ML19317G245
| ML19317G245 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/09/1978 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19317G235 | List: |
| References | |
| CS-78-112, NUDOCS 8002280875 | |
| Download: ML19317G245 (2) | |
Text
. __
O.. ~ :"Fe
{.
c
[ c gect LC(QL Cl
- b"sc.eCW c
Florida 9 May 1978 Poo==no.wer 3-0-3-a-2 coa CS-78-112 Docket No. 50-302 Mr. J. P. O'Reilly, Director Office of Inspection & Enforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Commission Ref:
RII-WHB 230 Peachtree St. N.W., Suite 818 50-302/78-08 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following responses to the apparent Items of Noncompliance in the referenced Inspection Report.
Criterion XVII of Appendix B to 10 CFR 50 as implemented by Section 1.76 (Florida Power Corporation Quality Manual, approved by the NRC on May 31, 1977) of the FSAR, requires that completed Quality Assur-ance records be retained and stored in adequate facilities in accord-ance with ANSI N45.2.9 - 1974 which states in part that " permanent and temporary record storage facilities shall be so constructed to protect the contents from possible destruction by fire and should be afforded the equivalent protection of a NFPA Class A, four (4) hour rated facility."
Contrary to the above, on April 4, 1978, certain QA records which consisted of all plant operating records for 1977 and a portion of the plant operating records for 1978 were stored in a temporary record storage vault which had two (2) doors which had fire ratings of 1 1/2 hour each.
A.
Response
A request for Engineering Information (REI) has been submitted to FPC Production Engineering requesting a modification (MAR) be genera-ted to modify the three (3) doors involved in the permanent and tempor-ary record storage vaults to comply with the four (4) hour rating requirement of ANSI N45.2.9 - 1974.
Full compliance will be achieved by 30 September 1978.
8002 28n DC
J. P. O'Railly REF: RII-WHB-50-304/78-08 Page 2 Notice of Violation Cont'd B.
Technical Specification 6.8.1 requires that written procedures shell be established, implemented and maintained covering the activities referenced in Appendix "A" to Regulatory Guide 1.33, November 1972.
Appendix "A" to Regulatory Guide 1.33, Section 9(e) requires that procedures exist for the control of modifica-tion work.
.=
Contrary to the above, Compliance Procedure 114 (Procedure for Control of Permanent Modifications, Temporary Modifications and Deviations - CP-ll4) was not fully implemented or followed in that:
1.
Certain safety-related modifications did not have a safety evaluation performed on them. Examples include: MAR 77-1-24, 77-2-30, 77-2-10.
2.
Drawings were not always updated following safety-related modifications. Examples include:
Drawing No. FD-302-082 (MAR 77-11-04)
Drawing No. FD-302-681 (MAR 77-10-06)
B.
Response
l.
By letter of 9 May 1978 from the Technical Services Superintendent to the Maintenance Superintendent, all Maintenance Supervisors, Technical Support Engineer, and all Plant Review Committee Mem-bers have been instructed to ensure that safety evaluations have been performed on all safety-rela'ted plant modifications.
Full compliance has been achieved as of this date.
2.
By letter of 9 May 1978 from the Technical Services Superintendent to the Technical Support Engineer the instruction was given to review the safety-related modifications and update the drawings j
as required. Full compliance will be achieved by 1 July 1978.
If there are further questions, please contact us.
o, B. DJ6 / w l
W. P. Stewart f
Director, Power Production j
JCire l
Nuc1 ar D nt Manager l
\\
4
,-