ML17221A682

Responds to NRC 880225 Ltr Re Violations Noted in Insp Repts 50-335/86-08 & 50-389/86-07.All Environ Qualification Files Have Been Reviewed,Revised & Converted Into Doc Pacs & Placed Under Control of Drawing Program

ML17221A682
Person / Time
Site:	Saint Lucie
Issue date:	03/21/1988
From:	Conway W FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-88-137, NUDOCS 8803250297
Download: ML17221A682 (6)

Text

". ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM INFORMATION DISTRIBUTION SYSTEM (RIDS) 'EGULATORY SSION NBR:8803250297 DOC.DATE: 88/03/21 NOTARIZED: NO DOCKET CIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILZATION CONWAY,W.F. Florida Power & Light Co.

RECI0.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 880225 ltr 50-335/86-08 & 50-389/86-07.

re violations noted in Insp Repts DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response D NOTES:

S RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 TOURIGNY,E 2, 2 A

INTERNAL: ACRS 2 2 AEOD 1 1 DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/PEBllB 1 1 NRR/DLPQ/QAB10A 1 1 NRR/DOEA DIR11E 1 1 ~ NRR/DREP/EPB10D 1 1 NRR/DREP/RPB10A 2 2 NRR/DRIS DIR9A2 1 1 NRR/PMAS/ILRB12 1 1 OE LIEBERMAN,J 1 1 OGC 15-B-18 DIR 1

1 1

1 0M'TCEy RGN2 FILE 01 02 1 1

1 1

RES/DRPS AL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

'OTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

r FLORIDA POPOVER 8 LIGHT COY>w",

k)ARCH 2 1 1988 L-88-137 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Ins ection Re ort 335 86-08 and 389 86-07 Florida Power & Light Company has reviewed the Notice of Violation dated February 25, 1988, and pursuant to the provision of 10 CFR 2.201, the response is attached.

Very truly yours, gC"Vr)'u"~yf W. F. Connw iy Acting Group Vice President Nuclear Energy WFC/GRM/gp Attachment cc: Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant

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GRM/001.IR BS03250297 830321 PDR ADOCK 05000335 0 DCD PEOPLE, . SERVING PEOP=".

FINDING A 10 CFR 50.49 Paragraph (J) requires in part, that a record of the qualification, iricluding documentation in Paragraph (D) of this section, must be maintained in an auditable form to permit verification that each item of equipment important to safety covered by this section is'(1) qualified for its application and, (2) meets its specified performance requirements when it is 'subjected to the conditions predicted to be present when it must perform,its safety function..

Contrary to the above, at the time of the inspection and as far back as November 30, 1985, the, following environmental qualification (EQ) files did not adequately demonstrate qualification of various equipment. The data contained in the.EQ files

~

were inauditable in that the information was not documented and organized so as to be readily understandable and traceable. Additionally, the data did not permit independent verification of inferences or conclusions based on the documented information for the following equipment'.

Rockbestos coaxial cable EQ File No. 6.3 (Unit 2)

ITT Barton 763 and 764 Pressure Transmitters EQ File No. 9.2 (Unit 2)

TEC Acoustic Flow Monitoring Systems EQ File Nos. 22.0 and 23.0 (Unit 1); EQ File No. 8.5 (Unit 2)

Rome Cable EQ File No. 19.0 (Unit 1)

Garrett Solenoid Valves - EQ File No. 35.9 (Unit 2)

General Cable EQ File No. 8.0 (Unit 1)

Victoreen Radiation Monitoring System - EQ File No. 26.0 (Unit 1)

RESPONSE

1. Florida Power R Light Company (FPL) concurs with the finding.

2t Based on the NRC concerns identified in the NRC EQ Inspection Report dated August 7, 1986, there were three main reasons for the finding. The first can be traced to the fact that unofficial hard copies of the EQ Files were inspected rather than 'the official record copy on microfilm in the St. Lucie QC Vault.

The second is a difference in engineering opinion of the acceptable methods and levels of documentation required to demonstrate qualification. The third was a lack of time to respond to the question raised by the inspector on the morning of the last day of the inspection.

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The following specific items mentioned in the Notice of Violation are examples of the first reason. A recent review of the microfilm record copy indicated that the entire profiles for the Rockbestos cable (Unit 2 EQ File 6.3) and for the ITT Barton Transmitters (Unit 2 EQ File 9;2) were in the record copy at the time of the inspection and had been xeroxed incorrectly when the hard copies were made. (The profiles were on fold out pages and were copied in the folded position.)

Similarly for Rome cable (Unit 1 EQ File 19.0), the entire Franklin Report is in the record copy even though pages may have been missing in the hard copy that was inspected. (It is unclear at this time whether the pages were missing from the hard copy since a recent review of the hard copy indicated that all the pages of the Franklin Report are there and the latest revision date is 4/25/85.)

