ML19254B400
| ML19254B400 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/28/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19254B393 | List: |
| References | |
| NUDOCS 7909270473 | |
| Download: ML19254B400 (2) | |
Text
!
.s
.*h.e ed %
c ge{g g- ]'u fO '
e
...t n,.c.,
y ec
,p* * #;<
'l
'1 Sf9 : 5i Florida l
Power 28,_p_s,us t,19 79
' " ~ "
l CS-79-250 l
Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Commission Ref:
RII: HDJ 101 Marietta St., Suite 3100 50-302/79-27 Atlanta, GA 30303 Dear %.
O'Reilly:
We ofrer the following response to the apparent Item of Noncompliance in
.he referenced inspection report.
NOTICE OF VIOLATION As required by 10 CFR 50, Appendix B, Criterion V, " Activities affecting quality. shall be prescribed by documented instructions and procedures and shall be accomplished in accordance with these instructions and pro-cedures". The licensee's accepted QA Program, Section 1.7.6.7.le, states in part, " Florida Power Corporation's Quality Program contains requirements and procedures to assure that each of the eighteen (18) criteria within 10 CFR 50, Appendix B are delineated, accomplished, and controlled by docu-mented procedures. Written procedures shall be strictly adhered-to in all matters relating to nuclear safety..."
CP-114, Procedure for Control of Permanent Modifications, Temporary Modifications, and Deviations, Page 5, Paragraph 3.4.2 requires that the Plant Review Committee review all modi-fications up n completion for completeness of testing requirements, NDE findings, etc.
Contrary to the above, safety-related temporary modifications were completed and final records were stored without Plant Review Committee review of testing completeness since implementation of Revision 17 to CP-ll4, dated February 23, 1979.
Response
A procedure revision to Compliance Procedure CP-114 has been submitted and will be implemented by 15 September 1979. This impending revision will:
1)
Section 3.4.2 will require the Plant Review Committee to review all safety-related temporary modifications to ensure completeness of testing requirements, NDE findings, document revision completion, and other pertinent information, and 2) Enclosure two (2) of CP-l'14 will be revised to include the PRC Chairman to sign to verify that the PRC has re-viewed post modification testing of the temporary modification.
1048 092 909svoN General Office 3201 Tnirty-fourth street soutn. P O Box 14042. St Petersburg Florida 33733 e 813-866-5151 OM4
J. P. O'Reilly, Director Ref:
RlI; HDJ-50-302/79-27 Page 2 In response to the Notice of Deviation of the referenced inspection report, the following is offered:
1)
Item A - CP-ll4 enclosure two (2) was revised and implemented on 9 August 1979. The revision was late being implemented as committed-to due to numerous procedure revisions required by the Unit Startup Order of 17 May 1979. To prevent recurrence of this deviation, Pro-cedure Review Records, requesting revisions to procedures, will be annotated as the NRC commitment dates. Full compliance has been achieved as of this date.
2)
Item G - Florida Power's earlier response contained an error wherein we stated that QOP 2.0 had been revised rather than reviewed on April 2, 1979 to provide better control of training operations.
As a result of that review, additional actions were identified and included in our response as future corrective action. Progress to date has included selection of a contractor to provide support in the establishment of a certification program for storeroom personnel.
Subsequent steps will include:
- 1) Publication of certification criteria
- 2) Certification of storeroom personnel
- 3) Certification of offaite personnel by their respective areas
- 4) Procedural revisions to accomplish the above.
Full compliance will be achieved by September 15, 1979.
- 3) Item H - QAP-8, Quality Program Audits, has been revised to require all Quality Program Department Audits to include an evaluation state-taent regarding the ef fectiveness of the quality assurance program ele-ments which were audited.
In addition, a departmental training session was held to assure understanding of this requirment by our auditors.
Full compliance has been achieved.
Shoulo there be further questions, please contact us.
Very truly yours, FLORIDA FJWER CORPORATION IM I'
/Q W. P. Stewart Nuclear /21an(Manager Manager, Nuclear Operations JC/rc 1048 093