IR 05000250/1979033
| ML17339A508 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/06/1979 |
| From: | Gibson A, Zavadoski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17339A507 | List: |
| References | |
| 50-250-79-33, 50-251-79-33, NUDOCS 8002010152 | |
| Download: ML17339A508 (34) | |
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos. 50-250/79-33 and 50-251/79-33 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, Florida 33101 Facility Name:
Turkey Point License Nos.
DPR-31 and DPR-41 e near Homestead, Florida Inspection at Turkey Poi Inspected by:
Approved by:l
,.~ R. W.'
c l
A. F. Gibson, Section Chief, FFMS Branch SUMMARY Date Signed Dat Signed t
Inspection on November 11-16, 1979 Areas Inspected This routine, unannounced inspection involved 27 inspector-hours onsite in the areas of liquid, gaseous and solid radwastes, records and reports of radioactive effluents, procedures for controlling effluent releases, respiratory protection program, filtration systems, and ALARA consideration.
Results Of the nine areas inspected, no apparent items of noncompliance or deviations were identifie i
DETAILS Persons Contacted Licensee Employees-H.
J.
Ap D.
D.
J.
E.
A.
R.
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"S.
E. Yaeger," Plant Manager E. Moore, Superintendent, Nuclear Operations W. Hughes, Health Physics Supervisor W. Jones, Quality Control Supervisor W. Haase, Technical Supervisor S.
Wade, Jr.,
Chemistry Supervisor R. LaPierre, Radiochemist T. Hall, Results Assistant L. Longdon, Documentation Specialist F. Story, Corporate Health Physicist E. Tucker, QA Engineer S. Peck, Health Physics M. Feith, Quality Assurance The inspector also talked with and interviewed other licensee employees, including members of the technical staff, health physics and operations personnel.
-Attended exit interview Exit Interview The inspection scope and findings were summarized on November 16, 1979, with those persons indicated in Paragraph 1 above.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance 79-10-01 (50-250/79-10; 50-251/79-10):
Posting of Airborne Radiation Areas.
Licensee has posted both containments as Airborne Radiation Areas.
This item is closed.
(Closed)
Noncompliance 79-10-02 (50-250/79-10; 50-251/79-10):
Contamination on Respirators.
Licensee demonstrated that several respirators did not have loose contamination.
This item is closed.
(Closed) Noncompliance 78-11-03 (50-250-79-11; 50-251/79-11):
Solid Rad-Waste Shipments.
Licensee has modified procedures and shipments are in accordance with regulations.
This item is closed.
(Closed)
Noncompliance 79-27-02 (50-250/79-27; 50-251/79-27):
Radiation Levels in Unrestricted Areas.
Area identified has been fenced off.
This item is close (Closed) Noncompliance 79-20-01 (50-250/79-20; 50-251/79-20):
Radiation Ievels in Unrestricted Areas.
Area identified has been eliminated.
This item is closed.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
'Plant Tour a
~
During the course of the inspection, the inspector toured the auxiliary building including the two foot elevation, ten foot elevation pipe chase, residual heat removal pits, ground elevation cubicles, chemical volume control systems on the roof elevation, and the radwaste building.
It was obvious to the inspector that continuing progress in cleanliness had been made in each building as compared to past inspections (IE Report Nos. 50-250/78-11, 50-251/78-11, Details I, paragraph 4.c 50-50-250/78-21, 50-251/78-21, paragraph 9.c, 50-250/78-26, 50-251/78-26, paragraph 4,
and 50-250/78-29, 50-251/78-29; paragraph 10.a) by the same inspector.
b.
The inspector again noted:
(1) the absence of large quantities of anticontamination clothing left at step-off pads in the auxiliary building, (2) the large majority of the step-off pads were new, (3)
the change out area in the RCA was relatively well stocked with clean anticontamination clothing.
At the entrance to the waste gas decay tank pipe and valve room, the inspector noted a survey sheet which indicated smearable contamination levels of less than 1000 dpm/100 cm (IE Report 50-250/78-29, 50-251/78-29, paragraph 7).
In the auxiliary building the inspector noted that the storage areas under the tool room and on the rampway from the two foot elevation to the ten foot elevation (IE Report 50-250/78-26, 50-251/78-26, paragraph 4.c) were clear and all articles stored under the tool room were properly packaged.
The inspector observed numerous instances where contaminated material was properly packaged in double polyethylene bags as required by procedure HP-41,
"Movement of Materials Inside the Radiation Control Area".
