ML20134B522
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR FLORIDA Polv1R AND LIGHT COMPANY a t-850703
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1-1 Region II UTILITY PERFORMANCE EVALUATION Utility: Florida Power and Light Company Units: Turkey Point 3, 4 St. Lucie 1, 2 s
Appraisal Period: Turkey Point 3, 4, St. Lucie 1 - May 1, 1979 through April 30, 1980 St. Lucie 2 - September 1, 1979 through August 31, 1980 Review Board Members:
R. C. Lewis, Acting Chief, RONS Branch C. E. Murphy, Chief, RC&ES Branch R. Martin, Chief, Reactor Projects Section 2 J. C. Bryant, Chief, Projects Section 1 T. E. Conlon, Chief, Engineering Support Section 1 M. Grotenhuis, LPM, NRR C. Nelson, LPM, NRR
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Background===
SALP evaluations for each site were generated as prerequisites to the NRC identi-fying the general performance level of each utility with an hRC license. These evaluations are forwarded to an interoffice review board formed of senior members from all Offices of the NRC involved in licensed activities. The board will, by virtue of receiving all SALP evaluations, form a national perspective of licensee pe r fo rmance. Additionally, the evaluations will provide a means for highlighting areas of NRC programs that may require changes or redirection.
In developing the site evaluations it was determined that an overall evaluation of the utility's performance in its nuclear activities was desirable. Additional enclosures document the individual site evaluations.
The utility and site evaluations were presented in a meeting with senior corporate management in order to provide the decision makers of each utility with the NRC's evaluation of its overall performance in nuclear activities.
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1-2 A.
Areas of Good Performance Florida Power and Light (FP&L) is generally responsive to NRC regulations and findings of noncompliance. Reassignment of persofinel at' tiie site level
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has improved manageme%t effectiveness.
Licensed operator performance is above average.
Non-licensed operator performance warrants continued attention by the licensee.
B.
Areas Where Improved Performance is Warranted Substantive differences have been observed in performance between the two sites. This suggests there is minimal corporate involvement in day-to-day operations. FP&L, exhibits a rigid view of their regulatory oblimations and s trites to meet the letter rather than the spirit of their_ commitments.
This is counterproductive in dealing with the NRC. A poor attitude toward regulatory efforts exists on the part of certain indiv4 An=1= =* W c*
tue d site. This has been brought to the attention of the corporate office.
C.
Overall Evaluation As a result of,this evaluation, FP&L is consi,dar-d r =verage performer in the Region. It should be noted that this appraisal contains the results of two team inspections. The results of the noncompliance items cannot be directly compared to other facilities which have not received these inspections.
Future inspection results in these areas, compared with these results will be more indicative of both relative and absolute performance.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
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- O 3-1 Region II Licensee Performance Evaluation (Operations)
Facility:
St. Lucie 1 Licensee: Florida Power and Light Company Unit Identification:
Docket No.
License No./Date of Issuance Unit No.
50-335 DPR-67/3-1-76 1
Reactor Information Unit 1 NSSS Combustion Engineering MW 2660 Appraisal Period: May 1, 1979 through April 30, 1980 These dates were used to provide a comparable basis for all operating reactors in Region II. ' Significant events or enforcement items occuring af ter these dates were considered in arriving at the indicated conclusions.
Appraisal Completion Date: October 9, 1980 Review Board Members:
R. C. Lewis, Acting Chief, RONS Branch R. Martin, Chief, Reactor Projects Section 2 F. Jape, Acting Project Coordinator C. Nelson, LPM, (contacted by telephone on 10/8/80)
S..Elrod, Senior Resident Inspector (contacted by telephone on 10/7/80)
A.
Number and Nature of Noncompliance Items Noncompliance Category:
Unit 1 Violations 0
Infractions 13 (3 r eats)
Deficiencies Areas of Noncompliance Unit 1 List Areas As Required (Points)
Security 72 Radiation Protection 40 Operations / Maintenance 24 Quality Assurance 20 fraining 12 TOTAL POINTS 168
I 3-2 The radiation protectiqn items were concentrated in the area of shipping re_quirements. Subsequent inspections failed to identify further problems in this area.
The QA items were the result of a team QA inspection.- The security items centered around failure to control accesses **recially to vital area, and searches. The other areas contain relatively low point valuis, indicating satisfactory performance.
B.
Number and Nature of Licensee Event Reports Type of Events:
Quantity e
Personnel Error 5
Design Error 3
Installation 2
Defective Procedures 1
Component Failure 21 Other 4
TOTAL 36 Licensee Event Reports reviewed included 79-001/03L-0 through 79-036/03L.
Evaluation of the Above Tabulation:
Nine of the 36 event reports concerned the rod control system.
It appears that reliability of operation is low but failure prevents rod withdrawal or results in rod insertion (dropped rod). This compilation suggests a design problem rather than equipment failure.
The pers,onng1 errors, design errors and installation errors are all personnel errors in reality.
They were spread over a spectrum of responsible parties. No clear pattern emerges.
C.
Escalated Enforcement Actions Civil Penalties None Orders TMI Lessons Learned Orders issued and resolved.
D.
Management Conferences Held During Twelve Months A meeting was held with FP&L facility management and corporate personnel in Region II Office on March 26, 1980, to discuss NRC's concerns about the licensee's security program at St. Lucie Unit 1.
Areas of major concern were vital area accesses and searches, compounded _by repeat noncompliances.
Followup inspections are planned.
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3-3 E.
Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency The evaluation and management conference indicate a need for increased emphasis in the physicel security area. Followup inspections in the physical security area will be conducted to resolve current issues. No change in routine inspection program is warranted.
F F.
Comparison of Unit 1 With Unit 2 A comparison of Unit 1 (in operation) with Unit 2 (in construction) is not useful for the period of this evaluation. As Unit 2 progresses through I
construction (estimated c.ompletion early 1982) an appropriate comparison will be available.
G.
Overall Evaluation Licensee performance is acceptable. The licensee's performance is considered average as cc.mpa red with other Region II reactors. No increase in the inspection program scope or f requency is needed.
The routine inspection program will place increased emphasis on plant physical security.
Appendix A - Functional Areas Appendix B - Action Plan (Internal Use Only)
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4 APPENDIX A 3-A-1 FUNCTIONAL AREAS (Operations)
Inspection Frequency and/or Scope FUNCTIONAL AREA Increase No Change Decrease 1.
Management Control X
2.
Plant Operations X
3.
Refueling Operations and Activ'ities X
4.
Maintenance X
5.
Surveillance and Preoperational Testing X
6.
Training X
7.
Radiation Protection X
8.
Environmental Protection X
9.
Emergency Planning X
10.
Fire Protection X
11.
Security and Safeguards X
12.
Design Changes and Modifications X
13.
Reporting X
14.
QA Audits X
15.
Committee Activities X
16.
Quality Control X
17.
Procurement X
E. C.,
(BRANCH CHIEF)
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APPENDIX B 3-B-1 a
REGION II ACTION PLAN Facility:
St. Lucie Unit 1 Appraisal Date: October 9, 1980 1.
Escalated Enforcement Action No escalated enforcement action is warranted at this time.
2.
Inspection Program Changes (include increased or decreased frequency)
The routine inspection program will place greater e_mphasis on No increase in inspection scope or frequency is needed~ppysical security.
3.
Management Meetings Planned A management meeting was held on October 29, 1980 to discuss the results of this assessment.
No additional meetings outside those required by the routine inspection program are planned.
4.
Status of Action From Previous Appraisals Satisfactory. All previously open issues have been resolved.
L9Rdt rten t J' mes P. O' Reill'y Re ional Director /
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9 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR ST. LUCIE UNIT 2 9
5 4-1 REGION II LICENSEE PERFORMANCE EVALUATION (CONSTRUCTION)
Facility:
St. Lucie, Unit 2 Licensee: Florida Power and Light Company Unit Identification:
Docket No.
CP No./Date of Issuance Unit No.
50-389 CPPR-144/5/2/1977 2
Reactor Information:
Unit 2 NSSS Combustion Engineering HWt 2440 Appraisal Period: September 1, 1979 through August 31, 1980 Appraisal Completion Date: October 9, 1980 Review Board Members _:_
C. E. Murphy, Chief, RC&ES Branch J. C. B ryant, Chief, Projects Section #1 T. E. Conlon, Chief, Engineering Support Section #1 C. R. McFarland, Project Inspector R. A. Birkel, Licensing Project Manager, NRR (By Telephone)
A.
Number and Nature of Noncompliance Items Nor. compliance category:
Unit 2 Violations 0
Infractions 6
Deficiencies 2 j/ gg Areas of Noncompliance:
Unit 2 (List Areas as Required)
(Points)
Instructions, Procedures, and Drawings 52 Part 2 Procedural Requirements 10 Environmental Concerns 2
Total Points 64
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l The board in its deliberation of Noncompliance Items considered that the timing-af_the noncompliance did not indicate a trend that would Tndicate any_ major breakdnua in the licensee's QA program. The l'icensee's responses to the noncompliances has been found to be adequate and timely.
B.
Number and Nature of Construction Deficiency Reports (CDRs)
Electrical 6
Mechanical 4
Welding Jp Only one CDR (hurricane damage) related to site work.
The other CDRs related to design and component manufacturing problems.
The licensee has exercised care in evaluating CDRs and the reports have been acceptable.
C.
Escalated Enforcement Actions None during this audit period.
Management Con'erences Held During Past Twelve Months D.
f None.
E.
Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency / Scope (See evaluation sheet)
The construction activities have increased to the point that within the next twelve months windows of opportunities will be open for all modules.
Cold hydro is scheduled for March 1982, and fuel loading is scheduled for October 1982. The routine KRC inspection of areas has been needed, but the routine program has been severely impacted by the reactive inspection requirements. During the appraisal period no inspections were performed by a mechanical inspector, and only one was performed by an electrical inspector.
The licensee's construction and inspection programs have been maintained on schedule.
F.
Comparison of Unit 2 With Unit 1 A comparison of Unit 2 (in construction) with Unit 1 (in operation) is not useful for the period of this evaluation. As Unit 2 progresses through construction (estimated completion early 1982) an appropriate comparison will be available.
G.
Overall Evaluation Inspection results reflect that the licensee's performance is adequate and average for the region. The licensee is responsive to KRC concerns.
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Appendix A - Functional Areas Appendix B - Action Plan (Internal Use Only)
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APPENDIX A 4-A-1 FUNCTIONAL AREAS (Construction)
Inspection Frequency and/or Scope FUNCTIONAL AREA Increase No Change Decrease 1.
Quality Assurance, Management & Training X
2.
Substructure and Foundations X
3.
Concrete X
4.
Liner-(Containment and Others)
X 5.
Safety-Related Structures X
6.
Piping & Hangers (Reactor Coolant & Others)
X 7.
Safety-Related Components (Vessel, Internals and HVAC)
X 8.
Electrical Equipment X
9.
Electrical (Tray and Wire)
X 10.
Instrumentation X
11.
Fire Protection X
12.
Preservice Inspection X
13.
Reporting X
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n APPENDIX B 4-B-1 REGION II ACTION PLAN Facility - St. Lucie, Unit 2 Appraisal Date: October 9, 1980 1.
Escalated Enforcement Action' No escalated Enforcement Action is warranted at this time.
2.
Inspection Program Changes (include increased or decreased frequency)
No increase in. inspection scope or frequency is required at this time.
3.
Management Meetings Planned No management meetings are planned at this time other than those required by the routine inspection program. A management meeting was held on October 29, 1980 to discuss the results of this evaluation.
4 Status of Action From Previous Appraisals Past regional appraisals have been reviewed to determine the status of actions recommended. All previously recommended actions have been completed.
6$iY cLa s J mes P. O'Reifly Re ional Director
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VI.
NRR Project Manager Comments Discussions with V. Nerses, Project Manager for the Saint Lucie Plant No. 2 indicates the following:
1.
Quality of responses re.lative to amendments', generic letters,' FSAR' submittals and requests for additiona information.
.The applicants responses are of average quality since they rely on,
their NSSS-vendor and architect-engineer (A/E) for inputs.
I have been able to detect some upgrading of NSSS vendor and A/E responses by the utility staff in some disciplines.
I expect this area to improve because the utility staff realizes the tight schedules in obtaining their 0.L. and the need to make efficient, effective responses.
2.
Efforts in obtaining acceptable responses a.
Time and effort It generally takes less than the average time and effort to obtain acceptable responses if the staff identifies the answer it is seeking.
If it requires innovation or imagination on the part of the applicant the time and effort are above average, b.
Responsive in a reasonable time period This utility consistently meets schedules and takes the initia-tive in getting its people to our offices to solve problems.
The utility is well above average in its ability to respond to' staff requests in a timely fashion and takes schedules seriously.
c.
