L-88-540, Responds to Violations Noted in Insp Repts 50-250/88-28 & 50-251/88-28.Corrective Actions:Checker of Calculation Retrained in Application of Design Calculation Procedure Edpi 4.37-10 & Bechtel Personnel Readvised
| ML17345A603 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/21/1988 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| L-88-540, NUDOCS 8812300059 | |
| Download: ML17345A603 (8) | |
Text
t gc Cp~ ~TED DISTKBUTION DEMONSTRATION SYSTEM REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS) 4 ACCESSION NBR:8812300059 DOC.DATE: 88/12/21 NOTARIZED:
NO DOCKET ACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Poi'nt Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Florida Power
& Light Co.
REClP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 881117 ltr re violations noted in Insp Repts 50-250/88-28
& 50-251/88-28.Corrective action noted.
DISTRIBUTION CODE:
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SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD DEDRO NRR/DLPQ/PEB ll NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 N,J RE ILE 02 TERNAL: LPDR NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1
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NOTE 'lO ALL 'KIDS" MKXPIBGS:
PIEASE HELP US I0 REDUCE KQ)TE!
03ÃZACT 'IHE DOCUMENT CONGEAL DESK, RDCN Pl-37 (EXT. 20079)
TO EIZMZNATE KN3R NAME EKH DIPHGBIOTXGH LISTS KR DOCUMENTS YOU DON'T NEED)
D' TOTAL NUMBER OF COPIES REQUIRED:. LTTR 23 ENCL 23
PO.Boxl4000,JunoBeach,FL 3340S-0420 DECEMBER 2 1 ~48 L-88-540 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Reply to Notice of Violation
'ns ection Re ort 88-28 Florida Power
& Light Company has reviewed the subject inspection report and a response is attached.
Very truly yours, W. F.
Conway Senior Vice President Nuclear WFC/RHF/gp Attachment CC:
Malcolm L. Ernst, Acting Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant PDR oPP59 88i22
- 88) ppp DO~K p5pppp5p PhlU an FPL Group company
ATTACHMENT VIOLATION 50-250, 251/88-28-01 Finding:
10 CFR 50 Appendix B, Criterion III requires measures be established to assure that. applicable regulatory requirements and design basis are correctly translated into procedures and instructions.
These measures shall provide for checking the adequacy of design.
Contrary to the above, the measures to assure that design basis are adequately transmitted to procedures and instructions were not adequate in that:
the numerical value for "Fluid Velocity" used in the stress calculation for component cooling water (CCW) thermowell Nos. TI-4-663A-F in Bechtel Power Corporation Calculation 17712-183-J01, "Component Cooling Water Heat Exchanger Replacement, Unit ~ 4 thermowell stress analysis local TIs" Revision 0
originated September 13,
- 1988, checked September 13,
- 1988, and approved September 14,
- 1988, could not be explained or supported by the engineer
-who originated the calculation," the checker who reviewed the calculation, or the engineer who approved the calculation.
Response
1)
FPL concurs with the finding.
2)
The reason for, the violation is personnel error.
The originator of the
,calculation cited made a numerical error and the calculation checker failed to detect the error.
The error related to the value used for flow velocity input to the computer program to calculate thermowell stresses.
It was stated in the calculation that the velocity was derived from the mass flow rate (with specific reference to the source of this data) and the inside diameter of the nozzle.
The originator of the calculation was requested by the inspector to recreate the velocity calculation (indicated as 6.139 ft/sec in the calculation).
- However, he was unable to do so, calculating values between 12 and 15 ft/sec (depending on the flow rate and nozzle diameter used).
The inspector requested an explanation of the discrepancy, but none could be established other than a numerical error occurred when the calculation was originally prepared.
Bechtel Procedure EDPI 4.37-10, Rev.
10 requires that the checker verify numerical calculations or verify results by alternate documented methods.
Accordingly, the calculation checker appears not to have appropriately checked the velocity calculation described above.
3) a.
The calculations in question (Calculation No. 18712-183-J01 for local TI thermowells and Calculation No. 18712-183-J02 for RTD thermowells) have been revised.
The maximum stress intensity in the sub)ect thermowell shanks derived in the original calculations when utilizing the incorrect fluid velocity was approximately 106 psi and 110 psi for the 0.75 inch diameter portion of Calculations 18712-183-J01 and 18712-183-J02,
respectively, and 126 psi for the 0.5 inch diameter portion of both calculations (versus an allowable of 22,500 psi).
The revised calculations reflect thermowell shank stress intensity of approximately 550 psi and.570 psi for the 0.75 inch diameter portion of Calculations 18712-183-J01 and 18712-183-J02, respectively, and 213 psi; for the 0.5 inch diameter portion of both calculations (versus an allowable of 26,250 psi) when utilizing the corrected fluid velocity figure.
b.
Other Turkey Point calculations which were verified by the checker involved wi.th this calculation have been rechecked by a third party and found acceptable.
4)
The following actions have been completed as a result of this occurrence:
a.
The checker of this calculation has been retrained in the application of the Design Calculation Procedure (EDPI 4.37-10) as well as other relevant engineering procedures with which he may be involved.
a.
