ML20046B052

Forwards Thirty Day Response to Concerns Stated in Encl to 930428 Ltr Re Undervessel Work at Plant.Stated Concerns Could Not Be Substantiated

ML20046B052
Person / Time
Site:	Pilgrim
Issue date:	05/24/1993
From:	Boulette E BOSTON EDISON CO.
To:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20046B040	List: ML20046B052
References
BECO-93-68, NUDOCS 9308030045
Download: ML20046B052 (4)

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• BOSTON EDISON Pilgnm Nuclear Power Station Rocky Hal Road Plymouth, Massachusetts 02300 E. T. Boulette, PhD Senior Vee President-Nuclear May 24 , 1993 BEco Ltr. 93- 68 Mr. James T. Wiggins, Acting Director  !

Division of Reactor Projects, Region I  !

U.S. Nuclear Regulatory Commission .l 475 Allendale Road J King of Prussia, PA 19406 1

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Docket No. 50-293  !

License No. OPR-35 I

Subject:

RESPONSE TO CONCERNS REGARDING ACTIVITIES AT l PILGRIM NUCLEAR POWER STATION 1

Dear Mr. Wiggins:

The purpose of this letter is to provide Boston Edison Company's thirty day response to concerns stated in the enclosure to your letter of April 28,.1993, regarding the undervessel work at Pilgrim Nuclear Power Station.

Boston Edison Company has thoroughly reviewed and evaluated the stated  ;

concerns. Based on the results of our review and evaluation it was concluded l the stated concerns could not be substantiated. i The details of our review and evaluation are provided in Attachment 1. If ,

further information is required regarding this response, please do not l hesitate to contact me. l 7 OLLLth ]

E. T. Boulette l RLC/bal l

Enclosure 9309030045'930722 ..

PDR ADOCK 050002932 P PDR

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Page 2 BEco Letter 93- 68 cc: Mr. Thomas'T. Martin .

Regional Administrator, Region I U.S.- Nuclear Regulatory. Commission

'475 Allendale Rd. #

King of Prussia, PA 19406 ,

Mr. R. B. Eaton .

Div. of Reactor Projects I/II Office of NRR - USNRC H l One White Flint North - Mail Stop 14D1 1 L

11555 Rockville Pike s Rockville, MD 20852 Sr. NRC Resident Inspector - Pilgrim Station  ;

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ATTACHMENT I

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RESPONSE TO CONCERNS Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Boston Edison Company has thoroughly reviewed and evaluated the concerns stated in the enclosure of Mr. Wiggins' letter of April 28, 1993, regarding the undervessel work at Pilgrim Nuclear Power Station. The undervessel work was being accomplished by a contract organization hired by Boston Edison Company. The expressed concerns have been labeled "A", "B", and "C" respectively.

The results of our review and evaluation are discussed below.

CONCERN "A" Contractor work packages are incomplete and lack current information (i.e.,

drawings, vendor manuals). Associated radiation work permits are not being properly referenced.

RESPONSE TO CONCERN "A" Boston Edison Company's Quality Control Division performed a review of six work packages assigned to the contractor for accomplishment. The purpose of the review was to determine if the work package contained proper work direction, logical sequencing, assignment of production and quality control hold / witness points, and clarity. Based on this review, no discrepancies were-identified.

In addition, contractor personnel performing undervessel work were individually interviewed. During the course of the interviews, the individuals were asked to express any concerns they had regarding the quality and completeness of work packages / documents they had worked with during RF0 9 at Pilgrim Station. The individuals were asked if they had experienced any difficulty in identifying or understanding the radiation work permits associated with the work packages. The results of these interviews did not identify any information to substantiate the above concern.

CONCERN "B" Some of the technicians performing the undervessel work do not appear to meet the ANS 3.1 technician standards.

RESPONSE TO CONCERN "B" The Quality Assurance Department (QAD) performed a review of the qualification records of both the contractor supervisors as well as the technicians involved in the RF0 9 work. Prior-to performing this review, QAD reviewed the original BEco Request for Quotation (RFQ) as well as the contractor proposal for RF0 9 work. The RFQ did not impose any specific regulatory requirements regarding training of technicians, stating only that personnel should be trained and qualified for duties to be performed or be directly supervised by qualified personnel.

It should be noted that BEco is not committed to Regulatory Guide 1.8, Rev. 2,

',. which endorses ANS 3.1-1987. The Boston Edison Quality Assurance Manual (BEQAM) commits to R.G. 1.8, Rev. 1-R, which endorses ANSI N18.1-1971

" Selection and Training of Nuclear Power Plant Personnel". ,

e The review of qualification records was performed to determine relative  !

experience levels and not to verify compliance with either standard, both of which require two years experience for technicians. However, the results  !

indicate that all nine I&C Technicians met or exceeded two years nuclear .'

i experience. Two invessel technicians were noted to have 1iss than two years experience; however, each had in excess of one year of experience and had received mock-up training prior to performing work.

l l Technicians performing work at PNPS during RF0 9 were under the direct I supervision of experienced contractor supervisors with experience well in L excess of minimum experience levels of ANSI N18.1 or ANS 3.1. BECo performed surveillances of the contractor's ongoing work during the course of the outage y as part of BECo's Contractor Monitoring Program. Results of these i surveillances indicate strong supervisory oversight of ongoing work.

CONCERN "C" (PART 11 l The contractor's second shift turnover and pre-evolution briefs are weak.

RESPONSE TO CONCERN "C" (PART 1)

The contractor's shift turnover and pre-evolution briefings have been i routinely attended by BECo personnel during RF0 9. Interviews with the BECo I personnel yegarding their assessment of the contractor's turnovers and l briefings concluded they were thorough and complete.

The contractor's turnovers include a shift turnover sheet that is passed from i L manager to manager and it is included in the contractor's log book. j l Supervisors review and brief the work force on evolutions / work to be l performed. Briefings are interactive. Craft are able to ask questions and l obtain the information they need from supervision. If problems are l encountered, craft are instructed to discuss them with their supervision prior i to proceeding. Supervisor responsibilities also include confirming worker is working safely, minimizing exposure and working within radiological limits.

During interviews with contractor craft personnel, the craft were asked to express any concerns they may have regarding shift turnover and pre-evolution  ;

briefings. The persons interviewed felt the turnovers / briefings were good and  ;

adequately covered needed information. Based on these interviews, it was  !

concluded the above concern could not be substantiated.

CONCERN "C" (PART 2)

The second shift supervisor has not been responsive to employee concerns.

RESPONSE TO CONCERN "C" (PART 2) l During the interviews conducted with the contractor craft personnel the topic i of supervisor responsiveness was discussed. Based on these interviews and BEco observations, the contractor's craft supervision (including second shift) was assessed to be sensitive and responsive to employee concerns. No information was identified to substantiate the above concern.

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