IR 05000250/1979035
| ML17266A148 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 12/19/1979 |
| From: | Brownlee V, Burdette T, Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17207A853 | List: |
| References | |
| 50-250-79-35, 50-251-79-35, 50-335-79-33, 50-389-79-22, NUDOCS 8002280189 | |
| Download: ML17266A148 (13) | |
Text
~R REay
~4
~o O
I 4'~
'O
++*++
UNITEDSTATES NUCLEAR REGULATORY COMMISSION
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 II License Nos.
DPR-31, DPR-41, DPR-67 and CPPR-144 Insp'ection at St. Iucie Units 1 and 2, and Florida Power and.Light Company's General Offices Inspectors:
V. L.
ownlee K
T. E. Burdette Approved by:
.
M
, Chip RCSES Branch SUMMARY Inspection on November 27-30, 1979 Areas Inspected Dat Si:gned
/2, / c/ 74 Date Signed Date igned This routin'e, unannounced inspection involved 44 inspector-hours onsite and at the General Office in review of procedures and controls adopted by Florida Power and Light, (FPSL) 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
'I I
I
\\
k
DETAILS 1.
Persons Contacted-Licensee Employees
%%R.
B.
Ma~A
"R.
"N.
AD-T.
%J
%F AD, W.
E.
N.
~JR.
E. Uhrig, Vice President, Advanced Systems 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 W. Sherman, QA Engineer G. Roos, Acting QC Supervisor J.
Spooner, Construction QC 8 Technology-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 November 30, 1979, with those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings Not inspected.
I C
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Compliance with 10 CFR Part 21 and
CFR 50.55(e)
a ~
General The purpose of this inspection was to ascertain whether FPK 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
FPM '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.
Lucie 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 implementa'tion were examined and evaluated on November 29-30, 1979, at the Miami General Office.'art 21 requires that each organization, such as FPSL, that constructs, owns or operates a facility which involves "basic components" as defined under Part 21 is subject to its regulations.
FPGL and its responsible officers must therefore ensure compliance with requirements of-Part 21 as specified in Section 21 '
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's a result of this inspection, the inspectors indentified one (1)
item of noncompliance discussed in paragraphs 5.c and 5.d below.
b.
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 Assurance Manual Procedure No.
QP 16.6, Rev. 0, August 16, 1976, Reporting of 10 CFR 50.55(e) Deficiencies (4)
(5)
St. Lucie Procedures Manual Procedure No. SQP-21, Rev.
0, April 20, 1979, Site Quality Procedure Corrective Actions.
I Nonconformance Report 894c and associated
CFR 55(e) review documents.
(6)
Noncompliance reports, relating to CBSI derrick failure and associ-ated
CFR 50.55(e)
review documents.
(7)
Nonconformance Report 895E and associated
CFP. 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 I
(9)
(10)
Turkey Point 3 and 4 Administrative Procedure 0103.6, July 7, 1978, Reportable Occurrences St. Iucie Plant Administrative 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.
(12)
Turkey Point Units 3 and 4 Administrative Procedure 0190.21, May 29, 1979, Nuclear Safety Hazard-Identification (13)
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.
(15)
Quality Assurance Procedure No.
QP 4.4, Review of Requisition on Purchasing Agent for Items and Services Other than Spare Parts.
(16)
Power Plant Engineering Department Quality Instruction QI 16-EPP-9, Rev.
0, Identification and Correction of Discrepant or Deficient Conditions Rel'ated 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'owever, the inspectors noted that QA Procedure, QP-16.4, paragraph 5.2 and figure 16.4-1 do not require thatall 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 the 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".
FPK representatives informed the inspectors that our conclusions regarding QP-16.4 were correct.
The inspectors informed FPSL representatives that QP-16.4 does not provide:
1.) the necessary guidance and evaluation criteria
L
-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 information [(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 personnel noted in Paragraph 1 above.
It could not be demonstrated that formal Part 21 evalua-tions were being performed and documented in all cases.
FPGL 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 FPGI, 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
'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.14, 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,
r~
E ~
C l
A'
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 FPM representatives that QP-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)(l);
(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
evaluations'ere 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.10 and b.14 to verify that procedures or instructions have been established and addres's 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 comments regarding the inadequacy of FPSL's QA Procedure 16.4 and the item of nonconformance addressed
-6-in paragraph 5.d(l)(a) above are applicable to St. Lucie 1.
The item of noncompliance number is 335/79-33-01,
CFR Part 21 procedures.
(b)
Implementation The inspectors comments in paragraph S.d(1)(b) are applicable to St. Lucie also.
The inspectors determined that FPSL personnel actions were consistent with QA Procedure 16.4.
See item of noncompliance addressed in paragraph 6.d(1)(a)
above.