ML17341A365: Difference between revisions

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#REDIRECT [[L-81-250, Ack Receipt of IE Insp Repts 50-250/81-09 & 50-251/81-09 on 810406-10 & 13-17.No Proprietary Info.Corrective Actions:Ltr Issued Emphasizing Proper Review Channels for Special Tests]]
| number = ML17341A365
| issue date = 06/15/1981
| title = Ack Receipt of IE Insp Repts 50-250/81-09 & 50-251/81-09 on 810406-10 & 13-17.No Proprietary Info.Corrective Actions:Ltr Issued Emphasizing Proper Review Channels for Special Tests
| author name = Uhrig R
| author affiliation = FLORIDA POWER & LIGHT CO.
| addressee name = Oreilly J
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| docket = 05000250, 05000251
| license number =
| contact person =
| document report number = L-81-250, NUDOCS 8107240342
| package number = ML17341A364
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 12
}}
 
=Text=
{{#Wiki_filter:~ I    J t                        OFFICIAL COPY P.O. BOX 529100 MIAiUll,F L 3315 4
FLORIDA PO'VcR 5 LIGHT COMPANY June 15, 1981 L-81-250 Mr. James P. O'Reilly, Director, Region Office of Inspection and Enforcement II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
 
==Dear Mr. O'Reilly:==
 
Re:  Turkey Point Units 3 & 4 Docket Nos. 50-250 & 50-251 IE Ins ection Re ort 81-09 Florida  Power  & Light Company has reviewed the subject inspection report and a response  is attached.
There  is  no proprietary information in the report.
Very  truly yours, Robert E. Uhrig Vice President Advanced Systems    & Technology REU/PLP/ras cc:  Harold F. Reis, Esquire 8107240342 8l0702 PDR ADOCK 05000250 8                  PDR
 
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Re:  Turkey Point Units 3 & 4 Docket Nos. 50-250 & 50-251 IE Inspection Report 81-09 FINDING:
A. 10 CFR  50.59(b) requires the licensee to maintain records of tests and experiments and these records shall include a written safety evaluation which provides the bases for the determination that the test or experiment does not involve an unreviewed safety question.
Contrary to the above, safety evaluations for test numbers 79&3, 79-15, 80-01, 80-04, 80-07 and 80-08 were not performed.
 
===RESPONSE===
FPL  concurs with the  finding.
The    reason  for  the finding was failure to follow          the administrative procedure for processing special tests.
As  corrective action, safety evaluations were written for the special tests and were given to the inspector at the exit interview.
(A-4)    As  corrective action in order to avoid future problems, we will issue a letter to plant departments, emphasizing the proper review channels which must be adhered to for special tests.
Tentative plans are also in the discussion stage concerning the possibility of developing a check off sheet for special tests which would insure" that processing would be conducted in a systematic method.
(A-5)    Full compliance will be achieved    by June 30, 1981.
FINDING:
B. 10 CFR  50, Appendix  B criterion V and the accepted Quality Assurance (QA)
Program    Technical  Quality Requirement 5.0 require that activities affecting quality be prescribed by documented procedures and shall be accomplished in accordance with these procedures.          Procedure QP 17,1.
The Collection and Storage of Quality Assurance    Records  for Nuclear Power Plants, Revision 6 dated October      1980,'equires  that a  log of QA records be included in the receipt control system and states that maintenance of QA records transmittals is an acceptable log.
Contrary to the above, a log or transmittal maintenance system is not in use for quality identified recorder charts received at the site document control center.
 
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===RESPONSE===
            'B-1)
                  'FPL concurs  with the finding.
(B-2)        The"  reason for the finding was that we did not interpret the requirement for record transmittals to apply to recorder charts.
(B-3)        As    corrective    action,    a  receipt  control      process  has  been established    for all recorder charts that are transmitted to the site  document  control center.
( B-4)        As  corrective action in order to avoid further problems,              this process has become a permanent policy for document control (B-5)        Full compliance    was achieved on May 15, 1981.
FINDING C. 10 CFR 50,        Appendix  B  Criterion  V and  the accepted    QA  Program Technical Quality Requirement 5.0 require that activities affecting quality be prescribed by documented procedures and shall be accomplished in accordance with these procedures.            Procedure AP 0190.14, Document Control and Quality Assurance Records, dated August 1980, requires that record custodians shall keep records cabinets locked when not in use.
Contrary to the above, on          April 8,  1981, the Health Physics (HP) quality records cabinet in the HP          trailer  was observed    open and unattended with the trailer unlocked.
 
===RESPONSE===
(C-1)        FPL  concurs with the  finding.
The    whole  body    count trailer was in the process of being relocated    when  the record cabinet was discovered unlocked and unattended.      It was an inadvertent oversight in the rush of making preparations to move the trailer which resulted in the cabinet not being closed and locked when the trailer personnel exited the trailer for      it  to be moved.
As  corrective action, upon discovery of the unlocked cabinet by the inspector, the cabinet was immediately locked.,
As  corrective action in order to avoid further problems, Health Physics administrative personnel were re-instructed in the procedural requirements for the records cabinet.
(C-5)        Full compliance    was achieved    on  April 18,  1981.
 
