ML19317G245

Responds to NRC 780424 Ltr Re Violations Noted in IE Insp Rept 50-302/78-08.Corrective Actions:Mod to Record Storage Vault Doors Requested & Personnel Reinstructed to Ensure Safety Evalutions

ML19317G245
Person / Time
Site:	Crystal River
Issue date:	05/09/1978
From:	Stewart W FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19317G235	List: IR 05000302/1978008 ML19317G234 ML19317G240 ML19317G245 ML19317G248 ML19317G249
References
CS-78-112, NUDOCS 8002280875
Download: ML19317G245 (2)

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. c Florida 9 May 1978 3-0-3-a-2 Poo==no.wer coa CS-78-112 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-WHB 230 Peachtree St. N.W., Suite 818 50-302/78-08 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. Criterion XVII of Appendix B to 10 CFR 50 as implemented by Section 1.76 (Florida Power Corporation Quality Manual, approved by the NRC on May 31, 1977) of the FSAR, requires that completed Quality Assur-ance records be retained and stored in adequate facilities in accord-ance with ANSI N45.2.9 - 1974 which states in part that " permanent and temporary record storage facilities shall be so constructed to protect the contents from possible destruction by fire and should be afforded the equivalent protection of a NFPA Class A, four (4) hour rated facility."

Contrary to the above, on April 4, 1978, certain QA records which consisted of all plant operating records for 1977 and a portion of the plant operating records for 1978 were stored in a temporary record storage vault which had two (2) doors which had fire ratings of 1 1/2 hour each.

A. Response:

A request for Engineering Information (REI) has been submitted to FPC Production Engineering requesting a modification (MAR) be genera-ted to modify the three (3) doors involved in the permanent and tempor-ary record storage vaults to comply with the four (4) hour rating requirement of ANSI N45.2.9 - 1974.

' Full compliance will be achieved by 30 September 1978.

8002 28n DC

J. P. O'Railly ,

REF: RII-WHB-50-304/78-08 Page 2 Notice of Violation Cont'd B. Technical Specification 6.8.1 requires that written procedures shell be established, implemented and maintained covering the activities referenced in Appendix "A" to Regulatory Guide 1.33, ,

November 1972. Appendix "A" to Regulatory Guide 1.33, Section 9(e) requires that procedures exist for the control of modifica-

.= tion work.

Contrary to the above, Compliance Procedure 114 (Procedure for Control of Permanent Modifications, Temporary Modifications and Deviations - CP-ll4) was not fully implemented or followed in that:

1. Certain safety-related modifications did not have a safety evaluation performed on them. Examples include: MAR 77-1-24, 77-2-30, 77-2-10.

2. Drawings were not always updated following safety-related modifications. Examples include:

Drawing No. FD-302-082 (MAR 77-11-04)

Drawing No. FD-302-681 (MAR 77-10-06)  :

B. Response: _

l. By letter of 9 May 1978 from the Technical Services Superintendent to the Maintenance Superintendent, all Maintenance Supervisors, Technical Support Engineer, and all Plant Review Committee Mem-  :

bers have been instructed to ensure that safety evaluations l have been performed on all safety-rela'ted plant modifications.

Full compliance has been achieved as of this date.

2. By letter of 9 May 1978 from the Technical Services Superintendent to the Technical Support Engineer the instruction was given to review the safety-related modifications and update the drawings j as required. Full compliance will be achieved by 1 July 1978.  :

l If there are further questions, please contact us.

o, B. DJ6 / w l

W. P. Stewart f

' Director, Power Production j JCire l

Nuc1 ar D nt Manager l

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