IR 05000250/1982007
| ML20053B332 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/02/1982 |
| From: | Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20053B314 | List: |
| References | |
| 50-250-82-07, 50-250-82-7, 50-251-82-07, 50-251-82-7, NUDOCS 8205280298 | |
| Download: ML20053B332 (19) | |
Text
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[ aux UNITED STATES
NUCLEAR REGULATORY COMMISSION o
E REGION 11
101 MARIETTA ST., N.W., SulTE 3100 o,
[
ATLANTA, GEORGIA 30303
Report Nos. 50-250/82-07 and 50-251/82-07 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: Turkey Point 3 and 4 Docket Nos. 50-250 and 50-251 License Nos. DPR-31 and DPR-41 Inspection at Turkey Point site near Homestead, FL and the FP&L General Office in Miami, FL
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C. M. Upright, Se 1>nJfief Dat4 S(gned Engineering In ctio H ranch Division of Engineering and Technical Programs SUMMARY Inspection on March 1-5 and 8-12,1982 Areas Inspected This routine, unannounced inspection involved 172 inspector-hours on site and at the general offices in the areas of licensee action on previous enforcement matters; design changes and modifications; procedures; calibration; surveillance; maintenance; QA program review; audits; training; requalification training; organization and administration; review and audits; preparation for refueling; and licensee action on previously identified inspection items.
82052808981
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Results Of the 14 areas inspected, no violations or deviations were identified in 10 areas; 4 violations were found in 4 areas (Failure to include acceptance criteria in a maintenance procedure, paragraph 9.a; Failure to promptly correct conditions adverse to quality, paragraph 11.a; Failure to document Technical Specification reviews, paragraph 8; Failure of PNSC to meet Technical Specification require-ments, paragraph 15).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- K. Beatty, Training Supervisor
- R. Cook, QC Engineer
- R. Engimeier, Manager, QA
- T. Essinger, Assistant Manager QA, Turkey Point
- S. Feith, QA Operations Supervisor
- J. Ferrare, QA Operations R. Garrett, Security Supervisor
- J. Hays, Plant Manager, Nuclear
- P. Hughes, HP Supervisor
- D. Jones, QC Supervisor
- J. Labarraque, Technical Department Supervisor P. Lanning, Nuclear Plant Supervisor J. Lowman, Assistant Superintendent - Nuclear Maintenance
- J. Mendieta, Maintenance Supervisor - Nuclear R. Seay, I&C Planner Supervisor L. Thomas, Assistant Superintendent - Mechanical Maintenance
- R. Tucker, QA Engineer V. Wager, Operations Supervisor
- H. Yaeger, Site Manager Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personnel NRC Senior Resident Inspector
- R. Vogt-Lowell
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on March 12, 1982, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspection finding.
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3.
Licensee Action on Previous Inspection Findings The following terms are defined and used throughout this report:
Accepted QA Program Topical Quality Assurance Report FPLTQAR 1-76A, Revision 4 CNRB Company Nuclear Review Board CVCS Chemical Volume Control System DCTG Drawing Control Task Group I&C Instrumentation and Control ISI Inservice Inspection Program for Pumps and Valves PC/M Plant Change / Modification PNSC Plant Nuclear Safety Committee PORV Power Operated Relief Valve
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i PWO Plant Work Order QA Quality Assurance T/S Technical Specifications (Closed) Unresolved (250,251/81-09-06):
Perform Record Fire Protection Evaluation.
The inspector reviewed the results of six evaluations per-formed for storage of QA records within the company headquarters building.
Several of the areas where record storage deficiencies had been identified were inspected to verify satisfactory corrective action.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. One new unresolved item identified during this inspection is dis-cussed in paragraph 11.b.
5.
Design Changes and Modifications (37700, 37702)
References:
(a) TQR 3.0, Design Control, Revision 3 (b) TQR 11.0, Test Control, Revision 0 (c) TQR 15.0, Corrective Action, Revision 2 (d) QP 3.1, Evaluation of Contractor Design, Revision 2 (e) QP 3.2, Identification and Control of Design Interfaces, Revision 2 (f) QP 3.4, Plant Changes and Modifications for Operating Plants, Revision 4 (g) QP 3.6, Control of FPL Originated Design, Revision 3 (h) QP 6.4, FPL Drawing Control, Revision 1 (i) AP 0103.3, Control and Use of Jumpers and Disconnected Leads, Revised 5/81 (j) AP 0190.15, Plant Projects - Approval, Implementation and Regulatory Requirements, Revised 11/81 (k) AP 0190.17, Maintaining Records for Design Cycles, Revised 2/80
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The inspector reviewed the references listed to verify that they met requirements of the accepted QA Program.
