IR 05000335/1981015
| ML17212A826 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/05/1981 |
| From: | Bemis P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17212A822 | List: |
| References | |
| 50-335-81-15, NUDOCS 8109290687 | |
| Download: ML17212A826 (17) | |
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NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.WSUITE 3100 ATLANTA,GEORGIA 30303 Report No.
50-335/81-15 Licensee:
Florida Power and Light 9250 West Flagler Street Miami, Florida 33101 Facility Name:
St. Lucie Docket No. 50-335 License No. DPR-67 Inspection t. Lucie s'ear Ft. Pierce, Florida Ins ector:
Approved by:
C.
. Uprig t, S c ion ef Engineering Ins etio ranch Engineering and Technical Inspection Division s,
I Date Signed at Signed SUMMARY Inspection on June 22 - July 2, 1981 Areas Inspected II This routine, announced,,inspection involved 80 inspector-hours on site in the areas of licensee action o'n previous, identified inspection findings, training, requalification training, test and measuring equipment program, surveillance test and calibration control program, 'maintenance program',
and non-routine reporting program.
n Results Of the 7 areas inspected, no vi'olations or deviations were identified in six areas; one violation was found in one area (failure to store training records in fire proof containers, paragraph 5.).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. Anderson, Q.A. Engineer A. Bailey, Q.A. Supervisor
- J. Barrow, Operations Superintendent
~J. Bowers, Maintenance Superintendent
~N. Buchanan, H. P. Supervisor
"P. Fincher, Training Supervisor
~R. Glaze, Training Instructor
~R. Jennings, Technical Superintendent
- C. Leppla, I & C Supervisor
"T. Lyons, QC Supervisor II
"H. Mercer, H.P. Coordinator
~D. Sager, Operations Supervisor
~M. Vincent, Assistant Superintendent-Electrical
~J. Walls, Q.C. Engineer
"C. >Iethy, Plant Manager Other licensee employees contacted included generating equipment maintenance systems planners, technici'ans, operators, nuclear watch engineers, security force members, office personnel, plant coordinators, and engineers.
NRC Resident Inspector
~S. Elrod
"Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on July 2, 1981 with those persons indicated in paragraph
above.
The licensee acknowledged the inspection findings.
3.
Licensee Action on Previous Inspection Findings (92702)
The following terms are defined and used throughout this report:
ANSI AP CAR FRG FSAR GET HP American Nuclear Standards Institute Administrative Procedure Corrective Action Report Facility Review Group Final Safety Analysis Report General Employee Training Health Physics
18(C M&TE NRC NRR OP PAB PC/M PM PWO QA QC QI RO SRO TC TQAR T/S Instrumentation and Control Maintenance and Test Equipment Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Operations Procedure.
Performance Appraisal Branch Plant Change/Modification Preventive Maintenance Plant Work Order Quality Assurance Quality Control Quality Instruction Reactor Operator Senior Reactor Operator I
Training Coordinator Topical Quality Assurance Report Technical Specifications Items of noncompliance from Inspection Report 50-335/80-07 were reviewed with respect to the licensee letter dated June 12, 1980.
(Closed)
Deficiency (335/80-07-04):
Failure to follow procedures audit response.
As stated in the cover letter to report 50-335/80-07 the immediate corrective actions were completed and verified by the inspector prior to completi,on of the 335/80-07 inspection.
The inspector questioned QA personnel to ensure they understood the intent and details of Quality Procedure 16. 1, corrective action, relative to requirements of the action to be taken when no audit response was received.
The inspector found the individuals to be knowledgeable and did not identify further examples of noncompliance.
(Closed) Deficiency (335/80-07-09):
Failure to follow procedure.
The inspector reviewed the disconnected lead and temporary jumper log and found that the responsible supervisors had made the required reviews.
The inspector also reviewed OP 0030120, Section 8.4, Pre-Start Checkoff List, Revision 8 dated 5/81 to ensure the change had been made to require the cognizant signature.
(Closed)
Unresolved (335/80-07-03):
Implementation of cleanliness requirements beyond the
"routine" level.
