ML20064L217

Forwards Performance Improvement Program in Response to NRC 820118 Order Modifying License,Effective Immediately. Program Details 18 to 24-month Period That Will Result in Demonstrated Effective Regulatory Performance

ML20064L217
Person / Time
Site:	Pilgrim
Issue date:	03/18/1982
From:	Harrington W BOSTON EDISON CO.
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19291G193	List: ML20064L214 ML20064L217 ML20064L222
References
82-86, EA-81-063, EA-81-63, NUDOCS 8204160222
Download: ML20064L217 (3)

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Co:: TON EHCCN CMMPANY  ;

500 BOVLsTON STREET l

BOeTON, MASSADMUSETTS D2199

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f wituam o. MARRMSTON March 18, 1982 l BECo. Ltr. No. 82-86 l 1

Mr. Ronald C. Haynes. , f' Regional Administrator ,

U.S. Nuclear Regulatory Commission i Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 License No. DPR-35 i Docket No. 50-293 l

Dear Sir:

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, By letter dated January 18, 1982, the Commission by the Director of l Inspection and Enforcement, issued an Order Modifying License Effective -

Immediately (the Order). This Order required that Boston Edison Company  !

(BECo) submit to the Administrator of Region I of the Nuclear Regulatory l Commission (NRC) for review and approval, a comprehensive plan of action j l

(the Plaa) that "will yield an independent appraisal of site and corporate j management organizations and functions, recommendations for improvements  !

in management controls and oversight, and a review of previous safety-  !

related activities to evaluate compliance with NRC requirements." On l February 16, 1982, at BECo's request, the time for submission of the l

Plan was extended to March 19, 1982.

l The attached Boston Edison Performance Improvement Program submitted in i response to the Order details an 18 to 24 month program that will result l in demonstrated effective regulatory performance and continued safe and l

reliable operation of the Pilgrim f acility. The program includes an

! independent appraisal of site and corporate organizations and functions,  !'

! modifications in organizational structure, improvements to be made in aanagement control and oversight systems, and programs designed to improve individual performance.

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The indapendent appraisal is likely to provide information relevant to i both the scope and schedule of the Performance Improvement Program, and i is likely to modify _ the long term tasks and milestones identified in the - .

i attached plan. BECo will provide the Administrator of Region I of the I NRC all program revisions and a description of implementation staff l requirments, documentation requirements, and specific schedule milestones I' Lin July 1982.

We believe the program is comprehensive and focused on effective management

.for continued safe plant-operation. The following are considered to be key tasks. Specific reference to each aspect of the Order is provided.

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WOSTON EOCIN COMPANY .

. March 18, 1982 )

Page Two i

BECo intends to better control the scheduling and implementation of  !

future modification work performed within the plant. This will be ,

accomplished by limiting the. total number of craf t personnel as well as l the ntaber of areas being worked. Complete engineering and procurement will be accomplished prior to the start of work to minimize construction l durations. Engineering and analysis efforts will be similarly maintained l at safe, effective, manageable levels. Work scoping, planning and j authorization will be implemented with improved rigor and work activities i more effectively controlled. Emphasis will be placed on the quality of ,

-work and the ability to achieve committed completion dates. This control program was discussed with Region I personnel on February 16, 1982 and '

with NRR at our meeting on February 19, 1982 and may require schedule i rtdief from NRC in meeting certain in service dates, for future modifi- ,

cation. This strategy is an essential supporting element of the Perfor- j mance Improvement Plan.  !

Obviously a key milestone in the process is the approval of the Comprehensive l Plan. BECo believes the Plan is responsive to the NRC request; however, i we are prepared'tndiscuss and resolve any questions which may arise. We j also consider the Plan to be sufficiently comprehensive to encompass the prr51 ems identified in your Inspection Report dated February 4,1982. i Once the Plan is approved, BECo will continue to update the NRC through '

periodic meetings at a frequency to be specified by Region I. l Very truly yours, j i

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4^'Jd'E WDH/ag 4  :

Enclosures l cc:

Mr. Richard C. DeYoung, Director  ;

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BECO COMPREHENSIVE ACTION PLAN FOR PERFORMANCE IMPROVEMENTS I i

t Reference Paragraph in Section V  !

Task to Order Modifying License i

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1. INDEPENDENT REVIEW AND EVALUATION E

1. Management Analysis Company Assessment 1 i

2. Organizational Peer Group Review of 1 5 Independent Evaluation +

t II. ORGANIZATION

1. Corporate On-Site Review 6  ;

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2. Safety Organization Review 3,6,7 i t

III. MANAGEMENT SUPPORT SYSTEMS

1. Commitment Management Systems 2 L

a. Commitment Control f

b. Regulatory Change and Compliance

c. Corrective Action

d. Correspondence Review

2. Safety Management Systems 3,6,7  !

a. Safety Review and Assessment

b. QA Audit Program i

3. Configuration Management Systems 4

a. Modification Management [

b. Plant Procedure and Drawing Evaluation

c. Testing Program  ;

d. Preventative Maintenance System IV. INDIVIDUAL PERPORMANCE l t

1. Improved Training Program 5  :

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