ML20196A562
| ML20196A562 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/28/1988 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| References | |
| NUDOCS 8802050094 | |
| Download: ML20196A562 (3) | |
See also: IR 05000293/1987033
Text
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JAN 281988
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Docket No.
50-293
. Boston Edison Company
ATTN: Ralph G. Bird
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Senior-Vice President - Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Gentlemen:
Subject: Inspection-No. 50-293/87-33
This refers to your letter dated December 21, 1987, in response 'to our letter
dated August 21, 1987.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
Sincerely,
RCRGT M. T.'.o
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William V. Johnston, Acting Director
Division of Reactor Safety
cc:
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K. P. Roberts, Nuclear Operations Manager
Paul Levy, Chairman, Department of Public Utilities
Chairman, Board of Selectmen
Plymouth Civil Defense Director
J. D. Keyes, Boston Edison Regulatory Affairs and Programs
E. D. Robinson, Nuclear Information Manager
R. N. Swanson, Nuclear Engineering Department Manager
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The Honorable E. J. Markey
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Senator Edward P, Kirby
The Honorable Peter V. Forman
Sharon Pollard, Secretary of Energy Resources
Peter W. Agnes, Assistant Secretary of Public Safety,
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Commonwealth of Massachusetts
Rachel Shimshak, MASSPIRG
y
Public Document Room (PDR)
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Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Massachusetts (2)
0FFICIAL RECORD COPY
RL PILGRIM 87-33 - 0001.0.0
01/11/88
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
PA0 (2) SALP Reports Only
Robert J. Bores, DRSS
S. J. Collins, DRP
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RL PILGRIM 87-33 - 0002.0.0
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Boston, Massachusetts o2199.
Ralph G. Bird
December 21', 1987
senior Vice President - Nucle at
BECo 'Ltr. #87 202
.U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Hashington, DC 20555
License No. DPR-35
Docket No. 50-293
Subject: NRC Inspection Report 50-293/87-33
Dear Sir:
Attached is a revision of Boston Edison Company's response (BECo Ltr. #87-176,
October 5,1987) to the Notice of Violation contained in the subject
inspection report. Our response is revised as a result of clarifications
obtained during a telephone conference between Boston Edison Company and NRC
representatives on November 10, 1987.
Subsequent to the NRC Inspection 87-33, multiple communications with the NRC
inspector occurred at our request.
These communications were necessary
because we did not effectively communicate our position during the
inspection.
The need for effective communication and diligence in
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investigating inspectors' concerns in a timely manner has been reemphasized to
the appropriate members of our staff.
Please do not hesitate to contact me directly if you have any questions.
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.G. Bird
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BPL/la
Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Sr. Resident Inspector
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ATTACHMENT
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Boston Edison Company
Docket No. 50-293
Pilgrim Nuclear Power Station
License No. OPR-35
10CFR50.54 (a)(1), requires each nuclear power plant licensee subject to the
Quality Assurance Criteria in 10CFR50, Appendix B, to implement pursuant to
10CFR50.34(b)(6)(ii), the quality assurance program described or referenced in
the Safety Analysis Report, including changes to that report.
Boston Edison Company Quality Assurance Manual (BEQAM) Volume II implements
the requirements of 10CFR50, Appendix B.
BEQAM, Section 6, Document Control,
requires that measures be established to assure that documents affecting
quality are reviewed for adequacy and approved for release by authorized
personnel.
Contrary to the above on August 6,1987, it was determined that Plant Design
Change (PDC) 86-70, Standby Gas Treatment System Modification, had been
reviewed, released and implemented but did not completely specify design
verification testing requirements as required by BEQAM, Section,3, Paragraph
3.3.2.8., specifically electrical functional and logic testing requirements.
In addition, Temporary Procedure 87-128, Preoperational Test of Standby Gas
Treatment System (SBGTS) Modification Per PDC 86-70 was reviewed, approved and
released for performance on July 22, 1987 and contained several errors and did
not verify all design aspects of PDC 86-70.
