IR 05000335/1981004
| ML17209B175 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/23/1981 |
| From: | Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17209B171 | List: |
| References | |
| 50-335-81-04, 50-335-81-4, NUDOCS 8106090299 | |
| Download: ML17209B175 (55) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/81-04 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name:
St. Lucie 1 Docket No. 50-335 License No. DPR-67 Inspection at St. Lucie near Ft. Pierce, Florida Iespector:
P.
H. Skinner Approved by:
C.
M. Upright, C
f, M agement Program Section Engineering Ins ction ranch Engineering and Technical Inspection Division ate S gned Dat Signed SUMMARY Inspected on February 1T 20, 1981 Areas Inspeoted This routine, unannounced inspection involved 30 inspector-hours onsite in the area of Plant Procedures.
s ss Resul ts Of the. area inspected, two apparent violations were identified (Failure to pro-.
vide measures to control temporary changes, paragraph 5.a.(1);
Failure to provide appropriate procedures-,
paragraph S.a.(2)).
REPORT DETAILS 1.
Persons Contacted Licensee Employees
"C. Wethy, Plant Manager
"J. Barrow, Operations Superintendent
"A. Bailey, guality Assurance. Supervisor
~N. Roos, guality Control Supervisor
"R. Jennings, Technical Supervisor
"D. Sager, Operations Supervisor J. Bowers, Maintenance Superintendent J. Walls, equality Control Engineer J. Lewis, guality Control Engineer NRC Resident Inspector
"S. Elrod; Senior Resident Inspector
"Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on February 20, 1981, with those persons indicated. in paragraph l,above.
3.
Licensee Action on Previous. Inspection Findings Not inspected.
4.
Unresolved Items 5..
Unresolved items were not identified during this inspection.
Procedures (42700)
References:
(a)
CFR 50,.
Appendix B,
(}uality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants (b)
ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants (c)
Technical Specifications (d)
Regulatory Guide 1.33, November 1972, guality Assurance Program Requirements (Operation)
(e)
Final Safety Analysis Report
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(f)
Quality Assurance Manual Procedure OP 5.1 Operating Plant Procedures, Rev.
3 dated November 1980 a.
Review of Plant Procedures The inspector-reviewed selected plant procedures in accordance with the guidance and requirements provided by references (a)
through (f)
above to ascertain whether. overall procedures are in accordance with regulatory requirements.
The following criteria were used during th'is review:
Required review and approval of procedure changes and temporary changes had been performed Overall procedure content is consistent with references (c) and (e)
Records of changes in procedures are being maintained-Based on this review, two apparent violations were identified and are discussed in paragraphs 5.a(1)
and 5.a(2).
A listing of those procedures reviewed and comments as appropriate are given below.
(.1)
Administrative Procedures (
QI 5-PR/PSL-1, Preparation, Revision Review/Approval of Procedures, Revision 13 dated 3/80.
QI. 6-PR/PSL-1,. Document Control, Revision 4 dated 9/79.
Reference (a) Criterion VI states measures shall be established to. control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which pre-scribe all activities affecting quality.
These measures, shall assure that documents, including changes, are reviewed for~ ade-quacy and. approved for release and are distributed to and used at the location where the prescribed activity is pe~formed.
The accepted QA Program Topical Quality Requirement 6.0, Document Control, Revision 0 dated January 23,'976, states that quality procedures shall "delineate the control measures for controlled documents, including direction for the review for, adequacy, approval by authorized personnel, distribution-and verification that changes are promptly incorporated.
These control measures-shall apply to documents affecting the quality of nuclear safety related structures, systems and components such as plant operating and maintenance procedure Reference (f) Section 5.3 requires a written procedure deline-ating the methods for requesting, reviewing, approving and docu-menting revisions and temporary changes to procedures.
QI 5-PR/PSL-1 implements the requirements of reference (f) to provide.
a written procedure to delineate the methods for request.-
ing; reviewing, approving and documenting revisions and temporary changes -to procedures.
The criteria that must be met. to initiate a temporary change are provided in section 5.5.4, but the proce-dure does not contain detailed instructions on the method to be used to institute and control a temporary change.
This failure to provide measures to control issuance of temporary changes to operating procedures and distribute these changes to locations where the activities are performed constitutes a vio-lation (335/81-04-01).
Operating Procedures Reference (a) Criterion V requires that instructions, procedures or drawings affecting quality include appropriate quantitative or qualtitative acceptance criteria for determining that important activities had been. satisfactorily accomplished.
The accepted QA Program Topical Quality Requirement 5.0 Instructions, Procedures, and Drawings, Revision
dated January 23, 1976, states that activities affecting quality of nuclear safety related structures, systems, and components shall be prescribed by documented, instructions, procedures, or drawings of a type appropriate to the-circumstances and shall'e accomplished in accordance with these instructions, procedures, or drawings.
These documents shall include appropriate quantitative and qualitative criteria to assure that the quality assurance activity has been satisfac-torily accomplished.
