ML20133N912
| ML20133N912 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/25/1985 |
| From: | Runyan M, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133N890 | List: |
| References | |
| 50-335-85-16, 50-389-85-16, NUDOCS 8508140051 | |
| Download: ML20133N912 (23) | |
See also: IR 05000335/1985016
Text
{{#Wiki_filter:~
h
'
. UNITED STATES
[4 Kaog o, NUCLEAR REGULATORY COMMISSION
^
O' REGION ll
j #' 101 MARIETT A STREET. N W.
* * * A T L ANT A. GEORGI A 30323
g, v.....f
Report Nos.: 50-335/85-16 and 50-389/85-16
Licensee: Florida Power and Light Company
9250 West Flagler Street
Miami, FL 33102
Docket Nos.: 50-335 and 50-389 License Nos.: DPR-67 and NPF-16
Facility Name: St. Lucie 1 and 2
Inspection Conducted: June 24-28, 1985
Inspector:_ ,1
8
c% i +9 6 6 7
1
M. F. Runyan Date Signed
Acccmpanying Personnel: R. M. Latta, Region II
M. A. Scott, Region II
Approved by:_[ [[
C. M. Upright, 5
g
ton et
[ _[ ateT$1$nedJ
~
Division of Rea, or Sa ty
SUMMARY
Scope: This routine, unannounced inspection involved 108 inspector-hours on sito
in the areas of licensee action on previous enforcement matters, QA program
review, audits, audit implementation, records, document control, QA/QC admini-
stration, surveillance testing and calibration, measuring and test equipment
(M&TE), and licensee actions on previously identified inspection findings.
Results: One violation was identified - Failure to control environmental
conditions for calibration of M&TE.-
0300140051Q$8h[$30
PDH ADUCK PDH
G
- - _ - _ _ - - _ _ _ - _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ - - - _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ .
e -
*
-
.
,
REPORT DETAILS
1. Persons Contacted
Licensee Employees
J. Adams, Lead Auditor
*A. Bailey, QA Operations Supervisor
*H. Buchanan, Health Physics
*D. Culpepper, Power Plant Engineering
A. Deroy, GEMS Planner
T. Dillard, Maintenance
*R. Frechette, Chemistry
M. Goodiel, Maintenance Supervisor
K. Harris, Vice President
D. Heycock, ISI Coordinator
D. Howard, QC Inspector
*R. Justine, Procurement Agent
G. Kozlowski, Vault Custodian
*M. Lamp, Construction Superintendent
W. McGarie, Lead Auditor
*T. McKinon, ISEG
*R. Marr, Systems Supervisor
*B. Parks, QA Supervisor
L. Pearce, Operations
*L. Rich, NPS
J. Riley, QC Engineer
*N. Roos, QC Supervisor
D. Sagar, Plant Manager
*M. Smith, System Protection
R. Spooner. QA Supervisor
*D. Stewart, Lead Performance and Test Engineer
J. Vessely, Manager of QA
J. Walls, I&C
N. Wesms, QA Superintendent
*R. Yaung, Mechanical Maintenance
Otner licensee employees contacted included construction cra f tsmen,
technicians, mechanics, and office personnel.
NRC Resident Inspectors
*R. Crlenjak, Senior Resident Inspector
H. Bibb, Resident Inspector
* Attended exit interview
_ _ _ _ - _ _ -
-
. .
.
:2
l
2. Exit Interview l
The inspection scope and findings were summarized on June 28, 1985, with
those persons indicated in paragraph 1 above. The licensee did not identify
as proprietary any of the materials provided to or reviewed by the inspector
during this inspection. The inspector described the areas inspected and
discussed in detail the inspection findings listed below.
Violation: Failure to Control Environmental Conditions for Calibration
of M&TE, paragraph 11.a
Unresolved Item: Torque Wrench Acceptance Criteria, paragraph 11.b
3. Licensee Action on Previous Enforcement Matters
a. (Closed) Severity Level IV Violation (335/84-12-01, 389/84-14-01):
Failure to Include Gages in Calibration Program
The licensee response dated July 2, 1984, was considered acceptable by
Region II. The inspector reviewed Corrective Action Request (CAR)
6-6-84 including licensee documentation stating that Instrumentation
and Control (I&C) has performed a 100% check of all safety-related
instruments for inclusion in the calibration program. The inspector
verified that the subject gages had been added to the calibration
program by examining FPL I&C procedure 1-1400064, Revision 23, and
procedure 2-1400064, Revision 4 As further verification, a, sample of
safety related instruments in the calibration program were examined and
discrepancies were not identified. The inspector concluded that the
. licensee had determined the full extent of the violation, taken action
to correct conditions, and developed corrective actions needed to
preclude recurrence of similar problems. Corrective actions stated in
~
the licensee response have been implemented.
b. (Closed) Severity Level V Violation (335/84-12-02, 389/84-14-02):
Failure to Audit to Necessary Depth
The licensee response dated July 2, 1984, was considered acceptable by
' Region II. The inspector reviewed licensee documentation contained in-
CAR 6-9-84 and QA Audit No. QSL-0PS-84-329 dated October 26, 1984.
Examination of this information indicated that the QA Department had
placed an increased emphasis on the depth of audits to include all
programmatic aspects. . Additionally, the inspector reviewed a letter
from Mr. N. T. Weems to plant QA' personnel dated April 2,1985, which
provided specific guidance to QA auditors in the areas of administra-
'
tive review and personal verification of completed work. The inspector
.
concluded the licensee had determined the full extent of the violation,
taken action to correct conditions, and developed corrective actions
needed to preclude recurrence of similar problems. Corrective actions
stated in the licensee response have been implemented,
j
,
+ . .
. .. .
.. ..
. . __-
. _ _ _ _ _ _ _ _ _ _ -
-
. .
.
