ML20099B686

Responds to NRC Re Violations Noted in Insp Rept 50-286/84-19.Corrective Actions:Activities Covered in Insp Checklist Added to Maint Checklist So That Completion of Activities Will Be Documented in Two Places

ML20099B686
Person / Time
Site:	Indian Point
Issue date:	11/08/1984
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IP-WDH-3705, NUDOCS 8411190252
Download: ML20099B686 (3)

Text

_.

Inallen Point 3

. Nuclear Power Plant P.O. Box 215

, Buchanan, New Wrk 10511 914 739.8200

1. > NewYorkPbwer 4# Authority November 8, 1984 IP-WDH-3705 Docket No. 50-286 License No. DPR-64 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

SUBJECT:

Inspection No. 50-286/84-19

Dear Mr. Martin:

This letter provides the Authority's response to your Inspection Report No. 50-286/84-19 dated October 9, 1984 and received at this office on October 15, 1984.

Attachment I to this letter addresses the concerns cited in Appendix A (Notice of Violation) of the Inspection Report.

Should you or your staff have any questions concerning this matter, please contact Mr. W. Hamlin of my staff.

Very truly yours, 11

. John C. Brons Resident Manager Indian Paint Unit 3 WDil:jmd Nuclear Power Plant Attachment cc: IP3 Resident Inspector's Office 8411190252 841108 PDR ADOCK 050007.86 PDR G

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s ATTACHMENT I VIOLATION A. 10 CFR 71.101(b)-requires each licensee to establish a quality assurance program for packages. 10 CFR 71.101(f) states that a Commission approved quality assurance program that satisfies the applicable criteria of Appendix B of Part 50 of this chapter, ar.d which is established, main-tained, and executed with regard to transport packages will be accepted as satisfying the requirements of paragraph (b) of this section.

1. Criterion XVII, Appendix B, Part 50, " Quality Assurance Records", of the licensee's previously approved program, requires that the licensee maintain sufficient records to furnish evidence of activ-ities affecting quality.

Contrary to the above, in December 1983, certain preventative maintenance activities were performed on the NUPAC 14D-2.0 transport package and the licensee did not maintain sufficient records to furnish evidence of activities affecting quality. Records were not maintained for the change of the secondary gasket and lubricant requirements.

2. Criterion XVIII, Appendix B. Part 5D, " Audits", of the licensee's previously' approved program, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compli-ance with a11~ aspects of the Quality Assurance Program for transport packages and to determine the effectiveness of the program.

Contrary to the above, a comprehensive system of planned and period-ic audits has not been carried out to verify compliance with all aspects of the Quality Assurance Program for transport packages or to determine the effectiveness of the program.

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RESPONSE

Item A. 1 The secondary gasket had been replaced and the various package lubricant requirements had been performed. However, subsequent to these activ-ities, the preventative maintenance check list was apparently lost.

Those activities required by the lost check list were repeated on September 4, 1984.

We are adding to the inspection check list those activities covered in the preventative maintenance check list so that completion of these activities will be documented in two places. In addition, a copy of all preventative maintenance and other maintenance activities relating to the NUPAC 14D-2.0 transport package will be forwarded to the site Quality Assurance Superintendent.

These corrective actions have been completed.

Item A.2 The Authority's QA and Reliability Department has been implementing appropriate 10 CFR 50 Appendix B program elements to transport packages as provided for by 10 CFR 71.101 (f), previously approved programs. Such implementation is effected through a variety of activities which include document reviews, QC inspections, QA surveillances, QA audits and QA & R program appraisals. Records of these activities are documented on the forms and reports which apply to the type of activity performed.

While the Authority believes that the current standard audit program and the supplementary surveillance audits adequately cover the NRC concerns, the Authority will, by December 31, 1984, review its present procedures and develop a plan which defines site QA audit activities applicable to transport packages.

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