ML20213F870
| ML20213F870 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/06/1986 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Lydon J BOSTON EDISON CO. |
| References | |
| NUDOCS 8611170222 | |
| Download: ML20213F870 (6) | |
See also: IR 05000293/1986014
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6 1986
Docket No. 50-293
Boston Edison Company M/C Nuclear
ATTN: Mr. James M. Lydon
Chief Operating Officer
800 Boylston Street
Boston, Massachusetts 02199
Gentlemen:
Subject:
Inspection Reports No. 50-293/86-14 and 50-293/86-21
Our review of Boston Edison responses dated August 25, 1986, and September 24,
1986, to NRC inspection reports 86-14 and 86-21 respectively, indicates that
you did not clearly address our concerns. Those areas requiring supplemental
response are identified in attachments 1 and 2.
Please provide, within thirty
days of the receipt of this letter, a written response fully addressing these
items.
Your cooperation with us in this matter is appreciated.
Sincerely,
Original signoe 3 ,
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William Kane, Director
Division of Reactor Projects
Enclosures:
1.
Concerns Regarding Response to IR 50-293/86-14
2.
Concerns Regarding Response to IR 50-293/86-21
cc w/ enc 1:
L. Oxsen, Vice President, Nuclear Operations
A. E. Pedersen, Station Manager
Paul Levy, Chairman, Department of Public Utilities
Chairman, Board of' Selectmen
J. D. Keyes
Plymouth Civil Defense Director
Congressman E. J. Markey
Senator Edward P. Kirby
The Honorable Peter V. Forman
Sharon Pollard
Public Document Room (PDR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Massachusetts (2)
0FFICIAL RECORD COPY
NRC PIL RESPONSE LTR - 0001.0.0
8611170222 861106
ADOCK 05000293
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06 NOV 1988
Boston Edison Company
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10/1i/86
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0FFICIAL RECORD COPY
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bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
W. Raymond,_ SRI, Vermont Yankee
T. Shedlosky, SRI, Millstone 1&2
H. Eichenholz, SRI, Yankee
P. Leech, LPM, NRR
PA0 (2) SALP Reports Only
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Robert J. Bores, DRSS
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ENCLOSURE 1
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' CONCERNS REGARDING RESPONSE TO
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INSPECTION REPORT 50-293/86-14
/A
Senior Managemerit Response 'to Quality Assurance Issues
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Actions taketi to promote effective communication and prompt action on QA
findings at the station level are adequately addressed in your response
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to inspection report 86-14. However',' the cover ~1etter of inspection
report 86-14 expressed concern about the apparent lack of senior
Morporate management initiative in resolving Quality Assurance (QA)
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identified issues.
Specifically; t'eports of delinquent QA responses had
bs n routinely provided at the Vfch-President level prior to our
inspection, but little senior management action was evident.
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Neasures 'to ensure that senior managers are active in resolving quality
' assurance issues were not clearly described in your response.
Please
provide an explanation of. steps taken to resolve this concern.
B.
Response to Notite of Violation, Item A
Your response does r.ht, address three--specific items described in Item A
of the Notice of Violations (HOV). Please provide.an_ explanation of
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actions taken in these areas.f
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(1) NOV item: . The Boston Edison Quality Assurance Hanual (BEQAM)
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required that Deficiency Reports (DR) be eithet dispositioned within
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90 days or have a DR extension authorized by the appropriate' Vice
President. However, no Vice President extension was requested
either before or after DR 1466 exceeded its 90-day completion date.
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Boston Edison response: The Quality Assurance Manual will be
revised to; require that'the Quality Assurance Depa*tment (QAD)
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notify the appropriate department manager and Vice President when
the 90 day time limit has been exceeded for each Dil. The department
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manager is advised that unless QAD receives an extersion in 15 days,
the DR will be escalated to the-VP for resolution.
Bcston Edison
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also stated that the VP of.Duclear Operations now requires that
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weekly status reports be submitted for all open DR's and that this
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NRC conceren Actions planned in the event of overdue DR's appear
Tess reurlctive than previous requ'raments,
i.e., an additional 15
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day period is allo.ed prior to escalation to the VP level. Also, OR
status reports vera previously provided to senior management. Why
is the previous 90-day resolution requirement being relaxed and how
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will senior management b'ecome more actively . involved?
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OFFICIAL RECORD COPY
NRC PIL RESPONSE LTR - 0002.0.0
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(2) NOV item: The BEQAM requires that a DR identifying conditions
reportable tc ,the NRC be classified as significant. However, the
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reportable surveillance test problem identified by DR 1466 was not
classified as significant.
Boston Edison response: The BEQAM will be revised to state that all
Technical Specifications or FSAR deviations and all potentially
reportable 10 CFR Part 21, 10 CFR 50.72 and 10 CFR 50.73 items found
during a audit or surveillance will be issued as a significant
Deficiency Report.
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NRC concern: The BEQAM previously required that the above items,
with the exception of FSAR deviations, be classified as significant.
What action has been taken to ensure significant findings are
properly identified?
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(3) NOV item: The BEQAM required that a written request for a second
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response for a disputed DR be forwarded to and approved by the
appropriate Vice President. However, the QA request for a second
response to DR 1466 was not forwarded to the appropriate Vice
President after the initial DR finding was disputed.
Boston Edison response: The SEQAM and N0P83A13 N111 be revised to
require all requests for second responses be forwarded to the
appropriate Vice Presiderit.
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NRC concern:
Since this requirement previously existed it is again
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unclear what action has been taken.
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0FFICIAL RECORD COPY
NRC PIL RESPONSE LTR - 0003.0.0
10/28/86
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ENCLOSURE 2
CONCERNS REGARDING RESPONSE TO
INSPECTION REPORT 50-293/86-21
The cover letter transmitting NRC inspection report 86-21 identified five
specific areas of concern.
Boston Edison letter 86-147, attachment 2, details
your response to these items. We have the following questions about your
response.
A.
Your response stated that if no clear cause for the recurring failure of
the recirculation motor generator set field breaker failures can be
established, more frequent surveillance testing will be implemented.
It
is our position that an increase in surveillance frequency cannot
compensate for unreliable equipment.
If a definite failure cause is not
identified, the ability of this equipment to function will remain in
question. We expect your final response to Region I on the AKF breaker
issue to address this concern. We understand that the AKF response will
be submitted at least 45 days before startup.
B.
Regarding the apparent failure to properly schedule surveillance tests,
Boston Edison committed to perform an analysis and submit an updated
response to Region I by November 21, 1986. This issue was identified
approximately six months prior to your analysis completion date.
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Considering that surveillance tests could be required for current plant
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modes, please explain the caust for the delay in your analysis.
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C.
Inspection report 86-21 identified several concerns regarding the
technical adequacy of surveillance testing. Boston Edison was requested
to respond to a specific concern about the completeness of emergency core
cooling system (ECCS) logic system functional tests.
However, your
response does not address the completeness and adequacy of the logic
system functional tests.
Instead, it discusses other surveillance
concerns in our inspection report. Please describe your plans and
positions on this specific issue.
D.
Your response to our concern regarding fire brigade training stated that
35 brigade members have not participated in a drill in 1986. However,
current plans would allow individuals to remain active members of the
brigade without meeting minimum drill requirements until the end of 1986.
It is our position that you are committed to meet minimum drill require-
ments for all active brigade members and that only individuals who
currently meet the minimum drill requirements are eligible for brigade
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duty.
Please describe your plans to meet these criteria.
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NRC PIL RESPONSE LTR - 0004.0.0
10/28/86