ML17208A836
| ML17208A836 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/15/1980 |
| From: | Belisle G, Ruhlman W, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17208A832 | List: |
| References | |
| 50-335-80-07-01, NUDOCS 8007220088 | |
| Download: ML17208A836 (27) | |
See also: IR 05000335/1980007
Text
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Report No. 50-335/80-07
UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100
ATLANTA,GEORGIA 30303
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL
33101
Facility:
St. Lucie
Docket No. 50-335
License.,No.
I
Inspection at St. Lucie site near Fo
Pierce, Florida
Inspectors:
~ A. Ruhlma
a
at
Signed
G. A. Belis
e
Approved by:
C.
M. Upright
ti
ection Chief,
RONS Branch
/
SUMMARY
Inspection
on April 15-18,
1980
AreasInspected'te
igned
f~
n
ate
igned
This routine,
announced
inspection involved 48 inspector-hours
in office and 57
inspector-hours
on site in the areas of QA/QC Administration;
QA Program Review;
Housekeeping
and Cleanliness
Program;
Organization
and Administration;
Audits; Receipt Storage
and Handling of Equipment
and Material; Offsi'te Support
Staff; Design, Design Changes
and Modifications; Design Changes
and Modifications
Program;
Test and Experiments
Program;
Maintenance;
and Personnel Qualification
Program.
Results
Of the twelve areas
inspected,
no items of noncompliance
or deviations
were
identified in ten areas;
two apparent
items of noncompliance
were found in two
areas
(Infraction, failure to'follow procedure,
Paragraph
14.c; Deficiency,
failure to follow procedures,
Paragraph 9.c.)
0VO2
2OOPP
j
q+~~l+ V
4
DETAIIS
Persons
Contacted
Licensee
Employees
""A. Bailey,
QA Supervisor
-J. Barrows,
QC Operations
Superintendent
+J. Bowers,
Maintenance
Supervisor
+R.-'Englmeier,
QA Assistant
Manager
-T...Essinger,
QA Assistant
Manager
T;~ Grozan, Licensing Engineer-Nuclear
Licensing
"R. Jennings,
Technical Supervisor
>D. Oliver, Stores
Supervisor
+N. Roos,
QC Inspector
+A. Siebe,
QA Assistant
Manager
-R. Spooner,
QA Supervisor
-J. Vaux,
QC Supervisor
-J. Vessely,
QA Director
-J. Walls,
QC Inspector
+N. Weems,
QA Assistant
Manager Construction
-C. Wethy, Plant Manager
Other licensee
employees
contacted
included
17 engineering personnel,
3
purchasing personnel,
2 operators
and
3 office personnel.
-Attended exit interview
Exit Interview
The inspection
scope
and findings were summarized
on April 15,
1980 at
Florida Power and Light, corporate offices in Miami, Florida and
on April 18,
1980 at the St.
Iucie site with those persons
indicated in paragraph
1
above.
At the St.
Lucie site exit the licensee
was informed that inspector
identified items 335/79-21-07,08
and 09 would be closed.
The licensee
was
also informed of the two items of noncompliance
(Paragraphs
9.c.
and 14.c.)
and five unresolved
items
(Paragraphs
5.a., 7.a., 7.b.,
10.c.
and 13.d.)
due to the inspectors'indings.
The licensee
acknowledged
the
inspectors'indings.
Licensee Action on Previous Inspection Findings
~
(Closed) Unresolved
Item (335/79-21-02)
Revise
QI 16-PR-PSL-1
and QI
18-PR/PSL-2 to procedural
requirement practices that were currently being
carried out to fulfillregulatory items.
QI 16-PR/PSL-3,gas
revised
and
approved
on September
27,
1979 so that item 4.1.4 now formalizes the
process for escalation of items which are not resolved'-'at
a ..lower level.
QI 18-PR/PSI-2
was also revised
and approved
on September
27,
1979 so that
item 5.2.1 is now expanded
to specify the
QC Supervisor's jurisdiction in
the area of material handling,
storage
and shipping.
This item is
resolved.
4.
Unresolved
Items
Unresolved items are matters
about which more information is required to
determine whether they are acceptable
or may involve noncompliance
or
deviations.
New unresolved
items identified during this inspection are
discussed in Paragraphs
5., 7.a., 7.b., 10.c.,
and 13.d.
~
5.
Quality Assurance/Quality
Control Administration
In the previous review of this area
(August 1979, Report 50-335/79-11)
two
attributes of this program area
could not be reviewed since they were
corporate office functions.
These
two areas
were tracked
as items 335/79-
11-08 (verification of establishment
of responsibilities
and methods to
assure
review of overall effectiveness
of the
QA Program)
and 335/79-11-09
(Verification that methods exist and that actions
are taken to modify the
QA Program to provide additional emphasis in "identified problem areas").
