ML20132C157
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{{#Wiki_filter:/ [0' +N8" h p erc 8 UNITED STATES 8 ( !hi NUCLEAR REGULATORY COMMISSION h WASHINGTON, D. C. 20555 kd / MAY 111991 +...+ MEMORANDUM FOR: Darrell G. Eisenh'ut, Director Division of Licensing THRU: Robert A. Clark, Chief Operating Reactors Branc #3, DL Thomas A. Novak, Assi_ ctor for Operating Reactors L FROM: Christian C. Nelson, Project Manager Operating Reactors Branch #3, DL
SUBJECT:
SALP INPUT FOR ST. LUCIE, UNIT NO. 1 1. Quality of responses relative to amendments, generic letters, and requests for aaaitional information. FPL responses, characteristically, have sound technical bases. FPL responses reflect a sufficient review of the request, in that all topics in a request are addressed in the response. 2. Efforts in obtaining acceptable responses. FPL is generally responsive to written and oral requests for information with respect to timing of submittals. FPL alerts NRR if it has a problem with a response date. Resolution of most items requires communication, written and/or oral, beyond the initial NRR request and FPL response. FPL responses sometimes lack sufficient detail to fully support FPL's position. In this regard, FPL is an ave g performer. 3. Technical competence, managerial and operational capabilities, cuality assarance and operational control pei+ormance. FPL personnel are technically competent. Operator qualification is average to good. Plant operation during the current cycle has b,een very good with a high capacity factor. In June 1980, plant operators safely operated the plant during a natural circulation cooldown compli-cated by a steam bubble in the reactor vessel head. 4. Working knowledge of regulations, guides, standards and generic problems. FPL personnel exhibit a good working knowledge in these areas. Communi-cations with both corporate and site personnel have indicated their awareness of current issues and the related documents. Fot A M s %lo5 Moh h
t Darrell G. Eisenhut 5. Observed trends in performance, if any. No trends observed. 6. Notable strength and weaknesses. A potential barrier to a constructive licensing relationship between NRR and FPL is the poor attitude,both expressed and observed,of some FPL personnel towards the NRC. Christian C. Nelson, Projec ianager Operating Reactors Branch #3 Division of Licensing 4 e i i e
St Lucin / \\ NRR PROJECT MANAGER COMMENTS Discussions with C. Nelson, Project Manager for St. Lucie 1, indicates the following: Overall, my licensing relationship with FP&L is average. FP&L is fairly responsive to written requests for information as far as timing of submittal is concerned and alerts me to problems with date of response. The licensee, however, in following/ proposing a position which differs to some degree from the NRC's, provides minimal detailed support for his potision. IIn most cases this position has a sound technical basis which must be extracted by further discussion. The licensing contact for St. Luciel, Dave Evans, is very cooperative and responsive. He initiates meaningful discussions prior to documenting issues in letters or other licensing correspondence. I have not been to the plant as its project manager although I visited St. Lucie 1 last March as leader of the Category A lessons learned review team. Coopera-tion and attitude of plant personnel during that visit, overall, was below average. , -. + _. _
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- .' h lip,R PERFOR!GliCE EVALUATIO!i 1
l ff . ~, ~,, Facility: St. Lucie. Unit',1 Project Manager: C. l:els W Appraisal Period: July 1,1980 to June 30,198}%Y-dL* Ucv m qc Robert A. Clark, Chie'f, ORS #3 1. Performance Elements a. Quality of responses and submittals Florida Power and Light (FPL) responses and submittals, characteristically,.have sound technical bases. FPL responses reflect a sufficient review of the requests, in that all topics in a request are addressed in the response. Resolution of some f;RC initiated items requires written comunication beyond the initial !!RC request and FPL response. In these matters, FPL initial responses do not provide sufficient detail to support FPL's position. On the other hand several license amendments, proposed by FPL, have been issued durin.g this period which required either no or, at most, oral com-munication to supplement the original submittal. b. Efforts required to obtain an acceptable response or submittal including: (1) Timeliness (2) Effort (3) Responsiveness to staff requests (/-) Anticipates or reacts to l RC needs.. FPL is generally responsive to written and oral requests for inforr.ation with respect to timing of submittals. FPL alerts I;P.R if it.has a problem rseting a response date (eq. Station-Blackout). !!ormally FPL does not respond until the requested response date but, considering the numerous I;RC requests, FPL is probably average in.this regard. FPL is cooperative in furnishing information requested by telephone. This includes voluntarily providing information requested to aid the I4RC in its review of unresolved safety issues such as piping and layout drawings for USI-A-43, (Containment Sump Blockage) and diesel data for USI-A 44 (Station Blackout). c. Working knowledge of regulations, guides, standards and generic issues. FPL personnel exhibit a good working knowledge in these areas. Communications with both corporate and site personnel have indicated their awareness of current issues and the related t documents. l l O
I e, d. 'iec'hnical competence. FPL personnel are technically competent. Plant operation during this evaluation period has been very good with high reliability. FPL licensing personnel maintain a current understanding of industry technical issues particularly for plants of similar CE design. e. Conduct of meetings with !!RR. FPL seems to have a good understanding of the advantages and limits of meetings. FPL requests meetings when, in their opinion, face-to-face communication is necessary for resolution of an issue (eq. environmental qualification of safety related electrical equipment). Periodic. meetings between FPL's licensing contact and the i;RR project manager, most often with FPL coming to Bethesda, aid the understanding of what. each others organizations are doing on St. Lucie Unit 1 issues. f. Long-standing open items. fio items in this category that are awaiting FPL action. g. Organization and management capabilities. Good - licensing personnel get adequate management support to resolve outstanding issues. Results of operator licensing exaninations ccnducted during the appraisal period. Excellent - During the appraisal period 6 of 6 reactor operator applicants and 4 of 4 senior reactor operator applicants were
- licensed, i.
Performance on specific issues. FPL has been responsive regarding post-TMI related items including the proposal of technical specification changes regarding " Category A" Lessons Learned which required only minor modifications. FPL has been very cooperative in facilitating f;RC's review of FPL's stretch power request. FPL has acted on advanced draft lists of questions to allow the.fiRC staff maximum review time. u_
ss. e <g,. 3-2. Observed trends in performance. flo significant trends observed. Minor delays (days) in responding to fGC requests may be becoming more frequent. a 3. flotable Strengths and Weaknesses FPL licensing contact is cooperative and easy to work with. 4. Overall Summary Overall rating: average and consistent. e e 4 S' 4
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UNITED STATES $E y3.,gI'l NUCLEAR REGULATORY COMMISSION 2
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REGION 11 o i'i 101 MARIETTA ST., N.W., SulTE 3100 Y'*Q j' ATLANTA, GEORGI A 30303 e ,;( . Uti 0 1 1931 3 ' s 3g h Florida Power and Light Company . r:, Advanced Systems and Technology ]-I h. W.C')b .J ATTN: Mr. R. E. Uhrig, Vice President a ~ sc 5 S / q. - P. O. Box 529100 p; ! Q';,, A it 's;A F,3 9*p' Miami, FL 33152 ~ /d' Gentlemen: 'Jc,. d' ,.6.c "'!./i.!?..i[.I'
Subject:
Report No. 50-389/91-04 Thank you for your letter of May 11, 1981, informing us of steps you have taken to correct the violations concerning activities under NRC Construction Permit CPPR-144 brought to your attention in our letter of March 25, 1981. We will examine your corrective actions and plans during subsequent inspections. We appreciate your cooperation with us. Sincerely,
- f. C. L-
.C. i s, acting Director Division of Resident and Reactor Project Inspection ec: C. M. Wethy, Plant Manager N. Weems, Assistant QA Construction Manager fh 'I/'& ( g L,. 4& \\ .J ) ')0 P.9 FeIA-2 + -zis l,l l63 c,w. w c, 1 - g i
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101 MARIETTA ST.. N.W.. SulTE 3100 Q ATLANTA, G EoRGI A 30303 +.... JUN0 3 198; Florida Power and Light Company ATTN: R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami. FL 33152 Gentlemen:
Subject:
Report Nos. 50-335/81-10 and 50-389/81-06 This refers to the special safety inspection condccted by Mr. J. J. Lenahan of this office on May 4-7, 1981, of activities authorized by NRC Operating License No. DPR-67 and Construction Permit No. CPPR-144 for the St. Lucie facility. Our preliminary findings were discussed with Mr. B. J. Escue, Plant Manager, at the conclusion of the inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. During the inspection, it was found that certain activities under your license appear to violate NRC requirements. This item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A. Elements to be included in your response are delineated in Appendix A. We have examined actions you have taken with regard to previously identified enforcement matters and unresolved items. The status of these items is discussed in the enclosed report. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of t s letter and the enclosed report will be placed in the NRC's Public Document com. If the report contains any information that you believe to be exempt from disclo-sure under 10 CFR 9.5(a)(4), it is necessary that you: (a) notify this office by telephone within ten days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five days from the date of this letter a written application to this office to withhold such infor-mation. If your receipt of this letter has been delayed such that less than seven days are available for your review, please notify this office promptly so that a new due date may be established. Consistent with section 2.790(b)(1), such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be with-held, and a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address witn specificity tne considerations FotA-74 -213 sto;rm e10713 gDRADOCK05000 g
- g JUN 0 3 581 Florida Power and Light Company 2
listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, - the report will be placed in the Public Document Room. Should you have any questions concerning this letter, we will be glad to discuss them with you. Sincerely, $~[. R. C. ewis, Acting Director Division of Resident and Reactor Project Inspection En' closures: 1. Appendix A, Notice of Violation 2. Inspection Report Nos. 50-335/81-10 and 50-389/81-06 cc w/ encl: C. M. Wethy, Plant Manager N. Weems, Assistant QA Construction Manager B. J. Escue, Plant Manager r c_-, -~,
-2 APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company Docket No. 50-389 St. Lucie 2 License No. CPPR-144 As a result of the inspection conducted on May 4-7, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified. 10 CFR 50, Appendix B, Criterion V, as implemented by FP&L Topical Quality Assurance Report Number 5.0, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings, and shall be accomplished in accordance with these instructions, procedures or drawings. Contrary to the above, there were no documented instructions or procedures for control and disposition of site generated nonconformance reports within the Ebasco Site Support Engineering group (ESSE). This is a Severity Level VI Violation (Supplement II.F). Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within twenty-five days of the date of this Notice, a written state-ment or explanation in reply, including: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of Section 182 cf the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. NY 0 31981 Date: h 810713 PDR ADOCK 05000389 0 PDR
d'pu scm D o UNITED STATES [ y, y' NUCLEAR REGULATORY COMMISSION r.z # REGION 11 e o 101 MARIETTA ST., N.W., SUITE 3100 Y TD' o ATLANTA, GEORGIA 30303 q Report Nos. 50-335/81-10 and 50-389/81-06 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: St. Lucie Docket Nos. 50-335 and 50-389 License' Nos. OPR-67 and CPPR-144 Inspection at St. Lucie site near Ft. Pierce, FL Inspector: Mbd Fa7 ////h / J.y.Lenahan 0'ats Signed Approved by:
- 7f'h 4- -/- Tl T. E. Conlon~, Section Chief Date Signed Engineering Inspection Branch Engineering and Technical Inspection Division
SUMMARY
Inspection on May 4-7, 1981 Areas Inspected This special, announced inspection involved 26 inspector-hours onsite in the areas of licensee action on previous inspection findings, structural concrete, levels B, C, and D storage, licensee identified items and followup on IE Bulletin 80-11. Results Of the five areas inspected, no violations or deviations were identified in four areas; one violation was found in one area (Insufficient procedures for dispo-sition of NCRs within ESSE paragraph 3). -&iff240296 810713 PDR ADOCK 05000389 G PDR
.s '~ ~ REPORT DETAILS 1. Persons Contacted j Licensee Employees I
- B. J. Escue, Project Manager, Unit 2 W. Hayward, QA Construction Supervisor
- E. W. Sherman, QA Engineer C. M. Wethy, Plant Manager, Unit 1 C. Hamilton, Unit 1 QC Supervisor J. Krumins, Site Engineer, Unit 1 Other licensee employees contacted included 6 civil QC inspectors.
Other Organizations (EBASCO)
- G. H. Krauss, ESSE Project Engineer, Unit 2
- V. J. Gerley, Civil Engineer, Unit 2
- R. A. Garramore, Senior Resident Engineer, Unit 2 T. Tarte, Project Engineer, Unit 1 D. Cacoilo, Civil Engineer, Unit 1 NRC Resident Inspector
- S. A. Elrod, Senior Resident Inspector
- P. Bibb, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized by the inspector on May 7, 1981 with those Unit 2 personnel indicated in paragraph 1 above. The violation described in paragraph 3 was discussed. The Unit 1 inspection scope and findings were discussed by the NRC senior resident inspector with the Unit 1 plant manager on May 8,1981. 3. Licensee Action on Previous Inspection Findings l a. (Closed) Infraction Item (335/77-10-01): Failure to Update As-Built l Detail Drawings with Latest Computer Design Loads; Infraction Item (335/77-10-02): Failure to Install Pipe Support Anchor Bolts in Accordance with Requirements of Design Drawings; and Infraction Item (335/77-10-03): Failure of Pipe Support Inspection Program to Identify Inadequate Bolting.
