ML19260A234
| ML19260A234 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/19/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19260A233 | List: |
| References | |
| 791030-02, 791030-2, CS-79-302, NUDOCS 7911080209 | |
| Download: ML19260A234 (2) | |
Text
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E' Nfd8 19 October 1979 Power 3-0-3-a-2 couo a m CS-79-302 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement License No. DPR-72 U.S. Nuclear Regulatory Commission Ref:
RII:CJ 101 Marietta St., Suite 3100 50-302/79-29 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following responses to the apparent Items of Noncompliance in the referenced inspection report.
As required by Technical Specification 6.8.2, procedures for surveil-lance and test activities of safety-related equipment, and changes thereto shall be reviewed by the PRC and approved by the Nuclear Plant Manager prior to implementation.
Contrary to the above, on July 26, 1979, Procedure SP-102, " Control Rod Drop Time Tests" (October 1978) was revised and implemented with-out the required review and approval.
A.
Response: The concerned maintenance personnel have been instructed by a letter designated " signature rcquired". The maintenance superin-tendent has instructed all concerned maintenance personnel that all plant procedures used to perform maintenance or surveillance will be the latest revised Working Copy of that procedure. The changes, either temporary or permanent, to any plant procedure will be in accordance with Administrative Instruction AI-400.
Full compliance has been achieved.
B.
As required by Technical Specification 6.8.l(c), written procedures shall be established, implemented, and maintained, covering surveillance and test activities of safety-related equipment.
Contrary to the above, on July 26, 1979, step 6.9 of procedure SP-102,
" Control Rod Drop Time Tests" was incorrectly implemented, resulting in erroneous measurement of control rod drop times.
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Ref; RII;CJ 50-302/79-29 Page 2 B.
Response
Step 6.9 of Surveillance Procedure SP-102, Control Rod Drop Time Test, has been revised to eliminate any inconsistencies that might occur in the timing of control rod drop.
The change re-quires a 60 llz reference trace be recorded along with tlie data, so that the timing marks can be compared to this reference for cor-rectness and accuracy.
In view of the cited deficiency, there are certain mitigating cir-cumstances which should be brought to light.
The primary reason was due to the fact that the Surveillance Procedure had not been given the opportunity to pass through the normal procedural review cycle prior to its review by the IE inspector.
The procedure was inspected by the IE inspector prior to being reviewed by the Tech-nical Specification Coordinator, or the Compliance Review Section, llad the review cycle been completed, the discrepancy would have been detected and corrected prior to Mode change.
Compliance has been achieved.
Should there be further questions, please contact us.
Very truly yours, FLORIDA POWER CORPORATION s
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Stewart Manager Nuclear Operations JC/rc WPSekcF01(D70) 1296 146