These
items were reviewed at the corporate offices during this inspection
with the following results.
The program used
a Joint UtilityManagement Audit (JUMA) where personnel
from other utilities come in and perform a management
audit as the method
for reviewing the overall effectiveness
of the
QA Program.
In addition,
regular management briefings are held in which the outstanding audit
findings are reviewed.
These methods, collectively, meet the requirements
of the accepted
QA Program,
a'nd item 335/79-11-08 is closed.
Finding I of the
JUMA report documented
a tendency to address
only the
findings, and not their cause.
This apparent
weakness
was also supported
by an apparent
trend of increased
findings.
This would indicate that the
Program
had not been modified to provide the required additional emphasis
ih identified problem areas.
However, although responses
to this finding
had been received,
a proposed corrective action statement
had not been
formulated.
Since the inadequacy
had been identified by the licensee's
internal audit system,
no citation is issued.
However, until the licensee's
corrective action has been formulated and reviewed for adequacy
by NRC,
this item (335/80-07-01) is unresolved.
With the opening of this item, the
- previous inspector followup item (335/79-21-09) is closed.
6.
Quality Assurance
Program Review
C
References:
(a)
Letter, R. E. Uhrig to R.
W. Ried, serial L-80-46,
dated February 6,
1980
(b)
(c)
QI 16-PR/PSL-1,
"Corrective Action",.~Revision 5
approved 9/27/79
QI 18-PR/PSL-2,
"Quality Control Surveillances",
Revision 6'approved
9/27/79
"3"
Reference
(a)
was issued to place St. Iucie Unit
1 under the accepted
Florida Power and Light Company Topical Quality Assurance. Report
(FPLTQAR
or TQAR).
References
(b) and (c) were reviewed to ascertain that previously
unresolved
item 335/79-21-02
concerns
had been incorporated into the
revisions;
these
are detailed in Paragraph
3 of this report.
Other portions of the Quality Assurance
Program had been .revised in various
implementing procedures.
Where these procedures
were reviewed
as part of
other inspection activities, they are identified in the. appropriate detail
paragraphs.
lg
No items of noncompliance or deviations
were identified.
7.
Housekeeping
and Cleanliness
Program
References:
(a)
QI 10-PR/PSI-5,
"Technical Specification Surveillance
Inspection of Reactor Building", Revision
1 dated 2/80
(b)
QI 13-PR/PSL-2,
"Cleanliness
Control Methods",
Revision
3 dated 3/80
a.
Program Review
Two separate
reviews were conducted.
Since the
TQAR contains
a
commitment (Appendix C) to comply with ANSI N45.2.3 - 1973 as modified
and endorsed
by Regulatory Guide 1.39 date 3/16/73,
reference
(b),
was
reviewed with respect to the
TQAR as supplemented
by the standard.
Within that framework, administrative controls for general plant
housekeeping
were reviewed to assure:
housekeeping
zones
had been
established;
control of housekeeping
during work activities was
specified which included return of excess
equipment to a storage
area
and prompt removal of combustible material
and debris.
A separate
review of cleanliness
controls
was conducted to verify establishment
of:
cleaning requirements for safety-related
components;
cleanliness,
cleanliness
classifications;
material accountability
and control when
appropriate;
and,
requirements. for cleaning o'f primary system
components,
including maintenance
and cleanliness
of previously cleaned
systems,
during rework, replacement,
or repair.
During the review the inspector
found that the current program does
not follow the TQAR's commitment to ANSI N45.2.3 in that no zones
are
used
as specified in paragraph
2.1 of the standard.
The licensee is
currently in the process of taking exceptions
to or 'providing alterna-
tive approaches
or incorporating into existing procedures
various
aspects
of the standards
listed in Appendix
C of the 7(AR.
This
process
was in progress prior to this inspection
and those items which
will require
NRR approval are or will be included in Revision 3 of the
TQAR. Since this specific" issue
was part of that ongoing 'process
and
has not been closed by NRR action based
on the licensee's
submittal as
-4-
of the end of the inspection, this item (335/80-07-02) will be unre-
solved until after issuance
of the approved Revision
3 of the
TQAR.
Several other items identified during this inspection have this
same
status,
and have therefore,
been assigned
the
same item number for
tracking purposes.
These
items are discussed
in paragraphs
8,
9d and
10d of this report.
b.
Implementation
For implementation of housekeeping
and the routine cleanliness
require-
ments,
the licensee relies
on training of personnel
as
opposed to
detailed procedures.
As such,
housekeeping
and cleanliness
requirements
are not routinely delineated in work procedures.
To verify the adequacy
of this approach,
the inspector interviewed
one electrician
and one
special
crew maintenance
mechanic to determine their understanding
of
the requirements.
