ML20195C162
| ML20195C162 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/16/1986 |
| From: | Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8605300087 | |
| Download: ML20195C162 (3) | |
Text
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Murcy Selman Vc3 PrtS&M Consohdated Edison Company of New York. Inc.
Indian Point State Broadway & D:eak:ey Ave.
Buchanan, NY 10511 Telephone (914) 737 8116 May 16, 1986 Ret Indian Point Unit No. 2 Docket No. 50-247 Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
This refers to the meeting at your office on March 20, 1986 The meeting was held to review routine inspection 50-247/86-01 conducted by Mr. P.
Clemons of your office on January 6-10, 1986 at Indian Point Nuclear Generating Station, Unit 2 Your April 16, 1986 letter following the meeting stated that it appeared that certain deficiencies existed in one of our activities, and that your concerns were set forth in the Notice of Violation enclosed therewith as Appendix A.
Pursuant to the provisions of 10 CFR 2.201 our response to the notice is presented in Attachment A to tH E.etter.
Should you or your staff have any questions, p case contact us.
Very truly yours,
?
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Attachtr.ent cc:
Senior Resident Inspectcc U.S. Nuclear Feculatory Commission P.C. Box 38 Buchanan, New York 10511 17.191.5.8.3 8605300087 860516 PDR ADOCK 05000247 M
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e' Re:
Indian Point Unit No. 2-Docket No. 50-247 ATTACHMENT A Response to Notice of Violation VIOLATION The establishment and execution of the required quality assurance progran was inadequate as itemized below.
1.
The quality control responsibilities of the Environmental Health and Safety personnel who are responsible for the shipment of radioactive material was not adequately specified.
2.
The Environmental Health and Safety personnel were not trained in the responsibilities for quality control.
3.
The implementing procedures did not adequately discuss the role of Environmental llealth and Safety personnel in quality control.
This is a Severity Level IV violation (Supplement V).
Response
Con Edison Corporate Instructions
- CI's) are the company's highest tier procedures.
CI-240-1 defines the responsibilities of the Quality control program including the shipment of radioactive material and the responsibilities of Environmental Health and Safety (EH&S) personnel for this activity.
These responsibilities are further defined as specific activities in the lower tier implementing procedures.
Although these Quality Control activities were defined and being performed, the implementing procedures did not adequately define them as " Quality Control" steps.
Accordingly, their identification as " Quality Control" steps was inadequately communicated to the personnel carrying them out.
Environmental Health and Safety personnel have been instructed in tneir responsibilities according to Corporate Instruction, CI-240-1 Supplement I.
They have also been instructed that the inspections and verifications they have been performing are indeed Quality Control activities.
The management position guides of all Radwaste personnel have been clarifled to include Quality control requirements.
Implementing procedure EHS-SQ-4.003, hadwaste Section Duties and Responsibilities, was revised May 1, 1986 to include CI-240-1 Supplenent I requirements and to clearly define them as " Quality control" steps.
Quality Ancurance and Reliability will also assure increased awareness of the QA program responsibilities assigned to each organization.
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e In addition to the actions described above, which are in direct response tra the Notice of Violation, we are taking or have taken the following actions:
As of May 1, 1986 the following five implementing procedures have been revised to include QA/QC documentation of Nuclear Power Quality Assurance (NPQA) participatien in vaste processing, receipt inspection of waste packaging containers, dewatering and solidification.
Ells-SQ-4. 000 - Shipment Final QA Inspection EIIS-SQ-4.200 - CNSI System EHS-SQ-4.303 - Shipping Cask Handling Procedure Ells-SQ-4.704 - Removal and solidification cf riant Filters EIIS-SQ-4. 007 Process Control Program Three additional Radwaste procedures have since been revised.
Replacetaent and Dwatering of Filters EHS-Q-4.201 10CFR Part 61 Radwaste Classification EHS-Q-4.103 Ells-SQ-4.010 - WASTETRAK Operations The remaining procedures associated with the Quality control Program for the shipment of radioactive materials will be reviewed by Radwaste and NPQA and revised as necessary by July 31, 1986.
In cases in which there are peer or supervicory inspections, NPQA will communicate to these personnel the insoection philosophy and regulatory nature of these inspections.
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