The inspector reviewed AP0010430 Maintenance of Seismic Class Systems, Revision 5 dated 6/80 to ensure specific requirements relative to cleanliness levels were delineated.
This item is also discussed in paragraph 11, item (335/
79-21-10).
(Closed)
Unresolved (335/80-07-06):
Small water leak in warehouse.
The inspector reviewed the corrective action with the maintenance superintendent and found a
PWO was issued by the stores group.
The mechanical maintenance department located the leak, corrected the leak
and a water tight sealant was applied to the roof.
The inspector also walked through the warehouse twice after very heavy thunderstorms and did not identi fy any further leakage.
(Cl osed)
Unr eso 1 ved (335/80-07-08):
Incompl ete documentati on.
The inspector reviewed CAR 5-16-80 which verified that procedures for completion of work on PC/M 485-78 had been returned to the plant from the contractor's office and had been uncorporated into the PC/M pack-age.
(Closed)
Unresolved (335/81-02-03):
Failure to have an adequate program for storage of quality controlled material.
The licensee has revised (}I-13-S-I Operating Stores/Handling, Storage and Shipping and now defines in Revision 6 dated 6/81, a-program for shelf life on warehouse items which relate to safety and these items will fall under the gC surveillance program.
(Closed)
Unresolved (335/81-02-04):
Failure to establish or implement adequate non-licensed training programs. 'he part'icular training program addressed'y the PAB report dealt with the Journeyman Mechanical Maintenance Training Program in maintenance procedure M-001.
The licensee has cancelled the training requirement in M-001 and developed a
new procedure to cover this training.
The inspector reviewed AP0010435, Maintenance Department Training Program, Revision
dated 6/81 and found this to be an adequate program.
The inspector interviewed personnel in the maintenance discipline and found that the licensee is implementing its defined program.
The inspector also found that speciality groups other than mechanical maintenance were devel-oping and implementing training for their personnel.
(Closed)
Unresolved (335/81-02-05)
Failure of departmental training coordinators to always submit monthly training reports.
As of 6/81 all TC's had submitted the required reports to the training supervisor.
In addition to sending in the required reports, the licensee has changed the monthly training reports to require a
copy to be sent to the training supervisor.
(Closed)
Unresolved (335/81-02-06):
Failure of licensed operators to complete requalification program.
During the inspector's audit of the requalification program it was identified that the licensee was meeting the requirements of the NRC, in that any individual who did not pass the annual requalification examination was removed from licensed duties until such time that the individual attended an accelerated program and passed an annual exam.
(Closed)
Unresolved (335/81-02-07):
Failure to perform gC surveillance on the training department.
The gC department provided the inspector with the following audits to show its increased surveillance of the training departmen Audit number 7667, 6/18/81, Hot license training Audit number 7653, 4/07/81, Training files Audit number 7670, 6/26/81, Station training Audit number 7363, 11/10/80, I&C training Audit number 6845, 1/03/80, Mechanical maintenance training records The gC department also provided a master surveillance schedule which included training audits.
(Closed)
Unresolved (335/81-02-10):
Failure to have an adequately detailed quality control surveillance program.
The inspector reviewed the following revised gI's to insure adequate program details and guidance for the gC surveillance program:
gI-5 PR/PSL-1 Preparation, Revision, Review/Approval of Procedures, Revision 15 dated 4/81, Section 5.2.6 provides guidance in 17 specific areas and Section 5.5.4 defines tracking for temporary changes.
gI-18/PR/PSL-2, gC Surveillance, Revision 8 dated 6/81 shows requi re-ments for what is to be survei lied.
(Closed)
Unresolved (335/81-02-13):
Inadequate plant work orders.
PWO 2928 was properly torqued on PWO 2997 dated 12/3/80 and was attached to PWO 2928.
PWO 2929 will be corrected on PWO 12417 which has already been written and is to be worked during the 1981 refueling outage.
(Closed)
Unresolved (335/81-02-16):
Failure to obtain FRG approval prior to changes to AP-0010123 (Valves, Locks).
