ML17338A995
| ML17338A995 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/20/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17338A993 | List: |
| References | |
| 50-250-79-11, 50-251-79-11, NUDOCS 7908160185 | |
| Download: ML17338A995 (8) | |
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APPENDIX A
'OTICE OF VIOLATION Florida Power and Light Company Turkey Point Units 3 and 4
License Nos.
DPR-31 6 DPR-41 Based on the NRC inspection Harch 12-16, 1979, certain of your activities were apparently not conducted in full compliance with hRC requirements as indicated below.
These items have been categorized as described in correspondence to you dated December 31, 1974.
A.
As re uired b 10 CFR 50 A
endix B
Criterion V "Activities affectin q
PP 7
g quality shall be prescribed by documented
. procedures and shall be accomplished'n accordance with these procedures The accepted Quality Assurance
- Program, Paragraph 5.1 requires "Activities affecting quality'
. shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures 1t Quality Procedure (QP) 2.4, Paragraph 5.1 requires quality instructions to be developed when it is necessary to delineate actions and responsi-bilities that involve activities within a department and/or organization and are unique to that activity.
Contrary to the
- above, no instruction exists which indicates the source documents to be utilized in the determination of quality require-ments for safety-related structures systems and components.
2.
The accepted Quality Assurance
- Program, Paragraph 2.2.4 requires the Quality Assurance Department to be responsible for the control of the QA Program.
Contrary to the above, the Quality Assurance Department has no formal method of control over the designation of safety-related items as contained in the "Q"-List and Westinghouse Spin List.
The accepted Quality Assurance Program, Appendix C, commits to Regulatory Guide 1.38 which endorses ANSI N45.2.2-1972.
ANSI N45.2.2 Section 7.4 requires a program be established for inspection of hoisting and rigging equipment.
4.
Contrary to the above, procedures do not exist to implement the require-ments of Section 7.4 of ANSI N45.2.2-1972'he accepted Quality Assurance
- Program, Appendix C, commits to Regulatory Guide 1.33 which endorses ANSI N]8.7-1972.
ANSI N18.7 Section 5.3.6 requires procedures to be provided for periodic testing and calibration of safety-related plant, instrumentation.
7908].so {gs
. Florida Power and Light Company Turkey Point Units 3 and 4 2w Appendix A Notice of Violation Contrary to the above, procedures do not exist to implement the calibration of all gauges and instruments utilized in activities affecting quality.
Examples of gauges and instruments for which procedures do not exist are battery hydrometers, thermometers, Fuel Oil Day Tank and Lube Oil Pressure.
5.
Quality Procedure (QP) 18.1, Revision 2 dated December 15,
- 1975, Paragraph 5.3 requires that audit reports include names of persons contacted during pre-audit activities and a statement evaluating the effectiveness of the quality assurance program in audited areas.
Contrary to the above, none of the audits reviewed by the inspector for the period January 1, 1978, through Narch 1, 1979, for both Corporate Office and Turkey Point Site QA audits contained the required statement of evaluation and none of the Turkey Point site QA audits reviewed contained a list of pre-audit attendees.
6.
Quality Procedure (QP) 17.1, Revision 2 dated November 15,
- 1978, Paragraph 5.3.2 requires that QA records be stored in either records storage vaults which are either specially constructed storage rooms or fire resistant file cabinets with at least a
one hour Underwriter's rating.
Some strip charts were identified as Quality Assurance Records.
Contrary to the above, none of the Turkey Point Plant quality assurance records in the form of strip charts which are greater than one year old are stored as required.
7.
Quality Procedure (QP) 17.1, Paragraph 5.3.1.1 requires written storage instruction including the designation of a custodian, a description of the storage
- area, type of filing system, rules governing access and control of the files, record removal and a method for filing supplemental material.
Contrary to the above, Quality Assurance records were being stored in the Electrical Shop and Quality Control offices without the required procedures.
Examples of these records are completed Plant 'Pork Orders and Personnel Qualification Records.
This is an Infraction.
As required by 10 CFR 50,Appendix B, Criterion X "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instruction, procedure and drawings for accomplishing the activity".
The accepted Quality Assurance Program TQR 10.0 states in part "A program for inspection shall be established and executed by or for FPSL to verify conformance with the documented instructions, 'procedures, and drawings for accomplishing the activity.
Contrary to the above, a program for inspection had not been established in the following areas:
Florida Power and I.ight Company Turkey Point Units 3 and 4
w3 Appendix A Notice of Violation 1.