The inspector verified the following aspects of the design change program:
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Procedures have been established for control of design and modification change requests
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Procedures and responsibilities for design control have been estab-lished
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Administrative controls for design document control have been estab-lished
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Administrat:,e controls assure that design changes are incorporated into plant procedures, operator training, and the updating of drawings
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Controls have been developed that define channels of communication between design and responsible organizations
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Administrative controls require that design documentation and records be collected and stored
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Controls require that implementation of approved design changes be in accordance with approved procedures
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Responsibility has been assigned for identifying post-modification testing requirements
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Controls require that post-modification testing be performed per approved test procedures and that the results be evaluated
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Responsibility and method for reporting design changes to the NRC in accordance with 10 CFR 50.59 has been identified.
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l Similar methods and controls were also verified for use of temporary modi-fications (jumpers and disconnected leads).
In order to verify implementa-tion of the program, the inspector reviewed six plant change / modifications against the procedural requirements.
Based on this review, no violations or deviations were identified.
6.
Procedures (42700)
References:
(a) Technical Specifications, Section 6.8, Procedures (b) ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants l
(c) TQR 5.0, Instructions, Procedures, and Drawings,
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Revision 1 l
(d) TQR 6.0, Document Control, Revision 1
(e) QP 5.1, Operating Plant Procedures, Revision 3 l
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(f) QP 6.2, Control of Documents Issued by Florida Power and Light Company, Revision 3-(g) Administrative Procedure 0109.1, Preparation, Revision, and Approval of Procedures, revised 12/81 (: ; Administrative Procedure 0109.3 On the Spot Changes to Procedures, revised 11/80 (1) Administrative Procedure 0109.6, Temporary Procedures, revised 4/79 (j) Administrative Procedure 0110.4, Plant Nuclear Safety Committee General Procedures, revised 9/81 (k) Administrative Procedure 0190.14, Document Control and Quality Assurance Records, revised 12/81 (1) Administrative Procedure 0190.19, Control of Maintenance on Nuclear Safety Related and Fire Protection Systems, revised 12/81 (m) Administrative Procedure 0190.22, Changes, Tests, and Experiments, revised 11/81 (n) Administrative Procedure 0190.70, Inspection of Main-tenance Activities on Nuclear Safety Related and Fire Protection Equipment, revised 8/80 The inspector conducted a review of selected plant procedures in accordance with guidance and requirements provided in references (a) through (n) to ascertain whether overall procedures were in accordance with regulatory requirements. The following criteria were used during this review:
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Required re/iew and approval of procedures and temporary changes had been performed
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Overall procedure content is consistent with the requirements of Technical Specifications and the Fi_nal Safety Analysis Report
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Records of changes in procedures are being maintained
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Safety reviews pursuant to 10 CFR 50.59 were performed
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The training department and operations personnel are informed of changes to procedures i'
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Administrative procedures were followed in the preparation and handling l
of procedures Procedure changes were made to reflect Technical Specification revi-
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sions.
The following procedures were reviewed:
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Administrative Procedures listed in references (g) through (n) above
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Operating-Procedure 0202.1, Reactor Startup - Cold Condition to Hot i
Shutdown Condition, revised 2/82
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Operating Procedure 0205.2, Reactor Shutdown - Hot Shutdown to Cold Shutdown Condition, revised,2/82
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Maintenance Procedure 0729, Safety Related Motor Operated Valve (MOV)
i Motor Maintenance, revised 1/81
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Maintenance Procedure 0734, Safety Related Supports / Restraints Removal j
and Replacement, revised 4/81
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Operating Procedure 1001.1, Filling and Venting the Reactor Coolant System, revised 2/82
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Operating Procedure 2140.1, CVCS - Charging Pump Operation,- dated revised 1/82
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Operating Procedure 3206.2, Residual Heat Removal System - Annual Test, revised 3/81
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Maintenance Procedure 3207.8, Residual Heat Removal Pump Motor -
l Overhaul and Maintenance, revised 4/80
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Operating Procedure 4004.1, Containment Spray Pumps - Periodic Test, revised 9/81
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Emergency Operating Procedure 20003 (E-3), Steam Generator Tube Rup-l ture, revised 2/82 i
j Based on this review, one inspector followup item was identified. During l
this review the inspector noted that temporary procedures as discussed in i
reference (1) were not being controlled as required by reference (b).
Discussion between the licensee and Region II personnel determined that NRC-i had verbally agreed to the method being used for temporary procedures.
l Since this method does not fully reflect the requlrements of reference (b),
the licensee committed to changing the mechanism fc - issue of temporary
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procedures by May 1, 1982, to reflect the same review and approval require-ments as permanent procedures.
