IR 05000335/1982016
| ML20054G799 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/28/1982 |
| From: | Debbage A, Merriweather N, Upright N, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20054G791 | List: |
| References | |
| 50-335-82-16, 50-389-82-18, NUDOCS 8206220311 | |
| Download: ML20054G799 (15) | |
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- pt** "' %<g UNITED STATES NUCLEAR REGULATORY COMMISSION
[\\ f,h REGION 11
e C 101 MARIETTA ST.. N.W Sulf E 3100 0, [ ATLANTA. GEORGI A 30303
..,,, Report Nos. 50-335/82-16 and 50-389/82-18 Licensee: Florida Power and Light Company P. O. Box 529100 Miami, FL 33152 Facility Name: St. Lucie Docket Nos. 50-335 and 50-389 License Nos. DPR-67 and CPPR-144 Inspection at licensee corporate office in Miami, Florida Inspectors: [ # [ - / $ $8L R. W. Wrigh'E g [fte SMned f4d O f 2Ghz-s A.G.Debage/ ate Signed ' (dM Yb ^ & s~7de/nu ' N.Merriweather// g D / ate Signed Approved by: [[g// 8 6*L . C. M. Upright' Secti Chief DpeS/gned Engineerin ' nspect n Branch Division of Engineering and Technical Programs SUMMARY i Inspection on April 26-30, 1982 l Areas Inspected ! This routine, announced inspection involved 95 inspector-hours at the corporate ( offices in the areas of quality assurance program, design control, procurement activities, audits for St. Lucie 1 and 2, and one inspector followup item for St. Lucie 1.
Results j Of the five areas inspected, no violations or deviations were identified.
! 8206220311 820528 PDR ADOCK 05000335 O PDR
. . REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J.
E. Vessely, Director of Nuclear Affairs
- R. F. Englmeier, Manager of Quality Assurance
- J. B. Harper, Asst. Manager QA Systems and Audits
- W. K. Sterett, Asst. Manager QA Engineering & New Projects
- W. W. Woodard, Sr. Engineer, QA Systems
- R. E. Spooner, Sr. Engineer, QA Audits
- R. A. Kaminski, Supervisor, Nuclear Licensing N. T. Weems, Superintendent of St. Lucie Projects QA R. E. Uhrig, Vice President Advanced Systems & Technology R. N. Marsh, Manager of QA Procurement & Reliability G. Keller, Nuclear Licensing Representative F. Green, QA/QC Coordinator, Technical Licensing E. Dotson, Engineering Project Manager, Power Plant Engineering S. R. Jackson, Sr. Engineer, Procedure Review K. E. Van Oeveren, Sr. Engineer, Vendor Activity
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on April 30, 1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Quality Assurance Program (35060B) a.
General The purpose of the inspection was to complete an overall review of the effectiveness of licensee management and the implementation of the FPL Corporate QA program for control of on going activities of design, procurement, and construction for the St. Lucie 2 (SL2) project.
FPL's Topical Quality Assurance Report (FPLTQAR 1-76A) Rev. 4, accepted by NRR Quality Assurance Branch (QAB) on May 14, 1981, is the current document that establishes FPL's QA Program requirements. FPL is
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functioning in accordance with Revision 4 with the exception of a few changes that are identified in draf t Revision 5 which will be submitted to NRR for their acceptance in the near future.
b.
Documents Examined FPL10AR 1-76A, Rev. 4 & Draf t Rev. 5 FPL Quality Assurance Manual with associated procedures FPL QA Department Instruction Manual FPL ASME QA Manual FPL QA Organizational Manual c.