Going as far as they are pushed bysthe staff Clearly this utility probes for what the staff will accept then agrees to go that far.
In some instances the utility has gone beyond what the staff has required.
In this regard, I would consider the utility, above average, d.
Anticipates or reacts to NRC needs Currently, this is an above average utility in this area.
In March, 1980 they applied for an OL.
At that time the FSAR they submitted had the minimum information. Subsequently, their amendments are beginning to show that they are anticipating a
our needs.
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Technical competence, managerial and operationa'l capabilitie's, quality assurance and operational control performance Technical competence - No input on this subject. Staff review to begin within the next three months.
Managerial - Similar to comments above for Technical Competence.
Operational Capabilities - Similar to comments above for Technical Competence.
Quality assurance - Similar to comments above for Technical Competence.
Operational Performance - This area is not applicable since this is not an operating plant.
4.
Working knowledge of regulations, guides, sten'dards, and generi'c
- problems, The licensing organization at the utility is well managed and staffed with competent people. They have a good current working knowledge of each of these areas.
I would rate the utility well above average in this area.
5.
Observed trends in performance, if an'y_
Noticed a decided improvement in the applicant's cooperativeness in providing the staff timely information needed to complete the staff's reviews.
6.
Notable strengths and weaknesses Strengths - Licensing Weaknesses - None obvious at this time.
Overall Summary - Since the acceptance of their ER and FSAR, this utility has demonstrated a cooperative attitude towards meeting the staff's needs for reviewing the FSAR and ER.
-, [- v cerug4 UNITED STATES 8'
3, NUCLEAR REGULATORY COMMISSION i
I REGION 11 101 MARIETTA ST N.W., SUITE 3100 e 'D ATLANTA, G EORGIA 3o303 o
FEB 2 01981 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. 50-335/81-03 and 81-02 This refers to the routine safety inspection conducted by W. P. Kleinsorge of this office on January 20-23, 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 B. J. Escue 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.
These items 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.
We have examined actions you have taken with regard to previously identified enforcemenc matters and unresolved items. The status of these items is discussed in the enclosed report.
Two new unresolved items are identified in the enclosed inspection report. These items will be examined during subsequent inspections.
In accordance with Section 2.790 of the NRC " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such infor-mation from public disclosure. Any such application must include the basis for claiming that the information is proprietary and the proprietary information should be contained in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
For A-Fv-zM3 J
FEB 2 01981 Florida Power and Light Company,
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, C. E. M rp y, C ef Reactor Construction and Engineering Support Branch Enclosures 1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-335/81-03 and 50-389/81-02 cc w/ encl:
C. M. Wethy, Plant Manager Nat Weems, Assistant QA Construction Manager F
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 January 20-23, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified.
A.
10 CFR 50, Appendix B, Criterion IX as implemented by FPL Topical Report (FP&L TQARI-76A) Section 9 requires measures be established to assure special processes including nondestructive are controlled.
Licensee procedure QI-9.1 establishes visual inspection requirements. EBASCO specification FLO-2998-G761 establishes ultrasonic examination requirements for structures.
Contrary to the above, measures were inadequate to control nondestructive testing in that:
1.
On January 21, 1981 four safety injection system licensee accepted socket weld flange to pipe fillet veld joints had fillet weld leg size 1/16" smaller than the minimum permitted by Figure (b), Attachment I to QI-9.1.
2.
On October 27-31, 1980, Weld Joint 2F-2STL-G838-275 was incorrectly accepted by ultrasonic examination.
This is a Sever:.ty Level V Violation (Supplement II.E.).
B.
10 CFR 50, Appendix B, Criterion XVII, as implemented by FP&L Topical Report (FP&L TQARI-76A) Section 17. states " Sufficient records shall be maintained to furnish evidence of activities affecting quality... Inspection records shall as a minimum identify...the type of observation...
Contrary to the above, on January 21, 1981, inspection records did not identify the type of observation in that WRR-2107 was annotated for Root MT or PT inspection when Root After Backgouging MT or PT inspection was intended.
This is a Severity Level VI Violation (Supplement II.F.).
Pursuant to the provisions of 10 CFR 2.201, Florida Power and Light Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) admis-sion or denial of the alleged violations; (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 da,te when full compliacce 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.
SL9 " WeFEB 2 01981 Date:
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UNITED STATES 8
7 NUCLEAR REGULATORY COMMISSION aE REGION 11 101 MARIETTA ST., N.W., SulTE 3100 e
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ATLANTA, GEORGIA 3o3o3 FE B 2 01981 Report Nos. 50-335/81-03 and 50-389/81-02 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Docket Nos. 50-335 and 50-389 Facility Name: St. Lucie License Nos. OPR-67 and CPPR-144 Inspection at St. Lucie site near Fort Pierce, Florida Inspecto il
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W. P. Kleinsorge Date Signed Approved by:
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A. R. Herdt, Sect 1on" Chief, RC&ES Branch Date $1gned
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SUMMARY
Inspection on January 20-23, 1981 Areas Inspected This routine, unanncunced inspection involved 28 inspector-hours onsite in the areas of licensee action on previous inspection findings (Unit 2), equipment storage (Unit 2), reactor coolant pressure boundary piping - observation of work and work activities (Unit 2), safety related piping (Unit 2), steel structures and supports (Unit 2) and inspector follow-up items (Unit 1).
Results Of the six areas inspected, no violations or deviations were identified in three areas; two violations were found in three areas (Violation - Failure to Adequately control NDE paragraphs 3.c. and 6.b.(5)(a).1 and Violation - Failure to properly annotate inspection requirement paragraph 8.a.(1).
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DETAILS 1.
Persons Contacted Licensee Employees
- B. J. Escue, Site Manager, PSL-2
- J. A. Thompson, Assistant Site Manager N. T. Weems, Assistant Manager QA Construction "R. A. Garramore, Senior Resident Engineer
- W. M. Hayward, Supervising QA Engineer
- 0. Cooper, Supervising QA Engineering "W. F. Jackson, Welding Superintendent
- J. L. Parker, Project QC Supervisor
- J. W. Adams, Quality Engineer
- T. C. Grozan, Nuclear Licensing (GO)
- G. H. Krauss, ESSE Project Engineer
- G. A. Maxwell, Storas Supervisor
- 0. L. McAfee, QA Engineer, QA0 PSL-1
- E. W. Sherman, QA Engineer Other licensee employees contacted included several construction craftsmen, QC technicians, and office personnel.
- Attended exit interview.
2.
Exit Interview The inspection : cope and findings were summarized on January 23, 1981, with these persons indicated in Paragraph 1 above.
The inspector identified areas inspected and discussed in detail the violations, unresolved items and the inspector follow-up item. No dissenting comments were received from the licensee.
i 3.
Licensee Action on Previous Inspection Findings a.
(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 in one location. The response from the licensee considered the above as an isolated case and dealt with the matter accordingly. During this inspection, the following examples were noted.
(1) One class 2 main steam stop valve, installed in the trestle, was uncovered out doors.
(2) Three valves ASME Class 1 and 2, were stored out doors uncovered in the south long term storage area.
(3) Two valves, ASME Class 2 and 3, were stored, in plastic bags containing holes and water, outdoors behind the stainless steel pipe fabrication shop.
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(4) Approximately fifty valves of unknown class were stored in opaque plastic bags, some containing holes and water stored outdoors behind the stainless steel pipe fabrication shop. FP&L Procedure SQP-3 Pav 2, " Site Quality Procedure Material Control", identifies valves as requiring level C storage conditions.
SQP-3 further specifies that Level C storage shall be indoors or equal, free from flooding and well ventilated.
In view of the above, the inspector informed the licensee that improper valve storage is not a problem isolated to one location. The licensee indicated that they would re-examine their storage and storage inspection programs. This item remains open.
b.
(Closed) Infraction (389/80-13-02) Welding Filler Material Control.
FP&L letters of response dated November 7 and December 15, 1980, have been reviewed and determined to be acceptable by Region II.
The inspector held discussions with Project Manager, Unit 2, and examined the corrective actions as stated in the letter of response.
The inspector concluded that FP&L had determined the full extent of the subject noncompliance, performed the necessary survey and follow-up actions to correct the present conditions and developed the necessary corrective actions to preclude recurrence of similar circumstances.
The corrective actions identified in the letter of response have been implemented.
c.
(Closed) Unresolved Item (389/80-15-06) Evaluation of Repair Requests.
This item concerns a questions of whether an ultrasonic examination reflector (indication) was within the area of interest of Weld Joint 2F-2STL-G838-275 and therefore whether the reflector required repair.
Ultrasonic examination was conducted in accordance with Ebasco Speci-fication FLO-2998 G-761. The licensee originally determined that the reflector did not require repair.
As a result of this item, the licensee re-evaluated the reflector, and determined that repair was required.
Repair was accomplished in accordance with WRR-2158.
Therefore, the licensee did not adequately control non-destructive examination evaluation. This matter will be closed as an unresolved item and included as an example of violation 389/81-02-01.
Within the area examined, no violations or deviations except as described in paragraph 3.c. were identified.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items identified during this inspection are discussed in paragraphs 5.b and 6.b.(5)(a) 2_.
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Independent Inspection Effort a.
Construction Activities (Unit 2)
The inspector conducted.a general inspection of the unit two reactor building, auxiliary building and stainless steel pipe fab shop to observe construction progress and construction activities such as welding, welding filler material control, material controls, and housekeeping and storage.
b.
Equipment Storage (Unit 2)
On January 21, 1981, the inspector accompanied by a representative of the licensee, made a general inspection of the Level A warehouse. The inspector noted that the Level A warehouse temperature dropped below 60*F on three consecutive days during the previous week.
FP&L Procedure SPQ-3, Revision 2, " Site Quality Procedure, Material Control", requires Level A items to be maintained between 60* and 80*F.
The inspector could not find any indication that the licensee had evaluated the effects of the above temperature excursions had on the contents of the warehouse.
The licensee indicated that they would look into the matter. The inspector stated that the above would be an unresolved item identified as 389/81-02-04: " Level A Warehouse Temperature Excursions".
Within the area examined, no violations or deviations were identified.
6.
Reactor Coolant Pressure Boundary Piping - Observation of Work and Work Activities (Unit 2)
The inspector observed non-welding and welcing work activities for reactor coolant pressure boundary (RCPB) piping.
The applicable code for instal-lation of RCPB piping is the ASME B and PV Code Section III,1977 Edition through the Summer 1977 Addenda.
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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, record keeping requirements, installation specifi-cation requirements, specified material and qualified inspection l
personnel.
l Safety Injection System Activity Identification procedure Marking Weld Joint SI-245-SW-6 SQP-47 R-1 l
Marking Weld Joint SI-239-SW-6 SQP-47 R-1
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4 Marking Weld Joint SI-239-SW-6 SQP-47 R-1 Marking Weld Joint SI-239-SW-6 SQP-47 R-1 Storage Valves Various SQP-3 R-2 Reactor Coolant System Marking Weld Joint RC-142-SW-002 SQP-47 R-1 Marking Weld Joint RC-142-SW-003 SQP-47 R-1 Marking Weld Joint RC-142-SW-004 SQP-47 R-1 Marking Weld Joint RC-142-SW-008 SQP-47 R-1 Marking Weld Joint RC-142-SW-010 SQP-47 R-1 Marking Weld Joint RC-142-SW-012 SQP-47 R-1 (1) With regard to the above inspection in the area of marking, the inspector identified unresolved item 389/81-02-03 discussed in detail in paragraph 6.b.(5)(a) 2.
(2) With regard to the above inspection, the inspector noted one ASME Class 1 Safety Injection Valve stored contrary to the requirements of SQP-3. This matter is discussed in detail in paragraph 3.a.
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 and locaticn; welding procedure; WPS assignment; welding technique and sequence; materials identify; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment conditions; interpass temper-ature; interpass cleaning; process control systems; identity of welders; qualifications of inspection personnel; and weld history records.
Stage of Joint No.,
Si::e Fabrication System RC-150-SW-003 2"x0.334" Welding Out Reactor Coolant CH-148-SW-013 2"x0.334 Welding Out Chemical and Volume Control RC-124-FW-003 35.62 Welding Out Reactor Coolant RC-124-FW-004 36.42" Welding Out Reactor Coolant RC-115-FW-030 35.62" Clad Welding Reactor Coolant RC-121-FW-004 36.12" Welding Out Reactor Coolant
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5 (2) Weld Heat Treatment The inspector reviewed the FP&L program for weld heat treatment for compliance with QA procedure and Code requirements. The welds listed in paragraph 6.b.(1), 7.b.(1), and 8.a, were examined in process relative to weld joint preheating to determine; procedures available; procedures specify acceptable preheating method; procedures provide monitoring and recording requirements and procedure compliance.