This item will be tracked as an inspector
followup item (250,251/82-07-09) pending a subsequent review of this area.
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Calibration (56700)
References:
(a) Technical Specifications l
(b) QP 12.2., Calibration Control of Installed Plant Instru-
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mentation and Control Equipment, Revision 1 (c) MP 0731, Calibration of Mechanical Maintenance Depart-
ment Measuring and Test Equipment, dated 8/79
(d) AP 190.23, Electrical Department Instrument Calibration Program, dated 5/79 J
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(e) AP 190.26, Calibration Control of Installed Nuclear
Safety Related Instrumentation and Control Equipment, dated 2/80 (f) AP 190.27, Electrical Department Installed Instrument Calibration Program, dated 9/79
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(g) HP-18, Calibration of Portable Gamma Survey Instruments, dated 2/80
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i (h) OP 14004.1, Steam Generator Protection Channels, dated 6/80 (1) OP 14004.2, Reactor Coolant Flow Protection Channels -
Periodic Test, dated 3/81 l
(j) OP 14004.4, Pressurizer Pressure And Water Level
Protection Channels - Periodic Test, dated 3/81 l
(k) OP 14007.12, Reactor Coolant Flow Instrumentation
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Calibration During Refueling, dated 11/77 (1) OP 14007.17, Charging Flow - Instrumentation Calibra-tion During Refueling, dated 12/79
(m) OP 14007.18, Residual Heat Removal Pump Flow Instru-mentation Calibration, dated 9/80 (n) OP 14007.19, Boric Acid Tank Level Instrumentation Calibration During Refueling, dated 11/77 (o) OP 14007.22, Containment Pressure (Wide and Narrow j.
Range) Instrumentation Calibration During Refueling, dated 12/78 i
(p) OP 4104.2, Engineering Safeguards and Emergency Power i
Systems - Integrated Test, dated 2/81
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(q) OP 1804.1, Axial Flux, Rod Deviation and Rod Position
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Indicating System Monthly Test, dated 10/79 i
(r) MP 1007.3, Setting the Reactor Protection Undervoltage Time Delay Relays (UVTD), dated 4/80
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(s) OP 9604.1, D.C. System Periodic Test and Inspections,
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dated 9/79
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i The inspector reviewed references (b) through (s) and verified that-they met
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requirements of reference (a), the accepted QA Program, and ANSI N18.7-1972 as endorsed by that program. The inspector verified the following aspects
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of calibration activities:
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The frequency of calibration of selected instruments specified in the T/S has been met-
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Test documentation for completed calibrations included acceptance
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criteria, documentation was complete, approved procedures were used, j
and personnel were qualified to perform the calibration
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Procedures contain controls to assure that limiting conditions for j
operation are met during the calibration
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b Procedures contain controls to assure that calibrations will be to the
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required accuracy, as-found and as-lef t conditions will be recorded, and_ calibration equipment will be traceable to the National Bureau of Standards
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Procedures exist to calibrate safety-related instrumentation not
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specifically addressed by Technical Specifications.
To verify implementation of these aspects, the inspector reviewed the calibration of 15 safety and non-safety related instruments. The inspector
also reviewed the procedures used to calibrate these instruments.
Based on this review, no violations or deviations were identified.
8.
Surveillance (61700)
References:
(a) AP 0190.16, Scheduling and Surveillance of' Periodic Test
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and Checks Required by Technical Specifications, dated j
5/79
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(b) AP 0190.73, Quality Control Surveillance Program, dated
8/80
(c) AP 0209.1, Valve Exercising Procedure, dated 12/81 (d) AP 0190.28, Mechanical Test Control (Post Maintenance),
dated 4/81
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(e) OP 16001.2, Technical Specification Surveillance Requirements for Core Refueling, dated 1/82
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(f) OP 0204.2, Schedule of Periodic Tests, Checks, Cali-brations and Operating Evaluations, dated 2/82 (g) OP 0209.4, Inservice Testing - Valve Seat Leakage
Testing, dated 11/79 (h) OP 0209.3, Inservice Pump Testing Program Implementation Procedure for Auxiliary Feedwater Pumps, dated 12/81
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(i) OP 4004.1, Containment Spray Pumps - Periodic Test, dated 9/dl (j) OP 3104.1, Component Cooling Water System - Periodic
Test of Pumps, dated 12/81 (k) OP 4104.1, High Head Safety Injection System - Periodic Test, dated 1/82
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(1) OP 3404.2, Intake Cool _ing Water System - Periodic Test l
of Pumps, dated 1/82
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(m) OP 3204.1, Residual Heat Removal System - Periodic Test, dated 9/81
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The inspector reviewed the references listed and verified that they met I
requirements of the T/S and ANSI 18.7-1972 as endorsed by the accepted QA i
Program.
