L-82-301, Responds to NRC Re Violations Noted in IE Insp Rept 50-389/82-23.Corrective Actions:Draft Site Quality Procedure Prepared Re Fire Protection Sys,Outlining QA Controls

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Responds to NRC Re Violations Noted in IE Insp Rept 50-389/82-23.Corrective Actions:Draft Site Quality Procedure Prepared Re Fire Protection Sys,Outlining QA Controls
ML20062J367
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 07/22/1982
From: Robert E. Uhrig
FLORIDA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062J343 List:
References
L-82-301, NUDOCS 8208160343
Download: ML20062J367 (2)


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P. O. BOX 14000, JUNO BE ACH, F L 33408 w',

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FLORIDA POWER & LIGHT COMPANY July 22, 1982 L-82-301 Mr. James P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 RE: RII:WHM St. Lucie Unit 2 Docket No. 50-389/82-23

Dear Mr. O'Reilly:

Florida Power & Light Company has reviewed the subject Inspection Report which identified the following deviation: " Failure to Fully Implement QA Requirements of QP 2.12". Please find attached our response to this deviation.

Very truly yours, W4 4 n

o) 4 Robert E. L'hrig [

Vice President Advanced Systems and Technology f REU/PPC/ cab l

cc: Harold F. Reis, Esquire

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8208160343 820802 PDR ADOCK 05000389 G PDR PEOPLE. . SERVING PEOPLE

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  • ad RII: WHM 50-389/82-23 Deviations:

Florida Power and Light Company's (FPL) approved Topical Quality Assurance Report, Revision 4, Appendix E identifies FPL's Procedure QP 2.12 as the applicable procedure for implementation of a Quality Assurance Program for

- Fire Protection Systems.

Contrary to the above, a site quality assurance program for the fire protection systems had not been fully implemented.

Res ponse :

As stated in the deviation the elements of the Florida Power and Light Quality Assurance Program that apply to Fire Protection Systems necessary to protect areas containing safety related equipment are identified in Quality Procedure QP 2.12. The level of quality assurance effort applied to each element of the program is determined by the implementing FP&L department. This determinat .on is based upon the importance of the equip-ment or service to fire protection in areas containing safety related equipment and includes all actions required to ensure that the fire prc-tection system will perform its function in these areas.

At St. Lucie Unit 2 levels of quality assurance effort applied to construction are outlined in site quality procedures and in Quality Control quality instruc-tions. To ensure that the elements of the FPL QA program applicable to the installation of fire protection systems are clearly delineated, a draf t site quality procedure, SQP-99, has been prepared on Fire Protection Systems. This draft proceuure outlines the quality controls applicable to the installation of fire protection cystems by listing each FPL quality procedure, each site quality procedure and each quality instruction in terms of the applicable elencats of the FPL Laality Assurance Program. For exanple, all materials received at the site are processed by Stores as outlined by SQP-3, Material Control,with receiv-ing responsibilitie? outlined in QP 8.1, Identification and Control of Materials.

Quality Control uses QI 10.78, Integrity Testing, to inspect systems required to be hydroatatically tested. In this manner a compilation of all applicable gaality controls are presented. SQP-99, Revision 0 was issued on July 9, 1982.

Quality Assurance has reviewed and commented on this draft procedure and the overall QA program will be improved by its issuance. Audit requirements applicable to fire prctection continue to be fulfilled by Quality Assurance.

With regard to OA program effectiveness, we feel that the FPL QA program has always been and will continue to be ef fectively implemented in all safety related areas of construction at St. Lucie Unit #2. However, we realize that certain changes such as clarification of existing procedures and/or issue of singular procedures to place emphasis on certain facets of the QA progran are needed from time to time to add that extra degree of program ef fectiveness which is our ultimate goal at FPL. Thus, with the issuance of SOP-99, as noted in the previous discussion, we feel that this extra degree of QA procram effect-iveness will be accomplished with respect to the fire protection system.

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