2 These infractions were identified during an investigation of the Unit 1 anchor bolt and pipe support / restraint installation program. The problems identified during this investigation concerning anchor bolt installation contributed to issuance of IE Bulletin ' 79-02. The licensee's corrective actions, which are stated in FP&L's letters to NRC Region II dated September 7,1977, October 7,1977, November 30, 1977, and December 8,1977, were reviewed and accepted by Region II inspectors during onsite inspections of activities associated with IE Bulletin 79-02. These items are closed. b. (Closed) Unresolved Item (335/79-18-01): Documentation for Barrier Dam Compaction Piles. This unresolved item was applicable to Units 1 and 2. The Unit 2 unresolved item (item number 389/79-10-01) was closed out during an inspection conducted on Septcmber 5-6, 1979 (See RII IE Report No. 50-389/79-15). Based on the documentation reviewed during the September 5-6, 1979 inspection, Unit 1 Unresolved Item 335/79-18-01 is closed. c. (Closed) Unresolved Item (335/81-04-01): ESSE NCR Control Procedures. The inspector discussed procedures for control and disposition of NCR's (nonconformances) within the EBASCO Site Support Engineering group (ESSE) with licensee and EBASCO engineers. These discussions disclosed that there is not a documented procedure within the ESSE group which meets the requirements of Criterion V of 10 CFR 50, Appendix B for control and disposition of site generated nonconformances by ESSE. This item is closed as an unresolved item and upgraded to violation item 389/81-06-01, " Insufficient Procedure for Disposition of NCRs within ESSE". d. (Closed) Unresolved Item (389/81-04-03): Soil Testing Methods. The inspector examined Revision 1 to FCR 2-058. This revision voided the original FCR which deleted the requirement of Note 2 to ASTM D1557. Note 2 to ASTM D 1557 calls for replacing the plus 3/4 inch material with #4 to 3/4 inch material in performance of modified proctor tests. The inspector discussed the reason for voiding FCR 2-058 with the EBASCO civil engineer. These discussions disclosed that Note 2 is an optional testing requirement, and since it was not specified in EBASCO specification number FLO-2998.471, " Excavation and Backfill", there was no need to write an FCR (number 2-058) to delete the requirements of Note 2. Thus FCR 2-058 was voided. Further discussions with the EBASCO civil engineer disclosed that the testing methods specified in Note 2 to ASTM D 1557 were not made a requirement in order to obtain good correlation between the proctor curve, in place field density tests, and relative density tests. The inspector reviewed EBASCO memo dated April 30, 1981, subject "FP&L St. Lucie Plant - Unit No. 2, Relative Density Determinations". This memo describes in detail the method useo in performance of relative density tests. It also stated that at the beginning of the laboratory testing program for Unit 1, the relative density tests were performed by the wet and dry methods, and
3 that the dry method yielded the highest density requirements. Since the Class I backfill requirements for Unit 2 are the same as for Unit 1, there was no need to perform the relative density test by both the wet and dry methods. The inspector reviewed relative density tests performed by both the wet and dry method as Unit 1 Class 1 backfill. These results showed that determination of relative density tests by the dry method yielded the highest maximum density. test results. The inspector has no further questions on this item at this time. This item is closed. e. (Closed) Unresolved Item 389/81-05-04: Spacing of Reinforcing Steel. The inspector discussed with the licensee and EBASCO engineers, the reasons for groups of three to five reinforcing bars with clear distance between bars of less than one inch in the containment building shield wall at the maintenance hatch opening and penetration 43. These discussions disclosed that additional bars were placed in areas where restrictions or congestion did not permit placement of reinfor-cing steel with the minimum splice lengths required by Section 7 of ACI 318-71. This resulted in a few groups of three to five rebars in the containment building shield wall penetration areas. EBASCO engineering approval of the placement of additional bars at locations where the minimum splice length could not be obtained is shown in Field Change Request number 2-154. The placement of these additional bars is not in conflict with the requirements of paragraphs 7.4.1 and 7.4.5 of ACI 318-71. This item is closed. 4. Unresolved Items Unresolved items were not identified during this inspection. 5. Independent Inspection Effort The inspector examined the following areas: a. Construction status of Unit 2 l b. Unit 2 B, C, and D storage areas c. Concrete and soils laboratory and currentness of calibration of laboratory equipment. [ No deviations or violations were identified. 6. Containment (Structural Concrete II) - Observation of Work and Work Activities, Unit 2 The inspector observed partial placement, inspection and curing of pour number 38 for the Unit 2 reactor building dome. Acceptance criteria examined by tne inspector were as follows: a. PSAR Sections 3.8.1 and 3.8.3 i
4 b. EBASCO specification FLO-2998.473, " Concrete" c. FP&L site quality procedure SQP-2, " Concrete and Grout Placement" d. FP&L Construction Quality Control Instructions QI 10.3, QI 10.4, QI 10.70 and QI 10.71. e. EBASCO drawing nutbers 2998-G-511, 512, and 513. Forms were tight and clean, rebar was properly installed and clean. Placement activities pertaining to delivery time, free fall, flow distance and consolidation conformed to specification requirements. Concrete placement activities were monitored by QC inspectors. Samples of plastic concrete were tested in accordance with specification requirements. The test results indicated that the concrete being placed met the specification requirements for slump, air content, and temperatures. Following completion of the pour on May 4, the inspector examined post placement inspection activities (curing) on May 5 and 6,1981. The curing was being accomplished in accordance with specification requirements. No deviations or violations were identified. 7. Licensee Identified Items (LER) (0 pen) LER (335-81-03) Masonry Walls Performance of the masonry wall design re-evaluation required by IE Bulletin 80-11 disclosed that 3 walls had local stresses above the code allowable values upon application of seismic loads. In addition, it was also deter-mined during the design re-evaluation that the support angles at the tops of the walls which attach the walls to the building structure had to be modified on approximately 20 walls to accommodate the calculated seismic reactions. The licensee's actions to correct this problem are discussed in paragraph 8 of this inspection report. The inspector examined the licensee's justification for continued operation of the plant in view of the problems identified with the walls. The justification for continued plant operation is documented in the minutes of the Facility Review Group Meeting of January 23, 1981, and in FP&L letter number PRN-81-64 dated February 6,1980 to NRC Region II. The justification is based on the probability that, in the event of a LOCA or seismic event, the failure mode of the wall is most likely to be cracking of various degrees rather than total collapse. Also for the three walls which had local stresses above the code allowable upon application of seismic loads, the safety related equipment in proximity of the walls, either penetrates the walls at or near the top, or run vertically adjacent to the wall. This equipment was not supported by the walls. Therefore, total collapse of the walls in question would not result in failure of the equipment. No deviations or violations were identified.
5 ~ 8. (0 pen) IE Bulletin 80-11, Masonry Wall Design, Unit 1 a. Summary of Licensee's Response to IE Bulletin 80-11 Florida Power and Light Company (FP&L) submitted its 60 day IE Bulletin 80-11 response to NRC Region II for St. Lucie Unit 1 on July 24, 1980. This response discussed the number of masonry walls in the plant and briefly summarized the prioritized program of field inspections to identify which walls were in the proximity of safety related equipment. The response stated that identification of safety-related equipment in the proximity of masonry walls would be completed by October 1, 1930. In a letter to NRC Region II dated October 1,1980, the licensee stated that the detailed identification of safety-related equipment in the proximity of masonry walls would not be completed until October 20, 1980. Region II was notified of a delay in completion of the design re-evaluation of the masonry walls in a letter from FP&L dated November 4, 1980. The letter stated that the field inspection of the masonry walls had been completed and the walls in proximity of safety related equipment had been identified. This letter stated that the design re-evaluation of the masonry walls in proximity of safety related equipment was scheduled to be completed by February 9,1981. FP&L submitted its 180 day IE Bulletin 80-11 response to NRC Region II for St. Lucie Unit 1 on February 11, 1981. The 180 day response summarized the approach used to identify masonry walls in the proximity of safety-related equipment and the methods used in design re-evaluation of the masonry walls, described the function and configu-ration of the walls, discussed the construction practices and materials used in erecting the walls, and presented the results of the design re-evaluation. As a result of the design re-evaluation, it was determined that several walls had to be modified in order to meet design criteria. As discussed in paragraph 7 of this report, this was reported to NRC Region II as Licensee Event Report (LER) Number 335-81-03 on January 23, 1981. b. Review of Procedures for Accomplishment of IE Bulletin 80-11 Require-ments The inspector examined the following procedures which address the requirements for accomplishment of IEB 80-11 field inspection activi-ties: (1) Procedure number FLO 128-4.800, " Procedure for Inspection of Concrete Masonry Walls"
6 (2) Procedure number FLO 128-4.801, " Quality Assurance Procedure for Compliance with NRC IE Bulletin 80-11" (3) Procedure number FLO 128-4.802, " Procedure for Verification of Concrete Masonry Wall Design" These procedures address the field surveillance requirements to identify masonry walls in the proximity of safety-related equipment, preparation of masonry wall as-built drawings, documentation of the field inspection effort, QA review of the field inspection results and documentation, and the method to be used to verify the design adequacy of existing concrete masonry walls. c. Field Walkdown in Safety Related Areas to Identify Masonry Walls The inspector, accompanied by licensee and EBASCO engineers, walked down the Reactor Auxiliary Building on floor elevations -0.5,19.5, 43.0, and 62.0 to verify that all masonry walls in the proximity of safety related equipment had been identified for design re-analysis in accordance with IEB 80-11 requirements and the licensee's responses. No additional masonry walls were identified by the inspector during this inspection. The inspector also toured the diesel generator building to confirm that there were no masonry walls in this structure. The field surveys performed by EBASCO engineers appears to have been adequate to identi fy all masonry walls in the proximity cf safety related equipment. d. Review of Quality Records Related to IE Bulletin 80-11 The inspector examined the following quality records relating to IEB 80-11: (1) General Arrangement Drawings, Reactor Auxiliary Building, drawing numbers 8770-G-069, 070, 071, and 072 (2) Documentation of training received by personnel performing the masonry wall inspections (3) Memos documenting results of QA audits of IES 80-11 activities. These audits were made by EBASCO engineers (4) Masonry wall inspection data sheets and as-built drawings showing locations of equipment attached to the walls which results in significant loads acting on the walls. Records examined were wall numbers 34, 35, 62, 72, 74, 76, 80, 114, 123, 124, 159, 162, 164, 166, 167, 174, 201, 202, and 203. These records were reviewed by the inspector during the field walkdown discussed in paragrapn 8.c to verify the accuracy of the inspection data sheets and as-built drawings.
~ 7 (5) Computations of loads acting on walls from attached equipment. These loads are indicated on the as-built drawings. The inspector made independent checks of these computations and verified that the load computations had been checked. e. Review of Masonry Wall Repair Program The inspector examined procedures, design drawings, quality records and the completed work associated with masonry walls which were modified to meet design requirements. A summary of the repair program and the details of the inspection of the repair program are stated in the s following paragraphs: (1) Summary of Masonry Wall Repair Program During the early stages of the Bulletin 80-11 masonry wall evaluation program, the masonry walls in Unit 1 were inspected to verify that they had been built in accordance with the design drawings. During this initial inspection, it was discovered that 14 walls did not have clip angles installed which were to tie them to surrounding structural members. The missing clip angles were installed prior to the start of the design re-evaluation. After the analysis was completed, it was shown that these walls could 4 not meet the re-evaluation criteria without having the angles installed. This was asio reported to NRC Region II by the licensee under LER 335-81-03. The design re-evaluation disclosed that three walls had local stresses above code allowable values and would require field modification. These modifications consisted of attachment of various types of structural steel supports to the walls in order to provide additional support to the walls and reduce the local stresses in the walls to below the code allowable values. After the design re-evaluation was completed, the reactions at the tops of the walls were used to evaluate the adequacy of the supporting (clip) angles. A review of this portion of the wall design indicated that 20 walls had to be modified in order to meet the safety factors specified in IE Bulletin 79-02 for the anchor bolts which attach the clip angles to the surrounding structural members. These modifications consisted of installation of additional anchor bolts in the clip angle supports and/or thru bolting of clip angles on either side of the walls. F (2) Review of Procedures for Accomplishment of Masonry Wall Repair The inspector examined the following documents which control the masonry walls modification activities: (a) Plant Change Modification numbers 9-81 and 11-81
3... ~ 8 (b) EBASCO drawing numbers BCS 128-4.307, 4.308, and 4.309 (c) EBASCO letter SL BF-81-042, dated February 5, 1981, and attachments to letter,
Subject:
St. Lucie Plant Unit No.1 - Backfit Program Masonry Wall Design (d) FP&L Quality Instruction QI 10.23, " Inspection and Testing of Expansion Anchors" (3) Inspection of Completed Wall Modifications The inspector examined the walls listed below and compared the modification which had been made to the walls with the details shown on the design documents. Walls examined were as follows: 34, 74, 114, 123, 124, 159, 174, and 203. (4) Review of Quality Records Relating to Masonry Wall Modifications. The inspector examined the following quality records relating to the masonry wall modification (repair) program: s (a). Inspection Checklists for Anchor Bolts for Wall numbers 114, 123, 124, 125, 159, and 203 (b) Weld Inspection Documentation for Wall Numbers 114, 123, 124, and 125 (c) General Inspection Report Number IR 2/138-045 and IR 2/138- .045. These reports document inspection of structural steel
- erectionthru-bolting.
(d) Nonconformance Report Numbers 2/138-211 R and 2/138-241 C. IE Bulletin 80-11 remains open pending completion of review of the licensee's response by the NRC Office of Nuclear Reactor Regulation. No deviations or violations were identified.
OFFICIAL COPY , at ,,hg '~f UNITED STATES 8 i NUCLEAR REGULATORY COMMISSION g. r REGION ll j[ 101 MARIETTA ST., N.W., SulTE 3100 Q% ATLANTA, GEORGIA 30303 JIM 0 9198) Florida Power and Light Company ATTN: Mr. R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Report No. 50-389/81-07 This refers to the routine safety inspection conducted by Mr. B. P.. Crowley of this office on May 12-15, 1981, of activities authorized by NRC Construction Permit No. CPPR-144 for the St. Lucie facility. Our preliminary findings were-discussed with Mr. B. J. Escue, Plant Manager, at the conclusion of the inspec-tion. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations.of procedures and representative records, interviews with personnel, and observations by the inspector. During the inspection, it was found that certain activities under your license appear to violate NRC requirements. This item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A. Elements to be included in your response are delineated in Appendix A. One new unresolved item is ide'ntified in the enclosed inspection report. This item will be examined during subsequent inspections. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be exempt from disclo-sure under 10 CFR 9.5(a)(4), it is necessary that you: (a) notify this office by telephone within ten days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven days ~ are available for your review, please notify this office promptly so that a new due date may be established. Consistent with section 2.790(b)(1), such applica-tion must be accompanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be withheld, and a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790-(b)(4). The information sought to be withheld shall be incorporated as far as f 0 t h
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.s. 2 JUN 0 91981 possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. Should you have any questions concerning this letter, we will be glad to discuss them with you. Sincerely, E.c. R. C. ewis, Acting Director Division of Resident and Reactor Project Inspection
Enclosures:
1. Appendix A, Notice of Violation 2. Inspection Report No. 50-389/81-07 cc w/ enc 1: B.. J Escue, Plant Manager N. Weems, Assistant QA Construction Manager f e f 4 .m. ...-.,-.,_-r-,._,., --___..__,-.c ~,y_.,._..m m r, r.-._-. -
APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company Docket No. 50-389 St. Lucie License No. CPPR-144 As a result of the inspection conducted on May 12-15, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified. 10 CFR 50, Appendix B, Criterion V, implemented by Section TQR 5.0 of FP&L Topical Report FPLTQAR-1-76A, requires in part that, activities affecting quality shall be prescribed by documented instructions, procedures, and drawings and shall be accomplished in accordance with these instructions, procedures and drawings. Paragraph 5.2.3 of NDE procedure 13172-ISI-20, the applicable procedure for ultrasonic inspection of reactor coolant loop welds, requires that each weld and h T metal on each side of the weld be examined using a 45 degree and 60 degree angle beam technique applied in two directions toward the weld. Contrary to the above, on May 13, 1981, activities affecting quality were 1.. not being accomplished in accordance with documented procedures in that for the 60 degree scan toward the weld for reactor coolant loop weld 112-1407-771A, the examiner was scanning the base material up to the edge of the weld and not scanning the weld surface. This is a Severity Level V Violation (Supplement II.E). Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola-tion; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Date: JUN 0 9121 P 810723 0 050oogg9 PT@
/ o, UNITED STATES j'" ~1, NUCLEAR REGULATORY COMMISSION c REGION 11 e 101 MARIETTA ST., N.W.. SUITE 3100 h o[ ATLANTA. GEORGIA 30303 Report No. 50-389/81-07 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: St. Lucie Docket No. 50-389 License No. CPPR-144 Inspection at St. Lucie Site near Fort Pierce, Florida [ Inspector: B. R. Crowley~ / Dhte Signed ~ Approved by: [ [74 [/4-/Mi A. R. Herdt, Section Chief D&te Signed ~ Engineering Inspection Branch Engineering and Technical Inspection Division
SUMMARY
Inspection on May 12-15, 1981 Areas Inspected This routine, unannounced inspection involved 26 inspector-hours on site in the areas of licensee identified items, reactor coolant pressure boundary piping,, preservice inspection (PSI) and reactor vessel internals. Results Of the four areas inspected, no violations or deviations were identified in three areas; one violation was found in one area (Failure to follow ultrasonic inspec-tion procedure for PSI - Paragraph 10.C). M *J2-Blo723 PDR ADOCK 05000389 0 @JbTS
v. i REPORT DETAILS 1. Persons Contacted Licensee Employees
- B. J. Escue, Site Manager
- W. M. Hayward, Supervising QA Engineer D. R. Cooper, Supervising QA Engineer
- W. F. Jackson, Welding Superintendent
- G. E. Crowell, Site Engineering Supervisor
- G. J. Boissy, Startup Superintendent
- E. R. Tilley, Construction Test Superintendent
- E. O. Poarch, Services Superintendent
- E. Sherman, QA Engineer
- J. W. Adams, QA Engineer
- J. L. Parker, Project QC Supervisor
- P. W. Heycock, PSI Coordinator - Power Resources F. T. Carr, Specialist - Power Resources W. M. Gaines, Power Plant Engineering G. Gotch, Specialist - Power Resources Other Organizations M. Carucci, QC Superintendent, Combustion Engineering, Inc.
B. A11 bee, PSI Project Engineer, Combustion Engineering, Inc.
- R. W. Zaist, Project Superintendnet, EBASCO Services, Inc.
- R. A. Garramore, Senior Rerident Engineer, EBASCO Service, Inc.