QA Program Changes The inspector reviewed the documents listed above and held discussions with responsible QA management personnel and concluded that the following organizational structure, management personnel, and QA procedural changes were handled in the proper manner: (1) By letter (L-81-430) dated September 28,1981,.FPL notified NRR QAB of the following organizational structure change that will be identified in Rev. 5 of the Topical. The Assistant Manager of QA - St. Lucie Projects, who formerly reported to the Manager of QA, now reports to the Director of Nuclear Affairs and has a new
- title of Superintendent of St. Lucie Projects - QA. The current Director of Nuclear Affairs was the former FPL QA Manager when SL2 construction commenced and has intimate familiarity with the project. Around September 1981, the QA Manager was promoted to a position elsewhere within FPL's corporate headquarters. Since the construction phase of SL2 is winding down, FPL decided to reestab-lish a former reporting relationship (Weems to Vessely) to main-tain continuity and total familiarization of the job rather than burden the newly-appointed Manager of QA (MQA). As a result of this change, QA independence has been retained and site QA now actually reports to a higher level of management authority than before.
(2) R. F. Engimeier (formerly Asst. Mgr. Procurement and Reliability) replaced A. E. Siebe as MQA around September 1981.
The new MQA has an extensive prior background in QA, has been employed with FPL in the QA field since 1974, and meets the qualification and experience requirements specified for FPL QA personnel in Appen-dix B of the Topical Report.
Discussions with the MQA and his managers identified that corporate QA staffing levels have remained relatively stable over the past year although some names of personnel within the QA department may have changed due to routine promotions or trans-fers. Department QA managers interviewed stated they were meeting
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the required QA program with current staffing levels and the inspector found no evidence to dispute this statement.
Consid-ering the project status, the corporate QA staff level and composition appears to be adequate.
(3) The below listed QA procedures and instructions for the specified control manual holders were examined for changes (revisions) implemented to verify that these changes were approved at appro-priate management levels and to ensure that document control (distribution) requirements had been effectively complied with: FPL QA Manual - Control Copy Nos. 031, 033, 067, 081, 096,109, and 144 QP 3.1, R2 Evaluation of Contractor Design QP 3.5, R3 Design Control of the Construction Site QP 4.4, RIO Review of Procurement Documents for Items and Services Other than Spare Parts QP 18.1, R5 Conduct of Quality Assurance Department Department Quality Audits FPL 0A Department Instruction Manual Control Copy Nos. 001, 019, and 034 QI 3 QA03, R3 Review of Design Related Documents QI 4 QAD1, R4 QA Review of Procurement Documents QI 18 QAD2, R0 Auditing of QA Committee, Company Nuclear Review Board and the QAD QI 18 QAD3, R0 Scheduling of QA Department Audit Acti-vities FPL ASME ( AQAM) QA Manual Control Copy Nos. 003, 010, 019, 021 and 029 AQR 3.0. R6 Design Control AQR 3.0, R0 St. Lucie Unit 2 Addendum AQR 4.0, R5 Procurement Document Control AQR 4.0, R4 St. Lucie Unit 2 Addendum AQR 18.0, R4 Audits AQR 18.1, R4 FPL Departmental Audits The changes made to the above identified procedures and instruc-tions were found to conform to the following respective applicable procedures: QP 2.3, R5 Preparation and Revision of Quality Procedure QP 2.4, R2 Preparation and Revision of Quality Instructions QI 2 QAD4, R5 Preparation and Revision of QAD QI's QI 2 QA06, R6 Control of QA and QI Manual QI 2 QAD7, R2 Maintenance and Control of the AQAM QI 2 QAD8, R0 Review of Changes to QA Manual AQR 2.1, R6 Control of the AQAM QA Manual
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Although no problems were identified with QA Procedural /Instruc-- ' tion changes and distribution control, review of the Topical QA Report TQR18.0, R2, disclosed an inconsistency in the frequency of inspection required for internal and onsite construction and design activities.
Section 18.2.2b states that " Applicable elements of the internal and onsite programs shall be audited at least once every two years or once within the life of a quality related activity, whichever is shorter." However, this two year cycle for auditing elements of the internal and onsite QA program applies during the operational phase of plant life following initial fuel loading.
FPL audits of internal and onsite con-struction and design activities are conducted in accordance with Appendix C, Rev. 4, of the Topical Report " Baseline Document . Matrix" which endorses Regulatory Guide 1.144 and states that " Applicable elements of an organization's QA program should be audited at least annually or at least once within the life of the activity whichever is shorter." Responsible licensee management stated that the next revision to the Topical Report (Rev. 5) will address this issued by clarifying TQR 18.0 so that it specifies an annual audit frequency for internal and onsite construction and design activities in accordance with Appendix C.