The inspector had no further questions or observations in this area.
6.
Gaseous Radioactive Effluent Releases The inspector examined selected gaseous release permits, gaseous waste management running logs and licensee scheduling records for the period January - October, 1979.
An inspection was also made of the waste gas decay tanks, compressor, monitor and surge tank.
Based on the records reviewed and discussions with licensee representatives,'he licensee appeared to be in compliance with Section 3.9, Technical Specifications requirements related to:
(1) noble gas instantaneous and quarterly release rates; (2)
release rates for radioiodines; (3) establishment of gaseous waste monitor alarm settings; (4) maximum activity in decay tanks; (5) sampling and analysis of radioactive material in gaseous wastes.
The inspector also
verified that adequate meteorological information was available during a
release.
No items of noncompliance or deviations were identified.
Liquid Radioactive Effluent Control The inspector examined selected liquid release permits, liquid waste manage-ment running logs, and chemistry department scheduling records for the period January - October 1979.
Based on these examinations and subsequent discussions with licensee representatives, the inspector determined that the licensee appeared to be in compliance with Technical Specification, Section 3.9, requirements relating to:
(1) instantaneous release limits; (2) cumulative release limits; (3) establishment of alarm setpoints for the effluent control monitor; (4) and sampling and analysis of liquid radwastes.
No items of noncompliance or deviations were identified.
Records and Reports of Radioactive Effluents The inspector verified from selected records of liquid and gaseous releases made during the period early 1979 to mid 1979 that records required by Section 6.9.1.a(3)
of the Technical Specification were maintained.
The inspector also noted that the licensee had submitted the Semiannual Radio-active Effluent Release Report for the period January 1 - June 30, 1979, as required by Technical Specification Section 6.9.1.
No itemsof noncompliance or deviations were identified.
Procedures for Controlling Effluent Releases The inspector reviewed Nuclear Chemistry Procedures:
NC-40, "Determination of Dissolved Fission and Activation Gases in a Typical Iiquid Release",
dated February ll, 1977; NC-41, "Determination of Sr-89-90 Activity in Monthly Liquid Release Composite",
dated February 11, 1977; NC-42,
"Sample Preparation, Analysis and Documentation of Weekly and Monthly Liquid Release Composites",
dated February ll, 1977; NC-43, "Sampling and Analysis of the Contents of Liquid Waste Tanks for Gross Py or Isotopic Radioactivity",
dated February 11, 1977; NC-44'Preparation of a Liquid Release Permit,"
dated February 11, 1977; NC-45, "Determination of Tritium Activity for Liquid Release Composites",
dated February 11, 1977; NC-46, "Determination of Gross Py and/or Gross
~ activity for Liquid Release Composites",
dated February 11'977'C 47'etermination of Ratio of Isotopic Concentrations to Maximum Permissible Concentration (Ci/MPC) in Liquid Release",
dated February ll, 1977; NC-52, "Sampling and Analysis, Preparation and Documen-tation of Gas Decay Tank Releases,"
dated February ll, 1977; NC-53,
"Sampling and Analysis of Containment Atmosphere for Preparation and Documentation of Instrument Bleed Line and Containment Purge Release",
dated February lip 1977'C 54'ethod for Monthly Accounting of Gas Leakage from the Auxiliary Building", dated February ll, 1977'C 55'Seven Day Gross Py and Gross
~ Activity on the Plant Vent and Spent Fuel Pit NMC Particulate Filters", dated February 11, 1977.
These procedures were previously reviewed in IE Report Nos. 50-250/78-26; 50-251/78-26, paragraph 9.
The inspector had no comments on procedure content or com-ments concerning recent revisions.
Based on a review of the procedures and
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-4-discussions with licensee representatives the inspector determined that revised procedures received the reviews and approvals required by licensee procedures.
The aforementioned procedures required that liquid and gaseous releases be done under a permit system.
Based on a review of licensee releases records for the period January - October 1979, the licensee appeared to be utilizing the permit system for all liquid and gaseous releases.
No items of noncompliance or deviations were identified.
10.
Solid Rad Wastes During the course of the inspection, the inspector randomly selected four drums of compacted waste and requested licensee representatives to open all four drums.
'The drums were designated 79-1365, 79-1379, 79-1381 and 79-1378, marked as "Radioactive LSA" and ready for shipment.
At the inspector's request, the entire contents of the first two drums were taken from the drums and examined by the inspector.