3
4. Unresolved Items l
An Unresolved Item is a matter about which more information is required to
determine whether it is acceptable or may involve a violation or deviation.
A new unresolved item identified during this inspection is discussed in
paragraph 11.b.
5. QA Program Review (35701)
References: 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear
Power Plants and Fuel Reprocessing Plants
The inspector reviewed the licensee QA program required by the above
reference to verify that these activities were conducted in accordance with
regulatory requirements. The following criteria were used during this
review to assess overall acceptability of the established program:
-
Personnel responsible for preparing implementing procedures understand
the significance of changes to these procedures.
-
Licensee procedures are in conformance with the QA program.
The procedures discussed throughout this report were reviewed to verify
conformance with the QA program.
.
The inspector reviewed the Commitment to Excellence Program (CEP) dated
I June 5,1985, which is a spin-off of the Performance Enhancement Program
begun at Turkey Point Nuclear Plant in 1984. Additionally, inter-office
correspondence of April 15, 1985 (QAC-PSL-85-075) which contained a schedule
of CEP tasks for completion by QA and QC was reviewed. Reportedly, the
effective aspects of the Turkey Point program have been incorporated into
CEP. The inspector interviewed QA and QC ~ personnel as to the progress of
these program commitments. The inspector was informed of the following:
Increased QA staff size (four additional positions.to be filled)
Increased QA personnel training
Increased QA technical expertise (one recently hired QA personnel was
a licensed operator)
Improved communication between QA and site personnel
Trend analysis and reporting
Performance monitoring to address plant systems / hardware
and real-time operating activities
Expanded QA and QC surveillance programs
1 1 .
. .- - _ - _
! .
-
.
.
1
- 4
,
QA audits to assure that CEP commitments are being met
Since the previous inspection of this area, a number of QA implementing
procedures have been revised. The revisions of procedures (QI QAD)
generated at the corporate offices were reviewed for conformance to QA
program description, Topical Report, and applicable codes, standards, and
regulatory guides. Additionally, a sample of procedure revisions issued at
the site received the above review and licensee personnel were questioned as
- to the cause for the change, the significance of the change, and whether the
'
change upgraded the QA program. The following site procedures were
,
discussed and reviewed:
i
QI 1-PR/PSL-7 Quality Control Organization, Revision 5
QI 2-PR/PSL-1 Quality Assurance Program, Revision 5
QI 2-PR/PSL-2 Indoctrination and Training of St. Lucie Personnel,
Revision 12
QI 6-PR/PSL-1 Document Control, Revision 9
QI 16-PR/PSL-1 Corrective Action, Revision 16
QI 17-PR/PSL-1 Quality Assurance Records, Revision 7
As a result of the Quality Improvement Program which preceded CEP, two of
these procedures were changed. One of the instructions was changed as a
j result of a QA audit. In all cases, the procedures were upgraded and the
reason for the revision was understood by site personnel. '
The inspector discussed QA program implementation and other topics with QA
personnel. The inspector reviewed general'onsite QA program implementation
as a part of the inspection. Each specific area is detailed in other
paragraphs of this report. Problem areas, if identified, are detailed in
the specific area inspected.
Within this area, no violations or deviations were identified.
6. Audits (40702 and 40704)
References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants, and Fuel Reprocessing Plants
i . . (b) Regulatory Guide 1.144, Auditing of Quality Assurance
Program for Nuclear Power Plants
(c) ANSI N45.2.12-1977, Requirements for Auditing of Quality
Assurance Programs for Nuclear Power Plants
(d) Regulatory Guide 1.146, Qualification of Quality
Assurance Programs for Nuclear Power Plants
t
. . - . - _ _ - - - - -- . - . _ .. . . . - - . - . . _ _ - - . - - . - - - - - _ - ,
__
-
. .
.
5
:
(e) ANSI N45.2.23-1978, Qualification of Quality Assurance
Program Audit Personnel for Nuclear Power Plants
3
(f) Regulatory Guide 1.33, Quality Assurance Program
Requirements (Operation)
J (g) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
- Plants
(h) Technical Specifications, Section 6
1 The inspector reviewed the licensee audit program required by references (a)
through (h) to verify that the program had been established in accordance
j with regulatory requirements, industry guides and standards, and Technical
Specifications. The following criteria were used during this review to
determine the overall acceptability of the established program:
-
The audit program scope was defined consistent with Technical Specifi-
i
cations and QA program requirements.
I -
Responsibilities were assigned in writing for overall management of the
audit program.
-
Methods were defined for taking corrective action on deficiencies
identified during audits.
- -
The audited organization was required to respond in writing to audit
! findings. 1
-
Distribution requirements were defined for audit reports and corrective
j action response.
-
Checklists were required to be used in performing audits.
j
-
Measures were established to assure that QA audit personnel met minimum
- education, experience, and qualification requirements for the audited
activity.
The documents listed below were reviewed to verify that these criteria had
j been incorporated into the auditing program: j FPL-NQA-100A Topical Quality Assurance Report, Revision 7
QP 2.2 Revision of the Topical Quality Assurance Report,
Revision 4
i QP 2.3 Quality Assurance Program Review, Revision 8
QP 2.4 Preparation and Revision of Quality Instructions,
i Revision 6 4
. _ _ _ . _ _ _ _ . _ _ _ _ _ _ , . . _ . _ _ . _ _ _ . , . _ _ _ _ _ _ _ _ _ . . - . _ _ _ _ _ _ _ . _ . _ _ _ _
_
-
. .
.
