ML17221A682

Responds to NRC 880225 Ltr Re Violations Noted in Insp Repts 50-335/86-08 & 50-389/86-07.All Environ Qualification Files Have Been Reviewed,Revised & Converted Into Doc Pacs & Placed Under Control of Drawing Program

ML17221A682
Person / Time
Site:	Saint Lucie
Issue date:	03/21/1988
From:	Conway W FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-88-137, NUDOCS 8803250297
Download: ML17221A682 (6)

See also: IR 05000335/1986008

Text

".ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM'EGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)SSION NBR:8803250297

DOC.DATE: 88/03/21 NOTARIZED:

NO CIL:50-335

St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILZATION

CONWAY,W.F.

Florida Power&Light Co.RECI0.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000335 05000389 SUBJECT: Responds to NRC 880225 ltr re violations

noted in Insp Repts 50-335/86-08

&50-389/86-07.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: D S RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEBllB

NRR/DOEA DIR11E NRR/DREP/RPB10A

NRR/PMAS/ILRB12

OGC 15-B-18 RES/DRPS DIR AL: LPDR NSIC COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 TOURIGNY,E

2 2 AEOD 1 1 NRR MORISSEAU,D

1 1 NRR/DLPQ/QAB10A

1 1~NRR/DREP/EPB10D

2 2 NRR/DRIS DIR9A2 1 1 OE LIEBERMAN,J

1 1 0M'TCEy 02 1 1 RGN2 FILE 01 1 1 NRC PDR 1 1 COPIES LTTR ENCL 2, 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 A D'OTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

r.FLORIDA POPOVER 8 LIGHT COY>w", k)ARCH 2 1 1988 L-88-137 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Re: St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Ins ection Re ort 335 86-08 and 389 86-07 Florida Power&Light Company has reviewed the Notice of Violation dated February 25, 1988, and pursuant to the provision of 10 CFR 2.201, the response is attached.Very truly yours, gC"Vr)'u"~yf W.F.Connw iy Acting Group Vice President Nuclear Energy WFC/GRM/gp

Attachment

cc: Dr.J.Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant GRM/001.IR

+Ea(BS03250297

830321 PDR ADOCK 05000335 0 DCD PEOPLE,.SERVING PEOP=".

FINDING A 10 CFR 50.49 Paragraph (J)requires in part, that a record of the qualification, iricluding

documentation

in Paragraph (D)of this section, must be maintained

in an auditable form to permit verification

that each item of equipment important to safety covered by this section is'(1)qualified for its application

and, (2)meets its specified performance

requirements

when it is'subjected

to the conditions

predicted to be present when it must perform,its

safety function..

Contrary to the above, at the time of the inspection

and as far back as November 30, 1985, the, following environmental

qualification (EQ)files did not adequately

demonstrate

qualification

of various equipment.

The data contained in the.EQ files~were inauditable

in that the information

was not documented

and organized so as to be readily understandable

and traceable.

Additionally, the data did not permit independent

verification

of inferences

or conclusions

based on the documented

information

for the following equipment'.

Rockbestos

coaxial cable-EQ File No.6.3 (Unit 2)ITT Barton 763 and 764 Pressure Transmitters

-EQ File No.9.2 (Unit 2)TEC Acoustic Flow Monitoring

Systems-EQ File Nos.22.0 and 23.0 (Unit 1);EQ File No.8.5 (Unit 2)Rome Cable-EQ File No.19.0 (Unit 1)Garrett Solenoid Valves-EQ File No.35.9 (Unit 2)General Cable-EQ File No.8.0 (Unit 1)Victoreen Radiation Monitoring

System-EQ File No.26.0 (Unit 1)RESPONSE 1.Florida Power R Light Company (FPL)concurs with the finding.2t Based on the NRC concerns identified

in the NRC EQ Inspection

Report dated August 7, 1986, there were three main reasons for the finding.The first can be traced to the fact that unofficial

hard copies of the EQ Files were inspected rather than'the official record copy on microfilm in the St.Lucie QC Vault.The second is a difference

in engineering

opinion of the acceptable

methods and levels of documentation

required to demonstrate

qualification.

The third was a lack of time to respond to the question raised by the inspector on the morning of the last day of the inspection.

Page 1 of 4

The following specific items mentioned in the Notice of Violation are examples of the first reason.A recent review of the microfilm record copy indicated that the entire profiles for the Rockbestos

cable (Unit 2 EQ File 6.3)and for the ITT Barton Transmitters (Unit 2 EQ File 9;2)were in the record copy at the time of the inspection

and had been xeroxed incorrectly

when the hard copies were made.(The profiles were on fold out pages and were copied in the folded position.)

Similarly for Rome cable (Unit 1 EQ File 19.0), the entire Franklin Report is in the record copy even though pages may have been missing in the hard copy that was inspected.(It is unclear at this time whether the pages were missing from the hard copy since a recent review of the hard copy indicated that all the pages of the Franklin Report are there and the latest revision date is 4/25/85.)The following items are examples of the second reason.In the TEC Acoustic Flow Monitoring

System files (Unit 1 EQ Files 22.0 and 23.0 and Unit 2 EQ File 8.5), the mild environment

and seismic portions of the report had been removed to conserve paper on Unit 1 but were included on Unit 2 (the files were assembled by different consultants.)

