ML19336A744
| ML19336A744 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/03/1980 |
| From: | Hancock J FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19336A743 | List: |
| References | |
| CS-80-241, NUDOCS 8010310187 | |
| Download: ML19336A744 (3) | |
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..g3 Florida October 3, 1980 Power 3-o-3-a-2 cea*oanw~
CS-80-241 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & E.iforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Com=ission Ref:
RII: WAR 101 Marietta St., Suite 3100 50-302/80-30 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following responses to the Items of Nonccepliance in the referenced inspection report.
NOTICE OF VIOLATI,0N A.
As required by 10 CFR 50, Appendix B, Criterion III, measures shall be established to assure that the design bases for those structures, systems and components to which this Appendix applies are correctly translated into drawings. The licensee's accepted QA program (FSAR) Section 1.7.6.7.1.s commits the licensee to Regulatory Ct ide 1.64, Revision 2, June 1976, and this Regulatory Guide endorses ANSI 45.2.11-1974.
ANSI 45.2.11-1974, Section 4.1 requires that design activities shall be accomplished in accordance with procedures of a type sufficient to assure that applicable design inputs are correctly translated into drawings.
Contrary to the above, applicable design inputs were not correctly translated into drawings in that MAR 79-11-82G electrical leads TB-14-ll-624 and TB-14-12-624 were specified to be connected in Relay Rack 3, relay BA, terminals 9 and 10 respectively as shown on drawing EC-210-621 Interim Revision C.
On August 14, 1980, the inspector verified with plant QC personnel that on relay BA, terminals 9 and 10 do not exist. MAR 79-ll-82G was signed off for proper installation.
A. Response: On 18 August 1980, Plant Modification (MAR)'79-ll-82H was generated to correct the drawing error in MAR 79-ll-82G.
To prevent further noncompliances of this type, a revision to Plant Procedure CP-114, Procedure for Preparation and Control of Permanent Modifications, Temporary Modifications, Deviations and MAR Functional Test Procedures, will require each MAR package be independently controlled. At any time a MAR cannot be installed in accordance with its installation instructions, a revision to that MAR most be effected prior to continuing with the installation.
Full compliance will be achieved by 31 October 1980.
. u KI AL COPY
. Gengr 3201 Tnirtetourin street sourn. P O Box 14042. St Petersburg. Florida 33733 813 - 866-5151 8 010 3 3:k. '
g Notice of Violation Response Ref:
RII-WAR 50-302/80-30 Page 2 i
l B.
As required by Technical Specification 6.8.1, procedures shall be implemen-l ted. AI-1000, Good Housekeeping, Revision 8 dated 4/80, Section 8.0, states that the Building Services Supervisor shall initiate corrective action with-i in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for deficiencies identified during weekly inspections performed by the Operations Technical Advisor or the Outage Shift Manager.
Contrary to the above, AI-1000, Good Housekeeping, Section 8.0 was not im-plemented in that for discrepancies identified during inspections, held on l
May 26 - June 1, June 9-14 and July 10, 1980, conducted by plant personnel, I
corrective action was not taken by the Building Services Superintendent by
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August 14, 1980.
j B. Response: The following immediate corrective action was taken:
- Building Service Supervision toured the plant and identified those items requiring immediate attention. Work crews were assigned to these areas and another plant tour was held at the completion of the cleanup to ensure those identified items were in an acceptable condition.
Steps taken to avoid future noncompliance include:
- Upon completion o2 the weekly inspection required by AI-1000, the list of discrepancies is hand carried to the Building Service Supervisor. Personnel who are responsible are immediately notified on all priority one items.
- For those discrepant items other than priority one, the responsible supervisor is notified and he must have the discrepancies resolved within one (1) week.
- For those discrepant items requiring more than one week to resolve, a Work Request is written and the Wu.i Request number is recorded on the inspection report.
- When all discrepant items have been corrected and reviewed by the Building Service Supervisor, the completed inspection report is i
forwarded to the Quality files.
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F'ull compliance has been achieved.
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C.
As required by 10 CFR 50, Appendix B, Criterion XVII, sufficient records shall be maintained to furnish evidence of activities af fecting quality.
The accepted QA Program (FSAR), Section 1.7.6.7.1.q.2 states that QA records
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l are those records that furnish. documentary evidence of the quality of items
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i and of activities affecting quality. These records include the results of p
reviews.
QAP-2, Preparation and Control of Administrative Procedures, n
Revision 3, dated 6/79, Section 4.5 requires that Administrative Procedures S
be reviewed annually or when departmental administration alignments have j
been revised.
E; Contrary to the above, there were no records to document the results of annual reviews of quality procedures.
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Notice of Violation Response Ref:
RII: WAR 50-302/80-30 Page 3 C.
Response
Following completion of the current review of Quality Programs Department Administrative Procedures, the Manager, Quality Audits and Engineering vill dicument the results of the review.
In addition, the requirement to document the results of Administrative Procedure reviews I
will be added in the next revision of QAP-2, Preparation and Control of Administrative Procedures, which will be issued prior to October 31, 1980.
1 Should there further questions, please contact us.
Very truly yours, I
FLORIDA POWER CORPORATION i
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MdN J j
. A. Hancock l
Nuc ear Plant Manage Assistant Vice President Nuc1 car Operations I
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