6
i
QP 2.5 Quality Assurance Indoctrination and Training,
Revision 6
QP 2.7 Identification of Safety-Related and Nuclear
Nonsafety-Related QA Required Structures, Systems,
Components and Services, Revision 1
QP 2.9 Qualification of QA Audit, QC Inspection and
Construction Test Personnel, Revision 5
QP 16.1 Corrective Action, Revision 8
1 QP 18.1 Conduct of Quality Assurance Department Quality
Audits, Revision 11
QI2 QAD 4 Preparation and Revision of QAD QIs, Revision 6
QI2 QAD 6 Control of the QA and QI Manual, Revision 2
QI9 QAD 1 Personnel Qualification and Certification in
Nondestructive Testing in Accordance with
SNT-TC-1A, Revision 3
) QI16 QAD 3 Controlling Contractor / Supplier Audit Open Items, , Revision 4 _ l 4
QI16 QAD 4 Corrective Action Follow-up for Quality Assurance
Audits, Revision 7
I
QI16 QAD 5 St. Lucie Projects Quality Assurance Surveillances,
Revision 1
QI18 QAD 2 Auditing of the Quality Assurance Committee,
Company Nuclear Review Board, and the Quality
Assurance Department, Revision 0
QI18 QAD 3 Scheduling of Quality Assurance Department Audit
Activities, Revision 4
QI16-PR/PSL-1 Corrective Action, Revision 16
, The Quality Assurance Monthly Report for May 1985 and the Joint Utility
Management Audit (JUMA) Report QAS-QAD-85-1 dated March 25-29, 1985, were
reviewed by the inspector. In each document, one and four findings were
indicated respectively. The monthly report item involved plant change /
modification transmittal from corporate offices to both FPL sites had been
open since September 4, 1984. Per the monthly report and Backfit Document
,
Control personnel, this controlled transmittal issue would be closed on
June 30, 1985. Of the four JUMA audit findings, two items were expediti-
, ' ously closed and the two remaining items are realistically scheduled for
completion. The JUMA open items (findings 6 and 13) dealt with auditor
i
I
.
_
__ . _ . -
. . - - - -
,
l
.
' -
.
l
7
(other than lead) and QC technician qualification requirements and adequacy
of the audit program. The qualification finding was based on the ANSI
'
N45.2.23 requirement for the responsible organization to establish qualifi-
cation for auditors and technical specialists and retain records of these
qualifications. The auequacy finding was based on the Topical Report
requirements to evaluate work areas, activities, processes, and items and
implementation of operating and test procedures. The evaluation of imple-
mentation is addressed in the CEP program and responses to both JUMA audit
findings were positive in nature.
- To verify audit program implementation, the inspector reviewed the following
.
audits:
.!
QSL-0PS-84-324
4
QS L-OPS-84-331
QSL-0PS-84-332
QSL-OPS-84-336
QSL-OPS-84-339
l
QSL-0PS-84-344
QSL-0PS-85-348
y QSL-0PS-85-356 i QSL-0PS-85-358
I
l The inspector verified that the sample of audits listed above were performed
within scheduled limits, issued within the required time, and that the
"
i
response to the findings met time requirements or had extensions granted.
The inspector generally reviewed corrective actions for findings identified
A
in these audits. TS audits are discussed in paragraph 10. The inspector
reviewed the auditor's qualification packages and verified that the lead
j auditors met the minimum required standards.
Within this area, no violations or deviations were identified.
1
7. Records (39701)
..
References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.88, Collection, Storage, and Mainte-
I nance of Nuclear Power Plant Quality Assurance Records l (c) ANSI N45.2.9, Requirements for Collection, Storage, and
Maintenance of Quality Assurance Records for Nuclear
j Power Plants
(d) Regulatory Guide 1.33, Quality Assurance Program
j Requirements,(Operation)
(e) ANSI N18.7-1976, Administrative Controls and Quality
.
Assurance for the Operational Phase of Nuclear Power
!
Plants
! l
.-. -.- - - -
- - - - - - . . --- , -. . _. -.- . - - , - - , . _ - . - - .
_ -- - - ._ - - . .- _ _ - .-
i
.
> . 1 > 8 ,
(f) Technical Specification, Section 6
1
The inspector reviewed the licensee records management program required by
references (a) through (f) to verify that the program had been established
in accordance with regulatory requirements, industry guides and standards,
and Technical Specifications. The following criteria were used during this
review to determine the overall acceptability of the established program:
-
Requirements and provisions were established to maintain essential
quality records.
>
-
Responsibilities were assigned in writing for overall management of the
records program.
-
Records storage controls were established in accordance with FSAR
commitments.
1 -
Records storage facilities were described in writing.
-
Provisions had been made to establish the retention periods for all
types of records.
-
Methods had been specified for the disposal of records no longer
required.
The following documents were reviewed to verify that these criteria had been
incorporated into the records program:
FPL-NQA-100A Topical Quality Assurance Report, Revision 7
QP 3.4 Plant Changes and Modifications for Operating
Plants, Revision 7
QP 3.6 Control of FPL Originated Design, Revision 3
QP 3.2 Backfit Procedures, Revision 0
QP 17.1 The Collection and Storage of Quality Assurance
Records for Nuclear Power Plants, Revision 12
QI I-PR/PSL-7 Quality Control Organization, Revision 5
QI 1-PR/PSL-8 Administrative Organization, Revision 0
1
QI 2-PR/PSL-1 Quality Assurance Program, Revision 5
l QI 17-PR/PSL-1 Quality Assurance Records, Revision 7 -
l
I
. - _ - _ _ ..._..__ _ . -. ,_., .__,_, , _ _ _ _ _ _ . ~ _ . _ _ . , . _ _ , . _ . _ , _ . . _ , . . _ . _ . _ . . . - , . . . . - , _ . _ _ _ _ . _ .
- -- .-. . . - . _ _ _ - - _ - -.
' '
. .
, .
9
.
