L-83-442, Responds to NRC Re Violations Noted in IE Insp Rept 50-389/83-44.Corrective Actions:Engineering Weld Deficiencies Reviewed,Ncr Initiated for Deficiency,Qc Performed Followup Insp & QC Hold Point Insp
| ML20080F380 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/10/1983 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20080F368 | List: |
| References | |
| L-83-442, NUDOCS 8309190280 | |
| Download: ML20080F380 (4) | |
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P. O. BOX 14000, JUNO BE ACH, FL.13408 d, D I
3 FLORIDA POWER & LIGHT COMPANY August 10,1983 L-83-442 c3
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Jcmes P. d'Reilly h
Regional Administrctor, Region 11 7b U. S. Nuclear Regulatory Commission "c
101 Marietto Street NW, Suite 2900 o
sT Atlento, Georgia 30303 w
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Re:
St. Lucie Unit 2 Docket No.50-38o insoection Recert 83-44 Florida Power & Light Company hos reviewed :ne sucject insoection report, and respons'es to findings A and B are ottoched. Our response to finding C and to the comment in the cover letter concerning tre rcot cause of the problems will be suomitted by August 24, Ic83.
Very truly yours, s
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Rooert E. Uhrig Vice President A'dvanced Systems & Technology REU/RJS/img Attachment cc:
Harold F. Reis, Esquire 8309190280 830907 PDR ADOCK 05000389 G
PDR PEOPLE.. SERVING PEOPLE
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ATTACHME NT RE:
ST. LUCIE UNIT 2 DOCKET NO. 50-389 INSPECTION REPORT 83-44 FINDING A 10 CFR 50, Appendix B, Criterion XV, as implemented by Florida Power and Lignt (FPL) Topical Quality Assurance Report Number 5.0, requires tnat nonconforming items be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedure.
FPL procedure SQP-21, Corrective Actiuns, requires that the NCR Review Board review inspection reports documenting discrepant conditions to determine if the discrepant conditions warrant an engineering review.
Contrary to the above, the NCR Review Board determined that discrepant conditions identified on inspection report numbers MH83-0896 and MH83-0898 were acceptable un th no additional work required where, in fact, these discrepant conditions required an engineering review to determine if the discrepancies were acceptaole.
RESPONSE
i 1.
FPL concurs with the ' finding.
f 2.
The reason for the finding was incanplete documentation to support the findings of the NCR Review Board.
The Board., at the tine tnat it was considering the subject inspection reports, requested additional i
information about-the deficiencies to properly evaluate them.
Tne site 1
welding superintendent inspected the deficient welds in the field and presented a verbal report to the Review Board.
The Board also reviewed documentation supplied by the vendor who perfonned the welding.
Neither the examination by the welding superintendent nor the relevant sections of vendor paperwork were documented to support the Board di sposition of the deficiencies "use-as-is".
I 3.
As corrective action, an inspection team of construction engineers, welding engineers and QC personnel was assembled. -Tne team re-inspected, in detail, the two subject whip restraints plus other similar restraints supplied by the same vendor (RE-MS 1, 4,12, and 13).
The results of the re-inspection were documented on inspectica report MH83-3935 and forwarded to the NCR Review Board for disposition.
The Board requested an engineering review of the noted weld aeficiencies.
This review was performed unth respect to the original design calculations and found that the deficiencies were negligible.
The restraints were
- determined to be acceptable.
The engineering calculations supporting this disposition are on file at Ebasco/New York.
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Page two Inspection Report 83-44 3.
(conti nued)
In addition, a review was pertonned of 10% of the approxiinately 2500 inspection reports dispositioned by the ICR Review t$oard as "use-as-is".
The review was perfonned by three task groups (Mechanical, Civil and Electrical) composed of individuals who had not served on tne ICR Revi ew Board.
Each task group was headed by a QA auditor and representatives from FPL Power Plant Engineering, QC, Construction and Ebasco Services.
The results of the review uncovered no significant hardware deficiencies, nor were the task group dispositions of individual irs different fran the original NCR Review Board di s posi tions.
4.
In order to prevent a recurrence of the problem identified, SyP-21, Corrective Actions, has been revised so as to require tnat an I4CR oe initiated for any deficiency identified which requires an engineering r evi ew.
Individual inspection reports are no longer sent to the ICR Review Board.
All NCRs are dispositioned by Engineering in writing, with sufficient documentation to support the disposition.
5.
Revision 11 to SQP-21 was issued July 15, 1983.
Full conpliance nas been achieved.
fit 0 LNG B 10 CFR 50, Appendix B, Criterion V, as implemented by FPL Topical yuality Assurance Report I4 umber 5.0, requires that. activities affecting quality be prescribed by documented instructions, procedures or drawings and be accomplished in accordance with these instructions, procedures or drawings.
Paragraph 5.7 of FPL procedure QP 10.2, Inspection of Plant Construction, requires that hold points be used when witnessing inspections that must be perfonned and signed of f before work can proceed.
Contrary to the above, work proceeded past hold points during modification of masonry wall numbers 57 ar.d 58 in the auxiliary building.
Hold points bypassed were those requiring verification of location of tnru bolts, verifying that wall reinforcing steel was not damaged during drilling of tnru bolt holes and verification that bolt materials were specified, including
, itnessing of transfer of bolt marking cut fron stock length.
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RESPONSE
1.
FPL concurs with the finding.
2.
The finding occurred due to the failure of construction supervisory personnel to notify Quality Control when the Hold Points were reached.
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Page three Inspection Report 83-44 3.
As corrective action, Quality Control performed a follow-up inspection of the walls, documented on IR C-83-1562.
Variation from design location of bolts in wall #58 was noted on this report.
Engineering evaluation accepted the as-built locations as acceptable.
The location of bolt holes in wall #57 was found to be acceptable.
The renaining inspections on these walls ware accomplished per procedure.
4 As corrective action to prevent fut!se problems, the responsible craf t superv.isor was instructed in the necessity for notification of. QC for all Hold Points and the requirenent that work not continue until tne required inspection is performed.
Construction has issued a memo (FM2-83-5428) to all civil supervisory personnel detailing the import 6nce of QC Hold Point inspection and identifying the proper channels for notification in the Construction Backfit mode.
Construction QC has also initiated a closer surveillance of all block wall modifications in progress.
5.
Full conpliance has been achieved and will be followed under tne Backfit Program.
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