Plant Work Orders (PWO) accomplished without a
procedure were not inspected or reviewed by the Quality Control Department.
2.
ANSI N45.2.2-1972 requires inspection and examinations on a periodic basis to assure the integrity of items in storage.
None of the items in storage received a periodic inspection or examination.
3.
QP 10.3 requires QC inspections of housekeeping.
No QC inspection has been performed in this area.
This is an Infraction.
C.
As 'required by Section 4.4.5 of the Technical Specifications the Residual Heat Removal System is to be tested annually and that the leak rate shall be less than 2 gallons per hour.
Contrary to the
- above, the required testing was accomplished under OP 3206.2 on 11/24/77 and the leak rate was greater than 2 gallons per hour.
The leaks were identified to be at the Unit 3B RHR Pump seal (3 gph) and at the RHR B heat exchanger (1 gph).
The repairs to the 3B RHR pump were completed on 12 February 1978.
However, no test vas performed to demonstrate operability following repairs.
This is an Infraction and is applicable to Unit 3 only.
D.
As required by Section 4:4.5 of the Technical Specifications, the Residual Heat Removal System por'tion that is down stream of the first isolation valve outside of containment shall be tested either by use in normal operation or hydrostatically tested at 350 psig and shall be conducted on a twelve month interval.
Contrary to the above, the required testing of Unit 3 Residual Heat Removal System was not performed for the period 11/24/77 to 2/24/79.
This is an Infraction and is applicable to Unit 3 only.
E.
As required by 10 CFR 50.59(2)(b),
"The licensee shall maintain records of changes in the facility.
These records shall include a written safety evaluation vhich provides the bases for the determination that the change does not involve an unreviewed safety question
'Contrary to the above, six of the eighteen Plant Change/Modification (PCM's) packages reviewed did not contain a safety evaluation which provided the bases for the determination that an unreviewed safety question was or was not involved.
These PCM's are; 79-05 (Manipulat.ion Crane Limit Swit,ch and Relay Installation),
78-52 (Removal of Part Lengt.h Rods),
78-23 (Install OMS Test Swit.ch),
78-16 (Redundant Air or N Supply to POU's),
78-61 (ECFS Plenum Air Flov Indicator), and 78-20 (Sampling System Modification).
This is an Infraction.
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'lorida Power and Light Company Turkey Point Units 3 and 4 Appendix A
,. Notice of Violation F.
As required by 10 CFR 50, Appendix B, Criterion III:
"The design control
. measures shall provide for verifying or checking the adequacy of design as required by FPSL's accepted Quality Assurance Program (TQR 3.1),
measures shall be applied to verify the adequacy of desiga.
ANSI N45.2.11-1974, as committed to by that Program states in part, "Design verification is the process of reviewing, confirming, or substantiating the design by one or more methods to provide assurance that the design meets the specific design inputs Contrary to the above, five of the eighteen Plant Change/Hodification (PCH) packages reviewed contained design reviews which did not verify the adequacy of the design in that no assurance was presented to assure that the design met the specific design inputs.
These PHC's were 79-05 (Hanipulator Crane Limit Switch and Relay Installation),
78-23 (Install OMS Test Switch),
78-13 (Replace Existing Heat Tracing Circuits), 78-61 (ECFS Plenum Air Flow Indicator), 78-20 (Sampling System Hodification).
This is an Infraction.
G.
As required by Section 6.8.2 of the Technical Specification, "Each procedure and administrative policy of 6.8.1
., and changes thereto, shall be reviewed by the PNSC.
Contrary to the above, the implementation procedure for PC/H 78-51, Unit 3 and 78-52, Unit 4, "Installation of Part Length CRDS Anti-rotation Device was modified during installation and was not authorized by the Plant Nuclear Safety Committee (PNSC).
Step 9.6.5 was modified by a letter dated 9/11/78 from Nuclear Service Division (FS-J4-095) to revise the method of torquing the set screws the required 12-15 ft-LBS; PNSC did aot approve the change to the procedure.
This is an Infraction.
As required by 10 CFR 50, Appendix B, Criterion XVII, "Sufficient records shall be maintained to furnish evidence of activities affecting quality.
Additionally, the applicant shall establish requiremcnt,s concerning record retention, such as duration, location and assigned responsibility.
The accepted Quality Assurance Program TQR 17.1 states in part:
"Sufficient records shall be maintained to furnish documented evidence of the quality of safety related structures,
- systems, and components, and of activities affecting their-quality." and ".
The requiremcnt,s and responsibilities for quality assurance record control shall be established aad documented Contrary to thc above, sufficient records vere not maintained as indicated'elow:
IVY 1.
