IR 05000335/1981021
| ML17212A966 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/02/1981 |
| From: | Burnett P, Fiedler R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17212A965 | List: |
| References | |
| 50-335-81-21, 50-389-81-17, NUDOCS 8111050560 | |
| Download: ML17212A966 (21) | |
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If UNITEDSTATES NUCLEAR REGULATORYCOMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100
'TLANTA, GEORGIA 30303 Report Nos.
SO-335/81-21 and 50-389/81-17 Docket Nos.
SO-335 and 50-389 Licens'e No.
DPR-67 and CPPR-144 Licensee:
Florida Power and Light Company Facility Name:
St Lucie Inspection Conducted:
August 24-28, 1981 Inspector:
R.
L. Fiedler Approved by:
P.
T. Burne
,
cting e tion Chief Engineering Inspection Branch Engineering and Technical Inspection Branch r'O-/- 8/
Date Signed Date Signed SUMMARY Areas Inspected:
This routine, announced inspection involved 38 insp'ector-hours on site in the area of the review of the preoperational test program.
Results:
Of the one area inspected, no violation or deviation was identified.
Siiio pg ii006 ADOCK 05000335 PDR
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REPORT DETAILS 1.
Person Contacted
"C.
M. Wethy, Plant Manager G. J. Boissy, Startup Superintendent J.
E. Garner, Lead I&C Engineer, Startup R.
E.
Dawson, Lead Mechanical Engineer, Startup
- A. W. Bailey, QA Operations
~G.
E. Walling, Technical Staff E.
Sherman, QA Engineer, Construction
~S.
A. Elrod, Senior Resident Inspector H.
E. Bibb, Resident Inspector
~Denotes those present at the exit interview 2.
Exit Interview The inspection scope and findings were summarized on August 28, 1981 with those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Ins ection Findin s
Not Inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Unit 2 Prep erational Test Pro ram Review The following documents were reviewed:
A.
Chapter 14 of St.
Lucie Plant Unit 2 FSAR f
B.
QI 1-PR/PSL-4 rev.
Start-Up Organization C.
QI 2-PR/PSL-1 rev.
Quality Assurance Program D.
QI 5-PR/PSL-1 rev.
Preparation, Revision, Review/Approval of Procedures E.
QI 11-PR/PSL-1 rev.
Test Control F.
QI 14-PR/PSL-1 rev.
Inspection, Test and Operating Status G.
QI 15-PR/PSL-2 rev.
Discrepancy Correction and Modification During Construction and Testing H.
SQP-64 rev
System Turnover
Administrative Procedure No.
0004021 rev.
Preliminary and Conditional Acceptance of Systems by FPL Power Resources Administrative Procedure No.
0010124 rev.
Control and Use of Jumpers and Disconnected Leads in Safety Related Systems K.
Letter of Instruction No. 0-6 rev.
Jurisdiction. of Systems During Startup L.
Letter of Instruction No.
SU-12 rev.
Preoperational Test Review Group The above documents were reviewed by the inspector in or'der to verify the
'following:
That areas of testing were identified and responsibilities for conducting the following action were assigned:
1.
Flushing and cleaning of NSS and auxiliary systems, and components.
2.
Hydrostatic testing 3.
Instrument calibration 4.
System turnover from the constructor 5.
Functional testing 6.
Electrical, mechanical and instruments and control testing That the test program includes requirements for testing consistent with FSAR commitments.
C.
That tests to be performed have been identified and sequenced.
D.
That the format and content of preoperational test procedures have been specified.
That the required qualifications and responsibility of key personnel in the test program are formally specified in writing.
That the lines of authority and responsibility of test personnel and the method of responsibility for appointing key personnel in the test program are formally specified in writing.
That formal administrative measures have been established for jurisdictional control of system, component, or instrumentation status befor'e, during, and subsequent to testing.
H.
That formal administrative measures have been established governing the conduct of testing including:
1.
Method of verifying a test procedure is current prior to its use.
2.
Methods to assure personnel involved in the conduct of a test are knowledgeable of the test procedures.
3..
Methods to change (both major and minor)
a test procedure during the conduct of testing.
4.
Criteria for interruption of a test and continuation of an interrupted test.
5.
Methods to coordinate the conduct of testing.
6.
Methods to document significant.events, unusual conditions, or interruptions to testing.
7.
Methods for identifying deficiencies, documenting their resolutions, and documenting retesting.
That formal methods have been established to control scheduling of test activities.
J.
That a formal program for evaluation of test results has been established which includes the following:
That test data is properly reduced to meaningful and understandable form.
The test results are checked and compared to previously determined performance standards or limits.
Oeficiencies are clearly identified and appropriate corrective action has been proposed, reviewed, and completed.
After corrective actions or modifications have been completed, tests or portions of a test have been rerun as necessary to
.assure that tests on the as-built system are adequate.
The results of the evaluations are reviewed by appropriate licensee personnel and contractor personnel, including the person(s)
responsible for approving the original test procedures.