No items of noncompliance or deviations
were identi-
fied.
0
'hen cleanliness
requirements
are necessary
beyond the "routine"
level, the inspector
found that in all six cases
reviewed the
Engineer
had attached
the appropriate
section(s)
of reference
(b) to
the Plant Work Order
(PWO).
However, the inspector
was unable to find
any written requirement to perform this function to assure that it
would be continued if a different
QC Engineer performed the
PWO review.
Administrative Procedure
0010432, "Plant Work Order", Revision 14,
dated 9/27/79,
contains
a requirement
(Paragraph
8.3.2) for the
review of PWO's, but no specific requirement relative to specification
of cleanliness
levels is delineated.
As stated, all cases
reviewed
indicated that the licensee's
current practices
are acceptable,
there-
fore, no citation is issued for an inadequate
procedure
because
the
licensee
stated that the procedure
would be revised to reflect current
practices.
Until the stipulated revision has been
made
and reviewed
by NRC, this item (335/80-07-03) is unresolved.
8.
Organization
and Administration
Reference:
Letter, R. E. Uhrig to
W. P. Haass, serial I-79-337 dated
December
7,
1979
. The referenced letter notified the Quality Assurance
Branch of two
organizational
changes.
The first consisted of reorganizing the
Department
so that there were four Assistant
Managers
instead of the
original five.
The inspector found that one manager
had been transferred
and that his functional area
had been absorbed
by an existing Assistant
Manager;
thus,
no new personnel
or different qualification requirements
were required or inspected.
The other change
involved shifting the reporting path of the Site Construction
Manager from the current position of Director of Construction to the Project
General
Manager.
The inspector held discussions
with the Director'f
Project Management (to whom the Project General
Manager reports) to ascertain
if any dilution of authority or discounting of the problem resolution
capability had been'ntended
or had occurred.
Based
on these discussions,
no adverse
impact on the
QA Program
was evident.
The referenced letter
states that these organizational
changes will be included in the final
submittal of Revision
3 of the FPLTQAR. As with the other items in this
report which can not be evaluated for adequacy until Revision
3 of the
FPLTQAR has
been
approved by NRR, this item is included as
a part of the
unresolved
item identified in paragraphs
7a,
9d and
10d of this report
which is designated
335/80-07-02.
9.
Quality Assurance
Audits
References:
(a)
QP-16.1,
"Corrective Action", Revision
2 dated
10/79
(b)
QP-18.1,
"Conduct of Quality Assurance
Department
Quality Audits", Revision
3 dated
1/80
(c)
QP-18.2,
"Scheduling of Quality Assurance
Department
Audit Activities", Revision
7 dated 3/79
a.
Program Review
The referenced
documents
were reviewed with respect to the requirements
of the FPLTQAR. Specific items reviewed included:
qualifications,
training and independence
of audit personnel;
programatic
requirements
and methods for assuring corrective actions,
issuance
of audit reports,
and determining
when reaudits
are necessary;
provisions for periodic
review of the audit program to determine status
and adequacy;
and,
criteria for and preparation of long range audit plans
and schedules.
The inspector also verified that the audited organization is required
to respond to audit findings, in writing, and that audit checklists or
procedures
are required for the audits.
Distribution requirements
were also reviewed.
As a result, of this review, an additional aspect
of an unresolved
item was identified and two areas
were found which
will be referred to NRR for consideration
during the review of Revision
3
of the FPLTQAR.
These
items are discussed
in paragraphs
d and
e
below.
b.
Implementation
The inspector reviewed audits at the Company offices
(QAE audits)
and
at the St.
Lucie site
(QAO audits).
The specific items evaluated
during the Program Review above were inspected for implementation.
The audits
reviewed were:
QAE-CNRB-80-1 conducted
between 2/13/80.,and
2/gOJ80
i
~ r~P,>
QAE-QAD-80-1 conducted
between 2/11/80 and 2/15/80.,
QAO-PSL-79-.09-174 conducted
between
10/12/79
and 11/9/79
QAO-PSL-80-02-182
conducted
between 2/19/80 and 3/3/80
QAO-PSL-80-02-184
conducted
between 3/3/80
and 4/2/80
QAO-PSL-80-004 conducted
between ll/26/79 and 1/29/80
One item of noncompliance
was identified as discussed
in paragraph
c
below.
Failure to Follow Procedures
- Audit Response
The Joint UtilityManagement Audit (JUMA), QAE-QAD-80-1, was conducted
February
11-15,
1980.
Letter QAD-80-013 made the distribution of the
JUMA report to those individuals responsible for answering
one or more
of the three findings on February 20,
1980.