The inspector verified the following aspects of surveillance activities:
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That T/S related surveillance tests relating to various safety-related
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I systems are covered by approved procedures
That surveillance tests for systems identified by the licensee's ISI
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program are covered by approved procedures
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That procedures are prepared according to required format and include acceptance criteria and restoration to normal That technical content of procedures assures compliance with T/S and
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i ISI requirements
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That completed tests are reviewed as required, performed within time frames required, performed by qualified individuals, and appropriate action is taken for items failing acceptance criteria.
The inspector randomly selected 44 T/S surveillances, as well as several ISI surveillances and verified that they were incorporated into the surveillance program and performed at the required frequency. Selected surveillances were reviewed 'to verify that data met acceptance criteria and that each
j had been reviewed as required by the licensee's controlling procedures.
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Based on this review, one violation was identified. Technical Specification
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Table 4.1-1, items 29 and 31, require monthly checks to be performed on the t
PORV and pressurizer safety valve position indicators.
These checks are performed by control room personnel, but are not documented. This failure
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to document checks required by T/S is contrary to 10 CFR 50, Appendix B,
Criterion XVII and is identifud as a violation (250,251/82-07-03).
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9.
Maintenance (62700)
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References:
(a) TQR 5.0, Instructions, Procedures and Drawings, Revi-
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sion 1
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(b) TQR 10.0, Inspection, Revision 3 (c) QP 5.1, Operating Plant Procedures, Revision 3
(d) AP 0103.4, In Plant Equipment Clearance Orders, Revised 10/81
(e) AP 0109.1, Preparation, Review and Approval of Proce-dures, Revised 12/81 i
(f) AP 0110.4, Plant Nuclear Safety Committee General Procedures, Revised 9/81 (g) AP 0190.12, Nonconforming Material Parts, or Components, Revised 6/81 i
(h) AP 0190.13, Corrective Action for Conditions Adverse to Quality, Revised 9/81
(i) AP 0190.19, Control of Maintenance on Nuclear Safety
Related and Fire Protection Systems, Revised 12/81
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(j) AP 0190.28, Mechanical Test Control (Post Maintenance),
Revised 4/81
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(k) AP 0190.70, Inspection of Maintenance Activities on Nuclear Safety Related and Fire Protection Equipment, Revised 8/80 (1) MP 0720, Preventative Maintenance Program - Mechanical, Revised 2/79 The inspector reviewed maintenance activitis on safety-related systems and components to ascertain whether the activities were conducted in accordance with approved procedures, regulatory guides, and industry cedes and in conformance with Technical Specification requirements.
The following criteria were used during this review.
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. Required administrative approvals were obtained prior to initiating the work
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Limiting conditions for operation were met while components were removed from service
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Approved procedures were used where the activity appeared to be beyond the normal skills of the craf t
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Activity was accomplished by qualified personnel The licensee had evaluated system failures and reported them in accord-
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Written procedures were established for initiating requests for routine and emergency maintenance
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Criteria and responsibilities for review and approval of maintenance requests were established
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Criteria and responsibilities that form the basis for designating the activity as safety or non-safety related were established
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Criteria and responsibilities were designated for performing _ work inspection of maintenance activities
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Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activities
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Methods and responsibilities were designated for performing functional testing of structures, systems, or components following maintenance work and/or prior to their being returned to service.
Ten PW0s were reviewed to verify implementation of the previously stated requirements. The PW0s were in the areas of reactivity control and reactor flux distribution, instrumentation, the reactor coolant system, emergency core cooling systems, plant and electrical power systems, and containment systems. Specifically, the following PW0s were reviewed:
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PWO-UNIT SUBJECT 2614
Pressurizer Safety Valve Inspection 2615
Pressurizer Safety Valve Inspection 2616
Pressurizer Safety Valve Inspection 2570
Containment Spray Valve Repair 2801
Pressurizer Piping Repair 7197
Repair ISI Valve CV-3-200C 8152
Power Range Meter Repair 8126
Repair Intermediate NIS 7716
PORV Activator Maintenance Based on this review, one violation and one inspector followup. item were identified and are discussed in the following paragraphs:
a.