K.'hat formal administrative measures have been established which control the Test Procedure process for review, approval and issuance.
L.
That formal administrative measures have been established which control revision of procedures which include the provisions that the revisions be reviewed and approved by the same persons and/or groups as the original procedure.
M.
That a formal method has been established for initiating, reviewing, and approving requests for design changes and modifications to equipment that has been turned over to the test group.
M.
That the review process, including assignment of responsibility, provides for assuring that all proposed plant changes are reviewed for potential FSAR and unreviewed safety question impact.
0.
That a formal method has been established to bring proposed or implemented design changes to the attention of the test group for incorporation into the test program.
P.
That written administrative controls have been established for controlling temporary modifications, jumpers, and bypasses.
- The above areas of the Preoperational Test program appear adequate with
. the following exceptions:
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The required qualifications of key personnel in the test program were not specified in Section 14 of the FSAR.
The experience and qualification of test personnel in the startup staff were not documented in section 13.2 of the FSAR as stated in Section 14 of the FSAR.
The responsibilities and required qualifications of the startup staff are specified in gI 1-PR/PSL-4.
This is an inspection fo1 1 ow-up itern.
( IFI 389/81-17-01)
.
There was no specified method to coordinate the conduct of testing such as a shift test supervisor located at a central location such as the control room which is necessary to maintain the status of plant systems and to record various tests or normal plant evolutions which are in progress.
This is an inspection'follow-up item.
(IFI 389/81"17-02).
There appears to be a potential problem area in verifying that discrepancies identified during the startup testing program are reviewed for 10 CFR 50.55(e) reportability.
The Discrepant Field Coordination Report (DFCR) is used to report construction discrepancies prior to system turnover.
The Field Discrepancy Report (FDR) is used to report minor discrepancies corrected by Power Resources during preoper ational testing.
Discrepancies discovered after system turnover and determined not correctable by Power Resources are returned to construction for correction and added to the exception list of the system turnover package.
In this case no DFCR of FDR i's required to be written.
Therefore, the discrepancy may not receive a timely review for 10 CFR 50.55(e)
r eportabi lity requi rements.
An example of this problem involved defective relays for class IE applications which was reported for the containment spray 2A motor by turnover package correction notice for startup no.
Also, there is no provision on the DFCR or FDR forms to 'verify that the items reported are reviewed for 10 CFR 50.55(e)
applicability.
This is an inspection follow-up item ( IFI 389/81-17-03).
The Field Discrepancy Report has provisions for documenting retest requirements but does not have provisions for documenting satisfactory completion of required retesting.
This is an inspection follow-up item (IFI 389/81-17-04).
The procedure controlling the preparation, revision, review, and approval of procedures does not specify that revisions to procedures and the results of procedures be reviewed by the same persons which reviewed and approved the original procedure when possible.
This is an inspection follow item (IFI 389/81-17-05).
There were no provisions for issuing a single copy of each test procedure designated as the official copy to be used for test documentation as specified in Section 14'.2.6 of the FSAR.
This is an inspection follow-up item (IFI 389/81-17-06).
Section 14.2.3 of the FSAR specifies that the Preoperational Test Review Group (PTRG) review preoperational test procedures and Section 14.2.5 of the FSAR specifies that the PTRG reviews the
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preoperational test results.
However, the members which make up the PTRG or their required qualifications are not described in the FSAR.
This is an inspection follow-up item (IFI 389/81-17-07).
H.
Section 14.2.2.3 of the FSAR states that at appropriate times the NSSS Vendor, Turbine-Generator Vendor, and Architect-Engineer, review test procedures, help with the conduct of the acutal tests or review completed test results.
Section 5.7.3 of gI 5-PR/PSL-1 states that Preoperational procedures of a safety related nature may be reviewed by Combustion Engineering.
QI 5-PR/PSL-1 needs to be revised to require NSSS Vendor, Turbine-Generator Vendor, and Architect-Engineer review of appropriate preoperational test procedures and test results.
This is an inspection follow-up item (IFI 389/81-17-08).
These items were discussed during the exit interview on August 28, 1981.
The licensee would not commit to make any changes to the test program during the exit interview.
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303
'PR 1 6 1981 Florida Power and Light Company.
ATTN:
R. f. Uhrig, Vice President Advanced Systems and Technology P. 0.
Box 529100 Miami, FL 33152 Gentl emen:
Subject:
Report No. 50-335/81.-02 Thank you for your letter of April 6, 1981, informing us of steps you have taken to correct the violations concerning activities under NRC Operating License No.
DPR-67 brought to your attention in our letter of March 12, 1981.
We will examine your corrective actions and plans during subsequent inspections.
We appreciate your cooperation with us.
S'ince y,
cc:
C.
M. Wethy, Plant Manager Nat Weems, Assistant gA Construction Manager
. C.,
c s ng Director Divisio Resident and Reactor Project Inspection
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FLORIOA POWEA d LIGHTCOMPANY April', 1981 L-81-158 Mr. James P. O'Reilly, Director-Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr.. O'Reilly:
Re:
RII:
50-335/81-02 Florida Power 5 Light Company has reviewed the subject inspection report and a
response is attached.