R. G. Beckham, Weld Test Supervisor, EBASCO Services, Inc. E. L. Thomas, Vice President, Lambert-MacGill-Thomas, Inc.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 15, 1981 with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee. ~ (0 pen) Inspector Followup Item 389/81-07-05, " Revision to procedure for overall control of PSI" - Paragraph 8.b(1). (0 pen) Inspector Followup Item 389/81-07-06, " Documentation of licensee approval of PSI contractor's program plan and QA manual" - Paragraph 8.b(2). l
i 2 (0 pen) Violation 389/81-07-07,." Failure to follow ultrasonic procedure for PSI" - Paragraph 10.c. (0 pen) Unresolved Item 389/81-07-08, " Welder not qualified to WPS specified on weld traveler" - Paragraph 7.b.(2)(a). 3. Licensee Action on Previous Inspection Findings Not inspected. 4. Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violat; ions or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 7.b.(2)(a). 5. Independent Inspection Effort The inspector conducted a general inspection of the reactor building and auxiliary building to observe construction progress and construction activities such as we.lding, welding material control, housekeeping and storage. i.. Within the areas inspected, no violations or deviations were identified. 6. Licensee Identified Items (LII) Prior to this inspection, the licensee identified the following items considered reportable under 10 CFR 50.55(e): a. (Closed) Item 389/80-12-01, Reactor coolant pump casing - Variations in nozzle weld preps. On September 15, 1980, Florida Power and Light Company notified IE:RII of a potential 50.55(e) item concerning variations in the nozzle weld preps on the reactor coolant pump casings. On November 17, 1980, the licensee reported that the condi-tion had been evaluated and determined not reportable. This item pertained to machining not shown on the drawing where the weld prep intersects the as-cast surface on the outside diameter of the casing nozzles. The decision that the item was not reportable was based on ~ the fact that the design requirement., would have been met whether or not corrective actions were taken. The decision to take corrective action was based on the fact that less welding would be required to obtain the required weld contour if the weld preps were blended into the as-cast surface. The inspector has no further questions on this item. 4
3 b. (0 pen) Item 389/81-07-01,. Structural member welded to containment vessel. On April 16, 1981, Florida Power and Light Company notified IE:RII of a 50.55(e) item concerning a structural member welded to the containment vessel contrary to ASME requirements. Investigation is in progress. A written report is due May 16, 1981. c. (0 pen) Item 389/81-07-02, Structural member welded to containment pad. On April 16, 1981, Florida Power and Light Company notified IE:RII of a 50.55(e) item concerning a structural member welded to a containment pad without required 4" clearance from edge of pad. Investigation is in progress. A written report is due May 16, 1981. d. (0 pen) Item 389/81-07-03, Lamination in 304 stainless pipe. On April 21, 1981, Florida Power and Light Company notified IE:RII of a 50.55(e) item concerning a lamination in a 24" diameter 304 stainless steel spool piece. Investigation is in progress. A written report is due May 21, 1981. e. (0 pen) Item 389/81-07-04, Low pressure safety injection system valves, Target Rock valves - design deficiency. On November 24, 1980, Florida Power and Light Company notified IE:RII of a potential 50.55(e) item concerning a design deficiency in Target Rock safety injection valves. An interim report was issued on December 23, 1980. The final construc-tion deficiency report was submitted on January 26, 1981. The report has been reviewed and determined to be acceptable by RII. All affected valves are being returned to the valve manufacturer for inspection, rework, modification and testing. This item remains open pending completion of corrective action. 7. Reactor Coolant Pressure Boundary Piping - Observation of Work and Work Activities The inspector observed non-welding and welding work activities for reactor coolant pressure boundary piping. The applicable code for installation of reactor coolant pressure boundary piping is the ASME Railer and Pressure Vessel Code, Section III, Subsection NB, 1977 Edition with Addenda through S77. a. Observation of Non-Welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following: inspection and/or work procedures, recordkeeping requirements, installation specification requirements, specified material, and qualified inspection personnel. Piping Comoonent Activity Procedure Surge line RC108 ( Assys. Handling and Protection SQP-47, Rev. 3 751-106 and 771-1609) during Installation
1 l j 4 l b. Observation of Welding Activities The inspector examined welding activities for reactor coolant pressure boundary piping as described below to determine whether applicable code and procedure requirements were being met. (1) Welding The inspector observed in process welding on FWOO2 on line RC 0151 and FW 005 on line SI 0148 to determine whether: (a) Work is conducted in accordance with a document which coordinates and sequences operations, references procedure, establishes hold points, and provides for production and inspection approval. (b) Weld identification and location are as specified. (c) Procedures, drawings, and other instructions are at the work station and readily available. (d) WPS assignment is in accordance with applicable code require-ments. (e) Welding technique and sequence are specified and adhered to. (f) Welding filler materials are the specified type and traceable to certifications. (g) Alignment of parts is.as specified. (h) Preheat and interpass temperatures are in accordance with procedures. (1) Electrodes are used in positions and with electrical charac-teristics specified. (j) Shielding gas is in accordance with the welding procedure. (k) Welding equipment is in good condition. ~ (1) Interpass cleaning is in accordance with applicable proce-dures. (m) Temporary attachments are removed in accordance with applic-able procedures. (n) Welding personnel are qualified.
?- 5 (o) Weld history records are adequate. (2) Welder Qualification (a) The inspector reviewed the welder qualification records for welders FDX and FDU as applicable to the two welds listed in paragraph 7.b.(1) above. During this review, the inspector found that records for welder FDX, who was assigned to field weld 002, did not indicate qualification to the applicable WPS. Further investigation revealed that on April 22, 1981, the.WPS for field weld 002 had been changed from WPS 006 to WPS 050. On May 12, 1981 and May 13, 1981, welder FDX withdrew welding material for field weld 002 to WPS 006. Welder FDX was qualified to WPS 006 but not to WPS 050. Review of WPS 006 welding variables indicate that WPS 006 appears to be qualified for field weld 002. The reason for the change from WPS 006 to WPS 050 and the full significance of this matter could not be determined prior to the conclu-sion of the inspection. The licensee stated that this matter will be examined to determine all details of the problem. This matter is considered an unresolved item and is identi-fied as item number 389/81-07-08, " Welder not qualified to WPS specified on weld traveler". (b) The following welder qualification activities were observed: (1) In process of welding test assemblies for qualification Welder Procedure Application 13-518 WPS 24 ' Carbon Steel Pipe BDM WPS 15 Carbon Steel Plate 13-517 WPS 43 Stainless Steel Pipe 13-638 WPS 24 Carbon Steel Pipe 13-519 WPS 24 Carbon Steel Pipe 6-560 WPS 5 Carbon Steel Plate (2) Review of RT film Welder Procedure Acolication 13-230 WPS 5 Carbon Steel Plate 9-517 WPS 15 Carbon Steel Plate 13-991 WPS 43 Stainless Steel Pipe 13-518 WPS 24 Carbon Steel Pipe 10-519 WPS 15 Carbon Steel Plate 10-517 WPS 15 Carbon Steel Plate 7-560 WPS 5 Carbon Steel Plate Within the area inspected, no violations or deviations were identified.
y 6 8. Preservice Inspection - Review of Program The inspector reviewed the licensee's preservice inspection (PSI) program as described below to determine whether regulatory requirements were being met. The PSI is being performed in accordance with the ASME Boiler and Pressure Vessel Code, Section XI, 1977 Edition with Addenda through S78 as modified by 10 CFR 50.55a.(g). FP&L - Power Resources has overall responsibility for the PSI, is coordinating the PSI, and has contracted Combustion Engin-eering-In-Service Inspection Power Systems Group (CE) for the inspection. CE is responsible for the PSI program and procedures. The actual inspec-tion work has been sub-contracted to Lambert-McGill-Thomas, Inc. (LMT) who will perform inspections in accordance with the CE program and procedures. The inspector reviewedTthe following documents in the areas of program a. approval, organizational structure and QA audit requirements: (1) CE Document PPB-ISI-001, Revision 0, " Pre-service Inspection Program Plan for Florida Power and Light St. Lucie, Unit 2" (2) CE " Development Department Quality Assurance, Program Description" Original Issue (3) CE Document 0000-ESS-155, Revision 2, " Quality Assurance Program for Inservice Activities (4) FP&L QA 2.9, Revision 3, " Qualification of QA Audit, QC Inspec-tion, and Construction Test Personnel" (5) FP&L QP 18.2, Revision 7, " Scheduling of Quality Assurance Depart-ment Audit Activities" (6) FP&L QP 18.1, Revision 4, " Conduct of Quality Assurance Department Quality Audits" (7) FP&L QP 10.5, Revision 0, "Preoperational (Baseline) Examination" b. During the above review, the inspector noted the following two problems: (1) The overall procedure for control of PSI (QP10.5) was written around the Unit 1 organization and does not adequately describe the organization interfaces (i.e., CE-FP&L-LMT) for Unit 2. The licensee was in the process of revising this QP and issuing an adminsitrative procedure to cover this area. This will be identified as inspector followup item 389/81-07-05, " Revision to procedure for overall control of PSI," for review on a future inspection.
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(2) The CE program plan and QA program had not been approved by letter from FP&L. The inspector did note that the documents had been reviewed and conditionally approved in minutes of meetings between FP&L and CE. The licensee stated that official letters of approval will be issued. This item is identified as inspector followup item 389/81-07-06, " Documentation of licensee approval of PSI contractors program plan and QA manual". Within the areas inspected, no violations or deviations were identified. 9. Preservice Inspection - Review of Procedures The inspector reviewed the PSI procedures listed below to determine whether the procedures were consistent with regulatory requirements. See paragraph
- 8. above for the applicable code.
CE Procedure 13172-ISI-020, Revision 2A, " Manual Ultrasonic Examination Procedure for Primary Piping Welds Including Branch Connections and Pipe to Ferritic Nozzle Welds" CE Procedure 13172-ISI-029, Revision 2, " Generic Manual Ultrasonic Examination Procedure" CE Procedure 0000-ESS-117, Revision 3, " Ultrasonic Instrument Linearity Ventilation" The procedures were reviewed in the areas of procedure approval; qualifi-cation of NDE personnel; and technical content relative to type of appa-ratus, extent of coverage including beam angles and scanning technique, calibration requirements, search units, DAC curves, reference level for monitoring discontinuities, method of demonstrating penetration, levels for ~ evaluation and recording indications, and acceptance standards. Within the areas inspected, no violations or deviations were identified. 10. Preservice Inspection - Observation of Work and Work Activities The inspector observed the PSI activities described below to determine whether these activities were being performed in accordance with regulatory requirements and licensee procedures. See paragraph 8. above for the applicable code. a. Personnel qualification records for one Level III, two Level II and two Level I NDE examiners were reviewed.
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~ 8 b. In process ultrasonic (UT) inspection including calibration or, applic-able calibration blocks, was observed to the extent indicated for the following welds: Component Weld Examination Loop B Reactor Coolant 121-801-771 45 Angle Beam Cold Leg (Zone 11) Loop B Reactor Coolant 121-109-742-8 45 Angle Beam Cold Leg (Zone 10) Loop A Reactor Coolant 112-1407-771A 60 Angle Beam Cold Leg (Zone 12) The inspections were compared with applicable procedure in the following areas: (1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel (3) Use of NDE personnel qualified to the proper level (4) Recording of inspection results (5) Type of apparatus used (6) Extent of coverage of weldment (7) Calibration requirements (8) Search Units (9) Beam Angles (10) DAC Curves (11) Reference level for monitoring discontinuities (12) Method for demonstration penetration 4-(13) Limits for evaluating and recording indications (14) Recording significant indications (15) Acceptance limits c. During observation of the UT inspection of weld 112-1407-771A, the inspector noted that the examiner was scanning the base material up to the edge of the weld and not scanning the weld surface when scanning perpendicular to the weld. Paragraph 5.2.3 of the applicable proce-dure, 13172-ISI-20, requires that, "Each wald and the volume of metal for hT on each side of the (WRV) shall be ultrasonically examined using a0 longitudinal beam applied in one direction and 45 and 60* shear wave angle beam techniques applied in two directions toward the weld and...." This failure to follow procedure is considered violation of Criterion V of 10 CFR 50, Appendix B as implemented by FP&L Topical Report FPLT0AR 1-76A, Section TQR 5.0 and is identified as item 389/81-07-07, " Failure to follow ultrasonic inspection procedure for PSI". Within the areas inspected, no violations except as noted in paragraph 10.c. or deviations were identified.
... g l 9 11. Reactor Vessel Internal - Review of Quality Records The inspector reviewed the BIGGE Power Constructor's QA records for handling the reactor vessel internals during moving from storage to the containment. The records consist of: (1) procedure hold points, (2) "on-site surveil-lance QA verification checklist" and (3) "BIGGE on-site QA check points". The applicable procedures were: CDP 5-19, Revision 2, "Loadout, Transport and Placement of the Core Shroud / Support Structure Inside the Containment" Placement of the Core Shroud / Support Structure Inside the Containment" C0P 5-23, Revision 0, "Loadout, Transport and Placement of the Core Barrel Inside Containment" Within the areas inspected, no violations or deviations were identified. i
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4 UNITED STATES [ ^ s., 'k NUCLEAR REGULATORY COMMISSION g r REGION ll 101 MARIETTA ST., N.W.. SulTE 3100 ek*@ ATLANTA, GEORGIA 30303 JUN 161981 Florida Power and Light Company ATTN: Mr. R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentle nen :
Subject:
Report No. 50-389/81-9 This refers to the routine safety inspection conducted by Mr. T. D. Gibbons of this office on May 12-15, 1981, of activities authorized by NRC Construction Permit No. CPPR-144 for the St. Lucie facility. Our preliminary findings were discussed with Mr. B. J. Escue, Plant Manager, at the conclusion of the inspec-t i o n,. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. During the inspection, it was found that certain activities under your license appear to violate NRC requirements. This item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A. Elements to be included in your response are delineated in Appendix A. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be exempt from disclo-sure under 10 CFR 9.5(a)(4), it is necessary that you: (a) notify this office by telephone within ten days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five. days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven days are available for your review, please notify this office promptly so that a new due date may be established. Consistent with section 2.790(b)(1), such applica-tion must be accomoanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be withheld, and a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790-(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. F00A-N-2A5 LflS6 hu1103We10731 PDR ADOCK 05000389 0 PDR
C JUN 161981 l Florida Power and Light Company 2 Should you have any questions concerning this letter, we will be glad to discuss them with you. Sincerely, i E. c. R. C, wi s, Acting. Director Division of Resicent and Reactor Project Inspection
Enclosures:
1. Appendix A, Notice of Violation 2. Inspection Report No. 50-389/81-9 cc w/ encl: B. J. Escue, Plant Manager N. Weems, Assistant GA Construction Manager l <a i i
APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company Docket No. 50-389 St. Lucie 2 License No. CPPR-144 As a result of the inspection conducted on May 12-15, and in accordance with the Interim Enforcement Policy, 45 FR 65754 (October 7,1980), the following viola-tion was identified. 10 CFR 50, Appendix B, Criterion V requires " Activities affecting ouality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions...". The Quality Instruction 15.1, Corrective Action, controls the conditional release of items which are nonconformed. The conditional release form states the limits of release. Contrary to the above, on May 13, 1981, SKV Switchgear 2A3-10 was found to have exceeded the conditional release limits in that switchgear compartment 2A3-10 was found to be wired and energized. The conditional release limited the compartment to be stored inplace only. This is a Severity Level VI Violation (Supplement II.F). Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola-tion; (2) th'e reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) cor*ective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation, JUN 161981 g, etBSTT0384'810731 PDR ADOCK 05000389 Q PDR
.h o ce3 / UNITED STATES [ \\ ) s.qg' NUCLEAR REGULATORY COMMISSION ~ "A/. e REGION 11 k ,[ 101 MARIETTA ST., N.W., SUITE 3100 V./ g ATLANTA, GEORGI A 30303 JUN 161981 Report No. 50-389/81-09 Licensee: Florida Power and Light Company 92590 West Flagler Street Miami, FL 33101 Facility Name: St. Lucie 2 Docket No. 50-389 License No. CPPR-144 Inspection t St. Lucie site near Ft. P%rce, FL Inspector: en 4 - /d " Il T. D Gibbons Date Signed Approved by: 22 M A - /#- F/ T. E. Conlon, Section Chief Date Signed Engineering Inspection Branch Engineering and Technical Inspection Division
SUMMARY
Inspection on May 12-15, 1981 Areas Inspected This routine, unannounced inspection involved 29 inspector-hours onsite in the areas of electrical components and systems work and work activities, electrical cables and terminations work and work activities, and quality records review. Results Of the three areas inspected, no violations or deviations were identified in two areas; one item of noncompliance was found in one area (Failure to follow the procecure for release of nonconforming items, paragraon 7). Ottet-toGGG, 810731 PDR ACOCK 05000389 G PDR t
'l l o 4: I REPORT DETAILS 1. Persons Contacted Licensee Employees
- B. J. Escue, Site Manager
- E. Sherman, OA Engineer
- R. A. Symes, Senior QA Engineer
- G. E. Rockwell, QA Engineer Other Organizations
- R. W. Zaist, Project Superintendent, EBASCO, Inc.
