ML20098C950

Responds to NRC Re Violations Noted in Insp Rept 50-220/84-09.Corrective Actions:Semiannual Deficiency Audit Expanded to Cover QA Nonconformances by Way of Reviewing QA Audits Performed Since Previous Audit

ML20098C950
Person / Time
Site:	Nine Mile Point
Issue date:	07/20/1984
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20098C932	List: ML20098C950
References
NUDOCS 8409270295
Download: ML20098C950 (3)

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NMe NIAGARA MOHAWK POWER CORPORAT10N/300 ER!E BOULEVARD WEST, SYRACUSE, N.Y.13202/ TELEPHONE (315) 4741511 1

July 20, 1984 t

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Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs United States Nuclear Regulatory Commission

-Region I-

.631 Park Anenue

-King of Prussia, PA 19406 Re: Nine Mile Point Unit 1 Docket No. 50-220-

. Inspection Report 84-09 i

Dear Mr. Martin:

, As requested,-this letter responds to the routine safety inspection.

conducted by E. T. Shaub of your staff from May 29 to June 1, 1984 at Nine Mile Point. Unit l1, Scriba,.New York, and our corporate office, Syracuse, New York. The 1_nspection report noted one area of noncompliance. Our response to this item i:, as follows:-

Item A

Technical Specification 6.5.2.8.C requires that once per six months, audits be

performed under the cognizance of the SRAB (Safety Review and Audit Board)

encompassing the results of all actions taken to correct deficiencies i occurring in facility equipment, structures, systems or method of operations that-affect nuclear. safety..

Contrary to the'above, the SRAB Deficiency Audit dated February 13, 1984

- performed to satisfy this Technical Specification, only addressed deficiencies identified in other SRAB audits. The audit did not address nonconformances,

-audit and surveillance _ findings, occurrence reports and LER's, and the scorrective. maintenance. system.

Response-The semi-annual Deficiency Audit has been expanded to cover quality assurance.

Lnonconformances by way of reviewing the quality assurance audits performed since the prevjeoCDe(1cienctNu.dit.

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Mr. Thomas T. Martin Page-2 I

-By review of the Safety Review and Audit Board Quality Assurance, Maintenance and. Testing Audit, the Deficiency Audit also covers audit and surveillance findings. However, a sample will be reviewed (as the word " audit" implies) and not all audit and surveillance findings.

Occurrence Reports and Licensee Event Reports are reviewed by the Site

~0perations Review Connittee. Documentation of these reviews is delineated in

'the Site. Operations Review Committee (50RC) minutes. The Safety Review and Audit Board (SRAB) reviews-Site Operations Review Committee minutes, including results of 50RC action on Occurrence Reports. The. Safety Review and Audit Board also reviews Licensee Event Reports and.their associated Occurrence Reports.

In our opinion, there is.no need to review these twice by including them in the scope of the-semi-annual Deficiency Audits.

IBy reviewing the Quality Assurance, M'aintenance and Testing Audit,- the Deficiency Audit' covers our corrective mainten'ance system (i.e., Work

= Requests).'-- However, this will be a sampling method as the audit and surveillance findings. review discussed above.

.The expanded scope of the deficiency ~ audit also includes review of any "nonconformances resulting from the Quality Assurance audits of Work Requests.

Further, the Site Staff 0peratiions Assessment organization evaluates plant

operations for safety. This~ organization reviews the following (as discussed in Site Administrative Procedure APN-3A):.

.1.

Engineering evaluatio_n of the' operating history of the plant (equipment failures, design problems, operations errors, etc.) and eH Licensee Event Reports from other plants of similar design, with suitable dissemination of the results of.such evaluations to other

. members'of the plant staff 2..

Engineering evaluation of plant conditions required for maintenance.

and testing

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-Engineering evaluation of the adequacy of utility policy for maintenance,-testing, equipment procurment, etc.

4.

Engineering evaluation of continuing adequacy of plant operations quality assurance 5.'

Engineering evaluation of adequacy of plant emergency and operating procedures.

.The.SORC conducts a special bi-monthly meeting to review the results of

these assessments. This review is documented in the SORC minutes which are reviewed by SRAB.

n-Mr.. Thomas T. Martin Page 3 FinaIly, SRAB reviews NRC Inspection Reports and the action / response to them.

We plan-a proposed change'in the. Technical Specifications to delete the word "all" in Section 6.5.2.8.C.

The word " audit" implies not 100% but a sampling review.

"All" is an inappropriate adjective describing audits.

Revision 2 to the: General Electric Boiling Water Reactor (BWR) Technical Specifications (NUREG 0123) is consistent with this change.

We believe with the proposed change in the Technical Specification and expanded scope of the Deficiency Audit, we will be in compliance with Section

-6.5.2.8.C of our Technical Specifications.

Very truly yours, T.

. Lempges Vice President Nuclear Generation TEL/LMM:ja W

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