'echnical Specification 6.8. 1 requires written procedures be established, implemented and maintained covering the-applicable activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972; operating procedures are included as typical safety-related activities to be covered by written procedures.
Various errors existed in several operating procedures reviewed by the-inspector.
The inspector could not verify that the errors were corrected prior to the accomplishment of the procedures since-documentation of the. latest valve lineup conducted on a,
system is not maintained.
In addition, temporary changes were not written to correct these discrepancies.
The discrepancies identified are listed below.
OP 0350020, Fuel Pool Cooling and Purification System-Normal Operation, Revision 3 dated January 197 (a)
Valves V4255 through V4260 were not identified on the valve lineup.
(b)
Several valves did not have valve numbers provided.
(c)
Step 8.3.5 required replacement of blind flanges removed in step 8.3.3.
Step 8.3.3 indicated no flanges were removed.
OP 0410020, HPSI/LPSI Normal Operations, Revision 12 dated August 1979 no comments.
OP 0210020, Charging and Letdown - Normal Operation, Revision 13 dated January 1981 Several valves on the valve lineup sheets were not identified by a number.
OP 0420020, Containment Spray Initial Valve Lineup, Revision 10 February 1980.
(a)
Several valves on the valve lineup sheets were not identified by a number.
(b)
The above unnumbered valves were not shown on the piping diagrams for the system.
OP 0030128, Reactor Shutdown, Revision 3 dated August 1978 no comment.
OP 030122, Reactor Startup, Revision 18 dated February 1980.no comment.
OP 0030124, Turbine Startup Zero to Full Load, Revision 13 dated September 1980 no comment.
The discrepancies noted above are examples of a failure to pro-vide appropriate procedures with qualitative or quantitative criteria for assuring that activities important to safety",. are satisfactorily accomplished and constitute'
violation (335/81-04-02).
(3)
Off-Normal Procedures OP 0410030 LPSI, Off Normal Operation, Revision 3 dated May 1979.
OP 0440030 HPSI', Off Normal Operation, Revision 3 dated August 1980.
OP 0210030>
Charging and Letdown Off Normal Operation, Revision 3 dated September 197 OP 0030130, Shutdown Resulting from Reactor Trip or Turbine Trip, Revision 9 dated June 1980.
No violations or deviations were identified.
(4)
Emergency Operating Procedures EOP 0120040, Loss of Reactor Coolant Pump Flow/Natural Circulation, Revision 7 dated September 1980.
EOP 0610031, Loss of Condenser Vacuum, Revision
dated July 1979.
No violations or deviations were identified.
(5)
Maintenance Procedures I&C Procedure 1400052, Engineered Safeguards Actuation System Channel Functional Test, Revision 12 dated January 1980.
MP 0210160, Charging Pump Maintenance, Revision 2 dated January 1978.
No violations or deviations were identified.
(6)
Other Procedures I&C Letter of Instruction GI&C-3, Temporary Freeze Protection on St. Lucie Plant Instrumentation, Revision 0 dated October 1977.
EPIP. 3100024E, Natural Emergencies, Revision
dated November 1979.
No violations or deviations were identified.
b.
Verification of Operating Procedure Review Section 5.9 of. gI 5-PR/PSL-,
1 requires that each operating procedure shall be reviewed at least once each 36 months to assure they represent current plant policy and practice.
Documentation was reviewed to verify that this requirement was being accompli'shed.
In the samples reviewed by the inspector no violations or deviations were identifie ~
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C.
Review of Temporary Changes to Procedures Technical Specification 6.8.3 requires that temporary changes to procedures be documented, reviewed by the Facility Review Group (FRG),
and approved by the Plant Manager within 14 days of implementation.
A review of sel'ected temporary changes made to procedures from November 1979 to February 1,
1981,,
identified three:
changes that were not reviewed within the required time period.
Two of the three changes were identified in the FRG meeting minutes and action was taken to preclude this from recurring.
No citation is issued for failure of the FRG to review temporary changes within 14 days as required by the Technical Specifications since the FRG has identified and taken cor-rective action that appears at this time to have resolved this proble P
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Florida Power and Light Company MAR 25 198t ATTN:
R. E. Uhrig, Vice President Advanced Systems and Technology P. 0. Box 529100 Niami, FL 33152 Gentlemen:
Subject:
Report No. 50-335/81-04 This refers to the routine inspection conducted by P. Skinner of this office on February 17-20, 1981, of activities authorized by NRC Operating License No.
OPR-67 for the St.
Lucie facility.
Our preliminary findings were discussed with
'.
H. Wethy at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection, it was found that certain activities under your license appear to violate NRC requirements.
These items and references to pertinent-requirements. are listed. in the Notice of Violation enclosed herewith as Appen-dix A. 'Elements to be, included in your response-are delineated in Appendix A.
In accordance with Section 2;790 of the NRC "Rules of Practice," Part Z, Title.
10, Code of Federal Regulations, a copyI of this letter and the enclosed inspec-tion report will be placed in the NRC Public Oocument Room. If this report contains any information that you believe to be. proprietary, it is necessary that you make a. written application within 20 days to this office: to withhold such information from public disclosure.
