IR 05000250/1985015
| ML17346B107 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/24/1985 |
| From: | Belisle G, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17346B106 | List: |
| References | |
| 50-250-85-15, 50-251-85-15, NUDOCS 8507010323 | |
| Download: ML17346B107 (25) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-250/85-15 and 50-251/85-15 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point 3 and
License Nos.:
DPR-31 and DPR-41 Inspection Conducted:
April 29 May 3, 1985 Inspector:
G. A. Belisle D te S gned Accompanying Personnel:
J.
H. Moorman, III, Region II M. A. Scott, Re ion II Approved by:
C.
M. Upright, cti Chief Division of R
ctor afety D te gned SUMMARY Scope:
This routine, unannounced inspection entailed 96 inspector-hours on site in the areas of licensee action on previous enforcement matter s, QA program, audits, records, document control, and licensee action on previously identified inspection findings.
Results:
No violations or deviations were identified.
85070i0323 850529 PDR ADQCK 05000250
lt W
I III
REPORT DETAILS Persons Contacted Licensee Employees
"J. Arias, Jr.,
Regulation and Compliance Supervisor
"C. Baker, Plant Manager
"W. Bladow, Quality Assurance (QA) Supervisor M. Costa, Production Supervisor T. Coste, Projects QA Engineer
"M. Crisler, Quality Control (QC) Supervisor
"T. Donis, Site Engineering Supervisor R. Farasch, QA Engineer J. Ferrare, QA Engineer T. Finn, Operations Supervisor L. Hayes, Shift Technician
"K. Jones, Technical Department Supervisor
"J. Labarraque, Technical Consultant C. Norris, Nuclear Energy Coordinator G.
Rhodes, Assistant Plant Technician R. Skiner, Mechanical Maintenance
- F~ Southworth, Technical Advisor R. Stone, QA Engineer
- M. Tagliamonte, Senior Engineer
~R. Teuteberg, Regulatory and Compliance Engineer
"J. Vessely, Director, QA N. Weems, QA Superintendent, St.
Lucie
~C. Wethy, Site Vice President Other licensee employees contacted included engineers, technicians, and office personnel.
NRC Resident Inspectors
"T. Peebles, Senior Resident Inspector
"R. Brewer, Resident Inspector
~Attended exit interview Exit Interview
.The inspection scope and findings were summarized on May 3, 1985, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio V t
3.
Licensee Action on Previous Enforcement Matters a ~
(Closed)
Severity Level V Violation (250/84-33-02, 251/84-34-02):
Maintenance of Reactor Trip Records b.
The licensee response dated January 7,
1985, was considered acceptable by Region II.
The inspector reviewed administrative procedure (AP)
0103. 16, Duties and Responsibilities of the Shift Technical Advisor (STA), which was revised on December 19, 1985, in response to this violation.
Section 7 '
was revised to designate the STA Report of Plant Abnormal Occur rences as a quality assurance record which will be retained in accordance with AP 0190. 14, Document Control and guality Assurance Records.
The inspector verified that STAs understand to route the original post-trip review to the Nuclear Operations Super-visor for review and signature.
The inspector also verified that post-trip reviews and the STA Report of Plant Abnormal Occurrences were being forwarded to the plant records vault in a timely manner.
The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems.
Corrective actions stated in the licensee response have been implemented.
(Closed)
Severity Level IV Violation (250/84-41-01, 251/84-42-01):
Failure to Establish Measures for Removing Uncalibrated Instruments From Service The licensee response dated March 18, 1985, was considered acceptable by Region II.
The inspector reviewed AP 0190.9, Control of Measuring and Test Equipment (M&TE),
and maintenance procedure (MP)
0731, Calibration of Mechanical Maintenance Department Measuring and Test Equipment, which were revised December 19, 1984, and March 20, 1985, respectively, in response to the violation.
Section 8.5.1 of AP 0190.9 was revised to delineate controls for the removal of measuring and test instrumentation from service which are past due calibration or are found to exceed required calibration tolerances.
