ML20030D512
| ML20030D512 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/17/1981 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20030D509 | List: |
| References | |
| CS-81-163, NUDOCS 8109010472 | |
| Download: ML20030D512 (4) | |
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2.l p t 23 A3: 3 'i Florida Power C O m r o m a Y a o es July 17,1981 CS-81-163 File:
3-0-3-a-2
- 3-071-25 Mr. J. P. O'Reilly, Director 1
Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta St., Suite 3100 Atlanta, GA 30303
Subject:
Crystal River Unit 3 Docket No. 50-302 License No. DPR-72
Reference:
RII:JJL 50-302/81-09
Dear Mr. O'Reilly:
We offer the following response to the Notice of Violation in the referenced inspection report.
NOTICE OF VIOLATION As a result of the inspection conducted on June 3-4, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified.
Criterion V,
as implemented by FSAR Section 1.7.6.7.1.e requires in part,
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings....and shall be accomplished in accordance with these instructions, procedures or drawings".
Contiracy to the above, no documented instructions were prepared to pre-scribe the methods of identification of taasonry walls in the proximity cf safety-related equipment, or to prescribe the preparation of as-built drawings for masonry walls in the proximity of safety-related walls for design re-analysis.
Response
Florida Power Corporation disagrees with the cited violatica for the following reasons.
8109010472 810813 -
PDR ADOCK 0500030E O
PDR uer sercs vince Jeu 1 Thirty fourth Street South e P O. Box 14042. St. Petersburg. Flonda 33733 813-866-5151
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Mr. J. P: O'Reilly Page 2 July 17, 1981 1.
A FPC Mechanical Engineer, who is a Registared Professional Engineer, familiar the Crystal River Unit 3 and the methods used for identifying safety-relatad equipment, authorized Gilbert Associates, Inc., to work on the response to I.E.
Bulletin 80-11 GAI provided the required 60-day response.
his response identified the locations of block walls and the need for field survey to determine the possibility of damage from failed block walls to instruments, equipments, piping, etc.
The I.E.Bulletin 80-11 instructions are explicit as to what kinds of things should be reviewed in the field survey.
Using the Bulletin in-structions as a guide, a FPC Mechanical Engineer performed the survey of the areas identified by GAI and reviewed other accessible areas of the plant to verify that additional block walls existed.
Be results of this survey were transmitted to GAI for analysis on block walls.
FPC submitted the results of the GAI analysis to Region II on November 17, 1980.
2.
Further, due to the limited extent that block walls were used at Crystal E tver Unit 3 and the knowledge from preliminary drawing reviews and work on I.E.Bulletin 79-02, there was probably no major safety-related equip-ment or piping attached to or in the vicinity of any of the block walls.
The need for a formal, specific engineering procedure to perform the field survey was not considered necessary.
3 The mechanical engineer was not specifically looking for cracks in the wall; however, if major cracks had been present, they would have been noted.
Be cracks identified by the I.E.
inspetor are not extensive, small in size, and are only in the mortar between the blocks and do not extend into the blocks themselves.
The interior face of the wall is inaccessible for investigation;
- however, it would be a
reasonable assumption that these are minor cracks of little concern rather than large cracks on the interior face of the wall which have propagated through the wall.
Even though the engineer was not looking for cracks specifically and did not note any,it is possible that these cracks may have developed after the field mrvey.
Since this wall is not one which has safety significar.ca in the event of collapse, ne further action is considered necessary on this item.
4.
The conduit (No. ACC-29) identific by the inspector as passing through a portion of Wall 1 but not identified on the field survey, is, in fact, color-coded and tagged as if it were safety-related. Based on the criteria used by the site engineer for the survey, this conduit should have been identified.
Research into the function of the cable within the conduit has shown that no safety-related function is performed by the cable (it is a reliability feed for lighting in the control complex). Bis particular re-liability feed is a non-safety-related circuit to a lighting distribution l
panel fed from a safety-related engineered safeguards motor control center.
i This typc arrangement is used to maintain a high degree of c nfidence that lighting will be available in the control complex only.
Bere would be no safety significance of a failure of this circuit or adverse effect on the motor control center.
No further action is considered necessary on this item.
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I Mr. J. P. O'Reilly Page 3 July 13, 1981 i
Florida Power Corporation is convinced that the documented instructions from the I.E.
Bulletin 80-11, Crystal River Unit 3 architectural / engineering Orawings, and independent review of architect / engineer's work by a registered professional engineer are more than adequate to meet FSAR Section 1.7.6.7.1.e.
Based on details and justifications described in this response to the identi-fled notice cf violation, Florida Power Corporation hereby requests for the withdrawal of the Notice of Violatica.
Should there be any questions, please contact us.
Very truly yours I
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D. C. Porle Dr.PatsyY.BAynard Nuclear Plant Manager Manager Nuclear Support Services WGL:mm i
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r STATE OF FLORIDA COUNTY OF PINELLAS P. Y. Bayr.ard states that she is the Manager, Nuclear Support Services, of Florida Power Corporation; that she is authorized on the part of said compny to sign and file with the Nuclear Regulatory Comission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
l C h o h,... O O FV Y. B $hard Suoscribed and sworn to befare me, a Notary Public in and for the State and County above named, this 17th day of July,1981.
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Notiry Public
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Notary Public, State of r]orida at Large, My Comission Expires: May 29, 1984 1
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