Any such application must include the basis for claiming that the information is proprietary and the proprietary information should be contained in a separate part of the document.
If we do not hear from you in this regard within the speci. fied period, the report will be placed in the Public Oocument Room.
((
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely
Enclosures:
See Page
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. C.
ewis, Acting Oirector Oivision of Resident and Reactor Project-Inspection
I Florida Power and Light Company Enclosures:
1.
Appendix A, Notice of Violation 2.
Enspection Report No. 50-335/81-04.
REGION II==
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/81-04 Licensee:
Florida Power and Light Company 925Q West Flagler Street Miami, FL 33101 Facility Name:
St. Lucie 1 Oocket No.
50-335'icense No. OPR-67 Inspection at St. Lucie near Ft. Pierce, Florida et Inspector: P.. Skinner E
Approved by:
C. M. Upright, C
f, M
agement Program Section Engineering Ins ction ranch Engineering and. Technical Inspection Oivision ate S gned Oat Signed SUMMARY Inspected on February 17 - 20, 1981.
Areas Inspected'his routine, unannounced inspection involved, 30 inspector-hours onsite in the area of Plant Procedures.
s Results Of the area inspected, two apparent. violations were identified (Failure to pro-vide measures to.control temporary changes,,
paragraph 5.a.(1); Failure to provide appropriate procedures, paragraph 5.a.(2)).
REPORT OETAILS 1.
Persons Contacted Licensee Employees
"C. Wethy, Plant Manager
"J. Barrow, Operations Superintendent
"A. Bailey, guality Assurance Supervisor
"N. Roos, guality Control Supervisor
-'R. Jennings, Technical Supervisor
"0. Sager, Operations Supervisor J. Bowers, Maintenance Superintendent J. Walls, guality, Control Engineer J. Lewis, guality Control Engineer NRC Resident Inspector
"S. Elrod; Senior Resident Inspector
"Attended exit interview.
3, The inspection scope and findings were summarized on February 20,.
1981, with those persons indicated in paragraph 1 above.
Licensee Action on Previous, Inspection Findings, Not inspected.
4.
Unresolved Items Unresolved items were. not identified during this inspection.
5.
Procedures (42700)
References:
(a)
CFR SO, Appendix B, guality Assurance Criteria For Nuclear Power Plants and Fuel'eprocessing Plants (b)
ANSI N18.7-1972, Administrative Controls for Nuclear-Power Plants (c)
Technical Specifications (d)
Regulatory.Guide* 1.33, November 1972, gual ity Assurance Program Requirements (Operation)
(e)
Final Safety Analysis Report
-2-(f)
Quality Assurance Manual Procedure OP 5.1 Operating Plant Procedures, Rev.
3 dated November 1980 a.
Review of Plant Procedures The inspector reviewed selected plant procedures in accordance with the guidance and requirements provided by references (a)
through (f)
above to ascertain whether overall procedures are in accordance with regulatory requirements.
The. following criteria were used during this review:
Required review and approval of procedure changes and temporary changes had been performed Overall procedure content is consistent with references (c) and (e)
/
Records of changes in procedures are being maintained Based on this review, two apparent violations were identified and are discussed in paragraphs 5.a(1) and 5.a(2).
A listing. of those procedures reviewed and comments as appropriate are given below.
(1)
Administrative Procedures I
QZ 5-PR/PSL-1, Preparation, Revision Review/Approval of Procedures, Revision 13 dated 3/80.
QI 6-PR/PSL"1, Document. Control, Revision 4 dated 9/79.
Reference (a) Criterion VI states measures shall be established to. control.
the issuance of documents, such as instructions; procedures.,
and drawings, including changes thereto, which pre-scribe all activities affecting quality.
These measures shall assure that. documents,
.including changes, are reviewed for",.ade-quacy and approved for release and are distributed to and used at the location where.
the prescribed activity is performed.
The accepted QA Program Topical Quality Requirement 6.0, Oocument Control, Revision 0 dated January 23,'976, states that quality procedures shall delineate the. control measures for controlled documents,.
including direction for the review for adequacy, approval by authorized personnel,.
distribution and verification that changes.
are promptly incorporated.
These control measures shall apply, to documents affecting the quality of nuclear safety related structures, systems and components such as plant operating and maintenance procedure <<3<<
Reference (f) Section 5.3 requires a written procedure deline-ating the methods for requesting, reviewing, approving and docu-menting revisions and temporary changes to procedures.
gI 5-PR/PSL-1 implements the requirements of reference (f) to provide a 'written procedure to delineate the methods for request-ing, reviewing, approving and. documenting revisions and temporary changes to procedures.
The criteria that must be met to initiate a temporary change. are provided in section 5.5.4, but the proce-dure doer not contain detailed instructions on the method to be used to institute and control a temporary change.
This failure to provide measures to control issuance of temporary changes to operating procedures and distribute these changes to locations where the activities are performed constitutes a vio-1 ati on (335/81" 04-01).
