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DIRECTORATE OF REGULATORY OPERATIONS l
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RO Inspection Report No. 50-389/73-1 i
Licensee: Florida Power and Light Company 4200 Flagler Street P. O. Box 3100 Miami, Florida 33101 Facility Name:
St. Lucie Unit 2' Docket No.:
50-389 License No.:
Not Issued Location: Hutchinson Island, Florida Type of Inspection: Routine, Announced, Construction D
Dates of Inspection: October 29-30, 1973 1
Dates of. Previous Inspection: None, ij Principal Inspector:
L. E. Foster,*. Reactor Inspector 1
Facilities Section, Facilities Constrtiction Branch Accompanying Inspector:
B. J. Cochran, Reactor Inspector Engineering Section, Facilities Construction Branch Other Accompanying Personnel:
F. J. Long, Chief, Facilities Construction Brane W. A. Crossman, Senior Inspector, Facilities Section, Facilities construction Branch Principal Inspector:
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L. E. Foster, Reactor Inspector, Facilities Date S
ion Facilities Construction Branch Reviewed byt
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_M LM ob4"7-W. A. Cr,ojs man, Senior Inspdctor, Facilities Section
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Facilitilifs Construction Branch l
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"RDRpt.,No.50-Om-1
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SIDMARY OF FINDINGS 1
I I.
Enforcement Action
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Violations 3
l None B.
Safety Items J
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II.
Licensee Action on Previously Identified Enforcement Matters
,,u A.
Violations l
None-t i
7 B.
Safety Items
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None i
III. New Unresolved Items
. 0 73-1/1 Ormanization The St. Lucia Unit No. 2 (FP&L and Contractors) 'QA Organizations 1
are not adequately described in written documents or charts.
J (Details I, paragraph 3) 73-1/2 overall OA Pronram FP&L's overall QA program appears to meet requirements of 10 CFR 50 Appendix B; however, more development is needed to meet tne N.45.2 requirements.
(Details I, paragraph 4) i 73-1/3 Design and Procurement t
l Written policies, procedures and instructions to ensure i
adequate design reviews, design review check-off lists, release of procurement documents, doctament control and interface responsibilities are not couplete.
(Details I, paragraph 5)
I 73-1/4 Auditing of the QA Program l
Written policies, procedures and instructions for auditing
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personnel (internal and external) are not adequate to ensure that meaningful QA audits are performed by FP&L and their contractors.
(Details I, paragraph 6)
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73-1/5 Record Collection' and Filing b
The FP&L QA program does not adequately establish the QA j
records control. system.
(Detairs' I, paragraph 7)
.l 73-1/6 Review od QA ' Program by Management i
l Procedures to provide for regular review of QA by management were not complete.
(Details I, paragraph 8) 73-1/7 Training of QA Personnel A fomal written program has not been developed to ensure i
that QA personnel are trained, indoctrinated and have suitable proficiency in the QA functions.
(Details I, paragraph 9) 73-1/8 Corporate QA Manual j
FP&L has a draft of the proposed " Table of Contents" of the i
QA manual; however,the manual has not been completed.
'j (Details I, paragraph 10)
IV.
Status of Previously Reported Unresolved Items Nee 4
V.
Desian Channes None VI.
Unusual occurrences None VII.
Other Significant Findings A.
Florida Power and Light Company's QA Program is being developed to ensure that the QA functions are separate from other functions.
B.
Design and Engineering activities are underway with no significant procurement of equipment to date.
l C.
The overall project is approximately 10% complete.
This completion is mostly in the engineering area.
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30 Rpt. No. 50-389/73,1 J I
VIII. Mananement Interview g
At the conclusion of. the inspection, s'aseting was held with R. A. Cockrell of Florida Power and Light "Comoany and representatives i
of IBASCO and Cohbustion Engineering, Inc.
Discussion included the areas inspected and the results of 'the inspection.
