View source for L-83-287, Responds to NRC Re Violations Noted in IE Insp Rept 50-389/83-16.Corrective Actions:Process Sheets Will Include Const Hold Points That Will Be Signed Off,Providing Ongoing Status of Required/Completed Insps

{{Adams
| number = ML20076F970
| issue date = 05/09/1983
| title = Responds to NRC Re Violations Noted in IE Insp Rept 50-389/83-16.Corrective Actions:Process Sheets Will Include Const Hold Points That Will Be Signed Off,Providing Ongoing Status of Required/Completed Insps
| author name = Uhrig R
| author affiliation = FLORIDA POWER &amp; LIGHT CO.
| addressee name = Oreilly J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION II)
| docket = 05000389
| license number = 
| contact person = 
| document report number = L-83-287, NUDOCS 8306140510
| title reference date = 03-25-1983
| package number = ML20076F957
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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       .J u c' REG 10H 3 NTA. GEORGI A                                                          =
nonio^ eowEn a ucsr cour*~v B3 MAY 17 A 8 : 45                           May 9, 1983
                                                                        .         L-83-287 Mr. James P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30303

==Dear Mr. O'Reilly:==

Re: St. Lucie Plant - Unit #2 Docket No. 50-389 IE Inspection Report 83-16 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.
In response to Paragraph 4 of your letter of March 25, 1983, regarding our justification for the resolution of the finding identified in Audit Number QAC-PSL2-80-49, we agree, based upon our review at turnover, that an audit resolution requiring inspection status at all times during plant construc-tion would have been more prudent. In order to assure that this type of audit resolution was an isolated instance, a review of 46 other audits involving the FPL inspectiun program was conducted by a qualified independent FPL Lead Auditor. This review revealea satisfactory audit resolutions in all cases.
To ensure the effectiveness of our management systems and our QA Program during plant operation, all management audit reports and responses will be forwarded to the Company Nuclear Review Board for an independent second level review.
There is no proprietary information in the report.
Very truly yours, l A kh4    p Robert E. % rig Vice President Advanced Systems and Technology REU/PLP/ cab Attachment cc: Harold F. Reis, Esquire 8306140510 830525 PDR ADOCK 05000389 0                   PDR                                                   PEOPLE. . SERVING PEOPLE

Violation 389/83-16-01 10 CFR 50, Appendix B, Criterion X, and the accepted QA program (FPL Topical Quality Assurance Report) requires that a program for inspection of activities affecting quality be established and executed to verify conformance with docu-mented instructions, procedures and drawings for acc...plishing the activity.
10 CFR 50, Appendix B, Criterion XIV, and the acceptec QA program requires that measures be established to indicate the status of inspections of individual itema of the nulcear power plant. These measures are required to provide for identi-fication of items which have satisfactorily passed required inspections to pre-clude inadvertent bypassing of required inspections.        FPL Procedure Number QP 14.2 implements this requirement by requiring that inspection status be main-tained during construction through use of construction process sheets, test plans or other status indicating documents. These status indicating documents are necessary to provide a clear indication of the inspection status to preclude the bypassing of any required inspections.
Contrary to these requirements, (1) the program for inspection of structural steel welding and bolting was only partially executed in accordance with the established structural steel inspection program (QI 10.5, Structural Steel Inspection) for seismic Class I structural steel in safety related structures.
As a result, a large percentage of seismic Class I structural steel was not in-spected during steel erection as required by QI 10.5 and (2) the inspection status for seismic Class I structural steel was not maintained during construction.

===Response===
: 1. FPL concurs with the finding. We acknowledge that ongoing inspection status of structural steel bolting and nonuniquely identified welding was not main-tained during construction up to the time of civil turnover.        Inspection status at the time of civil turnover was substituted for ongoing inspection status. This resulted in approximately 30% of required structural steel bolting and welding inspections to be performed at the time of civil turnover.
: 2. The root cause of the inadvertent bypassing of required inspections has been determined to be insufficient hold points for the inspection of structural steel bolting and nonuniquely identified welding.       FPL QA Audit Report QAC-PSL-80-49 identified the fact that inspection status was not fully docu-mented in all cases. This finding was resolved by management action which allowed documenting inspection status at the time of turnover.        At that time, this decision was judged to be acceptable since final verification of inspec-tions would be accomplished as a part of civil turnover.
_ 3 '. To provide verification that the inspection of structural steel bolting and welding was adequate, a team of structural inspectors was brought to.the jobsite at the time of civil turnover to review existing records against required inspections, to document any bypassed inspections, to develop inspection packages, and to ensure that requried inspections were then per-formed. This effort resulted in final verification that all required inspec-tions were performed and documented.       In addition, the Mechanical Equipment List was reviewed to assure that all items were identified for inspection,
!                   and the SQP-64 Appendix B review was conducted by the QA Records Center to l                   verify that all identified inspections have been performed and that the Inspection Records are on file.

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: 4. In order to preclude recurrence of this problem, any required future seismic structural steel erections will be accomplished in accordance with specific Process Sheets. The Process Sheets will include construction hold points, that will be signed off, thus providing ongoing status of any required / completed inspections. The system for controlling inspection j                           status during Unit 2 Backfit will incorporate the use of a Plant Change Modification (PCM) Packages and specific Process Sheets.
: 5. Full compliance has been achieved.
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