NRC Resident Inspector
- S. A. Elrod
- H. E. Bibb I
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarizac on May 15, 1981 with those persons indicated in paragraph 1 above. The violation was discussed in detail. 3. Licensee Action on Previous Inspection Findings Not inspected. 4. Unresolved Items Unresolved items were not identified during this inspection. 5. Electrical (Cables and Terminations I and II) - Observation of Work and Work Activities The inspector selected twelve power and twelve control cables for examina-tion as follows: 21607C-SA, 20991C-SA, 20993F-SA, 20302B-MC, 20516F-SB, 21120A-SA, 20991B-SA, 20991A-SA, 20938A-SA, 20939A-SB, 220993A-SB, 20993B-SB, 20378R-MD, 21130A-SB, 211220A-SA, 21160C-SA, 2100IL-ASA, 2100aD-SA, 20655A-SA, 21121A-SA, 21131A-SB, 205238-ASB, 20542D-SA, and 20656A-SB.
n-2 The cables were examined to assure that the requirements of the SAR and QAM l were complied with in the areas of storage, handling, nonconformance con-trol, use of specified material, material control, vendor certified test reports, mill certifications, drawing and procedure control, installation and QC procedures, size and type cable, location, routing, protection separation, grounding, raceway supports, raceway identification, cable pulling procedures, raceway identification, cable pulling procedures, raceway loading, terminations and installed cable tests. Within the areas examined, there were no violations identified. 6. Electrical Cables and Terminations I and II - Review of Quality Records The inspector selected the cables identified in paragraph 5 for an exami-nation of Quality records. The records were examined to assure that the SAR and QAM requirements were complied with in the areas of receiving inspec-tion, acceptance, vendor certified test reports, source inspection, mill 4 certification, size and type of cable, location, routing, bend radius, i grounding, raceway identification, cable pulling records, terminations raceway supports, cable tests and cable _ acceptance. Within the areas examined there were no violations identified. 7. Electrical (Components and System I) - Observation of Work and Work Acti-vities a The inspector selected Emergency Diesel Generators 2A and 2B, SKV switchgear 2A3 and 2AB4, 480 Volt Load Center 2AZ, and Motor control centers 2AS, 2A6 and 2A7. The equipment was examined to assure that the SAR, QAM and instal-lation procedures were complied with in areas of receiving inspection, acceptance, storage, identification, handling, placements, protection, cleanliness, separation, location, anchoring, qualification of QC personnel and nonconformance control. The inspector identified an apparent violation during the inspection of SKV switchgear 2A3. A nonconformance (NCR 496E) was identified by the ifcensee on April 13, 1978 which related to switches on the potential transformers in five cabinets in three switchgear units. The licensee issued a Temporary Release of nonconforming material on March 2, 1979. The release was issued to allow storage in place with no work to be performed. The inspector noted that the panels were wired, energized and under the control of licensee startup. This item is identified as 389/81-09-01, Failure to follow the procedure for temporary release of nonconforming items. This appears to be an isolated case and the equipment has not been damaged. The licensee has taken corrective action to verify that tnere were no further violations in this area. The licensee has corrected the temporary release. The licensee stated that the replacement switches are due for delivery prior to final I turnover to operations.
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- FLORIDA POWER & LIGHT COMPANY g (,
y June 29, 1981 L-81-269 Mr. James P. O'Reilly, Director, Region II Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 101 Marietta. Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Re: RII:JJL St. Lucie Unit 2 Docket No. 50-389/81-06 Florida Power and Light Company has reviewed the subject Inspection Report and our respcnse is attached. There is no proprietary infonnation contained in the report. Very t ly yours, c Robert E. Uhrig Vice President Advanced Systems & Technology REU/TCG/ah cc: Harold F. Reis Esquire Fo/A-84-I13 8107240290-G10713 PDR ADOCK 05000389 b l N' O PDR I
o r RII:JJL 50-3.89/81-06 Violation: Insufficient Procedure for Disposition of NCRs 10 CFR 50, Appendix B, Criterion V, as implemented by FPL Topical Quality Assurance Report Number 5.0, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings, and shall be accomplished in accordance with these instructions, procedures or drawings. Contrary to the above, there were no documented instructions or procedures for control and disposition of site-generated nonconfonnance reports within the Ebasco Site Support Eng'ineering Group (ESSE).
Response
1. FPL concurs with the finding. 2. Due to the fact that Ebasco is not the constructor at St. Lucie Unit 2, a number of Ebasco's Standard Procedures had to be modified or . deleted for the project. ESSE processing of NCRs has been in accordance with an Internal ESSE Standard Operating Procedure (SQP-5), which had not been reviewed by the New York Office for application to quality-related work. 3. The ESSE Project Engineer has drafted a procedure modeled after SQP-5 and transmitted the draft to the New York Office for review / approval and inclusion in the St. Lucie Unit 2 Supplementary Procedures Manual. 4. ESSE personnel will be trained in the new procedure and NRC processing will be monitored by the ESSE Project Engineer to insure compliance. 5. Full compliance will be achieved when the new procedure is issued, estimated to be not later than August 29, 1981. The New York Office has verbally approved the procedure and will forward a letter of approval in the near future. i
J.T.a. STATE OF FLORIDA ) ) ss. COUNTY OF DADE ) Robert E. Uhria , being first duly sworn, deposes and says: That he is Vice President of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee. Robert E. Uhrig [ Subscribed and sworn to before me this 19 h/ M day of %a - O /\\,J-6 A_> > A. L NOTARY PUBLIC, i$ and for the County of Dade, State of Florida Nota y Pub!ic. S:sfo of Monde at Large Mr Commen Exoires October 30. IS83 My commission expires: sonced thru Mavard Boa *ae Acaacy O e
1 ge a cz, M ..a :co WW ' " '."] IE FILE CDP.y ~ ~ ~ ~ July 7,1981 L-81-280 Office of Nuclear Reactor Regulation Mr. Darrell G. Eisenhut, Director.(,3 k Attention: Division of Licensing y." e.,.s y V. S. Nuclear Regulatory Commission c,,( i '. g y 3) h Washington, D. C. 20555 ) ni. A.!. L.:.
Dear Mr. Eisenhut:
E 1) E* 5 u T;P M Re: St. Lucie Unit 2 .C Docket No. 50-389 NM. Construction Completion Schedule b{c At your request, Florida Power & Light Company (FPL) has re-examined its bases for the current projected fuel load date of October,1982 for St. Lucie Unit 2. This date has not changed since the construction permit was issued in May, 1977. Our construction progress perfomance since receiving the construction permit provides a strong basis for confidence in this projection. We continue to feel that the St. Lucie Unit 2 schedule is realistic, achiev-able, and should' be used for planning all work required to support the project. St. Lucie Unit 2 is similar in design to St. Lucie Unit 1, completed in 1976. The St. Lucie Unit 2 construction schedule was developed independently of and is comparable to that of Unit 1 (see Attachment 1). To date we have completed every milestone virtually on schedule and have no reason to believe that the remaining milestones will not be met (see Attachment 2). Our average monthly construction completion rate for the last eighteen months was 2.05% vs. an industry average of about 1.25% (see Attachment 3). FPL tracks the construction effort by bulk quantities and has established installation curves for those quantities (see Attachment 4). This information is reviewed weekly at site meetings and corrective action taken if rates are unacceptable. The engineering design work for St. Lucie Unit 2 is essentially complete. Material delivery is in excess of 90% complete. Based on FPL's experience with Turkey Point Units 3 & 4 and St. Lucie Unit 1, our startup effort was organized and staffed early (when construction was approximately 35% complete). The construction and startup programs were integrated to assure a logical, orderly startup program. To date more than 167 procedures out of a total of 193 have been written, five pre-operational tests have been completed, and 76 systems or subsystems are either in service or in test (see Attachment 5). Beginning this month, operational personnel will man the control room 24 hours a day to support the startup effort. As you are aware, FPL is currently experiencing problems with some reactor coolant system piping welds identified by the ASME Section XI baseline examina-tion. We will not be able to resume normal construction activities in that \\ 8 Foe A-* 4-213 o J;3 m 30144 910707 / PDR ADOCK 05000 g g\\ COPY S3NBEGION
e Page Two Office of Nuclear Reactor Regulation area until mid-July, which puts us some weeks behind schedule on the critical path activities. A schedule recovery plan is being developed, and we are confident that the project will be back on schedule by November, 1981. In the past, the St. Lucie Unit 2 project organization has been effective in dealing with such problems and in minimizing their impact on the construction schedule. The project has the full support of FPL management, and is committed to completing St. Lucie Unit 2 on time. No financial restraints are expected. FPL will continue to update you monthly on the construction /startup status of St. Lucie Unit 2, and also inform you of any problems that might impact the projected fuel load date. We are well aware of your need to accurately assess licensee construction progress and will provide you with the information you need to perform that assessment for St. Lucie Unit 2. Very truly yours, g, Gy Robert E. Uhrig Vice President Advanced Systems & Technology REU/TCG/ah Attachments cc: J. P. O'Reilly, Director, Region II Harold F. Reis, Esquire 4P
UNIT #1 VS. UNIT #2 SCllEDULE MILESTONES 1977 1978 1979 1980 1981 1982 1983 PS L-2 b b bb MAY M 3G MONTils k 4 30MONIllS k 1933 1970 1971 1972 1973 1974 1975 1976 PS L-1 b bb UEC 4 39 MONTilS p 4 30 MONTils p 1976 h STAf tT RCD BASE MAT CONC. h COMMLNCE COLO IlYOllO STAllT INTAKE STituCTUllE 13ASE MAT CONC. h STAlti ilOT OPS #1 STAftT llAB flASE MAT CONCilETE COMMENCE COftE LOAD 3> h COMP EllECT & TEST STEEL CU TO EL 149*- STAllT CillT PEllFOllMANCE lESTS N, h STAftT f tCD INTEllfJAL CONCflETE h COMMEfJCE POWEll ESCALLAltON h START Filu llASE MAT CONCilETE
- COMMtillCIAL OPEllATION h STAlti SElTING NSSS MAJOlt EOulPMENT
ATTACHMENT 2-1 FLORIDA POWER & LIGHT COMPAtN ST. LUCIE UNIT NO 2 COMPETED MILESTONE ANALYSIS SCHEDur Fn M ACTUAL 05/0297 CONSTRUCTION PERMIT 05/02/77 07/06/77 COMPLETE RCB BASEMAT 07/07H7 10/25H7 COMPLETE INTAKE BASEMAT 10/27/77 01/0'4H8 COMPLETE TGB BASEMAT ll/29/77 01/18H8 START RCB LINER 12/21/77 03/01/78 COMPLETE RAB BASB%T 03/15H8 12/06H8 POST WEW HEAT TREATfENT 09/20H8 01/17/79 START RCB INTERNAL CONCRETE 11/03H8 05/09/79 COMPLETE FHB EASB%T 07/20/79 06/18/80 SET NSSS COMPONENTS 06/26/80 09/23/80 COMPLETE RCB OPERATING FLOOR 10/17/80 AT62.0' 09/26/80 SET CONTAINMENT VESSEL D0tE 10/04/80 12/15/80 COMPLETE RAB EXTERIOR 12/18/80 CONCRETE 03/14/81 COMPLETE RC LOOP 02/06/81 LARGE BORE PIPING 04/28/81 COMPLETE REFUELING WATER 04/30/81 STORAGE TANK
I ATTACHMENT 2-2 FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT NO. 2 RB%INING MILESTONES JIEti SCHEDULE COMPLETE EXTERIOR SHIELD WALL DOME CONCRETE 09/06/81 INTAKE TURNOVER (CTO) 09/25/81 COMPONENT COOLING WATER TURNOVER (CTO) 10/11/81 PLACE TURBINE-GENERATOR ON TURNING GEAR 12/15/81 COMPLETE OCEAN DISCHARGE PIPE 12/25/81 DIESEjl GENERATOR INITIAL RUN \\CTO) 01/13/82 SECONDARY HYDRO ~ 01/21/82 Co mENCE COLD HYDRO 03/17/82 START HOT OPERATIONS 07/03/82 C0ne!CE CORE LOAD 10/28/82
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. /_'._ JAN 81 181,862 231,236 850,005 899,108 C 34 _ _. _ _. _e fen 135,477 199,330 985,482 1,098,438 -- 22 1- -+- _j. - sca
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= _{/h._.- _=_ __r AUG 230,451 2,243,531 . ~ _ J __,__ C) 26 r h __;_QEI I $5 5 E EZz2 5 r SEP 211,675 2,455,206 ~r26 24 , i-r_. _ :._._, n.:j__r._. __ =. __ oct 203,181 2,658,387 E F ._,__._ _ i : x e _Er o,.. p_.I.. 24 z rr =__- -_-_-r NOV 207,886 2,'866,273 o b Eb-!2 Ffi ~.'-E=: E EE:= =-T E=== =EE. DEC 174,725 3,040,998 { 2-I -"7 '!-sa'iaaln'- 9E E3.._3'5 '_ _ 3(_53 ".4 4.... . : _E b !._[.._'!MS_ E._,k_!_'7 ~~ ~ ~~ -'~ JAN02 161,577 3,202,575 20 I 12o m ._i_ FEB 133,747 3,336,322 r h 355-$ f'5 h._ _. rW"@"r:_. MAR 109,867 3,446,189 E' -j...., g_ ;.. j_ is k E!i. TEF% T: f EFr== E: E APR 80,639 3,526,828 = cota gogo,-: 36 irir.: - 3; 5 - --- 552 ~~ ~~ ~ ~ MAY 58,656 3,585,484 E 36 x juN 49,504 3,634,988 Z 8 %3F.br nr 1-ji,:Cr-JUL 38,933 3,673,921 E '4
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0 8e t/s.74 too <3._. 10 90 ~ SCHEDULED ACTUAL SCHEDULED ACTUAL. MONTHLY MONTHLY CUMULATIVE CUMULATIVE JANB1 1,308 2,246 7,156 8,093 9 _~ FEB 1,532 2 963 8,788 11,056 = _. = _._-__
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""-" "L KTTXCHIGNr 5-2 SYST21 PTO NAME OF SYSTDI DATE d [ g. 54-1 m FIRE WATER & PROTECTION 2/23/79 54--3 4 FIRE WATER & PROTECTION 3/31/79 g 34-2 FIRE UATER & PROTECTION 5/11/79 57-1 6.9 KV ELECTRICAL SYST91 5/11/79 58.-2 4.16 KV ELECTRICAL SYSTEM 5/11/79 58-1 4.16 KV ELECTRICAL SYSTDI 5/14/79 56-1 STARTUP TPWISFORMERS 5/14/79 56-1 240 KV SWITCHYARD 5/22/79 66-2 STARTUP TRANSFORMERS 3/24/80 57-2 6 9 KV ELECTRICAL SYSTE: 3/27/80 58-3 4.16 KV ELECTRICAL SYSTai 3/27/80 63-1 SEQUENCE OF EVENTS RECORDER 3/27/80 58-4 4.16 KV ELECTRICAL SYSTDi 6/03/80 57-3 6.9 KV ELECTRICAL SYSTEi '6/13/80 57-4 6.9 KV ELECTRICAL STSTDi 7/01/80 58 5 4.16 KV ELECTRICAL SYSTai 7/01/80 52.-4 3.- -FIRE NATER & PROTECTION 8/15/80 59A-1 19.- SYA-3 ~ 480 V LC 2A1 12/18/80 480 V LC 231 12/18/80 593-1 480 V MCC 2A1 12/18/80 -593 -2 -480-7 MCC 2C 12/18/80 5 93 -3 480 V MCC 231 12/18/80 52-4 125 7 DC SYSTai 12/18/80 58-S 4160 V SWITCHGEAR 233 1/07/81 5 93 -6 480 V MCC 2B3 1/07/81 593-7' 480 V MCC 2A3 1/07/81 593-8 480 V MCC 2B5 1/07/81 62-1 125 V DC TRAIN "A" 1/08/81 62-2 125 V DC TRAIN "AB" 1/08/81 52-3 125 V DC TRAIN "AB" 1/08/31 593-5 480 V MCC 2A2 1/14/81 593-9 480 V MCC 2B6 1/19/81 ~ 54-6 FIRE PROTECTION. SYSTDI 1/19/81 3A (CTO) SERVICE AIR SYSTDI 1/25/81 Sf3-4 480 V MCC 2B1 1/28/81 j 59A-2 480 V LOAD CENTERS 2/02/81 1 6-1 TURBINE COOLING UATER 2/04/81 j 6-4 TURBINE COOLING UATER 2/10/81 s ) 55-1 ANNUNCIATORS 2/11/81 59A-5 480 V SWITCHGEAR 2AB 2/19/81 58-9 4160 V SWITCEGEAR 2AB 2/23/8L 593-12 480 V MCC 2A6 2/26/81 58-7 4.16 KV ELEC. SYS. STCR. 2A3 3/10/81 34-5. FIRE PROTECTION SYSTai 3/L1/81 59A-4 480 V MCC 2A2 3/12/81 60A-1 120/208 V AC PUR. PNLS. 3/19/81 4A (CTO) INSTRTIENT AIR SUPPLY 3/17/81 l l l e 1 l L ~ g,
ST. LUCIE UNIT 2 ATTACHMENT 5-3 PARTL\\L SYSTEM TURNOVERS June 19, 1981 SYSTEM - PTO NAME OF SYSTEM DATE 40D-1 L.W.M. Spent Resin 3/31/31 61A-1 120/208 VAC Instr. Buses 2B&2D 4/02/81 61A-2 120/208 VAC Instr. Bases 2A&2C 4/02/81 180-1 Condensate Serg. & Transf. 4/05/81 41A-2 Gas Waste Hold Up 4 /14 /81 60A-2 120/208V Power Panels 4/16/81 6 (CTO) Turbine Cooling Water 4/21/81 62-5 125V Powcr Distribution 4/27/81 66-3 Startup Transformers 4/29/81 59B-13 480V Mcc's 4/29/81 61B-1 120V AC Vital Power 4/29/81 59B-11 480V Mcc 2A5 4/29/81 59A-6 480V Elec, Load Centers 4/29/81 57-5 6.9KV System 4/29/81 43A-2 Equipment & Floor Drains 4/29/81 60A-6 120/208V Power Panels 4/30/81 58-10 4160V SWGR. 5/06/81 40B-3 Waste Ion Exch. Tanks & Pu: cps 5/13/81 40B-2 Waste Ion Exch. Tanks &' Pumps 5/13/81 59B-14 480V Mce 2 A7 5/15/81 59B-15 480V Mce 2 B7 5/15/81 60A-3 120/208V Power Panels 5/18/81 61A (CTO) 120/208V AC 57 (CTO) 5/26/81 6.9KV Electrical System 5/27/81 53A-2 Diesel Generator 2A 5/28/81 53B-3 Diesel Generator 2B 5/28/81 102-3 RTGB & HVCB 44L (CTO) 6/01/81 B. A. Condensate Tanks & Pu=ps 6/10/81 7-2 Circulating Water 6-16-81 O e e
'o*5 \\ July 8,1981 L-81-282 Mr. J. P. O'Reilly, Director, Region II Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Re: RII:BRC St. Lucie Unit 2 Docket No. 80-389/81-07 Florida Power & Light Company has reviewed the subject Inspection Report and our response is attached. There is no proprietary information contained in the report. Very
- yours, 1
l} Robert E. Uhrig Vice President Advanced Systems & Technology REU/TCG/ah cc: Harold F. Reis, Esquire l l l l Fo/A -N-297 N ES 810723 b [ l$$ l DR ADOCK 05000389 i PDR
RII:BRC 50-389/81-07 Violation: Failure to Follow Ultrasonic Procedure for PSI 10 CFR 50, Appendix B, Criterion V, impir.mented by Section TQR 5.0 of FPL Topical Report FPLTQAR-1-76A, requires in part that, activities affecting quality shall be prescribed by documented instructions, procedures, and drawings and shall be accomplished in accordance with these instructions, procedures and drawings. Paragraph 5.2.3 of NDE procedure 13172-ISI-20, the applicable procedure for ultrasonic inspection of reactor coolant loop wel.ds, requires that each weld and Y T metal on each side of the weld be examined using a 45 degree and 60 degree angle beam technique applied in two directions toward the weld. Contrary to the above, on May 13, 1981, activities affecting quality were not being accomplished in accordance with documented procedures in that for the 60 degree scan toward the weld for reactor coolant loop weld 112-1407-771A, the examiner was scanning the base material up to the edge of the weld and not scanning the weld surface.
