ML20137K771
| ML20137K771 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/30/1996 |
| From: | FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17354B293 | List:
|
| References | |
| FOIA-96-485 QSL-PM-96-22, NUDOCS 9704070097 | |
| Download: ML20137K771 (47) | |
Text
..-. . .. _ - . . _ - - . . . .- - . . . - - . - - - - - - - - - - . . . _ . . - . - . . . _ _ _ - --
9
!4 l' .s' FPL Nuclear Division
{ p Quality Assurance Audit Report '
l i
i i
l i
j MONTHLY PERFSRMANCE MSNITSRING AUDIT (SL-PM-96-22 s
l October / November,1996 i
l 1
HAFT l
l Audit Team: '
L. Bearrer B. Lewery L. Neely i
C. Norris
, J. Walls L. W. Blaaew (A - PSL
'\
/
9704070097 970325 PDR FOIA BINDEP'6-485 PDR
0' AUDIT REPORT pg QSL-PM-96-22 Page 2 of 30 Table of Contents i
Executiv. Fummary .. .
. 3 Operations .. . .. . . .
6 4
PMON 96-060 - Post Accident Sampling System .
6 PMON 96-061 - Radwaste Shipping .. .. . .. 7 PMON 96-062 - Offsite Dose Calculation Manual . . . 8 j PMON 96-065 - In-Plant Radiciodine Monitoring .
9
- Maintenance . . ..
10 PMON 96-064 - Freeze Protection . 10 Services / Engineering .. .. . . . .... .. . .. .. .. 11 PMON 96-044 - CR/PMAI Corrective Action Closecut Process . . . ....I1 i PMON 96-056 - QA Programs /Mgmt Controls Functional Area Evaluation .. I1 PMON 96-063 - October / November Admimstrative Review . . . 12 l 4
Summary ofIndependent Technical Review (ITR) Activities . . .. . x Findings . . . ... . . .. .. . ... .. . .. . . .. .. ... x Finding 1 - . . . . . . . .. x Finding 2 - . . .. . .. . . . . .... x Finding 3 - .
... . ... . . . . .....x Audit Participants . . . .. . .. . . .. .... .. . . .x O
)~ /
AUDIT REPORT ppt QSL-PM-96-22 Page 3 of 30 Audit Location: St. Lucie Plant Date of Audit: October-November,1996 -
Audit Scope: This audit is an evaluation of activities affecting quality, and provides verification that those activities are conducted in accordance with appropriate controls and requirements. Performance Monitoring was conducted for selected plant operating, maintenance and services activities to provide objective evaluation and qualitative verification that activities are being performed in accordance with specific technical and quality requirements.
Executive Summary:
_ Rerformancclnonitoring summaries for evaluations completed during October and November 1996 are included in this report. Actit..ies in the areas of plant operations, maintenance, and site services were evaluated:
The results of these evaluations indicate continuing weakness in the area of plant adminis'rative controls. Lack of adequacy in necessary procedures, coupled with lack of knowledge of applicable requirements, have combined to create situations in which non-
, compliance is both repetitive and, in some cases, significant.
Operations Results .
Operations activities were reviewed, both for procedure compliance on a real-time basis, and in program areas associated with Post-TMI and effluent monitoring programs. No significant discrepancies were identified during either type of observation.
Condition Reports The following Condition Reports, issued by QA and QC outside the scope of PMON activities during the months of October and November, desenbe problems in maintenance
, work control and continuing weakness in the implementation of administrative controls. A smaller number of Condition Reports was issued in the area of maintenance work control during this period than during previous months, and may be indicative of an improvement in this area.
.( AUDIT REPORT pg QSL-PM-96-22 Page 4 of 30 l
1 l
l Maintenance Work Control CR 96-2551 Several irregularities were noted in the work and documentation associated with NWPO 69/5085 "1B Fire Pump Casing Degraded - Repair or Replace" i
l CR 96-2206 2A GCW heat exchanger 1) No FME installed 2) Metallic scraper utilized on coated surface 3) Exceeded the maximum time of I minute 15 seconds for hydro-lazing tubes by 15 to 20 seconds l Imnlementation of Administrative Controls CR 96-2454 During UFSAR Chapter 17 review (TQAR Review) it was noted that plant and Engineering instructions do not require inclusion of specified statements in purchase orders CR 96-2564 Temporary changes to procedures are issued without the total number of affected pages identified. The implementor of a TC cannot be cenain that the TC is complete unless the total number of pages of the TC is known.
CR 96-2510 Review of procedure revisions at PSL is not in compliance with TQAR requirements.
CR 96-2700 An informal program called "FRG Hold" is being used to control procedure issuance for formal procedure requirements.
. Findings 1.
Site procedures do not adequately address the storage, accountability, and inventory requirements for required freeze protection equipment.
- 2. Corrective action for a previous Finding on overdue periodic reviews was inadequate in that, following corrective action for the Finding, an additional
' sixty five procedures did not receive a periodic review within the required time frame.
AUDIT REPORT FPL QSL-PM-96-22 Page 5 of 30
- 3. Existing admin 62rative processes and knowledge of these processes are not adequate to bring about required inspections and properly disposition Quality Control hold points.
l l
l 1
e e
- /
AUDIT REPORT p:PL.
QSL-PM-96-22 Page 6 of 30 Operations:
j PMON 96-060 was performed to review the Post Accident Sampling System (PASS) program as described in Unit 1&2 Technical Specification 6.8.4.e. This program review concluded that the training of personnel, procedures for sampling and analysis, and provisions for maintenance of sampling and analysis equipment are adequate.
Review of the training program resulted in no deficiencies noted. The initial training program for PASS provides adequate training in accident chemistry considerations and PASS operation. Review of the re-qualification program verified that each chemistry technician is performing an operability exercise of the PASS on both units and completing an exam on accident chemistry considerations wi'hin a two year period.
Review of PASS procedures for sampling and analysis was performed. Several types of procedural inadequacy were identified, such as steps with multiple tasks to be performed, valve identification contrary to the nomenclature used on the P&lD or in TEDB, and lack of provisions for necessary !
sign-offs and/or independent verification. In this connection it is noted that Condition Reports 96-1975 and 96-1991 had already been generated as a result of the mis-operation of the Unit 1 PASS l on August 12,1996 during an incident in which in the Unit 1 Containment Radiation Monitor was j
inadvertently valved out of service. A contributing factor to the problems documented in these '
CR's was procedural inadequacy. As a result of the disposition of these CR's, new procedures were being written at the time that this PMON was performed. Separate procedures were being written for operability testing, accident sampling, fill and vent. and calibrations. Based on the corrective actions taken for the Condition Reports and review of the new procedures, it has been determined that the new procedure.s for analysis and sampling are adequate.
Review of the provisions for maintenance of PASS sampling and analysis equipment resulted in one discrepancy. Chemistry Procedure C-02, Rev. 27, " Schedule for Test Calibrations", requires that the PASS boron meter be calibrated every 18 months. Review of chemistry records, procedures and discussions with Chemistry Department supervision indicated that this calibration was not occurring. Condition Report 95-2375 was generated by QA to document the problem ofcalibration not being performed on the boron meter. This is in conflict with the instrument calibration frequency of Table 9.310d of the Unit 02 FSAR. Initial discussion with Chemistry department personnel indicated that their preference is to take a grab semple and perform boron analysis at the chemistry hot lab. This does not however permit the requirement for calibration of the boron meter
, to be discounted until a change to the FSAR is performed with proper reviews. Chemistry supervision indicated they will add this to the PASS operability procedure for Unit 02 and request a FSAR change to allow for uu abandonment of the boron m:ter.
.I AUDIT REPORT ppt QS L-PM-96-22 Page 7 of 30 Review of the maintenance work history revealed no outstanding issues with regards to the preventative or corrective maintenance of the PASS system components. Walk down of the PASS system components resulted in no unidentified discrepancies.
The NRC identified that the PASS is one of the systems that should be within the scope of the Maintenance Rule as discussed at the September 20.1996 exit. In addition. at the September 13.
1996 exit, the NRC commented that the mis-operation of the PASS on August 12.1996 warranted future evaluation and is being tracked as a URI.
Review of five condaion reports miating to the PASS resulted in t'he assessment that adequate l corrective action was performed to address the discrepancies identified in the Condition Reports. l Performance Monitor: L. W. Neely PMON 96-061 was performed to evaluate selected areas ofradioactive material / waste shipping. The
. PM_ON activity began with a review of HP-40. Rev. 40 " Shipment of Radioactive Material". This procedure, coupled with several other procedures, contains the requirements associated with the program for shipment of radioactive material at St. Lucie.
Topics verified to be adequately addressed by HP-40 were: labeling and marking requirements, placarding, advanced notifications, shipping paper documentation, loading / storage of packages, and package and conveyance surveys. In addition. requirements for the use of QC hold points to inspect
~ the p eparation of shipments were reviewed and found to be satisfactory. Inadequate hold points had been previously identified in Audit QSL-OPS-94-13. Finding number 3. The present review included verification that corrective action for this finding remained in place. The preceding items were found to be properly addressed in HP- 40.
An observation of a Radioactive Material / Waste Shipment ( 96-63 ) was conducted during the course of the PMON. The shipping pcpers were reviewed and the transport was walked down prior to shipment. Aspects reviewed, were found to be in accordance with the requirements of HP-40. Items verified included: HP-40 checklist with hold points being signed as accomplished, placards on j transport, labeling of containers, weight marked on container and load secure on transport.