Operating Procedures Reference (a) Criterion V requires that instructions, procedures or drawings affecting quality include appropriate quantitative or qualtitative acceptance criteria for determining that important activities had been satisfactorily accomplished.
The accepted gA Program Topical guality Requirement 5.0 Instructions, Procedures, and. Drawings, Revision 0 >>dated Janua'ry 23, 1976; states that activities affecting quality of, nuclear safety related structures, systems, and components shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.
and. shall be accomplished in accordance.
with these.
instructions, procedures, or drawings.
These documents shall-include appropriate quantitative and qualitative criteria.
to assure that the quality assurance activity has been satisfac-torily accomplished.
Technical Specification 6.8. 1 requires written procedures be established, implemented and maintained covering the applicable activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972; operating p'rocedures are included as typical safety-related, activities to be covered by written procedures.
Various errors existed in several operating procedures reviewed by the inspector.
The inspector could not. verify that the errors were corrected prior to the accomplishment of the procedures since-documentation of the latest valve lineup conducted on a
system is not maintained.
In addition, temporary changes were not written to correct, these discrepancies.
The discrepancies identified are listed below.
OP 0350020,. Fuel Pool Cooling and Purification System-Normal Operation, Revision 3 dated January 197 (a)
Valves V4255 through V4260 were not identified on the valve lineup.
(b)
Several valves did not have valve numbers provided.
(c)
Step 8.3.5 required replacement of blind flanges removed in step 8..3.3.
Step 8.3.3 indicated no flanges were removed.
OP 0410020, HPSI/LPSI Normal Operations, Revision-12. dated August 1979 no comments.-
OP 0210020, Charging and Letdown " Normal Operation, Revision 13 dated January 1981 Several valves on the valve lineup sheets were not identified by a number.
OP 0420020, Containment Spray Initial Valve Lineup, Revision 10 February 1980.
(a)
Several valves on the valve lineup sheets were not identified by a number.
(b)
The. above, unnumbered valves were not shown on the piping diagrams for-the system.
OP 0030128, Reactor Shutdown, Revision 3 dated August 1978 no comment.
OP 030122, Reactor Startup, Revision 18 dated February 1980'
no comment.
OP 0030124, Turbine Startup Zero to Full Load, Revision 13.dated September 1980 no comment.
The discrepancies noted above are examples of a fail'ure to pro-vide appropriate:
procedures with qualitative or quantitative criteria for assuring that activities important. to safety,'; are satisfactorily accomplished and constitute a violation (335/81-04-02).
(3)
Off-Normal Procedures OP 0410030 LPSI', Off Normal'peration-,. Revision -3'ated Hay 1979.
OP 0440030 HPSI, Off Normal Operation, Revision 3 dated.
August 1980.
OP 0210030, Charging and Letdown - Off Normal Operation, Revision 3 dated September 197 "5-OP 0030130, Shutdown Resulting from Reactor Trip or Turbine Trip, Revision 9 dated June 1980.
No violations or deviations were 'identified.
(4)
Emergency Operating Procedures EOP 0120040, Loss of Reactor Coolant Pump Flow/Natural Circulation, Revision 7 dated September 1980.
EOP 0610031, Loss of Condenser Vacuum, Revision
dated July 1979.
P No violations or deviations were identified.
(5)
Maintenance Procedures.
I&C Procedure 1400052, Engineered Safeguards Actuation System - Channel Functional Test, Revision 12 dated January 1980.
HP 0210160, Charging Pump Maintenance, Revision 2 dated January 1978.
No violations or deviations were'dentiAed; (6)
Other Procedures I&C Letter of Instruction GI&C-3, Temporary Freeze Protection on St. Lucie Plant Instrumentation, R'evision 0 dated October 1977.
EPIP 3100024E, Natural Emergencies, Revision
dated November 1979.
No violations or deviations were identified.
b.
Verification of Operating Procedure Review Section 5.9 of gI 5-PR/PSL-1 requires that each. operating procedure shall be reviewed at 1'east once each 36 months to assure they represent current plant policy and practice.
Documentation was reviewed to verify that this requirement was being accompli'shed; In the samples reviewed by the inspector no violations or deviations were-identifie C.
Review of Temporary Changes to Procedures Technical Specification 6.8.3 requires that temporary changes to procedures be documented, reviewed by the Facility Review Group (FRG),
and approved by the Plant Manager within 14 days of implementation.
A review of sel'ected temporary changes made to procedures from November 1979 to-February 1,
1981,, identified three changes that were not reviewed within the required time period.
Two of the three changes were identified in the FRG meeting minutes and action was taken to preclude this from recurring.
No citation is issued for failure of the FRG to review temporary.
changes within 14 days as required by the Technical Specifications since the FRG has identified and taken cor-rective action that appears at this time to have resolved this proble l'-'ll ILEQy~
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W.. SUITE 3100 ATLANTA,GEORGIA 30303 FF.B 20 ~s8~
Florida Power and Light Company ATTN.:
R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Report Nos. 50-335/81-03 and 50-389/81-02 This refers to the routine safety inspection conducted by W. P. Kleinsorge of this office on January 20-23, 1981, of activities authorized by NRC Operating License No.