Response
1. FPL concurs with the finding. 2. FPL attributes failure on the part of the Level II NDE examiner to follow the ultrasonic procedure on the subject weld to oversight. ~3. The weld was re-examined by this ~ examiner under the direction of management NDE individuals in strict accordance with the procedure and found to be satisfactory. These results were then verified by an overview by another examination crew. Also, approximately thirty percent of previous examinations by this examiner were re-examined by other exam personnel and verified this examiner's results. Further investigation by the Combustion Engineering l cognizant engineer and examination subcontractor Level II l revealed that the oversight was an isolated occurrence. l l 4. All examiners were recounselled on procedural requirements pertaining to this finding. In addition, the procedure will be changed to further clarify this condition. 5. Full compliance will be achieved by July 15, 1981. l
STATE OF FLORIDA ) ) ss COUNTY OF DADE ) Robert E. Uhrig, being first duly sworn, deposes and says: That he is a Vice President of Florida Power & Light Company, the Applicant herein: That he has executed the foregoing document; made in this said document are true and correct to the best ofthat the stateme his knowledge, information and b71ief, and that he is authorized to execute the document on behalf of said Applicant. r /I p' a n y u- /, b ef b Lty Robert E. Uhrig [ Subscribed and sworn to before me this 7 day of M 19I 8# h. }lAgLnxi L t NOTARY PUBLIC, in()tnd for the County of Dade, State of Florida s a,,, n. .. rc of n. -i t:. m uw - Vy :x m., ,n h ncs Oc.t r.t 10. WO My commission expires: ee w - uer= e :mw i
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UNITED STATES ' ' ' ^ NUCLEAR REGULATORY COMMISSION 80 ~3 M n {- _. E REGION ll o 101 MARIETTA ST., N.W.. SUITE 3100 ) e ATLANTA. GEORGIA 30303 JUL 131981 gT /.p.h-N'l v
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'jE ElLE COPY j 6((,[/jft Florida Power and Light Company L 4. ATTN: Dr. R. E. Uhrig, Vice President Jg,', 2 3 pgI A,_ Advanced Systems and Technology T 7 y* g D P. O. Box 529100 P-er AS Miam'i, FL 33152 l- 's r L:' ' Ml% Gentlemen: ,. _1) ) S q) / l 1
Subject:
Report.No. 50-389/81-06 Thank you for your letter of June 29, 1981, informing us of steps you have taken to correct the violation concerning activities under NRC Construction Permit No. CPPR-144 brought to your attention in our letter of June 3,.1981. We will examine your corrective actions and plans during subsequent inspections. We appreciate your cooperation with us. Sincerely, [. J. Kellofcf, Acting thief Reactor Projects Branch #2 Divisibn of Resident and Rea~ctor Project Inspection cc: B. J. Escue, Plant Manager N. Weems, Assistant QA Construction Manager i TEo/ .5 /ff greyc40ess-810713 40 PDR ADOCK 05000389 g PDR G g
j$h4I 9 July 15, 1981 L-81-294 Mr. James P. O'Reilly, Director, Region II Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
-Re: RII:TDG St. Lucie Unit 2 Docket No. 50-389/81-09 Florida Power & Light Company has reviewed the subject Inspection Report and our response is attached. There is no proprietary information contained in the repont. Verygtly yours, by - bW7 - f. Robert E. Uhrig Vice President Advanced Systems & Technology REU/TCG/ah Attachment cc: Harold F. Reis, Esquire 4 FotA-su-293 fbi 55SE?o!$8gj, Ll461 PDR l
o RII:TDG 50-389/81-09 Violation: Failure to Follow Procedure for Release of Nonconforming Items 10 CFR, Appendix B, Criterion V, requires " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions...". The Quality Instruction 15.1, Corrective Action, controls the conditional release of items which are nonconformed. The conditional release form states the limits of release. Contrary to the above, on May 13, 1981, SKV Switchgear 2A3-10 was found to have exceeded the conditional release limits in that switchgear compartment 2A3-10 was found to be wired and energized. The conditional release limited the compartment to be stored in place only.
Response
1. FPL concurs with the finding. 2. Site personnel were not fully knowledgeable of the Material Control Procedure as it applies to discrepancies. 3. The Nonconformance Report was added to the Exception List for all affected switchgear compartments. Verification was made that modification kits required to satisfy St. Lucie Unit 2 design requirements are on order and will be installed prior to complete turnover of the system. 4. The Start-up group was reinstructed concerning the use of hold tags. Additionally, possible confusion existed due to the Receiving Department and Electrical Quality Control having valid hold tags attached to the same equipment. Receiving Department's hold tags identify "as received" sections while Electrical QC's identify individual compartments. The Receiving Department has reissued hold tags for each compartment to eliminate any confusion and Site Engineering has increased the scope of the limitation applied to NRC 496E and revised hold tags have been attached to the identified items. 5. Full compliance has been achieved.
,:.. Q STATE OF FLORIDA ) ) ss. COUNTY OF DADE ) Robert E. Uhrig, being first duly sworn, deposes and says: That he is a Vice President of Florida Power & the Licensee herein; Light Company, That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee. b j,f')yk~f/ ',('f ' /' is ,Et Robert E. Uhrig Subscribed and sworn to before me this
- 6 day of Mm 19 1/
~ 0 0 %,i. ,[. DiLd NOTARY PUBLIC, iW and for the county of Dade, Stat.e of Florida
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.-, e,.f, e,,._,,, n My commission expires: , < * ' >a Etru G,-:oter 30, igg .nro %r.ea em.e n, u... l l
5, : *- 7 ' JUL 2 31981 [7;;; e, g.- (. N pf f,5 i ~ '. I,', s Florida Power and Light Company 3
- n ;- 1 ATTN:
Dr. R. E. Uhrig, Vice President 'IE Ei.E COP.Y)V,..~' e- - ~r - ~' Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Report No. 50-389/81-07 Thank you for your le'tler-of July 8,1981, informing us of steps you have taken to correct the violation concerning activities under NRC Construction Permit No. CPPR-144 brought to your attention in our letter of June 9, 1981. We will examine your corrective actions and plans during subsequent inspections. We appreciate your cooperation with us. Sincerely, 4/ P. J. Kellogg, Acting Chief Reactor Projects Branch 2 Division of Resident and Reactor Project Inspection cc: B. J. Escue, Plant Manager ~ N. Weems, Assistant QA Construction Manager bcc: NRC Resident Inspector Central Files Local Public Document Room Washington Public Document Room Nuclear Safety Information Center Technical Information Center Document Management Branch State of Florida d RI RII RII RII RII RII BCrowley:ht AHe'rdt 'CMuNphy AFGibson Klandis PJK ogg 7/JG'81 7/, /81 7/; /81 741/81 7/1 /81 7/g81 gg/ s For4-99 31s M (_ WADOCKe= w e10,33 LlWL o 05000389 1 Mc
lf.hccU ..e JUL 311981 f'.h M g N f~@i g\\ Florida Power and Light Company /.UG 101981
- C-ATTN:
Dr. R. E. Uhrig, Vice President !{1 .~ u.s. g,, 7, g Advanced Systems and Technology P. O. Box 529100 6x % ' g s[/ Miami, FL 33152 f A Gentlemen: g((l((CQpy
Subject:
Report No. 50-389/81-09 Thank you for your letter of July 15, 1981, informing us of steps you have taken to correct the violation concerning activities under NRC Construction Permit No. CPPR-144 brought to your attention in our letter of June 16, 1981. We will examine your corrective actions and plans during subsequent inspections. We appreciate your cooperation with us. Sincerely, /s/ P. J. Kellogg, Chief Reactor Projects Branch 2 Division of Resident and Reactor Project Inspection cc: B. J. Escue, Plant Manager N. Weems, Assistant QA Construction Manager bcc: NRC Resident Inspector Document Management Branch State of Florida RII RI RII 1/ RII iJ RII RII dM tML \\P TDGibbons:ht TEConlon CEMurphy AFGibson MSb o' PJ 49 7/~J//81 7 /81 7/3l /81 7 T/81 7/ S1 7/ /81 4 IN Fo/A -N-2.13 Stlg &tC0440317 810731 {j $3 PDR ADOCK 05000389 G PDR
[A' pa m%'o. DESIGNATED ORIGINAD UNITJ STATES yc s h s.,[ NUCLEAR REGU.ATORY COMMMd By
- .p y#_e REGION 11 o, y g
101 MARIETTA ST., N.W.. SulTE 3100
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ATLANTA, GEORGI A 30303 j MAY 2 71981 Florida Power and Light Company ATTN: R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Report No. 50-389/81-05 This refers to the routine safety inspection conducted by Mr. B. R. Crowley of this office on April 28 - May 1, 1981, of activities authorized by NRC Construc-tion Permit No. CPPR-144 for the St. Lucie facility. Our preliminary findings ' ere discussed with Mr. B. J. Escue, Site Manager, at the conclusion of the w insoection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors. During the inspection, it was found that certain activities under your license appear to violate NRC requirements. These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A. Elements to be included in your response are' delineated in Appendix A. We have examined actions you have taken with regard to previously identified enforcement matters. These are discussed in the enclosed inspection report. One new unresolved item is identified in the enclosed inspection report. This item will be examined during subsequent inspections. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be exempt from dis-closure under 10 CFR 9.5(a)(4), it is necessary that you: (a) notify this office by telephone within ten days from the date of this letter of your intention to file a request for withhciding; and (b) submit within twenty-five days from the date of this letter a written application to this office to withhold such infor-mation. If your receipt of this letter has been delayed such that less than seven days are available for your review, please notify this office promptly so that a new due date may be established. Consistent with section 2.790(b)(1), such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be withheld, anc a full statement of the reasons on the basis of which it is claimed tha: the information should be withheld from public disclosure. This section further ~ For A-M -19a StG939041a 910918 PDR ADOCK 05000389 h h G PDR
MAY 2'7 !bi Florida Power and Light Company 2 requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The informatiori sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear frem you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. Should you have any questions concerning this letter, we will be' glad to discuss them with you. Sincerely, ~ E.c R. C. ewis, Acting Director Division of Resident and Reactor Project Inspection
Enclosures:
1. Appendix A, Notice of Violation 2. Inspection Report No. 50-389/81-05 cc w/ encl: B. J. Escue, Site Manager N. Weems, Assistant QA Construction Manager 1
APPENDIX A NOTICE OF VIOLATION Fiorida Power and Light Company Docket No. 50-L9 St. Lucie License No. CPPR-144 As a result of the inspection conducted on April 28 - May 1,1981, and in accord-ance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified. A. 10 CFR 50, Appendix B, Criterion XIII, as implemented by Section 13 of FP&L Topical Report (FP&L TQARI-76A), requires measures be established to control storage and preservation of material and equipment to prevent dam' age e deterioration. FP&L procedure SQP 47 requires that open pipe and equipan be capped or covered when no work is in progress. FP&L procedure SQP 23 ai associated form SOP-23.1 for the Waste Gas Compressors requires that the compressor motors be heated. Contrary to. the above, measures were inadequate to control material and equipment preservation in that: 1. On April 29, 1931, a 1" nozzle in the side of Gas Surge Tank 2A and a flanged pipe connection at Waste Gas Compressor 2A were open. 2. On April 29, 1981, the electric motor for Waste Gas Compresso,r 2A was not heated. 3. On April 30, 1981, fifteen examples of scaffolding supported by or rigging from installed safety related piping were noted. In addition, there were no documented procedures to control the above activity as well as temporary construction lifts being supported by installed piping and their associated hangers. This is a Severity Level V Violation (Supolement II.E). B. 10 CFR 50, Appendix B, Criterion IX, as implemented by Section 9 of FP&L Topical Report (FP&L TQARI-76A), requires measures be established to assure that special processes including welding are controlled. ASME Boiler and Pressure Vessel Code, Section IX, with interpretation IX-78-92 establishes requirements for qualification of welders and requires that the upper limit on thickness qualified be two times the weld deposit thickness on test assemblies 3/d" or less in thickness. IX-78-92 limits the welder cualifi-cation thickness range qualifiec to 1-5/3" for combination process welcer qualification tests administered on 13/16" pipe test assem> lies where ne'ither process deposit was 3/d" or greater. Specific requirements for e Nw'rvew4-810918 PDR ADOCK 05000389 0 PDR
Florida Power and Light Company 2 Docket No. 50-389 'St. Lucie License No. CPPR-144 purge gas flow rate, shielding gas flow rate, and electrode extension are contained in CE Welding Procedure Specification (WPS) GTA-8.8Y-300 and FP&L WPSs 43, 43F, 50 and 75. ~ Contrary to the above, measures were inadequate to control welding in tnat: 1. On April 28, 1981, weiding performance qualification records for welders welding on the upper guide structure showed the welders to be qualified for thicknesses between 1/16" and 3/8". The test assemoly thickness was 1/8" which qualifies the welder for thicknesses of 1/16" to 1/4" 2. On April 29, 1981, Welder Qucl;fication Records indicated that welders testing for qualification to WPS's 24, 39 and 50, deposited 1/8" gas tungsten arc weld deposit followed by 11/16" shielded metal arc weld deposit on 13/16" wall thickness pipe test assemblies and were granted an unlimited thickness qualification. 3. On April 28-29, 1981, eight welders welding on reactor vessel inter-nals, safety related piping, reactor coolant pressure boundary piping and control element drive mechanisms exceeded the maximum purge gas flow rate, exceeded the maximum shielding gas flow rate, or deviated from the electrode extension requirements as specified in the appro-priate WPS. This is a Severity Level V Violation (Supplement II.E). Pursuant to the provisions of la CFR 2.201, you are hereby required to submit to this office within twenty-five days of,the date of this Notice, a written state-ment or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if acmittea; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. MkY b71981 Date:
@ l?tQy / 'o UNITED STATES !7 NUCLEAR REGULATORY COMMISSION n {.- REGION ll o' 101 MARIETTA ST., N.W., SUITE 3100 f
- s.p ATLANTA. GEORGIA 30303 c
Report No. 50-389/81-05 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: St. Lucie Occket No. 50-389 License No. CPPR-144 Inspection at St. Lucie Site near Fort Pierce, Florida Inspectors: / I/Y B. R. y / Date Signea WAn LC l9$ 1 /4FP/ Mins rge Ga W Sfg6e'd Approved by: / / A. R. Herdt, Section Chief Da'te S'igned Engineering Inspection Branch Engineering and Technical Inspection Division
SUMMARY
Inspected on April 28 - May 1,1981 Areas Inspected This routine, unannounced inspection involved 55 inspector-hours on site in the areas of licensee action on previous inspection findings, reactor vessel inter-nals, reactor vessel installation, safety related components, reinforcing steel, safety-related piping and reactor coolant pressure boundary piping. Results Of the seven areas inspected, no violations or deviations were identified in three areas; two violations were found in four areas (Violation - Inadequate measures to control preservation of safety-related materials and eouipment - paragraph Nos. 9.a. and 10.a., and Violation - Inadecuate measures to control welding and welder qualification - paragranh Nos. 7.e., 10.b.(1), 10.b.(2), 11.b.(1) and 11.b.(4)(a)). E N C633 810918 PDR ADOCK 05000389 G PDR
REPORT DETAILS 1. Persons Contacted Licensee Employees
- B. J. Escue; Site Manager
- W. M. Hayward, Supervisor QA Engineering
- G. Crowell, Engineering Site Supervisor
- W. F. Jackson, Welding Superintendent "J. L. Parker, Project QC Supervisor
- J. W. Adams, QA Engineer
- E. W. Sherman, QA Engineer
- 0. J. Karch, QA Engineer
- 0. R. Cooper, Supervisor, QA Engineering W. Woodard, QA Engineer - Systems and Audits P. W. Heycock, PSI Coordinator - Power Resources F. T. Carr, Specialist - Power Resources G. Gotch, Staff Specialist - Power Resources Other licensee employees contacted included construction craftsmen, QC inspectors, security force members, and office personnel.
