, unique modifications and/or new designs (prototype).
L In some cases, our oversight did not identify the critical design and implementation criteria. As a l
result of this insight, preliminary attributes have been identified regarding the issue of vendor I
oversight and vendor interface. These attributes, although preliminary, serve to determine whether or not a vender is a specialty contractor. The attributes include:
Is the task routine or a one time task l
Does the vendor possess specialty knowledge and skills ?
Is the vendor's information proprietary ?
Is time a factor 7
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Once these attributes are developed, we plan to create a matrix that flags extra measures or L
precautions to be taken depending on the attributes of the specialty service being considered.
l Preliminary examples include Require third party review Independent verification Enhanced management oversight of the implementation Augmented quality oversight -
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Identify critical design and implementation criteria Augmented quality inspection of vendor design process i
Also, a common cause analysis is being conducted for problems identified during RFO #11.
When this letter was prepared, the common cause analysis had not been completed. The l-results of the common cause analysis will be reviewed regarding vendor oversight / interface to l
determine if additional adjustments to the identified corrective actions are necessary.
~ Summarv
' In recognition of vendor interface / oversight as an area for improvement, we are planning the following action independent of on-going root cause or common cause analyses:
Develop criteria that identifies categories of vendor interface (e.g., specialty skills, proprietary information used for analyses or calculations, atypical or prototype design) that will require additional controls. Create a checklist or matrix of additional controls when special vendor oversight / interface is required.
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in addition, we will complete the following as part of our established corrective action process:
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'.. [ Review the results of the RFO #11 common cause analysis regarding vendor oversight / interface issues. The focus of the review is to determine if additional actions or l
adjustments are necessary for vendor oversight / interface.
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. Complete the root cause analysis for the ECCS suction strainer slip joint clearances and implement corrective actions identified, i
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