There is no proprietary information in the report.
Very truly yours, Robert E. Uhrig Vice President Advanced Systems 5 Technology
. REU/JEM/ras Attachment cc:
Harold F. Reis, Esquire PEOPLE... SERVING P'EOPLE
4'
ATTACHMENT FINDING A-Technical Specification 3.7.12.a requires that when all electrical penetration fire barriers protecting safety related areas are not intact, a fire watch patrol to inspect at least one.side of the penetration(s)
must be established within one hour.
Contrary to the above, fire barriers were not intact and a fire Hatch patrol was not provided on January 6,
1981, when several penetrations in the cable spreading room were'ound open..
RESPONSE A:
1)
2)
3)
4.)
5)
FPL concurs with the finding.
The finding resulted from inadequate controls.
Immediate action was taken to ensure compliance with applicable specifications..
Additional controls have been instituted which require specific approval for degraded electrical penetration fire barriers.
Full compliance was achieved January 16, 1981.
Licensee Event Report 81-01 was also issued.
FPL would like to point out that the inspector stated he notifed the Nuclear Plant Supervisor (NPS)
on January 6,
1981.
The NPS involved could not recall such notification.
The plant staff took immediate steps when they became aware of this problem immediately prior to the exit interview on January 16, 1981..
Discussions with the NRC-Resident Inspector following this occurrence should provide for more positive communications regarding plant problems.
FINDING B:
CFR 50, Appendix B, Criterion V,.as implemented by Florida Power and Light Company Topical guality Requirement 5.0, requires that activities affecting quality for nuclear safety related structures, systems and components shall be prescribed, and accomplished in accordance with documented instructions.
St.
Lucie implementing procedure, gI-4 PR/PSL-I, provides various requirements for assuring that all technical requirements are included in the purchase orders/requirements and requires QC/gA review and approval.
Contrary to the above, activities affecting quality were not prescribed by documented instructions in that Pacific Scientific Mechanical Snubbers were ordered, reviewed and approved for purchase by Turkey Point personnel, for St.
Lucie.
The purchase order did not require compliance with applicable FPL
'specifications for mechanical snubbers nor did it require certification of comp'liance with applicable functional test requirements of FPL Snubber specifications or of specific St. Lucie technical requirements.
RESPONSE. B:
1)
FPL concurs with the finding.
2)
This order took place in 1978 and is considered an isolated case.
3)
Snubbers were evaluated in 1979 for proper technical requirements.
4)
Changes to applicabTe'uality procedures have been submitted for review and approval.-=
5)
The quality procedure. changes:wre
.expected. to-be completed by.July 1,. 1981.
Full compl-iance on this"ttem will'e'achieved. at. this time:
FINDING C:
CFR 50, Appendix R, Criterion V, as implemented by Florida Power and Light Company Topical guality Requirement 5.0 requires that activities affecting quality of nuclear safety related structures, systems and componehts shall be described by documented instructions, and shall be accomplished in accordance with those instructions.
Implementing procedure, gI-7 PR/PSL-2; paragraph 5.6, requires that qC material shall be receipt inspected using acceptance criteria included in applicable receiving inspection checklists.
Contary to the above, activities affecting quality were not accomplished as described by instructions in that the receiving inspection checklist for Pacific Scientific snubbers purchased.
on Purchase Order Ho.
71059-63078P and 65255-06810M required documentation/certification of compliance with purchase-orders-specified functional tests in accordance with procedure EPP-MS-276.
Certification for the above snubbers veryify conformance with the purchase order and Pacific Scientific functional tests using Pacific Scientific procedure 524L rather than EPP-M-276.
.
No record was available that showed that Pacific Scientific procedure 524L was compared to FPL specification EPP-MS-276 or that Pacific Scientific procedure 524L was even available to qC.
Also, no record was available to show that gC receiving inspection had questioned the situation.
The gC supervisor stated that the case was
.inspector error.
RESPONSE 1)
2)
3)
4)
5)
C:
FPL concurs with the finding.
This is considered to be an isolated case by the inspector.
Snubbers were evaluated. for technical requirements and accepted.
No further action is considered necessary.
FPL is expected to have a written record of this comparison on file May 1, 1981.
STATE'F FLORIDA
)
)
COUNTY OF DADE
)
ss Robert E. Uhrig, being first duly sworn, deposes and says:
That he is a-Vice President of Florida Power 6 Light Company,.
the Licensee herein;-
That he has executed the foregoing document; that the state-
~,
ments made in this said'document are true ance correct to the best. of his knowledge, information, and belief, and that he
. is authorized to execute the document on behalf of said, Licensee..
Robert E. Uhrig Subscribed and sworn to before me this
~aay of co+
NOTARY PUBLIC, and for the county of Dade, State of Florida Notary PublIc, State of Rorlda at Large My Commission Expires October 30, 1993 Ny commission expires=
ebttded tbru Maynard ttondin0 agency
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