ML19339B385
| ML19339B385 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 04/12/1976 |
| From: | French J YANKEE ATOMIC ELECTRIC CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19339B383 | List: |
| References | |
| WYR-76-45, NUDOCS 8011060835 | |
| Download: ML19339B385 (3) | |
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750 300 0739
.aHKEE AT M10 ELECTRIC C0fAPANY b
20 Turnpuke Road Westborough. Mossachusetts 01581 U
/L Wxus April 12, 1976 United States Nuclear Regulatory Commission Region I office of Inspection and Enforcement
-f 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
E. J. Brunner, Chief Reactor Cperations and Nuclear Support Branch
Reference:
(a)
License No. DPR-3 (Docket No. 50-29)
(b)
USNRC letter to YAEC, with enclosures, dated March 15, 1976.
Dear Sir:
(b) which indicates This letter is written in response to Reference that four of our activities were not conducted in full compliance with Nuclear Regulatcry Ccemission recuirements.
A.
Apparent Violation Centrary to 10 CFR 20.203(c) (2), requirements to control each entrance or access point to a high radiatien area, the access to the high radiation area containing the Waste Holdup and Activity Dilution celay tanks was neither equipped with the 21, required control devices nor locked during the period August 1975 through February 10, 1976.
i The access to this area was properly Iceked prior to the ecmpletion Ecwever, a respense detailing actions taken or f
of the inspection.
planned to prevent recurrence is needed on this item.
I A.
Reply access to the areas containing As stated in the inspector's report, the Waste Holdup and Activity Dilution Decay Tanks were proporly This was locked prior to the ccepletien of his inspection.
accenplished through the application.of padicc%s on the blocking
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- devices which had previcusly been installed on the tank area access ladders.
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United-States ITuclear Regulatory Commiscion April 12, 1976 l Cffica of Inspection and Enforcement Page Two Future entr/ into eitha.: of the areas in question will be controlled on an individual entry approval basis through the l
implementation of administrative controls established by the Chemistry and Health Physics Department supervisor who shall maintain control of the blocking device padlock Keys. This action will provide the necessary positive area control in the future.
B.
Apparent violation C ntrary to 10 CFR 50, Appendix B, Criterion XVIII and the Operational Quality Assurance Manual,Section V, item XVIII.10 requirements that audit results be documented and reviewed by management having responsibility in the area a,udited, four of
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the sixteen audits conducted in 1975 had not been reviewed by the Manager of Operations as required through issuance of Plant Position Reports within the prescribed (AP-0208) 30 day period.
This is a Deficiency.
The four Plant Position Reports were generated and forwarded for review prior to ecmpletien of the inspection. No additional response is required for this item.
h.
Reply s
4 As' stated in inspection repo.it, no additional response is required on this item.
C.
Apparent Violation Contrary to 10 CFR 50, Appendix B, Criterion XVI and the item XVI.2 Operational Quality Assurance Manual,Section V, requiremer s that measures be established to assure that conditions adverse to quality be promptly identified and corrected: measures had not been established to assure prompt correction; in that the licensee's prescribed action on his 12/27/74 audit finding that there was an inadequacy in the system for updating the FSAR (FESR) for design changes or modi-ficatiens was not received as of 2/lC/76.
This is a Deficiency.
C.
Reply Procedure (s) will be written or revised as necessary to assure that corrective actions are completed in a timely manner (immediately when conditiens warrant). Thg Procedupe (s) will provide for Plant and Yankee Nuclear Services Division Management
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t Unitrd States !!uclear Regulatory Cc= mission
, April 12, 1976 Page Three Office of Inspection and Enforcement review whenever scheduled completion dates for corrective action Provisions for rescheduling of ccepletion dates, are exceeded..
The when justifiable, will be included in the Procedure (s).
Procedures will provide for immediate initiation of rectification of discrepancies which could affect the health and safety of the public or plant personnel. The subject procedure (s) will be implemented within 90 days of the date of this letter.
D.
Apparent Violation contrary to 10 CFR 50, Appendix 3, Criterion II and the Cperational Quality Assurance Manual,Section V, item II requirements that the structures, systems and components to be covered by the quality assurance program be identified and that ths quality assurance e
program shall provide control over activities affecting the quality of the identified structurcs, syste=s, and cc=penents to an extent boren used to control consistent with their i=portance to safety:
reactivity, and fuel oil used in the emergency diesel are not covered by the quality assurance program.
D.
Reply We take exceptien with the auditor's pcsition on the above We have perf:::ed a review cf all applicable deficiency ite=.
ANSI Standards and Regulatory Guides and feel that at present there is no justification for the position taken by the auditor that these ite=s be covered by our Quality Assurance pregram.
There may be plans to develop guides which will cover items such as fuel oil cys c.ms and cheri:013 and a: that nice wc will ec =ent on these iters; hcwever, until such guides have been issued we feel that identification of deficiencies in the areas to be covered by these guides is premature and therefore believe that the audit finding is an invalid one.
Very truly yours, YANKEE ATCMIC ELECTRIC CCMPANY l
, & 7.l!./. v. lcr --..m
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M J. L. French Manager of Operations JLF/kg I
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