ML19308D511

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Responds to NRC Re Violation Noted in IE Insp Rept 50-302/77-21.Corrective Actions:Instructions Given to Supervisors Re Requirement for Approved Procedures Before Removal of Components from Svc & Conduct of Maint
ML19308D511
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 12/16/1977
From: Stewart W
FLORIDA POWER CORP.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19308D510 List:
References
CS-77-268, NUDOCS 8002280825
Download: ML19308D511 (2)


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Florida 16 December 1977 c o.o,o.. r.oP wer 3- *-2.

CS-77-268 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:RIN 230 Peachtree St. N.W., Suite 818 50-302/77-21 Atlanta, CA 30303

Dear Mr. O'Reilly:

We offer the following response to the apparent item of noncompliance noted in the referenced Inspection Report.

" Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained for the activities recommended in Appendix "A" of Regulatory Guide 1.33, November

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1972, which includes Administrative Instructions.

d Contrary to the above, at numerous times during the period January-October 1977, maintenance activities were performed on safety-related equipment without approved written procedures for (1) the removal of components from service, (2) the conduct of maintenance actions and (3) the restoration of components to service as required by Administrative Instruction (AI) No. 400, Plant Operating Quality Assurance Manual Control Document and AI 600, Conduct of Maintenance."

In none of the cases cited was there any evidence of actual deleterious effect on operability of equipment or systems. Subsequent operation and surveillance indicates that no further disposition is required for the work in question.

(1) Instructions have been issued to appropriate responsible supervision which reiterate the requirement for either approved procedure to adequately cover removal from service, or for an Equipment Clearance Order to be reviewed by the Plant Review Committee and approved by the Nuclear Plant Manager prior to removal of safety-related equip-ment from service. Compliance has been achieved as of this date.

8 0 02 280 [g General Office 3201 Th.rty burin street souin. P O Box 14042. St Petersburo. Florda 33733 e 813-866 518it

Mr. J. P. O'Reilly

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Ref: RII: RHW Page 2 In the future, maintenance actions on safety-related equipment w!11 (2)

As discussed be conducted in accordance with approved procedures.

with the inspector, this may take the form of generic procedures to cover similar equipment types, appropriate vendor manuals, or sections In any case, the procedure will re-thereof, or work instructions.

ceive review as required by AI-400, Plant Operating Quality Assurance Work which only requires skills normally Manual Control Document.

possessed by the qualified maintenance personnel may not require This decision will be made by the appropriate written procedures.

responsible Maintenance Supervisor. Maintenance supervision will be Full com-counseled in the importance of the above requirements.

Pliance, including the counseling, will be obtained by 15 January 1978.

"Ihe instructions noted in our response (1) above included the re-(3) quirements for restoration of components to service in accordance with written procedure, therefore, compliance has been achieved.

We believe the above actions should preclude further noncompliance of the type noted. If there are further questions, please contact us.

We find no proprietary information in the subject Inspection Report.

Very truly yours, i

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W. P. Stewart Director, Power Production DWP/rc Nuclear Plant Manager O

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