Specifically, neither the formal
review process of PDC 86-70, nor the formal review of TP 87-128 identified the
missing testing requirements of the PDC or the failure of the TP to fully
verify the SBGTS modified design.
Resoonse
Discussion:
On November 10, 1987, Boston Edison Co. management personnel contacted NRC
Region I management personnel via telecon to provide further explanation
of the position described in our initial response to the Notice of
Violation dated October 5, 1987. This dialogue enhanced our understanding
of the basis for the Notice of Violation.
He concur with the inspector's general concerns regarding the adequacy of
reviews and the need to more completely specify preoperational testing
requirements in Plant Design Change packages. During the telephone
conference, however, it was agreed that the perceived errors in TP87-128,
identifled in Sections 2.2.B", 2.2.0 and 2.2.E'of the Inspection Report,
were not errors. Although it was agreed that the error identified in
Section 2.2.A of the inspection report would have been identified during
the conduct of the test, it was also agreed that errors of this nature
could be eliminated by a more thorough technical review. Agreement was
not achieved regarding the perceived error identified in Section 2.2.C"of
the Inspection Report, as we continue to believe that a cognizant
inclusion of an unnecessary procedural step is not an error.
Page 1 of 3
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ATTACHMENT 1 (Cont.)
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The errors in TP 87-128 were identified by the inspector prior to the
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implementation of the preoperational test. During the conduct of a
preoperational test, the test is halted if a discrepancy is identified.
The discrepancy must be resolved and the procedure reviewed prior to.
continuing the test.
This conservative testing philosophy, in combination
with the multiple levels of review and verification associated with the
plant modification process, provide assurance against the possibility of
errors in the final product.
However, we recognize that the propensity to
rely on the process, as opposed to assuring that the job is done right at
each step in the process, must be guarded against.
Cause:
The errors identified in TP87-128 were a result of a lack of a thorough
technical review by independent reviewers.
These reviews may have
resulted from a substantial increase in individual work load in support of
the plant outage.
In particular, procedure reviewers are normally
selected from the line organization based on their technical expertise.
These line organization reviewers have concurrent managerial and/or
technical responsibilities. Although the need to take the time to do the
job right the first time has been repetitively communicated by senior BECo
management, a cituation of conflicting priorities may have resulted in a
less thorough preoperational test review than desired.
The incomplete specification of electrical functional and logic testing
requirements in PDC 86-70 resulted from a lack of procedural definition or
other guidance regarding the level of detail required to be specified in a
PDC.
Because of this lack of guidance, the level of detail of testing
requirements specified in PDC's has been inconsistent. He believe this
situation developed in part because of the demonstrated ability of the
Modification Management Group's personnel to prepare preoperational tests
with limited direction from the Nuclear Engineering Department.
Corrective Actions Taken:
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The Nuclear Engineering Department issued Technical Quality Memo
(TQM) No. 92 on August 19, 1987 to reemphasize to engineering
personnel the responsibility to clearly specify testing and
acceptance requirements in Plant Design Change packages.
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The Design Review Board (DRB) members have been specifically
reinstructed concerning their responsibility to assure PDC packages
contain complete preoperational testing requirements.
The DRB
members are comprised of the engineering discipline Group Leaders who
are responsible for the performance of engineers performing design
functions for Pilgrim Nuclear Power Station.
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Temporary Procedure (TP)87-128 has been revised to correct the
identified discrepancies.
TP87-128 Revision 3 was completed on
August 29, 1987.
Page 2 of 3
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ATTACHMENT 1 (Cont.)
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The Modifications Management Group of the Nuclear Operations
Department has established a three man team to conduct independent
reviews of the preoperational test for the duration of RF0 No. 7.
This review tean has no other concurrent responsibilities and
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provides additional assurance that the large number of modifications
implemented during RF0 No.7 receive thorough reviews.