Other Organizations
- K. N. Flanagan, Assistant Site Manager - Ebasco Services, Inc.
"R. W. Zaist, Project Superintendent - Ebasco Services, Inc.
- G. H. Krauss, ESSE Project Engineer - Ebasco Services, Inc.
- R. A. Garramore, Senior Resident Engineer -Ebasco Services,-Inc.
W. A. Shook, Process Control Specialist - Ebasco Services, Inc. P. M. Dancoes, Job Superintendent - Combustion Engineering (Avery Division) M. Carucci, QC Superintendent - Combustion Engineering (Construction Services)
- 8. R. Harbison, Welding Engineer, Combustion Engineering (Construction Services)
NRC Resident Inspectors "S. A. El rod
- H. E. Bibb
- Attended exit interview
2 s 2. Exit Interview The inspection scope and findings were summarized on May 1, 1981 with these persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee. (0 pen) Violation 389/81-05-01: " Inadequate Measures to Control Preservation-of Safety-Related Materials and Equipment" - Paragraph Nos. 9.a and 10.a. (0 pen) Violation 389/81-05-02: " Inadequate Measures to Control Welding and Welder Qualification" - Paragraph Nos. 7.e,10.b.(1),10.b.(2),11.b.(1) and
- 11. b. ( 4)( a ).
(0 pen) Inspector Followup Item 389/81-05-03: " Reference of Incorrect Procedure for Lif ting CSB" - Paragraph 6.a. (0 pen) Unresolved Item 389/81-05-04: " Spacing of Reinforcing Steel" - Paragraph No. 5.b. 3. Licensee Action on Previous Inspection Findings (0 pen) Infraction (389/80-13-01) Improper Storage. This item concerns the licensee's improper storage of six ASME Class 1, 2 and 3 valves. During the week of April 28, 1981, the inspectors examined the valve storage areas which had been improved to comply with regulatory. requirements. The insoection showed several examples which indicated that the improvement program was not yet fully implemented. In that the licensee's commitment was in full compliance by May 1,1981, this item will remain open pending review af ter that date. 4. Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violation or deviation. New unresolved items identified during this inspection are discussed in paragraph 5.b. 5. Independent Inspection Effort a. Construction Activities The inspectors conducted a general inspection of the reactor building, auxiliary building and stainless steel pipe fabrication snop to observe construction progress and construction activities sucn as welding, welding filler material control, material controls, and housekeecing and storage. 1
3 b. Reinforcing Steel With regard to the above general inspection on April 29, 1981, the inspectors accompanied by a representative of the licensee noted several examples of groups of three to five reinforcing bars with the clear distance between bars less than one inch. Each group of bars was in a single layer. The above bars were extending out of the completed concrete containment cylinder wall at penetration 43 and at the equip-ment hatch. The above appears to be in conflict with the requirements of ACI-318-1971, paragraphs 7.4.1 and 7.4.5. This will be examined in a subsecuent inspection and will be identified as unresolved item 389/81-05-04: " Spacing of Reinforcing Steel". Within the areas inspected, no violations or deviations were noted. 6. Reactor Vessel Internals The inspectors reviewed procedures, reviewed records, and observed work activities as described below relative to the reactor vessel internals to determine whether regulatory requirements are being met. The reactor vessel internals consisting of the upper guide structure (UGS) assembly, the core support barrel (CSB) assembly, the core shroud and lower support (CS-CS). assembly and miscellaneous equipment are being installed by Combustion Engineering (CE) using FP&L procedures as listed below. a. Review of Quality Assurance Implementing Procedures The inspectors reviewed the following procedures and specifications: (1) CE Specification CEND-353, Revision 6, " Field Handling, Mainten-ance, and Storage Requirements for Combustion Engineering Furn-ished Equipment" (2) QI 7.1, Revision 3, " Instructions for Receiving Inspection of Seismic or Safety-Related Material" (3) SQP-75, Revision 0, " Permanent Plant Equipment Installation CSS-CS Lifting Procedures" (4) SQP-76, Revision 0, " Reactor Vessel Intervals Installation and Alignment, CSCS-CSB to RV" (5) SQP-77, Revision 0, "UGS Lift Rig Assembly and Lif ting Procedure" (6) SOP-73. Revision 0, " Permanent Plant Eouipment Installation CSB/Li f ti ng" (7) SQP-72, Revision 0, " Reactor Vessel Internals Installation Into the Reactor Vessel" l
4 (8) SQP-68, Revision 1, " Reactor Vessel Internals Installation of RV Keyway" (9) SQP-69, Revision 0, " Reactor Vessel Internals Installation 'of Core Support Barrel" (10) SQP-70, Revision 0, " Reactor Vessel Internals Installation CSB Ke/way" (11) SQP-71, Revision 0, " Reactor Vessel Internals Installation of Dummy Alignment Key" (12) SQP-74, Revision 0, " Reactor Vessel Internals Installation Align-ment During Welding CSS to CSB" (13) SQP-76, Revision 0, " Reactor Vessel Internals Installation and Alignment.CSCS-CSB to RV" (14) SQP-28, Revision 0, " Operation and Maintenance of Lif ting and Handling Equipment" (15) SQP-3, Revision 2, " Material Control" (16) SQP-23, Revision 0, " Preventative Maintenance" (17) SQP-29, Revision 2, "NSSS Access and Cleanliness" (18) CDP 5-19, Revision 2, "Loadout, Transport and Placement Upper Guide Structure Inside Containment" (19) C0P 5-20, Revision 2, "Loadout, Transport and Placement of the Core Shroud / Support Structure Inside the Containment" _(20) CDP 5-23, Revision 0, "Loadout, Transport and Placement of the Core Support Barrel Inside Containment" The above procedures were reviewed in the areas of receipt inspection, storage, handling, crane testing and lifting of internals, installation of internals, inspection of internals installation, and post-installa-tion activities. During review of the above procedures, the inspectors noted that paragraph 5.2.4 of SQP-72 referred to SQP-32 for lifting the CSB. l Paragraph 2.1.2 of SQP-32 specifically eliminates application to reactor vessel internals. Discussion with the licensee revealed that the reference for lifting should have been SQP-73. The procedure will - be revised to refer to the correct procedure for lif ting tne CSS. This matter will be icentified as inspector folicwup item numoer 389/31-05-03, " Reference of Incorrect Precedure For Lif ting CSB". 2
5 b. Observation of Work and Work Activities The inspector observed the UGS, CSB and CS-CS in temporary storage location inside the containment. Protective coverings and storage supports were observed. A modification was being performed to add CEA shroud flow channel extensions to the UGS. This modification was being performed by CE in accordance with Field Action Request FAR-13172-108A. The inspectors examined this work to determine whether installation specifications and work procedures were being followed and QC activi-ties were being performed in accordance with established procedures. (See paragraph 7. below for examination of welding associated with tne modification.) c. Review of Quality Records The inspectors reviewed the receipt inspection records and the 1980 and 1981 storage and protection records for the reactor vessel internals. The receipt inspection records consisted of FP&L receipt inscection report and the CE " Certificate of Equipment". The storage and protec-tion records consisted of Form SQP-23.1 for MRR 13804 covering the major components and MRR 14443 covering the miscellaneous equipment. The records were reviewed to determine whether: (1) Storage inspections were made at the required frequency (2) Protection requirements were maintained (3) Rec 5ipt inspection requirements were met (4) Adequate protection was maintained during temporary storage. Within the areas inspected, no violations or deviations were identified. 7. Reactor Vessel Internals (Welding) - Observation of Welding and Associated Activities The inspectors observed welding activities for reactor vessel internals as described below to determine whether applicable code and procedure require-ments were being met. The applicable code for the welding observed is the ASME Boiler and Pressure Vessel Code, Section III, Subsections NA and NG, 1974 Edition. The following was examined relative to welding associated with modification to the flow channels on the UGS. a. Welding Identification The welding records for the following welds were reviewed and comoared to tne icentification on the component to insure that weld icentifi-cation records had been established to permit clear retrieval of accurate weld date:
r 6 Weld 82 Weld 72 Weld 63 Weld 15 Weld 68 Weld 56 b. Weld Preparation Welds 73 and 21 were observed during fitup. Condition of the surface to be welded, protection of weld area from environmental conditions and other construction activities and alignment were examined. c. Welding Material Control of welding materials was examined in the areas of: (1) Storage conditions (2) Issue practices (3) Occumentation controls for dispensing (4) Evidence of uncontrolled material at the work area or storage area d. Observation of Welding Weld No. 52 was observed during in process welding. The welding activity was examined in the following areas: (1) Weld identification / location (2) Use of specified welding material (3) Welder qualification (4) Use of applicable welding procedure (5) Fitting and alignment methods (6) Tack welds (7) Shielding and purging gas '(8) Essential variables of the procedure qualification are being followed in production (9) Welding technique (10) Weld surface condition (11) Observance of inspection points (12) Interpass temperature (13) Return of unused welding material (14) Weld repair (15) Weld inspection e. On April 28, 1981, during examination of above welcing activities, the inspectors found the following proolems; i i
P 7 (1) For three sets of welding equipment being used, the purge gas flow rate and shielding gas flow rate being used were outside procedure limits as follows: Procedure GTA-8.8Y-300 Actual Recuirements Being Used Purge Flow (CFH) 5-10 18-22 Shielding Flow (CFH) 10-20 22-27 (2) The welder performance qualification records show the welders to be qualified to weld on thicknesses from 1/16" to 3/8". Based on the thickness of the qualification test assembly, i.e., 1/8", Section IX of ASME specifies an upper thickness limit of 2t or 1/4". The performance qualification records were corrected during the inspection. The above problems indicate inadequate measures for the control of special processes and are examples of violation 389/81-05-02 discussed further in paragraph 11.b.(4)(a). Within the areas inspected, no violations except as noted in paragraph 7.e. or deviations were identified. 8. Reactor Vessel Installation The inspectors reviewed records and observed work activities as described below relative to the reactor vessel to determine whether regulatory requirements were being met. CE specification CEND-353, FP&L Procedure SQP-23, FP&L Procedure SQP-3, and FP&L procedure SQP-29 (see paragraph 6. above for titles) govern the records and work activities examined. a. Observation of Work and Work Activities The inspectors observed the installed vessel for prot 0ction to deter-mine whether: (1) procedures for protection were being followed (2) protective devices were installed around the top of the vessel (3) vessel side openings were blanked off (a) work platforms and scaffolding inside vessel were nonflammable (5) access control met requirements /
9 b. Review of Quality Records The inspectors reviewed the 1981 Equipment Storage / Maintenance record consisting of Form SQP-23.1 for those components noted in paragraph a. above. In addition, the " Shaft Rotation Checklist for Motors and Pumps" for the first quarter of 1981 for the waste gas ccmpressor were reviewed. The records were reviewed to insure that inspection require-ments for cleanliness, preservation, and protection were being met. Within the areas inspected, no violations except as noted in paragraph 9.a or deviations were identified. 10. Safety-Related Piping The inspectors observed non welding and welding work activities for safety-related piping as described below to determine whether applicable code and procedure requirements were being met. The applicable code for safety-related piping is the ASME B&PV Code, Section III, Subsections NC and ND, 1977 Edition with addenda through summer 1977, a. Observation of Non-Welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following; inspection and/or work procedures, recordkeeping, installation specifications or plans, specified materials, sp?cified NDE, calibration and use of proper test equipment and qualified inspection and NDE personnel. Activity System or Comconent Procedure Protection Piping, Various SQP 3-R2 SCP 47-R3 Handling Piping, Various SQP 3-R2 SQP 6-R1 SQP 28-R0 SQP 47-R3 With regard to the above inspection in the area of protection, the inspectors accompanied by a representative of the licensee on April 30, 1981, noted approximately 15 examples of scaffolding supported by, or rigging from installed safety-related piping. The licensee stated that they had no documented procedures controlling the above practices. Therefore, the licensee had not established adequate measures to protect stored equioment and materials. 7he acove combined with the examples discussed in paragraoh 9.a. indicates that the licensee has not established adequate measures to control storage and oreservation of equioment and materials. Failure i