DPR-67 and Construction Permit No.
CPPR-144 for the St. Iucie facility.
Our preliminary findings were discussed with B. J.
Escue at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection, it was found that certain activities under your license appear to violate NRC requirements.
These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
Elements to be included in your response are delineated in Appendix A.
We have examined actions you have taken with regard to previously identified enforcement matters and unresolved items.
The status of these items is discussed in the enclosed report.
Two new unresolved items are identified in the enclosed inspection report.
These items willbe examined during subsequent inspections.
In accordance with Section 2.790 of the NRC "Rules of Practice," Part 2, Title 10, Code of Federal Regulations,la copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such infor" mation from public disclosure.
Any such application must include the basis for claiming that the information is 'proprietary and the proprietary information should be contained in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Roo ~EH 2 0 )98)
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, C. E.
M rp y, C ref Reactor Construction and Engineering Support Branch Enclosures 1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-335/81-03 and 50>>389/81-02 cc w/encl:
C.
M. Wethy, Plant Manager Nat Weems, Assistant QA Construction Manager
APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company St. Lucie 2 Docket No. 50-389 License No.
CPPR-144 As a result of the inspection conducted on January 20-23, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified.
A.
CFR 50, Appendix B, Criterion IX as implemented by FPL Topical Report (FPSL TQARI-76A) Section 9 requires measures be established to assure special processes including nondestructive are controlled.
Licensee procedure QI-9.1 establishes visual inspection requirements.
EBASCO specification FLO"2998-G761 establishes ultrasonic examination requirements for structures.
Contrary to the above, measures were inadequate to control nondestructive testing in that:
1.
On January 21, 1981 four safety injection system licensee accepted socket weld flange to pipe fillet weld joints had fillet weld leg size 1/16" smaller than the minimum permitted by Figure (b), Attachment
to QI"9.1.
2.
On October 27-31, 1980, Weld Joint 2F-2STL-G838-275 was incorrectly accepted by ultrasonic examination.
'This is a Severity Level V Violation (Supplement II.E.)'.
B.
CFR 50, Appendix B, Criterion XVII, as implemented by FPGL Topical Report (FPGL TQARI-76A) Section 17. states
"Sufficient records shall be maintained to furnish evidence of activities affecting quality...Inspection records shall as a minimum identify...the type of observation...
Contrary to the above, on January 21, 1981, inspection records did not identify the type of observation in that WRR-2107 was annotated for Root NT or PT inspection when Root After Backgouging MT or PT inspection was intended.
This is a Severity Level VI Violation (Supplement II.F.).
Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) admis-sion 'or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5)
the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date:
UNITED STATES NUCLEAR REGULATORY COMMISSION RE@ON II 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 FEB 20 )98)
Report Nos.
50-335/81"03 and 50-389/81-02 Licensee:
Florida Power and Light Company 9250 Nest Flagler Street Miami, FL 33101 Oocket Nos.
50-335 and 50-389 Facility Name:
St. Lucie License Nos.
'OPR-67 and CPPR-144 Inspection at St. Lucie site near Fort Pierce, Florida Inspectoyt 2P lk'lC ~
A M. P. Kleinsorge Approved by:
ft/
A. R. Herdt, ection Chief, RC&ES Branch Oa e S1gned Oate igned SUMMARY Inspection on January 20-23, 1981 Areas Inspected This routine, unannounced inspection involved 28 inspector-hours onsite in the areas of licensee action on previous inspection findings (Unit 2),
equipment storage (Unit 2), reactor coolant pressure boundary piping " observation of work and work activities (Unit 2), safety-related piping (Unit 2), steel structures and supports (Unit 2) and inspector follow-up items (Unit 1).
Results Of the six areas inspected, no violations or deviations were identified in three
.
areas; two violations were found in three areas (Violation - Failure to Adequately control NOE - paragraphs 3.c.
and 6.b.(5)(a)
1 and Violation - Failure to properly annotate inspection requirement - paragraph 8.a.(1).
0ETAILS 1.
Persons Contacted Licensee Employees
"B. J. Escue, Site Manager, PSL-2
"J. A. Thompson, Assistant Site Manager N. T. Weems, Assistant Manager QA Construction
"R. A. Garramore, Senior Resident Engineer
"W. M. Hayward, Supervising QA Engineer
- 0. Cooper, Supervising QA Engineering
- W. F. Jackson, Welding Superintendent
"J. L. Parker, Project QC Supervisor
"J. W. Adams, Quality Engineer
"T. C. Grozan, Nuclear Licensing (GO)
- G. H. Krauss, ESSE Project Engineer
"G. A. Maxwell, Stores Supervisor
"0. L. McAfee, QA Engineer, QAO PSL-1 E. W. Sherman, QA Engineer Other licensee employees contacted included several construction craftsmen, QC technicians, and office personnel.
"Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on January 23, 1981, with those persons indicated in Paragraph 1 above.
The inspector identified areas inspected and discussed in detail the violations, unresolved items and the inspector follow-up item.