Corrective Steps To Be Taken:
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As comitted in TQM No. 92, NED procedures will be revised to specify
the level of detail required for preoperational testing requirements
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in PDC packages.
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A process is being developed (proceduralized) to require comments
from the station review of PDC packages to be collected by the
Modification Management Group and sent to the Nuclear Engineering
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Department (NED) for disposition prior to approval by the Operations
Review Committee.
This process will provide feedback to the NED on
PDCs released to the station.
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The results of the three man team's independent review of the
preoperational tests prepared during RF0 No. 7 will be evaluated to
allow incorporation of lessons learned to the preoperational test
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review process if appropriate.
Date of Full Compliance:
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Full compliance was achieved on August 29, 1987 when TP87-128 Revision 3
was completed.
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Page 3 of 3
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BOSTON EDISON
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300 BWsty street
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Ralph G. Bird
October 5, 1987
semor Vice Presioent - Nuoear
BECo Ltr. #87-176
U.S. Nuclear Regulatory Commission
Attention:
Document Control Desk
Hashington, DC 20555
License No. DPR-35
Docket No. 50-293
Subject: NRC Inspection Report 50-293/87-33
Dear Sir:
Attached is Boston Edison Company's response to the Notice of Violation
contained in the subject inspection report.
Based upon our review and investigation of the matters described in the
subject inspection report, we do not believe a Violation is appropriate. The
basis for this position is described in the Attachment to this letter. A
meeting with the appropriate level of NRC management has been requested to
allow further explanation of our position and the reasons we believe that the
Notice of Violation should be withdrawn.
Please feel free to contact either myself or Mr. Robert Grazio (Telephone
617-747-8189) if you have any questions.
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R.G. Bird
BPL/la
Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Sr. Resident Inspector
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ATTACHHEMI
Boston Edison Company
Docket No. 50-293
Pilgrim Nuclear Power Station
License No. DPR-35
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Notice of Violatiqn
10CFR50.54 (a)(1), requires each nuclear power plant licensee subject to the
Quality Assurance Criteria in 10CFR50, Appendix B, to implement pursuant to
10CFR50.34(b)(6)(ii), the quality assurance program described or referenced in
the Safety Analysis Report, including changes to that report.
Boston Edison Company Quality Assurance Manual (BEQAM) Volume II implements
the requirements of 10CFR50, Appendix B.
BEQAM, Section 6, Document Control,
requires that measures be established to assure that documents affecting
quality are reviewed for adequacy and approved for release by authorized
personnel.
Contrary to the above on August 6, 1987, it was determined that Plant Design
Change (PDC) 86-70, Standby Gas Treatment System Modification, had been
reviewed, released and implemented but did not completely specify design
verification testing requirements as required by BEQAM, Section 3, Paragraph
3.3.2.8., specifically electrical functional and logic testing requirements.
In addition, Temporary Procedure 87-128, Preoperational Test of Standby Gas
Treatment System (SBGTS) Modification Per PDC 86-70 was reviewed, approved and
released for performance on July 22, 1987 and contained several errors and did
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not verify all design aspects of PDC 86-70.
Specifically, neither the formal
review process of PDC 86-70, nor the formal review of TP 87-128 identified the
missing testing requirements of the PDC or the failure of the TP to fully
verify the SBGTS modified design.
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Resoonse
Boston Edison believes that Plant Design Change (PDC) 86-70 and Temporary
Procedure (TP)87-128 were prepared, reviewed, approved, released and
implemented in compliance with the requirements of 10 CFR Part 50, Appendix B
and the Boston Edison Quality Assurance Manual (BEQAM). He have, however,
implemented actions described at the end of this response to further
strengthen the PDC testing process.
Discussion:
The subject Notice of Violation identifies three issues as follows:
1.
PDC 86-70 did not completely specify design verification testing
requirements as required by BEQAM, Section 3, Paragraph 3.3.2.8,
specifically, electrical functional and logic testing
requirements.
2.