Nine of nine Plant Pork Orders and Vork Reports'nvolving maintenance on safety-rclat.cd equipmcnt. that vere on file in Document Control did not have thc QC inspector signature recorded and six of t.he same nine work reports did not have thc Supervisor's signature recorded.
Florida Power and Light Company Turkey Point Units 3 and 4
w5 w Appendix A Notice of Violation 2.
Document control/retention requirements had not been established for maintaining vendor instruction manuals used in the performance of safety-related maintenance.
3.
The data reports required by PO 876019-65231 could not be retreived.
4.
The heat treat verification required by PO 9 73523-230721C could not be retrieved.
This is an Infraction.
As required by )0 CFR 50, Appendix B, Criterion XIII which states in part:
"Measures shall be established to control the handling, storage,
- shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deteriotion".
The accepted Quality Assurance
- Program, Appendix C and D to FP&L TQAR 1-76A commits to Regulatory Guide 1.38, dated March 16, 1973, which endorses ANSI N45.2.2-1972 as the baseline guidance for FPSL's QA Manual and the QA Program commitments.
Paragraph 2.2 of ANSI N45.2.2-72 states in part:
"Procedures and instructions shall be generated,
- used, and maintained current; these shall contain
~ sufficient detail to provide a basis for packaging, design, shipping require-ments, receiving, storage and handling procedures, implementations
- thereof, and inspection
." FPGI, QA Procedure QP 13.1, "Handling, Storage and Shipping of Material, Parts and Equipment During Plant Operation" specifies the measures and responsibilities for controlling the subject areas.
Turkey Point Administrative Procedure AP 0190.72, Paragraph 5.7 requires that storage facilities to be utilized by plant departments for storage of safety-related materials, not purchased through stores, be designated in writing.
Contrary to the
- above, the electric department had not implemented, on March 21, 1979, paragraph 5.7 of AP 0190.72.
This item is an Infraction.
A similar item was previously identified to you in our letter of November 17, 1977.
J.
-As required by 10 CFR 50, Appendix B, Criterion XVI, "Measures shall be established to assure that conditions adverse to quality, such as nonconformances are promptly identified and corrected The accept 11 ed Quality Assurance
- Program, Paragraph 16 ) y requires"...
measures shall be used to assure that conditions adverse to quality such as deficiencies, and nonconformances, are promptly identified and corrected as soon as practicable."
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Contrary to the
- above, measures had not been established to assure that conditions adverse to quality were corrected as soon as practicable in that:
Florida Power and Light Company Turkey Point Units 3 and 4 Appendix A Notice of Violation 1.
The lack of as-built Circuit Wiring Diagrams for'ertain safety-related equipment relay circuitry was identified as a nonconformance in Item II of audit QAA-SP-74-2 conducted December 3 and 5,
- 1974, and all of the required diagrams had not been updated to as-build conditions as of March 14, 1979.
2.
The lack of documentation of the current drawing control practices in procedure QP 6.4 was identified as a nonconformance in Item II.C of audit QAA-HA-76.2 which was issued June 28,
- 1976, and the procedure still had not been updated as of March 14, 1979.
3.
The lack of documentation with respect to design interfaces was identi-fied in Item I of audit QAA-EPP-77-1 issued April 28,
- 1977, and the required revision of QP 3.2 had not been accomplished as of March 14,
)979.
4.
Various inadequacies with receipt, control and inspection of safety-related material arriving at the Turkey Point site through channels other than routine Stores Department orders were identified in Items I, II and III of site Quality Assurance audit QAO-PT78-05")71.
A response was due on June 29,
- 1978, and none was received until October 16, 1978.
In addition corrective action was not obtained until January 22, 1979.
'This is an Infraction.
X.
As required by 10 CFR 50, Appendix B, Criterion XVIII, "
. Followup
," action shall be taken where indicated."
The accepted Quality Assurance
- Program, Paragraph 18.1 requires that "Followup action shall be taken where necessary."
Quality Procedure (QP) 16.1, Revision 1
dated March 3),
)978, Paragraph 5.4.1.3 states" "If a response is not received, is inadequate, or subsequent corrective action is not satisfactory, the cognizant Assistant Manager of QA shall contact the department or plant management, in writing, and inform him of the inadequacies, and request a
commitment or other appropriate action."
.Contrary to the above, followup action was not taken where indicated in that:
2.