The inspector reviewed AP-0010123, Administrative Control of Valves, Locks and Switches, Revision 25 dated 5/81, and identified that all changes to switch and valve lists must go through FRG.
(Closed)
Unresolved (335/81-02-17)
Program for evaluation of opera-tional events and initiating reports to the NRC.
A new procedure was developed by the licensee to cover evaluation and reporting require-ments via a
log system.
This procedure is AP0005724, Operating Experience Feedback, Revision 0 dated 1/81.
The inspector reviewed this procedure and found it to be adequate.
(Closed)
Unresolved (335/81-02-19):
Certain instructors do not, have an SRO license.
The licensee wrote a letter to the NRC in response to Nureg 0737 item ¹I.A.2.3 requiring instructors who teach systems or integrated plant response to hold an SRO license.
In that letter the licensee only committed to using nonlicensed instructors with many years experience to teach systems under the guidance of an individual who holds an SRO license, until such time that these nonlicensed individuals could obtain a license.
The licensee is following that commitment and is presently upgrading their instructor p.
(Cl osed)
Unresol ved (335/81-08-06)
Fai l ure of pl ant management to provide direction and guidance for various departmental training programs.
The licensee holds monthly meetings between management and all training department coordinators in which all facets of training are discussed.
Since the PAB report, the licensee has begun develop-ment of departmental training programs under the direction of plant management to include the training supervisor.
(Closed)
Unresolved (335/81-08-08):
Inadequate QC involvement in PC/M activities.
The licensee revised QI-18 PR/PSL-2, QC Surveillances, such that Revision 8 dated 6/81, Appendix A now lists the requirements for what is to be surveilled.
(Closed)
Unresolved (335/81-08-09)
QA department did not review all PC/M's 'to ensure that all quality requirements were addressed.
QI 18 PR/PSL-2, QC Surveillance, Revision 8 dated 6/81, Section 5.4.3 details the review of all PC/M's to ensure all quality requirements are met.
s.
(Closed)
Unresolved (335/81-08-10):
Failure to ensure all associated procedures, instructions, and drawings were revised as required at the time of the PC/M implementation.
Letter Bk. h'1367 issued by the plant manager to all department heads at St.
Lucie plant addressed work start and completion for PC/M's and also generated a
new form to be filled out by cognizant personnel.
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(Closed)
Unresolved (335/81-02-11):
Failure to include equipment clearance procedures in maintenance and surveillance instructions and to obtain proper approval of equipment clearance procedures.
The licensee has made a
change to its procedure covering clearances in OP0010122, In-plant Equipment Clearance Orders, Revision 12 dated 4/81 implementation and approvals of clearance procedures are satisfactory.
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.
New unresolved items identified during this inspection are discussed in paragraphs 6a and b.
5.
Training (41700)
References:
(a)
(b)
(c)
(d)
(e)
(f)
T/S 6.4, Training FSAR 13.2, Conduct of Operations ANSI 18. 1-1971 Selection and Training of Nuclear Power Plant Personnel Regulatory Guide 1.8, Personnel Section and Training Regulatory Guide 8. 13, Prenatal Radiation Exposure QI 2-PR/PSL-2, Plant Staff Training Revision 8 dated 10/80
This inspector reviewed the training program which provides GET for both licensed and nonlicensed personnel to.insure the program meets the require-ments of the above references which were committed to by the licensee.
The specialty group training programs were reviewed to insure formal technical training commensurate with the job classification and QC surveillance of the training programs.
The inspector reviewed 60 training records of the unit operating personnel and interviewed 20 people as to the training they were receiving.
At the time the inspector reviewed the licensee's nonlicensed training program for the specialty groups, the inspector found the licensee in an indepth development program for nonlicensee training in response to the PAB inspection (PAS-80-4).
The inspector reviewed the licensee's development to date and projected development and found the direction of the development to be satisfactory.
Inspector followup items 50-335/81-08-02; 81-08-03; 81-08-04; 81-08-07 and 81-08-11 remain open pending completion of the training program developement.
Based on this review, one violation was identified.
T/S 6. 10.2(g) requires training and qualification records of plant staff to be stored.