Records of four other radioactive material shipments were reviewed and found to be in compliance
, with applicable requirements from HP-40. In addition, training records for two QC inspctors were reviewed against 49 CFR 172.704 " Training Requirements", of part 172 of the Code of Federal Regulations titled " Hazardous Materials Table, Special Provisions. Hazardous Materials
9
/ AUDIT REPORT FPL QSL-PM-96-22 Page 8 of 30 Communications. Emergency Response Information, and Training Requirements".The five required elements for record keeping in this area were found to be present in the applicable training folders.
Areas and activities observed and documents reviewed during this PMON were evaluated as satisfactory.
J Performance hionitor: J. Walls PM 96-062 was performed to evaluate compliance with the requirements pertaining to the PSL Offsite Dose Calculation Manual (ODCM). This review centered around changes to the ODCM and to implementing procedures. Audit of the ODCM and implementing procedures is required by Technical Specification 6.5.2.8.i.
Technical Specification 6.14 provides requirements concerning the processing of ODCM changes.
At PSL. the ODCM is issued and controlled as Chemistry Procedure. C-200. "Offsite Dose Calculation Manual" ODCM changes are processed as changes to C-200 and routed to the Facility Review Group as part of the normal procedure change process. The following ODCM changes were processed during the two year period covered by this PMON:
Revision 16, implemented on January 26,1995. The purpose of this revision was to provide monitoring ofinstrumentation at an increased frequency when the Control Room alarm annunciation is inoperable for a radioactive effluent instrument channel. This revision will provide a h;gher level of protection by requiring hourly channel checks of effluent monitors as an altemative to performing a single grab sample per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
Revision 17, implemented on May 30,1995. This revision permits the data used for the
' biennial re-evaluation of the gaseous intake pathway to based on a period of one year or longer (to include a refueling outage), rather than a six oonth period. The revision should provide consistent dose evaluations based on all plant conditions and end the previous situation in which revisions to ODCM defined intake pathway constants were affected by whether or not there had been refueling outage in the last six months.
Technical Specification 6.14 contains specific requirements with respect to the review and documentation associated with the ODCM changes discussed above. Records to support these changes were reviewed in the site QA Records Vault, and were found to be satisfactory. Changes
, to the ODCM are required to be submitted to the Nuclear Regulatory Commission in conjunction with the Annual Radioactive Effluent Release Report. The 1995 Annual Radioactive Effluent Release Report was verified to contain the required information and have been submitted in accordance with Technical Specification requirements.
l
/
AUDIT REPORT ppt QSL-PM-96-22 Page 9 of 30 1
Requirements contained in the ODCM are primarily implemented by procedures C-70. " P Aetated Liouid Wastes" and C-72 " Processing Gaseous Wastes" During the period covered bI review, the , wing revisions to these procedures occurred.
l C-70, Revision 31, was changed to add a reference to COP-65.02, "Efiluent Grab Samp and to add the performance ofliquid monitor source checks.
C-72 " Processing Gaseous Waste" was revised 3 times during the period for items such as QA review of program and to make provisions for using a more detailed method of provid historical monitor data.
A new procedure, COP-65.85 " Process Monitor Setpoints",was prepared. This procedure improves documentation of the methodology and calculational methods associated with the setpoints established for site effluent monitors.
The revisions discussed above did not adversely impact compliance with ODCM requirements.
l Review of the implementation of COP-65.85 will be performed as a future surveillance activity. l Performance Monitor: J. Walls PMON 96-065 was conducted to verify implementation of the program for In-Plant Radioiodine Monitoring. This program is required by Technical Specification 6.8.4.b. "In-Plant Radioiodine Monitoring" and derives from a commitment originating in Item II.F.1 of NUREG 0737,
" Clarification of TMI Action Plan Requirements". The verification was conducted through review of records, review of procedures and discussion with plant personnel.
A review was pe-formed of 1996 training records for required personnel which included 39 members of the Health Physics Department. There are future training classes planned for additional person The applicable Lesson Plan, 2402008, Rev. 7 " Emergency Radiation Team Training " was reviewed and compared to approved plant procedures and found to be satisfactory.
Implementation of the monitoring process b found in plant procedures HPP - 22 Rev. 6," Air Sampling " and HP - 205, Rev. 6 " Emergency In- Plant Air Sampiing " It was also found that additional procedures are available to support the maintenance and calibration of required
, instruments. The conduct of this activity was found to be satisfactory.
Based upon the information reviewed, implementation of the In-tilant Radiciodine Monitoring Program is evaluated as satisfactory.
l i
/ AUDIT REPORT ppt QS L-PM-96-22 Page 10 of 30 Performance Monitor : J. J. Walls Maintenance:
PMON 96-064 was initiated to verify site compliance with AP 0005753. Rev. I 8. section 8.1. " Cold l
Weather Preparations and Precautions" The absence of actual cold weather conditions prevented a walkdown to verify the implementation of the following checklists-Checklist 17. " Operations Pre-Cold Weather Checklist" Checklist 18. " Operations Cold Weather Checklist" Checklist 19. " Maintenance Department Pre-Cold Weather Checklist" Checklist 20. "I&C Cold Weather Checklist" l
In the cbsence of a walkdown to verify actual implementation, this audit concentrated on verifying the availability of freeze protection equipment. the adequacy of procedural guidance and corrective actions for issues identified in the previous examination of this area (PMON 95 076).
Corrective Action Review STAR 96-0128 - This STAR identified that Data Sheet 3, " Temporary Hose InsW'.ation /
Restoration" , of AP 0005753 had not been filled out in accordance with Checklist 19, " Maintenance Department Pre-Cold Weather Checklist". When this discrepancy was identified, the hose installation process was a joint effort between Operations and Maintenance personnel. The Maintenance personnel performing the hose installation did not know where Data Sheet 3 was located. Corrective action for the STAR generated a Procedure Change Request (PCR) which combined Data Sheet 3, and Data Sheet 2," Valve Position"into a single Data Sheet. Revision 18 of this procedure contains Date Sheet 2 which incorporates the required changes.
STAR 96-0326 - This STAR was generated by a walk down that identified the absence of heat tape on instrumentation listed in Checklist 20 of AP 0005753. Revision 15 of this procedure specifically instructed personnel to install heat tape and gave no provisions to bypass this step for instruments that are.already protected by insulation. A PCR was generated and the checklist was modified to read," Verify insulation is installed or install heat tape for cold weather preparation for each unit."
, Revision 18 of this procedure contains the modified checklist.
Eauinment Storace. Condition ard Availability:
AUDIT REPORT ppt, QSL-PM-96-22 Page 11 of 30 Per procedure. eleven kerosene heaters are required for deployment during cold weather conditions.
Twelve heaters are stored in the F4 warehouse and, in general appear to be in good condition. No preventive maintenance is accomplished beteen usage periods. Problems are identified and corrected when heaters are tumed in or. as an altemative, the heater is tagged out for repair at a later date.
All heater fuel (kerosene), is purchased PC3 (Quality Related), because of an altemate potential use as a cleaning solvent on safety related equipment. Nuclear Materials Management (NMM) maintains a minimum of 2 drums and a maximum of 4 drums assigned to the Stores Department on site. At the time that this PMON was performed there were three untapped 55 gallon drums in Stores. One other drum is set up and 'wed for use. There are 2 additional drums marked NIS.
"Not In Stores" These drums are signed out to the Maintenance Department and can consist of kerosene drained out of the heaters prior to their storage in the warehouse. The kerosene in these drums is available for use in the heaters, as is the designated PC3 kerosene. It was noted that Checklist 19 requires Maintenance to verify heater fuel supply and make arrangements through '
NMM for additional supplies if necessary. By procedure, this is usually accomplished 16 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior toJhe onset of cold weather conditions.
I&C maintains extension cords, drop lights and heat tape specifically dedicated for use in the freeze ;
protection plan. At the present time they also maintain approximately 70 new 4 foot heat tapes in excess of those required by Checklist 20, "I&C Cold Weather Checklist", in case of additional need or as potential spares for the stored. previously used material. Interviews revealed that, in the l absence of procedural guidance, personnel were operating on their own initiative to maintain an l
4 adequate stock of material to implement the requirements of Checklist 20. I&C had previous plans !
in place to pre-identify storage locations for power sources and the lengths of extension cord needed for each item designated in the Checklist. However, the two personnel who were assigned this task are no longer employed by FPL. This was a very good idea. It would shorten the time required to deploy the freeze protection equipment and considerably maximize personnel time and effort. It is recommended that work should proceed in this effort.
AP 0005753, Rev.18, Checklist 17 " Operations Pre-Cold Weather Checklist", directs operations to station electric space heaters in the C AFW pump area to maintain AFW pump oil temperature at or above 70 degrees F. Interviews with F4 warehouse personnel revealed they were aware of three electric' space heaters, of which one was broken and two were checked out. Personnel indicated there is no procedural guidance specifying a set number of heaters to be dedicated for freeze
. protection deployment. Personnel also indicated that they were in the process of performing a complete warehouse inventory which would probably identify additional space heaters available for use.
~
/
AUDIT REPORT ppt, QSL-PM-96-22 Page 12 of 30
Conclusion:
The lack of procedural guidance delineating required inventory and accountability requirements.
limits the plants ability to efTectively organize and prepare for extremely cold weather conditions.
' It also interjects the possibility of limiting conditions. (i.e... lack of material), that could conceivably hinder plant efforts in locating and deploying its freeze protection equipment. This problem is discussed further in Finding 1 (see below).
Performance Monitor: B. Lowery Services / Engineering:
PMON 96-044 examined the closure process for a selected sample of Condition Reports and associated PMAl's generated to implement and track corrective action completion. One STAR. four Condition Reports and numerous Change Request Notices. (CRN's), Document Change Requests'.
(DCR's) and PMAl's were evaluated.