This discrepancy in auditing requirements was identified as an inspector followup item 50-389/82-18-01, Clarification of Internal and Onsite Construction and Design Activity Audit Frequency.
d.
Licensee Reviews of QA Program Effectiveness FPL utilizes QA Committee Meetings, Joint Utility Management Audits, and Bimonthly Directors Meetings to regularly review the status and adequacy of the SL2 QA program.
The President of FPL has established a QA Committee composed of top level management personnel and chaired by the Executive Vice President.
This group is directly involved in reviewing the status and adequacy of the program, reviewing any significant problems that may exist and ruling on or recommending policy change.
The QA Committee meets formally twice a year and additional special meetings are called as needed to resolve issues or to discuss significant events.
Periodic program reviews of the status and adequacy of the FPL QA program are accomplished by an independent audit team and by QA ! Department audits.
The independent audit team is usually a Joint i Utility Management Audit (JUMA) team composed of senior QA personnel from other utilities.
These individuals evaluate FPL's program with respect to their own and others they have seen.
They point out deficiencies and pass along better methods they have seen employed.
i j Bimonthly Directors Meetings held on site are called by the Director of - Construction and Director of Nuclear Affairs to resolve issues and I establish an effective course of action to be taken on audit findings j and other quality problems.
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The inspector examined the following 0A ef fectiveness reviews for compliance to procedural requirements, recommendations, and disposition of these recommendations: QA Committee Meeting Minutes conducted 1/26/81, 3/18/81, 7/28/81, and 2/4/82 Joint Utility Management Audits QAS-QAD 81-1 2/9-13/81 QAS-QAD 82-1 2/22-26/82 In addition to the above reviews, FPL management is kept aware of the QA program status through monthly reports issued by the QA Department to management.
This report summarizes FPL QA audit results, NRC inspection results, the results of the QA trend analysis of audits and nonconformances, and any significant problems or events that may have occurred during the month.
The monthly report is effective in informing management of any problems requiring special attention. The inspector examined the FPL-QAP Monthly Reports published for the period July 1981 through March 1982 inclusive.
e.
Corporate QA - Site Interface The St. Lucie Projects QA group is responsible for planning, developing and verifying implementation of the onsite QA program. Although not examined during this inspection, numerous previous NRC site inspections have evaluated FPL's onsite QA program.
The Superintendent of St. Lucie Projects QA (SSLPQA) wears two hats in that he manages the site QA program sharing his time at both the site and corporate offices thereby providing a direct two-way management information flow.
The site projects group QA audit reports are distributed to the audited organization, site management, the Superintendent Construction QC, and to the Manager of QA.
The site projects QA group conducts trend analyses of receiving, mechanical, civil, and electrical discrepancies on a quarterly basis.
The results of these analyses are reported to the SSLPQA and to the Site Manager at specific meetings held to review the results. At these meetings the results of Trend Analyses of site QA audits, construction deficiencies, and welding deficiencies are also discussed.
The Corporate QA Department performs trend analyses on a semiannual basis. A comprehensive trend analysis presentation is made before the QAC members at their semiannual meetings.
Within this area, no violations or deviations were identified.
One inspector followup item was identified as 389/82-18-01, Clarification of Internal and Onsite Construction and Design Activity Audit Frequency.
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6.
Design Review - External A/E (350608) a.
Documents Examined (1) EPP-QI 1.1, R3 General Requirements Power Plant Engineering (EPP) Quality Assurance Program (EPP-QAP) (2) EPP-QI 1.2, R2 Design Activities Delegated by Power Plant Engi-neering (3) EPP-QI 2.2, R3 QA Indoctrination and Training (4) EPP-QI 3.1, R6 Control of Design Performed by EPP (5) QP 3.1, R2 Evaluation of Contractor Design (6) QP 3.2, R2 Identification and Control of Design Interfaces (7) QP 3.5, R3 Design Control at the Corstruction Site (8) QP 3.6, R3 Control of FPL Originated Design (9) QI 18-QAD3, R0 Scheduling of Quality Assurance Department Audit Activities (10) QP 18.1, R5 Conduct of Quality Assurance Department Quality Auaits (11) QP 2.13, R0 Licensing Processing of NRC Requests b.
