ML20064N538

Responds to NRC Re Violations Noted in IE Insp Rept 50-247/82-10.Corrective Actions:Personnel Retrained on Issuance of Documents & Preoperation Test to Confirm Response Time for Containment Pressure Will Be Conducted

ML20064N538
Person / Time
Site:	Indian Point
Issue date:	07/30/1982
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20064N519	List: ML20064N538
References
NUDOCS 8209080408
Download: ML20064N538 (5)

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m John D. O'Toola vu P cu m ccesu.d*3 E a son comrry o r..m rw r 4 trerg Pia:e. Fie.v York. N Y 1%C 1 Tvep*'ow (212) 4M 2531 July 30, 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 1

Dear !!r. Starostecki:

This refers to I.E. Inspection 50-247/82-10, conducted by Dr. P. K. Eapen of your office on May 24 through 28, 1982 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No. 2. Your July 2, 1982 letter stated that it appeared that certain of our activities were 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 items of non-compliance is presented in Attachment A to this letter.

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

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Ver truly yours,

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Notary Public THOMAS LOVE Ndhry Pubtre State of New York No. 3124&X>38 Quattfled inExpires Commission New Yvk March C%x."n;d tv 3 h$[$bo O O

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- ATTACHMENT A Response to Notice of Violation Violation A 10 CFR Part 50 Appendix B, Criterion VI states in part:

" Measures shall be established to control the issuance of documents...,

which prescribs all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy. . . ."

Licensee's procedure OP-290-1 Section 5.2, " Development and Review of Discipline Design Criteria", dated February 11, 1981 states in part:

"The results of the review efforts shall be documented....."

Contrary to the above, as of May 28, 1982 the result of the review ef forts for design modification packages FDIC 80-2-04 and FFI 82-2-7 (an audit sample) were not documented.

This is a Severity Level V Violation (Supplement I)

Response A The Con Edison Quality Assurance Program - Corporate Instruction CI-240-1 and Engineering Operations Procedure Manual OP-290-1 satisfy the requirements of Appendix B to 10CFR Part 50. Paragraph 3.3 of Section 5.2 of OP-290-1 stipulates that "The discipline design criteria shall be validated by an engineer other than originator" and that "the results of the review effort shall be documented..." In addition, procedure III of Section 3.0 of the Con Edison Indian Point Quality Assurance Manual stipulates an " independent review of the design documents. .." These are mandatory requirements on the part of Con Edison Engineering employees.

A-1

In review of the above the lack of documantation for the two cases cited are acknowledged deficiencies. By way of correction, modification file and packages MMC-80-2-04 and FFI-80-2-06 (incorrectly identified as FFI 82-2-7 in the cited violation), were independently reviewed and found to be adequate as of July 22, 1982. Corrective measures taken include ]

re-training of personnel in accordance with Section 5.18 (Engineering Training) of OP-290-1 which began June 28, 1982 in the applicable Engineering organizations.

i A-2

Violation B 10 CFR Part 50, Appendix B states in part, " Measures shall be established for the identification and control of design interfaces and coordination among participating organizations..."

Contrary to the above, as of May 28, 1982, the design interfaces and coordination were inadequate in that the Engineering organization did not identify and transmit the response time verification requirement of NUREC-0737 for design modification number MMC-80-02-04 "High Range Containment Pressure Indication" to the pre operational test writing group.

This is a Severity Level V Violation (Supplement I) . -

Response B The C&I Engineering Modification Procedure (MMC-82-2-04) was developed, approved and issued on September 19, 1980. At that time it was not required to justify a response time for high range containment pressure.

NUREC-0737 was issued in October, 1980. liowever, based on NUREG 0737, post implementation response time calculation and testing is required and an approved final calculation dated May 5,1982 was issued to the Test and Performance group on July 15, 1982. A pre-operation test to confirm the response time will be conducted during the Fall 1982 re-fueling outage, thus fully complying with requirements.

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CORRECTIVE STEPS TO AVOID FURTIIER VIOLATIONS '

t The personnel involved in the above deficiencies have been instructed (re-trained) to follow the mandatory requirements stated in our Corporate Instruction CI-240-1, Q.A. Program for Operating Nuclear Power Plants and -

Corporate Engineering Operating Procedure Manual. L As a consequence of the noted deficiencies and the increasing regulatory ,

requirements and complexities, we are reviewing our existing training i

program to further improve the numerous activities associated with nucicar power plants, such as, document control, design interface, review process, etc.

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