Section 9.7. 1 was added to MP 0731 to address the removal of measuring and test instru-mentation from service when no longer within required calibration tolerances.
Sections 9.7.2 and 9.7.3 were added to delineate controls when instrumentation cannot be repaired or recalibrated and document retention requirements for instrumentation permanently removed from service.
Site gA personnel were auditing the M&TE 'rea and a
100 percent review. of mechanical, M&TE for out-of-tolerance -conditions and subsequent evaluation was being conducted.
The inspector concluded that the licensee had determined the full extent of the specific violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems.
Corrective actions stated in the licensee response have been imple-mented,
4.
QA Program Review (35701)
Reference:
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The inspector reviewed the licensee QA program required by the above reference and verified that these activities were conducted in accordance with regulatory requirements.
The following criteria were used during this review to assess overall acceptability of the established program:
Personnel responsible for preparing implementing procedures understand the significance of changes to these procedures.
Licensee procedures are in conformance with the QA program.
The procedures discussed throughout this report were reviewed to verify conformance with the QA program.
Discussions were conducted between FP&L personnel and NRC representatives on January 13, February 17, and April 11, 1984, pertaining to improvements being made by FP&L personnel for nuclear plant operations.
Confirmatory Order EA-84-55 was issued to FP&L on July 13, 1984.
This order reiterated Turkey Point Performance Enhancement Program (PEP)
commitments outlined in correspondence from FP&L to the NRC on April 11, 1984.
Certain commitments impacted existing QA activities.
The inspector interviewed QA and QC personnel as to progress of these commitments.
The inspector was informed of'the following:
Increased QA and QC staff size Increased QA personnel training Increased QA technical expertise (two recently 'hired QA personnel were licensed operators)
Improved communication between QA and site personnel Modification in QA reporting structure Appointment of a new QC supervisor Appointment of a new QA site manager Expanded QA and QC surveillance programs QA is also performing audits to assure that PEP commitments are being me l'
The inspector discussed QA program implementation and other topics with QA personnel.
The inspector reviewed general onsite QA program implementation as a part of the inspection.
Each specific area is detailed in other paragraphs of this report.
Problem areas, if identified, are detailed in the specific area inspected.
Mithin this area, no violations or deviations were identified.
5.
Audits (40702 and 40704)
References:
(a)
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and Fuel Reprocessing Plants (b)
Regulatory Guide 1. 144, Auditing of Quality Assurance Programs for Nuclear Power Plants (c)
ANSI N45.2. 12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants (d)
Regulatory Guide.
1. 146, Qualification of Quality Assurance Programs.for Nuclear Power Plants
.
(e)
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (f)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
(g)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (h)
Technical Specifications, Section
The inspector reviewed the licensee audit program required by references (a)
through (h) to verify that the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during this review to determine the overall acceptability of the established program:
The audit program scope was defined consistent with Technical Speci-fications and QA program requirements.
Responsibilities were assigned in writing for overall management of the audit program.
methods were defined for taking corrective action on deficiencies identified during audits.
The audited organization was required to respond in writing to audit finding Distribution requirements were defined for audit reports and corrective action responses.
Checklists were required to be used in performing audits.
Measures were established to assure that QA audit personnel met minimum education, experience, and qualification requirements for the audited activity.
