IR 05000335/1982003
| ML20053A861 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/24/1982 |
| From: | Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20053A842 | List: |
| References | |
| 50-335-82-03, 50-335-82-3, NUDOCS 8205270364 | |
| Download: ML20053A861 (14) | |
Text
__
.
8[
%,
UNITED STATES NUCLEAR REGULATORY COMMISSION o
-
r REGION il
'*
101 MARIETTA ST., N.W., SUITE 3100 o
o[
ATLANTA, GEORGIA 30303
.....
Report No. 50-335/82-03 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 site near Ft. Pierce, FL Inspectors:
tW Of'
M
' ~Be i n le W/
Ofte signed
,
3 _/_ Si ned P. E. Fredr13 son D te k
Ze, 3
& B 2-~
-
~
P. H. Skinner Date Signed Approved by: k[
bf L
-
C. M. Upright, Se tionfiief Dpte SVgned Engineering Ins ctiorVBranch Division of Engineering and Technical Programs SUMMARY Inspection on February 16-19, 1982 Areas Inspected This routine, unannounced inspection involved 78 inspector-hours on site in the areas of licensee action on.nrevious enforcement matters; QA program review; organization and administration; design changes and modifications; onsite review committee; audits and audit implementation; calibration; surveillance; and maintenance.
Results
,
Of the nine areas inspected, no violations or deviations were identified in eight areas; two violations were found in one area (failure to follow procedures on
,
plant work orders, paragraph 12.a; and failure to provide measures required to f
control maintenance activities, paragraph 12.b).
l 8205270 36I j
t
.
.
.
REPORT DETAILS 1.
Persons Contacted Licensee Employees R. Adams, GEMS Planner, Electrical
- A. Bailey, QA Operations Supervisor
- J. Bowers, Maintenance Supervisor H. Cooper, GEMS Planner, Maintenance
- D. Gilbert, Security Supervisor F. Gross, GEMS Planner, Mechanical
- R. Jennings, Technical Support Supervisor
- C. Leppla, I&C Supervisor
- J. Porter II, EPP (Backfit) Power Plant Engineer L. Rich, Watch Engineer N. Roos, QC Supervisor H. Villar, GEMS Planner, Maintenance
- M. Vincent, Electrical Supervisor
- J. Walls, QC Inspector
- D. West, Nuclear Plant Support - Operations
-
- J. West, Security Supervisor
- C. Wethy, Plant Manager
- C. Wilson, Mechanical Maintenance Other licensee employees contacted included technicians and office per-sonnel.
NRC Resident Inspector
- H. Bibb, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 19, 1982, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspection findings.
3.
Licensee Action on Previous Enforcement Matters The following items are defined and used throughout this report:
Accepted QA Program Topical Quality Assurance Report FPLTQAR 1-76A Revision 4 FRG Facility Review Group
- - -.
.
I&C Instrumentation and Control PWO Plant Work Order a.
(Closed) Deficiency (335/79-21-01):
Failure to Follow Procedure QI 12-PR/PSL-4.
This item was reviewed with respect to licensee correspondence dated October 3, 1979 (L-78-281).
The inspectors reviewed the measuring and test equipment (M&TE) log and selected PW0s to verify that when M&TE is utilized the serial number of the item is annotated on the log sheet and on the PWO.
b.
(Closed) Unresolved Item (335/80-07-01):
Quality Assurance / Quality Control Administration.
The inspector reviewed the licensee's audit program as discussed in paragraph 9.
The inspector reviewed corrective actions taken on several deficiencies identified during licensee audits and verified that the cause of each deficiency appeared to be ade-quately determined.
c.
(Closed) Unresolved Item (335/81-02-12):
Failure Of Maintenance Instructions (Plant Work Orders) To Have Prior FRG Approval.
Dis-cussions with the resident inspector indicated that this item pertains to Plant Work Orders (PWO) being reviewed by the FRG.