Design Assurance The objective of this inspection was to determine the licensee /AE organizational responsibilities for design assurance.
To accomplish this inspection the inspector reviewed the Florida Power and Light (FP&L) Topical Quality Assurance Report, Revision 4, and interviewed responsible licensee management to understand the internal and external interfaces for design assurance.
FP&L delegates design work for St. Lucie Unit 2 to the architect-engineer (Ebasco Services. Incor-porated, New York, New York). The inspector reviewed the engineering, construction, ano related services contract for St. Lucie Unit 2 between FP&L and Ebasco Services dated November 15, 1975 and as amended by Supplement No. I dated December 15, 1978.
In this contract Ebasco is designated the architect engineer for engineering and design services.
Ebasco is contracted to perform such functions as engineering and design, procurement, QA of engineering and design, and vendor quality assurance.
The licensee performs an annual audit to evaluate the effectiveness of Ebasco's design assurance activities and reviews design documents on a sampling basis to determine adequacy of design.
Interfaces betweer. FP&L/Ebasco are handled through the St. Lucie 2 Engineering PrcJect Marager on design related issues.
Within this area, no violations or deviations were identified.
c.
Design Assurance Audits The inspector reviewed the licensee's quarterly audit schedules for calender year 1981 through first quarter of calender year 1982 to assure that an audit schedule was documented and that the f requency and scope of audits was suf ficient to assure that representative design
groups and safety functions were included. The manager of QA-Procure-ment and Reliability maintains the quarterly audit schedule for audits of the suppliers QA/QC programs. The input to the audit schedule for design audits is provided by the Superintendent of Quality Assurance St. Lucie Project. The audit schedule is reviewed and approved by the the manager of QA prior to implementation. The schedule indicates the principal auditor and may include accompanying auditors.
Technical specialists from other organizations such as Power Plant Engineering are brought in as needed to be members of the audit teams.
The inspector selected FP&L's audits of Ebasco for calender year 1981 for examination. These audits are identified as 08.01.EBSNY.81.1, 2, 3 and 4.
The areas examined were: preparation, review, and approval of drawings; calculations and specifications; development and documenta-tion of design inputs; review of vendor drawings; design verification; design interfaces; indoctrination and training; nonconformances and corrective action; NRC Inspection and Enforcement Bulletins and Generic Letters: Ebasco procurement practices for design services; Ebasco external design interface practices for engineering / design services; and followup on open items.
The reports were examined to determine if the objective and scope established in the audit plans were accomplished, whether followup on audit findings was timely, and whether corrective action was adequate.
The qualifications of the principal auditors were examined and found acceptable.
Within this area, no violations or deviations were identified.
d.
Bulletins, Circulars, and Information Notices The inspector reviewed the licensee's program for handling NRC bulletins, circulars, and information notices to assure that the NRC requirements and positions transmitted to the licensee are reviewed by the appropriate organizations for applicability to the St. Lucie 2 ( Project. The inspector reviewed Quality Procedure QP 2.13, Licensing Processing of NRC Requests, to understand the licensee's program for coordinating incoming correspondence Trom the NRC.
The inspector interviewed personnel in the Quality Assurance Systems Section, Quality Assurance Engineering and New Projects Section, Nuclear Affairs Licensing Section, and Power Plant Engineering to determine if proce-dure QP 2.13 was being implemented. The inspector reviewed the Nuclear Lice.; sing commitments list which tracks commitments made to the NRC from such documents as bulletins and generic letters.
Circulars and information notices are not tracked on this list because they de not normally require a response to the NRC.