The documents listed below were reviewed to verify that these criteria had been incorporated into the auditing program:
FP L-NQA-100A QP 2.5 Topical Quality Assurance Report, Revision
Quality Assurance Indoctrination and Training, Revision
QP 2.9 Qualification of QA Audit, QC Inspection and Construction Test Personnel, Revision
QP 16.1-QP 18.1 Corrective Action, Revision
Conduct of Quality Assurance Department Quality Audits, Revision
QP 2.2 Revision of the Topical Quality Assurance Report, Revision
QP 2.3 QP 2.4 Quality Assurance Program Review, Revision
Preparation and Revision of, Quality Instructions, Revision
QP 2.7 Identification of Safety-Related and Nuclear Nonsafety-Related QA Required Structures, Systems, Components and Services, Revision
QI2 QAD 4 QI2 QAD 6 QI9 QAD
Preparation and Revision of QAD QIs, Revision
Control of the QA and QI Manual, Revision
Personnel Qual ificati on and Certi ficati on in Nondestructive Testing in Accordance with SNT-TC-lA, Revision
QI16 QAD 3 QI16 QAD 4 Controlling Contractor/Supplier Audit Open Items, Revision
Corrective Action Follow-up for Quality Assurance Audits, Revision
'
QI16 QAD 6 QI18 QAD 2 QI18 QAD 3 Turkey Point Construction Quality Assurance Survei llances, Revision
Auditing of the Quality Assurance Committee, Company Nuclear Review Board, and the Quality Assurance Department, Revision
Scheduling of Quality Assurance Department Audit Activities, Revision
AP 0190.13 Corrective Action for Conditions Adverse to Quality, dated August 2, 1984 The inspector also reviewed the following additional documents relating to QA and auditing activities:
Quality Assurance Operations Open Item Tracking Status, dated April 30, 1985 Interoffice Correspondence QAO-PTP-84-519, Subject:
Semi-Annual Review of Corrective Action Status for Turkey Point Plant, dated December 10, 1984 Quality Assurance Monthly Reports, December 1984, January 1985, February 1985, and March 1985 Quality Assurance Committee Meeting Minutes, dated February 12, 1985 1Interoffice correspondence relating to a Quality Improvement Program (QIP)
team formed to establish an optimum integrated program for mechanical snubbers.
This correspondence included the following:
QAO-PTP-84-209 QAO-PTP-84-240 QAO-PTP-84-255 QAO-PTP-84-282 QAO-PTP-84-474 QAO-PTP-85-037 QAO-PTP-85-209 July 23, 1984 August 7, 1984 August 17, 1984 September 17, 1984 November 14, 1984 January 15, 1985 April 3, 1985 The QIP team formation was encouraged by QA personnel and included selected supervisory QA and plant personnel.
After a
series of meetings and concentrated evaluation of the root cause of the problems, the following had been accomplished:
A good working relationship between participating organizations A program for upgrading the main steam dump to condenser snubbers Development of new snubber inspection, testing, and control procedures
N
Proposed license amendment for snubber TS Information exchange with St.
Lucie for snubber activities and development of optimum degree of uniformity between St.
Lucie and Turkey Point Satisfactory Audit'AO-PTP-84-542 finding closure Assignment of an inservice inspection coordinator for snubber-related activities Discussions were conducted by the inspector with various QA personnel including the QA Director, QA Supervisor, and various QA auditors.
Improve-ments have been made in QA activities due to PEP.
Since PEP implementation and contractor training of supervisory personnel, communication between various organizational levels and different disci-plinary groups of plant personnel has improved.
Personnel attitudes toward quality have improved.
QA auditing activities have also improved with increased staff size, certain auditors having plant operating experience due to being previously licensed, and increased operations training for all auditors.
Audits have generally improved in scope and depth.
Audit findings are generally more relevant.
To verify audit program implementation, the inspector reviewed the following audits:
QAO-PTP-83-449 QAO-PTB-84-088 QAO-PTP-84-529 QAO-PTP-84-531 QAO-PTP-84-532 QAO-PTP-84-533 QAO-PTP-84-534 QAO-PTP-84-535 QAO-PTP-84-536 QAO-PTP-84-537 QAO-PTP-84-538 QAO-PTP-84-539 QAO-PTP-84-541 QAO-PTP-84-542 QAO-,PTP-84-545 QAO-PTP-84-547 QAO-PTP-84-548 QAO-PTP-84-566 QAO-PTP-84-567 QAO-PTP-84-568 QAO-PTP-84-570 QAO"PTP-84-571 QAO-PTP-84-572 QAO-PTP-84-574 QAO-PTP-84-575 QAO-PTP-84-576 QAO-PTP-84"585 QAO-PTP-84-586 QAO-PTP-84-587 QAO-PTP-84-588 QAO-PTP-84-589 QAO-PTP-84-590 QAO-PTP-84-591 QAO-PTP-84-592 QAO-PTP-84-593 QAO-PTP-85-595 QAO-PTP-85-602 QAO-PTP-85-624 QAO-PTP-85-627 QAO-PTP-85-630 QAO-PTP-85-637 The inspector verified that all audits were issued within required time limits.