There is no requirement for PW0s to be reviewed by the FRG, but the maintenance instructions or procedures that are referenced on a PWO are required to be appoved by the FRG.
This item is closed based on the open item
,
discussed in paragraph 12.c of this report.
f d.
(Closed) Unresolved Item (335/80-07-02):
Review of Revision to FP&L Topical Report.
(1) Housekeeping and Cleanliness Program The inspector reviewed the accepted QA program and identified that the licensee has taken exception and provided a suitable alter-native to the zone classification of plant areas required by ANSI N45.2.3-1973.
(2) Organization and Administration The inspector reviewed the accepted QA program and identified that organizational changes due to Revision 4 dia not have any adverse impact on QA organization and administration.
(3)
Exception to ANSI N45.2.12 The inspector reviewed the accepted QA program and identified that the licensee has taken exception to and provided suitable justi-fication for not holding a preaudit conference as required by ANSI N45.2.12-1977 for audits of limited scope and of specific site activities conducted by the Construction and Operations Group.
i l
___
>
.
-
.
(4) Exceptions to ANSI N45.2.2 The inspector reviewed the accepted QA program and identified that the licensee has taken exception to and provided suitable alter-natives to sections of ANSI N45.2.2.
e.
(Open) Violation (335/81-15-01):
Failure To Properly Store Training Records.
This item was reviewed with respect to licensee's corre-spondence dated September 8. 1981 (L-81-392).
The licensee ordered file cabinets to meet the requirements of QI 17 PR/PSL-1, Quality Assurance Records, Revision 4 (1-hour fire rating) in December 1981.
These cabinets had not been received at the time of this inspection due l
to a supplier's shipping problem, f.
(Closed) Unresolved Item (335/81-15-02):
Failure To Follow NRC Criteria For Annual Requalification Examination.
The inspector reviewed the NRC criteria for annual requalification examinations with cognizant training personnel. The licensee has upgraded the training requirements to reflect NRC criteria. One person in question has been dropped from the requalification program and his license has been allowed to lapse. No other personnel currently in training were in question relative to examination grading.
g.
(Closed) Unresolved Item (335/31-15-03): Failure To Follow Procedure.
'
The inspector reviewed Corrective Action Commitment Request (CACR)
8-6-81 and determined that all personnel, except two, had made up the necessary quizzes that had been missed. Two individuals are awaiting NRC examinations to be administered in March 1982.
Successful com-pletion of the NRC examinations will satisfactorily meet the require-ments for retraining quizzes.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
QA Program Annual Review (35701)
References:
(a) QP 2.2, Revision of the Topical Quality Assurance Report, Revision 2 (b) QP 2.3, Preparation and Revision of Quality Procedures, Revision 5
(c) QP 2.4, Preparation and Review of Quality Instructions, Revision 2 l
.
_ - _ _ _ _.
..
-
.__
>
.
.
.
(d) QP 2.7, Identification of Safety-Related Structures, Systems and Components, Revision 1 (e) QP 2.8, Cleanliness Cortrol Methods, Revision 3 (f) QP 2.9, Qualification of QA Audit, QC Inspection, and Construction Test Personnel, Revision 4 (g) QP 5.1, Quality Plant Procedures, Revision 3 (h) QP 8.1, Identification and Control of Materials, Parts and Component ; at the Plant Site, Revision 1 (1) QP 9.2, Control of Special Processes During Operational Phase, Revision 2 (j) QP 10.5, Preoperational (Baseline)
Examination, Revision 0 (k) QP 10.6, Inservice Inspection (ISI), Revision 1 (1) QP 14.1, Inspection, Test and Operating Status During Plant Operation, Revision 2 The licensee submitted QA Program, Revision 3 to NRR on December 17, 1980.
This revision was not accepted due to the request for additional information by NRR (letter, W P. Haass to R. E. Uhrig dated February 4, 1981).
The licensee submitted Revision 4 to NRR on April 3, 1981. Revision 4 provided the additional information and was accepted by NRR (letter, W. P. Haass to R. E. Uhrig dated May 14,1981).
