ML19317G344
| ML19317G344 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/18/1978 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19317G339 | List: |
| References | |
| CS-78-93, NUDOCS 8002280945 | |
| Download: ML19317G344 (2) | |
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18 April'1978 3-&3-a-2 coa o,
CS-78-93 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-RHW 230 Peachtree St. N.W., Suite 818 50-302/78-6 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following response to the apparent Item of Noncompliance in the referenced inspection report.
NOTICE OF VIOLATION Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained for activities recom-mended in Appendix "A" of Regulatory Guide 1.33, November 1972, which includes Administrative Instructions. Technical Specif1-cation 6.8.2 requires that procedures be reviewed periodically, as set forth in facility administrative procedures.
Contrary to the above Technical Specifications, several procedures were not reviewed, revised and controlled in accordance with the requirements of AI-400, Plant Operating Quality Assurance Manual Control Document, as follows:
i Annual reviews were not performed on various maintenance, a.
operating, emergency, and emergency plant implementing procedures.
b.
Procedure reviews following Technical Specification changes were not documented, Temporary changes to procedures were not implemented and c.
rescinded as required by AI-400.
d.
Control room " Working Copies" were not controlled as required by AI-400.
Response: The required annual reviews have been completed for ai.'
oper-(
j ating, emergency and emergency plan implementing procedures and the
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General Office 32ci Trwty burm sireet soum. P O Box 14042 St Peteescurn Fine ru 11711. a,i. aan aia e
J. P. O'Reilly
(/s REF: RII-RHW 50-302/78-6
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Page 2 appropriate review sheets have been annotated. Revisions to all Maintenance procedures are being implemented at this time and the annual review will be accomplished by 1 August 1978.
All procedures affected by changes to the Technical Specifica-I tions have been reviewed and the documentation of these reviews is now complete. All future reviews resulting from changes to the Technical Specifications will be documented on the procedure review section as the amendments are incorporated.
Temporary changes to OP-209 and OP-204 were, in fact, entered on the accountability sheet of the Control room working copy of the P0QAM.
This is interpreted to satisfy the requirements of AI-400, Section 8.1.
The Control room files have been purged of all rescinded temporary changes as of this date.
The Administrative Section is charged with the responsibility to maints.in all procedures current and this responsibility includes the separation of enclosures from the controlling pro-cedure. A revision to Document Control procedure DC-103 is being developed to specify the controlling of the enclosures of P0QAM procedures.
Full compliance to all portions of this infraction will be achieved by 1 August 1978.
If there are further questions, please contact us.
Very truly yours,
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W. P. Scewart Director, Power Production JC/th PJ 9ws
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- ar/ Nuclear Plant Manager
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