The following items are examples of the second reason. In the TEC Acoustic Flow Monitoring System files (Unit 1 EQ Files 22.0 and 23.0 and Unit 2 EQ File 8.5), the mild environment and seismic portions of the report had been removed to conserve paper on Unit 1 but were included on Unit 2 (the files were assembled by different consultants.) Since mild environment and seismic qualification are outside the scope of 10CFR50.49 this was considered acceptable.

Also, there was no reason to doubt that the appropriate testing had been done and that the actual data taken during the test (and considered proprietary by TEC) was available for review at the vendor's facilities for the following reasons.

1) The test reports received from TEC indicated that the, testing program performed by TEC was very complete.

2) A procedure describing the functional testing to be performed during the LOCA was referenced in the files.

3) A word description of the functional performance of the system during the LOCA was contained in the files.

4) FPL's QA department had audited and approved TEC's QA program.

Therefore a special audit to review the data was deemed unnecessary.

Similar circumstances can be noted for the Garrett Solenoid Valves (Unit 2 EQ File 35.9) and the Victoreen Radiation Monitoring System (Unit 1 EQ File 26.0).

The Garrett SCEW sheet did not require a one year post DBA operability (Unit 2 has a maximum post 'BA of 180 days) and during the inspection was demonstrated not to be required at all. Forty (40) year life was demonstrated by the aging done in the test report and the Arrhenius calculation done in the test report procedure that were in the file. Applicability of the reports to the valves 'installed was demonstrated by two Combustion Engineering letters and the use of gaskets that were not pre-irradiated was dispositioned by Garrett through supplemental testing and similarity analysis. The Victoreen qualification Page 2 of 4

was based on analysis backed up by actual conditions experienced at TNI which exceeded the requirements at Unit 1. These again were in the files at- the time of the inspection and considered adequate by FPL.

The final item, General Cable (Unit 1 EQ File 8.0), is the result of the third reason. The question of air thermal aging qualification arose on the morning of the last day of the inspection with no time to respond. FPL had developed several methods in the EQ File to demonstrate qualification of the General XLPE cable, the strongest of which was considered to be the Raychem report "

qualif ying their XLPE cable which was pre-aged. A second method also considered acceptable used the General Cable 'LOCA report on their XLPE cable that was not pre-aged and the original 79-01B aging analysis on the Since this item identified to just prior to the inspection exit General'able.

was FPL meeting, there wasn't time to point this out to the inspector.

3. The EQ Files reviewed by the inspectors have been converted from record files to Environmental Qualification Documentation Packages (doc pacs) which are living documents presently controlled under the FPL drawing program.

t 4.

5.

Comments made by the inspectors have been incorporated into the doc pacs.

All EQ Files have been reviewed, revised and converted into doc pacs and placed under the control of the drawing program, Work began immediately after the April 1986 inspection to convert the EQ files to doc pacs. The first revised doc pacs were issued in June 1986 with 60 percent of the work completed by the end of September 1986. The last of the original files was converted and issued by January 30, 1987. However, since the files are now living documents, they will be continuously revised and updated.

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FINDING B 10 CFR 50.49 (f) states in part, that each item of electrical equipment important to safety shall be qualified by testing of or experience with, identical or similar equipment, and qualification shall include supporting analysis to show that the equipment to be qualified is acceptable.

Contrary to the above, at the time of the inspection, environmental qualification (EQ)

File No. 39.1 (Unit 2) did not adequately demonstrate qualification of RDF Resistance Temperature Detectors (RTD), in that data required to support a qualified life of the RTV sealant used in the detectors were not included in the file.

RESPONSE

1. Florida Power & Light Company (FPL) concurs with the finding.

2. During the Combustion Engineering (CE) LOCA testing of the RTD's a problem with moisture intrusion developed. To correct this a high temperature, radiation resistant RTV was used to pot the RTD head and LOCA testing was completed. Two letters (CE letter L-CE-8878 dated 6/29/83 and Ebasco letter P-M-SL-84-035 dated 1/10/84 included in the file prior 'o the time of the inspection) documented that although the RTV was not aged or irradiated it would be qualified for a 22 month period (actual Arrhenius calculated life based on data from the Ebasco letter was 81.44'years) and work began to redesign the RTD head or find a suitable replacement for the RTD's. It was decided to replace the RTD's, however, suitable qualified replacements could not be found or obtained in time to support the outage. Therefore the gaskets and RTV were replaced during the outage to, keep the CE/Ebasco letters valid for an additional refueling cycle. During the inspection, the inspector determined that this was an unacceptable method to demonstrate aging qualification.

3t During the inspection an additional calculation was done which demonstrated that the LOCA test had sufficient margin to qualify the RTV for over a 40 year life as well as the required DBA. The inspector agreed that this was acceptable and that the calculation should be incorporated into the file. This was done during the review and conversion of the files into doc pacs.

4, All EQ Files have been reviewed, revised and converted into doc pacs and placed under the control of the drawing program.

5. In addition to incorporating the comments made by the inspector, information from General Electric on the RTV was obtained and included in the new RDF RTD doc pac. The doc pac was then issued in January 1987.

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