The inspector reviewed the references listed above as well as those mentioned throughout this report and verified they met requirements of the accepted QA Program and Regulatory Guides endorsed by that program.
Based on this review, no violations or deviations were identified.
6.
Organization and Administration '36700)
References:
(a) Technical S.,cifications Section 6.2.2 (b) Quality Assu. ance Manual (c) QI 1-PR/PSL-1, Plant Organization, Revision 7 (d) QI 1-PR/PSL-2, Operations Organization, Revision 3 (e) QI 1-PR/PSL-3, Instructions for Maintenance Organiza-tion, Revision 3 (f) QI 1-PR/PSL-4, Startup Organization, Revision 4 (g) QI 1-PR/PSL-7, Quality Control Organization, Revision 2
,
.
.
,
.
.
The inspector reviewed references (b)-(g) and verified they met the require-ments of reference (a). The inspector verified the following aspects of the licensee's organization and administration:
Personnel qualification levels are in conformance with regulatory
-
requirements endorsed in Technical Specifications
-
Lines of authority and responsibilities are in conformance with Tech-nical Specifications Changes in organizational structure have been reported to the NRC.
-
The inspectors reviewed the qualifications of 28 personnel including the plant manager, all superintendent and supervisory positions, and several technical positions.
During this review, the inspectors identified that certain position titles and additional lines of authority discussed in references (b) and (c) are not consistent with those of reference (a). These changes do not degrade the organizational structure. The licensee is in the process of submitting a revision to reference (a) as well as updating references (b) and (c) to provide consistency between these documents.
This lack of consistency between references (a), (b), and (c) was identified as an inspector concern to the licensee.
7.
Design, Design Changes, and Modific cions (37700 and 37702)
References:
(a)
TQR 3.0, Design Control, Revision 3 (b) TQR 11.0, Test Control, Revision 0 (c)
TQR 15.0, Corrective Action, Revision 2 (d) QP 3.1, Evaluation of Contractor Design, Revision 2 (e) QP 3.2, Identification and Control of Design Interfaces, Revision 2 (f) QP 3.4, Plant Changes and Modifications for Operating Plants, Revision 4 (g) QP 3.6, Control Of FPL Originated Design, Revision 3 (h) QP 6.4, FPL Drawing Control, Revision 1 (1) QI 3-PR/PSL, Design Control (After Fuel Loading),
Revision 8 (j) AP 0010130, Administrative Control of Backfit Activi-ties, Revision 4
___
_
_
.
. -
_
,
.
.
.
(k) CPL: ASP-11, St. Lucie Unit 1 Construction Turnovers, Revision 1 The inspector reviewed the references to assure they met the requirements of the accepted QA Program. The inspector verified the following aspects of the design change program:
-
Procedures have been established for control of design changes
-
Procedures for design change document control have been established
-
Controls require that documentation of design change and review processes were performed and transmitted to records storage
-
Controls. require that design changes be performed in accordance with approved procedures j'
-
Controls rekuire that post-modification testing be performed and results evaluated
-
Controls of similar requirements exist for jumpers and lif ted leads.
To verify implementation of the previously stated aspects of the design
-
change program, the inspector reviewed five design changes that had been installed during the latest Unit 1 outage.
The following design changes (plant change / modification) were reviewed:
Pjant Change / Modification Topic 153-80 CST Redundant Level 152-80 CST Cross-Tie '
142-80 TMI Shielding 69-81 RCP Seal 17-81 Pressurizer Prest"re Recorder Based on this review, no violationf or deviations were identified.
8.
Onsite Review Committee (40700)
References:
(a) Technical Specifications, Section 6.5.1 (b) ANSI N18.7-1972 (c) AP 0010520, Facility Review Group, Revision 7 The inspector reviewed FRG activities to assure that they met requirements of references (a) and (b).