The following records were retrieved from the St. Lucie document control
system:
Nuclear Control Center Operations Daily Log, May 17, 1985
Plant Work Order 2215, Interim Ultimate Heat Sinks, April 1,1981
PCM 208-283 - Unit 2, Charging Pump "0" Ring Modification, November 8,
1983
i
LER 84-10, September 23, 1984
Operating Procedure 1800050, Monthly Fire Valves and Fire Pumps
Surveillance, June 19, 1985
- Administrative Procedure 1-0010125, Schedule of Periodic Tests, Checks,
. and Calibrations Data Sheet No. 8, Quarterly Valve Cycle Test, May 31,
1985
Purchase Order 18656 - 67089A, Crosley Valve Seal Part Number
3760087-2, May 7, 1985
Quality Control Report 3900-14361, Procedure Compliance OP 0010122 and [
0010129, July 6,1984
Personnel Health Physics Examination Record, June 22, 1984
j I&C Procedure 1-1400064, Installed Plant Instrumentation Calibration,
Appendix C, July 15, 1983 ' l The above records were readily retrievable and the quality of the microfiche ! record was good. Several of the records were tracked by the inspector ! through their review cycle. Several of the records were being processed for
t filming (at an intermediate point) prior to becoming a QA record. The l intermediate controls were adequate. QA audit reports, 10 CFR 21 reports, j and QA personnel qualification packages are not maintained as QA records on
site; these records as well as a number of other records such as control
ll room logs are stored at other corporate sites. During performance of the ] audit procedures, QA audit reports and qualification packages were retrieved . from off site within one day or less. 1 -
Space is at a premium in the small vault area which also serves as a primary
work area. The vault houses two computer terminals, at least two microfiche
- tape machines and three or more employees. Control room logs are kept in l
- cardboard boxes and manila envelopes which accumulate for one year prior to
- being shipped off site; this accumulation takes up considerable floor space
- in the vault. Plans were underway to store the logs in cardboard files at
!
the time of the inspection. With the addition of a new simulator building
in 1986, existing additional vault space should become available as the
training group moves to their new location.
l
. - - _ , , . _ - . - . . ..__. - - - _ - - - - - - - . _ . - - . , . . - , . . - - . . - . - . . - . -
. - - - - . . _ _ . - . - - - - - -- = _ _ - .. . _ = _ - . - . - - .
.
' '
i . I i
10
, i ) Within this area, no violations or deviations were identified. ! ! 8. Document Control (39702) - 1 . ) References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for i Nuclear Power Plants, and Fuel Reprocessing Plants ! ) (b) Regulatory Guide 1.33, Quality Assurance Program i Requirements (Operation) , ! i (c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(d) Technical Specifications, Section 6
The inspector reviewed the licensee document control program required by
'
references (a) through (d) to verify that the program had been established
in accordance with regulatory requirements, industry guides and standards,
and Technical Specifications. The following criteria were used during this
review to determine the overall acceptability of the established program: ;
! -
Administrative controls had been established for issuance, updating,
j and recall of outdated drawings. . , j
-
Master indices were maintained for drawings, manuals, and procedures. -
-
Administrative controls had been established for distributing, updating
and recall of outdated documents.
I
-
i Admir.i strative controls had been established for distribution of j as-built drawings and P& ids in a timely manner. i l
-
Administrative controls had been established to control discrepancies
i between as-found conditions and as-built drawings. I !
The documents listed below were reviewed to verify that these criteria had
been incorporated into the document control program:
i FPL-NQA-100A Topical Quality Assurance Report, Revision 7 i l QP 2.4 Preparation and Revision of Quality Instructions, l . Revision 6 ! l QP 3.4 Plant Changes and Modifications for Operating j Plants, Revision 7 4 1 QP 6.1 Control of Construction Project Contractor
- Drawings, Specifications, and Procedures,
j Revision 1 ! 1 ,
. ~.--.. .. _ _ . - - _ - _ , - --
, _ , - . , , . -_ _ _ m ._ m . _ . _ , - - . . - - _ - _ - , - _ , ,
_ . _ . _ _ _ _ _ _ _ . . _ _ _ . _ _ . .. _ __. _ ._ . . _ .
,
'
l, . . , I
11 l!
l QP 6.2 Control of Documents Issued by Florida Power and
- Light Company, Revision 4
4 QP 6.6 Drawing Control for Operating Nuclear Power Plants, ,
Revision 1
I
QI 3-PR/PSL-1 Design Control, Revision 13
QI 4-PR/PSL-1 Procurement Document Control, Revision 7
QI 5-PR/PSL-1 Preparation, Revision, Review / Approval of
Procedures, Revision 26
1
i QI 6-PR/PSL-1 Document Control, Revision 9
l
l
The inspector selected several controlled documents which were issued within
- the previous two months and verified that they were issued and received at
j various controlled document locations. The following documents were
reviewed:.
Drawings Procedures Technical Manuals l
{
r
i 2998-G-078 I&C 1400055 8770-4139 i
i 2998-G-089 CM M-003 2998-12218 :
] 8770-G-081 QI 7-PR/PSL-1 2998-11976 j 2
C0 C-120
A0 0005746
A0 0005723
OP 0630022
i OP 0910050
OP 0120026
j HP 14F
I
l Copies of each document containing revisions consistent with the master } index were found at each location checked. Each location checked maintained i l a master index of controlled documents. l
- Within this area, no violations or deviations were identified.
i l 9. QA/QC Administration (35751) l
' 1
j References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for j Nuclear Power Plants and Fuel Processing Plants. ' a i.
l (b) FSAR Section 3.2, Classification of Structures, Systems,
and Components.
.
I
"
(c) Regulatory Guide 1.33, Quality Assurance Program i
) Requirements (0perations), Revision 2. ' i , i 4 4 ;
- I
i ,
j
l
_ _ _ _ _ _ _ . . _ . , _ _ _ _ - , _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _ , _ ,____ _ _ _
_ -
, - .- . --- .. . . . - - .-- .. - . . --- . _ -
_
.
