ML20083P131

Responds to NRC 840119 Ltr Re Violations Noted in IE Insp Rept 50-220/83-26.Corrective Actions:Engineering Procedure EP-20 Will Be Revised to Include Transport Packages as Item to Be Covered by QA Program

ML20083P131
Person / Time
Site:	Nine Mile Point
Issue date:	03/20/1984
From:	Lempges NIAGARA MOHAWK POWER CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20083P083	List: ML20083P105 ML20083P131
References
NMP-8181, NUDOCS 8404190387
Download: ML20083P131 (4)

Text

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• NMP-8181 NIAGARA MOHAWK POWER CORPORATION NIAGARA MOHAWK 300 ERIE BOULEVARD, WEST SYRACUSE. N. Y.13202 March 20, 1984 kk. Thomas T. Martin, Director Division of Engineering and Technicai Programs United States Naciear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PennsyLuania 19406 Re: DocketNo.50-QO Inspection Report 83-26 Niagara Mohawk Letter dated February 21, 1984'

Dear Ah. Martin:

This refers to the routine Safety inspection conducted by Alt. P. Clemons of your staff on November 7-10, 1983, at Nine

~b lite Point Unit H1, Scriba, New York of activities authorized by '

' NRC License No. DPR-63.

Our raponse dated February 21, 1984 answered item A of Inspection Report 83-26 and requested 30 ' day extension on _ items B and C. Our responses to these' items are as foitows.

-ITDI B

- 10 CFR 71.101(b) requires each license to estab.lish a quality assurance program for packages. 10' CFR 71.101(f)' states that '

a Commission approved c,uality assurance program that satisfies the applicable criteria of Appendix B of Part 50 of this' chapter,.

and-which is established, maintained'and"esecuted with regard to transport packages will be accepted as satisfying the require-inents of paragraph (b)' of this section.

- Criteria II, Appendix B of Part 50 of the licensee's previously

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approved program requires that the .li'censee.-identify the' structures,.

-systems and components to be covered by the; quality _ assurance program.

Contrarycto the above, as of November 9,~1983, the licensee has not: identified transport packages as a: structure, system or com,

ponent.to be. covered by the. quality assura. ice program'.'

S4041 7 840411 U PDR K:-05000220 -

, " T .- e PDR m..

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RESPONSE

By a letter dated June 2,1981 from Niagara Mohawk Nuclear Quality Control Supervisor, bit. David Palmer, to Niagara Mohawk General Superintendent of Nuclear Generation, blt. Thomas Perkins, transportation packages were included in the Nine blite Point Unit 1 Quality Assurance Program. Audit surveitiance reports are on file proving Quality Assurance activity in this area. The point of con-

.tention surrounds the words used in the Quality Assurance program which stated:

"The identification of structures, systems, and components, which are covered by the Quality Assurance Program is contained in the Engineering Design Procedures."

This refers .to EngineeA.ing Procedure EP-20, " Procedure for tassification of Materials and Components" and specifically its attachment, The Q List.

This document wiit be revised at the next quarterly update to include transport packages as an item to be covered by the Quality Assurance Program.

ITEM C 10 CFR 71.101(d) states, "The licensee shall provide for indoc-trination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Contrary to the above, one licensee employee performing activities affecting quality has not been trained in D.O.T. and NRC regulatory requirements. involved in the transfer, packaging and. transport of radioactive material to assure that suitable proficiency was achieved and maintained.

RESPONSE

Reference the Quality Assurance site organization dated 2/29/84 (attached); the Niagara Mohawk rad-waste Quality Assurance Program is chanced as follows, . effective April 30, 1984:

(A); Quality Control inspection utill.do:

1. . Cask receipt inspection.

2. Montton the torquing of cask bolts and "O" ring / gasket

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- inspection. .

.3. Monitor the final rad-prote: tion survey completion and placement of rad-was.te placards on .the Ltuck.

(B') ISite Quality Assurance will perform audit /survelitances on avproximately 10% of total.had-waste shipments leaving the

,ite (a site audit function).

b

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Page 1 (C) Corporate Quality Assurance will once a year (plus or minus a quarter of a year) perform an audit on the rad-waste Quality Assurance Program.

(D) The Quality Control inspectors performing rad-waste inspections wiit have documented training in D.O.T. and NRC rad-waste regutatory requirements.

(E) The Quality Assurance site audLtors/ surveillance personnel and the Corporate audit personnel will have appropriate N45.2.12 and N45.2.23 required training.

Very truly yours, Thomas E. Lempges fY Vice President Nuclear Generation TEL/RGR/Lo L ~

.].

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a Y a .LL -

W W. Connolly ,'

Nuclear Operations QA Supervisor .

29 r- -1 Consultant i I Unit #1 & #2 l- - --- ---

p ._, - - - i I . G. Leskiw I 8- ---3 ------: Steno-Clerk.

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I QC Engineering QC Inspection Operations QA A. Kovac (Lead) -

F. Stelter (Lead) K. Shea (Lead) 8 l 12 5 i

V. Mennella i L. Stucky P. Sconzert H. Master I F. Slye C. Coniber A. Bernardi Contractor H. During P. Farsaci C. McClay Support M. Donoghue F. Lukaczyk K. Baker Courter & Co. G. Daniels F. Sienczak G. Loan M. DeMassi 1 Open Electrical J. Porter 1 Open Mechanical G. Ogburn

S. Queen C. Moss A. Zelenka -

D. Dowd Proposed by ////I.' ~ Date ,p/49 ff' Accepted b +- Date 2 29,,99

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