The inspector verified membership / quorum requirements, review processes, and meeting frequencies for 13 FRG meetings (numbers 82-01 - 82-13) conducted in January 1982.
Discussions with the resident inspectors also verified that they have attended FRG meetings. The results of the residents inspections are documented in their monthly inspec-tion reports.
-
.
.
.
Based on this review, no violations or deviations were identified.
9.
Audits, Audit Implementation (40702, 40704)
References:
(a) QP 18.1, Conduct of Quality Assurance Department Audits, Revision 5 (b) QP 16.1, Corrective Action, Revision 5 (c) QI 18 QAD2, Auditing of the Quality Assurance Committee Company Nuclear Review Board and the Quality Assurance Department, Revision 0 (d) QI 16 QAD4, Corrective Action Follow-up For QA Depart-ment Open Items, Revision 4 (e) QI 16 QA05, St.
Lucie Projects Quality Assu ance Surveillances, Revision 1 The inspector reviewed references (a) - (e) and verified they met require-ments of the accepted QA Program and ANSI N45.2.12-1977 as endorsed by that program.
The inspector verified the following aspects of the audit and audit implementation program:
-
The content of the audit reports clearly define the scope of the audit and the results
-
Audits are conducted by trained personnel not having direct responsi-bility in the area being audited
-
Frequency of audits is in conformance with Technical Specifications and the accepted QA Program i
-
Appropriate follow-up actions had been taken for deficiencies identi-l fied during the audit l,
The audited organization's response to the audit findings was in
-
writing, timely, and addressed the findings and recommendations l
l
-
QA personnel conducting the audit meet education, experience, and
'
qualification requirements for the audited activity.
The inspector reviewed the results of 23 audits conducted during 1981. The inspector reviewed the qualifications of four lead auditors.
Based on this review, no violations or deviations were identified.
_.
.
.
.
.
10.
Calibration (56700)
Reference:
(a) TQR 12.0, Control of Measuring and Test Equipment, Revision 1 (b) QP 12.1, Calibration and Control of Measuring and Test Equipment, Revision 3 (c) QP 12.2, Calibration Control of Installed Plant Instru-mentation and Control Equipment, Revision 1 (d) QI 12-PR/PSL-1, Calibration of Measuring and Test Equipment, Revision 7 (e) QI 12-PR/PSL-2, Calibration of Instrumentation and Control Department Measuring and Test Equipment, Revision 7 (f) QI 12-PR/PSL-3, Electrical Measuring and Test Equipment, Revision 8 (g) QI 12-PR/PSL-4, Instructions for Mechanical Maintenance Measuring and Test Equipment, Revision 5 (h) QI 12-PR/PSL-7, Calibration of Installed Plant Instru-ment and Control Equipment, Revision 3 (i)
I&C Department Procedure 1400064, Installed Plant Instrument Calibration, Revision 14 (j) MP 099060, Five Year Overhaul Calibration Check of Installed Metering Equipment (+25%), Revision 3 Utilizing the licensee's calibration program as described in the references, the inspector verified that selected instruments and measuring and test equipment (M&TE) had received proper calibration according to the following criteria:
-
For completed calibrations, documentation was complete, acceptance criteria met, proper revision used, and calibration conducted by qualified individuals
-
For calibration procedures, reviews are as required by Technical Specifications, controls are established to meet limiting conditions for operation, equipment is returned to service, calibration equipment is traceable, and acceptance values are within required limits
..
.
-
.
-
For M&TE, equipment is controlled by site procedures, calibration frequency is maintained, storage of equipment is proper, and accuracy is traceable to the National Bureau of Standards or other independent testing organization.
The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspectors.
Discussions with the residents revealed that a review of the M&TE program implementation had not specifically been conducted.
Consequently, the inspector selected several torque wrenches, micrometers, and electronic test instruments and verified that the required calibration controls had been implemented.
Based on this review, two inspector follow-up items were identified and are discussed in the following paragraphs.
a.