Finding I of audit QAA-LEP-78-) received an inadequate response on August 25, 1978, that provided no, immediate corrective action for the cited nonconformance (fai)ure to have an approved procedure) and the condition of inadequacy was not brought to the attention of the cognizant Assistant Hanager of QA, no followup action was taken, and the condition remained uncorrected as of March 14, 1979.
Findings I and II of audit QAA-ÃAN-78-2 dealing with design verifi-cation and collection and storage of QA records had a
response due date of December 17, 1978.
When no response was received, the cognizant Assistant Hanager of QA was not informed by the auditor.
The auditor, not the Assistant Manager took followup action and that was orally and not in writing.
Florida Power and Light Company Turkey Point Units 3 and 4
w7 w Appendix A Notice of Violation 3.
Finding I of audit QAO-PTP-78-04-170 dealing with failure to follow procedures had a response due date of June 17, 1978.
No response was received until October 12, 1978.
Although followup action was initiated by the auditor on July 21, August ll, August 22 and September 26,
- 1978, the act;ion was not taken by the cognizant Assist.ant
- Manager, nor was it in writing as required and it was not effective in obtaining the corrective action which was not complet.ed until November 22, 1978.
This is an Infraction.
As required by 10 CFR 50, Appendix B, Criterion XVIII, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
The accepted Quality Assurance Program, Paragraph 18.1 requires "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program Appendix C of the accepted Program commits Florida Power and Light to follow Regulatory Guide 1.64, Revision 1 which endorses and applies ANSI N45.2.11-1974.
Contrary to the above, a comprehensive system of audits was not carried out as required in that the six audits conducted which dealt with the Plant Change/Modification (PCM) area did not verify compliance of that activity with the accepted Program's commitment to ANSI N45.2.11-1974 in that the specific audit requirements of Section 11.4 of the Standard to evaluate the design quality assurance practices,
- policies, procedures and instructions and actions taken to correct deficiencies in the program were not covered.
'his is an Infraction.
As required by 10 CFR 50, Appendix B, Criterion VI, "Measures shall be established to control the issuance of documents including changes
- thereto, which prescribe all activities affecting quality The accepted Quality Assurance
- Program, Paragraph 6.2.1 states that "Quality Procedures shall delineate the control measures for controlled documents
. including direction for verification that changes are promptly
.incorporated.
These control measures shall apply to c.
quality program manuals, procedures...
f.
plant Safety Analysis Reports
." "Quality Procedure (QP) 6.2, Revision 2 dat,ed November 15, 1977, Paragraph
~ 5.2.2 states that "A reference center document may be checked out of the reference center by completing an entry in the reference check-out book II Contrary to the above, currently cst,ablishcd measures did not control the issuance of document.s as rcquircd in that:
1.
Two of five Quality Manuals (copics 143 and 044) reviewed at the General Offices on March 13,
- 1979, contained copies of Quality Proce-dures (QP) 16.2 and 16.3 bot,h of which had been superseded and made obsolct.e on March 31, 1978;
Florida Power and Light Company Turkey Point Units 3 and 4 Appendix A Notice of Violation 2.
Audit reports issued by the site Quality Assurance organization showed that QP 16.3 was still referenced as the document to be followed in audit reports up to and including one issued on June 27, 1978, three months after QP 16.3 had been superceded; 3.
The reference center copy of the Turkey Point Final Safety Analysis Report had been returned to the reference center by one engineer without filling in the reference center check-out book and had been taken out of the reference center by another engineer o
M h 20 19 79, without filling in a
checkout entry in the reference center checkout book.
This is a Deficiency.
H.
As required by 10 CFR 50, Appendix B, Criterion XIV "Measures shall be established to indicate, by the use of markings such as st t
t a
e s, routing cards, or other suitable
- means, the status of inspections and tests performed upon individual items of the nuclear power plant" The accepted Quality Assurance Program TQR 12.2.1 requires labeling.
The committed standard ANSI N45.2.4-1972 requires labeling of instrumentation to show the date of the next calibration.
.Contrary to the
- above, safety related instrumentation mounted on anels were not labeled.
on pane s
This is a Deficiency.
0.
As required by 10 CFR 50, Appendix B, Criterion IV, "Measures shall be established to assure that applicable regulatory requirements, design
- bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material equipment and services
." The accepted Quality Assurance Program as implemented by TQR 4, Paragraph 4.2.1 and TQR 15 Paragraph require measures to be established which require reporting of noncon-aragrap formances, during supplier activities to the purchases.
Contrary to the above, all sixteen purchase orders reviewed did not contain piovisions which required reporting of supplier nonconformances to the purchaser.
This is a Deficiency.