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3 DETAILS I Prepared by _,,
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L. E. Foster, Reactor Inspector Date FacilitiesSection I
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s'ConstrEctioiBranch n - __ '
- N/M 73 1
- 5. p Cochran, Rasctor Inspector
' Dat's Facilities Section Facilities Construction Branch l
Dates of Inspection:
tob 2 30, 1973 Reviewed by8 ed N
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- W. A. f4 ~sdinan, Senior Ig6pector Dats i
Faciltties Section Facilities Construction Branch i
1.
Individuals Contacted Florida Power and Linhe Company (FP&L)
E. A. Adomat - Executive Vice President N. F. Ajiuni - Assistant Manager of QA, System Development 3
H. L. Allen - Vice President, Construction, Purchasing and; Stores R. G. Cockrell - Manager of Quality Assurance T. Essinger - Assistant Manager of QA, Procurement W. A. Fries - Assistant Manager of QA, Audits H. D. Mantz - Assistant Manager of QA, Construction E. H. O'Neal - Project Manager
- 0. F. Pearson - Executive Assistant to Director of Nuclear Affairs W. H. Rogers - Chief Engineer, Power Plant Engineering J. W. Williams - Project General Manager, St. Lucia Plant J. A. Lasseter - Vice President, Engineering Ebasco Services. Incorporated (EBASCO)
L. Borchardt - Project Manager, St. Lucie Units 1 and 2 W. C. Herman - Chief Engineer, Quality Assurance.
Combustion Engineerina. Incorporated (CE).
W. Medinger - Senior QA Engineer C. Requa - Supervisor, Design Quality Assurance i
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30 Ryt. No. 50-389r/3-1 I-2
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2.
General t
The St. Lucie Unit.No. 2 Quality Assurance program for the control of design and procurement of nuclear power plant structures, systems and components was inspected to determine if PP&L had developed a QA program to meet the requirements of 10 CFR 50 Appendix B and l
ANSI N45.2. The AEC reference book - Guidance on Quality Assurance Requirements During Desige. and Procurement Phase of Nuclear Power i
Plants was utilized as a guide. A general review of FP&L's overall i
QA program was also performed.
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Organization FP&L made a presentation which,showed.the entire FP&L corporate organization. The presentation was further broken down to depict t
the present, QA organization and the lines of authority and j
responsibilities of, each QA function.
1 The Manager of Quality Assurance reports directly to the Director of Nuclear Affairs who reports to the Executive Vice President.
Five (5) Assistant Managers of QA report to the Manager of QA.
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These five Assistant Managers are assigned responsibilities in 1
the areas of system development, procurement, construction, operating plants, and audits.
q Several QA engineers have been assigned positions and they' report
,1 to the individual assistant managers. Position descriptions, i
qualifications and responsibilities of QA personnel have been prepared. A seven member QA committee has been formed to assure top management responsibility for assessing the licensee's QA activities. The licensee's sub-contractor's (EBASCO, CE, & W) QA functions and interfaces with other QA departments were explained to the inspectors.
The licenses was informed that the FP&L St._ Lucia 2 and contractor's QA organizations are not adequately described in written documentation or charts and the_ organization responsible for design and construction interfaces is not clearly described.
This is an unresolved item.
4.
Overall QA Program The licensee's overall QA program appears generally to meet the requirements of 10 CFR 50 Appendix B, but does not adequately j
cover the design and procurement requirements of ANSI N45.2.
The licensee is developing a QA program for the corporate I
organization which will be utilized during the design and procurement phases of St. Lucie Unit No. 2.
FP&L has a QA manual, under preparntion, which will specify requirements O
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to control design, procurement and audit functions. The licenses states that this manual will stand alone; hodever, each projaict will develop their own particular procedurWs. The licensee 's l
sub-contractor's manuals are well developed d.n the area of design sad procurement and' are' a part of the licensee's overall QA program.
f.l The program is being imposed on all organizations (both internal and external) involved in St. Lucie Unit No. 2 project.
The licensee stated that the overall QA program will be measured against the 18 QA critaris and N45.2 requirements and that the results would be available for RO review prior to the ACRS i
meeting. This is an unresolved item and will be examined during i
subsequent inspections.
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i 5.