When the inspector
reviewed
this audit at the Corporate Offices on April 15,
1980, the response
to
Finding N3 had not been received.
This is contrary to the
FPLTQAR and
procedure
QP-18.1 which require
a response
within 30 calendar
days.
Paragraphs
5.4.3
and 5.4.4 of QP-16.1 specify
a series of actions to
be taken if a required response
is inadequate
or not received in the
specified time; these actions
were not carried out.
These failures to
follow procedures,
collectively, constitute
an item of noncompliance
(335/80-07-04).
When the licensee
was informed of this item, the responsible
organiza-
tion wrote the required
response
and it was provided to the inspector
prior to leaving for the site on April 15,
1980.
d.
Exception to ANSI N45.2.12
QP-18.1,
Paragraph
5.2, item 1, states
that onsite activity audits
conducted
by the construction
and operating plant groups
may omit the
pre-audit conference.
Paragraph
4.3.1 of ANSI N45.2.12
makes this
conference
manditory for all audits.
The licensee's
proposed Revision
3 to the FPITQAR takes
an exception to this requirement of the standard.
This item is combined with similar items discussed in paragraphs
7a,
8
and
10d of this report which will be evaluated after Revision 3 of the
FPLTQAR is accepted
by NRR.
This collective unresolved
item is desig-
nated 335/80-07-02.
e.
Item Referred to NRC Management for Review
The licensee's
procedure,
QP-18.1,
described,two
typm of audits;
management
audits
and activity audits.
Section 5.5 oMithat procedure
addresses
distribution of these audits by stating the management
audits shall be distributed to "appropriate
management
personnel
within the Company"; activity audits are to be distributed, at a.
minimum, to "the responsible
supervisor of the audited organization".
In all cases
reviewed,
the licensee
had made what the inspector
determined
was appropriate distribution.
However, in the absence
of
any more speci'fi'c criteria or a definitive distribution system,
the
inspector could not assure
himself that all audit reports
would be
distributed to appropriate
personnel.
Personnel
responsible for
determining distribution were interviewed.
One person stated that he
made distribution based
on past audit reports
and to anyone else
who
had indicated that he wanted
a copy.
the standard
followed by the FPLTQAR in this area,
states
(Section 4.4.6) that
distribution of the report shall include responsible
management
of
both the audited
and auditing organizations.
The current
QA program does not make use of reaudits,
as such; correc-
tive actions
are closed out, but no overall reaudit is conducted until
the area is again scheduled
as part of the routine program.
The ANSI
standard
addresses
this issue
by stating
(Paragraph
4.5.2) that followup
action may be accomplished
through written communication,
reaudit, or
.
other appropriate
means.
The inspector discussed
with the licensee
the possibility, especially
when several
items are found during the
audit of an area, that while individual corrective actions
could be
appropriate,
the combination of corrective actions
could produce
another problem.
Thus, in some cases,
a reaudit of the area
would be
necessary
to truly assess
the adequacy of the corrective action.
In both of the areas
mentioned
above,
the words in 10 CFR 50, Appendix
B, Criterion KVIII are
no more specific than the words in the ANSI
Standard
N45.2.12.
The licensee's
TQAR is currently under review by
NRR. These
two issues will be forwarded to NRC management for evaluation.
For tracking purposes
only since
no licensee action is required,
these
issues
are assigned
item 335/80-07-05.
10.
Receipt,
Storage
and Handling of Equipment
and Material
References:
(a)
QI 7-PR/PSL-1,'"Control of Purchased
Material, Equipment
and Services," Revision 4, dated 3/80
(b)
QI 7<<PR/PSL-2,
"Receiving Inspection", Revision
6
approved
2/80
(c)
QI 8-PR/PSL-l, "Identification and Control of Material,
Parts
and Components",
Revision
2 dated
2/79
(d)
QI 13-PR/PSL-l,
"Handling, Storage
and Shipping",
Revision 5 dated 3/80
(e)
QI 7-S-l, "Control of Purchased
Mater'.al", Revision
4
dated 3/79
~ c ~also selected
reviewed to determine that proper controls were in place:
Nuclear Steam Supply, System Diaphram,
MNS8 574-.3764
-9-
Unit jjl Containment Airlock Gasket,
MNS// 082-107
PT Developer,
MNSN 711-097
There is
a nearby warehouse
where large items are stored.
The inspector
selected
the following two items
and verified that these
items were
given the
same controls
as those received at the main warehouse:
10" safety-relief valve,
PO 21540-06461,
Item 30,
MNS// 572-1880
1/4" stainless
steel pipe,
schedule
40,
PO 67204-34353,
MNSN
561"636
As
a result of the above review and the tour of the warehouse,
one
unresolved
item, an additional aspect of another unresolved
item, and
an item to be referred to NRR for evaluation were identified,
These
items are discussed in paragraphs
c, d,
and
e below.