Documentation of I&C Calibration Frequency Regulatory Guide 1.33, 1972 requires that safety-related installed instruments be calibrated on a specified frequency. Reference (i) is the procedure which controls this type instrument for the I&C depart-ment.
The planner has a schedule for the instruments and is main-taining the calibrations on an 18-month or refueling frequency with a 25% grace period. The inspector did not identify any instruments which had missed the periodic calibration, but an interview with the planner revealed that this specified frequency with grace period was more of a target frequency than a required one. This discrepancy appeared to be due to the fact that reference (i) does not delineate any frequency or grace period nor the importance of meeting the specified frequency selected. The licensee stated that reference (i) would be changed by April 1,1982 to reflect the actual frequency with grace period for the installed safety-related instruments.
This area is identified as an inspector follow-up item (335/82-03-04), and will be reviewed during subsequent inspections.
b.
Calibration Frequency for Electrical Department Installed Instruments i
Reference (j) is the controlling procedure which calibrates all the l
meters maintained by the Electrical Department.
The five year fre-i quency for the calibration of these meters do not appear to be based l
on any manufacturers recommendation or technical evaluation.
The licensee stated that an evaluation of the latest" calibration of the
,
l meters would be conducted by September 1, 1982, in order to determine the adequacy of the five year frequency for individual meters.
This area is identified as an inspector followup item (335/82-03-05) and will be reviewed during subsequent inspections.
!
l l
l
[
a
.
.
.
.
,
11.
Surveillance (61700)
References:
(a) TQR 14.0, Inspection, Test and Operating Status, Revision 1 (b) QP 10.6, Inservice Inspection (ISI), Revision 1 (c) AP 0010125, Schedule of Periodic Tests, Checks and Calibrations, Revision 44 (d) AP 0010132, ASME Code Testing of Pumps and Valves, Revision 2 (e) AP 0010437, Schedule of Maintenance Surveillance Requirements, Revision 9 Utilizing the licensee's surveillance program as described in the refer-ences, the inspector veri fied that selected plant surveillances met following required criteria:
-
Technical Specification surveillance and inservice inspection (ISI)
tests were covered by approved procedures which contained applicable prerequisites and preparations, acceptance criteria, and instructions to insure that systems or components are restored to operation following testing
-
Completed surveillances were reviewed in accordance with facility administrative requirements, were performed within the required time frequencies, were properly handled when tested items failed acceptance criteria, and were performed by qualified individuals.
The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspectors.
Discussion with the resident inspectors revealed that the ISI program implementation had not been specifically reviewed. The inspector reviewed several ISI procedures for implementation.
Based on this review, no violations or deviations were identified.
12. Maintenance (62700)
l References:
(a) Technical Specifications (b) TQR 5.0, Instructions, Procedures and Drawings, Revision 1 (c) TQR 10.0, Inspection, Revision 3 (d) QP 5.1, Operating Plant Procedure, Revision 3 (e) QI 18-PR/PSL-3, Quality Control Monitoring, Revision 2 (f) QI 5-PR/PSL-1, Preparation, Revision, Review / Approval of Procedures, Revision 17 l
!
.
.
.
.
(g) QI 10-PR/PSL-1, Quality Control Inspection, Revision 6 (h) AP 0010430, Maintenance on Nuclear Safety-Related or Seismic Class I Systems, Revision 6 (i) AP 0010432, Plant Work Orders, Revision 17 (j)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), November 1972 The inspector reviewed maintenance activities on safety-related systems and components to ascertain whether the activities were conducted in accordance with approved procedures, regulatory guides, industry codes, and Technical Specifications as required in references (a) - (j). The following criteria were used during this review:
-
Required administrative approvals were obtained prior to initiating work
-
Limiting conditions for operation were met while components were removed from service
-
Approved procedures were used when the activity appeared to be beyond the normal skills of the craf t
-
Written procedures were established for initiating requests for routine and emergency maintenace
-
Criteria and responsibilities for review and approval of maintenance requests were established i
-
Criteria and responsibilities that form the basis for designating the activity as safety or non-safety related were established
-
Criteria and responsibilities were designated for performing work inspection of maintenance activities l
-
Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activities
-
Methods and responsibilities were designated for performing functional testing of structures, systems, or components following maintenance work and/or prior to their being returned to service.