(3) Welder Qualifications The inspector reviewed the FP&L program for qualification of welders and welding operators for compliance with QA procedures and ASME Code requirements.
(a) The following welder qualification status records and
" Records of Performance Qualification Test" were reviewed relative to the weld joints listed in paragraph 6.b.(1),
7.b.(1), and. 8.a.
Welder Symbol Acolication PTE RCBP PVT RCBP PYC RCBP FAM RCBP PD RCBP PRZ RCBP PSM RCSP PWT RCBP FCS RCBP PSL RCBP FAM RCBP PTP RCBP FEH Safety Related Piping PWV Steel Structures and Supports (b) The following repair welder's qualification status records, and " Records of Performance Qualification Test" were reviewed to determine whether they meet applicable qualification requirements.
Welder Symbol Weld Repair Report No.
PWT 1917 PTM 1917 FBT 1999 PRZ 2062 PXU 1858 l
6 (4) 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 procedures and applicable code requirements. The following specific areas were examined:
-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 Type Size Code Application ER-308L 1/8" 0176 RCPB 7052 0.045" 0151 RCPP ER-308L 0.045" 0170 RCPP 7018 1/8" 0171 Safety Related Piping and Steel Structures and supports 7018 3/32" 0174 Safety Related Piping 7052 1/8" 0182 Safety Related Piping 7052 3/32" 0101 Safety Related Piping (5) The inspector visually exa.nined completed RCFB Welds as described below to determine whether applicable code and procedure require-ments were being met.
(a) The following welds were examined relative to the following:
location, length, size and shape; weld surface finish and appearance, include inside diameter of pipe welds when accessible; transitions between different wall thickness; weld reinforcement-height and apoearance; joint configu-rations of permanent attachments and structural supports; removal of temporary attachment, are strikes and weld spatter; finish grinding or machining of weld surface, surface finish and absence of wall thinning; surface defects, cracks, laps. lack of penetration, lack of fusion, porosity, slag, oxide film and undercut exceeding prescribed limits:
Joint Number System SI-245-SW-006 Safety Injection SI-239-SW-006 Safety Injection SI-230-SW-006 Safety Injection
7
~
SI-235-SW 006 Safety Injection RC-142-SW-002 Reactor Coolant RC-142-SW-003 Reactor Coolant RC-142-SW-004 Reactor Coolant RC-142-SW-008 Reactor Coolant RC-142-SW-010 Reactor Coolant RC-142-SW-012 Reactor Coolant 1
With resard to the above inspection on January 21, 1981, the inspector noted that the completed and accepted Safety Injection System, socket weld flange to-pipe fillet welded joints above were undersized. FP&L Procedure QI-9.1 " Visual Inspection of Welds" Attachment 1,
Revision 4, figure (b) requires that one inch schedule 160 socket weld flange to pipe joints, like the safety injection system welds above, have a fillet weld leg size not less than 0.350".
The safety injection welds above had fillet weld leg sized 1/16" (0.062")
less than the 0.350" required.
The above and para-graph 3.c are examples of unacceptable conditions, accepted by the licensee's nondestructive examination program, detected, by the NRC inspectors.
The above examples indicate failure to establish adequate controls for nondestructive examination, and is in violation of 10CFR50 Appendix B, Criterion IX. This violation will be identified 389/81-02-01: " Failure to Adequately Control NDE".
2 With regard to the inspection of paragraph 6.b.(5)(a) above, the inspector noted on all the joints that the licensee was vibroetching joint identification and/or joint fit-up marks inside the one half inch nondestruc-tive examination area of interest. At the time of this inspection, it could not be determined whether the marking could mask indications of unacceptable indi-cations.
The licensee indicated that they would look further into the matter. The inspector stated that the above would be an unresolved item and identified as 389/81-02-03 " Marking in NDE Area of Interest".
Within the area inspected, no violations or deviations except as described in paragraph 6.b.(5)(a) I were identified.
7.
Safety-Related Piping The inspector observed non-welding and welding work activities for safety-related piping as described below to determine wnether applicable code and procedure requirements were being met.
The acclicable code for safety-related piping is the ASME B and PV Code,Section III 1977 Edition with addenda through Summer 1977.
i
l 8
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, record keeping, installation specifications or plans, specified materials, specified NDE, calibration and use of proper test equipment and qualified inspection and NDE personnel.
Activity System or Comoonent procedure Storage Valves, Various SQP-3 R-2 (1) With regard to the above inspection, the inspector noted five valves (4 ASME Class 2 and 1 Class 3) stored contrary to the requirements SQP-3.
This matter is discussed in detail in paragraph 3.a.
b.
The inspector 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 technioue and sequence; materias identify; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature; interpass cleaning; process control systems; identify of welders; qualificatio'n of inspection personnel; ar.d weld history recorcs.
Stage of Joint No.
Size Fabrication System CC-0039-FW-008 8"x0.322" Welding Out Component Cooling (2) Weld Heat Treatment Weld heat treatment is discussed in paragraph 6.b.(2).
(3) Welder Qualification Welder qualification is discussed in paragraph 6.b.(3).
(4) Welding Material Control Welding material control is discussed in paragraph 6.b.(4).
Within the area inspected, no violations or deviations were identified.
l
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7 r
9 8.
Steel Structures and Supports (Unit 2)
The inspector observed welding work activities for steel structures with the containment as described below to determine whether applicable code and procedure requirements were being met. The applicable code for main steam restraint structures is AWS D 1.1-74.
Observation of Welding Activities The inspector observed in process welding activities of containment structural field welds as described below to determine whether applicable code and procedure requirements were being met.
a.
Welding The following welds were examined in process to determine work conducted in accordance with traveler, welding procedures available; welding technique and sequence; weld geometry, fut-up electrical characteristics; equipment condition:
Joint No.
Stace of Fabrication Structure ST1.-G799-131 Welding Out Main Steam Restraint (1) With regard to the above inspection, on January 21, 1961, the inspector noted that the welder of record, for the above joint, had by passed the traveler QC hold point for root inspection. The Traveler (WRR 2107) required MT or PT inspection of the root.
The licensee stated that they intended the root inspection to be accomplished after backgouging of the root, for crack control.
The welder had been verbally informed of the above intention. The inspector stated that if MT or PT inspection of the root after backgouging had been intended, then the traveler should have been so annotated. Without the above annotation, the inspection record (the traveler) would reflect " root inspection" and not " root inspection after backgouging".
Therefore, the record would erroneously state the stage of fabrication at which the inspection was accomplished.
Failure of inspection and test records to identify the type of observation is in violation of 10CFR50 Appendix B, Criterion XVII. This violation shall be identified as 389/81-02-02, " Failure to Properly Annotate Inspection Require-ments".
b.
Weld Heat Treatment Weld heat treatment is discussed in paragraph 6.b.(2).
c.
Welder Qualification Welder qualification is discussed in paragraph 6.b.(3).
10 d.
Welding Material Control Welding material control is discussed in paragraph 6.b.(4).
e.
Welding Procedure Specification Within the area inspected, no violations or deviations except as described in paragraph 8.a.(1) were identified.
9.
Inspector Followup Items (Unit 1)
(Closed) Inspector Follow-up Item (335/80-31-01) Review of Welder Qualiff-cation Audit".
This item involves an audit of welder qualification committed to by the licensee as the result of a concern reported to NRC:RII.
The inspector reviewed the Licensee's Audit No. QAO-PSL-80-09-203, " Quality Assurance Department Audit of Backfit Welding Qualifications".
The inspector identified no violations or deviations, and has no further questions. This item is considered closed.
i I
L
P.O. Box 529100 M1AMI, FL 33153
- }
.e r'. w FLORIOA PCWER & LIGHT CCP/PANY March 18, 1981 L-81-120 Mr. J. P..O'.Reilly, Director, Region 11 Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Re:
Rll:WPK St. Lucie Unit 2 Docket No 50-389/81-02 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 truly yours, I
l Robert E.
Uhrig Vice President Advanced Systems & 'Ihchnology REU/TCG/nh.
cc: Harold F.
Reis, Esquire pooA-M-293
<t; K4 H @ t E ~
L[l47 L
l PECPLE.. SERVING PEOPLE
, *y. E RII:WPK 50-389/81-02 A.
'liolation:
Inadequate Control of NDE 10 CFR 50, Appendix B, Criterion' IX as implemented by FPL Topical Report I
(FPL TQARI-76A) Section 9 requires measures to be established to assure special processes. including nondestructive are controlled. License procedure QI-9.1 establishes visual inspection requirements EBASCO specification FLO-2998-G761 establishes. ultrasonic examination requirements for structures.
1 Contrary to the-above,. measures.were inadequate to control nondestructive testing in that:
1 1.
On January 21, 1981 four safety injection system licensee accepted socket weld' flange to pipe fillet weld joints had fillet weld leg size 1/16" smaller than the minimum permitted by Figure (b), Attachment 1 to QI-9.1 3 2.
On October 27-31,1980, Weld Joint 2F-2STL-G838-275 was incorrectly accepted by ultrasonic examination.
R".sponse:
(Example 1) 1.
FPL concurs with the finding.
2.
The finding is attributed to inattention to job detail and drawings.
3.
QC reinspected the SI welds identified in the audit report and generated NRC 1689M for Engineering evaluation.
4.
All Category '1, 2' & 3 pipe to flange socket welds are in the process of being re-inspected and ff found to be discrepant a WRR 'or an MCR will ~ be-initiated. Estimated compTetion is approximately three (3) months.
5.
To preclude recurrence, the inspectors have and will continue, to receive training in fillet sizes and visual examination of weld in accordance-with QI 9.1 and 9.2.
6.
Full compliance will be achieved in approximately three (3) months.
Response
(Example 2) 1.
FPL concurs with the finding.
2.
Acceptability of the weld was evaluated based on AWS D.l.1 requirements and without complete ~ istory of initial joint fitup configuration.
n 1
3.
Re-evaluation of the weld. geometry required additional ultrasonic testing and weld repair was authorized by Weld Repair Report 2158.
4.
QC will increase fitup surveillance. A fitup inspection will be performed in all cases where it appears that welds may not be readily accessible after completion. This information will be made available as required to evaluate similar conditions.
r
' ;.6 RII:WPK 50-389/81-02 Page 2 5.
Full compliance has. beerr achieved.
B.
Violation:
Failure to Properly Annotate Inspection Requirements 10 CFR 50, Appendix-Sk Criterion XVII,. as implemented by FPL Topical Report.
(FPL TQARI-76A) Section 17, states " Sufficient records shall be maintained to furnish evidence of activities affecting quality..
Inspection records shall as. a, minimu:n identify... the type of observation...
Contrary to the above, on January 21, 1981, inspection records did not i
identify the type of observation in thatrWRR-2107 was annotated ;for Root HT or PT inspectica when Root After Backgouging MT or PT inspection was intended.
Response
1.
FPL concurs with the finding.
2.
This finding resulted from incomplete information: annotated on the weld requirement.
3.
This item noted during this inspection was art isolated incident. Also, the Weld Repair Report was clarified a'; the time to indicate MT of the l
root after backgouging.
t 4.
Inspectors have been informed to be more-specific when assigning QC hold point inspections to Weld Repair Reports.
5.
Full compliance was achieved prior to the exit interview.
e ee l
. -g x ;.e STATE OF FLORIDA
)
)
ss.
COUNTY OF DADE
)
Robert E. Uhriq
, being first duly sworn,. deposes and.says:.
That he is Vica 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.
t Robert E. Uhrig ~
Subscribed and sworn to before me this
/8 day of 19 f/,
Q a;L. J g N - a,
NOTARY PUBLIC, inULnd for the County of Dade, State of Florida Notary PubEc. State of Roride st W My Commemon Expres octobe, 30.-1983 My cnmmissiert expires:
sonded thru Maynard Bondes W
P.O. BOX 529100 MI AMI, FL 33152 i
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FLORioA PCWER & LtGHT COMPANY
~.
- OI April 3,1981 L-81-151 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:WPK St. Lucia Unit 2 Docket No. 50-389/81-02 In accordance with the request of Mr. W. P. Kleinsorge,. this supplementary response is provided to address corrective action taken with respect to storaga of valves in responsa to open infraction 50-389/80-13-01.
The main steam stop valve is designed to function exposed to the atmosphere.
The equipment storage / maintenance record card for this valve is being
- b*
revised to show that the valve can be stored uncovered. This revision will be processed by April 13, 1981.
To assure compliance witit quality requirements, separate enclosures are currently being fabricated in the south long ter:a storage area and behind both the stainless steel and carbon steel fabriaccion shops for ASME Class I, II and III Valve Storage.
In addition, heat will be provided to each enclosure. This activity will be completed by April 30, 1981.