However, to document the review of circulars and information notices, the licensee is developing a program to review and evaluate circulars and information notices with a statemer.t to file addressing the applicability to St. Lucie 2 for close-ou. .
Within this area, no violations or deviations were identified.
7.
Procurement (350608) a.
Procurement Organization Controls Ebasco, New York, New York, is the architect-engineer for Florida Power and Light Company (FP&L) Plant St. Lucie 2 (PSL-2) with Combustion Engineering, Windsor, CT, (CE) being the NSSS supplier.
Procurement activities for PSL-2 are performed by both Ebasco and FP&L.
Initially the procurement by Ebasco was performed under the Ebasco QA program Ebasco evaluated the QA programs of suppliers and maintained an approved supplier list ( ASL). In 1976, FP&L assumed responsibility for . performing the majority of supplier audits related to Ebasco procure - ment activity. It was agreed that Ebasco would use the FP&L QA ASL as well as their own ASL as a source for QA approved suppliers.
FP&L has participated in Ebasco supplier evaluations; representatives have accompanied Ebasco personnel during shop surveillances and par-ticipated in resolution of supplier related problems. Ebasco maintains an engineering group at the construction site to process all engin-eering and design documents.
Site procurement is originated by the FP&L office engineering staff based on approved documents and purchase requisitions receive site QA review prior to initiation of the purchase order.
Corporate procurement receives QA review by the Manager, Procurement and Reliability, who reports to the Manager of Quality Assurance. The Manager, Procurement and Reliability, conducts supplier audits including Ebasco and Combustion Engineering, and also corporate-wide purchasing of safety-related materials, equipment, and services.
Procedures controlling the above activities were reviewed to ensure that they contained the essential controls for procurement activity.
The procedures reviewed included the following: TOR 4.0, R1 Procurement Document Control TQR 15.0, R3 Nonconforming Materials, Parts or Components TQR 16.0, R2 Corrective Action TQR Appendix C Baseline Document Matrix QP 4.1, RIO Control of Requisitions and the Issuance of Purchase Orders for Spare Parts, Replacement Items and Services QP 4.2, R2 Evaluation of Contractor's Bids Technical QP 4.4, R10 Review of Procurement Documents for Items and Services Other Than Spare Parts QP 7.4, R5 Evaluation of suppliers of Safety Related Items or Services OP 7.6, R2 Acceptance of items and Service QP 7.8, R0 Review and Disposition of Supplier Deviation Notices 6_ ... . .
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1 QP 16.1, R5 Corrective Action QP 18.1, R5 Conduct of Quality Assurance Department Quality
Audits i AQR 4.0, R5 Procurement Document Control " AQR 4.0, R4 St. Lucie Unit.2 Addendum AQR 15.2, R7 Nonconformance Reports
AQR 16.0, R6 Corrective Action b.
Procurement Document Control . Procurement documents were reviewed to ensure the following: i - Applicable regulatory requirements, design basis, and other requirements were included or referenced.
- Procurement document ch nges were subjected to the same level of control as used in the original preparation.
- Scope of work to be performed by the vendor was identified.
- Technical requirements referenced appropriate documents.
l Test, inspection, and acceptance criteria were identified.
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- Vendors had a documented QA program and were required _to incor-porate QA requirements in subcontract documents.
- Special instructions / requirements were included for activities
such as designing, identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and extended storage.
! - Documents identified which were to be sent to Florida Power & Light for review and approval.
l - Nonconformance reporting and control were specified.
- Access to the vendor's facilities and records for inspection or i audit was specified.
l Items reviewed included procurement of structural steel, electrical tennination lugs, insulation, and calibration of a load cell. Requi-sition on Purchasing Agent (RPA) 290403 dated April 13, 1982 was for structural steel ASTM A-36 to specification #FLO-2998-761, Rev. 2.
A certificate of compliance to specifications and certified mill test i report were required. The purchase order 02447-21244S stated that the steel was nuclear safety related (QL-1) and that conformance to
{ 10 CFR Part 21 was required. The supplier was Alfab, Inc., Enterprise, l AL.