Small Water Leak in Warehouse
QI 13-S-1, paragraph
5.2.1B requires that the warehouse
be weathertight.
The storage levels specified in other procedures
dictate that water
leakage into the warehouse is not acceptable.
During the tour of the
main warehouse,
the inspector noted
a small (approximately three
square
inches)
puddle of water on the floor between
two racks of
material; it had not rained at the site for three days.
The licensee
initiated action to have the leak in the roof reviewed
and to make
necessar'y provision for repair.
Since the size of the leak was very small,
and since
no material in
storage
was or could be affected by the leak,
no citation is appropriate.
However, until the required repairs
have been effected
and reviewed,
this item (335/80-07-06) is unresolved.
Exceptions to ANSI N45.2.2
During the program review, the inspector noted several
areas
where the
current procedures
do not meet the FPLTQAR's commitment to ANSI N45.2.2.
As before,
the licensee
was aware of these differences
and was in the
process of including exceptions,
alternative
approaches,
or current
program modifications.
During the implementation review,
a requirement
of a current procedure
was not yet in place
((Paragraph
5.2.1 or QI
7-S-1); this was
a program to control limited shelf life items.
Again, the development
and implementation of this program is dependent
on the conditions
imposed by Revision
3 of the FPLTQAR. These items,
collectively, are combined with the other aspects
of..-t)e program which
can not be evaluated until Revision
3 of the
FPLTQAR x.s accepted
by
NRR. The item is designated
335/80-07-02
and other 'aspects
are addressed
in paragraphs
7a,
8 and 9d of this report.
Although the list below is
not all inclusive, the inspector noted the following specific'ifferences
between the current program and the current
FPLTQAR commitments;
"10-
Paragraph
2.2 of the standard
requires procedures
to contain
sufficient detail to provide for the listed items
a basis for
receiving in accordance
with the standard.
There .was no check-
list provided for the "shipping damage inspection" of paragraph
5.2.1
(performed by Stores personnel),
and the
4 line entry for
acceptance
criteria on the
gC Inspector's
checklist does not
cover the
16 specific line items of paragraph 5.2.2 of the standard.
Personnel
interviewed could not detail the specific requirements
of the standard
from memory.
While a copy of the standard
was
available in the receiving area,
personnel
interviewed stated
that the copy was not used while performing the inspection.
Paragraph
5.2.1 of the standard
requires
the completion of the
"shipping damage inspection"
PRIOR to unloading;
the licensee's
procedures
specify that the inspection is to be performed
AFTER
unloading.
Paragraph
5.6 and others of the standard
require packages
to be
marked in accordance
with the very specific requirements
of
Appendix A 3.9; these
requirements
are not currently met or
inspected.
Paragraph
6.4.2(6) of the standard
requires
the meggering of
rotating equipment in storage
on a periodic basis;
no program
currently exists to perform this function.
Paragraph
6.4.2(7) of the standard
requires
the rotating of the
shafts of all rotating equipment in storage; this is not currently
being accomplished.
Paragraph
7.4 of the standard
specifies
a hoisting equipment
qualification and certification program;
the licensee is taking
exceptions
to some specific requirements in this section based
on
a previous inspection at the Turkey Point facility (50-250/79-11;
50-251/79-11).
The equipment classification requirements
of paragraph
2.7 of the
standard
are not currently in use.
Paragraph
2.4 of the standard
requires that ALL personnel
performing
inspections
be qualified/certified in accordance
with ANSI N45.2.6;
currently the Stores personnel
who perform the "shipping damage
inspection" are not meeting this requirement.
The inspector did not find any cases
where the
absentee
of the above
items adversely affected the ability of the hquipmen~q perform its
safety-related
function.
While the lack of a program For controlling
items with a limited shelf life had such
a potential,
no items had
currently been stored for a length of time where deterioration would
be expected to begin.
While rotation and meggering were not performed
in storage,
these
items are
checked during and after installation;
-11-
this could adversely affect unit reliability, but not safety.
The
inspector also stated that he had
NOT performed
a detailed line-by-line
review of the standards
involved; this review was part of the licensee's
ongoing "baseline
document" review.
e.
Item Referred to NRC Management for Evaluation
In reviewing stored items,
the inspector noted that safety-related
components
are not identified as such.
The only differentiation is
based
on the designation
"QC Required",
"Receiving Inspection Required",
and "No Substitution Allowed".
Such items
as the Pressurizer
Manway
the Unit 1 Containment Airlock Gasket,
various valves,
breakers
and pumps which are safety-related
are ordered
as
"No QC Required"
based
on the fact that,
under the licensee's
program,
they are
"Commer-
cial Grade".