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FlNDING:
D. 10 CFR  50, Appendix    B Criterion    V and the accepted  QA Program Technical Quality Requirement 5.0 require that activities affecting quality be prescribed by documented procedures and shall be accomplsihed in accordance    with these procedurs.          Procedure    AP  0190.72,  Receipt Inspection, Identification and Control of Nuclear Safety Related and Fire Protection Parts, Materials and Components, dated August 1980, requires that Quality Control (QC) inspection tags (denoting material acceptance) will remain attached to the control material until installation in the plant system.
Contrary to the above, several      "QC required" items including Asco Valves and  Namco  Switches  were  observed  in the Instrumentation and Control Section material control cabinet without the required QC tags.
 
===RESPONSE===
(D-1)    FPL  concurs with the finding.'
Investigation into the reason that these tags        were not attached to the items did not reveal why they had been removed.            It was established that the tags had been placed on these items as required by our procedure requirements.        The most likely reason for the missing tags was a misunderstanding of the tag removal requirements by I&C personnel.
As  corrective action, our QC Department was notified of the problem. QC personnel    immediately reconfirmed that the proper documentation requirements had been fulfilled and then placed new tags on the item's which were "QC required" material.
(D-4)    As  corrective action in order to avoid further problems, I&C Department  supervision was notified of the problem and personnel within the I&C Department were counseled on the proper procedural requirements.
(D-5)    Full compliance  was  achieved  April 30, 1981.
FINDING:
E. In response to Item A.3 in the Notice of Violation transmitted by the Region  II  letter dated June 20, 1979, FP&L correspondence dated July 12, 1979, listed the following long term corrective action involving rigging and hoisting equipment:
(I)      The  submittal of an exception to the FPL Topical'uality Assurance Report by June 20, 1979 to describe this program.
(2)      Inclusion of this program into Corporate Quality Procedures and Turkey Point Administrative Procedures          within 30 days after approval of the Topical Quality Assurance Report revision.
 
t (3)      Full compliance      will  be    achieved    upon  revision    of  these procedures.
Revision  3  to the FPL Topical QA Report was submitted as required by item (1). FPL  stated during the inspection that full implementation had been achieved on September 1980 as intended by items (2) and (3).
Contrary to the above, inclusion of this program relative to the exception involving rigging and hoisting equipment into<<rM<<<<Quality Procedures    and Turkey Point Administrative Procedures              had not been accomplished as of the date of this inspection.
 
===RESPONSE===
(E-1)    FPL  concurs with the    finding.
Topical Quality Assurance Report Revision 3 addressed                      an inspection program'i which complied with certain sections of ANSI 45.2.2 concerning< rigging and handling equipment.                  A draft revision to Quality Procedure 13.2 was prepared to reflect these changes.      The draft Quality Procedure was presented              to our review committee for approval but was tabled for additional work.      Inadvertently, the procedure was not reworked due to administrative oversight. In the meantime, the NRC issued NUREG 0612, 'Control of Heavy Loads.          Upon review of the NUREG      it  was
-              realized that the ANSI N45.2.2 program requirement and the NUREG-0612 program requirements are very closely related and that our
              ,FPL program should address          the requirements of both of these documents.      Therefore, our commitment date to implement these changes must be delayed.
As  corrective action,    we have begun our studies      and  evaluations as  requested    by the NRC letter dated December          22, 1980 which accompanied NUREG&612. The revised QP 13.2 was              approved by our review committee on June 11, 1981 and              it  is  scheduled to be issued by July 31, 1981.
As  corrective action in order to avoid further problems, NUREG-0612, Control of Heavy Loads, is              in the process of being addressed by FPL.        The requirements      which we intend to meet through    NUREG-0612  will  accomplish  in. the  long term, the ultimate goal of establishing a standard rigging and hoisting inspection and    use  program. We  will  also take the necessary        actions to comply    with our revised  QP  13.2.
Full compliance will      be achieved by October 22, 1981, which is the date we have scheduled for the submittal of our final response to NUREG 0612
 
p STATE OP PLORXDA        )
                        )        ss COUiilTY OP DADE        )
Robert E. Uhr i          being      first      duly sworn, deposes and says:
That he i.s            Vice President                              of Plorida Power a Light Company, the Licensee herein; That he has executed the foregoing document; tha the -state-            -
ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.
Robert E. Uhrig Subscribed, and sworn to before              me    this 15    day  of        June NOTARY PUBLXC      in and  fo" the County of                Dade, State  o  Plorida Notary Public, State of Rorida at Large h5y Commission Expires October 30, t983 My  commission expires:
 
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