ML20069G245

Responds to NRC Re Violations Noted in IE Insp Rept 50-247/83-01.Corrective Actions:Storage Cabinet for Flammable Liquid Properly Relocated & Secured & Station Administrative Order 114 Being Revised

ML20069G245
Person / Time
Site:	Indian Point
Issue date:	03/09/1983
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20069G232	List: ML20069G245
References
NUDOCS 8303250077
Download: ML20069G245 (3)

Text

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. John D. O' Tools V.ce Prescent Consobdated Ed' son Company of flew Yo4. Inc 4 Irving Place. New York, fdY 10003 Telephone (212) 460-2533 March 9, 1983 Ret Indian Point Untit No. 2 Docket No. 50-247 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406 Dear Mr. Starostecki This refers to I.E. Inspection 50-247/83-01 conducted by Messrs T. Foley and P. Koltay of your office on January 1 through 31, 1983 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No. 2. Your February 7, 1983 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-compliance is presented lu 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.

Ve truly yours,

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Subscribed and- orn to

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befoy'mcthi , , , day of March, 198 s' V/ /

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No. 312R%33 Qua!!fied in New Yu k C m ty Commissien Expires Man W.1931 8303250077 030321 PDR ADOCK 05000247 G PDR

4 No. 50-247/83-01 Attachment A Response to Notice of Violation Appendix A VIOLATION Technical Specification 6.8.1 requires that written proce(.res and administrative policies shall be established, implemented, and maintained.

Station Administrative Order (SAO) No. 116, "Housekeening Policy",

Revision 1, requires the licensee to establish housekening and cleanliness controls for work activities, and conditions and environments that can affect the quality of important parts of the nuclear plant.

Station Administrative Order (SAO) No. 114, " Fire Protection and Prevention," Revision 3,Section II.B.1, requires that accumulations of combustibles which are significant fire hazards be removed after each shift.Section II.B.2 requires the storage of combustible and flammable liquids in approved containers. Attachment 7 to SAO No. 114, requires that within 35 feet of welding and cutting operations, all combustible and flammable material be removed and floor openings shall be covered.

Contrary to the above, a tour of the Primary Auxiliary Building, on January 20, 1983, identified accumulations of combustibles, improper storage of combustible and flammable materials, and evidence of insufficient protection of material and equipment during cutting and welding operations. Housekeeping and cleanliness controls were not established in the area of the component cooling pumps, charging pumps, and 78 foot level mezzanine areas (important parts of the nuclear plant).

This is a Severity Level IV Violation (Supplement I).

RESPONSE

All housekeeping deficiencies noted have been corrected. In addition, the storage cabinet for flammable liquid found in the component cooling water heat exchanger area has been properly relocated and secured.

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To strengthen compliance with SAO-ll6 and to prevent the recurrence of housekeeping problems the program of assigning specific housekeeping inspection responsibilities to management employees and upgrading those areas is continuing. These managers are responsible for conducting periodic inspections of their areas to assure that deficiencies found are corrected.

To provide additional assurance that the prevention requirements delinaated in SAO No. 114 (Fire Protection & Prevention) ara adhered to, it is being .;evised under the Fire and Property Protection Engineer to further emphasize its intent.

The " Cutting, Welding, Grinding, or Open Flame Permit" (Attachment #1 SAO-ll4) is being revised and will include a requirement for a daily inspection by the work party supervisor, to assure all applicable precautions listed on the permit are being followed.

In the Planned Revision of SAO-ll4, the storage of flammable and combustible liquids in any safety related area will not be permitted (except for immediate use). The housekeeping requirements in work areas and the plant in general as set forth by the existing SAO-ll4 (Fire Prote,: tion & Prevention) SAO-ll6 (Housekeeping Polic)) and SAO-105 (Work Permits) will be reemphasized to company and contractor personnel to assure compliance.

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The Fire and Property , Protection Engineer 's i responsible for interpretations and is available for advice with regard to combustible control in all areas.

A-2 m