Very y yours, Robert E. Uhrig-Vice President Advanced. Systems & Technology REU/TG/nic cc: Harold F. Reis, Esquire Fo/ A 44 -M3 Q i+r r-PEOPLE.. SERVING PEOPLE
D UNITED STATES NUCLEAR REGULATORY COMMISSION j'
r REGION 11 1
101 MARlETTA ST N.W SUITE 3100
^'jfk @" E Florida Power and Light Company ATTN:
R. E. Unrig, Vice President Advanced Systems and Technology P. O. Box 529100 Miami, FL 33152 Gentlemen:
Subject:
Report No. 50-389/81-02 Thank you for your letter of March 18, 1981, informing us of steps you have taken to correct the violations concerning activities under NRC Construction Permit No.
CPPR-144 brought to your attention in our letter of February 20, 1981. We will examine your corrective actions and plans during subsequent inspections.
We appreciate your cooperation with us.
Sincerely, E. C.
R. C.
wts, Acting Of rector Division of Resident and Reactor Project Inspection cc:
B. J. Escue, Plant Manager N. Weems, Assistant QA Construction Manager e
FotA- % -195 L.ll41 g
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%g UNITED STATES
~
8 NUCLEAR REGULATORY COMMISSION n
2 fr REGION 11 101 waRimA ST N.W.. SUITE 3100 g * *" *,/
ATI.ANTA. GEORGIA 30303 APR 15 G81 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. 50-389/81-04 This refers to the special safety inspection conducted by J. C. Bryant et al of this office on March 9-20, 1981, of activities authorized by NRC Construction Permit No. CPPR-144 for the St. Lucie 2 facility. Our preliminary findings were discussed with B. J. Escue at the conclusion of the inspection.
This inspection was a comprehensive examination of site work in progress and of your management and quality assurance controls as applied to that work and other activities. In addition to inspection of selected areas of responsibility at the site, discussions were held with many employees to determine their knowledge of and ability to carry out their individual responsibilities. These discussions included determination of the employees freedom to obtain corrective action on safety issues.
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 Appendix A.
Elements to be included in your response are delineated in Appendix A.
Two new unresolved items are identified in the enclosed inspection report. These items will be examined during subsequent inspections.
In accordance with Section 2.790 of the NRC " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include the basis for claiming that the information is proprietary and the proprietary information Fo + 8 M i3 rM% ung n
APR 15 Iggy Florida Power and Light Company 2
should be contained in a separate part of the document. If we do not hear from you in this regard within the specified period, 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, rd C.f.fwTs, Actdg Direc r
ivision df Resident and Reactor Project Inspection
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report No. 50-389/81-04 cc w/ enc 1:
B. J. Escue, Plant Manager N. Weems, Assistant Manager QA Construction
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 March 9-20, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified.
A.
10 CFR 50, Appendix 8, 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. Quality Control instructions were not being followed for concrete inspection as described below.
1.
Quality Control Instruction QI 10.4 requires that concrete repair activities be inspected.
Contrary to this requirement, no inspection was performed during placement of concrete in an area being repaired on the exterior surface of the primary shield wall at azimuth 0*, elevation 36, on March 12, 1981.
2.
Quality Control Instruction QI 10.71 states that water is not to be added to any concrete batch after making in process tests for slump, air unit weight and compressive strength.
Contrary to this requirement, water was added to concrete which was placed in reactor building struts 53 0-F, and 54 C-0 after making the in process tests for air, unit-weight, and compressive strength. The inprocess tests were not repeated after addition of the water.
3.
QC Instruction QI 10.71 states that concrete compressive strength speciments are to be tested in accordance with ASTM C-39.
ASTM-39 requires that the rate of loading during testing of the concrete cylinders be applied within the range of 20 to 50 psi per second.
Contrary to this requirement, during testing of concrete cylinder numbers 6796 through 6798, the rate of loading was applied in the range of 60 to 70 psi per second.
l 4.
QC Instruction QI 10.4 requires that concrete surfaces be inspected L
after the concrete forms are removed and be documented in Part III of the Post Placement Concrete Inspection Report (Attachment 1 to QI 10.4).
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3
Florida Power and Light Company 2
Oceket No. 50-389 Notice of Violation License No. CPPR-144 Contrary to this requirement, an informal method was used to document post placement inspections on pour numbers 4, 5, 6, 8A, 88,12 and 13 in the Diesel Oil Storage Structure.
This is a Severity Level V Violation (Supplement II.E.).
B.
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.
Pipe support and valve drawing requirements were not being followed as described below.
1.
Pipe support drawing SI-2407-40, Rev. 4, requires the installation of structural member piece 4; requires the rigid shock arrestor, piece 6, be within 3* of perpendicular to the wall; and requires the instal-lation of fasteners for piece 1.
Contrary to these requirements, piece 4 was not installed, piece 6 was installed at least 5' off prependicular, and a piece 1 fastener had insuf-ficient thread engagement.
This support had been inspected by QC and accepted.
2.
Pipe support drawing SI-2412-31, Rev. 3, requires 1/16" clearance between the box type pipe support and the top and both sides of the pipe.
Contrary to these requirements, pipe support SI2412-31 had no clearance on the west side of the pipe, 3/32" clearance on the east side, and 3/16" clearance on top of the pipe.
This support had been inspected by QC and accepted.
3.
Pipe support drawing CC-2063-22, Rev. 2, requires a 12 to 9 slope for structural member piece 4 and a 1 to 1 slope for structural member piece 5.
Contrary to these requirements, piece 4 of pipe support CC-2063-22 had approximately a 6 to 4 slope and piece 5 had approximately a 5.3 to 4.6 slope. This support had been inspected by QC and accepted.
4.
Fisher control valve drawing 52A86590 requires chemical and volume control valve 2500 to have a 60* internal counterbore on the valve nozzles.
Florida Power and Light Company 3
Docket No. 50-389 Notice of Violation License No. CPPR-144 Contrary to this requirement, valve 2500 had a 90* counterbore on the bottom nozzle.
This is a Severity Level V Violation (Supplement II.E.).
C.
10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be performed in accordance with established procedures.
FP&L QA Topical Report supplements this requirement and established Site Quality Procedure 17, Design Control, which requires changes in design requirements to be accomplished through field change requests.
Contrary to the above, the requirements of SQP 17 were not met in that seismic class I cable tray restraint 1336 was modified to permit instal-lation of a non safety-related cable tray without a field change request being prepared.
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 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 admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken tu 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.
APR 151981 Date:
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UNITED STATES NUCLEAR REGULATORY COMMISSION o
E I
REGION li o,
101 MARieTTA ST., N.W SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-389/81-04 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, Florida 33101 Facility Name: St. Lucie 2 Docket No. 50-389 License No. CPPR-144 Inspection at St. Lucie site near Ft. Pierce, FL.
Inspectors:
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C." Bry g
Date Signed
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M 0. H0nt Qate 7 gned LMJ e/u/rr V. L.verownie OMe Stijned Y/3k/
J. Jgnahan Date Signed A,
4A' ffff W. pang ~F f
Ofte Signed y/n/#f i
Approved by:
m J
Bryantgection Chief, Division of 0' ate Signed esident and Reactor Project Inspection l
SUMMARY
l Inspection on March 9-20, 1981 Areas Inspected This special, announced inspection involved 336 inspector-hours on site in the areas of QA program implementation, on site design control, site management, site procurement, and construction controls and activities.
Construction activities l
inspected included electrical components and systems, civil construction l
activities, safety-related pipe support and restraint system, and mechanical i
equipment installation, p\\LwtLL X Q
Results Of the five areas inspected, no violations or deviations were identified in four areas; three violations were found in one area (Failure to follow procedures in civil QC inspections, paragraph 9; Failure to follow procedures in installation of pipe supports, paragraph 10, Unauthorized modification of cable tray restraint, paragraph 11).
e 1
DETAILS 1.
Persons Contacted Licensee Employees
- H. J. Dayer, Vice President, EPC
- W. B. Lee, Director of Construction
- B. J. Escue, Site Manager
- A. E. Siebe, Manager of QA
- W. T. Weems, Assistant Manager QA Construction
- W. M. Hayward, Supervising Engineer QA
- 0. R. Cooper, Supervising Engineer QA
- E. W. Sherman, QA Engineer
- J. L. Parker, Project QC Supervisor
- J. D. Kirk, Superintendent General Construction
- J. E. Vessely, Of rector, Nuclear Affairs Other licensee employees contacted included 35 construction craftsmen, 20 engineers, 33 QC inspectors,10 craft supervisors, and 18 office personnel.
Other Organizations (Ebasco)
- K. N. Flannagan, Project Superintendent
- R. A. Garramore, Senior Resident Engineer P. Sweitzer, Labor Relations
- G. H. Krauss, ESSE Project Engineer NRC Resident Inspector
- S. A. Elrod, Senior Resident Inspector
- P. Bibb, Resident Inspector 2.
Exit Interview The inspection scope and findings were summarized on March 20, 1981, with those persons indicated in' Paragraph 1 above.
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 violations or deviations.
New unresolved items identified during this inspection are discussed in paragraphs 7 & 9.
2 5.
Project Management - Site Portions of this inspection were directed toward methods used by site management to assure that a quality product is produced and toward partici-pation of management and the supervisory staff in the handling of site problems.
Discussions were also held with craftsmen, irspectors, and engineers to determine their perception of work quality, availability of technical assistance, access to management, freedom to express concerns and protection from harassment.
Results of discussions with craftsmen, inspectors and workers are discussed in several sections of this report.
a.
Organization The overall design is the responsibility of $basco Services, Inc.
(Ebasco) except for the NSSS scope of work. Ebasco maintains an onsite engineering field office. Approval of major design changes is made through the New York Offices.
FP&L manages the site construction program.
The site organizational / functional alignment. is a composite structure of FP&L, Ebasco, US Testing and Union Boiler personnel. Overall site construction management and QA/QC functions are manned by FP&L personnel. The site engineering and construction functions are manned by Ebasco personnel under direct supervision of FP&L.
Quality Control Inspection activities are performed by US Testing personnel under direct supervision of FP&L Project QC Supervisor.
The Union Boiler management personnel responsible for piping and instrumentation installation report to thq Eba'sco Project Superinten-t dent.
The NSSS supplier has the normal complement of personnel for technical support and coordinatit. with the home offices.
The
. inspectors were provided with current organization charts which clearly define the lines of authority and communications between the licensee and contracting organizations, the inspectors verified that the onsite organization / functional alignment was consistent with the information provided.
The inspectors conclude that there is a proper balance of work load assigned to lead site supervisory personnel and the span of control for managers and supervisory personnel is within normal mana,gement control expections.
b.
Position Descriptions Positions descriptions for the top four levels of site management and supervision were reviewed. The inspectors conclude that the position i
descriptions are consistent with the organizational structure and pro; am description. The position descriptions provide sufficient
3 detail to clearly define responsibilities, authority, and interfacing activities.
The QA/QC procedures further define the areas of respon-sibility and authority within scope of the activity defined by the procedure.
c.
Implementation As a result of the overall review of the QA program, organizational /
l functional alignment and the QA/QC site implementing procedures, J
discussions with site personnel, observations of ongoing activities and record examinations, the inspectors conclude that there are adequate provisions in place for control of the following:
commurications, i
staffing, reporting of site activities, problems, trending, report analysis, activity planning, stop work, records and record maintenance, and inspection activities.
d.
Management Involvement The inspectors held discussions with site management, engineers, site
'j QA personnel, QC inspectors, and craftsmen of various disciplines; they reviewed audit reports and findings, COR's, trending reports, field engineer reports, and other report forms intended for the interchange i
of information; and attended management assessment meetings.
The inspectors conclude that managmenet on this site is aware of the daily on going activities, day to day problems and their resolution.
Further, it is quite evident from discussions with site personnel that management is highly visible, accessible and fully involved with the day to day activities and problems.
e.
Employee Freedom to Express Concerns and Perception of Management Activities The site manager has issued a notice and directed that it be placed on all site bulletin boards and that it be presented to all site personnel through stewards or at safety meetings.
The notice is entitled,
" Reporting of Safety-Related Defects and Noncompliance".
The notice encourages all personnel, in the event that they are aware of such a defect, to talk to their foremen, supervisor or department head. It states that if they still have concerns, they should talk to the services superintendent. As an alternative, it suggests that they call the FP&L QA Manager in Miami and provides his phone number.
It l
then states that if their concerns still are not satisfied, they should t
call the NRC.
FP&L has no wage roll people on site other than Administrative and, therefore, has no grievance procedures for crafts.
The Ebasco labor relations manager stated that a grievance procedure was part of each j
craft's contract. The inspector reviewed several of these procedures.