The purchasing department had verified that Alfab was on the ' approved supplier list.
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RPA 290808 dated March 19, 1982, was for a quantity of-Amp terminal lugs. No substitution was permitted; they were to be supplied by Amp, Borwyn, PA to specification FLO 2998.278E, Rev. 3.
The RPA had been . reviewed by the QA staff and Amp was verified to be an approved supplier.
The purchase order 04991-211265 stated that the lugs were nuclear safety related, that conformance to 10 CFR Part 21 - was . required, and a certificate of compliance to specification was required.
Proposal Record Requisition 262-536 resulted. in Purchase Order 71365-205605 on Raychem Corporation Atlanta, GA. The material was
heat shrinkable electrical insulation and classified as nuclear safety related; the material was to comply with Ebasco specification 1214-78, Project I.D. FLO-2998, 278P. Direct shipment from Raychem Corporation, ' Merlo Park, CA was specified. Raychem, CA and Raychem, GA were on the approved supplier list.
Calibration of a Dillon load-cell was the requirement of an RPA dated August 18, 1981. Calibration accuracy was . ! specified and a certificate of calibration was required. The Proposed
i Requisition 289355 was placed on W. C. Dillon & Co., Van Nuys, CA and l Purchase Order 24930-259835 invoked 10 CFR Part 21. The documents had been reviewed by the QA staff and W. C. Dillon was on the ASL.
c.
Audits of Combustion Engineering ' FP&L conducted audits of Combustion Engineering and these audit reports were reviewed.
Audit 08.03.CETM.82.1 was conducted March 3 and 5, 1982, with the audit team being C. U. Laisure (lead), L. P. Lewis, and R. B. Valentine. The scope of the audit was to examine and reevaluate the Combustion Engineering Tubular Products Division QA Program and its
implementation. The audit checklist was based on ASME NCA 3800, Winter 1981 addenda. No deficiencies were identified; the supplier evaluation results were subsequently transmitted to the CASE data center in , j Sacramento, California.
' Audit 08.05.CENPM.82.2 was conducted February 9-10, 1982, with the audit team being C. U. Laisure (lead) and O. I. Hanek (nuclear fuel resource specialist). The scope of the audit was to examine the fabri-cation and inspection activities associated with the manufacture fuel pellets, fuel rods, and miscellaneous skeletal hardware.
of Activities in progress during the audit were pellet and rod fab-rication and inspection, grid cage assembly and piece part fabrication, and fuel assembly fabrication. No deficiencies were identified.
Audit 08.05.CENPM.82.3 was conducted March 8-10, 1982, with the audit team being C. U. Laisure (lead) and A. W. Bailey.
The scope of the
audit was to reevaluate the QA Program to 10 CFR 50 Appendix B and to j ANSI N45.2-1971. A 19 element checklist was used,18 based on 10 CFR ! 50 Appendix B and tne 19th on 10 CFR Part 21.
No deficiencies were j noted.
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Audit 08.04 CEEWF.82.1 was conducted February 11-12, 1982 by C. U. Laisure.
The audit scope was-to audit the program for manu- -facturing control element drive mechanisms and the manufacture of Class I vessels, appurtenances, and component supports Also examined were quality records associated with the PSL-1 reactor vessel liquid ( level monitoring system. No deficiencies were identified.
d.
Audits of Ebasco FP&L conducted audits of Ebasco and these audit reports were reviewed.
Audit 08.01.EBSNY.81.1 was conducted April 27 - May 1, 1981, with the audit team being N. T. Weems (lead), J. R. Luke, R. A. Symes, and F. P. Green (Power Plant Engineering).. The scope of the audit was to examine implementation of the QA Program in design, training, noncon-formances and corrective action. Twelve findings were identified, one concerning the processing of vendor and manufacturers procedures; this was resolved by processing all vendor / manufacturers procedures through Project Quality Assurance Engineering in accordance with PSL-2 Project Manual and department procedure QA-P1, and subsequent modifications to the implementing procedure.