While no specific inadequacy
was noted during the inspec-
tion, copies of the licensee's
implementing procedures will be forwarded
to NRC Headquarters
for possible
review in conjunction with the
current
NRR evaluation of the
FPLTQAR Revision 3.
Since
no specific
action is required or requested
from the licensee,
this item is desig-
nated
as
an inspector followup item and is assigned
the number 335/80-
07-07 for tracking purposes
only.
ll.
Quality Control Surveillances
References:
(a)
QI 18-PR/PSL-2,
"Quality Control Surveillances,"
Revision
6 dated
10/79
(b)
QI 18"PR/PSL-3, "Quality Control Monitoring", Revision
2 dated
6/79
One of the Quality Assurance audit functions involves verification of
adequate
QC coverage of significant site activites.
The inspector
reviewed
fifty QC Surveillance reports
taken from a period between
September
19,
1979 and February 28,
1980.
These surveillances
covered various site
activities including maintenance,
operations,
receiving inspection
and
monitoring of work activities.
No items of noncompliance
or deviations
were identified,
12.
Offsite Support Staff
References:
(a)
EPP QI 1.2
QA Program Delegation to Participating
Organizations
by Power Plant Engineering,
Revision 0,
Dated 4/ll/77
(b)
EPP QI 2.2
QA Indoctrination and Training, Revision 1,
Dated 3/17/80.
(c)
EPP QI 2.3 Classification of Activities,"'Structures,
Systems
and Components,
Revision 0, Dated 3/7/80.
-12-
(d), EPP QI 2.3B, Classification of Structures,
Systems
and
Components,
St.
Lucie Plant, Revision 0, Dated 3/7/80.
(e)
EPP QI 3.1, Control of EPP Design, Revision 2, Dated
10/19/72.
(f)
(g)
EPP QI 3.2, Identification and Control of Design
Interfaces-EPP
Design, Revision 0, Dated 4/7/78.
EPP QI 3.3, Plant Changes/Modifications,
Revision 1,
Dated 3/19/79.
(h)
EPP QI 3.4, Control of Field Design Changes,
Revision
0, Dated 4/25/78
AP 2.3, Workload Planning
and Management,
Revision
0, Dated 6/15/78
Department
Approved
Suppliers List Dated 4/1/80.
(k)
QI PUR l-l, Instructions for Implementating the
Purchasing
Department
(Operating Plants) Quality
Assurance
Program, Revision 3, Dated 1/10/79.
(m)
QI PUR 2-1, Instructions for Indoctrinating, Training,
and Qualifying Purchasing
Personnel
(Operating Plants)
for Nuclear Procurement,
Revision 3, Dated 1/10/79.
QI PUR 4-1, Instructions for Processing
and Routing of
Procurement
Documents for Spare Parts
and Replacement
Items Revision 5, dated 8/21/78.
(n)
QI PUR 6-1, Document Control, Revision 3, dated 8/21/78.
(o)
QI PUR 17-1, Instructions for Storage
and Maintenance
of Purchase
Orders
and Related Documentation,
Revision 0,
'Dated 2/7/80.
(p)
FPL QAM, Quality Assurance
Manual
QP 18.1,
Conduct of Quality Assurance
Department Quality
Audits Revision 3, Dated 1/10/80.
Program Review
r
CI'
-~g~$
~
The Referenced
documents
were reviewed to verify that, the licensee
established
administrative controls to describe the'esponsibilities,
authority and lines of communications available for personnel
who
perform the following offsite support functions:
(1)
Design
-13"
(2)
Technical Support
r
(3)
Quality Assurance
(4)
Procurement
(5)
Construction
(6)
Interface
Between onsite
and Offsite Functions
.
Additionally, the inspector verified that the procedures
are in conformance
with the requirements
of 10 CFR 50, Appendix B and the licensee's
approved
QA Program.
b.
Implementation
The inspector interviewed
one manager,
one group leader
and one staff
member in the diciplines mentioned,
where possible,
and verified they
understood their responsibilities
and authorities
and that they were
qualified for their related work.
The inspector
reviewed the results of two QA audits;
QAS-EPP-79-2
and
QAP-PUR-79.1
and ascertained
that corrective action for identified
deficiencies
had been
completed in a satisfactory
manner.
No items of noncompliance
or deficiency were identified.
~
~
13.
Design, Design
Changes
and Modifications
References:
(a)
EPP QI 3.1, Control of EPP Design, Revision 2, Dated
10/19/72.
(b)
EPP QI 3.2, Identification and Control of Design Inter-
faces-EPP
Design, Revision 0, Dated 4/7/78.
(c)
EPP QI 3.3, Plant Changes/Modifications,
Revision 1,
Dated 3/19/79.