No problems were identified by the inspector.
The inspector observed the compacting operation for several drums and did not identify any problems or items of noncompliance.
t of ea exnp ll.
Respiratory Protection Program Health Physics Procedure HP-60, "Respiratory Protection Manual", Section 12.6, requires that no detectable removable contamination be allowed on respirators made available for reissuance.
On November 14, 1979, the inspector randomly selected three used, cleaned and packaged respirators from the issuance shelf and took smear surveys on the outside of each facepiece.
On November 14, 1979, the inspector selected two respirators on the ready-to-issue shelf, numbered F47B and F564.
The inspector took a smear survey of each respirator and found no removable contamination.
The inspector informed licensee representatives that the item of noncompliance raised in Report Nos. 50-250/79-10; 50-251/79-10, paragraph 9.b
, had been adequately resolved.
The inspector had no further questions in this area.
The inspector also checked the contents of several spent resin portable demineralizers and filters (reading up to 6 Rem/hr contact)
located in the low level storage vault in the radwaste building.
After viewing the contents ch tank th
'
ector had no further questions or observations.
12.
Bulletin 78-08, "Radiation Levels From Fuel Element Transfer Tubes" This bulletin described potential problems of radiation streaming from fuel transfer tubes during fuel movement.
The inspector examined the results of a survey of the Unit 3 and 4 fuel transfer tubes performed during movement of fuel in the tube.
The inspector had no further questions.
13.
Airborne Radioactivity Areas The inspector reviewed the records of airborne radioactivity levels inside the Unit 3 and 4 containments.
The records showed levels of Xe-133 exceeded the maximum permissible concentration in air, as stipulated in 10 CFR 20, Appendix B, Table 1, Column 1.
CFR 20.203(f) requires that each airborne
"5" radioactivity area be conspicuously posted with a sign bearing the radiation caution symbol and the words "Caution Airborne Radioactivity Area".
The inspector, accompanied by a licensee representative noticed that the entrance to the Units 3 and 4 containments were posted as an airborne radioactivity area.
The inspector had no further questions or observations in this area.
14.
Filtration Systems The inspector reviewed the licensee's program for ensuring compliance with Technical Specifications, Section 4.7.1, on Emergency Containment Filtering systems.
The inspector reviewed the test results for DOP, Freon, and laboratory tests for calendar year 1979 and had no further questions or observations.
15.
ALARA Considerations
- Steam Generator Jumpers The inspector discussed with licensee representatives the present status of training provided for steam generator jumpers.
Presently steam generator jumpers are provided over fifteen hours of training including a simulated steam generator jump.
An examination over the material covered is admin-istered at the end of the training.
In addition, jumpers received respirator training utilizing a quantitative fit method.
The inspector toured the steam generator mock-up facility located in the radwaste building.
The mock-up is to scale and is complete with blasting covers and collapsible tools and jigs.
The inspector also noted several small (approximately 1000 to 1500 CFM) portable ventilation systems.
Licensee representatives stated that the portable units would be used for cleaning the air during steam generator entries.
The inspector had no further questions or observations in this area.
16.
ALARA Considerations
- Anchor Bolt Inspections The inspector asked licensee representatives the present estimates of man-rem exposure received as a result of mandated anchor-bolt inspections.
Licensee's representatives provided the following tabulation to the inspector:
Anchor Bolt Inspection (Man-Rem) for 1979 Unit g4 (Containment)
126.742 Unit j/4 (Auxiliary Building) 6.829
~
Unit II3 (Auxiliary Building) 7.495 Total as of November 16, 1979, 141 Man-Rem The inspector had no further questions or observations in this are <<1
17.
Information Notices, Bulletins and Circulars The inspector reviewed with licensee representatives the following Information Notices:
"Rupture of Radwaste Tanks", IE Information Notice 79-08, "Interconnection of Service Air and Breathing Air", IE Information Notice 79-09, "Spill of Radioactively Contaminated Resin", IE Circular 79-15, "Bursting of High Pressure Hose and Malfunction of Relief Valve and "0"-Ring in Certain Self-Contained Breathing Apparatus" and found that each of the above applied in a minimal way to the facility.