Audit 08.01.EBSNY.81.2 was conducted July 13-16, 1981, with the audit team being R. A. Symes (lead), N. T. Weems, and A. W. Bailey.
The audit concerned design control and seven deficiencies were identified.
Audit 08.01.EBSNY.81.4 was conducted November 23-25, 1981, with the audit team being K. E. Van Deveren (lead) and R. B. Wallace. The scope of the audit was to evaluate the QA Program and its implementation by the Ebasco internal audit group and the Ebasco vendor evaluation group, this included the audits of suppliers by Ebasco, the maintenance and issuance of Ebasco's approved vendors list and other vendor evaluation activities. Four findings were identified; one noted that the approved vendors list was issued quarterly but interim change notices to update it between quarters were not issued. Eoasco responded by arranging to issue interims on a monthly basis; they further reviewed all purchase orders placed during the preceding five years and verified that vendors removed from the list had not been subsequently used for the PSL-2 project.
Audit 08.01.EBSNY.81.3 was conducted December 1-4, 1981, with the team being J. R. Luke (lead), K. E. Van Oeveren, T. P. McKinon, G. J. Sagliocca, and W. F. Brarren.
The audit was to verify imple-mentation of inspection and enforcement bulletins / generic letters delivered by FP&L to Ebasco.
The scope was then expanded to include Ebasco procurement practices for engineering / design service and Ebasco external design interface practices for these services. Three findings were identified during this audit. One stated that Ebasco had placed E-series purchase orders for safety-related items and services without having qualified the suppliers in accordance with all of the require-ments of the Ebasco QA program for PSL-1 and PSL-2. The corrective action was for Ebasco to review all issued E-series purchase orders
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for safety significance and prepare a report summary for further action; also Ebasco was to issue a quality procedure to ensure that purchase orders having safety significance receive QA review prior to issuance and QA review all orders until the procedure was effec-tive. Meetings were held in New York during the week of April 19, 1982, to evaluate the corrective action. FP&L evaluation is expected to be ccmpleted by May 7,1982.
e.
Corporate Audit of Purchasing Department FP&L QA staff conducted audit QAP-PUR 81.1 during September 8-25,- 1981, with the audit team being K. Wianiewski (lead), S. R. Jackson, and L. W. Bladow. The purpose of the audit was to evaluate Purchasing Department's compliance with FP&L's QA Program.
The audit was corporate wide covering the General Office in Miami, Turkey Point back-fit, St. Lucie 1 backfit, and St. Lucie 2 construction. The checklist covered all procedures affecting procurement activity and included 0A indoctrination and training, nonconforming ma te ri al s, and records control. Five findings were identified; one finding was that several supplements to purchase orders were not reviewed and approved by QA staff prior to their release; another was that objective evidence was not available to substantiate the QA indoctrination, or sufficent QA training given, of various site contract purchasing personnel.
These findings were closed March 16, 1982. At the time of this_ inspection, the Manager, Procurement and Reliability, was performing an investiga-tion to verify that the corrective measures taken were adequate to prevent recurrence.
f.
Vendor Evaluation and Audits The Manager, Procurement and Reliability, is responsible for all supplier activity including the auditing of suppliers, generation and I maintenance of the approved supplier list, review of FP&L procurement documents, and all vendor surveillance activity related to FP&L pro-curement documents. FP&L is a member organization of CASE (Coordina-ting Agency for Supplier Evaluation) ana the Manager is FP&L's repre-
sentative.
The Manager of Quality Assurance, R. F. Engimeier, has just concluded his service as President of CASE.
l The approved suppliers list is issued quarterly with interim reports to notify holders of changes in the status of listed vendors, or additions to the list.
The approved suppliers list in use was dated April 1, ' 1982, and listed approximately 580 vendors.
The vendor audit schedule and inspection activity was examined.
, ' Currently audits average 30 per month and surveillances averages 10/12 per month.
Seven auditors are available on a full time basis for , j participation in vendor inspection and surveillance.
Three of the ' auditor's certification files were examined; they were found to be well experienced in quality assurance work and industrial activity.