Star 960210 was written to review NRC discrepancies identified during a system walkdown of the Unit 1 Instrument Air System. and to provide corrective actions for the NRC noted items. This STAR generated two CRN's, one DCR, one OPS Procedure Change Request. (PCR) and several PMAl's. An examination of a sampling of these documents and affected procedures and drawings did not identify any problems in the corrective actions completed.
Four Condition Reports and twelve resulting PMAl's were also reviewed. All corrective actions taken were identifiable and traceable. All actions associated with changes to procedures, procedure development or work to be performed were verified _to be complete.
Condition Report 96-551 identified the following condition:
" Unit 1 RAB pipe penetration room to RCB purge plenum fire barrier was breached by 2.
10 inch unattended holes, which were created to implement PCM 01-196. These holes bring into question the design basis operability and compliance of the fire suppression system and the ECCS exhaust ventilation system. Reference IHE 96-034."
This CR along with the accompanying engineering evaluation generated 7 PMAl's to track the
, necessary corrective actions. PMAI PM96-05-122 was initiated and assigned to Operations to review the circumstances of this breach approval by the ANPS for procedure non-compliance.
Attachment 1 of this PMAI effectively answered the condition addressed. However, the last paragraph of the response stated the following:
~
1 l
/
AUDIT REPORT FPL QSL-PM-96-22 Page 13 of 30 "A Condition Report will be generated to evaluate the following:
a.
Method to determine whether an operable fire detection system exists on at least one side of the fire barrier.
b..
What personnel will be accountable to determine (a) above?"
The intent of this PMAl was to review the circumstances involved during implementation of PCM 01-196 and determine if procedure non-compliance was an issue. Items ( A) and (B) were addressed by PMAI PM96-05-123, which was closed on 8/15/96. Operations management was informed that the last paragraph was misleading and at the suggestion of QA agreed to issue a CR supplement clarifying the response. The supplement was generated and issued on 9/25/96.
Additional examination of the Condition Report process is being performed by QSL-CA 96-020,
" Corrective Action Functional Area Evaluation", which is currently in progress.
Performance Monitors: S. Mead, B Lowery PMON 96-056 was conducted to verify the implementation of QA Programs and Management Controls at St. Lucie Plant. Areas reviewed included Unit 1 and 2 Technical Specifications, Section 6.0, " Administrative Controls", and Section 2.1, " Safety Limits". Also reviewed was the implementation of various Sections of the FPL Topical Quality Assurance Report (TQAR) that applied to the audit topic. A review of corrective actions initiated by QA Audit QSL-OPS-94-24,
" Performance Monitoring Activities for October 1994", PMON 94-105 "QA Programs and Management Controls" the previous PMON in this area, was also accomplished.
PMON 94-105, Finding 2, identified a lack of timely periodic procedure reviews as required by Tech Specs. It was found that a problem still exists in this area. During the period that the present PMON was conducted, Information Services (IS) personnel self-identified sixty five procedures that were bey ad their required periodic review date. Condition Report (CR) 96-2531 was issued to document this problem and initiate the following two changes:
- 1) A change was made to Q15-PR/PSL-1, " Preparation, Revision, Review / Approval of Procedures", to improve the process of periodic reviews.
- 2) A monthly status report of upcoming required periodic reviews sent to responsible Department Heads was created.
. This revised approach taken by IS personnel recently made responsible for this process is expected to prevent similar discrepancies in the future.
AUDIT REPORT p:pt QSL-PM-96-22 Page 14 of 30 Finding #2 (see below) was written to address the inadequacy of the corrective action taken with respect to the previous Finding in this area. This is based on the fact that not only are there still overdue reviews, but their number has more than doubled since the last PMON addressed this issue.
A recent Amendment to Tech. Spec. 6.1.2 now requires that the Site Vice President. rather than the l
President - Nuclear Division issue a management directive annually to address the Shift Supersisor's !
Control Room command function. A directive was issued 9/20/96 to comply with the requirement.
Offsite and onsite organization procedures, policies, and charts were reviewed to ensure compliance with Tech. Spec. and TQAR requirements. This included defined lines of authority, responsibilities, and communications extending from the President - Nuclear Divi: ion through intermediate levels down to and includmg all operating organization positions. Although recent site organization changes have realigned the Operations Support Engineering Group, made up of the STAS, Reactor Engineering, and System Performance into the Site Engineering Organization, the following i procedural requirement has been added to QI l-PR/PSL-1, " Site Organization", paragraph 5.2.4.
"The Plant General Manager shall have direct unfettered control over those OSE resources l necessary for the safe operation and maintenance of the plant" l l
This statement is evaluated as providing compliance with a similar requirement contained in Tech.
Spec. 6.1.1.
Minimum unit staffing requirements were found to be properly proceduralized and implemented.
A weakness identified in PMON 94-105 regarding the Tech. Spec. requirement for continuous Health Physics Technician on-site coverage not being proceduralized, has been addressed by a change to HPP-4," Scheduling of Health Physics Actiyities", which addressed this requirement. All other areas of Organization and staffing reviewed were found to be acceptable.
Overtime guideline discrepancies recently identified and documented in findings associated with Quality Assurance Performance Monitoring audits QSL-PM-96-08 and 018 have been addressed by necessary corrective actions.
The PSL procedure program was reviewed and a selected sample of Tech. Spec. requirements was found to be adequately addressed. The temporary procedure change (TC) process was evaluated.
Previous QA identified problems in this area have been corrected. The total number of TCs being
. written has been reduced by approximately two thirds. The activities of the Site Facility Review Group (FRG) were found to be in compliance with Tech. Spec. requirements. The October 1996 FRG minutes were reviewed which documented the satisfaction of requirements for membership, frequency of meetings. quorum, and Plant General Manager's approval of agenda items.
/
AUDIT REPORT ppg QSL-PM-96-22 Page 15 of 30 The reporting requirements contained in Tech. Spec section 6.9 were found to be adequately addressed. A review of those reports prepared and submitted to the NRC during the !ast year w conducted to ensure that requirements for content and timeliness were met. Reports were pro stored and retrievable in the Nuclear records Vault as required by QI 17-PR/PSL-1 " Quality Assurance Records"
~
As a result of observations made and objective evidence reviewed. it was determined that the requirements of the Technical Specifications and the Quality Assurance Program in the areas audited have been adequately addressed at St. Lucie.
Performance Monitor: Lee Bearror i
PMON 96-063 was initiated to evaluate administrative control processes during the performance monitoring period. In this connection, the bypass of Quality Control Hold Points was found to have been the topic of a number of recent Condition Reports (CR).
A review of CRs written for the past 6 months indicated that 13 CRs have been written on 11 cases in which Quality Control hold points had been bypssed. The description of the missed hold points ranged from "l A Charging Pump back in service without a VT inspection", to "QC Hold Point step 9.2.4 of GMP M-0039," Threaded Fasteners on Pressure Boundaries and Structural Steel", signed off by craft personnel not Quality Control personnel". Although these events occurred during the period of May through November, a root cause evaluation was not specified as necessary until the 11th condition report out of the 13 was approved by the Plant General Manager.
j i
The root cause of these events is a lack of knowledge of the Quality Control Hold Point requirements}
by personnel responsible for requesting the required inspections, and the fact that hold points in pla
{
procedures are often not standardized or easily identifiable. In the past, during the period when the j
Quality Control (QC) Department reported to the Plant Manager, the plant Quality Instruction :
regarding QC inspection (QI 10 PR/PSL-1 ), contained a section that listed responsibilities for I "Other departments involved in QC Inspection Activities" When the corporate reorganization moved the QC Department under the Quality Manager, these responsibilities were deleted along with the remainder of the quality instruction. This contributed to the subsequent poor control over hold i points. -
i Finding #3 (see below) was written to obtain the corrective action necessary to address the observed problem. The failure of the plant corrective action program to address the problem previously will be addressed in Audit QSL-CA-96-020. " Corrective Action Functional Area Evaluation" which currently in progress.
/
AUDIT REPORT p:PL.
QSL-PM-96-22 Page 16 of 30 Performance monitor: J. Walls Independent Technical Review Reports ITR 96-027 was conducted to review an operational deficiency that resulted in three out of the four independent channels of the Reactor Protection System (RPS) linear nuclear instrumentation (NI) becoming inoperable from a single cause. An independent review of the event was conducted to evaluate the causes and corrective actions for operation of the plant with NIs in a condition I prohibited by the Unit 1 Technical Specification (TS). Full details of this event are included in licensee event report (LER) 335/96-010. " Operation Prohibited by Technical Specifications Due to l
i Linear Range Nuclear Instrumentation Out of Service." dated August 29.1996. j On July 30.1996, at approximately 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />. St. Lucie Unit I was operating at 100 percent power after starting up from the cycle founeen refueling outage. During a Reactor Engineering evaluation of shape annealing factor (SAF) data obtained during the unit power ascension it was discovered that the upper and lower detector leads for the RPS linear range NI's (consisting of two stacked detectors per channel) were reversed on RPS channels A. C, and D. The data showed that the axial a shape indexes (ASI) for RPS channels A, C, and D, and control channel 9 were not in the expected, positive direction. The Unit 1 Assistant Nuclear Plant Supervisor (ANPS) immediately declared the l
three affected linear range safety channels out of service and, after determining that the LCO and i action state.nents of TS 3/4.3.1 could not be met, entered TS 3.0.3. This TS requires that when an l LCO is not met, except as provided in the associated action requirements, within I hour, action shall be taken to place the unit in a Mode in which the specification does not apply by placing it at least in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Concurrent with the actions regtiired by TS 3.0.3, steps were 1 taken to restore the RPS channels to operable status. Specifically, instrument electrical leads were reconnected in the correct configuration and the instruments were functionally tested. Channel A and D RPS linear NI's were returned to an operable status at 1350 and 1400, respectively. With three operable RPS linear NI channels (A, B, and D), the LCO requirements of TS 3/4.3.1 were met, and the plant exited from TS 3.0.3. Channel C linear range NI was repaired, tested and declared back in service at 1515. Following the restoration of all four NIs, an ASI response test was performed on all four RPS chanels, with satisfactory results.