QA Requirements for Design and Procurement The licenses has made consnitments in the PSAR that design and procurement yA activities will be covered by written policies, procedures and instructions to ensure that basic design criteria, interfaces, codes, material selection, issue and approval of drawings, change notices and specifications and documentation
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will meet 10 CFR 18 Appendix B and N45.2.
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RO advised the licenses that the PSAR was only a connitment; therefore, procedures must be developed to implement the j
conmitments made in thn PSAR.
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The licensee's contractor's presently have procedures which appear to meet requirements for design and procurement activities as i
required by 10 CFR 50 Appendix B; however, these QA procedures do not adequately meet the requirements for long time storage of equipment or meterial plus specific requirements of N45.2.
The licenses stated that the N45.2 requirements were used as a guideline and that further reviews will be performed to ensure that the N45.2 requiraoents are met.
The inspectors were shown a " Quality Assurance Program Matrix" which lists Appendix B and the related N45.2 requirements. This matrix will be utilized as a checklist during the above mentioned review. The licenses stated that the QA requirements are presently being developed and that the QA procedures wculd be finalized after the QA requirements are conplate. The licenses stated that Quality Requirements (QR's) Nos. 1, 2, 3, 4, 5, 6, 7, 17 and 18 and Quality Procedures (QP's) Nos.1, 2, 3, 3.1A, 4, 4.1, 4.2,10, l
17,18,18.1 and 18.2 will be available for RO review prior to February 1974. This is an unresolved item.
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Auditing of the QA Program' I
The licensee has a, managemant policy statement yhich connits them to an audit system as required by N45.2.12~.
The manpower, j
funding and facilities.co implement the audit sequirements j
appear to be adequate. Position descriptions, qualification.
requirements and responsibility of QA audit personnel were j
reviewed and appear to be adequate.
Written policies, procedures and instructions for auditing i
personnel are being developed to ensure that meaningful audits will be performed on all disciplines (internal and external) l i
performing design and procurement activities for St. Lucie 2.
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This is an unresolved item and will be examined during subsequent l
inspections.
7.
QA Record Collection and Filing
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The licensee's.QA. system development group is responsible for i
developing procedures.
The audit group assistant manager is i
responsible for obtaining documents, records and results of
,l ali audits performed by the licensee and contractors. A central location for all records has not been determined; however, duplicate copies of records will be retained at the licensee's j
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corporate offices. The licensee has in progress a procedura to ensure fast retrieval of records.
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The procedure will provide control of non-conformance reports, i
vendor reports and other pertinent records which are to be logged in and indexed.
The licensee's sub-contractors presently have procedures for control of records; however, these have to be reviewed to ensure that they will comply with the licensee's program.
RO advised the licensee that their. program concerning record collection and filing is not adequate to meet the re-quirements of the N45.2 standard.
The licensee stated that work in this area is underway and that certain procedures will receive high priority for completion. This item is unresolved and will be examined during subsequent inspections.
8.
Review of QA Program by Management Procedures which provide for regular review of the implementation of the QA program by manageme.nt, to ensure that necessary require-ments are included in procurement documents early in the procurement
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phase, were not complete. The licensee is presently reviewing design and procurement documents and procedures to be used by their contractors to ensure that the requirements of 10 CFR 50 Appendix B and N45.2 are included.
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s The licensee's "QA Program Matrix" audit checklist will be
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utilized during the review. Upper management is kept informqd of QA activities by monthly audit reports. The;QA committee, j
composed of upper management, is scheduled to meet every six.
1 months to review the overall QA program. This is an unresolved
.I item.
RO will examine during subsequent inspections.
1 9.
Training of QA Personnel The licensee has an informal training program for new and i
experienced personnel. A synopsis of the Atlanta conference on i
the N45.2 requirements concerning QA during design and procurement was given to the QA committee by a member of the QA staff on
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October 16,1973._, The licensee, intends to present the synopsis to their contractors and site personnel in the near future. The licensee stated that a formal training program is under development and will consist of in house and contracted training sessions.
The licensee was apprised of the requirements for a formal training program and that the program should specify the training material, 4
sequence, schedules, attendees and methods for presentation. The j
licensee will examine his program and determine appropriate resolu-tion. This is an unresolved item.
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