I-
4
(d)
EPP QI 3.4, Control of Field Design Changes,
Revision
0, Dated 4/7/78.
(e)
QP 3.1, Evaluation of Contractor Design, Revision 2,
Dated 4/28/78.
(f)
QP 3.2, Identification of Control Design Interfaces,
Revision 1, Dated 6/6/79.
II
(g)
OP 3.4, Plant
Changes
and Modifications, for Operating
Plants, Revision 2, Dated 8/14/78.
-14-
(h)
gP 3.6, Control of FPL Originated Design, Revision
2
Dated 9/28/79.
'I
(i)
(}P 6.6,
FPL Drawing Control, Revision 1, Dated 8/6/79
(j)
T(}R 3.0, Design Control, Revision 1, Dated 8/15/76
a.
Program Review
The referenced
documents
were reviewed with respect
to the licensees
accepted
QA Program
and ANSI N45.2.11,
1974,
as committed to by that
program.
The inspection verified that design
changes
were reviewed in
accordance
with the Technical Specifications
and the Established
gA
Program;
that design
changes
were conducted in accordance
with approved
written procedures;
that acceptance
test records
were reviewed and
approved; that operating procedures
and modifications were made
and
approved; that installation procedures
were adequate for the identified
function; that drawings were changed to reflect the modifications;
that records
were maintained
as required
and that installation of the
modification was
as described in the design
change
package.
b..
Implementation
The inspector
reviewed the design
changes
and modification area
and
verified that design
changes
and modifications are in conformance with
the requirements
of the Technical Specifications
and
Eleven safety-related plant changes/modification
packages
were reviewed.
The specific items reviewed were:
(1)
PC/M 150-76, Ioss of Diesel Generator
Control Power Annunciator.
(2)
PC/M 335-78, Replace
Selected Hydraulic Restraints with Mechanical
Seismic Restraints
(3)
PC/M 454-78,
Charging
Pump Discharge Pulsation
Damper Phase l.
(4)
PC/M 485/78,
Steam Generator Modifications Rim Cut
(5)
PC/M 512-78, Install Hour Meters
on Charging
Pump Breakers
(6)
PC/M 521-79,
Add Union to Auxiliary Feed
Pump Turbine Bearing
Cooling Water Lines.
(7)
PC/M 535-79
7
Clip.
(8)
PC/M 550-79,
Steam Generator Primary Mainway Gasket Retainer
~ f
~W~
~~p
~
CEA Guide Tube Modification
(9)
PC/M 569/79, Autoinitiation of ESFAS "CIS" Upon Actuation of
"SIAS".
-15-
(10)
PC/M 411-78,
Containment Cooler Relief Valve Flanges
(ll)
PC/M 293-77,
Temporary Test Connections for Charging System.
As
a result of the review the inspector identified one unresolved
item
as discussed
in Paragraph
c. below.
c.
Incomplete Documentation
In reviewing PC/M 485-78 the inspector noticed that the procedures
for
completion of the work by the contractor required certain steps
to be
witnessed
and signed off.
Upon termination of the work these
completed
records
were taken by the contractor.
The licensee verified by a
telephone
conversation to the contractor
on 4/17/80 that the records
were available in the contractor
home office and copies
would be sent
to the licensee within 10 working days of the telephone
conversation.
Until these
records
can be reviewed this item is unresolved
(335/80-
07-08).
14.
Design Changes
and Modifications Program
References:
(a)
QI3PR/PSC-l,
Design Control After Fuel Ioad, Revision 5,
Dated 10/79.
(b)
QP 3.4 Plant
Changes
and Modifications for Operating
Plants,
Revision 2, Dated 8/14/78.
(c)
AP 0010124 Control and Use of Jumpers
and Disconnected
Leads in Safety Related
Systems,
Revision 5, Dated
3/2/79.
a
~
Program Review
The referenced
documents
were reviewed with respect to the licensee's
accepted
QA Program
and the requirements
of 10 CFR 50.59
and ANSI
45.2.11Property "ANSI code" (as page type) with input value "ANSI</br></br>45.2.11" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
1874,
as committed to by that program.
The inspection
was to
verify that procedures
had been established
for control of design
and
modification change requests;
that procedures
and responsibilities for
design control have been established;
that administrative controls for
design document control have been established;
that responsibility
had been established
in writing to assure
necessary
implementation;
that administrative controls
and responsibilities
have been established
to assure that design
changes
and modification are incorporated into
plant procedures,
operator training and the updating of plant drawings
in a timely manner; that controls have been developed
which define
changes
of communication between design organizations
and responsible
individuals; that administrative controls r'equire
rec'deeds
of design
documentation
and review be collected
and transmitted for storage;
that design
changes
be accomplished in accordance
with approved
procedures;
that controls require post modification acceptan'ce
testing be performed
and results
approved; that responsibility has
been assigned <or identifying post modification testing requirements
and acceptance
criteria;
and that responsibility and methods for
reporting design
changes
and modifications to the
NRC in accordance
with 10 CFR 50.59 have been assigned.