Channel B linear range RPS NI indicated normally throughout the event. A review of maintenance history by plant staff found that Instmment and Control Maintenance (I&C) personnel replaced the ;
channel B linear detector as a maintenance item during the cycle fourteen outage. Cable '
9.
/
AUDIT REPORT ppt QSL-PM-96-22 Page 17 of 30 l
designations on the new detectors differed from the nomenclature in the existing drawings. I&C l
personnel did not identify this difference as a discrepant item requiring resolution. Consequently, ,
the leads for the upper and lower detector sections were reversed during the detector installation, and I
then reversed again at the NI cabinet during the PC/M 009-195 replacernent of RPS NI drawers in I the control room. The reversed leads at both the detector and the NI cabinet for channel B compensated each other, resulting in channel B reading correctly. Training is being developed as a countermeasure to address I&C personnel performance issues resulting from the channel B 1mear l
range detector replacement. l l
An independent review of LER 335/96-010 found that the report contained the information required by 10CFR50.73 including: operating conditions before the event, a description of major occurrences, personnel errors, corrective action taken and planned, and a narrative description of what occurred
'and its known causes. Additionally, the LER was submitted within 30 days as required by the regulations..
The ITR Engineer determined through reviews of L.ER 335/96-010. Quality Assurance Audit report QSL-PM-96-017. Finding 3, dated 9/9/96. Condition Report (CR) 96-1878. " Linear Range Detectors," dated 8/96, and Engineering's responses that the appropr ate causal factors, generic issues and operability concems were identified and being addressed in the associated responses. The primary event causal factor, an undetected design error, was due to significant PC/M design control and implementation process weaknesses. These process weaknesses, also identified in the Quality Assurance Audit mentioned above, affected the design input, design verification. post modification testing, and Engineering's involvement during implementation of the PC/M. These process weaknesses resulted in the replacement of RPS nuclear instrument drawers under a PC/M which contained a design error that was not detected until full power operation. Specifically, a control and wiring diagram (CWD) in PC/M-009-195 for the NI channels erroneously depicted the lower uncompensated ion chamber (UIC) going to the upper ion chamber input for NI channels A, B, C, and D at the NI Drawer. The CWD error occurred because the designer and the Lead Engineer for the project did not a complete understanding of the details included in Combustion Engineering's (CE) design of the St. Lucie NI installation, which required the cable connections to be oriented to the bottom of the detector. The original detectors were installed in an inverted orientation where the BOTTOM detector is actually the upper chamber. Additionally, PC/M-009-195 did not identify the upper and lower N1 inputs to ASI as a critical function to be verified during post modification testing (PMT)'. As a result, PMT requirements were less than adequate, and the PMT for the new RPS NI drawers failed to identify the connection errors.
The ITR Engineer also found that operability considerations were adequately addressed in the analysis section of the LER. The analysis section of the LER concluded that operation at beginning-of-cycle (BOC) with the incorrect ASI inputs would not have resulted in violation of the plant safety
1 l
1
/
AUDIT REPORT pg QSL-PM-96-22 Page 18 of 30 analysis limits for the events described in Chapter 15 of the Updated Final Safety Analysis Report, and that the health and safety of the public were not affected. Engineering Evaluation JPN-PSL-SEFJ-96-036. " Assessment ofInverted Excore Detector Contiguration for Channels A, C, and D During Cycle 14 Operation at BOC." dated 8/19/96 effectively supports the LER conclusion.
Corrective actions to address the modification' process weaknesses and other contributing causal factors are discussed below. The corrective actions are being tracked by Plant Manager Action Items (PMAls).
Walkdowns oflinear detector cabling is planned for the first outages of sufficient duration.
The purpose of the walkdowns are to reconcile conflicting information on existing plant drawings and to facilitate cable tag and drawing correction where needed.
- PMAl# PM96-08-225 and PM96 226 !
. 1 Engineering Quality Instruction ENG-QI 1.7 " Design / Input Verification." will be revised '
to require independent verification of and signing of safety related drawings, and to require the same level of review for duplicate PC/Ms as the original PC/M. These items will ensure complete verification of Engineering Packages including the supporting drawings is performed.
PMAl# PM96-08-227 and PM96-08-229 Previously prepared safety-related Instrument and Control and Electrical PC/Ms will be reviewed to verify compliance with the design requirements. PMAl# PM96-08-228 Engineering Quality Instruction ENG-QI 1.1, " Engineering Packages," will be revised to require identification of critical functions for PMT in safety-related engineering packages.
PMAl# PM96-08-230 I&C will provide training to personnel on the detector cabling designation issue to increase awareness and emphasize the importance of obtaining the proper technical guidance in unclear situations. PMAI# PM96-08-231 ASI targets will be established for trending ASI during power ascension on restarts from a refueling outage. PMAl# PM96-08-233
.. SAF data will be evaluated on a real time basis during power ascension.
PMAl# PM96-08-232
S
/
AUDIT REPORT ppt QSL-PM-96-22
- Page 19 of 30 The above corrective action items adequately addressed the event causal factors and generic implications. Additionally, the safety significance of the event was adequately evaluated and documented.
Recommendations None
_ ITR Engineer: C. E. Norris ITR 96-033 was conducted to evaluate the causes and corrective actions for an event involving a condition prohibited by Technical Specifications due to failure of the in-service waste gas oxygen analyzer. Full details of this event are included in licensee event report (LER) 335/96-011.
" Operation Prohibited by Technical Specifications due to Failure of Oxygen Analyzer," dated September 13,1996.
On August 17.1996. St. Lucie Unit I was operating in Mode 1 at 100 percent power. The l A waste
-gas decay tant (GDT) was in service and aligned to the discharge of the waste gas compressor. The gas concentration in the 1 A GDT was being monitored by continuous flow oxygen analyzer (02Y-6601), and redundant analyzer (02Y-6602) was out of service. At approximately zero hours, a non-licensed operator observed that the oxygen value indicated by 02Y-6601 had not changed since the previous mid shift, and that the analyzer might not be properly updating sample information. When operations personnel reset the oxygen analyzer, the indicated oxygen concentration of 12.9%
exceeded the alarm set point of 2% oxygen. Operators took immediate actions to reduce the oxygen
, concentration by pressurizing the GDT with nitrogen. The Chemistry Department subsequently verified the hydrogen and oxygen concentrations in the GDT, to be 5% and 9%, respectively. These gas concentrations exceeded the Technical Specification 3.11.2.5 Limiting Condition for Operation, which requires oxygen to be limited to less than 2% by volume whenever hydrogen exceeds 4% by volume. Actions to reduce the gas concentrations in the l A GDT were continued until the GDT oxygen concentration, as determined by Chemistry Department sampling, was reduced to 0.63 %
by volume. These actions included: aligning the waste gas discharge to the plant vent and purging the GDT by refilling the tank with nitrogen and releasing the contents through the plant vent. During the gas purging operations, operators again noted that oxygen analyzer 02Y-6601 was not updating the oxygen concentration, and the analyzer was subsequently declared out of service. The ITR Engineer determined that the actions taken to reduce the oxygen concentration in the l A GDT, were according to Off-Normal Operating Procedures ONOP l-0030131, " Plant Annunciator Alarm
. Summary," and ONOP l-530030," Waste Gas System."
O m
t i
/
AUDIT REPORT p:PL QSL-PM-96-22 Page 20 of 30 The ITR Engineer determined that LER 335/96-011 adequately identif i the appropriate even causal factors and included immediate and long term countermeasures to adress those factors and prevent recurrence. These countermeasures included:
The source of the oxygen in leakage (drain trap T-691 l) was determined and repaired.
Determination of the cause for the oxygen analyzer failure is in progress. The status of this item is being tracked by Plant Manager's Action item PM96-09-137. I Oxyg n analyzer 02Y-6601 was returned to service after calibration and functional testing Chemistry samples will continue to be taken on a daily basis until the cause for the analyze failure is determined and any indicated additional corrective action is completed.
. I The Data Logger system, used to obtain periodic log readings, was improved by including an additional check of gas analyzer indication characteristics that will provide early identification of analyzer malfunction. Additionally, the frequency of aulyzer readings was l increased from once in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to every eight hours.
This event and its failure mode were reviewed with operators on chift by the Real Time I Training Coach.
Restoration of the redundant oxygen analyzer is being evaluated. This item is being tracked l by PMAI PM96-09-192.
These Corrective action items appropriately address the event causal factors and include action items addressing recurrence prevention. -
The safety significance of the event is adequately evaluated and : Jdressed by the LER. Specifically, the LER concluded that the potential failure of the CDi in this event is bounded by the current accident analysis, and failure of the GDT did not occur; therefore, the health and safety of the public were not adversely affected. These conclusions are consistent with the Unit 1 Upgraded Final Safety Analysis Report (UFSAR), Section 15.4.2, " Waste Gas Decay Tank Leakage or Rupture." Results of the GDT gas analyses validated this consistency by showing that the radio nuclide concentrations in the GDT during the event were less than those assumed in the Unit I accident analysis.
. Recommendations None ITR Engineer: C. E. Norris
i
/ AUDIT REPORT FPL QSL-PM-96-22 i mer Page 21 of 30 i i
Findings:
l Finding 1: Site procedures do not adequately address the storage, accountability, and inventory requireprats for required freeze protection equipment.