QI
PR/PSL-1, QA Records, Revision 3, states in part that permanent storage shall be in the vault and temporary storage in fire proof containers.
>!hen the inspector contacted the training coordinators fo'r the individual depart-ments, two out of the four departments contacted were storing training records in containers not meeting the 1 hr fire rating.
This failure to store records in fire proof containers is a violation (335/81-15-01).
6.
Requalification Training (41701)
References:
(a)
10 CFR 55 Appendix A, Operator Requalification (b)
ANSI 18. 1 1971, Selection and Training of Nuclear Power Plant Personnel (c)
Regulatory Guide 1.8, Personnel Selection and Training (d)
FSAR 13.2, Conduct of Operations (e)
T/S 6.4, Training (f)
QI-2 PR/PSL-2, Plant Staff Training, Revision 8 dated 10/80 (g)
AP0005721, Hot License Operator Training Program, Revision 3 dated 8/80 The implementation of the accepted requalification program was reviewed to verify that the licensee has prepared a schedule for conducting lectures and prepared lesson plans for the lectures presented.
The inspector reviewed the following areas:
retraining conducted; copies of annual written and oral examinations; documentation of attendance at required lectures; docu-mentation of required reactivity manipulations; and, documentation of procedure and change review.
Based on this review, two unresolved items were iden'tified and are discussed in the following paragraphs.
a.
Failure to Follow NRC Criteria for Annual Requalification Examination The NRC criteria for passing either an RO or SRO written examination is a score of 80% overall and at least 70% in each section.
If an indi-
vidual makes less than 70% in a section, he must retake that section and, if he makes less than 80% overall, he must retake the entire examination.
Individuals making less than 80% are not retaking the entire examination.
Since these criteria are not specifically spelled out, this item is being referred to NRC management for resolution and shall be carried as unresolved (335/81-15-02) until resolution is made.
b.
Failure to Follow Procedure Reference (F) requires quizzes to be given for makeup within 60 days of the original quiz.
Upon reviewing the requalification lectures and quizzes, it was found that 18 people had missed as many as 3 quizzes and at least 2 persons were more than 60 days overdue.
The inspector reviewed a
memo from the operations supervisor requiring the delequent individuals to make up their quizzes with suspense dates.
This item will be carried as unresolved (335/81-15-03) until it can be determined if the individuals meet their suspense dates and NRC management can be consulted as to the large number of individuals missing quizzes.
7.
Test and Measurement Equipment Program (61724)
References:
(a)
QI 11 PR/PSL, Test Control Series, Revision 4 dated 3/79 (b)
QI
PR/PSL-1, Calibration -of Measuring and Test Equipment, Revision 7 dated 8/79 (c)
QI
PR/PSL-2 Calibration of ILC Department M&TE, Revision 7 dated 8/79 (d)
QI 12 PR/PSL-3, Electrical M&TE, Revision 7 dated 8/80 (e)
QI 12 PR/PSL-4, Mechanical Maintenance M&TE, Revision
dated 2/81 (f)
QI 12 PR/PSL-5, Chemistry M&TE, Revision 1 dated 6/79 (g)
QI 12 PR/PSL-6, H.P.
M&TE, Revision 7 dated 10/79 (h)
QI
PR/PSL-7, Calibration of Installed Plant Instru-mentation and Control Equipment, Revision 3 dated 11/79 (i)
QI 7-PR/PSL-2, Receiving Inspection, Revision 9 dated 4/81 (j)
QI 17 PR/PSL-1, QA Records, Revision 3 dated 10/79 The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program.
The review was concerned with shop standards and portable measuring and test equipment.
The licensee's practices were reviewed to verify the following:
Criteria and responsibility for assignment of calibration frequency have been established An equipment inventory list has been established which identifies the calibration frequency, standard and procedure for all equipment to be used for any reason on safety-related structures, systems or components
Formal requirements exist for marking the date of the latest inspec-tion/calibration on each piece of equipment or otherwise identifying the status of calibration Systems are provided to assure that each piece of equipment is cali-brated on or before the date required and that new equipment will be added to the list and calibrated prior to use Controls have been established to prohibit the use of equipment which has not been calibrated within the prescribed frequency Controls have been established to ensure that when a piece of equipment is found out-of-calibration, the acceptability of items previously tested with the equipment will be evaluated and documented and the cause of the equipment being out-of-calibration will be evaluated Responsibilities have been assigned to assure accomplishment of the above.
