ML20054C335

Responds to NRC 820318 Ltr Re Violations Noted in IE Insp Rept 50-247/82-01.Corrective Actions:Administrative Directive Revised to Require Semiannual Review of All Controlled Procedures within Operations Section

ML20054C335
Person / Time
Site:	Indian Point
Issue date:	03/18/1982
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20054C324	List: ML20054C335
References
NUDOCS 8204200387
Download: ML20054C335 (4)

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• John D. O' Tools Vrce Presuject e ,

Consolidated Edison Company of New York, Inc 4 trying Place, New York. NY 10003 Telephone (212) MM533 March 18, 1982 Re: Indian Point Unit No. 2 Docket No. 50-247 Mr. Richard W. Starostecki, Director Division of Resident and Project Inspection U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406

Dear Mr. Starostecki:

This refers to I.E. Inspection 50-247/82-01, conducted by Mr. T. Rebelowski, Senior Resident Inspector, on January 1-31, 1982 of activities authorized by NRC license No. DPR-26 at Indian Point Unit No. 2. Your February 16, 1982 letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A. Our response to the item of non-contpliance is presented in Attach-ment A to this letter.

Our response is being provided pursuant to Section 182 of the Atomic Energy Act 1954 as amended. Should you or your staff have any questions, please contact us.

Ver truly yours, hf Subscribed an sworn to f} g 9 /, Vf befoEe me thik /6 day

,of March,,/1982

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l l C:u b M Notary Public THOMAS LOVE Notary Publ#c State of New York No. 312409633 Qualified in fitw York C % nty Commission Lxp;tes March x,1*$

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cc: U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D. C. 20555 Mr. T. Rebelowski, Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511 1

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ATTACHMENT A t

RESPONSE TO NOTICE OF VIOLATION Violation A Criterion VI 10 CPR 50, Appendix B, Document Control states,

" Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings..."

Station Administrative Order (SAO) No. 102, Revision 6, in Paragraphs 2.5.8 and 2.5.12, which describe Section Head responsibility, states in part, "He shall assure that pro-cedure distribution lists are current and updated (or make new list (s) and document same each time procedures are dis-j tributed," and, " assure that the latest approved revisions of procedures are available and followed as required."

Contrary to.the above, during the inspection period January 1-31, 1982, the inspector identified incorrect revisions to Controlled Procedures in the Central Control Room, Watch Foreman's Office, Nuclear and Conventional Operator's Offices and the Radiation Waste Supervisor's Office.

This is a Severity Level V Violation, Supplement I.

Res_gonse Upon identification of certain procedures that were not being maintained up-to-date at several locations in the station, the procedures at these locations were promptly reviewed and brought up-to-date. We believe that this immediate corrective action was effective in assuring that station personnel would

have available the correct procedures.

4 The procedures in the Central Control Room, Watch Supervisor's Office, Nuclear Plant Operator's Office and Conventional NPO Office had not been maintained up-to-date due to deficiencies in the Operations Administrative Directive No. 7, entitled i Procedure Control. This Administrative Directive will be re-vised to require up-to-date procedures at specified locations including the Central Control Room, the Watch Supervisor's Office, the Nuclear Plant Operator's Office and the Conventional NPO's Office. In addition the Administrative Directive will 4

be revised to require a semi-annual review of all controlled procedures within the Operations section. The frequency of these audits may be increased if warranted by the results i of the first audit. The revisions to this Administrative l

Directive will be completed May 15, 1982.

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- The failure to maintain up-to-date copies of procedures in the_Radwaste General Supervisor's Office was due to the lack of a formal procedure control system in this newly formed section. The Radwaste General Supervisor has been instructed in the need to maintain controlled copies of procedures and a procedure control system has been developed. In addition the Radiation Protection section, which issued the controlled procedures referred to in the NRC inspection report, has increased the frequency of auditing all controlled copies of procedures to provide additional assurance that the current revisions are on file.