- -
,
,
)
12
'
i
(d) ANSI N18.7-1976, Administrative Controls and Quality < Assurance for Operational Phase of Nuclear Power Plants.
i
(e) Technical Specifications, Section 6
i The inspector reviewed the licensee QA/QC administrative program required by
references (a) through (e) to verify that the program had been established
j in accordance with regulatory requirements and industry guides and stand- l '
ards. The following criteria were used during this review to determine the
overall acceptability of the established program:
,
' -
The QA program documents clearly identified those structures, systems, l
components, documents, and activities to which the QA program applies. j
.
l
l -
Procedures and responsibilities were established for making changes to l
QA program documents. l
<
.
! -
Administrative controls for QA/QC procedures required review and ,
i approval prior to implementation, control of revisions, and control of l
distribution and recall. l
{
-
Responsibilities were established to assure overall evaluation of the i
effectiveness of the QA program.
! !
-
Methods existed to modify the QA program to provide increased emphasis i
on identified problem areas.
~
,
i
The documents listed below were reviewed to verify that the previously
j listed criteria were incorporated into the Itcensees QA/QC administration j program.
FPL-NQA-100 Topical Quality Assuran'ce Report, Revision 7
QP 2.2 Revision of the Topical Quality Assurance Report,
~
Revision 4
!
!
QP 2.3 Preparation and Revision of Quality Procedures, !
j Revision 8 :
'
!
l QP 2.4 Preparation and Revision of Quality Instructions, '
Revision 6 i
!
QP 2.7 . Identification of Safety Related Structures, Systems,
i and Components, Revision 1 ,
!
!i QP 2.12 FPL QA Program Applicability for Fire Protection Systems,
Revision 2
QP 5.1 Operating Plant Procedures, Revision 3
QP 10.3 Inspection and Surveillance, Revision 6
i
- i
1
-e.,- ,m--- , - . . , - - , - ----,,--,.n, ,..-,,.--n.e, . ..-n-----,..-. ,, ,,,,-m -n .,m.-e-=,.-- -. --~-g-,-- r
n
- . . _-. __ - - . . _- - - _ . .-_ -. - - . . . . - _ _ _ _ . - - . - -
I l
*
t . .
*
1 l 13
5 !
QP 16.1 Corrective Action, Revision 8 ,
1
QP 18.1 Conduct of Quality Assurance Department Quality Audits,
Revision 11
QI 2-PR/PSL-1 Quality Assurance Program, Revision 10
! QI 5-PR/PSL-1 Preparation, Revision, Review / Approval of Procedures, j Revision 26
QI 16PR/PSL-1 Corrective Action, Revision 16
j QI 18-PR/PSL-2 Quality Control Surveillances, Revision 11
QI 18-PR/PSL-3 Quality Control Monitoring, Revision 4
i
'
- Site QA audits were reviewed to determine the effectiveness of the QA
! Administrative Program and these are indicated in paragraph 6. i j The inspector reviewed procedure QP 2.12 and determined that the require- j ments of Regulatory Guide 1.120, Revision 1, concerning specific criteria , j for fire protection which must be included in the licensee's QA program j j appear to be implemented by the subject Quality Assurance Manual Procedure, j
The licensee is a member of JUMA; consequently, QA program effectiveness was
reviewed during this annual audit. Findings identified during this audit
i are corrected by the established corrective action control system. The ! inspector reviewed the latest licensee JuMA Report, QAS-QAD-85-1, dated i March 29, 1985, and determined that the Quality Assurance Department was ,
j meeting its commitments and providing effective programmatic control.
4 i
Within this area, no violations or deviations were identified.
, 1
10. Surveillance Testing and Calibration Control (61725) ,
<
i
References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for i , Nuclear Power Plants and Fuel Reprocessing Plants
! L i (b) Regulatory Guide 1.33, Quality Assurance Program , i Requirements (Operations), Revision 2 i ! (c) ANSI N18.7-1976, Administrative Controls and Quality !
- Assurance for the Operational Phase of Nuclear Power !
! Plants I i (d) Technical Specifications, Section 4 I . I The inspector reviewed the licensee surveillance testing and calibration l ! control program required by references (a) through (d) to verify that the j program had been established in accordance with regulatory requirements, ! ! ! !
' ,
$
__ _ _ ___ _ ___ __ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ - - - - _ _ - _ _ _ _ _ _ _ . _ _
* . .
,
14
industry guides and standards, and Technical Specifications. The following
criteria were used during this review to determine the overall acceptability
of the established program:
-
A master schedule for surveillance testing and calibration delineated
test frequency, current status, and responsibilities for performance.
-
The master schedule reflected the latest revisions of the Technical
Specificaticas and operating license.
-
Responsibilities were assigned to maintain the master schedule
up-to-date and to ensure that required tests are performed.
-
Detailed procedures with appropriate acceptance criteria were approved
for all surveillance testing requirements.
-
The program defined responsibilities for the evaluation of surveillance
test data as well as the tethod of reporting deficiencies and malfunc-
tions.
The inspector also verified that similar controls were established for
calibration of instruments used to verify safety functions but not specifi-
cally identified in the Technical Specifications. The documents listed
below were reviewed to verify that these criteria had been incorporated into
the surveillance testing and calibration control program:
Administrative Operating Procedure 1,2-0010125, Schedule of Periodic
Tests, Checks, and Calibrations, Revision 62
Plant Operating Procedure 0010437, Schedule of Mechanical Maintenance
Surveillance Requirements, Revisian 15
Plant Operating Procedure 0010132, ASME Code Testing of Pumps and
Valves, Revision 5
QP 12.2, Calibration Control of Installed Plant Instrumentation and
Control Equipment, Revision 1
QI 5-PR/ PSL-1, Preparation, Review, and Approval of Procedures,
Revision 26
QI 10-PR/PSL-4, Plant Inservice Inspection, Revision 4
QI 10-PR/PSL-4, TS Surveillance Inspection of Reactor Building,
Revision 4
Q1 11-PR/PSL-1, Test Control, Revision 6
'
. .