Based on this review, two violations, and one open item were identified and l
are discussed in the following paragraphs.
a.
Failure to Follow Procedures l
!
Technical Specification section 6.8.1 requires written procedures to be
!
established, implemented, and maintained covering the procedures in
!
Appendix "A" of reference (j).
Appendix "A" section I.5, requires general procedures for the control of maintenance, repair, replacement,
-
.
.
.
.
and modification.
Reference (1) implements this requirement for St. Lucie 1.
A review of 19 PW0s indicates that the requirements specified in reference (i) are not being met. The following is a list of specific examples of failure to adequately implement AP 0010432.
(1) Paragraph 8.4 requires the Maintenance Foreman / Supervisor to agree to the work description and completeness by signing section "C" of the PWO. PW0s 3325, 3631, 2608, and 2658 were not signed by the approving supervisor.
(2) Paragraph 8.5 requires craft personnel to review all sections and attachments of the PWO to assure that all requirements and instructions are understood and adhered to.
The plant staff did not adhere to instructions in the following PW0s:
-
On PWO 2652, the on-shift SRO did not sign the verification of Technical Specifications for the work to be accomplished as required by an attachment to the PWO.
-
On PW0s 1785, 1772, and 1800, the retest was to perform ASME Code Pump Bearing Temperature testing per QI 11-PR/
PSL-2 Appendix B; however, the data sheets contained no indication that bearing temperature testing was perfor. ed and in addition were marked "N/A" in the space provided for logging of readings.
-
On PWO 1800, directions were provided to identify oil used to perform pump lubrication but there was no record of lubri-cant used.
,
-
On PWO 3643, directions were provided to disassemble cylinder
- 4 on the "A" diesel to repair a test valve but the work per-formed did not require disassembly of the cylinder yet the directions were not changed to delete this requirement.
l
-
On PWO 3631, a QC hold point was signed by the QC inspector for step 9.1.23 of M-0017 (an attachment to the PWO).
This step required torquing the inlet flange to a specified value.
Since this step could not be performed as written, the main-tenance personnel used slugging wrenches and hammers to tighten the flange without approval to change the procedure.
In addition, a similar valve (V1202) was worked during this process without obtaining authorization prior to performance of the work.
-
On PWO 2608, the entire description of work was changed l
without review by persons originally approving the work.
The examples listed above constitute a violation (335/82-03-01) of failure to implement procedures.
I
,
.
.
.
.
.
b.
Repair of Seismic Pipe Supports During this review, the inspector examined PWO 3488 which had been issued to repair support SI 971-6234 on a reactor safety injection pipe.
The PWO did not contain an engineering evaluation, torque requirements, or procedure references and material used during the repair was different from that shown on the drawing.
The changes completed under this PWO were e; ivalent to a plant design change.
Failure to provide measures to assure that appropriate quality standards are specified and deviations from such standards are controlled is a violation (335/82-03-02).
c.
Facility Review Group Revie.v of Maintenance Instructions Reference (a) section 6.5.1.6 requires the FRG to approve all proce-dures required by Appendix A of reference (j).
Appendix A requires that maintenance that can affect the performance of safety related equipment be performed in accordance with written procedures with the exception that maintenance within the normal skills of maintenance personnel may not require detailed step-by-step delineation in a procedure. At the present time several Plant Maintenance Instructions have not been approved by the FRG. The licensee has given a date of June 1, 1982, when all Plant Maintenance Instructions will be reviewed by FRG or classified as maintenance within the skills of the craft personnel. This item will be tracked as ar open item (335/82-03-03)
pending review of this area during a subsequent inspection.
l
,
,
I l
l l