Failure to Include Acceptance Criteria in a Maintenance Procedure During the review of PW0s 2614, 2615, and 2616, the inspector noted.
that the implementing procedure MP 1207-1, Pressurizer Safety. Valve Repair and Setting, revised 12/81, did not contain quantitative accept-ance criteria for torquing the inlet and outlet flange bolts. Research through previous procedural changes revealed that the original proce-dure required that the bolts be tightened in accordance with the manu-facturer's recommended torque value. A subsequent change reviewed by the PNSC and approved in July 1978, changed the torque requirements so that accessible bolts were tightened per the manufacturer's procedure but those remaining were tightened "by the best means available". This partial removal of specific torque values without providing a quantita-tive equivalent was accomplished without any apparent technical review.
A second change reviewed by the PNSC and approved in December 1981.was implemented due to the potential for leakage from the unequal torquing'
of the flange bolts.
This change eliminated all quantitative torque
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j values and replaced them with "Tiohten flange bolts to obtain even i
compression of gasket" and for the inlet flange, to verify outside l
face parallelism.
In both changes, the PNSC review required by
Technical Specification 6.5.1.6 was inadequate in that the review I
did not identify that the quantitative acceptance criteria required'
i by 10 CFR 50, Appendix B, Criterion V and the accepted QA Program, l
TQR 5.0, was removed with no equivalent replacement. This inadequate i
review by the PNSC and use of a procedure with inadequate quantitative l
acceptance criteria is identified as a violation- (250,251/82-07-01).
After the identification of this problem, an equivalent tightening
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process was developed to show that using a 3/4" impact wrench would not overstress the bolts.
The inspector was informed that the use of a specific size impact wrench would be included as an alternative j
acceptance criteria.
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Safety Related Valve Identification While reviewing PWO 7197, which repaired CVCS solenoid operated let-down valve CV-3-200C, the inspector noted that although the valve was identified in reference (j) as part of the site ISI program for valves and as such was declared nuclear safety related. the PWO was identified and worked as non-safety related. Interviews with the I&C planner and several QC inspectors revealed that, as this section of the CVCS is not specifically addressed on the "Q" list, any work on the valve would be considered as non-safety related. An interview with the ISI lead engineer identified that this valve had been rese' arched and found to be safety related and placed in the ISI program.
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This failure to document clearly the boundaries of a safety related system as required by QP 2.7, Identification of Safety-Related Struc-
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tures, Systems and Components, is another example of.a violation previously identified in inspection report numbers 250.and 251/81-29.
The licensee response to item 250,251/81-29-01, states that a more precise
"Q" list will be issued by June 1982 which should correct
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this problem.
For tracking purposes, this item is identified as an inspector followup item (250,251/82-07-06).
10.
QA Program Annual Review (35701)
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Reference:
(a) Accepted QA Program
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The inspector reviewed the procedures referenced throughout this report and verified they met the requirements of reference (a). The inspector verified by direct questioning that licensee personnel understood the significance of
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recent changes to reference (a). The inspector also verified that a system exists for informing personnel of new and existing regulatory requirements.
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Based on this review, no violations or deviations were idhntified.
11.
Audits, Audit Implementation (40702 and 40704)
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i References:
(a) QP 2.5, Quality Assurance Indoctrination \\a a Training, l
Revision 3
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i (b) QP 2.9, Qualification of QA Audit, QC Inspection, and Construction Test Personnel, Revision 4
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(c) QP 16.1, Corrective Action, Revision 5
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(d) QP 18.1, Conduct of Quality Assurance Department Quality
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Assurance Audits, Revision 5 lj
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(e) QI 2 QAD 1, Recording of Personnel Indocuination and i
j Training, Revision 4 i
(f) QI 16 QAD 4, Corrective Action Followup' for QA Depart-
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ment Open Items, Revision 5 (g) QI 18, QAD 2, Auditing of the Quality Assurance Com-mittee Company Nuclear Review Board and the Quality
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Assurance Department, Revision 0
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12 (h) QI 18 QAD 3, Scheduling of Quality Assurance Department Audit Activities, Revision 0 (i) QP 16.4 Evaluating and Reporting of Defects and Non-compliances for Substantial Safety Hazards in Accordance With 10 CFR Part 21, Revision 3 (j) AP 0190.13 Corrective Action for Conditions Adverse to Quality, dated 12/81 The inspector reviewed the references listed and verified that they met requirements of the accepted QA Program and ANSI N45.2.12 as endorsed by that program.