No dissenting comments were received from the licensee.
3.
Licensee Action on Previous Inspection Findings
'a ~
(Open) Infraction (389/80-13-01)
Improper Storage.
This item concerns the licensee's impr oper storage of six ASME Class 1, 2, and 3 valves in one location.
The response from the licensee considered the above as an isolated case and dealt with the matter accordingly.
Our ing this inspection, the following examples were noted.
(1)
One class 2 main steam stop valve, installed in the trestle, was uncovered out doors.
(2)
Three valves ASME Class 1 and 2, were stored out doors uncovered in the south long term storage area.
(3)
Two valves, ASME Class 2 and 3, were stored, in plastic bags containing holes and water, outdoors behind the stainless steel pipe fabrication sho yl
(4)
Approximately fifty valves of unknown class were stored in opaque plastic bags, some containing holes and water stored outdoors behind the stainless steel pipe fabrication shop.
FP&L Procedure SQP-3 Rev 2, "Site Quality Procedure Material Control", identifies valves as requiring level C storage conditions.
SQP-3 further specifies that Level C storage shall be indoors or equal, free from flooding and well ventilated.
In view of the above, the inspector informed the licensee that improper valve storage is not a problem isolated to one location.
The licensee indicated that they would re-examine their storage and storage inspection programs.
This item remains open.
b.
(Closed) Infraction (389/80-13-02)
Welding Filler Material Control.
FPAL letters of response dated November 7 and Oecember 15, 1980, have been reviewed and determined to be acceptable by Region II.
The inspector held discussions with Project Manager, Unit 2, and examined the corrective actions as stated in the letter of response.
The inspector concluded that FP5L had determined the full extent of the subject noncompliance, performed the necessary survey and follow-up.
actions to correct the present conditions and developed the necessary corrective actions to preclude recurrence of similar circumstances.
The corrective actions identified in the letter of response have been implemented.
C.
(Closed) Unresolved Item (389/80-15-06)
Evaluation of Repair Requests.
This item concerns a questions of whether an ultrasonic examination reflector (indication) was within the area of interest of Weld Joint 2F-2STL-G838-275 and therefore whether the reflector required repair.
Ultrasonic examination was conducted in accordance with Ebasco Speci-fication FLO-2998 G-761.
The licensee originally determined that the reflector did not require repair.
As a result of this item, the licensee re-evaluated the reflector, and determined that repair was required.
Repair was accomplished in accordance with WRR-2158.
Therefore, the licensee did not adequately control non-destructive examination evaluation.
This matter will be closed as an unresolved item and included as an example of violation 389/81-02-01.
Within the area examined, no violations or deviations except as described in paragraph 3.c. were identified.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items identified during this inspection are discussed in paragraphs 5.b and 6.b.(5)(a) I
5.
Independent Inspection Effort a.
Construction Activities (Unit 2)
The inspector - conducted.
a general inspection of the unit two reactor building, auxiliary building and stainless steel pipe fab shop to observe construction progress and construction activities such as welding, welding filler material control, material controls, and housekeeping and storage.
b.
Equipment Storage (Unit 2)
On January 21, 1981, the inspector accompanied by a representative of the licensee, made a general inspection of the Level A warehouse.
The inspector noted that the Level A warehouse temperature dropped below 60'F on three consecutive days during the previous week.
FP&L Procedure SPQ-3, Revision 2, "Site Quality Procedure, Material Control", requires Level A items to be maintained between 60'nd 80 F.
The inspector could not find any indication that the licensee had evaluated the effects of the above temperature excursions had on the.
contents of the warehouse.
The licensee indicated that they would look into the matter.
The inspector stated that the above would be an unresolved 'tem identified as'89/81-02-04:
"Level A
Warehouse Temperature Excursions".
Within the area examined, no violations or deviations were identified.
6.
Reactor Coolant Pressure Boundary Piping
'- Observation of Work and Work Activities (Unit 2)
The inspector observed non-welding and welding work activities for reactor coolant pressure boundary (RCPB) piping.'he applicable code for instal-lation of RCPB piping is the ASME B and PV Code Section III, 1977 Edition through the Summer 1977 Addenda.
'a ~
Observation of Non-Melding Activities II'bservation of specific work activities were conducted to determine conformance, where applicable, with the following; inspection and/or work procedures, record keeping requirements, installation specifi-cation requirements, specified material and qualified inspection personnel.
. Safety Injection System
~Activist Marking Marking
'dentification Meld Joint SI-245-SM-6 Meld Joint SI"239-SW-6 Procedure SQP-47 R-1
'QP"47 R"1
Marking Marking Storage Marking Marking Marking Marking Marking Marking Weld Joint SI-239-SW-6 Weld Joint SI-239-SW-6 Valves Various Reactor Coolant System Weld'oi nt RC-142-SW-002 Weld Joint RC-142-SW-003 Weld Joint RC-142-SW-004 Weld Joint RC-142-SW-008 Weld Joint RC-142-SW-010 Weld Joint RC-142-SW-012 SQP",47 R-1 SQP"47 R"1 SQP"3 R-2 SQP-47 R"1 SQP-47 R-1 SQP-47 R-1 SQP-47 R-1 SQP"47 R-1 SQP"47 R-1 (1)
With regard to the above inspection in the area of marking, the inspector identified unresolved item 389/81-02-03 discussed in detail in paragraph 6.b.(5)(a) 2.