.
15
QI 12-PR/PSL-1, Calibration of Installed Plant Instrumentation and
Control Equipment, Revision 3
QI 15-PR/PSL-1, Nonconforming Materials, Parts, and Components,
Revision 6
QI 16-PR/PSL-2, Corrective Action, Revision 16
I&C Department Procedure 1,2-1400064, Installed Plant Instrumentation
Calibration, Revision 23,4
The following corporate audits were reviewed to gain a perspective of the
programs current status:
QSL-OPS-84-313, QA Department Audit of PSL Units 1 and 2 TS Appendix A,
Sections 3/4.5, Emergency Core Cooling Systems and 3/4.9, Refueling
Operations, June 5, 1984
QSL-0PS-84-318, QA Department Audit of PSL Units 1 and 2 TS,
Appendix A, Section 314.7, Plant Systems, July 25, 1984
QSL-0PS-84-323, QA Department Audit of PSL Units 1 and 2 TS,
Appendix A, Section 3/4.4, Reactor Coolant System, August 29, 1984
QS L-0PS-84-331, QA Department Audit of PSL Units 1 and 2 TS,
Appendix A, Section 3/4.11, Radioactive Effluents and 3/4.12,
Radiological Environmental Monitoring, October 31, 1984
QSL-0PS-85-350, QA Department Audit of PNE Compliance to PSL Units 1
and 2 TS, Appendix A, Section 3/4.1, Reactivity Control, 3/4.2, Power
Distribution Limits, 3/4.10, Special Test Exceptions, 2.0, Safety
Limits and Limiting Safety System Sett'ings, February 1,1985
QS L-OPS-85-354, QA Department Audit of PSL Units 1 and 2 TS,
Appendix A, Section 3/4.3, Instrumentation, March 21, 1985
QSL-0PS-85-356, Quality Assurance Department Audit of PSL Units 1 and 2
TS, Appendix A, Section 3/4.6, Containment Systems, May 20, 1985
Many of the findings involved procedures which did not fully implement the
Technical Specifications (TS). As an example, a chemistry procedure lacked
a time limit on the analysis as required by the TS. The procedural response
time of a containment pressure instrument was not consistent with the TS.
These errors were promptly corrected. Many other findings of lesser
significance were identified and expediently corrected.
Surveillance tests required by the TS and inservice inspection (ISI) of
pumps and valves required by ASME Code Section XI and TS Section 4 were
scheduled together in a manual master schedule. This schedule is maintained
in the control room and is checked daily by a member of the Quality Control
e
- . . - . - _ - - - - . - . - - - - - _ - _ _ . - - - - - _ - -
' '
. .
.
,
i 16 1
'
i l staff, which is responsible for TS surveillance compliance. This system is I
well monitored and assigns enough overlapping responsibilities to greatly
'
_
reduce the probability of a missed surveillance. Grace periods are reserved ;
solely for instances where surveillance tests cannot be performed on time. ~
:
To assess program implementation, the following surveillance test work
j packages were reviewed: ! ! OP-1-0700050, Auxiliary Feedwater Periodic Test, IA AFW Pump, June 13, j 1985.
!
l OP-1-3200058, Surveillance Requirements for Total Radial Peaking
i Factor, June 14, 1985.
, ;
OP-1-0010125, Schedule of Periodic Tests, Checks, and Calibrations, 1C
'
j
Charging Pump, June 18, 1985.
'
i
J
OP-1-0410050, HPSI, LPSI Periodic Test, June 18, 1985 1
OP-1-0420050, Containment Spray -
Periodic Test, Pump, and Valve
Operability,1A Containment Pump, June 20, 1985.
'
Several questions concerning these data packages were discussed with the i licensee:
i' !
a. Some of the pump test procedures required that the pump be run until
!
three consecutive temperatures readings at 10 minute intervals do not
i
vary by more than three percent. The individual performing the test
] apparently makes this determination in the field but does not-record
the results. This could result in mathematical mistakes or in
shortcutting of the procedure. However, the licensee felt assured that
,
this was not occurring.
, l b. When installed process instruments are used to verify TS surveillance j test compliance, the current calibration status of the installed 1 instrument is not verified prior to the test. This is normally checked
! by a sticker on the gage or by checking documentation. The implied
! assumption is that the calibration program maintains all subject
instruments calibrated on schedule. As such, the calibration program
should be closely monitored to assure that the above assumption is
] valid. i
'
c. Monthly pump vibration data on the charging pumps, High Pressure Safety
Injection (HPSI) pumps, and Low Pressure Safety Injection (LPSI) pumps
was reviewed. Although all recorded readings were under the alert
{ range as defined by ASME Code XI, Subsection IWP, the vibration levels
for an individual pump of ten varied to a great extent month to month.
For example, vibration level H1 on the 1A LPSI pump was recorded as
'
1 0.98 mils on May 7,1985, and as a 0.11 mils on June 4,1985. Though I these levels are acceptable, if this data scatter remained if and when j the pump began to fail, this fact may initially be .
.
l
-
.
.
.
17
missed. The licensee stated that large fluctuations were inevitable in '
this range of small vibrations and that the fluctuations would dampen
at high vibration levels. Nevertheless, readings a decade apart may
not be fully explicable by this argument. The licensee uses handheld
vibration meters which are highly dependent on individual nuances.