The inspector verified that eight TS audits (6,5.2.8.a-c and e-i)
had been performed within TS time limits.
The inspector reviewed qualifi-cations for site QA auditing personnel.
The inspector generally reviewed corrective actions for findings identified in the audits reviewed, The inspector also selected specific audit findings from the Open Item Tracking Status and the QA Monthly Reports and verified corrective action resolution.
Findings associated with the following specific audits were reviewed in depth:
QAO-PTP-83-449 QAO-TPB-84-04-088 QAO-PTP-84-542 The corrective action resolution for items identified in these audits was complex and time consuming.
Corrective action resolution has been agreed upon between QA and participating organizations.
Corrective action methodology was discussed with QA personnel.
Corrective action for two other audit findings, QAS-PTP-84-1.4 Finding
and QAS-IDA-83-1 Finding 3, was discussed with the QA Director.
Within this area, no violations or deviations were identified.
6.
Records (39701)
References:
(a)
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
Regulatory Guide 1.88, Collection, Storage, and Main-tenance of Nuclear Power Plant Quality Assurance Records l (~I>i+
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(c)
ANSI N45.2. 9, Requirements for Collection, Stor age, and Maintenance of Quality Assurance Records for Nuclear Power Plants (d)
Regulatory Guide 1.33, Quality Assurance Program Requirements, (Operation)
(e)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f)
Technical Specification, Section
The inspector reviewed the licensee records management program required by references (a) through (f) to verify that the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during this review to determine the overall acceptability of the established program:
Requirements and provisions were established to maintain essential quality assurance records.
Responsibilities were assigned in writing for overall management of the records program, Records storage controls were established in accordance with FSAR commitments.
Records storage facilities were described in writin Provisions had been made to establish the retention periods for all types of records.
Methods had been specified for the disposal of records no longer required.
The following documents were reviewed to verify that these criteria had been incorporated into the records program:
FPL-NQA-100A QP 17.1 Topical Quality Assurance Report, Revision
The Collection and Storage of Quality Assurance Records for Nuclear Power Plants, Revision
QP 4.1 Control of Requisitions and the Issuance of Purchase Orders for Spare Parts, Replacement Items, and Services, Revision
SQAD 1001 SQAD 1002 Qual ity Requirements for Items Requiring Nuclear Quality Assurance, Revision
Defect or Noncompliance Reporting Requirements for Nuclear Related Purchasing, Revision
SQAD 1005 AP 0190. 14 Standard Quality Control Notices, Revision
Document Control and Records, dated October 11, 1984 The following records were retrieved from the Turkey Point document control system:
Preoperation Procedure 0800.27, Fire Suppression Preaction and Deluge Sprinkler System Preoperational Test Procedure, dated April 3, 1985; conducted April 27, 1985 Operating Procedure 16002',
Preparations and Precautions for Refueling Fuel Shuffle, dated September 29, 1983; conducted April 10, 1984 Plant Work Order 133584, Repack Valve 558B, completed October 3, 1984 Plant Modification Summary, Isolation of Unit 3 from Northeast 240KY Bus, Summary date October 16, 1984 Reportable Event 84-07 (PNS-LI-84-99),
Engineered Safety Feature Actuation Reactor Trip, reported March 19, 1984
Special Report SwRI Project 17-4352, Special Examination of Main Steam Isolation Valves and 3-inch Charging Lines at Turkey Point Plant Unit 3, dated February 1977 Calibration Record for Fluke 8120A, Serial Number:
PTP number 103-11, dated January ll, 1985 Special Test 84-04 Results (Inter-Office Correspondence),
dated March 1, 1984 Purchase Order 000124, 2-inch, 150 lbs.