The inspector verifed the following aspects of-the audits and audit implementation program:
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Methods have been defined for taking corrective action when deficien-cies are identified during audits The audited organization is required to respond in writing to audit
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findings
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Distribution requirements for audit reports and corrective action responses have been defined
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Checklists are required to be used in the performance of audits
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Audits are conducted by trained personnel not having direct respon-sibility in the area being audited
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The frequency of audits is in conformance with' Technical Specification requirements
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The scope of the audit program has been defined and is consistent with the Technical Specifications Responsibilities have been assigned in writing for the overall manage-
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ment of the audit program.
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t To verify implementation of these aspects, the inspector reviewed the results of 28 activity and management audits conducted' during 1981
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(QAO-PTP-81-327 through 354).
The inspector also reviewed the qualifi-cations of seven lead auditors.
d, Based on this review, one violation, one unresolved item, and one 1 concern were identified and are discussed in the following paragraphs,nspector '
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a.
Failure to Promptly Correct Conditions Adverse to Quality
,1 Audit QA0-PTP-81-01-328, conducted January 1,1981, identified as a -
finding the failure to meet an NRC commitment in a timely manner regarding inaudibility of alarms as identified in IE Bulletin 79-18.
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Audit QA0-PTP-81-07-354 conducted July 21-29, 1981, identified three findings relative to completion of corrective action (finding II),
delayed responses to NCRs (finding III), and effectiveness of the corrective action system (finding IV). All of these items.from both audits were brought to management's attention October 20, 1981 (letter QA0-PTP-81-094).
At the time of this inspection, these items were still outstanding.
This failure to promptly correct problems adverse to quality is a violation (250,251/82-07-02),
b.
Corrective Action System Audit QA0-PTP-SI-07-354 identified five finding; specifically related to the licensee's corrective action system.
The audit report addi-
, tionally identified, on more general terms, that none of the areas
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examined during the course of the audit were found to be completely
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satisfactory and the system for tracking and assuring completion of corrective action is seen as neither effectively nor adequately imple-menting the QA Program. The corrective action program was brought to the attention of the QA Committee on February 4,1982, where many of.
the problems associated with the corrective action were presented. The proposed followup was that the corrective action recommendations are currently under study by the plant.
Until this study is completed and the corrective action system is strengthened and reinspected by the NRC, this item is unresolved (250,251/82-07-05).
c.
Incorrect Reference in QP 18.1 Reference (d), Section 5.1 refers to QP 18.2, Scheduling of Quality Assurance Department Audit Activities.
_ P 18.2 has been deleted.
Q Until the next revision of reference (d) is made and this procedure is deleted as a reference, this is identified as an inspector concern.
12. Non-Licensed Personnel Training (41700)
References:
(a) Technical Specifications, Section 6.4, Training
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(b) ANSI N18.1-1971, Selection and Training of Nuclear Power
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Plant Personnel (c) QP 2.5, Quality Assurance Indoctrinatior ar'i %ining, Revision 3 (d) QP 2.9, Qualification of QA Audit, QC Inspec is..
and Construction Test Personnel, Revision 4 (e) Administrative Procedure 0190.71, Qualification of Quality Control Inspectors, dated 10/81 (f) Administrative Procedure 0303, Non-licensed Operator Training and Retraining Program, dated 2/82 (g) Administrative Procedure 0304, Plant Training, dated-8/81 (h) Administrative Procedure 0306, New Employee Indoctrin-ation and Orientation, dated 11/81
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(i) Administrative Procedure 0307, Shift Technical Advisor Training Program, dated 6/81 (j) Security Procedure 0402, Personnel / Material Access Control, dated 4/81 (k)
Security Procedure 0403, Employee Security Orientation Program, dated 4/81 (1) Health Physics Procedure HP-81, Health Physics Training, dated 10/80 The inspector reviewed the training program which provides the required training for the facility staff personnel.
This program was reviewed to verify that:
the program complies with requirements contained in refer-ences (a) through (1) above; the program covers training in the areas of administrative controls and procedures, radiological health and safety, industrial safety, security procedures, emergency plan and quality assur-ance training, and pre-natal radiation exposure training for females; non-licensed operators are trained in functions which they perform; related technical and on-the-job training are provided to applicable personnel where required.
Based on this inspection, two inspector followup items were identified as discussed in paragraph 12.a and b.
Although these two problems were identified, the training program at this facility appears to be a very well planned and executed program which can provide personnel with required training and can maintain and develop the desired levels of proficiency required to safely operate and maintain the plant a.
Lack of System to Provide Retraining to Contractor Personnel Reference (b) requires that general employee training and retraining be provided to all personnel including temporary maintenance and service personnel. At present there is no system to assure that contractor personnel are trained and retrained in QA/QC requirements as required by reference (b). A program is currently under development to detail the retraining to be provided to personnel and putting this function under the auspices of the training department (with possibly the exception of Health Physics retraining).