Criteria: TQR 5.0," Instructions, Procedures and Drawings", Revision i1 Paracraoh 5.1 l Activities affecting quality of nuclear safety-related structures. systems, and components shall be prescribed by documented instructions, procedures. or drawings of a type appropriate to the circumstances and shall be accomplished in accordance }
with these instructions, procedures, or drawings. These documents shall include i appropriate quantitative criteria such as dimensions, tolerances, and operating limits.
and qualitative criteria such as comparative workmanship samples, to assure that the quality assurance activity has been satisfactorily accomplished.
Discussion: AP 0005753, " Severe Weather Preparations" Revision 18, paragraph 8.4, and associated checklists, delineate steps to be taken in the deployment of freeze ;
protection equipment at the St Lucie Plant. The checklists are specific in that they contain detailed requirements concerning the type of freeze protection equipment to be used and the locations at which it is to be installed.
The procedure states that the freeze protection plan should be implemented 16 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of the onset of cold weather conditions. Checklist 19,
" Maintenance Department Pre-Cold Weather Checklist'~, directs the Mechanical Maintenance depanment to ensure that an adequate supply of tarps /herculite, space heaters, and heater fuel is available, and to preposition electric / kerosene heaters in their designated positions. Checklist 20, "I&C Cold Weather Checklist", instructs
- I&C to install heat tape, if necessary, on equipment identified by the checklist.
Intervie.vs with personnel in the F4 warehouse revealed a lack of procedural direction in the inventory requirements pertinent to equipment required for implementation of the freeze protection plan. At the time of the interview there were no electric space heaters available for check out in the warehouse. Of the three heaters identified, two were checked out and one was awaiting repair. Personnel also
, indicated that a complete inventory of the F4 warehouse was planned which would probably locate several heaters presently unaccounted for
1 O I
/
AUDIT REPORT FPL QSL-PM-96-22 Page 22 of 30 l
l l
Additional interviews with I&C department supervision also revealed a lack of l procedural direction in inventory requirements. Steps had been taken since the last audit to acquire a significant number of spare heat tapes. Approximately 70 new spares were on hand. I&C also indicated that personnel had been in the process of identifying the power sources and the length of extension cord needed for.each ;
transmitter location. Their intent was to proceduralize the process to make it both !
easier and simpler to implement Checklist 20. This however had not been completed. The two personnel that were assigned this task are no longer with FPL.
and due to manpower and time constraints the task was not considered a high priority item.
Nuclear Materials Management (NMM), supervision also indicated that all kerosene on site was purchased PC3 due to its' availability for use as a cleaning solvent on safety related equipment. Personnel also indicated that there had been problems in the past in the time of delivery due to this PC3 designation.
This procedure inherently relies on several individuals to maintain significant quantities of material and equipment on hand in a readiness condition. With the Plants', departments and personnel structure in a constant state of flux, the continuity required for unproceduralized programs does not exist and can substantially degrade the efficiency of the overall program.
As was demonstrated in 1989, the onset of extremely cold weather, without having completed the required preparations, has the potential to both cause undesirable operating transients and to affect the operability of safety related equipment.
Recommendation:
The following recommendations are offered to aid you in responding to the finding.
However additional or alternate actions may be necessary based upon your investigation of the finding and the causal factors and generic implications identified.
Your response must address each of the five elements in the audit cover letter.
The intent of the suggestions given below is to improve the overall plan efficiency by maximizing personnel time and effort. This can be accomplished if equipment is staged and readily available for use.
' AUDIT REPORT ppt, QSL-PM-96-22 Page 23 of 30 1.
' Complete work started by 1&C in identifying power locations and extension cord requirements for all transmitters.
2.
Proceduralize and dedicate inventory needed for implementation of the Freeze Protection Plan.
- 3. Proceduralize personnel or position accountabili'v.
4.
5 Consider a threshold for initiating the purchase of PC4 kerosene during cold weather conditions when on site supply falls below minimum.
t
- o
.- . o k
.e d
6 f
e e
t AUDIT REPORT ppt QSL-PM-96-22 Page 24 of 30 Finding 2: Corrective action for a previous Finding on overdue periodic reviews was inadequate in that, following corrective action for the Finding, an additional sixty five procedures did not receive a periodic review within the required time frame.
Criteria: TQR 16.0," Corrective Action," Paragraph 16.2.2 In part "The organization (s) that provide (s) the corrective action disposition and I implementation is responsible to assure that the corrective action taken not only corrects the immediate condition, but also precludes recurrence.'
St. Lucie Plant Technical Specification 6.8.2 "Each procedure of Specification 6.8.1.a. through i. above. and changes thereto shall be reviewed by the FRG and shall be approved by the Plant General Manager prior to implementation and shall be reviewed periodically as set forth in l
administrative procedures."
l QI 5-PR/PSL-1, " Preparation, Revision, Review / Approval of Procedures,"
Revision 75 l
l Paracranh 5.8.1.
"All procedures shall be reviewed at least once every 36 months (plus or minus six months) to assure they represent current plant policy and practice."
Discussion: As a result of 1994 PMON 94-105, "QA Program and Management Controls,"
twenty-four procedures were identified as not having received a periodic review in the time period required by Q15-PR/PSL-1 " Preparation. Revision, Review / Approval !
of Procedures" This was documented in Finding 2 of the PMON. The finding was ;
addressed and corrective actions outlined to preclude future overdue periodic reviews. l The corrective actions included changes to the periodic review process contained in QI 5-PR/PSL-1. However, during the present review of this area, it was found that the periodic reviews of sixty-five procedures were overdue. The sixty-five overdue reviews were self-identified by Information Services personnel and were addressed by Condition Report CR 96-2531. Additional corrective actions have been implemented as a result of this CR. Since this is a repeat Tech. Spec and procedure
\
/
AUDIT REPORT FPL QSL-PM-96-22 Page 25 of 30 noncompliance regarding the required periodic review of procedures. it was i determined that it should be documented as a Quality Assurance Finding. In spite of the good intentions of Information Services personnel (producing a monthly periodic review status report sent to all responsible Department Heads), personal accountability for review of required procedures must be acknowledged or permanent corrective action may not bc achieved as was the case with the previous finding in this area. l l
l This is considered a repeat Finding under the provisions of the FPL Quality I Assurance Program.
1 Recommendation: '
i l
The following recommendations are offered to aid you in responding to the finding.
However additional or alternate actions may be necessary based upon your investigation of the finding and the causal factors and generic implications identified.
Your response must address each of the five elements in the audit cover letter.
- 1. Ensure that each Department Head has taken steps within their respective departments to address the procedure periodic review process including the mandatory review time frame.
l 1
i l
O d'
l 0
AUDIT REPORT ppt, QSL-PM-96-22 Page 26 of 30 e
Findine: 3 Existing administrative processes and knowledge of these processes are not adequate to bring about required inspections and properly disposition Quality Control hold points..
Criteria: ANSI N45.2 - 1971," Quality Assurance Program Requirements for Nuclear Power Plants" -
Paracranh 3 3 -Indoctrination and Traininc
" Provisions shall be made for indoctrination and training of those personnel in the owner organization performing activities that affecting quality to assu e that suitable proficiency is achieved and maintained. Such personnel also shall be provided training conceming the administrative controls and quality assurance program which, as a minimum, shall include the following areas: overall company policies, procedures or instructions which establish the program; procedures or instructions which implement the program related to the specific job-related activity."
Paracranh I l- Insnection "If mandatory inspection hold points, which require witnessing or inspecting by the applicant's designated representative and beyond which work shall not proceed without the consent ofits designated representative are required, the specific hold points shall be indicated in appropriate documents. Such consent shall be l
documented prior to the continuation of work beyond the designated hold point." !
FPL Topical Quality Assurance Report ,TQR 2.0, l
Paracraoh 2.2.5 " Indoctrination and irainine" "A program shall be established and maintained for quality assurance indoctrination, and for training which assures that the required level of personnel competence and skill is achieved and maintained in the performance of activities affecting quality."
ADM-0010432, Control of Plant Work Orders, Paragraph 5.0 Definitions, Revision 7 Subpacraoh 5.8
" Hold Point - A mandatory inspection, test or verification usually by QC that must be performed on a process or item and then released prior to the continuation of work activities. The organization performing the inspection, test or verification must be notified prior to or when this step is reached."
\
AUDIT REPORT FPL QS L-PM-96-22 Page 27 of 30 l
Event i CR# Date Desenption 1 96 2845 11/19/96iVT 2 not performed prior to operability determination on 2A ICW pp.
2 96 2662 11/1/9611 A chv pp. back in service without a VT 2 inspection.
2 96 2655 10/30/9611 A chv pp. back in service without a VT 2 inspection.
3 96 2637 10/29/96!2C chv pp. back in service without a VT 2 inspection.
4 96 2513 10/16/964 Weld end prep and fit up hold points were not done prior to weld completi
_ 5 96 1937 8/12/96: Bypass of bottin_g inspection for Main Feedwater check viv .
6 96 1881 7/31/96+ Package for V17200 for sect XI VT2 was not submitted to QC for PMT/ISLT 7 96 1806 7/22/96,2C Chv.Pp. declared 1.1 service without VT-2 by a qualified inspector.
8 96 1713 7/13/96 Weld traveler containing voided hold points not reviewed by QC, 9 96-1615 7/4/96. ASME test inspections are not completed after work is completed.
10 96-1154 5/29/96=QC Hold point step 9.2.4 of GMP.M-0039 was signed off by craft not QC.
11 96 1100 5/27/96.PWO did not contain documentation to record QC hold point inspection.
11 96 1060 5/27/96-QC Hold Point bypassed on NPWO 61-2382 (PT/MT).
l Discussion: A review of the plant Condition Report system indicated that since May 1996, eleven
-instances have occurred in which Quality Control holdponts have been bypassed. .A matrix of these events is included below.
