ML19319C963
| ML19319C963 | |
| Person / Time | |
|---|---|
| Site: | Crystal River |
| Issue date: | 07/28/1978 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19319C951 | List: |
| References | |
| NUDOCS 8003040898 | |
| Download: ML19319C963 (3) | |
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Q 28 July 1978 3-0-3-a-2 g
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Docket No. 50-302 i
Mr. 7. P. O'Reilly, Director Office of Inspection & Enforcement License No. DPR-72 U.S. Nuclear Regulatory Commission Ref:
RII:RHW 101 Marietta St., Suite 3100 50-302/78-16 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following responses to the apparent Items of Noncompliance in the referenced Inspection Report.
e NOTICE OF VIOLATION A.
Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for setivities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, which includes procedures for the control of radioactivity. RP-106, Radiation Work Permit Procedure, establishes the licensee's proce-dures for use of a radiation work permit. Section 5.1.3 of RP-106 requires the Chem / Rad Section to identify specific controls for plant personnel to follow when working urder the radiation work permit. RWP No. 78-1045 of June 5, 1978, issued for the Investi-gation of FHCR-4B Restriction and Repair required that " Chem / Rad will provide coverage when the divers are in the pool."
Contrary to the above, the divers were in the Reactor Building pool under the auspices of this RWP at about 6 p.m. on June 10, 1978, without Bealth/ Physics coverage.
A.
Response: This event was identified by the licensee and corrective action had been initiated prior to the inspector's review. Discrepancy Report W/DR-193 had been issued and all concerned personnel have been counselled as to the severity and possible consequences of this occur-In our opinion, this event should not have been classed as an rence.
ites of noncompliance as it was identified and corrective action'taken internally.
Corrective action to preclude recurrence has been achieved this date.
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b J. P. O'Reilly Ref: RII:RHW Page 2 Criterion VIII to 10 CFR 50 Appendix B (Identification and Control of B.
Material, Parts, and Components) requires the establishment of measures i
to prevent the use of incorrect or defective material in safety-relatedand Criterion XIV to 10 CFR 50 Appendix B (Inspection, Test, activities.
Operating Status)-requires the establishment of measures, such as tagging i
or marking to indicate the status of inspection or tests on components, These criteria are implemented, in 3
to preclude their inadvertent use.
by Section 1.7.6.7 (Operation QA Program) of the FSAR, and by.the licensee's Quality Program Policies 8.1 (Identification and Traceability
. l
- part, of Items Used During the Operational Phase) and 14.1 (Inspection, Test, j
and Operating Status).
Contrary to the above, the hook used to lift a 2050 lb. test weight i
in the spent fuel pool (adjacent to nuclear fuel assemblies) was locally manufactured from non-certified material, was not load tested or qualified prior to use, and was not tagged or marked as to the The failure of this hook en June 9, 1978 while limitations on its use.
in use contributed to the damage to fuel assembly A-48.
Surveillance Procedure SP-601 (Procedure for Load Testing of B. Response:
Slings)coverstheloadtestingofslingsandchokers{*butdidnot and hooks.
specifically address the load testing of shackles SP-601 has been revised to specify that, in addition to load testing, all shackles and hooks will be tagged as to the load rating, and all special purpose lifting equipment will be tagged to identify the purpose for which it was designed.
As an extra precaution and in addition to the preceding changes, several signs have been placed at strategic locations in the Reactor Building and spent fuel area, directing crane operators to make no lifts over pools or the reactor vessel while they contain fuel, except with a PRC approved l
procedure.
To ensure that all concerned plant personnel are aware of the additional l
requirements for identifying, controlling and selecting equipment used in rigging, each first-line supervisor has been directed to formally discuss (and confirm that he had discussed) the new requirements with each of his personnel.
Full compliance has been achieved as of this date.
Criterion XVI to 10 CFR 50 Appendix B (Corrective Action) requires the O
C.
establishment of measures to assure conditions adverse to quality such This as defective material, are promptly identified and corrected.
criterion is implemented, in part, by Section 1.7.6.7 (Operation QA Program)of the FSAR, and by the licensee's Quality Program Procedure 16.50 (Corrective Action for Operations Phase).
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s J. P. O'Reilly Ref: RII:RHW Page 3 Contrary to the preceding paragraph, action was not'taken to preclude the movement on June 11, 1978, of two potentially damaged fuel assemblies (No's A-48 & A-20) until completion of the evaluation and inspection of these assemblies was feasible.
A documented Plant Review Conunittee (PRC) meeting was held l
C. Response:
It was on 9 July 1978 with the Nuclear Plant Manager in attendance.
understood by those present St this meeting that the potentially damaged fuel assemblies would not be moved until a video camera inspection was completed. Both fuel transfer mechanisms were inoperative and the possibility of the potentially damaged fuel assemblies being moved by mistake was neither recognized nor discussed at this meeting.
Subsequently, the completed video taped safety evaluation indicated that there was no damage to the upper and fittings of the fuel assemblies.
A Sh.rt Term Instruction (STI) should have been issued to preclude the movement of the potentially damaged fuel assemblies.
In the future STI's will be issued to affect move sheet changes for PRC decisions affecting fuel status.
Full compliance has been achieved as of this date.
v.
If there are further questions, please contact us.
{
Very truly yours,
}
d W. P. Stewart Director, Power Production JC/rc Nuclear Plant Manager
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