ML20081A107
| ML20081A107 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/27/1984 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20081A106 | List: |
| References | |
| NUDOCS 8403050015 | |
| Download: ML20081A107 (3) | |
Text
.
John D. O' Tools a
V;ce Prercent Consoi iated Edson Company of New York, Inc t
4 Irving Place. New York, NY 10003 Telephor'e (212) 460-2533 January 27, 1984 Re:
Indian Point Unit No. 2 Docket No. 50-247 Mr. Thomas T. Martin, Director
' Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406 Dear Mr. Martin This refers to I.E. Inspection 50-247/83-22 conducted by Mr. G. Napuda of your office on October 5 through October 7 and October 11 through October 14 at Indian Point Unit No. 2 and at our corporate offices of activities authorized by NRC License No. DPR-26.
Your December 29, 1983 letter stated that it appeared that some 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 item of non-compliance is presented in Attachment A to this letter.
Should you or your staff have any questions, please contact us.
Very ruly yours,
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cc:
Mr. Thomas Foley, Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511 8403050015 840224 PDR ADOCK 05000247 G
o 1
No. 50-247/83-22 ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION Appendix A VIOLATION 10 CFR 50, Appendix B, Criterion X; the Consolidated Edison updated FSAR Quality Assurance Program description, dated May 6,
1983 (Revision 1);
and, ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, require that quality affecting activities on safety-related systems be inspected.
Contrary to the
- above, inspections of more important maintenance activities were not performed routinely in that only three cf approximately forty maintenance work packages sampled for review contained objective evidence of inspection of quality affecting work activities.
The following examples of Maintenance Work Requests (MWRs) lacking any documented inspection of associated work activities is provided.
MWRs 06835 and 06833, RPS Breaker Repairs MWR 07004, Replace Boric Acid Transfer Pump Seal MWR 07713, Testing of Westinghouse DB 50 ES Breakers i
MWR 08501, Remove and Replace Charcoal Filters, Adjust Dampers MWRs 08932 and 08045, Replace Charging Pump Seals l
This is a Severity Level IV Violation (Supplement I).
RESPONSE
Consolidated Edison's Quality Assurance Department has conducted a detailed evaluation of the documentation and inspection records of the forty maintenance work packages referenced in the notice of violation.
The results of that evaluation are:
1.
Only twenty six (26) of the forty (40) packages covered work that could be considered as "more important" maintenance activities.
Of these, twenty two (22) contained objective evidence of inspections that were performed.
2.
Of the remainder, six (6) packages were for work requeets that were cancelled or were for non-safety related work beyond the scope of 10 CFR 50 Appendix B,
or the work was in progress but not complete.
Consequently documentation of inspections was not required.
3.
The remaining eight (8) of the (40) were simple jobs - not "more important" maintenance activities.
In these cases work conpletion was evidenced by signature or post maintenance tests.
In view of the above, we have concluded that there is objective evidence that inspection of the "more important" maintenance activities is routinely performed by Consolidated Edison.
We thus request that the above violation be withdrawn.
It is possible that all of the record may not have been seen by your inspectors.
If further review of these records is necessary by your inspectors our Quality Assurance staff is available to assist.
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