elbow, stainless steel Purchase Order 93099 - 99891P, Copper bar, brazing alloy, and flux to repair 3B Safety Injection Pump Motor Rotor Purchase Order 53137 17361W, Limitorque Cap-worm shaft bearing and switch-double torque QC Surveillance Report serial number 84-0241 (NCR 84-010, Charging Pump Operability), dated February 24, 1984 The master index and the computer data base must be used conjunctively to retrieve records from microfilm which makes record retrieval time consuming.
The master index is manually updated and entered into a word processor for reproduction.
The computer data matrix has limited cross-referencing capability.
Reportedly, a
new computer system will be installed in the new admini stration building that is currently under construction and part of the system may be dedicated to document control.
Within this area, no violations or deviations were identified.
7.
Document Control (39702)
References:
(a)
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and Fuel Reprocessing Plants (b)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
(c)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (d)
Technical Specifications, Section
The inspector reviewed the licensee document control program required by references (a) through (d) to verify that the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during this review to determine the overall acceptability of the established program:
,
f l
Administrative controls have been established for issuance, updating, and recall of outdated drawings.
Master indices are maintained for drawings, manuals, and procedures'dministrative controls have been established for distributing, updating and recall of outdated documents.
Administrative controls have been established for distribution of as-built drawings and PK IDs in a timely manner.
Administrative controls have been established to control discrepancies between as-found conditions and as-built drawings.
The documents listed below were reviewed to verify that these criteria had been incorporated into the document control program:
FP L-NQA-100A QP 6.1 Topical Quality Assurance Repor t, Revi sion
Control of Construction Project Contractor Drawings, Specifications, and Procedures, Revision
QP 6.2 Control of Documents Issued by Florida Power and Light Co., Revision
QP 6.6 Drawing Control for Operating Nuclear Power Plants, Revision
AP 0190.4 Procurement Document Control, dated November 21, 1984 AP 0190. 14 Document Control and QA Records, dated October ll, 1984 The inspector selected several controlled documents which were issued within the previous two months to verify that they were being issued and received at various controlled document locations.
The following documents were reviewed:
~Drawin s
Procedures 5610-T-E-4501, sheet
5610-T-E-4503, sheet
5610-T-L1, sheet 22A 5610-T-E-4505, sheet
5610-T-E-4512, sheet
1407.8 16900.1 0-ADM-702 3-GMI-041. 1 3-GMI-041. 3 3-GMM-04 Copies of each document containing revisions consistent with the master index were found at each location checked.
Each location checked maintained a master index of controlled documents.
Within these areas, no violations or deviations were identified.
8.
Licensee Actions on Previously Identified Inspection Findings a
~
(Closed)
Open Item (250/78-12-06):
CFR 21 Administrative Controls Do Not Detail Record Keeping Requirements.
b.
In accordance with AP 190. 14, the licensing section has appointed a
document control custodian who processes records such as Licensee Event Reports
'and
CFR
report packages.
Although the detailed processing method is not described in site procedures, the gA records of the packages are being maintained in accordance with 10 CFR 20.51.
Inter-office correspondence (gAO-PTP-85-199)
dated March 29, 1985, verified that the records are being maintained at the corporate licensing office.
Site licensing has information copies of all packages.
(Closed)
Open Item (250, 251/81-09-11):
Conduct Study to Widen Scope of Shel f-Life Program.
An inspection was performed by QC personnel of al 1 warehouse and mechanical department procured items.
Based on procured items identified, NASA guidelines for critical components were applied and a
parts list was developed to identify shelf life for these items.
Audit gAO-PTP-84-0522 conducted January 10 - March 17, 1984, identified that a poorly defined shelf-life program existed.
Based on the corrective actions previously stated, findings associated with this audit were closed in February 1985.
Audit gAO-PTN-83-620 is currently in progress to verify administrative controls and implementation of the shelf-life progra ~
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