(2)
With regard to the above inspection, the inspector noted one ASME Class 1 Safety Injection 'Valve stored contrary to the requirements of SQP-3.
This matter is discussed in detail in paragraph 3.a.
b.
Observation of Welding Activities The inspector observed in-process welding activities of RCPB piping field welds as described below to determine whether applicable code and procedure requirements were being met.
(1)
Wel ding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure; WPS assignment; welding technique and sequence; materials identify; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment conditions; interpass temper-ature; interpass cleaning; process control systems; identity of welders; qualifications of inspection personnel; and weld history records.
Joint No..
RC"150"SW-003 CH-148-SW"013 RC-124-FW"003 RC-124-FW-004 RC-115-FW-030 RC-121-FW-004 Size 2"x0.334" 2"x0.334 35.62 36.42" 35.62" 36.12" Stage of Fabrication Welding Out Welding Out Welding Out Welding Out Clad Welding Welding Out System Reactor Coolant Chemical and Volume Control Reactor Coolant Reactor Coolant Reactor Coolant Reactor Coolant
(2)
Weld Heat Treatment The inspector reviewed the FPCL program for weld heat treatment for compliance with gA procedure and Code requirements.
The welds listed in paragraph 6.b.(1), 7.b.(l),
and 8.a, were examined in process relative to weld joint preheating to determine; procedures available; procedures specify acceptable preheating method; procedures provide monitoring and recording requirements and procedure compliance.
E (3)
Welder gual ifications The inspector reviewed the FP&L program for qualification of welders and welding operators for compliance with gA procedures and ASME Code requirements.
(a)
The following welder qualification status records and
"Records of Performance gualification Test" were reviewed relative to the weld joints listed in paragraph 6.b.(1),
7.b.(l), and 8.a.
Welder S mbol A lication PTE PVT PYC FAM PD PRZ PSM PWT FCS PSL FAM PTP FEH PWV RCBP RCBP RCBP RCBP RCBP RCBP RCBP RCBP RCBP RCBP RCBP RCBP Safety Related Piping Steel Structures and Supports (b)
The following repair welder's qualification status records, and "Records of Performance gualification Test" were reviewed to determine whether they meet applicable qualification requirements.
Welder Symbol PWT PTM FBT PRZ PXU Weld Repair Report No.
1917 1917 1999 2062 1858
(4)
Welding Filler Material Control The inspector reviewed the FP&L program for control of welding materials to -determine whether materials are being purchased,
=
accepted, stored and handled in accordance with gA procedures and applicable code requirements.
The following specific areas were examined:
-Purchasing procedures, receiving, storing, distributing and handling procedures, material identification, inspection of welding material issuing stations-Welding material purchasing and receiving records for the following materials were reviewed for conformance with applicable procedures and code requirements:
Type ER-308L 70S2 ER-308L 7018 7018 70S2 70S2 Size 1/8" 0.045" 0 045" 1/8 II 3/32ll 1/8 II 3/32" Material ID Code 0176 0151 0170 0171 0174 0182 0101 Application RCPB RCPP RCPP Safety Related Piping and Steel Structures and supports Safety Related Piping Safety Related Piping Safety Related Piping (5)
The inspector visually examined completed RCPB Welds as described below to determine whether applicable code and procedure require-ments were being met.
(a)
The following welds were examined relative to the following:
location, length, size and shape; weld surface finish and appearance, include inside diameter of pipe welds when accessible; transitions between different wall thickness; weld reinforcement height and appearance; joint configu-rations of permanent attachments and structural supports; removal of temporary attachment, arc strikes and weld spatter; finish-grinding or machining of weld surface, surface finish and absence of wall thinning; surface defects, cracks, laps.
lack of penetration, lack of fusion, porosity, slag, oxide film and undercut exceeding prescribed limits:
Joint Number System SI-245"SW-006 SI-239-SW-006
'I-230-SW-006 Safety Injection Safety Injection Safety Injection
SI-235-SW 006 RC-142-SW-002 RC"142"SW-003 RC"142-SW"004 RC-142"SW"008 RC"142 "SW"010 RC-142-SW-012 Safety Injection Reactor Coolant Reactor Coolant Reactor Coolant Reactor Coolant Reactor Coolant Reactor Coolant With regard to the above inspection on January 21, 1981, the inspector noted that the completed and accepted Safety Injection System, socket weld flange to-pipe fillet welded joints above were undersized.
FP&L Procedure gI-9. 1 "Visual Inspection of Welds" Attachment 1,
Revision 4,
figure (b)
requires that one inch schedule 160 socket weld flange to pipe joints, like the safety injection system welds above, have a fillet weld leg size not less than -0.350".