Since mild environment

and seismic qualification

are outside the scope of 10CFR50.49

this was considered

acceptable.

Also, there was no reason to doubt that the appropriate

testing had been done and that the actual data taken during the test (and considered

proprietary

by TEC)was available for review at the vendor's facilities

for the following reasons.1)The test reports received from TEC indicated that the, testing program performed by TEC was very complete.2)A procedure describing

the functional

testing to be performed during the LOCA was referenced

in the files.3)A word description

of the functional

performance

of the system during the LOCA was contained in the files.4)FPL's QA department

had audited and approved TEC's QA program.Therefore a special audit to review the data was deemed unnecessary.

Similar circumstances

can be noted for the Garrett Solenoid Valves (Unit 2 EQ File 35.9)and the Victoreen Radiation Monitoring

System (Unit 1 EQ File 26.0).The Garrett SCEW sheet did not require a one year post DBA operability (Unit 2 has a maximum post'BA of 180 days)and during the inspection

was demonstrated

not to be required at all.Forty (40)year life was demonstrated

by the aging done in the test report and the Arrhenius calculation

done in the test report procedure that were in the file.Applicability

of the reports to the valves'installed

was demonstrated

by two Combustion

Engineering

letters and the use of gaskets that were not pre-irradiated

was dispositioned

by Garrett through supplemental

testing and similarity

analysis.The Victoreen qualification

Page 2 of 4

was based on analysis backed up by actual conditions

experienced

at TNI which exceeded the requirements

at Unit 1.These again were in the files at-the time of the inspection

and considered

adequate by FPL.The final item, General Cable (Unit 1 EQ File 8.0), is the result of the third reason.The question of air thermal aging qualification

arose on the morning of the last day of the inspection

with no time to respond.FPL had developed several methods in the EQ File to demonstrate

qualification

of the General XLPE cable, the strongest of which was considered

to be the Raychem report qualif ying their XLPE cable which was pre-aged.A second method also" considered

acceptable

used the General Cable'LOCA report on their XLPE cable that was not pre-aged and the original 79-01B aging analysis on the General'able.

Since this item was identified

to FPL just prior to the inspection

exit meeting, there wasn't time to point this out to the inspector.

3.The EQ Files reviewed by the inspectors

have been converted from record files to Environmental

Qualification

Documentation

Packages (doc pacs)which are living documents presently controlled

under the FPL drawing program.Comments made by the inspectors

have been incorporated

into the doc pacs.t 4.All EQ Files have been reviewed, revised and converted into doc pacs and placed under the control of the drawing program, 5.Work began immediately

after the April 1986 inspection

to convert the EQ files to doc pacs.The first revised doc pacs were issued in June 1986 with 60 percent of the work completed by the end of September 1986.The last of the original files was converted and issued by January 30, 1987.However, since the files are now living documents, they will be continuously

revised and updated.Page 3 of 4

FINDING B 10 CFR 50.49 (f)states in part, that each item of electrical

equipment important to safety shall be qualified by testing of or experience

with, identical or similar equipment, and qualification

shall include supporting

analysis to show that the equipment to be qualified is acceptable.

Contrary to the above, at the time of the inspection, environmental

qualification (EQ)File No.39.1 (Unit 2)did not adequately

demonstrate

qualification

of RDF Resistance

Temperature

Detectors (RTD), in that data required to support a qualified life of the RTV sealant used in the detectors were not included in the file.RESPONSE 1.Florida Power&Light Company (FPL)concurs with the finding.2.During the Combustion

Engineering (CE)LOCA testing of the RTD's a problem with moisture intrusion developed.

To correct this a high temperature, radiation resistant RTV was used to pot the RTD head and LOCA testing was completed.

Two letters (CE letter L-CE-8878 dated 6/29/83 and Ebasco letter P-M-SL-84-035

dated 1/10/84 included in the file prior'o the time of the inspection)

documented

that although the RTV was not aged or irradiated

it would be qualified for a 22 month period (actual Arrhenius calculated

life based on data from the Ebasco letter was 81.44'years)

and work began to redesign the RTD head or find a suitable replacement

for the RTD's.It was decided to replace the RTD's, however, suitable qualified replacements

could not be found or obtained in time to support the outage.Therefore the gaskets and RTV were replaced during the outage to, keep the CE/Ebasco letters valid for an additional

refueling cycle.During the inspection, the inspector determined

that this was an unacceptable

method to demonstrate

aging qualification.

3t 4, During the inspection

an additional

calculation

was done which demonstrated

that the LOCA test had sufficient

margin to qualify the RTV for over a 40 year life as well as the required DBA.The inspector agreed that this was acceptable

and that the calculation

should be incorporated

into the file.This was done during the review and conversion

of the files into doc pacs.All EQ Files have been reviewed, revised and converted into doc pacs and placed under the control of the drawing program.0 5.In addition to incorporating

the comments made by the inspector, information

from General Electric on the RTV was obtained and included in the new RDF RTD doc pac.The doc pac was then issued in January 1987.Page 4 of 4