Based on this review, no violations or deviations were identified.
8.
Surveillance Test and Calibration Program (61725)
References:
(a)
AP0010125, Schedule of Peri odic Test Checks and Cali-
,bration Operations and IKC Schedule, Revision 38 dated 6/81 (b)
AP0010127, Reactor Engineering Schedule of Periodic Tests and Reports, Revision 5 dated 9/78 (c)
AP0010437, Schedule of Maintenance Surveillance Require-ments, Revision 8 dated 8/80
~
(d)
HP 4, Scheduling of H.P. Activities, Revision 11 dated 11/80 (e)-
EV01, Schedule for Periodic Testing Chemistry Oepart-ment, Revision 2 dated 12/80 (f)
T/S 6.8, Procedures (g)
10 CFR 50.55a, Codes and Standards (h)
ANSI 18.7 - 1972, Administrative Controls for Nuclear Power Plants (i)
Regulatory Guide 1.33, Appendix A, Typical Procedures for Pressurized Mater Reactors The inspector reviewed the licensee's program to ensure development and implementation of a program for control and evaluation of:
surveillance testing, calibration and inspection required by the above references, inservice inspection of pumps and valves; and, calibration of safety related instrumentation not specifically controlled by T/S.
Based on this review, no violations or deviation were identifie.
Maintenance (62702)
References:
(a)
AP0010432, Plant Work Orders, Revision 15 dated 6/80 (b)
AP0010430, Maintenance on Nuclear Safety-Related or Seismic Class I Systems,. Revision 5 dated 6/80 (c)
ANSI 18.7-1972, Administrative Controls for Nuclear Power Plants (d)
QI
PR/PSL-4, Mechanical Maintenance Measuring and Test Equipment, Revision 5 dated 2/81 The inspector selected safety-related maintenance activities (listed below)
performed in connection with each of the following systems:
reactivity control/power distribution instrumentation reactor coolant system emergency core cooling systems containment systems plant and electrical power systems.
For each activity selected, the inspector verified that, as applicable:
the limiting conditions for operation were met while components were removed for maintenance; required administrative approval(s)
were obtained prior to initiating work; approved procedures were used; provisions were made for fire protection, cleanliness, and housekeeping; required QC inspections were conducted; functional testing was performed; and, tests were performed by qualified personnel.
The inspector also verified that QC records were available for items listed below:
PWO 3125 PWO 3090 PWO 3128 PWO 3149 PWO 3155 PWO 3960 PWO 3942 PWO 3964 Auxiliary feedwater pump steam inlet flange Clean strainer Centrifugal charging pump seal leak Component cooling water pump seal leak Boric acid makeup pump packing replaced Replace hydraulic with mechanical snubber s Open and close primary manway and install nozzle dams on steam generator Reactor coolant pump seal replacement Based on this review no violations or deviations were identified.
10.
Nonroutine Reporting (90714)
References:
(a)
AP0010721, Non routine reporting, Revision 5 dated 6/81 (b)
QI16-PR/PSI-l, Corrective Action, Revision 8 dated 6/81 (c)
AP 0005724, Operating Experience Feedback, Revision
dated 1/81 (d)
PR 3418, Operating Experience Feedback, dated 1/81
The inspector review the licensee's program to ascertain whether responsi-bilitiess had been assigned for review and evaluation of offnormal operating events, planned and unplanned maintenance activities, surveillance testing and outage activities to assure conformance with regulatory requirements.
The inspector also reviewed the program to ascertain whether vendor bulle-ntins and ci rculars are reviewed for applicability.
Based on this review, no violations or deviations were identified.
11.
Licensee Action on Previous Identified Inspector Items (Closed) Inspector followup Item (335/79-21-10):
Cleanliness levels in work area.