Repeatability of results could best be achieved by having the same
person perform vibration tests on specified pumps. In addition, the
two types of handheld meters used, Mechanalysis Model 308 and IRD Model
306, are not entirely compatible. They have different frequency
ranges, maximum sensitivities, and amplitude ranges. As a minimum, the
type of instrument used on each pump should be consistent. The
licensee also possesses the Bently Nevada Model TK-80 handheld vibra-
tion meter, which permits frequency analysis, but this instrument was 1
not used for the vibration tests reviewed by the inspector. The
licensee maintains a periodic training program or the use of vibration
meters and it appears that increased emphasis on training may yield the
most productive results. The licensee was receptive to these concerns
and will consider them while upgrading the vibration monitoring
program.
The licensee is required to establish a program for installed process
instrumentation associated with safety-related systems or functions. ;
These instruments are listed in I&C Department procedures 1-1400069 and
2-1400064 for instrumentation located in Units 1 and 2, respectively,
and are scheduled for periodic calibration. The following plant
instruments were chosen at random from several surveillance and ISI
test procedures to verify their inclusion in the calibration program:
LT-07-2 Refueling Water Tank Level
PI-07-1A Containment Spray Pump Discharge Pressure
PI-3318 HPSI 18 Discharge Pressure
PI-3317 HPSI IC Discharge Pressure
PI-12-18A AFV Pump 1A Suction Pressure
PI-09-7A AFW Discharge Pressure
The above instruments were included in the program. Calibration
frequencies appeared consistent with instrument type and good l
engineering practice.
Within this area, no violations or deviations were identified.
11. Measuring and Test Equipment Program (61724)
'
References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.33, Quality Assurance Program
Requirements (Operations), Revision 2
L l
. . -
*
.
.
18
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance of the Operational Phase of Nuclear Power
Plants
(d) Regulatory Guide 1.30, Quality Assurance Requirements
for the Installation, Inspection, and Testing of
Instrumentation and Electric Equipment, August 11, 1972
(e) ANSI N45.2.4-1972, IEEE Standard, Installation,
Inspection, and Testing Requirements for Instrumentation
and Electric Equipment During the Construction of
Nuclear Power Generating Stations
The inspector reviewed the licensee measuring and test equipment (M&TE)
program required by references (a) through (e) to verify that the program
had been established in accordance with regulatory requirements and industry
guides and standards. The following criteria were used during this review
to determine the overall acceptability of the established program:
-
Responsibility was delegated and criteria established to assign and
2 adjust calibration frequency for each type of M&TE. I -
An equipment inventory list identified all M&TE used on safety-related
components, the calibration frequency and standard, and the calibration
!
procedure.
-
Formal requirements existed for marking the latest calibration date on
each piece of equipment.
-
The program assured that each piece of equipment was calibrated on or
before the date required or stored in a location separate from
inservice M&TE.
-
Written requirements prohibited the use of M&TE which was not calib-
rated within the prescribed frequency.
-
When M&TE was found out of calibration, the program required documented
i evaluations to determine the cause of the out-of-calibration condition
and the acceptability of items previously tested.
-
The program assured that new M&TE was added to the inventory list and
calibrated prior to use.
The documents listed below were reviewed to verify that these criteria had
been incorporated into the M&TE program:
- QAM, Section 12.1, Calibration and Control of Measuring and Test
Equipment, Revision 4
QAM, Section 12.2, Calibration Control of Installed Plant Instrumenta-
tion and Control Equipment, Revision 1
l
-
. .
.
19
QI 12-PR/PSL-1, Calibration of Measuring and Test Equipment,
Revision 12
QI 12-PR/PSL-2, Calibration of I&C Department Measuring and Test
Equipment, Revision 8
QI 12-PR/PSL-3, Electrical Measuring and Test Equipment, Revision 8
QI 12-PR/PSL-4, Instructions for Mechanical Measuring and Test Equip-
ment, Revision 7
I&C Department Procedure 1400067, Calibration of I&C Department
Measuring and Test Equipment, Revision 21
The inspector reviewed QSL-0PS-84-329, QA Auait of 10 CFR 50, Appendix B,
Criterion XII, October 26, 1984. This audit identified five findings in the
area of M&TE. One of the findings involved a discrepancy between the
Topical Quality Assurance Report (TQR) and Quality Instruction
QI 12-PR/PSL-1 in that the TQR required M&TE reference standards to have
one-fourth the maximum error of field standards while the QI required that
reference standards be at least as precise as the field standards. A TQR
change request had been submitted to NRC for approval. Another finding of
significance involved a discrepancy between Quality Procedure QP 12.1 and
Quality Instruction QI 12-PR/PSL-1. The QP delineated environmental
conditions which must be controlled for the calibration of M&TE while the QI
did not address environmental considerations. The QI was changed to be
consistent with the QP, but implementation of this policy remains inadequate
and is addressed as a violation below.
Implementation of the measuring and test equipment program was assessed in
the I&C calibration lab and the Mechanical shop. In the I&C lab, the
following items of M&TE were selected from the master equipment index to
evaluate equipment control and accountability:
PSL-011 Fluke Digital Multimete' r8600A
PSL-015 Fluke Digital Multimeter 8600A
PSL-039 General Radio Strobotac Model 1538A
PSL-111 Honeywell Visicorder Model 1858-079
PSL-137 Keithley Picoammeter Model 417
PSL-268 Ashcroft Test Gauge 0-3000 psig
PSL-39A Heise Test Gauge 0-400 psig
PSL-444 Dwyer Incline Manometer 0-1" H20
'
Initially, PSL-015 could not be found even though it was documented as being l
checked in. Later, it was determined that it was still checked out by the l
last individual listed and that the check-in had been documented by mistake.
'
This appeared to be an isolated incident.
The following calibration procedures were reviewed:
I&C Procedure 1400067
( I
*
.
..
20
Sheet #001C, Fluke 8600A, Revision 21
Sheet #013, Fluke 8012A, Revision 21
Sheet #037, General Radio Megohm Bridge Model 1644A, Revision 21
Sheet #062, Triplett 630 Multimeter, Revision 21
These procedures adequately described steps for performing the calibration
or referred to a vendor manual for this information. Acceptance criteria
was clearly stated. At least in the case of the Fluke 8600A procedure,
manufacturer's calibration environmental test conditions were not included
in the procedure. This issue is addressed as a violation below.