4 e
--.~,
.-~
4 There was evidence that employees are encouraged to take any problem to their supervisors and to higher supervision if they feel the need.
There was no evidence that there was any suppression of employee concerns by management and the inspectors were assured by on site union officials that employee concerns would be addressed promptly and would receive thorough consideration without recrimination. Employees at all levels clearly stated that harassment of QC personnel for rejecting work or the performance of poor work by craftsmen would not be tolerated at the site.
The site managers and lead superintendents are mature, experienced and knowledgeable people. The confidence shown by these managers permeates the lower levels of supervision. Otscussions with craftsmen, QC inspectors, QA auditors and various levels of supervision revealed a unified desire to produce a. quality product.
In general, people interviewed at the site appear knowledgeable of requirements and have adequate resources available to produce a quality product.
The inspectors identified no concerns or violations in the area of management controls.
6.
Site QA and Construction QA Program Implementation a.
General The purpose of this portion of the inspection was to complete an overall review of implementation of the FP&L program for control of site QA and construction activities.
FP&L Topical Quality Assurance Report (FPLTQAR 1-76A) Rev. 3 (Topical) is the current document that establishes FP&L QA Program requirements.
FP&L submitted Rev. 3 to the Quality Assurance Branch, NRR, (QAB) for review and acceptance via FP&L letter L-79-34 dated February 9,1979.
QA8 has not accepted Rev. 3 to the Topical as of the date of this l
inspection. FP&L has issued and implemented Rev. 3 to the Topical as stated within the February 9,1979, letter.
l b.
Documents Examined
-- FPLTQAR 1-76A, Rev. 3
-- Corporate QA Manual and associated Procedures
-- Quality Site Procedures Manual and associated Procedures
-- Quality Instructions Manual and associated Procedures c.
QA Program Review The inspector reviewed the documents listed above and held discussions 0
5 with responsible site management, QA, QC, technical support and craft personnel and concluded that the FP&L QA program and supporting manuals contain the following:
(1) A firm policy statement from upper management supporting the QA program and objectives.
(2) Adequate definition in the program for control of contractor and subcontractor activities.
(3) Provisions in the implementing QA manuals for interface control between engineering, QA, construction, consultants, contractors, and procurement.
(4) A listing of commitments to regulatory requirements.
(S) Provision for management audits to determine QA effectiveness.
(6) Clear-cut organizational / functional charts and responsibility definition within the QA program implementing documents.
(7)
Independence of the QA organization from design and contruction.
(8) QA Department direct access to management.
(9) Complete corporate QA manual and site quality instruction manuals with procedures to implement the scope of work, QA/QC activities and provide interface control with other departments and activi-ties.
(10) The QA manuals are controlled and contain procedures for change control.
(11) Stop work requirements are established and provisions provided for implementation.
d.
Program Implementation By observation of ongoing activities, review of reports and discussions with personnel at all levels, the inspector concluded that the FP&L QA program, supporting manuals and organizational / functional alignment are consistent with project status and adequate to monitor project activities in an effective manner.
Personnel at all levels were knowledgeable of the QA program and procedural requirements for their particular scope of work.
e.
Audits There is a comprehensive system of audit and surveillance activities which spans corporate, departmental and site QA program activities.
6 FP&L belongs to a Joint Utility Management Audit Organization which includes seven utilities.
This organization performs the corporate audit on an annual basis.
The inspector reviewed the JUMA Audit, QAS-QAO-81-1.
The inspector reviewed site audit and surveillance activities being performed by the site QA organization.
Site audits are performed in the form of management aduits and activities audits.
In 1980, there were 10 management audits and 40 activities audits performed.
During 1980, there were 350 surveillances performed by the site QA auditors.
At the time of this inspection, there had been 6 audits and 96 sur-veillances performed in 1981.
The inspector reviewed several audit reports and surveillance actions.
The inspector concluded that the audit / surveillance system provides for effective evaluation of program performance.
Audit plans are tailored to a function and are not superficial check lists.
No violations or deviations were identified.
f.
Deficiencies, Defects and Nonconformances The purpose of this inspection effort was to perform an in-depth examination of the licensee's/ contractor's program for identifying, documenting, evaluating, instituting proper corrective action, deter-mining cause, and detecting trends of identified construction discre-pancies.
Additionally, the inspectors examined the evaluation and reporting (10 CFR 50.55(e) and Part 21) measures that have been established and implemented.
Document's Examined FP&L Topical Quality Assurance Report (FPLTQAR 1-76A) Revision 3 Q.P.15.1, Control of Nonconforming Material, Parts or Components -
Plants under Construction, Rev. 2 0.P.16.1, Corrective Action, Rev. 2 Q.P.16.4, Evaluating and Reporting of Defects and Noncompliances for Substantial Safety Hazards in Accordance with 10 CFR Part 21, Rev 1 Q.P.16.6, Reporting of 10 CFR 50.55(e) Deficiencies, Rev.1 SQP 21, Corrective Actions, Rev.1 QI No.15.1, Identification and Control of 01screpant Conditions, Rev. 4 QI No.15.2, Processing of 10 CFR 50.55(e) Discrepancies, Rev.1 QI No.16.1, Stop Work Instruction, Rev.1 QI No. 2.6, Evaluation of Control Effectiveness / Trend Analysis, Rev. 2 Program Review The inspectors reviewed the above listed documents and held discussions with responsible site management staff, QA management and staff, QC management s
7 and staff, the EPP representative, and contractor personnel. The inspectors conclude that the FP&L implementing procedures provide sufficient measures to control on and off-site identified deficiencies, their corrective actions and the proper evaluation and reporting to the NRC if required.
Implementation By observation of activities, review of NCR's, IR's, OR's and discussions with personnel at all levels, the inspectors concluded that FP&L has imple-mented the established QA program and the program as implemented is a viable program.
The personnel interviewed were knowledgeable of the program procedure requirements and appeared to be very conscientious. Based on the review of the various documents related to control of site problems, the inspectors conclude that the problems are being adequately described, evaluated, dispositioned and corrective actions verified. The monthly and quartarly problem trending evaluation of site identified problems is one of the better managed systems that the inspector has observed.
No violations or deviations were identified.
7.
Design Controls a.
Organization On site design activities are performed by the Ebasco Site Support Engineering group'(ESSE). The group is supervised by the site project engineer who reports to the St. Lucie 2 Project Engineer in the Ebasco home (New York) office.
ESSE has design engineers in the following disciplines:
Civil, electrical, instrumentation, and mechanical.
These design engineers report to the site project engineer.
The responsibilities of ESSE are to review and approve field change requests (FCR's) which.results in only minor project design changes; l
disposition nonconformance reports (NCR's); prepare design change notices (DCN's), which are minor design changes; consult with the home office for approval of FCR's which result in major design changes; and coordinate design activities between the home office and onsite con-struction groups. Ebasco Engineering procedures define a minor change l
as one which has litle or no impact on a safety-related system, or cost less than $100,000. All other changes are considered major, b.
Review of Design Control Procedures i
The inspector examined procedures for on site design activities to determine if the onsite design activities are being controlled as specified in the FSAR and NRC requirements. The following procedures were examined:
(1)
FP&L Site Quality Procedure SQP-17, " Design Control" t
i
i 8
(2) Ebasco Engineering Procedures (a) E-11, "As-Built Orawings" (b)
E-30, " Preparation of Calculations" (c)
E-69, " Design Change Notice, Field Change Request" (d) E-82, "Ebasco Site Support Engineering (ESSE) Group" (e) E-88, " Preparation, Approval, and Distribution of Engineering and Design Guides" Review of the above procedures and discussions with ESSE engineers disclosed the following unresolved item:
The processing of noncon-formance reports (NCR's) in ESSE is controlled by an ESSE standard operating procedure (50P-5).
This procedure is not considered a QA procedure and does not appear to meet the requirements of Criterion V of 10 CFR 50, Appendix B.
Discussions with the civil discipline engineers and the site project engineer disclosed that NCR's are dispositioned in a manner similar to field change requests, i.e, approval of NCR's which would result in a minor design change is approved on site by ESSE, while disposition of more significant NCR's is made after consulting with the home office. However, there does not appear to be a formal procedural requirement to consult the home office in disposition of NCR's.
The apparent lack of a QA procedure for processing of NCR's in ESSE was. identified to the licensee as Unresolved Item 389/81-04-01, " ESSE NCR Control Procedures", pending further review by NRC.
c.
QA Audits ESSE is audited by the Ebasco home office QA Audit group and the FP&L site QA organization.
The inspector reviewed audit number QAC-PSL2-80-42, and discussed the audit findings with the licensee's QA engineer who has responsibility for auditing the ESSE group. This audit, which was an indepth audit of ESSE, disclosed several procedural violations which were committed by ESSE in performance of design activities.
These audit findings are currently in progress of being resolved.
No violations or deviations were identified.
8.
Site Procurement, Receiving and Storage a.
General The bulk of equipment or materials received at the site are either NSSS
. supplied or Ebasco procured.
Site requisitioned items are primarily l
consumables, standard stock items and replacement items.
9 b.
Documents Examined (1) Requisition 115661 P. O. No. 31526-273885 (2)
Requisition 107531 P. O. No. 93540-231965 (3) Requisition 115382 P. O. No. 68921-269915 (4)
Requisition 115878 P. O. No. 79827-282175 (5) Requisition 150959 P. O. No. 05972-253385 (6) Requisition 113883 P. O. No. 82029-244825 (7) Site Quality Procedure, SQP-11 Procurement (8) Quality Procedure, Q P. 4.1, Control of Requisitions and Issuance of Purchase Orders for Spare Parts, Replacement Items and Services.
c.
Program Implementation The inspectors examined the above noted requisitions, purchase orders and controlling procedures.
Discussions were held with site QA personnel, site engineering personnel, warehouse QC personnel and warehouse personnel. A walk through inspection of the warehouse and storage facilities was performed.
The inspectors observed receipt inspection activities in progress and determined that the receipt inspectors had the appropriate receipt inspection checklists, specifi-cations, drawings, and purchase documents to perform this task.
The inspectors concluded that:
(1) The procurement documents examined included the applicable technical, QA, Code, Standards and 10 CFR 21 requirements.
(2) The materials were ordered from suppliers which are on the licensee's approved vendor list.
(3) The procurement documents specify packaging, handling, storage and documentation requirements.
10 (4) The receiving QC technicians have access to the procurement documents at the warehouse.
(5) Site personnel were knowledgeable of site procurement, receiving and storage policies, procedures and activities.
(6) The site receiving, inspection, nonconforming, tagging, storage, records and transfer activities are being handled in a controlled manner.
(7) Class A, B, C and 0 storage facilities have been established.
No violations were identified.
9.
Civil Construction Activities a.
Review of Civil Construction and Quality Control Instructions and Procedures The inspector examined specifications, instructions, and procedures to determine if work activities and quality control and quality assurance functions were provided for as stipulated in the FSAR and NRC require-ments. The following procedures and specifications were examined:
(1) Ebasco Specifications (a)
FLO-2998.471, " Excavation and Backfill" (b)
FLO-2998.473, " Concrete" (2) FP&L Site Quality Procedures (a)
SQP-2, " Concrete and Grout Placement" (b)
SQP-34, " Excavation and Backfill" (c)
SQP-35, " Structural Steel Erection" (d) SQP-45, "High Strength Bolted Field Connections for Structural Steel" (e)
SQP-46, " Fabrication of Class 1 Structural Steel" (f)
SWP-60, " Repair of Concrete Using Shetcrete" (3) FP&L Construction Quality Control Instructions (a) QI 10.2, " Batch Plant Inspection"
11 (b) QIl0.3, " Inspection of Placing and Consolidating Concrete" (c) QI 10.4, " Post-Placement Concrete Inspection" (d) QI 10.5, " Structural Steel Inspection" (e) QI 10.6, " Inspection of Concrete, Formwork, and Reinforcing Steel Installation" (f) QI 10.7, " Evaluation of Compression Test 1esults of Field Concrete" (g) QI 10.10, " Soils Testing and Surveillance of Excavating, Backfilling and Compacting Operations" (h) QI 10.11 " Inspection of Embed Items" (1) QI 10.70, "In-Process Testing of Concrete Materials" (j) QI 10.71, " Field Inspection of Structural Concrete" (k) QI 10.72, " Periodic Inspection of Concrete Production Facilities and Concrete Mixer Uniformity" (1) QI 10.77, " Testing of Reinforcing Steel Bars" In addition to the above specifications, procedures, and instruc-tions, the 50 Field Change Reports (FCR's) and 8 Design Change Notices (DCN's) applicable to either specification FLO 2998.471 or specification FLO 2998.473 were reviewed.
b.
Concrete Materials Receiving Inspection Program The Civil QC Group is responsible for performing receiving inspections on concrete materials (coment, aggregates, and admixtures).