F 10 to establish adequate measures to control storage and preservation of materials and equipment in accordance with work and inspection instruc-tions to prevent damage is in violation of 10 CFR 50, Appendix 8, Criterion XIII. This violation will be identified as 389/81-05-01: " Inadequate Measures to Control Preservation of Safety-Related Materials and Equipment". b. The inspectors observed in process welding activities of safety-related piping field welds as described below to determine whether applicable code and procedure requirements were being met. (1) Welding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure; WPS assignment; welding technique and sequence; materials identity; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interoass temperature; interpass cleaning; process control systems; identity of welders; qualification of inspection personnel; and weld history records. Joint Number Size System CS-0024-903 6" x 0.280" Containment Spray CS-0024-902 6" x 0.280" Containment Spray SI-0457-002 12" x 0.406" Safety Injection CS-0032-002 4" x 0.237" Containment Spray With regard to the above inspection, the inspectors accompanied by a representative of the licensee,. on April 29, 1981, noted the following examples of welders failing to follow welding procedure back purge gas flow rate requirements. Required Adtual Weld Number WPS No. Back Purce Back Purce CS-0024-902 43-R3 4-10 CFH 31 CFH CS-0024-903 43-R3 4-10 CFH 31 CFH CS-0032-002 43-R3 4-10 CFH 40 CFH The above condition indicates inadequate measures for the control of special processes and is an example of violation 389/81-05-02 as discussed further in paragraph 11.b.(4)(a). 2
r l-11 (2) Welder Qualifications The inspectors reviewed the FP&L program for qualification of welders and welding operators for compliance with QA procacures and ASME Code requirements. The following welder qualification status records and " Records of Performance Qualification Test" were reviewed relative to the weld joints listed in paragraph 10.b.(1),11.b.(1) and 11.b.(4)(a). Welder Symbol Acolication PYP Safety-Related Piping PWP Safety-Related Piping PYI Reactor Coolant Pressure Boundary Piping PVP Reactor Coolant Pressurg Boundary Piping BAF Control Element 01rve Mechanism With regard to the above inspection, the inspectors, on April 29, 1981, noted that several welders took combination process welder qualification tests in accordance with Welding Procedure Specifi-cation Nos. 24, 39 and 50, on an 0.812" x 6" diameter grooved pipe test assembly. The tests consisted of 1/8-inch thick gas tungsten arc weld (GTAW) metal deposit followed by an 11/16-inch thick shielded metal arc weld (SMAW) metal deposit. The Welder Qualifi-cation Records for the above qualification test states the welders are qualified for welding pipe butt joints from 3/16-inch to unlimited wall thickness. The preceding is contrary to ASME Interpretation IX-78-92 dated September 25, 1978 in that the above test conditions would only qualify the tested welder for a maximum thickness of 1-5/8-inch. Therefore the licensee has been granting welders unlimited thick-ness qualifications when the welders are actually only qualified to 1-5/8-inch thickness maximum. The above condition indicates inadequate measures for the control of special processes and is an example of violation 389/81-05-02 as discussed further in paragraph 11.b.(4)(a). (3) Welding Filler Material Control The inspector reviewed the FP&L program for control of welding materials to determine whether materials are being purchased, accepted, stored and handled in accordance with QA procecures and applicable code requirements. The following specific areas were examined:
} a-12 l Purchasing procedures, receiving, storing, distributing and handling procedures, material identification, inspection of welding material issuing stations Welding material purchasing and receiving records for the following materials were reviewed for conformance with ' applicable procedures and code requirements: Material ID Tyoe Size Code ER-308L 1/8" 0181 ER-308 3/32" 0137 ER-NiCrFe-5 .045" 0187 ER-NiCrFe-5 3/32" 0191 E-308-16 3/32" 0031 E-308-16 1/8" 0027 (4) Welding Procedure Specifications The following welding procedure specifications (WPS) were selected for review: WPS Process 43-R3 GTAW (Manual) 43F-R3 GTAW (Manual) 50-R4 GTAW/SMAW (Manual) 75-R0 GTAW ( Automatic / Manual) Gas Tungsten Arc Welding (GTAW) Shielded Metal Arc Welding (GMAW) The above WPSs and their supporting Procedure Qualification Records (PQR) were reviewed to ascertain whether essential, supplementary and/or nonessential variables including thermal treatment were consistent with code requirements; whether the WPS were properly qualified and their supporting PQRs were accurate and retrievable; whether all required mechanical tests had been performed and the results met the minimum requirements; whether the PQRs had been reviewed and certified by appropriate personnel and, whether any revisions and/or changes to nonessential vari-ables were noted. Within the ar?as examined, no violations or deviations were identified axcoot as described in paragraph Nos. 10. a.10.b. ( 1) anc 10.b. ( 2). /
( I 13 i l 11. Reactor Coolant Pressure Boundary Piping The. inspector observed non welding and welding work activities for reactor coolant pressure boundary (RCPB) piping. The applicable code for the installation of RCPB piping is the ASME B&PV Code, Section III, Subsection NB,1977 Edition through the summer 1977 addenda, a. Observation of Non-Welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following: inspection and/or work procedures, recordkeeping requirements, installation specification requirements, specified material and qualified inspection personnel. Saf ety Injection System and Reactor Coolant System Activity Identification Procedure Protection Piping Various SQP 3-R2 SQP 47-R3 Handling Piping Various SQP 3-R2 SQP 6-R1 i-SQP 28-R0 l SQP 47-R3 i b. Observation of Welding Activities The inspector observed in process welding activities of RCPB piping field welds as described below to determine whether applicable code and procedure requirements were being met. (1) Welding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification ar.d location; welding procedure; WPS assignment; welding technique and sequence; materials identity; weld geometry; fit up; temporary l attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment conditions; interpass tempera-ture; interpass cleaning; process control systems; identity of welders; qualifications of inspection personnel; and weld history i records. Joint Number Size System RC-0228-007 3/4" x 0.219" Reactor Coolant RC-0154-001 12" x 1.312" Reactor Coolant RC-0154-002 12" x 1.312" Reactor Coolant /
14 With regard to the above inspection, the inspectors accompanied by a representative of the licensee, on April 19, 1981, noted the following examples of welders failing to follow welding procedure snielding gas and back purge gas flow rate requirements. Required Actual Weld WPS Shielding Back Shielding Back Number Number Gas Purce Gas Purce RC-022S-C07 43F-R3 15-25 CFH 30 CFH RC-0154-061 50-R4 4-10 CFH 45 CFH RC-0154-002 50-R4 4-10 CFH 45 CFH The above condition indicates inadequate measures for the control of special processes and is an example of violation 389/81-05-02 as discussed in paragraph 11.b.(4)(a). (2) Welder Qualification Welder qualification is discussed in paragraph 10.b.(2). (3) Welding Material Control Welding material control is discussed in paragraph 10.b.(3). (4) Special Welding Activities The inspectors examined special welding activities as describec below to determine whether applicable code and procedural require-ments were being met. (a) Seal Welding The below listed weld was examined in process to determine: whether work was conducted in accordance with travelers; welder identification and location; welding procedure; WPS assignment; welding technique and sequence; materials identity; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature; interpass cleaning; process control systems; identity of welders; anc weld history records. Weld No. System CDM-0069-001 Control Element Drive Mechanism
J.- 15 With regard to the above inspection, the inspectors accom-panied by a representative of the licensee, on April 29, 1981, noted the following examples of welders failing to follow welding procedure parameters: 1 Back purge was 16 CFH. WPS-75 R0 requires back purge to be 3 to 5 CFH. 2 The tungsten electrode extention beyond the gas cup was 1/4-inch. WPS-75 R0 requires electrode extention to be 5/S-inch. The above combined with the example as discussed in paragraphs 7.e,10.b(1),10.b(2) and 11.b.(1) indicate that the licensee does not have adequate measures for the control of special processes. Failure to establish adequate measures to control special pro-cesses including welding is in violation of 10 CFR 50, Appendix B, Criterion IX. This violation will be identified as 389/81-05-02: "Inadeauate Measures to Control Welding and Welder Qualification". (5) Welding Procedure Specifications Welding procedure specifications are discussed in paragraph 10.b.(4). Within the areas examined, no violations or deviations were identified except as described in paragraph Nos.11.b.(1) and 11.b.(4)(a). a
gS d' # 8c9 9 UNITED STATES fo, NUCLEAR REGULATORY COMMISSION I REGION 11 3 j ',,., [ j M ' j g 101 MARIETTA ST., N.W.. SUITE 3100 f ATLANTA, GEORGIA 30303 s.~. ) px i 2 '9... 23HQ Frzacorr~ Florida Power and Light Company ATTN: Dr. R. E. Uhrig, Vice President Advanced ystems and Technology P. O. Box 14000 Juno Beach, FL 33208 Gentlemen:
Subject:
Report No. 50-389/82-71 This refers to the routine safety inspection conducted by Mr. W. P. Ang of this office on December 6 to 9, 1982, of activities authorized by NRC Construction Permit No. CPPR-144 for the St. Lucie Unit 2 facility. Our preliminary findings were discussed with Mr. B. J. Escue, Site Manager, at the conclusion of the inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. During the inspection, it was found that certain activities under your license appear to violate NRC requirements. This item, and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A. Elements to be included in your response are delineated in Appendix A. The violation described in Appendix A is similar to the violation (Item B) contained in the Notice of Violation sent to ynu with our letter dated April 15, 1981 and the violation (Item B) contained in the Notice of Violation sent to you with our letter dated August 3, 1982. "Similar Violations", as described in the NRC Enforcement Policy, are subject to escalated enforcement action. Accordingly, in your response to the enclosed Notice, olease give particular attention to the identification and remedy of the root cause of the violation so that its further occurrence may be precluded. We have examined actions you have taken with regard to previously reported unresolved items. The status of these items is discussed in the enclosed report. One new unresolved item is identified in the enclosed inspection report. This item will be examined during subsequent inspections. Fo I A-N-23 5 L %A4 pt-t-041E-830318 PDR ADOCK 05000389 PDR
'c
- S Florida Power and Light Company 2
Docket No. 50-389 St. Lucie 2 License No. CPPR-144 In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC's Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written appli-cation to withhold information contained therein within thirty days of the date of this letter. Sucn application must be consistent with the requirements of 2.790(b)(1). The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Should you have any questions concerning this letter, we will be glad to discuss them with you. Sincerely, M R. C. Lewis, Director Division of Project and Resident Programs
Enclosures:
1. Appendix A, Notice of Violation 2. Inspection Report No. 50-389/82-71 i cc w/gncl: B. J. Escue, Plant Manager N. Weems, Assistant QA Construction Manager bec w/ encl: Document Management Branch State of Florida NRC Resident Inspector RII RII RII RI.I QE g ho hQ AdA01(stiinski k/ NO ng:es Blake ARHerdt KDLafRI s O RClewis Ullvwd 12/,/82 12/#4/82 D/ 12 /82 il6ltt 12/3=/82 12/p/82 12/,/82 3 3 / }(({}
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IE HQ FITA 00rT APPENDIX A NOTICE OF VIOLATION Florida Power and Light Company Docket No. 50-389 St. Lucie 2 License No. CPPR-144 As a result of the inspection conducted on December 7, 1982, and in accordance with the f!RC Enforcement Policy, 47 FR 9987 (March 9,1982), the following viola-tions were identified. 10 CFR 50, Appendix B Criterion V as implemented by Section TQR5.0 of FP&L Topical Report FPL TQAR-1-76A, requires that activities affecting quality be prescribed by documented instructions, procedures and drawings and be accomplished in accordarce with those instructions, procedures and drawings. Contrary to the above, on December 7,1982, the following examples of failure to comply with instructions procedures and drawings were identified. 1. QC inspected and accepted pipe support SI-2407-60A included a mechan-ical snubber, piece 2. Bergen Patterson drawing, SI-2407-60A rev.6 requires the snubber to be installed perpendicular to the pipe. Contrary to the above, the snubber was found to be installed at approximately a 78 angii from the pipe. 2. QC inspected and accepted pipe support SI-2407-67 included a rigid strut, piece 1. Bergen Patterson drawing 51-2407-67 rev. 9 requires piece 1 to be attached to a pipe clamp 19" below the centerline of the pipe. Contrary to the above, piece 1 was found to be attached to the pipe j clamp approximately 22" below the pipe centerline. 3. Cergen Patterson drawing SI-2407-84 rev. 7 requires the bottom hori-zontal member, piece 3. of pipe support SI-2407 to be welded to an l I embedded plate with a 5/16" fillet weld all around piece 3. Contrary to the above, support SI-2407, which had been QC inspected and l accepted, was not welded to the embedded plate on a six inch length across the bottom of piece 3. This is a Severity Level IV Violation (Supplement II). kb DR
'1: Florida Power and Light Company 2 Docket No. 50-389 St. Lucie 2 License No. CPPR-144 Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of ~the date of this flotice, a written statement or explanation in reply, including: (1) admission or denial of the elleged viola-tions; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will -be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Date: 3AN 131983
o .s m it% UNITED STATES a d
- o, NUCLEAR REGULATORY COMMISSION 8"
- 'o REGION !!