IIold Point Condition Report Matrix From 5/27/96 to 11/19/96 1
Eleven events of this type in 6 months is considered to be indicative of a quality program breakdown in this area.
se
l
/
AUDIT REPORT ppt, QSL-PM-96-22 Page 28 of 30 A review of site procedures indicated a lack of explicit guidance on actions necessary in order to properly address Quality Control Hold Points. The procedures do not contain discussion that addresses the conduct of the plant personnel when a hold point is encountered in a procedure. Discussion with plant personnel indicated that bypassing a hold poi .t may not be understood to be an act of procedural non-compliance.
Additional review disclosed a lack of consistency in the fonnatting of hold points in plant procedures. Some procedures contain elaborate bold bordered sections labeled Quality Control Hold Poir t. while other procedures contain generic sign offs that are not clearly distinguishable from other sign offs. This lack of consistency may have contributed to cognitive error as a possible cause in the bypassing of hold points. j Recent site reorganization activities have caused problems in that the responsibility ,
for procedure up date, notification, scheduling, training, and indoctrination of '
personnel involved with QC Hold Points is not well defined. An additional causal factor may have resulted from the movement of the Quality Control Group into the Quality Assurance Department. After the move the plant procedures or instructions were not revised to replace quality instructions that interfaced with the Quality Control group. As an examp the Quality Instruction for Inspection, QI 10 PR/PSL-1, was deleted and the interface instructions were not translated into plant instructions.
A number of the inspections that were missed are required to verify component operability under requirements of the ASME Code and other plant conditions.
Repeated failures to observe requirements of this type calls into question the effectiveness of other administrative measures necessary to ensure correct operation and satisfactory regulatory compliance on the part of the St. Lucie Plant.
Recommendatiom The following recommendations are offered to aid you in responding to the finding.
However, additional or altemate actions may be necessary based on your investigation of the finding and the causal factors and generic implications identified.
Your response must address each of the five elements in the audit cover letter.
- 1. Revise the procedure process to standardize the Quality Control Hold Point format to allow for ready recognition.
. . . .- . _ - - - -.- _ - . _ - . _ _ _ _ - _ _ _ - _ - . - _ _ - _ . _ = _ _ _ - . _ _ . . . __ -
/
AUDIT REPORT pg QSL-PM-96-22 Page 29 of 30
- 2. Revise the site procedures to provide adequate plant interface with the Quality Department.
- 3. Provide training and indoctrination to all personnel that interface with the Quality Program with emphasis on compliance.
i 4
e av
6
/
AUDIT REPORT p:pt, QSL-PM-96-22 Page 30 of 30 Audit
Participants:
Name Department / Group PMON No.
- M. Fox 96-060 J. Kawa ICM 96-060 M. Law ICM 96-060 V. Mendoza Engineering 96 060 M. Snyder Engineering 96-060 D. Woolridge 96-060 B. Sommers Health Physics96-061 D. Haithcox Health Physics96-061 T. Dwyer Quality Control 96-061 R. Hawley Quality Control 96-061 D. Faulkner Chemistry 96-062 R. Cox Chemistry 96-062 J. Voorhees Corrective Action 96-063 G. Schnebli Quality Control 96-063 A. Locke Corrective Action
'96-063 W. Hays Quality Control 96-063 L. Neely Quality Assurance 96-063 J. Scarola Plant General Manager 96-063 D. Fadden Site Services Manager 96-063 i J. Marchese Maintenance Manager 96-063 L. Miller Maintenance 96-064 B. Cason Maintenance 96-064 J. Mayr Maintenance 96-064 L. Large Maintenance 96-064 L. Collins ICM 96-064 B. W hite Materials Management 96-064 D. Whitwell Emergency Preparedness96-065 T. Ware Trair 96-065 J. Liethelm Training 96-065 r
L
.......n. . . - . _ . ~ _ - - . _ . - - - . . . - ,_ - . - . - .. ..- . . . _ . ..-. . . - ..- . . . . . . _ . . - . _ _ . . . - _ _
/ AUDIT REPORT ppt, QSL-PM-96-22 Page 31 of 30 Pre-Audit Notification ,
location: St. Lucie Plant Date: October 1.1996 Post-dudit Conference:
Location: St. Lucie Plant l
Date:
Summary of Post-Audit Conference:
Location of Audit:
St. Lucie Plant O
m e
O e
oe,
< 1 l AUDIT REPORT 3 ppt, QSL-PM-96-22 4
Page 32 of 30
$ Accompanying l Auditors: L. Bearror, B. Lowery, L. Neely. C. Norris i
s Princinal
! Auditor:
J. J. Walls Date Quality Asstirance - PSL j Reviewed hv:
., D. C. Lowens Date 4 QA Supervisor - PSL r
il
.i i
I l
I b
E I
i i
i 4
e 4
i a
1
F FFucs D PSL L Unit:* /.".02 Componcnt: Syo 07 Train: '
A Ascocists: Accign Priority: B3 MASTER W Name: RWT TEMP CAL Work Type: 7 WORK ORDER TASK d
TECH SPEC 4.5.4.B 8 Location: RWT LMD: 2 96010836 01 !
I Defect / Request: PM2 0701 RWT TEMP CAL ER/PWO: 64 / 6709 2 ' ' M* -
T. F C Detailed Explanation:
H... R. P. F C.
PM ID: PM2 0701 DUE BY DT: 07/30/96 EARLY DT: 03/17/96 (ATE DT: 12/12/96 More:
Work Request: Def Tag: Loc:
Trbl/Brkdown:
NPRDS: Y Fail Date:
Originator:
LCO:
Time: PM Det:
Date:
Unit Cond Req:
Stat Symp:
Dept:
Approve By: Date:
Task Determination Data:
IST Required : N NCR/CR : N/A Safety Class: SR PMT Required : N PCM : N/A Q Group : BTW 10 CFR 50.49 : N EQ Doc Pkg N/A Assign To : TN 1 Reg Guide 1.97 : N Seismic Cat : I Est M/H : 8.00 ASME XI(ISI) Reqd : N Scaffold Req : N Crew Qty : 1 Security Clearanc.e N Fire Prot Req: N Insul Rem : N Clearance Requirsd N Clearance No :
RWP Required: Y_RWP No: RCA M/H: L1: L2: L3:
QC Requirements: QC Required : Y QL-A Mores o=e=================================================-=======================
Wo;k Order Task
Description:
SEE PAGE 2 FOR TASK DESCRIPTION.
More: Y
_==========rw================================================================
Planned By MEWOCIT WILLIS ME Date: 04/25/96 Pkg Appr By : MEWOCIT WILLIS ME Date: 04/25/96 Time: 11:25 !
QC Approval : DSM00FK MELODY DS Date: 04/25/96 ;
- OPERATIONS APP OVAL TO START ***********************
NPS Start Permission: , M LCO (Y/N) : f/_
Start Date/ Time : 'g/Sc/5/ / g/ OJn-
- NPS Completion Notif: ,
Comp 1. Date/ Time: //9f# / /
d*Q Major Failure:
J f/CS Major Action :
Deficiency Tag Removed ~ (Y/N) : ,v/ T
/ /
/ /
/
y/'
Contp::n;nt s Sya: 07 Train: Fac: PSL Units 02 Acccciatos Accign Priority: B3 MASTER 43, Name:RWT TEMP CAL Work Type: 7 WORK ORDER TASK TECH SPEC 4.5.4.B Location: RWT LMD: 2 96010836 01 Defect / Request: PM2 0701 RWT TEMP CAL ER/PMO: 64 / 6709 Chg locs 910 PAGE 2 of 5 Continuation of Task Descriptions
- 1. CALIBRATE TI-07-4 USING IC 2-14 BOO 64T, APPENDIX A.
- 2. IF NECESSARY, REPAIR / REPLACE INDICATOR TO RESTORE PROPER INDICATION SEE TEDB SHEET FOR REFERENCES.
- 3. ENSURE SEISMIC EQUIPMENT IS RkMOUNTED PROPERLY.
- 4. PERFORM POST MAINTENANCE TEST PER QI 11-4, APPkNDIX B.
- 5. DOCUMENT ALL WORK AND PARTS USED IN JOURNEYMAN 8S WORK REPORT.
bYSTEM SUPERVISOR: TERRY NEWHOUSE 4
4 4
Compancnt Syos 07 Trcin: Fue PSL Unit: 02 g Accocictor Accign Priority: B3 MASTER Name:RWT TEMP CAL Work Type: 7 WORK ORDER TASK TECH SPEC 4.5.4.B Location: RWT LMD: 2 96010836 01 Defect / Request: PM2 0701 RWT TEMP CAL ER/PWO: 64 / 6709 Chg loc: 910 PAGE 3 of 5
. 1 JOURNEYMANS WORK REPORT Actual Start Date: Time: Actual Completion Date: Time: I 8 3 6 - 1 (s o creo 1.30-94 Note: Journeyman shall sign and date text after their entries.
//o.r 1 l
l Trouble Found This Section is NOT Applicable for PMs or other planned jobs wh' IESTENP. ,
PSt. F03 I PSI.