The inspector also reviewed the licensee's response and field data to IE Bulletin 79-19,
"Packaging of Low Level Radioactive Waste for Transport and Burial", IE Circular 79-21, "Prevention of Unplanned Releases of Radioactivity" and IE Bulletin 78-04,
"Personnel Radiation Exposure in Reactor Cavities",
and was satisfied with the responses and had no further questions or observation J f
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In Reply Refer To:
RII:TEB 50-335/79"33 50-389/79-22 50-250/79-35 50-251/79-35 UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 DEC 1 9 1979 Florida Power and Light Company ATTN:
R. E. Uhrig, Vice President Advanced Systems and Technology P. 0. Box 529100 Miami, FL
.33152 Gentlemen:
This refers to the inspection conducted by V. L. Brownlee of this office on November 27-30, 1979 of activities authorized by NRC License Nos.
DPR-31, DPR-41, DPR-67 and Construction Permit No.
CPPR-144 for the St. Iucie and Turkey Point facilities, and to the discussion of our findings held with R. E. Uhrig on t
November 29, 1979 and A. E. Siebe on November 30, 1979.
J Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective 'examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.,
I During the inspection, it was found that certain activities under your license appear to be in noncompliance with NRC requirements.
This item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
This notice is sent to you pursuant to the provisions of Sec-tion 2.201 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within 20 days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further noncompli-ance; and (3) the date when full compli'ance will be achieved.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons on the basis of which it is claimed;that the information is proprietary, and should be prepared so t
that proprietary information identified in the application is contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Roo ~.r,
Florida Power and Light Company DEC 1 9 1979 Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely,
. E.
rphy, Chief Reactor Construction and Engineering Support Branch
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-335/79-33, 50-389/79-22, 50-250/79-35 and 50-.251/79"35
REGION II==
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos. 50-250/79"35, 50-251/79-,35, 50-335/79-33 and 50-389/79-22 Licensee:
.Florida Power and Light Company 9250 West Flagler Street Miami; Florida 33101 Facility Name:
St. Lucie Units 1 and 2, and Turkey Point. Units 3 and
Docket Nos. 50-250, 50-251, 50-335 and 50-389 License Nos. DPR-31, DPR-41, DPR-67 and CPPR-144 Inspection at St. Iucie Units 1 and 2, and Florida Power and.Light Company's General Offices Inspectors:
V. L.
ownlee t
T. E. Burdette Approved by:
Dat Signed
/2 rt7'/
Date Sign'ed
.
M
, Chi R &ES Branch Date ig ed SUMMARY Inspection on November 27-30, 1979 Areas Inspected This. routine, unannounced inspection involved 44 inspector-hours onsite and at the General Office 'in review of procedures and controls adopted by Florida Power and Light (FPM) to implement the requirements of 10 CFR Part 21 and
CFR 50.55(e).
Results Of the two areas inspected, no items of noncompliance or deviations were identi-fied in one area; one item of noncompliance was found in one area (Infraction 335/79-33-01, 389/79-22-01, 250/79-35-01 and 251/79-35"01;
CFR Part 21 procedures.
See paragraph 5.c and 5.d).
I r
DETAILS 1.
Persons Contacted Licensee Employees
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E. Uhrig, Vice President, Advanced Systems 6 Technology J. Escue, Site Manager E. Siebe, Assistant QA Manager F. Englmeier, Assistant QA Manager T.
Weems, Assistant QA Manager Villar, Licensing Engineer W. Jones, QC Supervisor C. Gruzan, Licensing Engineer N. Paduano, Manager Power Resources Cuan, QA Engineer P.
Green, Power Plant Engineering R. Stone, QC Supervisor M. Hayward, QA Construction Supervisor Sherman, QA Engineer'.
Roos, Acting QC Supervisor J.
Spooner, Construction QC
+Attended exit interview held November 30, 1979
>-"Attended exit interview held November 29, 1979 Attended exit interviews held November 29 and November 30, 1979 2.
Exit Interviews The inspection scope and findings were summarized on November 29, 1979, and
.
¹vember 30, 1979, with those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items 5.
Unresolved items were not identified during this inspection.
Compliance with 10 CFR Part 21, and
CFR 50.55(e)
a.
General The purpose of this inspection was to ascertain whether FPSL and appropriate responsible officers had established and implemented procedures and other -instructions as required to ensure compliance with 10 CFR Part 21 requirements relative to the reporting of defects and noncompliances.
This inspection also involved the review of
r
FPSL's procedures for implementing
CFR 50.55(e)
requirements relative to the reporting of construction significant deficiencies.
