ML19320B924

Responds to NRC 800515 Ltr Re Violations Noted in IE Insp Rept 50-302/80-19.Corrective Actions:Meetings Recorded on Microfilm,New Drawings Ordered & Vendor Manuals Maintained & Controlled

ML19320B924
Person / Time
Site:	Crystal River
Issue date:	06/11/1980
From:	Hancock J FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19320B915	List: ML19320B924
References
CS-80-161, NUDOCS 8007150503
Download: ML19320B924 (3)

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Power CORFO R A T ao m M*3 b21" CS-80-161 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Commission Ref: RII:DP 101 Marietta St., Suite 3100 50-302/80-19 Atlanta, GA 30303

Dear Mr. O'Reilly:

We offer the following responses to the apparent Items of Noncompliance in the referenced inspection report.

NOTICE OF VIOLATION A. As required by 10 CFR 50, Appendix B, Criterion XVII. records shall be identi-fiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention. Section, 1.7.6.7.lg of the accepted Quality Assurance "regram, Chapter 1.7 of the Final Safety Analysis Report, states in part that Florida Power Corporation has estab-lished and implemented a system for the collection, storage, and maintenance of Quality Assurance Records and that all records transmitted to the quality files sh Il be done so in accordance with established written procedures. These records are identifiable and retrievable as defined in ANSI N18.7-1976, Section 5.2.12. This Standard references ANSI N45.2.9-1974, which requires in Section 3.2.3 that Quality Assurance records shall be distributed and handled in accord-ance with written procedures and in Section 6.2, that storage systems shall pro-vide for the accurate retrieval of information without undue delay.

Contrary to the above, Quality Assurance records ware not always distributed and handled in accordance with written procedures and/or the storage systems did not l always provide for the accurate retrieval of information without undue delay as  ;

indicated by the following examples:

1. Document Control Procedure DC-104, Control of Quality Constructica, Testing, and Plant Operating Records, requires in Section 3.2.1 that plant operating l records, including Minutes of meetings of the Nuclear General Review Committee l (NGRC) be microfilmed. Minutes from the eleven NGRC meetings conducted in l 1978 were not microfilmed.

2. Procedure DC-102, Control of Drawings, Specifications, Requirement Outlines, and Manufacturer's Manuals, requires that when a completed drawing change aperture card is received, the Document Control Clerk will update the "satel-lite file" and destroy old carde. The maintenance library aperture card for orawing 302-081, FW system, had not been updated with revision 21, and the old card for revision 20 had not been destroyed.

8007150 5o 3 GeneraTOffice 32o1 Tnirty fourtn street soutn . P O Box 14042. St. Petersburg. Florda 33733 813-86,6 51p1tCIhL COM -

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e 1, . Notice of Violation Response Y

Ref: ,RII:DP/80-19 Page 2

3. Procedure DC-101, Introduction to Document Control Procedures, states that "Information Only" copies are those that are not to be used for work or any other official function. These copies are identified by a red Information Only stamp. Two filing cabinets in the maintenance library contained drawings not used for official functions that were not stamped "Information Only".

4. NGRC Meeting Minutes for the eleven meetings in 1978 and for the meeting of 8/4/77, could not be retrieved without undue delay. Copies of Minutes from eight of these twelve meetings were retrieved prior to the conclusion of this inspection.

B. As required by 10 CFR 50, Appendix B, Criterion VI, measures shall be established to control the issuance of documents including changes thereto which prescribe all activi-ties affecting quality. Section 1.7.6.7.lf of the accepted Quality Assurance Program requires that approved changes be promptly included with documents and that obsolete or superseded documents be controlled to prevent their inadvertent use.

Contrary to the above, measures had not been established to assure that all approved changes to vendor manuals are promptly entered, and that obsolete or superseded docu-ments are removed from use as indicated by the following examples:

1. A superseded copy of a Reactor Build.ng Sump Pump Manual was located in the Control Room manuals file.

2. A second copy of the Reactor Coolant Pumn Manual, in addition to the single copy listed in the master index, was located in the maintenance library. One of.these copies did not have the latest revision.

3. Two sets of Control Rod Drive Mechanism (CRDM) Control System Manuals, Volumes I, II, and III, assigned to the maintenance library could not be located with-in that library. The electrical shop library, which was allocated none of these manuals, contained one Volume I, three Volume lI's, and one Volume III.

Failure to control these manuals contributed to changes not being entered in these manuals as evidenced by one Volume II, located in the electric shop library, and two Volume I's 1ccated in the Control Room and the electric shop.

4. Two service tips, dated November and December 1979, had not been entered into the CRDM Control System Volumes II and III. located in the instruction librarv.

Response "A"

1. NGRC Minutes from the eleven meetings in 1978, and the meeting of 8/4/77 are now on microfilm. The NGRC secretary has been requested to place the CR-3 Office Manager on distribution for all NGRC Meeting Minutes.

- 2. New drawings have been ordered from the Engineering Section to update the maintenance library aperature card file. The new drawings should be on site by 13 June 1980. Document Control personnel have been instructed to assure that the aperature cards are accurately filed.

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Notice of Violation Response I Ref: RII:DP/80-19 Page 3

3. Those drawings identified in the maintenance library will be stamped "Information Only" by 31 July 1980. The clerk in the library has been instructed that no drawings are to be maintained without proper " copy" identification.

4. See 1. under Response "A".

Full compliance in these areas will be achieved by 31 July 1980.

Response "B" The items identified in the examples of Item B have been corrected. To preclude recurrence, the Document Control Program is being altered to designate two areas in which all vendor manuals are to be maintained and controlled.

The program will specify the maintenance area library along with the Office Building Document Room as the distribution points for all manuals. An additional measure will require a thirty day maximum limitation for possession of manuals by plant personnel.

Full compliance will be achieved with the implementation of the revised program by 5 September 1980.

Should there be further questions, please conte.ct us.

Very truly yours, FLORIDA POWER CORPORATION NucWar Plan' Manager J. A. Hancock Assistant Vice President, Nuclear Operations KFL/rc

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