PE PS[ l ni -
Work Performed: ~
/2flt/V& NAO7/J[/CA/ RECM CPS 7D BE6/A/. /2&tolid
~7 T - 0 7 t/ Rd CAL,. (A/ .2WC S//c?. Obt/Ertaz) WEzt.- (FMb M/Abf75d Tr -o7- 9' Ar pst .z~/c p/tte . .# 2- /Yppg&W w$if7 DTrttTJ-ite-wsrtuch sysraamur M Par psensu@ ser anne GPS RAlb Suf. DF RESOLT3,/CohkET/w. N d'96
,k ht.Il W,
)
Continued on Additional Sheets:
Suggestions For Future Planning / Variance Reason: Yh I
Supv/ Foreman / Chief Date Supe sur Date QC Instr.ector Date
. 'llMaw _
b'S'$h it l
Compuncnts Syc 07 Trcin FGc: PSL Unit: 02 Ascociatos A"scign Priority: B3 l MASTER
, Name RWT TEMP CAL Work Type: 7 WORK ORDER TASK TECH SPEC 4.5.4.B Location: RWT LMD: 2 96010836 01 Defect / Request: PM2 0701 RWT TEMP CAL ER/PWO: 64 / 6709 Chg locs 910 PAGE 5 of 5 Component List:
Comp: TI-07-4 Assoc: Sys: 07 Names TEMPERATURE INDICATOR FOR REFUELING WATER TANK Loc RWT/21/S-20/E-15 9fty-Cls Q-Grp 50.49 1.97 FPR PMT IST SEIS DOC NCR PCM ASME SR BTW N N N I N/A 1Comm:
I
%s
-- _ _ . _ . _ . . _ _ - . _ _ _ . _ . - _ _ _ . _ ~ _ _ . . _ _ _ _ _ _ _ _ . _ . _ _ _ . . _ _ . _.
- f
. REVISION NO.: O'ROCEDURE TITLE: PAGE:
l 4 CONTROL OF PLANT WORK ORDERS
- PROCEDURE NO.3 81 Of 83 .
ADMINISTRATIVE PROCEDURE ADM-0010432 ST. LUCIE PLANT l FIGURE 3 TROUBLESHOOTING / MAINTENANCE NPWO PRE-JOB REVIEW SHEET j TROUBLESHOOTING / MAINTENANCE NPWO PRE-JOB REVIEW SHEET 1 Section A NPS/ANPS
! , NPWO No. 07o9 ER_[r.f_ Unit d?
- A. Has the Equipment been declared OOS? Yes Y No O B. Are the affects confined to the sub ect t Equgwnent? Yes d No O
- if A or B are No, a 10CFR50.59
- creening is reqwred. !
l 10 CFR 50.59 screening required?
- O Yes, corenue with Secnon B.
,' Mo, perform work per NPWO instructions.
! Reason for Disapprovat: //
Performed By Date //
f Seenon B l# Guhlffled Reviewer j 10 CFR 50.59 Screeneng Quescons j A. Does this alteration represent a chenge to the facility as descnbod in the SAR? Yes O "No O l j (includes connochon of DAS to redundant safety channels)
{ B. Does this alteration represent a change to proceduroa desenbod in the SAR? Yes O No O l C. Is the alteration associated with the test or expenmer.t not desenbod in the SAR7 Yes O No O ;
i D. Could the afteration affect nuclear safety in a way not previously evaluated in the SAR7 Yes O No O
{ E. Does implementation of this alteration require a change to the Technical Specifications? Yes O No O FSAR Sechons regnewed T.S. Saccons Reviewed Screenrig Results:
If the answer to any of the screerung queshons is yes, a 10CFR50.59 Safety Evaluation is required.
A. is 10CFR50.59 Safety Evaluaton requwed?
O Yes, submit package to JPN for Safety Evaluation.
O No, perform work per NPWO instruchons B. If Yes, have Engineenng perform the evaluatson, submst the NPWO, with a copy of the evaluaton, for FRG review. Continue with Section C.
Performed By: Date //
Sectson C FRG FRG Review No. Date //
PGM Approval or Designee: Date //
FRG Approved? 4 O Yes, perform work per NPWO instructions.
Qig {Q[.34.4.T10N ON'0/ ;
C No, retum package to requestor, TH':; CCctsfi.C PiiWi'Mm'i1LD. If/&I4~4 I yyy.py p p,wjm., en a : rwer.ile ; ccT'f2T.
Fwi. D \ PCWEf( f.?io UGM CO.
ST. LICE PLANT gtTE VER*MED P 3** i G INITIAL 09k
. Pcg31 of 71 I
, FLORIDA POWER & LIGHT COMPANY .
ST. LUCIE UNIT 2 @
[g I & C PROCEDURE NO. 2-1400064T , 3 REVISION 24 'd l( -
n:
1.0 TITLE
U* ' N
'.u
%~ -y INSTALLED PLANT INSTRUMENTATION CAllBRATION (TEMPERA 2.0 REVIEW AND APPROVAL:
Reviewed by Facility Review Group 8/27 1985 Approved by D. A. Saaer Plant General Manager 3/51986 Revision. 24 Reviewed by F R G 6/9199'6 Approved by J. Scarola Plant General Manager 6/91996
3.0 PURPOSE
3.1 This procedure identifies the installed plant instrumentation that requires periodic calibration within the scope of Ol 11-PR/PSL-4, Paragraph 3.3.
3.2 This procedure contains instructions for the calibration of each instrument / loop.
3.3 The instruments listed in this procedure shall be calibrated every 18 months with a maximum allowable extension of 4.5 months.
4.0 PRECAUTIONS AND LIMITS:
4.1 If a clearance is required, obtain per Operating Procedure 0010122 and Operations Department Letters of instruction 01,02 and 03.
4.2 Instrumentation found in broken condition should be repaired on a specific NPWO. Notify the NPS of failed conditions.
5.0 RELATED SYSTEM STATUS:
The shift ANPS or Nuclear Plant Supervisor shall be contacted to ensure proper system status.
S 2 OPS DATE FOR INFORMATION ONLY DOcT enoceouns TN!S DOCUMDG M frJT CMTKUID. EsIORE USE. DOCN 2-1400064T vowy semencN miu A cvimou.to coccueur. SYS FLORIDA POWER AND LIGHT CO. COMP COMPLETED ST.WCIE PUWT ITM 24
[om YERtRED T*38 TC INmAl O *#
Mcge 2 of 71 ST. LUCIE UNIT 2 1 & C PROCEDURE NO. 2-1400064T, REVISION 24 4
INSTALLED PLANT INS TRUMENTATION CAllBRATION (TEMPERATDlWE)
6.0 REFERENCES
6.1 Control Wiring Diagrams 2998-B-327.
6.2 instrument List 2998-B-270.
6.3 Instrument installation Details 2998-B-231.
6.4 Schematic Diagrams 2998-B-326.
6.5 Instrument Arrangement Drawings 2998-G-224,226,22'7,228,229.
6.6 Manufacturer's instruction Manuals.
6.7 instrument and Control Department E.O. Maintenance Instructions, St. Lucie Unit 2, Procedure No. 2-lMP-99.01.
6.8 Instrument and Control Department E.O. Maintenance Tabs, Procedure No.
IMP-99.03. .
6.9 Environmental Qualification (E.O.) List for 10.CFR 50.49, St. Lucie 2, Drawing No. 2998-A-450.
7.0 RECORDS REQUIRED:
7.1 Data Sheet Specified 7.2 Nuclear Plant Work Order (NPWO) 7.3 EO Tab where applicable Appendix A, Table 1 and equipment in this specific category Data Sheets.
8.0 MATERIALS AND EQUIPMENT REOUIRED:
As specified in calibration tabs.
1
age oviie ST. LUClE UNIT 2 I & C PROCEDURE NO. 21400064T, REVISION 24 x INSTALLED PLANT INSTRUMENTATION CAllBRATION (TEMPERA )
_ *gt-s 9.0 DETAILED PROCEDURE:
hl 9.1 Before proceeding with the calibration of any instrumentation within t procedure, the shih ANPS or Nuclear Plant Superv,sor shall be co to determine proper system status.
}' .
9.2 Where specified on Data Sheets, AS FOUND readings shall be taken before j
any calibration adjustments are .made, providing the instrument is operable i before calibrating. '
1 1
9.3 The detailed procedure for each loop is' listed as a tab number in Appendix A, Tables 1 and 2, as is other pertinent information. The tabs themselves appear in Appendix B to tt)is procedure.
9.4 Data Sheets for the instrumentation within this procedure are included as Appendix C to this procedure. These specify the inout signals, desired outputs, setpcints and instrument tolerances to be used.
9.5 The column-in Table 1 labeled Requirement Code soecifies the nature of each
{
instrument's im'portance per the following code:
A. FUSAR Table 7.4-1, instruments Required to Monitor Safe Shutdown. l B. FUSAR, Table 7.5.1, Safety Related Panel Mounted Display Instrumentation for Shutdown and Post Accident.
C. Environmental Qualification 10 CFR 50.49 Instrumentation.
D. Instruments used to monitor technical specification requirements, E. Instruments used to monitor ASME pump run acceptance criteria.
F. Regulatory Guideline 1.97, instruments Required to Assess Plant and
. Environ Conditions During and Following an Accident.
9.6 The order of the Calibration Tabs is:
TAB #1 Temperature Loop Calibration TAB #2 Electronic Recorder Calibration TAB #3 Boric Acid Make-up Tank Temperature Controller Calibration TAB #4 Control Room Air Temperature Monitor Calibration
. FEg's* Ossa ST. LUCIE UNIT 2 l & C PROCEDURE NO. 2-1400064T, REVISION 24 .
s INSTALLED PLANT INSTRUMENTATIC,N CAllBRATION (TEMPERATUFEi) 9.0 DETAILED PROCEDURE: (continued) 9.7 The M & TE listed in the calibration tabs (Appendix B) shall have a equal to or better than the installed plant instrumentation they are calibrate.