The inspector examined FP&L specification COP-3-1,
" Batch Plant Operations", Ebasco specification FLO 2998.473, " Concrete", and FP&L Construction Quality Control Instruction QI 10.70, "In-Process Testing of Concrete Materials", to determine if the concrete materials receiving inspection activities were provideo for as stipulated in the FSAR and NRC requirements.
The inspector discussed the inspection requirements with civil quality control inspectors and batch plant operating personnel.
These indi-viduals were cognizant of the receiving inspection requirements for concrete materials. The inspector examined quality records pertaining to receiving inspection of concrete material. Records examined were as follows:
~
12 (1) Certified-Material Testing Reports for cement received on the project site in January and February 1981.
(2) Certified Material Testing Reports for coarse aggregate received on site in February 1981.
(3) QC Inspection Reports for January - February 1981, pertaining to receiving inspection of concrete materials (4) Audit Number QAC-PSL2-80-31, " Batch Plant Operations" c.
Observation of Work and Work Activities (1) The inspector observed placement of concrete in pour numbers 9, 10,15,18, part 19 and deck 11 in the diesel oil storage tank building and placement of concrete in strut numbers 530-F, and 54C-0 on the elevation 23 level of the reactor containment building.
Acceptance criteria examined by the inspector were procedures pertaining to concrete placement inspection listed in paragraph 9.a, and the following documents:
~
(a) Drawing number 2998-G-687 501 and 502, " Diesel Oil Storage Tank Foundation and Missle Protection STR-R-SH1 and SH2" (b) Drawing number 2998-G-495, " Reactor Building Interior Base Concrete-Plan-Masonry" (c) Orawing number 2998-G-497, " Reactor Building - Interior Base Concrete-Plan-Reinforcing - Sheet 1" (d)
Field Change Requests (FCR's) and Design Change Notices (DCN's) applicable to the above drawings.
(e) Ebasco specification FLO-2998.473, " Concrete, and FCR's and OCN's" applicable to this specification.
Forms were tight, clean and level..Rebar was properly installed and clean. Placement activities pertaining to delivery time, free fall, flow distance, layer thickness, and consolidation conformed to specification requirements. The inspector noted that concrete placement activities for the pours listed above were monitored by QC inspectors. Examination of the concrete batch plant indicated materials were being controlled and accurate batch records were being generated.
Storage of materials (aggregates, cement, and admixtures) were observed to be in accordance with specification requirements. Batch plant activities were continuously monitored by a QC inspector.
Examination of testing of plastic concrete and QC inspection
13 activities during these placements disclosed the following vio-lations: Quality Control Instruction QI 10.71 states that water is not to be added to any concrete batch after making in process tests for slump, air, unit weight and compressive strength.
Contrary to this requirement, water was added to concrete which was placed in reactor building struts 53 0-F and 54 C-D after making the in process tests for air, unit-weight, and compressive strength. The in process tests were not repeated after addition of the water.
In addition, following completion of the concrete placement, the inspector noted that craft personnel were carrying buckets of concrete away from the pour area to another area in the reactor building. Discussions with these individuals disclosed that the concrete was being used to repair a honeycomb area on the exterior surface of the primary shield wall at azimuth O*, elevation 36.
The inspector accompanied the craft personnel to this area to witness the concrete placement in the repair area.
Upon his arrival at the location where the concrete repair was being made, the inspector observed that no QC inspection personnel were present to inspect the concrete repair activities as required by Quality Control Instruction QI 10.4 The above two examples of failure to follow instructions and procedures, i.e.,
addition of water to concrete after making in process tests, and failure to inspect a concrete repair activity, were identified to the licensee as Violation item 389/81-04-02, " Failure to Follow Procedures in Performance of Civil Quality Control Inspections".
(2) The inspector examined the soils and concrete materials testing laboratory and the currentness of calibration of laboratory testing equipment. The inspector observed unconfirned compression testing of concrete cylinder numbers 6796 through 6798.
Quality Control Instruction QI 10.71, states that concrete compressive strength specimens are to be tested in accordance with ASTM C-39.
ASTM C-39 requires that the rate of loading during testing of the concrete cylinders be applied within the range of 20 to 50 psi per second. Observation of testing of the above concrete cylinders disclosed that the load was being applied in the range of C0 to 70 psi per second.
This was identified to the licensee as another example of failure to follow instructions and procedures as stated in Violation item 389/81-04-02.
(3) The inspector observed placement of reinforcing steel in the reactor building ring girder and in the elevation 96.5 roof (pour number FHB-9?) of the fuel handling builidng. Acceptance criteria examined by the inspector were QI 10.6 and the following i
l i
14 drawings, including FCR's and DCN's, which were applicable to them:
(a) Drawing number 2998-G-601-SH-1, " Fuel Handling Building Roof El 62 and El 96.5 - Masonry" (b) Drawing number 2998-G-601-SH-2, " Stay In Place Form Framing and Details" (c) Orawing number 2998-G-602, " Fuel Handling Building - Plan at El 72 and 96.5 - Reinforcing" (d) Drawing number 2998-G-511
" Reactor Building Dome Plan and Sections - Masonry" (e) Orawing numbers 2998-G-512 and G-513, " Reactor Building Dome Reinforcement - SH1 and SH2" The inspector discussed the in progress inspection of the rein-forcing steel with Civil QC inspectors.
The inspector reviewed inspection reports pertaining to the in-progress inspection of the reinforcing steel in the reactor buildng ring girder and the elevation 96.5 fuel handling building roof.
The inspector observed that the rebar placed in the above locations, as of the inspection date, conformed to specification requirements. Details examined by the inspector included bar size and grade, bar spacing, location of splices, and length of splices.
(4) The inspector reviewed the post-placement concrete inspection program. This program includes inspection of curing, inspection of form removal, inspection of concrete surfaces for defects (e.g., honeyco.nbs) and inspection of concrete repairs.
The inspector discussed the post placement inspection requirements with Civil QC inspectors.
Acceptance criteria examined by the inspector were Ebasco specification FLO-2998.473, and FP&L Quality Control Instruction QI 10.4.
The inspector reviewed the post-placement inspection reports for several concrete placements which had recently been made.
Discussions with Civil QC inspection personnel and review of the post placement inspection reports disclosed the following:
QC Instruction QI 10.4, requires that concrete surfaces be inspected after the concrete forms are removed and documented in Part III of the Post Placement Concrete Inspection Report (Attachment 1 to QI 10.4).
Contrary to this requirement, the post placement inspections had not been performed on pour numbers 4, 5, 6, 8A, 88,12 and 13 in the Olesel Oil Storage Structure and the fact that these inspections had not been performed was documented informally. This was identified to the licensee as another example
15 of failure to follow procedures as stated in Violation item 389/81-04-02.
d.
Review of Quality Records The inspector examined quality records pertaining to civil construction activities. Acceptance criteria examined by the inspector are those procedures listed in paragraph 9.a.
Records examined were as follows:
(1) Results of Class i fill stockpile qualification tests performed in 1979 and 1980.
(2) Results of relative density correlation tests performed on Class 1 fill in 1980.
(3) Results of In-Process tests performed on concrete placed in pour numbers 9,10,15,18, part 19 and deck 11 in the diesel oil storage tank building.
(4) Concrete preplacement inspection records for concrete placements listed in paragraph 9.c.(1).
Review of the relative density tests and qualification test on Class 1 fill disclosed the following unresolved item:
FCR 058 deleted the requirement of Note 2 to ASTM 01557, which calls for replacing the plus 3/4 inch material with #4 to 3/4 inch material in performance of modified proctor tests.
The inspector questioned the ESSE soils engineer concerning the engineering justification for deleting ?.is requirement from the test method. This information was not available on site since this FCR had been approved by the Ebasco New York office.
In review of the relative density test results, the inspector noted that the relative density tests were being performed using the dry method only. The relative density tests are performed in an off-site commercial. testing laboratory. The description of the test methods and the justifications for using only the dry method in the relative c
density tests were not available at the project site.
This was l-identified to the licensee as Unresolved Item 389/81-04-03, " Soil Testing Methods", pending further review by NRC in a subsequent inspection of modified proctor and relative density test results and procedures.
e.
Personnel Interviews l
The inspector conducted informal interviews with craftsmen, craft supervisory personnel, QC inspectors, civil area (field) engineers, and civil office engineers. These discussions disclosed that all personnel felt that there was good cooperation between craft, QC, and engineering personnel. Craft and QC personnel stated that technical assistance l
l
r 16 from engineering personnel'in resolution of problems and interpretation of requirements was available whenever they requested it. There did not appear to be any animosity or resentment between craft and QC personnel.
Craft personnel were aware of the requirements to do the work properly and recognized the importance of QC inspectors performing inspection of their work. QC inspectors stated that craft personnel and their supervisors cooperated with them when they performed their inspections, and corrected work which did not meet requirements when directed to do so by QC personnel.
The area and office engineers stated that they received assistance from design engineering personnel in resolution of problems whenever they requested it.
All personnel interviewed were aware that safety concerns could be carried to the highest level necessary to obtain satisfactory answers and resolutions.
f.
Conclusions The inspector concluded that, with the exception of the examples of failure to follow procedures discussed in paragraph 9.c, civil con-struction activities are being conducted on the site in compliance with NRC QA requirements. All personnel were knowledgeable of the need to perform, inspect and document all work properly.
There is good cooperation between craft, QC and engineering personnel in completing the work in accordance with project requirements.
QC personnel are knowledgeable of civil inspection requirements which they are certified to perform.
However, the inspector expressed concern to licensee site management personnel regarding the occasional failure of civil QC inspectors to pay close attention to inspection requirements and detailsas noted in the examples of failure to follow civil QC inspection procedures and instructions discussed in paragraph 9.c.
No deviations were identified.
- 10. Mechanical Construction Activities The objective of this portion of the inspection was to determine the adequacy of the licensee's mechanical construction activities.
For the purpose of this inspection, safety-related pipe supports and safety-related components were chosan as the specific areas to be inspected, a.
Design Control
~
(1) The on site organization is composed of several engineering offices that are responsible for the various facets of plant construction.
The day to day construction activities are per-formed under the technical cognizance of area engineers. The c
17 containment building, auxiliary building, turbine generator building and the other outside facilities each have area engineers assigned. Each area engineer has field engineers in the various disciplines; i.e.,
civil, mechanical, electrical.
Technical l
control of the field engineers is maintained by the Field Resident Engineer and the Senior Resident Engineer (SRE).
The Resident Engineer's office is comprised of various discipline engineers.
An onsite Power Production Engineering (EPP) office is also maintained by the licensee. The A/E maintains a Site Project Engineers Office (ESSE) to provide onsite liaison with the A/E's New York office. The Nuclear Steam Supplier (NSSS), Combustion Engineering (CE), also maintains a site representatives office.
(2) The control of construction activities is maintained originally by the issuance of specifications and drawings by the A/E. Changes to the drawings or specifications, identified by Nonconformance Reports (NCR) or Field Engineer observations, are originated by field engineers on Field Change Requests (FCR).
FCR's are sub-sequently evaluated by the discipline engineers and approved for transmittal to the A/E by the SRE. The FCR's are subsequently evaluated by the A/E's site organization, ESSE. When applicable design information necessary for the evaluation is not available on site, the FCR's are forwarded to the A/E's Design Office or, on urgent items, the A/E's design office is contacted by telephone.
(3)
For pipe supports greater than 2" IPS, B. F. Shaw Company and Bergen-Patterson provide the original design drawings. FCR's for these pipe supports are forwarded to both the A/E's design office and Bergen-Patterson. For pipe supports 2" IPS and smaller, ESSE provides the design drawings and corresponding design change action, when required.
(4) Several design calculations for 2" IPS and smaller pipe supports were inspected.
Design calculations for pipe support SI-89-R7 were specifically inspected for design input data, independent review, and completeness of design documentation.
FCR 2-26230, Revision 1, was inspected for compliance with design control requirements.
b.
Safety-Related Pipe Supports (1) Detailed fabrication drawings are provided by Bergen-Patterson or the A/E for each safety-related pipe support.
Ebasco Project Specification FLO-2998.099 provides the specifications for the l
fabrication and erection of safety-related piping and pipe supports. Site Quality Procedure (SQP)-16 Revision 1 provides' the pipe suport erection instructions. Quality Instruction (QI) 10.14 Revision 0, provides the quality control (QC) inspection procedure for pipe suppor,ts. A review of QI 10.14, Revision 0, revealed
r-18 that although the procedure requires verification that the erected pipe support assembly is in accordance with current approved drawings at the time of the inspection, a specific dimensional inspection of the erected pipe support components is not required.
In addition, it was also noted that QI 10.14, does not provide any verification that the as-built pipe supports are be in accordance with the final issued revision of the pipe support drawing.