Inspector determinations are based on the requirements of 10 CFR Part 21, as clarified by staff positions in NUREG-0302, Revision 1, and
CFR
,50.55(e).
The inspectors examined and evaluated the St.
Iucie Units 1 and 2 program procedures and implementation on November 27-28, 1979, at the St.
Lucie site.
The General Offices and Turkey Point Units 3 and 4, program procedures and implementation were examined and evaluated on November 29-30, 1979, at the Miami General Office.
Part 21 requires that each organization, such as FPGL, that constructs, owns or operates>
a facility which involves "basic components" as defined under Part 21 is subject to its regulations.
FPSL and its responsible officers must therefore ensure compliance with requirements of Part 21 as specified in Section 21.6 for posting; 21.21.(a) for procedures; 21.21.(b) for notification and written reports to the Commission; 21.31 for the inclusion of.-appropriate references in procurement documents; and 21.51 for preparation and maintenance of records.
As'a result of this inspection, the inspectors indentified one (1)
item of noncompliance discussed in paragraphs 5.c and 5.d below.
Documents Reviewed
/
(1)
Construction Quality Control Quality Instruction Manual QI 15.2, Rev.
1, January 13, 1977, Processing of 10 CFR 50:55(e) Discrepan-cies (2)
Quality Assurance Manual Procedure No.
QP 16.4, Rev.
0, April 23, 1979, Evaluating and Reporting of Substantial Safety Hazards in accordance with 10 CFR Part 21 (3)
Quality Ass'urance Manual Procedure No.
QP 16.6, Rev. 0, August 16, 1976, Reporting of 10 CFR 50.55(e) Deficiencies (4)
St. Lucie Procedures Manual Procedure No. SQP-21, Rev. 0, April 20, 1979, Site Quality Procedure Corrective Actions.
(5)
Nonconformance Report 894c and associated
CFR 55(e) review documents.
(6)
Noncompliance reports relating to CBRI derrick failure and associ-ated
CFR 50.55(e)
review documents.
/
(7)
Nonconformance Report 895E and associated
CFR 55(e) 'review documents.
(8)
CFR 50.55(e) evaluation and report of 4.16 KV switch gear, April 6, 1978 and May 3, 197 Cl
,/ l'
(9)
Turkey Point 3 and 4 Administrative Pr'ocedure 0103.6, July 7, 1978, Reportable Occurrences (10)
(12)
St. Lucie Plant'dministrative Procedure No. 0010721, Rev. 3.
July 10, 1978, NRC Required Non-routine Reports.
Quality Assurance Engineering Audit of 10 CFR 50.55(e)
and
CFR 21 Compliance.
Turkey Point Units 3 and 4 Administrative Procedure 0190.21, May 29, 1979, Nuclear Safety Hazard-Identification (i3)
Power Plant Engineering Department EPP-QI 16.3; Rev. 0, April 7, 1978, Defects and Noncompliances Reporting and Evaluation.
(14)
Quality Assurance Procedure No.
QP 4.1 Control of Requisitions and the Issuance of Purchase-Orders for Spare Parts, Replacement Items and Services.
(i5)
Quality Assurance Procedure No.
QP 4.4, Review of Requisition on Purchasing Agent for Items and Services Other than Spare Parts.
(i6)
Power Plant Engineering Department Quality Instruction QI 16-EPP-9, Rev. 0, Identification and Correction of Discrepant or Deficient Conditions Related to Nuclear Power Plant During Construction and Operation.
Program Review and Implementation - Power Plant Engineering and Construc-tion Program Review The inspectors reviewed the above noted controlling procedures (5b(1), (2), (3), (4), (13),
(15) and verified that procedures have been established within Power Plant Engineering and Con-struction for 10 CFR Part 21 and
CFR 50.55(e)
requirements.
However, the inspectors noted that QA Procedure, QP-16.4, paragraph 5.2 and figure 16.4-1 do not require that all devia-tions be, formally evaluated and documented as Part 21 evalua-tions.
Paragraph 5.2 states, "If an item is reported to NRC under existing construction or operating plant reporting systems then'he reporting requirements of 10 CFR 21 have been fulfilled."
Figure 16.4-1 flow chart shows that a Part 21, evaluation is not required if an item has been evaluated and found to be reportable under other existing plant reporting systems.
FPSL representatives informed the -inspectors that our conclusions regarding QP-16.4 were correct.