The safety injection welds above had fillet weld leg sized 1/16" (0.062")
less than the 0.350" required.
The above and para-graph 3.c are examples of unacceptable conditions, accepted by the licensee's nondestructive examination program, detected, by the NRC inspectors.
The above examples indicate failure to establish adequate controls for nondestructive examination, and is in violation of 10CFR50 Appendix B, Criterion IX.
This violation will be identified 389/81-02-01:
"Failure to Adequately Control NDE".
With regard to the inspection of paragraph 6.b.(5)(a)
above, the inspector noted on all the joints that the licensee was vibroetching joint identification and/or joint fit-up marks inside the one half inch nondestruc-tive examination area of interest.
At the time of thi s inspection, it could not be determined whether the
'arking could mask indications of unacceptable indi-cations.
The licensee indicated that they would look further into the matter.
The inspector stated that the above would be an unresolved item and identified as 389/81-02-03 "Marking in NOE Area of Interest".
Within the area inspected, no violations or deviations except as described in paragraph 6.b.(5)(a)
1 were identified.
7.
Safety-Related Piping The inspector observed non-welding and welding work activities for safety-related piping as described below to determine whether applicable code and procedure requirements were being met.
The applicable code for safety-relat'ed piping is the ASME B and PV Code,Section III 1977 Edition with addenda through Summer 197 t
a.
Observation of Non Welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following; inspection and/or work procedures, record keeping, installation specifications or plans, specified materials, specified NDE, calibration and use of proper test equipment and qualified inspection and NDE personnel.
I
~Activist S stem or Com onent Procedure Storage Valves, Various SgP"3 R-2 (1)
With regard to the above inspection, the inspector noted five valves (4 ASME Class 2 and 1 Class 3) stored contrary to the requirements SgP-3.
This matter fs discussed in detail in paragraph 3.a.
b.
The inspector observed in-process welding activities of safety-related piping field welds as descrfb'ed below to determine whether applicable code and procedure requirements were being met.
(1)
Welding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure; WPS assignment; welding technique and sequence; materias identify; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature; interpass cleaning; process control systems; identify of welders; qualification of inspection personnel; and weld history records.
Joint No.
CC-0039-FM-008 (2)
Meld Heat Treatment Size 8"x0.322" Stage of Fabrication Welding Out
~Sstem Component Cooling Meld heat treatment is dfscussed in paragraph 6.b.(2).
(3)
Welder gualificatfon Welder qualification is discussed in paragraph 6.b.(3).
(4)
Welding Material Control Melding material control is discussed in paragraph 6.b.(4).
Within the area inspected, no violations or deviations were identifie.
Steel Structures and Supports (Unit 2)
The inspector observed welding work activities for steel structures with the containment as described below to determine whether applicable code and procedure requirements were being met.
The applicable code for main steam restraint structures is AWS D 1. 1"74.
Observation of Welding Activities The inspector observed in-process welding activities of containment structural field welds as described below to determine whether applicable code and procedure requirements were being met.
a.
Welding The following welds were examined in process to determine wor k conducted in accordance with traveler, welding procedures available; welding technique and sequence; weld geometry, fut-up electrical characteristics; equipment condition:
Joint No.
Sta e of Fabrication Structure STL-G799-131 Welding Out Hain Steam Restraint (1)
Mith regard to the above inspection, on January'21, 1981, the inspector noted that the welder of record, for the above joint, had by-passed the traveler gC hold point for root inspection.
The Traveler (WRR 2107) required MT or PT inspection of the root.
The licensee stated that they intended the root inspection to be accomplished after backgouging of the root, for crack control.
The welder had been verbally informed of the above intention.
The inspector stated'hat if MT or PT inspection of the root after backgouging had been intended, then the traveler should have been so annotated.
Without the above annotation, the inspection record (the traveler)
would reflect "root inspection" and not "root inspection after backgouging".
Therefore, the record would erroneously state the stage of fabrication at which the inspection was accomplished.
Failure of inspection and test records to identify the type of observation is in violation of 10CFR50 Appendix B,, Criterion XVII. This violation shall be identified as 389/81-02-02,
"Failure to Properly Annotate Inspection Require-ments".
b.
Meld Heat Treatment Meld heat treatment is discussed in paragraph 6.b.(2).
c.
Welder qualification Welder qualification is discussed in paragraph 6.b.(3).
d.
Melding Material Control Welding material control is discussed in paragraph 6.b.(4).'.
Melding Procedure Specification Within the area inspected, no violations or deviations except as described in paragraph 8.a.(1) were identified.
9.
Inspector Followup 'Items (Unit -1)
(Closed) Inspector Follow-up Item (335/80-31-01)
Review of Welder Qualifi-cationn Audit".
Thi s itern involves an
- audit of welder qual ification committed to by the licensee as the -result of a concern reported to NRC:RII.
The inspector reviewed the Licensee's Audit No. QAO-PSL-80-09-203, "Quality Assurance Department Audit of Backfit Melding Qualifications".
The inspector identified no violations or deviations, and has no further questions.
This item is considered closed.