Other Bechtel engineering personnel on the Turkey Point Project have been specifically re-advised of the checker responsibilities delineated in the project procedure.
5)
Full compliance was achieved on December 9,
1988.
VIOLATION 50-250 251/88-28-02 Finding:
10 CFR 50, Appendix B, Criterion X requires the establishment of an inspection program to verify conformance with documented instructions and procedures for accomplishing activities affecting quality.
Work activities shall not proceed past holdpoints without the consent of authorized personnel.
The above is implemented by Florida Power and Light (FPGL) Procedure QP 10.3, Revision 6, "Inspection and Surveillance",
Paragraph 5.8.1, and FP&L Administrative Site Procedure ASP-2, Rev'. 4, Paragraph 4.12.
Mechanical Installation List No. MIL 88-006M, Revision 1, and Process Sheet No. P.S.88-206, have been identified as the work and inspection controlling documents for the replacement of the CCW heat exchangers.
Procedure ASP-2, Paragraph Nos. 5.3.4 and 5.5.3, requires Pro)ect Field Engineers (PFEs) and Quality Control (QC) inspectors to sign-off process sheet "hold-points" within'4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the completion of the work activity or inspection.
Contrary to the above, the licensee has failed to establish an effective inspection program for the installation of the CCW heat exchangers as evidenced by the following:
1.
Both PS88-206 and MIL 88-006M, state that sequencing is not required.
Both documents contained "hold-points" which the licensee permitted to be accomplished out of sequence 2.
Two examples were noted where "hold-points" were signed off inadvertently when in point of fact, the required inspections had not been accomplished/
completed.
One case resulted in the "hold-point" being missed (only to be discovered during later document review).
3 ~
Ten examples were noted where the PFEs or QC inspector sign-offs failed to comply with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> timeliness window, for "hold-point" sign-off in some cases by as much as ten calendar days.
4.
The dates accompanying the PFE sign-off for work activity "hold-points" were, in some case, the date of the completion of the work activity and not the date of the actual sign-off itself.
5.
Data intended to be included in the process sheet by the QC inspector,.at the time of sign-off, was included by others during data review after the fact.
Response
1)
FPL concurs with the finding.
2)
The overall reason for the finding was, failure to follow procedural requirements'he discussions below refer to the corresponding items identified in the finding above.
Item 1
The procedure which controls preparation of Process Sheets (PS) and Mechanical Process Installation Lists (MPIL) does not provide a mechanism for'nspection points that are not required to be performed in sequence The examples identified were inspection points that did not require sequencing.
- However, once labeled as hold points these inspections should have been completed prior to proceeding with the work.
Item 2 The steps on the PS/MPIL were signed off in error by the inspector.
- However, the error was identified and corrected during the final verification of the Inspection Reports versus the PS/MPIL.
This final verification forms a part of the QC process.
Item 3 The PFE maintained a copy of the PS in the field.
Based on discussions with construction and QC personnel, it is believed that the PFE signed the field copy of the PS after completing the inspection, but failed to sign the original.
The inspector believed that the PFE sign-off was required prior to his sign-off.
When the PFE did sign off on the original PS, he entered the date from the field copy of the PS.
Following PFE sign-off, the QC inspector signed off on the PS, entering the sign-off date.
Item 4 The procedures controlling the PS/MPIL s provide no specific direction as to whether the sign-off date is to be the date of completion of the work
activity or the date of the actual sign-off.
The PFE maintained a copy of the PS in the field.
Based on discussions with construction personnel, it is believed that PFE signed the field copy of the PS after completing the isspection, but failed to sign the original.
When the PFE did sign the original PS, he entered the date from the field copy.
Item 5 3)
Through oversight, the QC inspectors= neglected to include some information on the PS.
- However, the appropriate information was included in the Inspection Report.
As in item 2, these errors were identified and corrected at the final verification and the information was transferred from the Inspection Report to the PS.
As noted in item 2, the final verification forms a part of the QC process.
a.
A memorandum was issued to"the Project Field Engineers to emphasize that all Field Engineering inspections must be signed off within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the work activity is completed.
The memorandum also requires that the sign-off date be the actual date of the sign-off.
This memorandum was issued October 24, 1988.
b.
A memorandum was issued procedural requirements point activities before entries where required.
to Construction QC inspectors emphasizing the for timely sign-offs, fully completing hold sign-off and fully recording supporting data This memorandum was issued October 25,'988;
)
a.
A new Administrative Site Procedure will be issued to address the use of Process Sheets and Installation Lists.
This procedure will provide clear direction on the use of hold points and when sequencing is required.
The procedure will also provide criteria for an "inspection point" for Process Sheets and Installation Lists.
Training sessio'ns will be conducted for Backfit Construction Field Engineers and QC inspectors whose activities are controlled by Process Sheets and Installation Lists.
b.
QC will monitor compliance with the action described by 3) above on a weekly basis.
This monitoring will be performed in order to determine the effectiveness of the memorandums and will be continued at least until the action described by 4a is completed.
This monitoring may continue beyond completion of action 4a, depending on the results obtained.
- 5) 'ull compliance for the actions described in 4a above will be achieved by February 15, 1989.