ML18040A321
| ML18040A321 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/20/1997 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-220-97-80, 50-410-97-80, NMP1L-1268, NUDOCS 9712020050 | |
| Download: ML18040A321 (6) | |
Text
ACARAMOHAWK C EN E RATION BUSINESS CROUP B. RALPH SYLVIA Executive Vice President Electric Generation Chief Nuclear Officer NUCLEAR LEARNINGCENTER, 450 LAKEROAD, OSWEGO, NY I3126/TELEPHONE'(315) 349-2882 November 20, 1997 NMP1L 1268 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine MilePoint Unit 1
~
Docket No. 50-220
¹ine MilePoint Unit 2 Docket No. 50-410
Subject:
Notice of Violation dated October 24, 2997 NRC Inspection Report $0-220/97-SO and 50-4IOI97-SO
, Gentlemen:
¹iagara Mohawk Power Corporation's (NMPC) reply to the Notice of Violation is enclosed as Attachment A to this letter. We admit to the violation as cited.
Very truly yours, B. Ralph Sylvia Chief Nuclear Officer BRS/GJG/lmc Attachment xc:
Mr. H. J. Miller, Regional Administrator, Region I Mr. S. S. Bajwa, Acting Director, Project Directorate I-l, NRR Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management 71 120 PDR ADOCK 08000220
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NIAGARAMOHAWKPOWER CORPORATION NINEMILEPOINT UNIT 1 ANDUNIT2 DOCKET NO. 50-220/50-410 DPR-63/NPF-69 "RESPONSE TO NOTICE OF VIOLATION,"AS CONTAINEDIN INSPECTION REPORT 50-220/97-80 AND 50-410/97-80 A.
NMP1 Technical Specification, Section 6.8.1, requires procedures to be written and implemented that meet the requirements of NRC Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)."
NMP2 Technical Specification, Section 6.8.1, requires procedures to be written and implemented that meet the requirements ofNRC RG 1.33.
RG 1.33, Appendix A, identifies procedure adherence as one of the safety related activities that should be covered by written procedures.
Nine MilePoint Nuclear Interface Procedure NIP-ECA-01, "Deviation/Event Report,"
Revision 11, Section 3.7.3, states extension to DER tDeviation/Event Report] dates (Part 4-Disposition or Part 5 - Closure) shall be processed using the DER Extension Request.
Contrary to the above, as of August 22, 1997, approximately 165 DERs pending disposition and 72 DERs pending closure were extended past the due dates without being processed using the DER extension request.
This is a Severity Level IVviolation (Supplement 1).
This violation was caused by a lack of sensitivity by Nine MilePoint senior managers and branch managers to the procedural requirements for schedule compliance regarding implementation of the corrective action program.
The management team failed to adequately hold personnel accountable to either complete DER actions or justify a new schedule.
The following corrective actions have been taken:
The DERs which were overdue during the inspection have been dispositioned, closed or extended in accordance with NIP-ECA-01. This assures that the DERs have been closed or the safety significance of extension evaluated.
2.
During the weekly plant managers'riday meeting, members of the Senior Management Team (SMT) have periodically reinforced the requirement that DER actions are to be completed on schedule or extended as required by NIP-ECA-01, "Deviation/Event Report."
3.
The SMT and branch managers are routinely reviewing the status of open DERs to ensure ongoing procedural compliance.
~ The following actions willprevent reoccurrence:
Quality Assurance Audit 97-013 is ongoing at the time of this submittal. This is the semi-annual corrective action audit which includes evaluating compliance with NIP-ECA-01, Section 3.7.3.
The preliminary results of the audit have shown improved performance with regard to schedule compliance.
The SMT willreview the results of the audit and take any appropriate corrective actions.
2.
NIP-ECA-01 willbe revised to provide additional flexibilityin the DER resolution process to allow time for administrative processing and comment resolution.
3.
The next semi-annual corrective action audit (May 1998) willspecifically evaluate compliance with DER completion requirements, 4.
The Quality Assurance DER Trend Report for the first quarter of 1998 willinclude data regarding DER completion compliance.
The need for continued inclusion of completion compliance in the trend report willbe evaluated by the SMT at that time.
5.
The SMT now routinely reviews DER status, including the issuance of extensions during quarterly review of the DER Trend Report, NMPC was in fullcompliance on November 19, 1997, when corrective action II.1 above was completed.