The licensee committed to considering placing contractor personnel into this program.
This program will be issued by July 1, 1982.
No examples were observed where contractor personnel had not received QA/QC training required by reference (b). This item will be tracked as an inspector followup item (250,251/82-07-07) pending issue of the program implementing procedure and subsequent review of this area.
b.
Clarification of Grace Period for HP Requalification Training Reference (1) requires retraining in health physics to be performed every two years and provides a grace period of 25% at the discretion of the Health Physics Supervisor.
It appears that the 25% has become common use rather than an exception as was intended. The licensee
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15 agreed to schedule this training at two year intervals. This item will be tracked as an inspector followup (250,251/82-07-08) pending a review of this area during a subsequent inspection.
13.
Licensed Operator Requalification Training (41701)
References:
(a)
10 CFR 55, Operator's Licenses (b) QP 2.5, Quality Assurance Indoctrination and Training, Revision 3 (c) Technical Specifications, Section 6.3, Facility Staff Qualifications (d) Technical Specifications, Section 6.4, Training (e) Administrative Procedure 0301, Licensed Operator Requalification Program, dated 8/81 The inspector reviewed the Operator Requalification Program as described in references (a) through (e). The following areas were reviewed: retraining conducted in 1931; annual written examinations and the individual's respon-ses; documentation of attendance at requalification lectures; documentation of required control manipulations; and records of eight licensed operators.
Based on this review, no violations or deviations were identified.
14.
Organization and Administration (36700)
References:
(a) Technical Specifications (b) Accepted QA Program (c) AP 0103.9, Facility Staff Qualifications, dated 4/79 (d) AP 0190.1, Quality Assurance and Quality Control Program and Organization at Turkey Point, dated 8/80 The inspector reviewed references (b) through (d) and verified that they met requirements of reference (a) in the area of personnel qualification levels and lines of authority.
The inspector reviewed the qualifications of 28 plant personnel at various positions of authority.
Based on this review, no violations or deviations were identified.
15.
Onsite Review Committee (40700)
References:
(a) Technical Specifications (b) AP 0110.4, Plant Nuclear Safety Committee General Procedures, dated 9/81 (c) AP 0103.7, Reports Required by Technical Specifications and 10 CFR, dated 6/80
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The inspector reviewed references (b) and (c) to assure that they met requirements of reference (a)
and ANSI N18.7-1972 as endorsed by the accepted QA Program. The inspector reviewed PNSC meeting minutes for 1981 (81-01 through 81-88) and verified T/S requirements relative to meeting frequency, membership, review process, and qualifications of personnel.
Based on this review, one violation was identified. Technical Specifica-tions 6.5.1.3 and 6.5.1.5 delineate PNSC requirements relative to appoint-ment of alternates and quorum requirements. During a review of PNSC meeting minutes 81-44, the inspector identified that one alternate used to meet the quorum requirement was not approved for the person he was substituting for at this meeting.
During a review of PNSC minutes 81-88 the inspector identified that only four members were present.
The T/S requires five members to be present for a quorum. This failure to use approved alternates and not meeting quorum requirements is identified as violation (250,251/
82-07-04).
16.
Review of Cleanliness Prior to Refueling (92706)
Turkey Point 3 was preparing for refueling activities during this inspec-tion.
Prior to lif ting the reactor vessel head, the fuel transfer canal area and refueling deck area were inspected for cleanliness conditions. The inspector performed another walk-through of the same areas to observe cleanliness controls that had been established af ter the reactor vessel head was lif ted.
Based on this review, no violations or deviations were ideni.ified.
17.
Licensee Action on Previously Identified Inspection Items (92701)
a.
(0 pen) Open Item (250,251/81-09-08):
Conflicting Procedure Require-ments In AP 0304.
This procedure has not been changed due to an agreenent between FP&L management and the union representing the maintenance personnel. To resolve this apparent conflict, a' procedure is being generated to develop a program that will require industrial
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safety training to be given as part of the retraining program.
See additional discussion in paragraph 12.a. of this report.
b.
(0 pen) Open Item (250,251/81-09-11): Conduct Study To Widen Scope Of Shelf Life Program. A study has been completed and a program initiated at the St. Lucie site.
A new target date of May 1,1982, for imple-l mentation at the Turkey Point site was provided by the licensee.
The program implementation will be reviewed during a subsequent inspection.
c.
(Closed) Open Item (250,251/81-09-12):
Clarify Use Of Controlled Drawings To Plant Personnel. The inspector reviewed AP 0103.10, Using Plant Drawings, dated 5/81 and identified that instructions have been developed to assure that plant personnel are aware of the potential for plant drawings not being accurate.