(2) The following pipe suports were inspected for compliance with their respective drawings and Ebasco Specification FLO 2998.099:
Safety Injection System Pipe Supports SI-2401-310, SI-2407-40, SI-2412-31 Component Cooling System Pipe Supports CC-2063-22, CC-2063-7437, CC-2063-6421 The following items were noted:
(a) SI-2407 Revision 1 of the detailed pipe support drawing was used by QC for the Phase I inspection of the pipe support. Rev. 4 of the Drawing was on file and was used for the NRC inspection, Pc.4, a W6X15 x 3 foot long structural member, was not installed.
Pc.6, a rigid shock and sway arrestor, was required to be installed perpendicular to the wall.
It was installed more than 5 degrees off perpen-dicular. FLO 2998.099 allows a 3 degree tolerance. One of the fasteners for pipe attachment Pc.1 had been installed with insufficient thread engagement. None of the above noted conditions were identified on the QC inspection report. No record existed of an engineering evaluation of the above noted discrepant condition.
(b)
SI 2412-31, Rev. 3 - The drawing requires a 1/16 inch clearance between the top and both sides of the pipe and the box type pipe support.
FLO-2998.099 did not provide tolerances for this requirement. The inspected pipe support had no clearance on the west side of the pipe, 3/32 inch clearance on the east side of the pipe, and 3/16 inch clear-i ance on top of the pipe. The above noted conditions had not been identified by QC on the inspection report and no documentation of engineering evaluation was available on record.
An interoffice memorandum from the SRE to the Project QC Supervisor provided ESSE interpretation of the drawing, requirement. This. interpretation allowed any gap to a 1/16 inch maximum on top of the pipe and any combined gap on the side that would "be some fraction greater than zero".
This interpretation had not been documented on an FCR.
l l
O
19 (c) CC-2063-22. Rev. 2 - The detailed pipe support dra' wing required a 12 to 9 slope for structural member Pc.4 and a 1 to 1 slope for structural member Pc.5. FLOW-2998.099 did not provide tolerances for this requirement.
Pc.4 had approx-imately a 6 to 4 slope and Pc.5 had approximately a 5.3 to 4.6 slope. These conditions had not been identified on the QC inspection report.
No documented engineering evaluation of the noted condition was availabit.
The differences between the as-built Phase I QC inspected pipe supports and their corresponding detailed drawings appear to be a violation of 10 CFR 50 Appendix B Criterion V, as implemented by Florida Power and Light Company (FP&L) Topical Quality Assurance Report (TQR) 5.0, and shall be identified as examples of Violation 389/81-04-04, " Failure to Follow Piping; and Pipe Support Instal-lation Procedures and Drawings".
(3) The receiving inspection and storage areas for pipe supports were also inspected.
Identification of each pipe support was noted.
Segregation of nonconforming material was observed.
c.
Safety-Related Piping and Components Installation of portions of the Containment Spray, Main Steam and Safety Injection Systems in the Reactor Containment Building were observed. Installation of a portion of the Chemical and Volume Control System Piping in the Auxiliary Building was also observed. Fabrication and inspection of various safety-related piping assemblies in the fabrication shop was observed. The folloiwng items were noted:
(1) Valve 2500, a 3" IPS diaphragm actuated Fisher control valve, of the Chemical and Volume Control System, was being installed. the bottom nozzle of the valve had an internal 90* counterbore. the valve assembly drawing 52A86590 required the nozzle to have an internal 60 degree counterbore. This appears to be a violation of 10 CFR 50, Appendix B, Criterion V as implemented by FP&L TQR 5.0 and shall be identified as another example of Violation 389/81- 04,
- Failure to Follow Piping and Pipe Support Installation Procedures and Drawing".
(2) During asembly of 34" IPS Main Steam piping in the containment building, another NRC inspector noticed that the piping was being positioned by means of a jack. Further inspection by QC resulted in the pipe being released from its restraints and being verified to show no signs of cold springing. Additional inspection of Safety Injection (SI) piping in the containment building, and subsequent discussions with QC inspectors, revealed that SI pipe 458 had been installed and field weld 1 of the pipe was presented for fitup with the other end of the pipe known to be located such
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c 20 that fitup for field weld 2 would require either cold springing or other corrective action.
A QC inspector stated that he had identified the condition verbally to the mechanics and their supervisor but field weld (FW)-1 was made anyway, Subsequently, due to the misalignment of piping, SI pipe 458 was pulled into line and presented for fitup of FW-2. QC noted the condition and issued Nonconformance Report 1711M.
Subsequently, the pipe was released from restraints at FW2 and it returned to its original position, indicating that the pipe had not been cold stressed.
the NCR has not yet been dispositioned.
After the NRC inspector discussed this matter with site personnel, the licensee prepared a revision to SQP 47.
This revision provides a description of what constitutes cold springing for the benefit of craftsmen and inspectors.
It also provides instruc-tions on how to avoid cold springing by fitup of complete pipe runs, control of weld sequence, planning of swing pieces, and approved modification of spools.
(3) During an interview with Combustion Engineering (CE) site personnel, it was noted that CE had identified 8 Target Rock Valves, furnished to FP&L for specific locations, which had a potential for cracking of the discs and/or seats.
This deter-mination was based on similar conditions noted at another facility that experienced the cracking problem. EPP confirmed that CE had identified all applicable valves. However, EPP had not requested Ebasco to determine if similar problems could be experienced by other valves ordered by Ebasco for FP&L.
EPP subsequently committed to have Ebasco accomplish the review.
d.
Interview With Site Personnel Interviews were conducted with the SRE, discipline engineers, field engineers, ESSE engineers, QC supervisors, QC inspectors (US Testing Company), Union Boiler supervisors and foremen, and Union Boiler mechanics. The following items were noted:
(1) No adverse pressure on QC inspectors was noted.
(2) QC inspectors appeared to know the requirements.
However, a common comment was that the quantity of inspections required exceeded the number of QC inspectors.
Normally there were only two mechanical inspectors available per building during the day and one per building during the night. US Testing Company is in the process of recruiting inspectors and is attempting to correct the situation.
(3) Mechanical QC had approximately a 50% turnover rate in the last six months. US Testing conducted a survey to determine the causes but no difinitive corrective action was identified.
)
21 (4) The site engineering organization was complex and. involved FP&L, Ebasco and CE. However, the personnel involved generally appeared to be aware of their responsibilities and functioned accordingly.
The interface between the varied organizations involved appeared to be satisfactory.
e.
Conclusions The interfacing and coordination between the numerous groups (FP&L, Ebasco, CE, US Testing, Union Boiler) involved in the construction of St. Lucie Unit 2, appeared to be good. The engineers and QC inspectors in those groups appeared to be knowledgeable and competent.in the area of their responsibilities.
However, the number of relatively minor nonconforming conditions noted showed a lack of attention to details.
This trend, if left uncorrected, could lead to potentially more signi-ficant conditions. The lack of attention to details could possibly be attributed to an apparent shortage of QC mechanical inspectors.
FP&L has just completed a three month long indepth investigation to determine causes of high turnover rates.
This included numerous interviews with inspectors and craftsmen to determine working relationships.
Reportedly, the licensee found little problem in that area. The licensee has been recruiting very actively for QC inspectors and has reporting dates for about twelve.
11.
Electrical Construction Activities The inspector examined the construction activities and records related to the installation of electrical equipment. This inspection included exami-nation of procedures, observation of activities, discussions with craftsmen, engineers, QC inspectors, QA and management personnel.
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a.
References The following procedures were reviewed:
(1) Site Quality Procedure (SQP) 22, Cable Termination (2) SQP-24, Cable Pulling (3) SQP-26, Inspection Status Safety-Related Equipment during Plant Construction (4) SQP-53, Raceway Installation (5) SQP-54, Electrical Construction Testing (6) SQP-21, Corrective Actions (7) Quality Procedure 15.1, Control of Nonconforming Material, Parts or Components - Plants Under Construction b.
Electrical (Cables and Terminations I) - Observation of Work and Work Activities (1) Cable Installation and terminations i
r 22 The inspector observed the pulling operation of single and grouped cables. These cable pulls were accomplished both by hand and mechanical methods.
It was noted that during mechanical pulling operation, the readings of the stress gages were closely observed to insure that the pulling force did not exceed the predetermined (calculated) value. On one occasion, excess pulling force was applied.
The cable pull was stopped and a nonconforming report prep & red requiring an evaluation before the cables could be accepted for use.
It was deceided that cables would be removed and a different routing was developed to reduce the pulling tension.
During hand pul. ling operations, the QC inspector was always present. Additionally, on two occasions a QA inspector also was present preforming a periodic surveillance of the operation.
The inspector examined several cables that had been pulled and were being terminated.
The crimping tools in use had been inspected and calibration stickers indicating when the next inspection is due were attached. The inspector noted that the drawings in use were current.
During these observations it was noted that several cables were not completely pulled. The cables were tied in coils and sus-pended above the floor as required by procedures. In areas where welding activities were in progress, the coiled cables were wrapped in fire retardant blankets for protection.
Discussions with the QA staff, the QC inspectors, area engineers and craftsmen revealed that partial pulling of cables is permitted under certain conditions, the main reasons being economical. A check of records regarding five partially pulled cables revealed that all actions had been documented in accordance with SQP-24.
l l
The inspector was advised that no partial pulls could be resumed without contacting the electrical QC inspection group.
Due to the method of record keeping, if a pull was completed without proper QC coverage the deficiency would be identified and the cable nonconformed.
1 l
The inspector expressed concern that later in the project, the pressure to get cables installed would increase and some partially completed pulls may be completed without adequate QC inspection.
As a result of these discussions, a revision to QCI-24, to strengthen the QC notification requirement, was being prepared.
The inspector noted that termination verification was being made in accordance with SQP-22. However, cable continunity tests were being conducted af terward by the construction test crews in accordance with SQP-54. The licensee representatives advised the inspector that they were aware of this condition and expected to resolve the issue shortly. The inspector attended a licensee I
1
r 23 meeting regarding this condition during the inspection and con-cluded that adequate steps are being taken to resolve the problem.
Since the continunity testing program has yet to reach its peak, provisions for backfitting should not present a problem.
(2) Cable Tray Restraints During this inspection the inspector examined class IE cable tray supports in various areas.
The inspector was informed that in crowded areas the cable tray restraints had not been completed but were verified to be in compliance with the requirements of SQP-24, which requires that the restraints be adequate to support the weight of the cable trays and cables. The additional bracing that is required will be added after the cables are pulled, thus permitting better access to the cable trays during pulling operations.
The inspectors noted that a seismic cable tray restraint (1336) for 4 safety-related cable trays.had been modified to accomodate a non-safety related tray. There were no records requesting or giving authorization for the cutting of a diagonal brace to allow installation of a 90* cable tray fitting. The cable tray suppport had been inspected and accepted before the tray was installed.
1 This modification appears to be in violation of SQP-17, Design Control, which requires changes or deviations in design require-ments to be identified. This item is identified as 389/81-04-05, Unauthorized Modification of Seismic Cable Tray Support 1336. The licensee issued nonconforming report 1710-E immediately.
(3) Nonconfoming Reports The inspector reviewed approximately 50 closed electrical noncon-forming reports.
The NRC's cover a period of 18 months and covered various deficiencies.
Several involved drawing changes which, in each case, referenced a Design Change Notice (DCN).
Review of the drawings revealed that the DCN's had been listed I
against the applicable drawings in accordance with procedures.
Those NCR's requiring rework were properly closed in accordance with procedures. In all the NCR's examined, available information j
provided assurance that the disposition had been adequately reviewed and approved, and the corrective actions were inspected l
and accepted by the appropriate QC group.
l c.
Conclusions Within the areas inspected the inspector found one isolated case where procedures had not been followed. (Cited in paragraph b(2) above).
There were two areas of concern both related to procedures which are now being addressed by the licensee. It appears that the over all l
p 24 organization, while a combination of consulting, contracting and licensee personnel, is functioning in a manner that should product a quality product if procedures are followed and the existing cooperation continues.
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May 11, 1981 L-81-199 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:MDH, JJL, WPA St. Lucie Unit 2 Docket No. 50-389/81-04 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 truly yours,
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Robert E. Uhrig Vice President Advanced Systems & Technology REU/TCG/gw Attachment cc:
Harold F. Reis, Esquire
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a RII:MDH, JJL, WPA 50-389/81-04 A.
Violation (81-04-02) - Failure to Follow Procedures in Performance of Civil Quality Control Inspections 10 CFR 50, Appendix B, Criterion V, as i nplemented by FP&L Topical Quality Assurance Report Number 5.0, requires that activities affecting quality shall be prescreibed by documented instructions, procedures or drawings and shall be accomplished in accordance with these instructions, procedures or drawings.