TP 87-128 contained several errors and did not verify all design
aspects of PDC 86-70.
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Page 1 of 5
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ATTACHMENT (Centd
3.
The review requirements of 10CFR50, Appendix B and SE0AM Volume
II, Section 6, Document Control were not fully implemented as
evidenced by issue (1) and (2) above.
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The balance of this discussion is formatted to address each of these
issues.
Issue 1 - Design Verification Requirements:
Qualification testing is one of the BEQAM approved methods for
performing design verification, but was not chosen for PDC 86-70.
Instead, PDC 86-70 was verified using the design review method as
permitted by the BEQAM.
The PDC received multiple levels of review and approval including
independent, interdisciplinary and Quality Assurance Department
reviews and approvals.
In addition, calculations were made and
independently reviewed to support the design.
The multiple reviews
and calculations verified the adequacy of the design and satisfied
the requirements of BEQAM Paragraph 3.3.2.8.
The reviews and
calculations are documented in the PDC package. Qualification
testing was not used as a verification method for this PDC.
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Our plant design change procedures require that preoperational test
requirements and acceptance criteria are specified in the PDC.
The
preoperational test TP 87-128 was prepared to verify the functions of
the SBGTS for the different modes of operation. The requirements of
Section 3.3.2.8 of the BEQAM do not apply to TP 87-128 since it is
not a design verification test.
Section 10.4.2.27 of the work instruction for PDC 86-70 specifies the
testing requirements for the logic portion of the PDC and identifies
the required calibrations.
Sections 10.5.19 and 11.4 of the work
instruction specified the acceptance tests required for electrical
equipment. The level of detail specified in these sections of the
PDC was adequate to assure that the SBGTS functions were verified.
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Issue 2 - Alleged Errors
Our responses to the specific discrepancies identified in Section 2.2
of the Inspection Report follow.
Section 2.2.A states,
"Paragraphs 7.2.5, 7.3.5 and 7.4.5 required 5 damper control
switches to be in the auto position and their associated dampers
in the open position.
The associated dampers would be in the
closed position with the specified switch position and no
initiation signal present."
Response:
Although the procedure was in error as stated the errors would
have been identified during the conduct of the test as follows:
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If the dampers were wired correctly, discrepancies between
the observed damper positions and the damper positions
specified in TP 87-128 would have been apparent.
Page 2 of 5
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ATTACHMENT (Cont.)
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Only two of the five dampers were affected by the
modi fication.
If those two dampers affected by the
modification were wired incorrectly, a discrepancy between
the modified dampers and non-modified dampers would have
been apparent.
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In either case, TP 87-128 specified the correct damper
positions in Attachment E, Steps El thru E20.
Therefore, if
the discrepancies had not been previously identified, they
would have been identified in these steps.
Procedure 1.3.4 "Procedures" defines the process by which
procedures are revised when errors are identified.
Prior to
completion of the test, the discrepancy would have been resolved
and TP 87-128 would have been corrected.
Section 2.2.8 states,
"Section 7.3.8 and 7.3.8.9 did not require verification that
valve AON-112 closed when the 'B' Standby Gas Treatment System
(SBGTS) fan tripped (per procedure).
Inlet valve A0N-106 was
verified as closing."
Response:
A0N-112 was verified to close during previous steps in the
procedure which tested major portions of the circuit.
Steps
7.3.8 and 7.3.8.9 tested discrete portions of the circuit that
feed the previously tested A0N-112 circuit.
Those portions of
the circuit were verified to be functional by these steps.
This
overlapping test method adequately demonstrates functionality of
the subject valve.
Section 2.2.C states,
"Paragraph 7.3.8.6 required the differential pressure across the
calibrated perforated plate (DPI-AA-32) in the 'B' SBGTS train
to be recorded with the 'B' SBGTS in standby (off).
This
reading was being taken to measure 'B' train bypass flow so it
could be combined with 'A' train to determine system flow.