, 9.8 During calibration of controllers, the desired response (as left) shall be )
obtained as noted on Cal Sheet. As found condition is to be used for information only. '
9.9 Instrument Calibration Procedures -
Where Independent Verification Signature Blocks appear on the Data Sheets, l perform Independent Verifications per ADM 17.06 for valves and wiring that has been disturbed.
l Perform Post Maintenance Testing (PMT) per Ol-11-PR/PSL-4 (Section 5.4). l l
9.10 Use the applicable Tab # and Data Sheet for desired leap to be calibrated. l A. Required Code C in Table 1 designates loops which contain components that are on the EQ List (Reference 6.9). Actions required during performance of loop calibrations can effect EO status (e.g., Lifting Leads, Removing Covers, etc.) Refer to the EQ Maintenance instructions 2-lMP-99.01 (Reference 6.8) for the information and actions required to maintain the EQ status of the EO List components in these loops.
s
ST. LUCIE UNIT 2 i I & C PROCEDURE NO. 2-1400064T, REVISION 24 INSTALLED PLANT INSTRUMENTATION CALIBRATION (TEMPERATt_J -
9.0 DETAILED PROCEDURE: (continued) gr
. 9.10 (continued) l
- l i
l l
INSTALLED PLANT INSTRUMENTATION CAllBRATION l
I l
APPENDIX A 1
INSTRUMENTATION ]
IDENTIFICATION AND INFORMATION l
' ~ ~
- ~
~~
, sagsosat<1 ST. LUCIE UNIT 2 1 & C PROCEDURE NO. 2-1400064T, REVISION 24 INSTALLED PLANT INSTRUMENTATION CALIBRATION (TEMPERATL---) l L. '.
s
. TEST EQUIPMENT TAG.NO. U 7~M MO P.fl. " iN
[0.3 A, \
REVibhY PROCEDURE NO. l O.w p i e
SYSTEM: CONTAINMENT SPRAY SYSTEM !
SERVICE: REFUELING WATER TANK MANUFACTURER: DRESSER LOCATION: RWT/21/S-20/E-15
+
SIGNAL FROM: RWT TEMPERATURE INST. ACCURACY: 1%
DEVICE: TI-07-4 TOLERANCE: + OR 2*F AS FOUND AS LEFT
% FULL SCALE *F INPUT ACTUAL ERROR ACTUAL ERROR I 1
1 so 49.5 -
- o. 5 /
2 1m 99.0 -
- t. o A. S/
3 1so I48.5 -
I.5 FouND 2 im /00.0 -
/
i so 50 0 -
/
NPWO #: $789/6Y COMMENTS:
,_,,,,__m.., , . . . . . . - . , = - - ~~.
t
- u. ;
e * , * ,s * ,, e
-. ;<,. .n ,
- c ...- ,
6 O e ,. ,
J---- - * - -
, l i Ur! iiN r U nliin f P. . 2 U M. f ; Ol 11 PR/PSLN rum cu t..n .: .n av::.erno.au L .m1 mL vot:ry :ra .v..r:cw em: A mm cu .5 comen. R; vision 32 \
FLGlMA f CE~!! .Wi'.1.13Mi CO. August,1996 sr. wc et. ANT Page 26 of 73 I DATE VEPtMED F* 38 T 4 !NmAL U *^'
-18tPPENDlX A 2.0 POST MAINTENANCE TEST SHEETS (A.O.10) INDICATOR FORM Unit o 2. lNPWO g7o,/gy Work Order 9fefo g3 6 Task of Component Tag Number Associated Component System e
- T.Z Y O9 Equpment Name/ Component Desenption 7"fM>rm A ru k 6 . l*Hb.*t Ms & A"~e E R ele.serl/ue,, (.d.Avr4 *T*A u K Bnet Repair Desenption: #
Pri t A L Testypg Requiret I initial Sat ,
Unsat Indicator Calibration M , /
O Channel Functional Test YChannel Check O System (Tubing) Pressure Leak Check (Local ind.)
[M ,
[
O O
O
,-1 O :
O ' '
O O -
O O l Testing Unsat Comments:
/ I PMT COMPLETE (NO DEFERRAL)
DATE: 4 / 3 /t /-
PMT DEFERRED I List tests DEFERRED:
BLANKET NPWO #: BLANKET WO #:
MAINT. SUPV.: DATE: / /
DEFERRED TEST RESULTS ACCEPTED BY PMT LEAD: DATE: / / /R32 IF ANY TEST IS UNSAT, NPWO #: WO# FOR REWORK EQUIPMENT RETURNED TQSEF1VtCE: ' e NPS/ANPS/NWE:
V
/H"'tMVw ' . , . DATE: $/ T Ob COMMENTS: ' ~/ J '
3 v
I
.. .- / ,
.- i tL l l
CHEMISTRY DEPARTMENT UPDATE 8/29/96 Due to the recent events associated with our Dept. and outside influences such as QA Audits, I would like to clarify certain expectations and responsibilities of Dept. personnel. As you all know we are now working in a different environment with heightened expectations. The !
following areas need our immediate attention:
A. Procedure Adherence I know this has been emphasized over and over, but we have to become very aware of the dangers of not using our procedures correctly. Keep the list of procedures that was '
distributed to you a couple of weeks ago in a very obvious place so you can refer to it when there is any question on whether a procedure is required "in hand" or not. If you are requested to perform some task that we do not have a procedure for and you don't think j it falls in the " skill of craft" category, then contact supervision. Be careful!!
If you are using a procedure and it is incorrect, STOP IMMEDIATELY! Contact supervision for guidance.
l B. QA Audit Findings '
There were a few of the QA Audit fmdings that we can correct immediately. The following expectations will be effective immediately: I
- 1. Three sigma violations on QC Charts shall be handled in the following manner.
A. Another QC check shall be performed immediately.
B. Lf_this f check fails, then corrective actions shall be taken and another QC check shall be performed. If this check is successfbl then the instrument can be used for analysis. REMARKS shall be placed in the template to reflect corrective actions, etc.
C. If.the instrument cannot pass the QC check, then it shall have a tag placed on it declaring it "OOS DO NOT USE" REMARKS shall be placed in the template to reflect the reason for the failure.
D. Only with Chemistry Dept. Supervisor approval may an instrument be used for analysis if the QC check fails via a three sigma violation.
- 2. The Standards and Sources Log shall be completed immediately upon the following:
A. Whenever a standard / buffer is removed from the Chem Store Rm and placed in the Cold Lab for EV use OR taken to the Sewage Treatment Labs. Lot number components are being added to the appropriate templates, these shall be filled out. The Sewage Treatment Labs will have both a Standards and Sources Log and a Standard Prep Log.
B. Inconsistencies in the completion of Chain Of Custody forms is a problem that will be addressed by Bo Butler / Training. One positive aspect of the audit
I will be the reduction in the number of samples requiring Chain Of Custody.
- 3. QC Chans for the Counting Room detectors will be handled as follows:
A. The QC Charts for the GeLi detectors and the Scint. are automatically sent to the VAX and the graphs updated. This makes ensuring there are no three sigma violations different from other instruments. The three sigma ;
acceptance criteria will be located on the Surveillance Card printout for the !
Counting Room. When you perform the QC Check verify the instrument is I within three sigma by companng your value to the value on the card. If the QC Check fails proceed as per # 1 above.
C. Unit 1 Process Monitor Responsibilities The Unit 1 Process Monitors have been turned over to the I&C Dept. The only procedure )
we currently have is the one to perform SOURCE CHECKS. We sull have the
{
responsibility to perform ALL source check surveillances on Unit I until further notice. !
I&C is revising their procedures to take over this responsibility. (Except for Gas and Liquid Rad Waste) Calls for support from Ops. will be handled as follows:
- 1. Inform Ops. that we do not have any procedures for troubleshooting monitor problems. They need to contact the Rotating Maint. Manager . We will be more than happy to provide any technical advice, etc. that they may require, but we will not perform any hands on work. Charlie Marple will issue a night order to this effect.
- 2. In addition to the SOURCE CHECKS the Chemistry Dept. will continue to be responsible for changing the effluent monitor installed charcoals and filters on a monthly basis.
- 3. The I&C Dept. has the responsibility for changing the Containment filter paper on both Unit I and 2. We do not have a procedure for this function!
D. Monitor Setpoints Effective Friday (8/30/96) the setpoints on the following monitors will be adjusted as follows:
Each Rx Unit's ALERT Alarm HIGH Alarm Plant Vent 5 X Current Reading 40 % Site Limit (No change)
FHB 5 X Current Reading 5 % Site Limit (No change)
Cont. PIG 2 X Current Reading 3 X Current Reading Air Ejector 2 X Current Reading 3 X Current Reading We will be adjusting these setpoints on a monthly basis. We will work with Ops to revise the OFF NORMAL procedures to keep us from unnecessary sampling.
Until these procedures are revised we may be asked to perform grab samples on the PV or FHB due to Alert Alarms. Comply with the NPS's wishes.
l
f I
l I
I 1
l E. Attention To Detail j Everyone needs to be more questioning about results. Look at previous data, etc.
If you get warnings, etc. during result entry. STOP and review your result. WHAT does the warning mean. Is this a VALID result. What ACTION should I take.
1 If you are performing anyjob function outside the boundries of the Chemistry Labs that l may influence plant operations, safety, tech specs, etc. and ;he procedure / guideline that !
you are using has not yet been upgraded to include signoffs/IV's, it is strongly advised that you ask a fellow technician / supervisor to perform an IV ofyour actions. We cannot afford any more mistakes related to valve mispositioning or procedure noncompliance.
We need your input and help! If you have a better way of doing something or we need new equipment to perform ourjob function, let me know. You may end up with the responsibility for implementing the change, but that is the only way we are going to improve our performance rapidly enough to meet management expectations. We are ALL guilty of operating in the " fly by the seat of your pants" mode. This is no longer acceptable! We must change our way of doing business and the sooner we make all of the necessary changes, the quicker we can make it back to the top. We have more knowledge and experience than most Chemistry Departments in the country, lets put it to good use.
.