Quality Control instructions were not being followed for con-crete inspection as described below.
A.
1.
Quality Control Instruction QI 10.4 requires that concrete repair activities be inspected.
Contrary to this requirement, no inspection was performed during placement of concrete in an area bging repaired on the exterior surface of the primary shield wall at azimuth 0, elevation 36, on March 12, 1981.
Resconse:
(Example 1) a.
FP&L concurs with the finding.
b.
The finding is attributed to unintentional communication mix-up between Construction Supervision and Quality Control.
c.
The Area Director was immediately notified by Quality Control of the by-passed Hold Point.
The newly placed concrete in the honeycomb area was washed and cleaned of fresh concrete.
d.
Construction supervision has been instruced in tne Quality Control Hold Point requirement for repairing concrete honeycomb.
e.
Full compliance has been achieved.
A.
2.
Quality Control Instruction QI 10.71 states that water is not to be added to any concrete batch after making in-process tests for slump, air unit weight and compressive strength.
Contrary to this requirement, water was added to concrete which was placed in reactor building struts 53 0-F, and 54 C-0 after making the in-process tests for air, unit-weight, and compressive strength.
The in-process tests were not repeated after addition of the water.
Response
(Example 2) a.
FP&L concurs with the finding.
b."
The concrete was sampled and tested in accordance with QI 10.71 require-ments.
That is slump, air content, unit-weight, temperature and cylinders were taken.
The slump obtained was 3h inches.
After these tests were performed, the Construction Supervisor decided to add additional weter.
Ten gallons were added and mixed in accordance with ASTM C-94 The con-crete was sampled again and tested for slump only.
The slump reached
7 RIT:MDH,JJL,WPA 50-389/81-04 P, age 2 3 3/4 inches.
The concrete QC supervisor was present at the test station and decided that further tests or taking cylinders were not necessary.
The QC Supervisor then initiated IR C-81-1496 and drafted an NCR for engineering evaluation.
The inspection report was dispositioned "Use-As-Is' Documentation of discrepancy was properly initiated in accordance with QI 15.1.
c.
Inspection Report C-81-1496 and a draft'NCR were issued by Quality Control.
The discrepancy was evaluated in accordance with CPL:QI 15.1.
d.
No further action is necessary to avoid further violations.
e.
Full compliance has been achieved.
A.
3.
QC Instruction QI10.71 states that concrete compressive strength specimens are to be tested in'accordance with ASTM C-39.
ASTM-39 requires that the rate of loading during testing of the concrete cylinders be applied within the range of 20 to 50 psi per second.
Contrary to this requirement, during testing of concrete cylinder nu'mbers 6796 through 6798, the rate of loading was applied in the range of 60 to 70 psi per second.
Response
(Example 3) a.
FP&L concurs with the finding.
b.
The finding is attributed to inattention to testing procedures.
The Concrete QC Supervisor instructed lab personnel to foad cylinders at c.
a rate of 1000 #/sec.
This instruction was issued immediately after the NRC Inspector questioned the correctness of procedure being used.
d.
The Concrete QC Supervisor monitors testing activities to insure complianc:
with ASTM C-39 requirements.
e.
Full compliance has been achieved.
A.
4.
QC Instruction QI 10.4 requires that concrete surfaces be inspected after the concrete forms are removed and be documented in Part III of the Post Placement Concrete Inspection Report (Attachment 1 to QI 10.4).
Contrary to this requirement, an informal method was used to document post placement inspections on pour numbers 4, 5, 6, 8A, 88,12 and 13 in the Diesel Oil Storage Structure.
Response
(Example 4) a.
FP&L concurs with the finding.
b.
The finding is attributed to inattention to procedure requirements.
RM:MDH, JJL, WPA 50-389/81-04 Page 3 c.
Quality Control reviewed the documentation and existing field conditions to determine extent of similar conditions.
The civil log was researched and the Post Placement Inspection Reports for the past six months were identified.
These reports date back to concrete placed on site since October 23, 1980 and total 138.
The concrete placements covered by these reports were re-inspected in order to verify that form work have been removed and that any concrete deficiency is properly documented.
- From, the 138 reports generated in the past six months, only six were found to have been closed before form work were completely removed.
The six reports were retracted from the QA Vault and are reopened in order to properly and completely document existing field conditions.
Two reports have been recently completed and the remaining four reports will be closed upon verification of forms removal and subsequent concrete repair, if necessary.
d.
The Concrete QC Supervisor was instructed to keep Post Placement Reports open until forms were removed or concrete repairs completed.
A Post Place-ment Log had been restablished previously and is being monitored by the Concrete QC Supervisor.
e.
Full compliance will be achieved following remaining form removal.
B.
Violation (81-04-04) - Failure to Follow Piping and Pipe Support Installation, Procedures and Drawings 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.
Pipe support and valve drawing requirements were not being followed as describec below.
B.
1.
Pipe support drawing SI-2407-40, Rev. 4, requires the installation of structural gember piece 4; requires the rigid shock arrestor, piece 6, be within 3 of perpendicular to the wall; and requires the installation of fasterners for piece 1.
Contrary to these requirements, piece 4 was not installed, piece 6 was installE at least 50 off perpendicular, and a piece 1 fastener had insufficient thread engagement.
This support had been inspected by QC and accepted.
Response
(Example 1)
The pipe support was installed and inspected in accordance with Revision 1 of the drawing.
The subsequent revisions to the drawing required a config-uration change which had not yet been constructed or inspected in accordance with the site programs.
Final accepteance of supports are verified prior to system turnover.
The revision number of the support detail used for inspection is verified to be current during Phase II QC inspection.
r,
-RN:MDH, JJL, WPA 50-389/81-04 Page 4 B.
2.
Pipe support drawing SI-2412-31, Rev. 3, requires 1/16" clearance between the box type pipe support and the top and both sides of the pipe.
Contrary to these requirements, pipe support SI-2412-31 had no clearance on the west side of the pipe, 3/32" clearance on the east side, and 3/16" clear-ance on top of the pipe.
This support had been inspected by QC and accepted.
Response
(Example 2) a.
FP&L concurs with the finding.
b.
This finding is attributed to inattention to engineering requirements.
c.
Nonconformance 1800M was written against this support.
d.
Construction supervision has been instructed to pay more attention to tolerances and engineering details.
e.
Full compliance will be achieved by July 1, 1981.
B.
3.
Pipe support drawing CC-2063-22, Rev. 2, requires a 12 to 9 slope for structural member piece 4 and a 1 to 1 slope for structural member piece 5.
Contrary to these requirements, piece 4 of pipe support CC-2063-22 had approx-imately a 6 to 4 slope and piece 5 had approximately a 5.3 to 4.6 slope.
This support had been inspected by QC and accepted.
Response
(Example 3)
The location of the hanger, including diagonal bracing is within design engineering approved tolerances.
In making the last revision to the hanger detail drawing, the vendor revised the bracing dimensions but neglected to recalculate the resulting slope.
The vendor is being notified in writing to review dimensions for consistency to avoid possible confusion.
B.
4.
Fisher control valve drawing 2998-2584, Rev. 3, (052A86590) requires chemical and volume control valve 2500 to have 60 internal counterbore on the valve nozzles.
Contrary to this requirement, valve 2500 had a 90 counterbore on the bottom nozzle.
Resoonse:
(Example 4) a.
FP&l, concurs with the finding.
b.
Inspection of similar valves not yet installed show this example to be a supplier originated problem not picked up at receipt inspection.
r -
Riq:MDH,JJL,WPA 50-389/81-04 Page 5 c.
General Inspection Report RG81-04 was written to authorize Combustion Engineering to investigate the significance of this problem.
A total of three valves were found where the weld ends which are part of the flange bolted to the bottom of the valve body are not in conformance with the drawing.
They are counterbored to a 90 degree shoulder trans-ition.
d.
Combustion Engineering will determine what actions will be taken with Fisher Controls to avoid further violation of this type, e.
Full compliance will be achieved by July 1, 1981.
C.
Violation (81-04-05) - Unauthorized Modification of Seismic Cable Tray Support 1336 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be performed in accordance with established procedures.
FP&L QA Topical Report supplements this requirement and established Site Quality Procedure 17, Design Control, which requires changes in design requirements to be accomplished through field change requests.
Contrary to the above, the requirements of SQP-17 were not met in that Seismic Class I cable tray restraint 1336 was modified to permit installation of a non-safety-related cable tray without a field change request being prepared.
Response
a.
FP&L concurs with the finding.
b.
The finding is attributed to inattention to job detail and drawings.
c.
NCR 1710E was prepared to authorize removal of the horizontal brace and fabrication and installation of a new brace with its connection at the west end moved to clear the interference.
d.
To avoid further violtations, this condition and corrective action taken was discussed in a staff meeting with the Area Directors.
e.
Full compliance has been achieved.
NRC CONCERNS 1.
NRC Civil Inspector expressed concern to licensee site management personnel regarding the occasional failure of Civil QC inspectorsto pay cloe attention to inspection requirements and details as noted in the findings naed.
Quality Control Civil supervisors and inspectors have been briefed on the need to pay attention to details and requirements delineated in the Quality Instructions.
Quality Control supervisors have been instructed to monitor this concern closely.
n.
-c Ril:MDH, JJL, WPA 50-389/81 '
Page 6 2.
The NRC Mechanical Inspector expressed concern that CPL:QI 10.14 does not require specific dimensional inspection of erected pipe support components nor does the procedure provide verification that as-built pipe supports are in accordance with the lastest revision of pipe support drawings during Phase II.
In this regard, a revision to CPL:QI 10.14 has been prepared and is currently in the review cycle to incorporate the requirement for dimensional checks to the latest drawing revision during Phase II inspections.
Also, a task force comprised of engineering and QC personnel has been formed to double check for final revisions during Phase II to assure compliance to the stress calculations.
3.
The NRC Mechanical Inspector expressed concern that site quality procedures and quality control instructions did not adequately describe how to avoid cold springing of piping.
Following discussions with the NRC Inspector, SQP-47 was revised to provide a description of what constitutes cold springing and instructions to craftsmen and inspectors on how to avoid this potential problem.
4.
The NRC Inspector noted that Power Plant Engineering had cor. firmed that the NSSS supplier had identified all applicable valves with a potential cracking problem as part of the investigation of a License Identified Item.
- However, EPP had not requested the Architect Engineer to determine if similar problems could be experienced in their valve orders.
The checklist used to documenc Construction Site Group review meetings to determine if a deficiency is ootentially reportable has been modified to add contacting the A/E or NSSS as necessary.
This action should prevent future occurrences of this nature.
5.
The NRC Inspector noted that the number of relatively minor mechanical non-conforming conditions also showed a lack of attention to detail and if left uncorrected could lead to potentially more significant conditions.
Quality Control Mechanical Supervisors and Inspectors have been briefed on the need to pay attention to details and requirements delineated in the Quality Instructions.
Quality Control Supervisors have been instructed to monitor this concern closely.
In addition, significant progress has been made by U. S. Testing in recruiting additional qualified inspection personnel and a continuing effort will be maintained to assure adequate staffing levels.
6.
The Electrical NRC Inspector expressed concern that later in the project, the pressure to get cables installed would increase and some partially completed cable pulls may be completed without adequate QC inspection.
SQP-24 is being revised to strengthen the OC notification requirement for partial pulls.
Approval of this revision is anticipated by June 1,1981.
7.
The inspector noted that termination verification was being made in accordance with SQP-22.
However, cable continuity tests were being conducted afterward by Construction Test in accordance with SQP-54.
m.
-/, ALI:MDH, JJL, WPA 50-389/81-04 Page 7 A letter of understanding is being prepared by Construction Test, stating that cable continuity tests and verification that cables are terminated to the CWD w ll be documented on the Control Cable Checklist.
Upon receipt of i
a copy of this checklist, Quality Control will perform their termination verification in accordance with SQP-22.
This program will be in effect by June 1, 1981.
8.
The NRC Inspector was concerned that an interoffice memorandum from the SRE to the PQCS provided ESSE interpretation of drawing requirements for pipe support clearances.
This interpretation had not been documented on an FCR.
To provide complete clarity, FCR 2-3643 has been issued to:
(1) document design engineering approval of the tolerance and (2) spell out the toler-ance which can be understood.
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- f..Wr STATE OF FLORIDA
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COUNTY OF DADE
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Robert E. Uhrig, being first duly sworn," deposes and says:
That he is a 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.
_Jb-Robert E.
Uhrig Subscribed and sworn to before me thic
/ical. day of 19//
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NOTARY PUBLIC, in and for the county of Dado,
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State of Florida Norm n:u: cm: :s r_&cs a v, t MY C:f.!?.9.33iCU $/f t".i$
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My commission expires:
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