Under the system conditions specified this reading would be zero
(0) since one of the SBGTS modifications moved the upstream
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bypass flow connection such that the connection between the A
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and B SBGTS trains is now downstream (bypassing) of the
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calibrated orifice plate. The flow recorded on the
'A'
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calibrated orifice plate would represent full system flow for
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the specified lineup."
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Response:
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Recording flow through the standby train of the SBGTS was
recognized as not being required in the draft review of the
procedure.
It was determined that the reading should be left in
the procedure based on the following:
Analysis of the data can be used to show no flow through the
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standby train when there should be no flow.
This would
reflect the integrity of the standby train inlet damper.
Page 3 of 5
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ATTACHMENT (Cont.)
Reading standby train flow is of no consequence to the test
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performance or results.
Section 2.2.0 states,
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"Train 'B' logic requires AON-106 damper (inlet) to open and
pick up a position limit switch which allows the
'B'
SBGTS fan
to start and outlet damper A0N-112 to open.
This logic sequence
would occur during any start of the 'B' SBGTS train and was not
checked in TP 87-128."
Response:
Although the logic sequence was not verified, the component
functions were verified to occur.
The actuation logic for this
series of functions is as follows. A0N-106 opens which operates
a limit switch starting the fan. A contact on the fan motor
starter relay causes AON-il2 to open. This sequence was
modified by the design. However, numerous independent wiring
errors in several locations would be required for the components
to function in other than the desired sequence.
Design
verification and construction verification, including QC
verification of the as-built versus design configuration,
provided assurance that the system wiring was correct.
Verification of the logic sequence was considered redundant.
Section 2.2.E states,
"The procedure did not verify that per design the 'B'
S8GTS
train would remain running after 20 minutes if the 'A' train had
insufficient flow or was tripped with the 'B' train in standby.
The system is designed to trip the 'B' train after 20 minutes if
sufficient flow exists."
Response:
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The design sequence of operation following auto initiation of
the SBGTS is as follows:
Both 'A'
and 'B' SBGTS trains start.
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After 20 minutes of operation the standby ('B') train
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shutsdown,
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If insufficient flow or no flow (' A' SBGT fan tripped) is
sensed, the standby ('B') train reinitiates after a 10
second time delay and locks in for a continuous run.
Section 7.3 of TP 87-128 properly demonstrated these functions.
This was discussed in detail with the inspector subsequent to
the inspection.
Issue 3 - Review Requirements:
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Criterion VI and BEQAM Section 6, require that
document control measures be established to control issue and
revision of documents which prescribe activities affecting quality.
These measures assure that documents, including changes, are reviewed
for adequacy and approved for release by authorized personnel.
Page 4 of 5
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ATTACHMENT (Cont.)
Both PDC 86-70 and TP 87-128 were reviewed and approved in accordance
with approved BECO procedures.
These procedures require multiple
reviews and approvals that were fully documented in TP 87-128 and
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PDC 86-70.
Based upon our response contained herein, we.believe that
adequate reviews of both FCC 86-70 and TP B7-128 were performed.
Additional Actions:
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The following additional actions have been taken or are planned to
further strengthen the PDC process:
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As immediate action the Nuclear Engineering Department issued
Technical Quality Memo No. 92 on August 19, 1987, to reemphasize
to engineering personnel the responsibility to clearly specify
testing and acceptance requirements, in Plant Design Change
packages. As committed in memo No. 92 NED procedures applicable
to design verification testing will be revised to-clarify
existing requirements.
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Temporary Procedure (TP)87-128 has been revised to correct the
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identified discrepancies.
TP 87-128 Revision 3 was completed on
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August 29, 1987.
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The Modifications Management Group of the Nuclear Operations
Department has established a three man team to conduct
independent reviews of the preoperational tests for the duration
of RF0-7.
This team provides additional assurance that the
large number of modifications implemented during RF0 No. 7
receive a thorough review for preoperational testing
requirements.
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