The conclusion with respect to
the acceptability of this area is given in Paragraph
b.
P'
~
(Use of jumpers
and disconnected
leads in
safety related
systems)
were reviewed to assure that controls require
the review and approval of temporary modifications in accordance
with
the Technical Specifications
and
10 CFR 50.59; thai controls require
the use of approved procedures;
that controls require records
be
maintained of status of jumpers
and disconnected
leads; that controls
require functional testing of equipment following removal of temporary
modifications;
and that controls require periodic reviews of records
of jumpers
and disconnected
leads including a check of outstanding
entries.
Conclusions with respect to the acceptability of this area
are given in Paragraph
b.
Implementation
The licensee
program for design
changes
and modifications
was reviewed
at St.
Lucie site.
The program had previously been inspected
during
the
QA inspection in March,
1979 at Florida Power and Light corporate
offices.
This inspection is documented in IE Inspection Report 50-250,
50-251/79-11.
During this review the inspector identified one item of
noncompliance
as discussed
in Paragraph
c
c.
Failure to Follow Procedure
The Technical Specifications, Section 6.8.1, states in part that
written procedures
shall be established,
implemented
and maintained.
AP 0010124 Control and Use of Jumpers
and Disconnected
Leads in Safety-
Related
Systems
Section 5.4, requires in part that the
IRC Supervisor
and the Assistant Superintendent Electrical Maintenance,
are responsible
for reviewing, with the Operations
Supervisor,
the disconnected
and temporary jumper log prior to each refueling.
Contrary to the above,
the IRC Supervisor
and the Assistant Superin-
tendent Electrical Maintenance
and the Operations
Superintendent
did
not review the Disconnected
Lead and Temporary Jumper Iog prior to the
refueling that
commenced
March 15,
1980.
This failure to follow
procedure constitutes
an item of noncompliance
(335/80-07-09).
15.
Test and Experiments
Program
References:
(a)
TQR 11, Test Controls, Revision 0, dat'el '1/23/76.
e
(b)
QP 11.1, Test Control Construction,
Revision 1, dated
8/15/75.
'
-17-
(c)
QP 11.2, Test Control-Operation,
Revision 0, dated
9/15/74.
(d)
QP 11.3, Test Control - Pre-Operational
and Startup
Test, Revision 0, dated 9/1/74
(e)
gP 11.4, Test Control Program, Revision 1, dated
8/16/76.
ac
Program Review
The inspector verified that
a formal method has
been established
to
handle requests
or proposals for conducting plant tests
and experi-
ments involving safety related
components,
systems
or structures;
that
provisions
have been
made to assure test and experiments will be
performed in accordance
with approved written procedures,
that respon-
sibilities have been assigned for reviewing and approving test
and
experimental procedures;
that a system,
including assignment
of
responsibility,
had been established
to assure that all proposed tests
and experiments will be reviewed to determine whether they are described
in the FSAR and that responsibilities
have been assigned
to assure
that safety evaluations
as required by 10 CFR 50.59 will be developed
to assure that it does not involve an unresolved safety question or a
change in the Technical Specifications.
Implementation
The licensees
program for test
and experiments
was reviewed at the
St. Iucie site with respect to the referenced
documents.
One test
performed in 1977,
Charging System Pulsation
and Vibration Testing,
was reviewed.
No items of noncompliance or deficiency were identified.
16.
Maintenance
The references
and program review for this area are identified in IE Inspec-
tion Report 50-335/79-21,
paragraph
9.
The inspector reviewed the circum-
stances
associated
with the following maintenance activities on safety
related
equipment to determine if the reporting requirements
of the Technical
Specifications
were adhered to:
PWO 2941, Fuel Handling Building Ventilation
PWO 2963, Replace
Gasket in FCB-23-5
PWO 2863, Inspect "C" CCW Pump
PWO 2902, Replace
"B" Charging
Pump Stuffing Box
/
-.18"
PRO 2940, Replace
PRO 2942, Fuel Oil Ieak in "B" Diesel Generator
PRO 2934,
Repack "A" Charging
Pump
No items of noncompliance
or deviation were identified.
17.
Personnel Qualification Program
The references
and program preview for this activity are given in IE
Inspection Report 335/79-21,
paragraph
6.
The inspector
reviewed the
permanent
and alternate
membership of the
Company Nuclear Review Board and
verified that their qualifications were in accordance
with established
requirements.
As a result of this review, inspector followup item
335/79-21"07 is closed.