ML20209A879

Responds to Violations Noted in Insp Rept 50-293/85-35. Corrective Actions:Qualification Maint Document & Maint Requirement Summary Sheet Revised to Indicate Proper 40 Yr Qualified Life

ML20209A879
Person / Time
Site:	Pilgrim
Issue date:	08/28/1986
From:	Lydon J BOSTON EDISON CO.
To:	Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
86-121, NUDOCS 8609080127
Download: ML20209A879 (3)

Text

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Executive offices 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon August 28, 1986 Chief operating officer BECo Ltr. #86-121 Mr. Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Safeguards Inspection Programs Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 License No. DPR-35 Docket No. 50-293

Subject:

Response to Inspection No. 50-293/85-35 (Environmental Qualification Program)

Dear Mr. Zech:

During the week of December 9, 1985, Mr. Richard Wilson and other members of your staff conducted an inspection of Boston Edison Company's 10CFR50.49 Environmental Qualification Program. The resiilts of this inspection are contained in the subject Inspection Report No. 50-293/85-35. This letter provides our response to the two identified Potential Enforcement / Unresolved Items and the three Open Items identified in the inspection report. The item responses are identified below by the NRC assigned item numbers.

Item 85-35-i Barton 288A Main Steam Flow Switches ITEM: EQ Data Files (EQDFs) did not demonstrate sufficient set point accuracy.

I l RESPONSE Prior to the inspection exit, the subject EQDFs were revised to j include an additional reference to document the proper accuracy. A review has been performed for other EQDFs where a similar accuracy question could arise. This review verified that the appropriate eccuracy requirements are specified in the EQDFs.

ITEM: EQDFs did not specify the proper qualified life for the 0-ring on the Qualification Maintenance Document and the Maintenance Requirement Summary Sheet.

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Mr. Gary G, Zech Page 2 RESPONSE The referenced documents listed a more conservative 19 year life instead of the actual 40 year life. The documents have been revised to indicate the proper 40 year quallfled life.

Item 85-35-2 General Electric EB-25 Terminal Blocks ITEM: EQDF did not reference all of the documents necessary to conclusively prove qualification.

. RESPONSE Prior to the inspection exit, the subject EQDF was revised to include an additional test report to document the proper qualification. A review has been performed for other transmitters which utilize terminal blocks in similar applications. This review verified, that the appropriate qualification requirements are met and specified in the EQDFs.

Item 85-35-3 Documentation Revisions ITEM: EQ Hork Instructions were not consistent with the QA Manual regarding methods for performing " pen and ink" changes.

~~ RESPONSE The necessary work instructions were revised to be consistent with the QA Manual and the new work instructions have been issued. BECo 4 is reviewing all EQDFs for " white out" and correction tape. This review will ensure proper documentation of changes to the EQOFs.

Item 85-35-4 Completion of Maintenance Procedures ITEM: N00 Procedure 1.5.3 (Maintenanc.e Requests) did not specifically-address E-Q.

RESPONSE Has been revised to incorporate control of maintenance actions including E-Q specific requirements. ,

ITEM: Certain E-Q component maintenance procedures had not been issued at the time of the inspection.

i RESPONSE All E-Q component maintenance procedures necessary to ensure daily operability of installed E-Q equipment have been issued.

Approximately 66% of all of the long term inspecticn procedures have been issued. The remaining inspection procedures are in the

- review cycle and will be issued within 90 days from the date of this' letter.

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Mr; Gary G. Zech Page 3 Item 85-35-5 ' File Corrections ITEM: EQDFs did not have proof of similarity between the tested terminal block and the terminal block installed in the PNPS Yarways.

RESPONSE A similarity analysis was developed and is referenced in the revised Yarway EQDFs.

1 ITEM: EQDFs for TSH-1A and IB referenced a terminal block instead of a switch and the Isomedix Inc. Cert)ficate of Testing was missing.

RESPONSE The EQDFs have been revised accordingly. The EQ Test Report has -

been revised to include the Isomedix Certificate of Testing.

ITEM: EQDF for PS1360-98 listed 105'C for aging calculation. However, the Aging Calculation used the proper 150*C.

RESPONSE The EQDF nas been revised to indicate 150*C. As mentioned in the Inspection Report, the correct temperature was used in.the Aging Calculation.

Boston Edison believes the corrective actions as described above adequately address the Inspection Report concerns. If you should have any further questions regarding this matter, please do not hesitate to contact me.

Respectfully' submitted,

/

W$ W J. M. Lydon RV/ko

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