The licensee trains mechanics as to levels of cleanliness required rather than documenting cleanliness levels on P'WOs.
The inspector observed two different maintenance activities to insure cleanliness levels were being maintained.
(Closed)
Inspector Followup Item (335/79-21-11):
Classification of control element assemblies.
In the licensee's FSAR, Table 3.2. 1, control rod drive mechanisms are exempted from the controls of the QA Program.
This item was referred to NRC management for adequacy.
Management determined that the controls discussed in the FSAR were adequate.
C.
(Closed)
Inspector Followup Item (335/79-21-12):
Illegible copies of PWO's.
The problem with the PWO's was due to failure by the writer to change the carbon between the PWO sheet when writing on the back of the page.
This item has been corrected by the use of a new paper which does not require carbon paper to be used.
PWO's now appear in legible form.
d.
(Closed)
Inspector Followup Item (335/79-21-13):
Additional review of maintenance.
As part of the inspector's review of maintenance, seven PWO's listed in paragraph
were looked at to ascertain if their removal for maintenance or fai lure was reportable under T/S.
(Closed)
Inspector Followup Item (335/79-21-14):
Correcting QA/QC documents.
As a result of this item the licensee issued a
CAR on September 7,
1979.
In response, the QC supervisor issued a memo to all holders of controlled documents requesting any illegible controlled documents to be turned into document control so legible replacements could be provided.
The inspector reviewed over one hundr'ed controlled documents during the inspection that were located in eight different areas and did not identify any illegible documents.
(Closed) Inspector Followup Item (335/80-07-05):
Items referred to NRC Management for review.
Both of the items addressed in this item were awaiting NRR approval of the licensee's Revision 3 to the TQAR.
This revision was approved without change to the audit distribution syste l g4
(Closed)
Inspector Followup Item (335/80-07-07):
Item referred to NRC management for evaluation.
This item was awaiting NRR approval of Revision 3 to the TQAR.
NRR approved FP5L's method of designating safety related components in Revision 3.
(Closed) Inspector Followup Item (335/81-08-24):
QI 1 PR/PSL-2 did not identify responsibility and qualification of AEO nor require NklS to hold SRO license.
In revision 14 dated 6/81 of QI PR/PSL-2, Operating Organization, Section 52, the licensee defines the responsibilities and qualifications of the AEO.
AP0010120, Duties and Resonsibilities of Operators on Shift, Revision 14 dated 6/81 requires the NWS to have a
SRO licensees (Closed)
Inspector Followup Item (335/81-08-25):
Lack of method for reviewing, approving, documenting, and tracking temporary changes.
This item is discussed in the close out of item 335/81-02-10 in para-graph 3.k.
(Closed)
Inspector Fol 1owup Item (335/81-08-28):
QC operations sur-veillance group had no written program to identify selection process or sample size of activities inspected.
QI-18 PR/PSL-2, QC Survei llances, Appendix A, Revision 8 dated 6/81 shows all requirements for what is to be surveilled to include selection process and sample size.
(Closed)
Inspector Followup Item (335/81-08-29):
Plant corrective action system did not include IE information notices.
QI 16 PR/PSL-1, Corrective Action, Revision 8 dated 6/81, Appendix A, reflects IE information notices into the plant corrective action system.
(Closed) Inspector Followup Item (335/81-08-30):
Corrective system did not address
CFR 19. 11(A)(4) requirements to post notices to workers.
QI 16 PR/PSL-1, Corrective Action, Revision 8 dated 6/81, Appendix A
now specifically addresses 10CFR19. 11 requirements.
(Closed)
Inspector Followup Item (335/81-08-35):
FRG Charter does not include all T/S requirements.
Section 5.0 of AP0010520 Revision
dated 6/81 lists all items which must be FRG approved and all T/S requirements are included in this list.
(Closed)
Inspector Followup Item (335/81-08-46):
Failure to provide training requested by an auditor.
The inspector reviewed the training of all auditors and found that the licensee was meeting their commit-ments to the NRC and is presently upgrading the training given to all plant personne W~
e