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Within the above area, no violations or deviations were identified.
8.
Audits (350608) a.
Audit Program The inspector examined the following controlling documents, Topical Report, QA Manual Procedures, QA Instructions, and American National Standards: TQR 18.0, R2 Audits QP 2.9, R4 Qualification of QA Audit, QC Inspection, and Construction Test Personnel QP 18.1, RS Conduct of Quality Assurance Department Quality Audits QI 18 QAD2, R0 Auditing of QA Committee, Company Nuclear Review Board and the QAD QI 18 QAD3, R0 Scheduling of QA Department Audit Activities RG 1.144 Auditing of QA Programs for Nuclear Power Plants RG 1.146 Qualification of QA Program Audit Personnel for Nuclear Power Plants ANSI N45.2,12 Requirements for Auditing of QA Progrann for Nuclear Power Plants ANSI N45.2.23 Qualification of QA Program Audit Personnel for Nuclear Facilities FP&L has ultimate QA responsibility for the design and construction of SL 2.
Although the design function is delegated to the architect engineer, Ebasco Services, and the NSSS vendor, Combustion Engineering; FP&L maintains strict control of the function through frequent audits, reviews, coordination meetings, and other monitoring activities. Site QA and QC are performed by FP&L.
The FP&L SL 2 Project QA group monitors (by audit and surveillance) FP&L construction activities, FP&L construction QC, and other site contractor organizations. FP&L has a comprehensive internal QA auditing program administered from its corporate headquarters to review activities of all safety-related p functions.
This audit program evaluates the adequacy of each depart-i ment's activities to the FP&L QA Manual requirements and reviews interfaces between departments.
All Principal (Lead) auditors are qualified and certified in accordance with a quality procedure that implements the requirements of ANSI N45.2.23 and Regulatory Guide 1.146. Principal auditors are required to maintain their proficiency through regular and active participation in the program auditing process.
Based on an annual assessment, management may extend the qualification, require retraining, or require requalification.
The QA Systems and Audits Department's Audit Program Plan for the period January 1, 1982, to December 31, 1984, and audit schedules (projected and completed) for year 1981 and the first quarter of 1982 were examined and the audits Department Supervisor interviewed to ascertain that the licensee's audit program encompasses all internal organizations and extends to all elements of the QA program at the -
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required frequency. The achit team size, composition, and the use of specialists routinely assigned from other organizations was discussed with QA management.
The inspector examined the auditor training, experience, and certifications of FP&L auditors who participated in the audits examined in paragraph 8.b and found the auditors all qualified to applicable procedure and ANSI N45.2.23 requirements, b.
Audit Reviews The following audits and respective audit check sheets were examined to determine applicability to the QA element audited, qualification of the audit team members, that audit findings were reported to upper manage-ment and the organization audited, that corrective actions as required are being initiated, and that there is followup and re-audit by QA as necessary: QAE-10A-80-3 Control of Procurement Documents QAS-10A-81-1 Implementation of the FP&L ASME QA Manual by Responsible Departments QAS-CR-81-1 Corporate Records QAS-QAD-81-1 JUMA - Management Level Audit of the QA Organiza- , l tion j QAS-PM-81-1 Project Management Compliance with FPL's QA Program QAS-EPP-81-1 Power Plant Engineering - Implementation of QA Program Requirements QAS-QAD-82-1 JUMA - QA Committee, Systems and Audit, Procurement and Reliability, St. Lucie Projects, Company Nuclear Review Board and Turkey Point Within this area, no violations or deviations were identified.
9.
Inspector Followup Item (Closed) (IFI 335/81-08-32) The Quality Assurance Department annual suppliers review did not always include nonconformances, staff comments, and. the vendor history file. The program was not in written form. PAS 335/80-4 paragraphs 8.b.(14) and (16).
Florida Power and Light procedure 017 QAD Revision 3 was issued August 31, 1981, to incorporate the requirements of nonconformance, staff comments, and the vendor history file in the QA department annual suppliers review.
The inspector reviewed this procedure and verified that the procedure adequately addresses the requirements.
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