The inspectors informed FP&I representatives that QP-16.4 does not provide:
1.) the necessary guidance and evaluation criteria
I
-4-to assure that the evaluation of deviations will be performed as required by 21.21(a)(i);
2.) the necessary guidance regarding the informing of the responsible officer of defects and failures to comply relating to substantial safety hazards
[21.21(a)(2)];
the necessary guidance to assure that the written report will contain Part 21 required i'nformation [(21.21 (b)(3)]; the neces-sary guidance to assure that Part 21 record maintenance will be accomplished as required by 21.51.
This matter constitutes an item of noncompliance, No.
389/79-22-01-
CFR Part 21 procedures.
(2)
Implementation The inspectors held discussions with'ersonnel noted in Paragraph
.,1 above.
It could not be demonstrated that formal Part 21 evalua-tions were being performed and documented in all cases.
FPSL representatives informed the inspectors that actions were consistent with QA Procedure 16.4.
An FPGL Quality Assurance Department Audit, No. QAS-QAC-79-1, had been: performed recently in the area of 10 CFR 50.55(e)
and
CFR 21 compliance.
The inspectors were informed of the audit findings and, recommendations.
The inspectors noted that several FPSL audit findings indicated procedure deficiencies with regard to
CFR Part 21 requirements.
Discussions with responsible personnel revealed that audit findings and recommendations were preliminary pending further review of corrective actions.
d.
Program Review and Implementation-Operations I
'1)
Turkey Point 3 and
(a)
Program Review The inspectors reviewed the above controlling procedures as noted in paragraph 5:
b.2, b.9, b.12, b.l4, to verify that procedures or instructions have been established and address posting (21.6), evaluating deviations (21.21(a)),
informing the director (21.21(a)),
assuring that the director will inform the Commission (21.21(b)), assuring that procurement documents specify that provisions of 10 CFR Part 21 will apply when applicable (21.31),
maintenance of records (21.51(a)),
and disposition of records (21.21(b)).
The inspectors noted that QA Procedure 16.4, Paragraph 5.2 and Figure 16.4-1 do not require that all deviations be formally evaluated and documented as Part 21 evaluations.
Paragraph 5.2 states, "If an item is reported to NRC under existing Construction or operating plant reporting systems,
I, I
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then the reporting requirements of 10 CFR 21 have been fulfilled"., Figure 16.4-1 flow chart shows that if an item has been evaluated, and found to be reportable, under other existing plant reporting systems, a Part 21 evaluation is not required.
FPM representatives informed the inspectors that our con-clusions were correct.
The inspectors informed FPGL representatives that gP-16.4 does not provide:
(1) the necessary guidance and evaluation criteria to assure that evaluation of deviations will be performed as required by 21.21(a)(1);
(2) the necessary guidance regarding the informing of the responsible officer of defects and failure to comply relating to substantial safety hazards
[21.21(a)(2)]; the necessary guidance to assure that the written reports will contain the Part
required information [21.21(b)(3)]; the necessary guidance to assure that Part 21 record maintenance will be accomplished as required by 21.51.
This matter constitutes an item of noncompliance, Numbers 250/79-35-01 and 251/79-35-01,
CFR Part 21 procedures.
(b)
Implementation The inspectors held discussions with personnel noted in paragraph 1 above.
It could not be demonstrated that formal Part 21 evaluations were being performed and documented.
FPSL representatives informed the inspectors that their actions were consistent with QA Procedure 16.4.
(2)
St. Lucie
(a)
Program Review The inspectors reviewed the above noted controlling procedures in paragraph 5, b.2, b.l0 and b.l4 to verify that procedures or instructions have been established and address posting (21.6), evaluating deviations
[21.21(a)], informing the director [21.21(a)], assuring that the director will inform the Commission [21.21(b)], assuring that procurement documents specify that provisions of 10 CFR Part 21 will apply when applicable (21.31), maintenance of'ecords
[21.51(a)]
and disposition of records
[21.21(b)].
The inspectors comments regarding the inadequacy of ZPM.'s QA Procedure 16.4 and the item of nonconformance addressed
I
in paragraph 5.d(1)(a)
above are applicable to St. Iucie l.
The item of noncompliance number is 335/79-33-01,
CFR Part 21 procedures.
(b)
Implementation The inspectors comments in paragraph 5.d(l)(b) are applicable to St. Lucie also.
The inspectors determined that PAL personnel actions were consistent with QA Procedure 16.4.
See item of noncompliance addressed in paragraph 6.d(l)(a)
above.