In the Mechanical shop, the following items of M&TE were chosen at random
from the equipment list as a check of control and accountability.
M-12 Micrometer Set 24"-30"
M-30 Torque Wrench 200 ft-lb.
M-55-7 Dial Indicator
M-75 Vernier Caliper 24"
M-87 Torquometer 600 ft-lb.
The above M&TE was either properly stored in the shop or its location was
adequately documented.
Within this area, one violation and one unresolved item were identified and
are discussed in the following paragraphs.
a. Failure to Control Environmental Conditions for Calibration of KITE
10 CFR 50, Appendix B, Criterion II, requires that suitable environ-
mental conditions be provided for activities affecting quality.
Calibration of M&TE is sensitive to environmental conditions and the
licensee's Quality Procedure QP 12.1 states:
M&TE shall be calibrated in environments which wi l not affect
their accuracy. Factors which shall be consider d include:
tem'ae ra ture , humidity, vibration, radio frequency i a.te rference ,
electromagnetic interference, background radiaticp, dust,
cleanliness, and fumes.
However, measures had not been established to control the above
environmental conditions. In the I&C lab, a strip chart temperature
and humidity recorder was operating but administrative limits defining
acceptable conditions had not been established. As a result, the
recorder is not actually monitored. Even though acceptable conditions
are probably normally maintained, the program would not preclude
calibration under abnormal, unacceptable conditions. In the Mechanical
shop, environmental conditions are not monitored for the calibration of
!
precision measuring equipment, which is sensitive to temperature, rate
! of change of temperature, and may require a period of temperature l
_ _ _ __ __
_ _ _ _
.
J
21
stabilization prior to calibration. Acceptable environmental condi-
tions should be based on vendor technical manuals and industry guides
and can either be maintained continuously or else verified prior to
each calibration known to be sensitive to a particular environmental
condition. Failure to establish measures controlling environmental
conditions for calibration of M&TE is identified as violation
335,389/85-16-01.
b. Torque Wrench Acceptance Criteria
Maintenance procedure M-0004, Torque Wrench Tester and Operation, and
Quality Instruction QI 12-PR/PSL-4, Instructions for Mechanical
Maintenance M&TE, establish the acceptance criteria for torque wrench
calibrations as 10 percent. This tolerance is considerably higher
than the intrinsic accuracy of torque wrenches, which is typically
about four percent. The unresolved issue is whether ten percent
accuracy is acceptable for all reactor plant applications. The
licensee has agreed to respond to this issue by August 1, 1985,
explaining the basis for the use of ten percent acceptance criteria.
Pending this response and further inspection, this item is identified
as unresolved item 335,389/85-16-02,
12. Licensee Actions on Previously Identified Inspection Findings (92701)
a. (0 pen) Inspector Followup Item 335/84-09-04, 389/84-12-04: Control of
Shaft Keys
The inspector reviewed CAR 5-4-84 which contained letter, EP0-84-1062,
addressing the control of shaft keys. Based on the recommendation of
Power Plant Engineering, two types of material are currently stocked
for use as spare / replacement shaft keys namely high strength steel,
A-193 (4140) and stainless steel, ASTM 564 grade 630 (17-4 PH). The
selection of these materials appears technically adequate; however, the
licensee has failed to develop a documented program to control the
implementation of shaft key usage. Based on conversations with
licensee personnel the determination of the material to be used for
spare / replacement shaft keys is delegated to the Mechanical Maintenance
Group who, by verbal agreement, decide on shaf t key material through
reference to the component drawing bill of material. As previously
stated in the referenced inspection report, until the licensee develops
and implements a program (written procedures) to control the use of
safety-related shaf t keys throughout the plant (storeroom and mainten-
ance), this Inspector Followup Item (335/84-09-04 and 389/84-12-04)
will remain open.
b. (0 pen) Inspector Followup Item 335/84-09-05, 389/84-12-05: Program to
Control the Use of Aerosols
As stated by the licensees onsite QC organization, the Program to
control the use of aerosols is a generic problem which is being
addressed at the corporate level. Because no objective evidence could
.
_ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ - _ - _ _ _ - _ _ . _ - - - _ -
.
O
22
be presented to the inspector regarding the closecut of this item it
will remain open until the licensee develops and implements a program
to control the use of commercial grade aerosols,
c. (0 pen) Inspector Followup Item 335/84-09-06, 389/84-12-06: Level A
Storeroom
CAR 5-16-84 was provided to the inspector which documented the
installation of a temperature and humidity recorder in the Level A
Storeroom. The subject recorder was placed on the I&C list and is
maintained in accordance with Procedure QI 13-SI, Revision 7. As
stated by the licensee, the temperature and humidity recorder is
positioned outside the stores supervisors of fice where storeroom
personnel " keep an eye on it". When asked what the temperature and
humidity tolerances were, the licensee stated that ANSI N45.2.2-1972
and Regulatory Guide 1.38, Revision 2 are not definitive in this area;
however, they are nominally maintained at 70F and a relative humidity
of 50 percent, which appear satisfactory. The licensee was unable to
provide objective evidence that a documented program had been imple-
mented to maintain the specified temperature and humidity and provide
for storeroom operational personnel to be aware of these parameters.
It is noted by the inspector that the requirements of ANSI N45.2.2-1972
state that items requiring Level A storage environmental controls such
as temperature and humidity shall be controlled within specified
limits. The specification of these environmental controls including
the relative tolerances is the responsibility of the licensee. Until
the licensee establishes written procedures for the control and
monitoring of temperature and humidity in the Level A storeroom, this
Inspector Followup Item will remain open.
}}