ML20092N615
| ML20092N615 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/29/1984 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20092N612 | List: |
| References | |
| NUDOCS 8407030342 | |
| Download: ML20092N615 (4) | |
Text
g John D. O'Toob Ytce Pres. dent Consolidated Edison Cornpany of New Yock, Inc_
4 Irving Place. New York, NY 10003 Telephone (212) 460-2533 May 29, 1984 Re Indian Point Unit No. 2 Docket No. 50-247 Thomas T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa.
19406 Dear Mr. Martin This refers to the operations assessment team inspection 50-247/84-03 conducted by Mr.
A.
T.
Cody of your office on February 13-24, 1984 of activities authorized by NRC License No..DPR-26 at Indian Point Unit No.
2.
Your April 26, 1984 letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements, as se_t forth in the Notice of Violation enclosed therewith as Appendix A.
Our-response t.o 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 truly yours, t
M cc Mr. Thomas Foley, Senior Recident Inspector U. S. Nuclear Pegulatory Commission Post Office Box 38 Buchanan, New York 10511 8407030342 840626 PDR ADOCK 05000247 G
e; 50-247/84-03 ATTACHMENT A Response to Notice of Violation Appendix A VIOLATION-
Criterion XVI " Corrective Action" requires that measures be established to assure - that conditions adverse to quality are promptly identified and corrected, and in the case of significant conditions adverse to quality, 'the measures shall assure that the corrective action taken precludes repetition.
Consolidated Edison Corporate Instruction (CI)-240-1, " Quality Assurance Program for Operating Nuclear Plants" Section 3, XIII "Nonconformance and Corrective Action" requires that nonconformances ba identified; actions be _taken to resolve the nonconformance, and when required, corrective action be taken to preclude their recurrence.
Contrary to the above, as of Feburary 15, 1984, corrective actions had not been taken to preclude recurrence of nonconformance identified in Quality Control Inspection Reports 78-G-ll, dated July 31, 1978 and 80-RI-201, dated May 29, 1980; and Deficiency Report DR-81-G-1, dated May 2 8,' 1981, regarding inadequate material segregation, failure to provide protective coverings, and inadequate environmental controls for storage
- and handling of safety-related materials.
This is a severity Level IV violation (Supplement I).
RESPONSE
It is both the policy and practice of Con Edison to promptly correct conditions adverse to quality and to take measures to preclude recurrence.
In the case of material ' storage conditions reported by the Quality Assurance programs, actions taken to alleviate the major cause of this problem, congested warehouse facilities, did not adequately address the inunediate correction of proper segregation, protection, and
-environmental control. When it has been determined that
7 action taken or being taken, may not correct conditions, the Quality Assurance department informs the cognizant officer and Senior Officers of the Company for resolution.
Corrective action taken to Quality Assurance reports such as Inspections, surveillance and Audits were evaluated for effectiveness and found to follow policy.
This instance is an isolated case.
Cognizant' Senior company managers met during the inspection.
During and subsequent to the inspection, all material in the warehouse was re-inspected for damage and improper material storage.
Material so identified was then procected, segregated and stored in accordance with the ANSI Standard N45.2.2 provisions of the Con Edison Quality Assurance Program.
Procedures have been upgraded and new procedures written.
To further facilitate proper segregation of material, an additional 2000 square feet of warehouse area was made available.
In addition, a Shelf-life Program and Preventive Maintenance Program has been defined and procedures implementing them are scheduled for August, 1984.
Additional existing procedures were reviewed and have been strengthened where necessary.
A review and a plan were immediately developed for material' storage and handling procedures to assure abequate a
continued management of this effort.
These procedures cover receiving, storage and handling of Class A material, training and record keeping, shelf-life,' preventive maintenance, housekeeping and timely responses to Quality Control Inspection Reports.
Procedures are planned for completion by August, 1984.
e -
The Quality Assurance -Department has increased its staff on-site.
Tracking and' reporting on corrective action to higher management has been increased.
More Quality Assurance audits are being conducted and tracking and followup of audits has been increased.
This includes more frequent status reports to higher management.
With Nuclear Power reorganization -in
- 1981, Communication and Regulatory Affairs (CRA),
reporting to the Vice President, Nuclear Power, was established.
CRA reviews inspection reports, audits and evaluations, has a principal responsibility for assigning them for action,
- t. racks the atatus of action and reports regularly to higher management.
This increased Quality Assurance and Nuclear Power attention should adequately assure prompt and effective corrective action.
[$
Significant resources have been applied to alleviate the material storacfec 'l conditione and there are further additions planned.
An additional 8,000 square feet of warehouse space was leased in 1982 and additional steps 4j r-were taken in 1982 and 1983 to fully resolve organization and maintenance. ;
u k! w of stored material.
A task force in 1983 reduced the back log of
-7 material. on hold by 80%.
A consulting firm in the materials storage field - was contracted to define our long term storage and handling needs and plans.
This resulted in identifying appropriate space and recommending that it be leased.
A lease arrangement for an additional 68000 square feet of warehouse is expected to be completed by August, 1984.
Based on these arrangements, occupancy of the new warehouse is 4
currently planned for December, 1984.