ML17227A291

Responds to NRC 920211 Ltr Re Violations Noted in Insp Rept 50-335/91-24 on 920210.Corrective Actions:Radiographic Rept Form Was Revised to Clarify Info Required & Film for Five Welds Were Remarked

ML17227A291
Person / Time
Site:	Saint Lucie
Issue date:	02/11/1992
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-92-32, NUDOCS 9202180192
Download: ML17227A291 (6)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9202180192 DOC.DATE': 92/02/11 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. '5000335 AUTH. NAME AUTHOR AFFILIATION

, GOLDBERG,J.H'. Florida Power & Light Co.

'RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 920211 ltr re violations noted in insp rept 50-335/91-24 on 920210.Corrective actions:Radiographic Rept Form was revised to clarify info required & film for five welds were remarked.

DISTRIBUTION CODE: IE01D COPIES RECEIVED'LTR ENCL SIZE:

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

RECIPIENT COPIES COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 -1 NORRIS,J 1 1 INTERNAL: ACRS AEOD/DEIIB 2

1

-1'ECIPIENT 2

1 AEOD AEOD/DS P/TPAB 1

1 1

1 DEDRO 1 1 NRR HARBUCKi C ~ 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1

.NRR/DREP/PEPB9H 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 -1 OGC/HDS3 1 1 c~

RE "=F-. 1 1 RGN2 FI LE 01 1 1 EXTERNAL: EG&G/BRYCE,J.H.

NSIC 1

1

- 1, NRC- PDR 1 1 D

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D NOTE TO ALL "RIDS" RECIPIENTS

, PLEASE HELP US TO REDUCE XVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiv! Pl-37 (EXT. 20079) TO ELlik!!NATE YOUR NAlv!E FROiil DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'7 NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

P.O. Box14000,Jurro Beach,FL 33408 0420 r;

PP'L FEB ) 1 3992 L-92-32 2.201

'0 CFR U. S. Nuclear Regulatory Commission Attn: Document Control Desk Wash'ington, D. C. 20555 Gentlemen:

Re: St. Lucie Unit No. 1 Docket No. 50-335 Reply to Notice of Violation Ins ection Re ort 91-24 Florida=Power and Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201 the response is attached.

Very truly yours, J. H. Goldberg President .Nuclear Division JHG/JWH/kw Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region Senior Resident Inspector, USNRC, St. Lucie Plant II DAS/PSL 616-92 92021801'92 920211 PDR 6

ADQCK 05000335 PDR r>.

an FPL Group company

'~

ATTACHMENT REPLY TO NOTICE OF VIOLATION FINDINGe 10 CFR 50, Appendix B, Criterion V as implemented by Florida Power and Light Company's Topical Quality Report 1-76A requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. .Florida Power and Light (FP&L) Company's Radiographic Inspection Procedure ITS 9.3, Revision 0, paragraph 14.F requires that; permanent, non-permanent, and info films shall have the following identification permanently included on each film by use of lead characters during exposure or by visible light imprinter. The film identified shall not. obscure the area being evaluated and shall be legible:

• FPL-PSL-No. Unit number

• PC/M or CWO No.

• System or Component Identification and Drawing No., Rev. No.

• Weld No. or part number (as applicable)

• Weld Repair Report No.

• Date (If applicable)

Contrary to the above, On December 5, 1991 radiographic film for weld CH-554-001M, CH544-001N, 2F1-HVS-001D, and 2Fl-HVS-101 were found either failing to have permanent film identification on the film, having film identification that was not legible, or having only partial film. identification acquired by procedure T.S.9.3. In addition, the Radiographic Inspection Report for weld 2F-1-CH-0553-030 had not been signed or dated by the radiographer, weld 2F-1-CH-0544001N had been dated by the radiographer with a date 6 months after the film had been reviewed and repaired, and wel'd 2F-1-HVS-0010 had missing entries for the Report No. of exposures, and number of film which was in violation of procedure T.S.9.3.

paragraph 17.B.1

RESPONSE

1. The reason for the violation was personnel error.

2. A review of every radiograph and associated report for the period January 1, 1990 through December 31, 1991 was performed. The results of this review were as follows: 1) no films were missing; 2) film for five welds were remarked because the film identification was either partially visible or not visible at all; 3) one report had the radiographer's signature missing; 4) several reports had a few unmarked blocks (e.g., shim material or lead screen). This review and any necessary corrections were completed on January 14, 1992.

3. Technique Sheet 9.3 "Radiographic Inspection" was reviewed and corrected by a Limited Change Notice to eliminate unnecessary film and film envelope marking requirements. The Radiographic Report Form was revised to clarify and .streamline the information required and include -,,a checkoff by the radiographer to ensure all required film identification is legible on the film; Inspectors and document review personnel have been retrained in these requirements. The final training class was held on February 10, 1992.

4. Full compliance was achieved on February 10, 1992.

All permanent radiographs conducted during the Spring 1992 Unit 2 outage, will be reviewed by the Nuclear Assurance NDE Level 3 inspector to ensure that all problems with film identification and inspection have be'en completely resolved.-