ML19319C936
| ML19319C936 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/11/1977 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19319C928 | List: |
| References | |
| CS-77-224, NUDOCS 8003040877 | |
| Download: ML19319C936 (3) | |
Text
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M 11 October 1977 3-0-3-a-2 l30 VW f-c o n,o n. e.o =
CS-77-224 v
Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement License No. DPR-72 U.S. Nuclear Regulatory Commission Ref:
RII:SCE 230 Peachtree St. N.W., Suite 818 50-302/77-14 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following in response to the apparent Items of Noncom-pliance in the referenced inspection report.
NOTICE OF VIOLATICN
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A.
10 CFR 50, Appendix B, Criterion IV, states that
" Measures shall be established to control materials, parts, or components which do not conform to require-ments in order to prevent their inadvertent use or
%sta11ation. These measures shall include, as ap-propriate, procedures for identification, documenta-tion, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repairad or re-worked in accordance with documented procedures."
Contrary to the above, a valve which did not con-form to the design specifications was temporarily installed in the waste gas system and was not re-moved from the system in accordance with corporate Quality Procedure No. 15.10 in that the request for waiver and the noncomformance report were closed but the nonconforming material was neither accepted nor disposed. This resulted in the valve remaining in-stalled as observed on August 18, 1977, while the associated documents were signed off on June 22, 1977 indicating that it had been removed, resulting in loss of control of nonconforming material.
A.
Actions taken to correct the physical problem of WDV-857 being mis-located and WDV-857T remaining installed were completed prior to de-O parture of the inspectors on 19 August 1977. WDV-857 was properly installed and WDV-857T was removed. This was verified at that time by the inspector.
8008040 Lar23 Affir a 'on1 Thirtv-fourth Street South e P.O. Box 14042. St. Petersburg Florda 33733 813-866-515t l
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J. P. O'Railly Raf: RII:SCE 50-302/77-14 Page 2 1
The actions taken to prevent recurrence primarily involve program transition from Test Phase to Operations Phase administrative controls having been completed. In this isolated case, the coordination of construction / test phase nonconformance control and operations phase control combined with a revision to the Engineering Change Notice in question resulted in the observed infraction. Administrative control of nonconformances is now fully under the Operations phase program with defined control of nonconforming material.
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In addition to the above, the Engineering Change Notica format is no longer in use. The operations phase program employs the Modification Approval Record (MAR) as control and documentation for design changes.
This system, directed by a plant engineer, is fully computerized for tracking and status which will provide latest revisions or changes to the field for implementation.
We believe the above actions will be effective in precluding future occurrences of this nature.
Full compliance has been achieved as of this date.
B.
Environmental Technical Specifications Table 2.4-1 requires that each batch release of radioactive lig-uids be analyzed for principal ganna emitters with a minimum detectable activity of 5x10-7 uCi/ml.
Contrary to the above four analyses performed during July and August, 1977 did not meet the sensitivity specification for four radioisotopes which were inclu-ded in the computer printout.
B.
The analytical requirements of CH-268 have been re-emphasized with Chem /
Rad personnel using a Follow-up Report requiring acknowledgement. These counting requirements assure that the detection limits specified in Table 2.4-1 of the Environmental Technical Specifications will be met with the exception of radionuclides having a limiting photon r.bundance, such as Cu 0.5% and Cr 9%.
An evaluation of the analytical parameters (sample volume, geometry, etc.)
that effect detection sensitivity is in progress to determine the proced-ural and/or instrument modifications required to ensure full compliance.
In the interim, those radionuclides having detection sensitivities not in accordance with the above mentioned specification will be considered to have measured activities equal to the calculated detection sensitivity.
Full compliance will be achieved on or before January 1,1978.
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We believe the above should resolve the Items of Noncompliance.
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J. P. O'Reilly Ref:
RII:SG
~50-302/77-14 Page 3 i
We find no proprietary information in the referenced inspection report.
i If there are any questions regarding the foregoing, plea.e contact us.
Very truly yours, e
I w.
. Orow d F W. P. Stewart Director, Power Production GT!rc Nucl' ear Plant Manager i
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