IR 05000250/1990007
| ML17348A195 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point |
| Issue date: | 04/12/1990 |
| From: | Jape F, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A193 | List: |
| References | |
| 50-250-90-07, 50-250-90-7, 50-251-90-07, 50-251-90-7, NUDOCS 9004240454 | |
| Download: ML17348A195 (10) | |
Text
1PS AEONS, fpo~i IA 0 +**y4 UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-250/90-07 and 50-251/90-07 Licensee:
Florida Power and Light Company 9250 West Flagler StI eet Miami, FL 33102 Docket Nos.:
50-250 and 50-251 License Nos.:
DPR-31 and DPR-41 Facility Name:
Turkey Point 3 and
Inspection Conducted:
March 19-23, 1990 Inspector:
m Approved by:
F. Jape, Section hief (equality Performance Section Operations Branch Division of Reactor Safety
~- lI-ate s
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)gne SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of inspection of guality Verification functions, and follow-up on previous inspection findings.
Results:
In the areas inspected, violations or deviations were not identified.
Audits performed by the on-site gA organization staff demonstrated in-depth evaluation of design basis functional capability of audited systems and components.
Additionally, reviews of operations, surveillance, and maintenance practices were performed to assess the operational readiness of the systems and components.
Inspection of activities performed by the procurement gA/gC.staff, revealed that gA reviews of purchase requisitions and procurement documents are technically adequate.
Dedication packages prepared by procurement gC were also determined to be properly controlled by implementation of screening 'criteria to ensure technical adequacy.
9OI.I4 g 2 PDr'VOCK II OOO2 O
e
REPORT DETAILS Persons Contacted Licensee Employees
- T. Abbatiello, Supervisor, gA Performance Monitoring
- J. Anderson, Supervisor, gA Regulatory Compliance
- W. Bladow, gA Superintendent
- T. Finn, Assistant Operaions Superintendent
- K. Harris, Vice President, Turkey Point
- V. Kaminskes, Technical Supervisor
'J.
Kuorr, Compliance Engineer
- M. Lacal, Configuration Group Supervisor
- G. Smith, Services Manager
- G. Warriner, gC Supervisor
- M. Wayland, Maintenance Superintendent
- L. Wilson, Area gC Supervisor Other licensee employees contacted during this inspection included, engineers and administrative personnel.
NRC Resident Inspectors
- R. Butcher, Senior Resident Operations
- Attended exit interview e
2.
Action on Previous Inspections Findings (9292701, 92702)
(Closed)
Severity Level V Violation (50-250,251/89-34-01):
Failure to follow the. site procedure for maintaining identification of Reactor plant components.
The licensee response dated January 17, 1989, was considered acceptable by Region II.
The inspector reviewed procedure O-ADM-209, Equipment Tagging, and verified that the procedure had been revised to (1) assign responsibilities for implementation of the equipment tagging program and (2) establish precautions/limitations and specify requirements. of the program.
A flowchart, enclosure 4, depicts the process for issuing missing equipment tags.
Provisions for preparation of a quarterly and annual project statues report, walkdown log, and permanent tag ordering log have also been made.
Additional corrective actions implemented by the licensee included a
review of tr aining materials for new and continuing employee training programs to ensure inclusion of equipment tagging requirements.
The inspector verified completion of this corrective action by review of lesson plan number 500000 e'
e 3.
Section III, Equipment Identification, describes the requirements of the equipment tagging program and assigns responsibilities to plant personnel concerning implementation of the program.
Modifications to the site work control programs were also made in response to implementing corrective action for this violation.
Turkey Point Units 3 and 4 backfit construction administrative site procedure ASP-14, Equipment Tagging, Revision 4, was revised to delineate requirements and methods used by backfit construction to tag permanent plant par ts, equipment and materials during implementation of a PC/M, PWO, or other installation process.
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)
IFI 50-250,251/88-34-02, guestionable Site Practices concerning Record Retention for Completed Design Packages.
The licensee has revised procedure number AP-0190. 14, guality Assurance Records, to require procedures which presently have a five year retention period to be retained for the life of the plant.
Additionally, procedure number gII3-PTN-1, Design Control, paragraph 6.0, specifies requirements for retaining records which document plant changes for the life of the plant.
This procedure also established requirements for all records generated during preparation, review, and approval of PC/Ms to reference the PC/M number on'he first page of the record.
An ongoing generic review of, PC/M packages prior to gA signoff and submittal as gA records is being performed by the licensee.
The PC/M packages are reviewed for technical adequacy and completeness.
The packages are also verified as having all required documentation prior to transmittal to the gA department.
Deficiencies identified during these reviews are documented in FPSL interoffice correspondence from R.
E.
Rose to D. Powell, Subject:
IFI 250,251/88-34-02.
Design Control, dated March 23, 1990.
Based on the types of deficiencies documented in this interoffice correspondence, and the stated corrective actions being taken, the inspector concluded that appropriate corrective actions have been taken by the licensee.
This IFI is closed.
Inspection of guality Verification Function (35702)
The inspector conducted interviews with licensee management and reviewed objective evidence of completed work to assess the effectiveness of the licensee's quality verification organization in identifying technical issues and safety significant problems within the design-engineering functional area.
