L-80-100, Responds to NRC 791219 & s Re Violations Noted in IE Insp Repts 50-250/79-35,50-251/79-35,50-335/79-33 & 50-389/79-22.Corrective Actions:Qa Procedures Will Be Revised Re Implementation of 10CFR21
| ML17339B077 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point, Saint Lucie  |
| Issue date: | 03/21/1980 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML17339B075 | List:
|
| References | |
| L-80-100, L-80-135, NUDOCS 8006040025 | |
| Download: ML17339B077 (6) | |
Text
P.O. BOX 529100, MIAMI,FL 33152 FLORIDA POWER 4 LIGHTCOMPANY March 21, 1980 L-80-100 r
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Mr. James P. O'Reilly, Director, Region II Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Rei lly:
Re:
RII:VLB 50-250/79-35, 50-251/79-35, 50-335/79-33 50-389 79-22 Florida Power 8 Light Company has reviewed the subject inspection report with the additional comments provided by your letter of February 20, 1980 and the response is attached.
Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8,Technology REU/MAS/ah Attachment cc:
Harold F. Reis, Esquire jjg
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PEOPLE,.,)EAVING PEOPLE
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ATTACHMENT Re:
RII:VLB 50-250/79-35, 50-251/79-35 50-335 79-33 50-389 79-22
~Findin:
Based on the NRC inspection November 27-30, 1979, certain of your activities were apparently not conducted in full compliance with NRC requirements as indicated below.
These items have been categorized as described in correspondence to you dated December 31, 1974.
. As required by Section 21.21(a) of 10 CFR Part 21, each entity subject to these regulations shall adopt appropriate procedures for evaluation of deviations and assure that a Director or responsible officer is informed if the construction or operation of a facility, or activity, or a basic component supplied for such a facility or activity fails to comply with the Atomic Energy Act of 1954, as
- amended, or any appliable rule, regulation, order or license of the Commission relating to a substantial safety hazard or contains a defect.
Section 21.21(b)(3) delineates the information to be included in the written report.
Section 21.51 delineates the maintenance of record requirements.
QP 15.4, Rev. 0, April 23, 1979 has been developed to specify the measures and responsibilities to ensure compliance to 10 CFR Part 21.
Contrary to the above Part 21 requirements, FPL Corporate QA Manual QA Procedure, QP 16.4, Paragraph 5.2 and Figure 16.4-1 does not require that all deviations be formally evaluated and documented as Part 21 evaluations.
Since formal Part 21 evaluations are not performed and documented in all cases, it follows that the follow-ing Part 21 requirements cannot be met:
(1) informing of the responsible officer (21.21(a)(2);
(2) the written reports to the Commission contain the required information (21.21(b)(3);
and
'3) the required records be maintained (21.51).
~Res ense:
Florida Power
& Light Company will revise FPL Corporate QA Manual QA Procedure, QP 16.4, in response to the finding.
The "Part 21" meeting with NRC-FPL-FPC to be held in the near future at our offices should 'provide us with additional information useful for revising our procedures for implementing 10 CFR 21.
We will, of course, coordinate the corporate procedure revisions with legal
- counsel, make changes to operating plant and construction site implementing
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procedures and conduct training in these revisions.
Accordingly, we anticipate that full compliance for future evaluations will be achieved on or before June 30, 1980.
There have been deviations, which in accordance with our previous procedures, were not specifically reported as Part 21 reports.
- However, in all cases the events were reported to the NRC as either 10 CFR 50.55 (e) reports or Licensee Event Reports.
For these
- cases, the Commission and FPL's responsible officer had been notified of the event.
Accordingly, we conclude that there would be little value gained in peforming additional evaluations of these past deviations.
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