g 101 MARIETTA ST., N.W., SUITE 3100 k.....,/ ATLANTA. GEORGIA 30303 ~ TEHQ FITE 00Fr Report No. 50-389/82-71 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name: St. Lucie 2 Docket No. 50-389 License No. CPPR-144 Inspection at St. Lucie te near Ft. Pierce, Florida Inspect r: / ,2*M r W. A Date Signed /4 4/Ie-Appro ed by: J. pi pf6ke, Section Chief Date Signea - Enafin(ering Program Branch Division of Engineering and Operational Programs
SUMMARY
Inspection on December 6-9, 1982 Areas Inspected I This routine, announced inspection involved 22 inspector-hours on site in the areas of pipe support baseplate designs using concrete expansion anchors (IEB 79-02); and seismic analysis for as-built safety-related piping systems (IEB 79-14). l Results Of the two areas inspected, no violations or deviations were identified in one area; and one apparent violation was found in one area. SSO4tte499-830318 PDR ADOCK 05000389 G PDR
I. o f. REPORT DETAILS 1. Persons Contacted Licensee Employees
- B. J. Escue, Site Manager J. L. Parker, Project Quality Control Supervisor
- C. Carlo, Jr., Area Mechanical QC Supervisor
- E. Preast, Senior Resident Engineer
- P. P. Carier, Licensing Engineer
- R. A. Symes, Supervising QA Engineer EBASCO Services Incorporated (EBASCO)
- G. H. Krauss, Project Engineer
- P. Grossman, Assistant Project Engineer
- P. N. Sheit, Supervising Engineer
- G. E. Grace, Licensing Engineer B. Zenon, Design Superviscr Combustion Engineering (CE)
R. L. Wade, Startup NRC Resident Inspector
- S. Elrod e
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on December 9,1982, with those persons indicated in paragraph 1 above. The licensee was informed of the inspection findings listed below. The licensee acknowledged the inspection findings with no dissenting comment. (Closed) Inspector Follow-up Item 82-11 Stress Analyst Input, paragra'pn 6 (0 pen) Violation 389/82-71 Pipe Support Discrepancies, paragraph 6 (0 pen) Unresolved Item 389/82-71 Seismic Analysis Overlap Modelling Technique, paragraph 6
2 3. Licensee Action on Previous Enforcement Matters Not inspected. 4 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 6. 5. Pipe Support Baseplate Designs Using Concrete Expansion Anchors (IEB 79-02) A follow-on inspection to the inspection documented on RII Report 50-389/81-16 was performed to verify licensee compliance with IE Bulletin 79-02 requirements and licensee commitments. The licensee's bulletin responses dated July 2, 1979 and January 14, 1980 were reviewed and discussed with the on-site licensing department representative. Since the licensee's responses were provided relatively early during the program, and since they mainly reflected the licensee's intended program to comply with the bulletin, a final response was requested to document the program was actually implemented and its results. A review of the licensee's QC concrete expansion anchor authorization log indicated that the licensee minimized expansion anchor installations te approximately 2000 expansion ariuhors in safety related pipe supports. It was noted, however that installation of concrete expansion anchors were still being authorized for remaining work. Pending receipt of the licensee's final response to IEB 79-02 ar.d completion of concrete expansion anchor installation and inspection, IEB 79-02 was left open. No violations or deviations were identified. 6. Seismic Analysis for As-Built Safety-Related Piping Systems (IEB 79-14) A follow-on inspection to those documented on RII report numbers 50-389/82-11, -28, and -41 was performed to verify licensee compliance with IEB 79-14 requirements and licensee commitments. The licensee's architect / engineer's (EBASCO) stress analysis design verification of safety-related seismic category 1 piping systems procedure was reviewed. The procedure addressed the concerns noted by Inspector Follow-up Item 389/82-11-01 regarding stress analysis input to the walkdown program, valve weight and center of gravity verification, cualification and/or training of walkdown personnel, and verification of piping penetration details.. The inspector had no further questions regarding IFI 82-11-01 and the IFI was closed. L
'. s O 3 The piping system walkdown records for the following drawings were reviewed: CE DWG E71472-761-004 Rev. 4 - RCS piping CE DWG E71472-761-005 Rev. 6 - RCS piping CE DWG E71472-761-006 Rev. 6 - RCS piping EBASCO DWG CS-K-3 Rev. 15 - Containment Spray piping EBASCO DWG SI-N-2 Rev. 14 - Safety Injection piping The QC inspection records for the following safety injection system pipe supports were reviewed. SI-2407 rigid strut type SI-2407-60A - mechanical snubber type SI-2407 box beam type SI-2407 rigid strut type SI-2407-671 - box beam type SI-2407 box beam type Piping detailed on EBASCO drawings CS-K-3 rev. 15 and SI-N-2' rey. 14 were sampled and inspected to verify accuracy of walkdown inspections. Pipe supports / restraints noted above were sampled and inspected. In addition pipe supports / restraints SI-2407-12, 51-2407-13 and SI-2407-3000 were also inspected. The following items were noted: (a) QC inspected and accepted pipe support SI-2407-60A included a mechanical snubber, piece 2. Bergen Patterson drawing SI-2407-60A rev. 6 requires the snubber to be installed perpendicular to the pipe. The snubber was found to be installed at approximately a 78 angle from the pipe. (b) QC inspected and accepted pipe support SI-2407-67 included a rigid strut, piece 1. Bergen Patterson drawing SI-2407-67 rev. 9 requires piece 1 to be attached to a pipe clamp 19" below the centerline of the pipe. Piece 1 attached to the pipe clamp approximately 22" below the pipe centerline. (c) QC inspected and accepted pipe support SI-2407-84 was a box beam made up with 6" X 6" square tubing welded to an embedded plate. Bergen Patterson drawing SI-2407-84 rev. 7 required the supports bottom horizontal 6" X 6" square tubing, pc. 3, to be attached to the embedded plate by a 5/16" fillet weld all around the 6" X 6" square tube. The E
'3 ,..d p t 8 i Lot.i.cr.i hcrizontal member, piece 2, vitt velced to the embedded plate only on 3 sides; e 6" 1rr.gth of weld between the bottom et piecc 2 cod the embeddec plate hao not been perfurned. The three items notec cbcve appear to be in violaticr cf 10 CFR 50 Appendix "B" Criterion V and were identified as violation 50-389/82-71-01 " Pipe Support Discrepancies". I The piping seismic stress analysis for stress prrblem SI-2407 was available er sitt and was inspected for incorporation of es-built walkdown inspection findings. During this inspection ttc fellcwing items were noted. (1) Stress prcblem SI 2407 analyzes p1pir.c frrrr the Refueling Water Tank (RWT) te ere trtin of ECCS pumps and to the pipir.gs contain-ment penetration. The anchor points are the RWT, the ECCS pumps, arc' the cuntainment penetration. The piping is routed from the tenk (outside the auxiliary building) to the ECCS pumps in the auxiliary building and tc the centainment building. The ert.!rsis was perferred in twc separate runs. One run utiliieo the applic-able seisraic response spectra for the tank ard for the cuxiliary' building. The other run utili7ed the applicable seismic response spectra for the auxiliary building r.rd the containment building. / l'o analysis was perfomed using all the applicable seismic response spectre, 4.c., the tanks, the auxiliary building's and the containrient builcing's seismic response spectra. In addition, stress problem 51-2412 ties into stress problera S!-2407 at a tee H coming off the RWT. The effects at stress problem S1-2412 on stress problem SI-2407 did ret appear to have been provided. The licensec'r A/E indicated that this condition had been previously revieweo ana rescived with NRC's licensive effir.r., PER. Pending further inspectinr., discussion and confirmation of these items with liRR, these items were identified ce. Unresolved item 389/82-71 Seismic Analysic Overit:r Pedelling Technique. The licensee's A/E fertis e stated that this modelling technic.ue was used in twc cther stress prcblems, 115-4102 enc FF 40C4 Pr.nding licensee completion of IEE 75-14 requirements and licensee cerrritments, and pending submittai of a final report, the bulle'.in was left open. l
i 5 January 14, 198;2' had L-83-16 Mr. James P. O'.Reillv EEQ71TE 00FT _egional Adr.:..nistrator, Region I.A nU.S. Nuclear Regulatorv Cc=ission 101 Marietta Street, ST:ite 3100 Atlanta, Georgia 30303 RE: RII: St. Lucie Unit =2 Docket No.1 50- 389 /E2-57
Dear Mr. O' Reilly:
Flcrida Power and Light Company has reviewed the subject inspection repcrt which identified the following violations: "railure to control drawings", and " failure te ccrrect a condition adverse to cuality prometly " Please find attached our response to this violation. Very truly yours, r' a l ~2-~ ~) \\>mp u ~' q. i Robert E. Uhrig Vice. President Advanced Systems and Technology @!A -ill-E15 I sao4tto4ts-830405 Lj ggg PDR ADOCK 05000335 PDR n m
t VICLATICM A: FAILURE TO CONTROL DRAWINGS 10 CFR 50, Appendix 3 Criterien V and the accepted QA Program (FPLTOAR l-76A, Revision 5) require that activities affectinc quality shall be prescribed by documented procedures and shall be acecmplished in accordance with these precedures. QP 6.1, Centrol of Construction Pro]ect Centractor Drawings, Specifications and Procedures, Revision 1, paragraph 4.2, requires using the latest correct revision of documents for construction and installation at each prcject site. Additionally, paragraph 5.2.2.4 of CP 6.1 states that each recipient of a centrolled document is responsible for ensuring that the latest revision is being used. Contrary te the above, the latest correct revisiens were not being used in that drawings 2998-G-46, 2998-G-3733, 2998-G-47, and 2998-G-48 in Unit 2 Centrol Room were the wrong revision. This was identified durinc an inspection of twelve control rocm drawings on November 17, 1982. These examples of incorrect drawings are not intended to be all inclusive but represent 33% of the sample size selected for inspection. This is a Severity Level IV Violation (Supplement I). n_r_e:C".. c e.- 1. FP&L agrees with t.5e finding. 2. The violation was due to failure of nuclear energy department personnel in the control room to establish a workinc procedure for contrelling documents assigned to them. 2. The Construction Department has assigned Document Centrol personnel in the Centrcl Room te assist the Nuclear Energy Department in performing their responsibilities. Document Control has replaced all controlled documents assigned to N.E.D. in the control room with current revisions. 4 Decument Centrol now updates the drawing files and audits centrolled drawings in the Contrcl Rocm. We will continue to provide this service until the Control Room is turned ever to the Plant Manacer. 5. Full compliance has been achieved.
W g 9 e g' VIILATICN 5: FAILURE TO CORRECT A CONDITICN ACVERSE TO CUALI"'Y PRCMPTLY 10 CFP 50, Appendix 5 Criterion XVI and the accepted QA Program (FPLTQAR l-76A, Pevisicn 5) require that measures be established tc assure that conditions adverse te quality are promptly identified and corrected. Contrary to the above, although measures have been established to assure conditions adverse to quality are promptly identified, one condition adverse to quality was not promptly corrected. Audit OAC-PSL-82-02 conducted January 21 - Februa ry 11, 1982, and issued February 17, 1982, identified as a finding, "precedure CPL:QI 6.2 is not adequate as regards to description cf a system to adequately centrol the distribution of Temporary Changes to cuality Instructions." As of this inspecticn (November 15-19, 1982) this item had not been resolved. This is a Severity Level V Violation (Supplement I). RESPCNSE: 1. FP&L does not agree with the finding. 2. This audit item did require an incrdinate length of time frc= initial identification until closure; however, FPsL does not consider this a true viciation of the intent of 10CFR50, Appendix 3, Criterion XVI (as pertaining te promptness), since it is, indeed, an exceptional case which required numercus meetings. involving upper level management at the construction site and at the FPL Juno Beach and Miami offices to arrive at a satis factory sclution. Emphasis must be placed on the werd satisfactory. Many solutiens were offered which took time to evaluate, but cnly one combination cf sclutions was acceptable to satisf actorily resolve the prcblem. This was the major reason why this problem was held open for se icng--the striving fcr a satis f actory solution. The intent of 10CFR50, Appendix B, Criterien XVI, as pertains to "prcept," is not to be,prcmpt to the extent of settling for partially satisfactory solutions to conditions adverse tc quality. Ouring the nine months that this problem was open, centinuous pressure was being applied to obtain a satisfactory solutien, and, until final resolution, centinuous surveillance was established to assure that ne further instances cccurred of a similar nature which might adversely affect quality program commitments. In view of this discussion, FP&L believes this to be an excepticnal case, and, therefore, does not violate the intent with respect to being " prompt," as ncted in 10CFR50, Appendix 3, Criterion XVI. Final corrective measures involved were as follows: Six (6) Quality Instruc-tiens were changed, cne (1) Quality Instruction was cancelled, and one (1) Quality Instruction usage was confined to Turkey Point. In addition, any new issues of the Quality Instruction Index will show all cutstanding Temporary Changes as applicable te each revision level Quality Instructicn. The audit finding of construction Cuality Assurance Audit CAC-PSL-82-02 was closed on January 4, 1952.
.f V u. JAN 181C83 Florida Power and Light Company ATTN: Dr. R. E. Uhrig, Vice Pyesident Advanced Systems and Technology P. O. Box 14000 Juno Beach, FL 33408 Gentlemen:
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE The Nuclear Regulatory Commission has completed its periodic evaluation of the performance of your reactor facilities. As you are aware, this evaluation program, the Systematic Assessment of Licensee Performance (SALP), involves an NRC staff assessment of the performance of each facility; the issuance of the staff's findings in the form of a final report, the SALP Board Report (Enclosure); a meeting with your senior staff to present and discuss the Board's assessment; your response to the assessment, if applicable; and the approval and public distribution of the report by the Regional Administrator. In accordance with NR'C policy, I have reviewed the SALP Board Report and, as Regional Administrator, approve its issuance. It is my view that Florida Power and Light Company's conduct of nuclear activities shows a proper concern for nuclear safety, and that your company's resources are being properly applied. The overall performance of your Turkey Point -facility indicates that your effective commitment of adequate resources has resulted in a fully satisfactory level of operational safety. In addition, your performance in the areas of radiological controls and refueling was commended by the SALP Board. Regarding your performance in the functional area of licensing activities, a change to the functional area rating established by the SALP Board is deemed to be appropriate. Additional information on your performance in this area, which was not originally provided to the SALP Board for their consideration, indicates that in the licensing area. your overall technical competence was good and that sound technical bases and conservatism were provided to support your company's positions. These attributes were certainly demonstrated in responding to the steam generator leaks and the pressurized thermal shock issues. Based upon this more detailed information, I hereby amend the SALP Board Report functional area rating for licensing activities for the Turkey Point facility from " Category 3" to " Category 2". In regard to the St. Lucie Unit 1 facility, your management involvement is aggressively oriented toward nuclear safety. No major weaknesses have been ] identified during the assessment period. The SALP Board recognized, and I agree, a high level of performance in the functional areas of plant operations, radiological controls, surveillance, and refueling. ) B3030T0660 830118 ~~ ~ ~ PDR ADOCK 05000250 i l Fo & S 0 293 TEol 'N'
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Florida Power and Light Company 2 JAN 181983 The overall performance of your St. Lucie 2 facility indicates that the proper amount of management attention is being devoted to the construction of this facility and that a high level of performance with respect to preoperational testing is being achieved. Strong performance was noted by the SALP Board in the construction functional areas of: safety-related components; electrical power supply and distribution; instrumen,tation and control systems; and in the functional area of preoperational testing. No reply to this letter is required; however, should you have any questions concerning th'ese matters, I will be pleased to discuss them with you. Sincerely, (original signed by O'Reilly) James P. O'Reilly Regional Administrator
Enclosure:
Letter from R. C. Lewis, NRC, to R. E. Uhrig, Florida Power and Light Company, dated November 12, 1982 cc w/ encl: C. M. Wethy, Plant Manager N. Weems, Assistant QA Construction Manager B. J. Escue, Plant Manager H. E. Yeager, Site Manager R. C. Lewis, NRC Region II, SALP Board Chairman bec w/ encl: NRC Resident Inspectors, Turkey Point and St. Lucie Document Management Branch State of Florida DPRP Directors, Regions I, III, IV,V D. G. Mcdonald, Jr., NRR E. L. Conner, Jr., NRR V. Nerses, NRR RII RII RI RII RJ <I M Mv3 Qhd. f DPrice:drt MSinkule CAlderson JDPshinski RClewis R ar in 1/ 7/83 1/7 /83 1//, /83 1/W83 1/[ /83 17 / / \\
0FFICIAL RECORD COPY NOV 121982 Florida Power and Light Company ATTN: Dr. R. E. Uhrig, Vice President Advanced Systems and Technology P. O. Box 14000 Juno Beach, FL 33408 j Gentlemen:
Subject:
Report Nos. 50-250/82-33, 50-251/82-33, 50-335/82-37 and 50-389/82 The NRC Systematic Assessment of Licensee Performance (SALP) Board has completed its periodic evaluation of the performance of the subject facilities. The Turkey Point and St. Lucie 1 facilities were evaluated for the period May 1,1980 through June 30, 1982. The St. Lucie 2 facility was evaluated for the period September 1, 1980 through June 30, 1982. The results of the evaluation are documented in the enclosed SALP Board Report. This evaluation will be discussed with you at your offices in Miami, Florida, on November 23, 1982. The performance of your Turkey Point and St. Lucie 1 facilities was evaluated in the functional areas of plant operations, radiological controls, maintenance, surveillance, fire protection, emergency preparedness, security and safeguards, refueling, and licensing activities. The performance of your St..Lucie 2 facility was evaluated in the functional areas of containment and other safety related structures, piping systems and supports, safety related components, support systems', electrical power supply and distribution, instrumentation and control systems, licensing activities, and preoperational testing. The SALP Board evaluation process consists of categorizing performance in each functional area. The categories which we have used to evaluate the performance of your facilities are defined in section II of the enclosed SALP Board Report. As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff. This report is the product of the revised policy. Any coments, which you have concerning our evaluation of the performance of your facility should be submitted to this office within twenty days following the date of our meeting in Miami, Florida. Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region II Administrator's letter which issues the SALP Report as an NRC Report. In addition to the issuance of the report, this letter will, if appro-priate, state the NRC position on matters relating to the status of your safety programs. In accordance with 10 CFR 2.790 (a), a copy of this letter, the enclosure and your response, if any, will be placed in the NRC's Public Document Room unless you notify this office, by telephone, within ten days following the date of our meeting in Miami, Florida, and submit written application to withhold infonnation contained therein within twenty days following the date of our meeting. Such application must be consistent with the requirements of 10 CFR 2.790 (b)(1). 93036t0672'830iis PDR ADOCK 05000250 G PDR
.. ~. Florida Power and Light Company 2 Should you have any questions concerning this letter, we will be glad to discuss them with you. Sincerely, R. C. Lewis, Director Division of Project and Resident Programs, Region II SALP Board Chairman
Enclosure:
SALP Board Report for Florida Power and Light Company cc w/ encl: C. M. Wethy, Plant Manager N. Weems, Assistant QA Construction Manager B. J. Escue, Plant Manager H. E. Yaeger, Site Manager bec w/ encl: NRC Resident Inspector Turkey Point NRC Resident Inspector, St. Lucie t ACD(d RII RII RI Rii RII f SLO s q . u.; DSPrice:ejw MVSinkule hsdPStohr JA01shinski RCLEwis 11/ A /82 11/f/82 '11/g/82 11/ /82 11/ /82 .}}