Personnel qualification and training of the staff was also reviewed to verify that necessary technical or operational experience and expertise were resident within the organization The licensee has conducted audits based on the methodology used by the NRC for SSFIs.
The objectives of a SSFI is to assess the operational readiness of selected safety systems by determining whether:
The systems are 'capable of performing the safety functions required by their design bases.
Testing is adequate to demonstrate that the systems would perform all of the safety functions required.
System maintenance (with emphasis on pumps and valves) is adequate to ensure system operability under postulated accident conditions.
Operator and maintenance technician training is adequate to ensure proper operations and maintenance of the system.
Human factors considerations relating to the selected systems (e.g.,accessibility and labelling of valves)
and the supporting procedures for those systems are adequate to ensure proper system operation under normal and accident conditions.
Management controls including procedures are adequate to ensure that the safety systems will fulfill the safety functions required by their design bases.
The inspector reviewed the following audit reports to determine if the above attributes were indeed demonstrated in the audit findings:
guality Assurance Audit gAO-PTN-88-947, Chemical and Volume Control System Vertical Slice Audit.
guality Assurance Audit gAO-PTN-88-925, Intake Cooling Water Vertical Slice Audit.
guality Assurance Audit gAO-PTN-89-013, Motor Operated Valve (MOV) Vertical Slice Audit.
The stated objectives of the above audits were to assess the design basis functional capability and operational readiness of the above systems/components.
The audit consisted of initial design reviews of design output documents such as reconstituted design basis documents, system descriptions, calculations, PODs, and selected PC/M packages.
This was followed up by a second phase which covered reviews and evaluations of operations, maintenance, testing and training practices as implemented
.
for the system/component being audited.
The audit findings demonstrated the broad scope of the reviews and evaluations performed in that both software (i.e., programmatic)
and hardware inadequacies were identifie '
Based on review of personnel qualifications of staff members in the site QA organization and discussions with licensee management, the inspector
.
determined that adequate technical resources are available for implementing their assigned responsibilities.
The inspector did not identify any deficiencies during this review.
The inspector reviewed the activities of select staff members of the Procurement QA/QC group related to ( 1)
QA reviews of -purchase requisitions and procurement documents and (2)
QC Procurement Document Reviewers activities concerning identification and control of nuclear safety related materials.
The controlling procedure for QA reviews of procurement documents is Ql 4 QAD1.
This procedure specifies requirements for QA department reviews of purchase requisition and procur'ement documents to assure -inclusion of appropriate technical and quality requirements.
The inspector conducted interviews with licensee personnel and reviewed objective evidence of completed work packages to verify technical adequacy of completed actions.
The status of QA reviews of procurement documents was assessed based on review of licensee performance indicator for percentage of purchase orders rejected by the QA staff.
A target of 10
. percent rejection was indicated as acceptable (i.e., good)
on the chart.
The performance indicator covered a duration from September 18, 1989, to March 12, 1990, and showed essentially a random pattern of rejection above and below the acceptance line for the time frame in question.
Additional reviews of selected Quality Assurance Tick Sheets further demonstrated this randomness-in rejection of purchase orders by the QA reviewers.
The inspector did not identify any deficiencies during the above review.
Activities of the QC procurement document reviewers are controlled by QC department instruction QCDl 4. 1.
This instruction assigns responsibility and provide instructions for implementing the requirements of procedure APO. 190.4, Procurement Document Control.
Among responsibilities specified in paragraph 5.0 are pre-screening of items and services for commercial. grade dedication per engineering guidelines.
The inspector conducted interviews with licensee personnel and reviewed objective evidence of completed dedication packages to determine the technical adequacy of the work performed.
The inspector verified that use of the pre-screening checklist ensures that engineering reviews are performed when appropriate, and inadvertent design changes are not being made.
Additional reviews of purchase orders and reciept inspection reports for selected dedication packages revealed no deficiencies.
An assessment of the status of the QC procurement document reviewers work was made using
'he performance indicator for percentage of A and B priority requisitions exceeding the review time target.
As of February 5, the overall trend has been unfavorable with increasing deterioration for the weeks of March 5 and 12, 199 Priority A and B requisitions are those requiring one and three days review time respectively, and which could be (I) load threatening/critical path/outage or (2) affect equipment operability; planned outage related PWO awaiting parts.
The inspector did not identify only inadequcies in the performance of activities by the QC procurement document reviewers because of, this unfavorable trend.
The inspector determined that a formalized training program for QC inspectors is being developed by the licensee.
The design phase for completion in December 1990, and the development phase in December 1991.
Additionally, changes to the on-site QC organization involving merger of the operations and cons'truction QC organization are being contemplated.
The inspector osbserved that expeditions development and implementation of the QC training program is required given the changes being considered for the QC organizations.
Licensee management agreed to review the QC training program schedule given the needs of the new QC organization.
Within this area no violations or deviations were identified.
Exit Interview The inspection scope and results were summarized on March 23, 1990, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not 'contained in this report.
Dissenting comments were "not received from the licensee.
Licensee management was informed that the previous violations and the IFI discussed in paragraph
were closed.
Acronyms and Initialisms PC/M PWO QA FPE(L IFI NRC SSFI POD QC Plant Change or Modification Plant Work Order Quality Assurance Florida Power and Light Inspector Followup Item Nuclear Regulatory Commission Safety System Functional Inspection Plant Operating Documents Quality Control