This procedure also delineates action to be taken by personnel if they find inaccurate drawings.
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(Closed) Inspector Followup Item (250,251/81-09-13):
CNRB Personnel Titles Not Consistent With Technical Specifications.
The inspector reviewed the current membership of the CNRB. CNRB meeting minutes 205, conducted February 5, 1982, unanimously approved changes to the Turkey
Point T/S for the administrative offsite organization. A proposed T/S
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change was submitted to the NRC in February 16, 1982, reflecting these changes.
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e.
(Closed) Inspector Followup Item (250,251/81-09'14): Storage Of Items At Construction Warehouse.
The inspector toured the construction
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warehouse area and determined that items are being properly stored for environmental protection.
Outdoor storage is limited to only those items authorized under the QA Program.
f.
(Closed) Inspector Followup Item (250,251/81-09-15): Maintenance Of
Training Records. A review of training records of selected personnel
receiving training since October 1980 identified that all personnel had a training record either in the document centrol system, the Health Physics Training file, or the individual's department supervisors'
training files.
g.
(Closed) Inspector Followup Item (250,251/81-09-16):
Provide Annual i
Report To NRC.
The inspector reviewed audit QAO-PTP-80-10-314 conducted November 10, 1980. This audit identified as a finding that no annual report relative to design changes had been sent to the NRC.
The corrective action for this item was successfully completed May 28, 1981, and the finding was closed.
h.
(Closed) Inspector Followup Item (250,251/81-09-17): Conduct Of Ad-Hoc
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Subcommittee Reporting To CNRB. The inspector interviewed the secre-tary of the CNRB.
It was identified during this interview that a standing committee had been formed to review such things as NRC Inspection Reports, responses to these reports, PNSC meeting minutes,.
i LER's and PC/M safety evaluations. After their review, this committee makes a formal presentation to the CNRB.
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(Closed) Inspector Followup Item (250,251/81-09-18):
Drawing Control j
Task Group And Annotating PC/M Changes To Drawings.
The inspector
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reviewed audit QAE-1DA-80-2, QA audit of drawings, conducted July 24, 1980. The DCTG formulated to correct drawing problems as the result of this audit have been actively pursuing resolution for updating plant drawings. Meetings by the DCTG on September 18, 1981, and October 8,
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1981, identified and reaffirmed that operator / training drawings had been totally updated.
These drawings are used by the operations l
department for daily plant operations. Other drawings less critical in
nature are in process of being updated. QA has developed but not
finalized or issued QP 16.6, Drawing Control for Operating Nuclear
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Power Plants. Once issued, this procedure delineates drawing control.
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(Closed) Inspector Followup Item (250,25i/81-09-19):
Use Of Jumpers And Disconnected Leads, Audit QAO-PTP-81-03-340.
The inspector reviewed audit QAO-PTP-81-03-340 in which three findings (unsatis-factory conditions) were identified.
Two of the findings involved failure of the technical department to perform periodic reviews of the temporary jumper / lifted lead log and unauthorized use of temporary jumpers to effect permanent plant changes.
This audit was conducted April 6-27, 1981.
The audited organization's response to these findings was in a memo from D. Jones to T. Essinger dated May 26, 1981.
Successful corrective action for the finding was completed June 15, 1981.
k.
(Closed) Inspector Followup Item (250,251/81-09-20): Waiver Of Source Surveillance.
The inspector reviewed QI 7 QA0 4, Supplier Annual Review, Revision 4.
Section 4.4 allows the QAP scheduler to track surveillance activities or to waive and document surveillance acti-vities.
The inspector reviewed the waivers for five vendors (QAP-82-051, 048, 080, 248, and 230) and identified that adequate justi-fication had been provided to allow the waiver of source surveillances.
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18.
List of Findings of Inspectior Reports 50-250.251/82-07 Item Numbers Item Report 250/82-07,251/82-07-Description Location Violations
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01 Failure to Include Acceptance Criteria 9.a
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In a Maintenance Procedure I
02 Failure to Promptly Correct Conditions 11.a Adverse to Quality
03 Failure to Document Technical Specification
Reviews
Da Failure of PNSC to Meet Technical Specifi-
cation Requirements Unresolved Items
05 Corrective Action Systen.
11.b Inspector Followup Items
06 Safety Related Valve Identification 9.b
07 Lack of System to Provide Retraining 12.a to Contractor Personnel
08 Clarification of Grace Period for HP 12.b Requalification Training
09 Revision of Control Issue of Temporary
Procedures Concern Incorrect Reference In QP 18.1 11.c
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