ML20080B362
| ML20080B362 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/14/1983 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20080B361 | List: |
| References | |
| IP-JAS-2981, NUDOCS 8402070096 | |
| Download: ML20080B362 (2) | |
Text
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Indian Po613 Nuclear Power Plant PO. Box 215 l
Buchanan, NewWk 10511
. 914 739 ?200
- > NewYorkPower
& Authority September 14, 1983 IP-JAS-2981 Docket No. 50-286 License No. DPR-64 Mr. Thomas T. hirtin, Director Division of Engineecing and Technical Programs U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
Inspection 50-286/83-06
Dear Mr. Martin:
This letter responds to your Inspection Report No. 50-286/83-06 dated August 15, 1983 and received at this office on August 19, 1983.
Attachment I to this letter responds to Appendix A of your letter.
In addition the Authority would like to comment on the following statement from Violation A in Inspection 83-06, "... Appendix B, Criterion II, requires that systems which are important to safety be included in the quality assurance prop. ram."
The regulatery tcrms " safety related" and "important'to safety" and the non-regulatory term " safety grade" have been consistently used synonymously by the industry and the NRC over decades of plant design, ceastruction, licensing and operation. The Authority believes that various recent actions taken within the NRC staff signal a sharp departure from the long-standing meaning of the term "important to safety" to cover a much broader and undefined set of plant structures, cystems and components than is covered by the term " safety related." The Authority does not believe that this new NRC position is consistent with present NRC regulations.
Very truly yours, nn
) C,%~
r John C. Brons Resident Manager a
JAS:ms Attachment cc:
IP3 Resident Incpectors' Office 8402070096 040127
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ATTACHMENT T Violation A The identification of certain systems which were included in the quality assurance program were not prescribed by plant administrative procedures and on various occasions between September 16, 1982 and March 25, 1983. Fire Protection System Corrective Maintenance activities were incorrectly classified.
Response.
As noted in Inspection 83-06 the cause of this violation was the failure of Procedure AP-9 " Work Requests", to recognize Category M designation. Quality Assurance Procedure 2.1 designates the Fire Protection System as Category M.
AP-9 has been revised to include the Category M designation. Inspection 83-06 also notes that AP-12 " Modifications", will require revision to recognize Category M designation, but was not a contributing factor to the subject violation. This procedure is presently being revised and the Authority will notify the Resident Inspector upon implementation of the revised AP-12.
Violation B PASNY Quality Assurance Program Manual for Nuclear Power Plant Operations, Appendix 17.2.6, requires adherence to ANSI N45.2.1 and ANSI N45.2.3 which respectively specify requirements for cleaning and flushing of systems and components, and plant housekeeping requirements.
Contrary to the above, as of March 23, 1983, activities for establishing suitable environmental conditions and cleanliness controls were not prescribed in appropriate procedures.
Response
Procedure AP-27.2, " Housekeeping", has been extensively revised and retitled
" Housekeeping and Cleanliness of Fluid systems". The activities for establishing suitable environmental conditions and cleanliness controls are addressed in the revised AP-27.2.
In addition AP-9, " Work Requests", has been revised to reference AP-27.2 for cleanliness requirements.
I
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