ML20129F425
| ML20129F425 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/23/1985 |
| From: | Runyan M, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20129F352 | List: |
| References | |
| 50-321-85-12, 50-366-85-12, NUDOCS 8507170333 | |
| Download: ML20129F425 (11) | |
See also: IR 05000321/1985012
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET.N.W.
ATLANTA, GEORGI A 30323
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Report Nos.: 50-321/85-12 and 50-366/85-12
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Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-321 and 50-366
License Nos.: DPR-57 and NPF-5
Facility Name: Hatch I and 2
Inspection Conducted: April 29 - May 3, 1985
Inspector: [1AWNw
522186
M. F. Runyah
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Date Signed
Approved by: M //w
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C. M. Uprigh~t/Jecti.
Chief
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Division of Riacto -' afety
SUMMARY
Scope: This routine, unannounced inspection involved 32 inspector-hours on site
in the areas of licensee action on previous enforcement matters, surveillance
testing and calibration control program, measuring and test equipment program,
and licensee action on previously identified inspection items.
Results: Two violations were identified - Noncompliance with Unit 1 Technical
Specification Surveillance Test Frequencies and Inadequate Calibration Procedures
in the Maintenance Tool Shop.
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8507170333 850531
ADOCK 05000321
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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J. Beck, Maintenance Foreman
E. Burkett, Engineer, Reactor Systems
T. Elton, Engineer and Supervisor, Regulatory Compliance
- P. Fornel, QA Site Manager
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D. Griffin, Performance Engineer
- C. Jones, Engineering Manager
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8. Keck, Engineering Supervisor, Reactor Systems
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- H. Nix, General Manager
J. Payne, Engineer. Regulatory Compliance
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T. Powers, Superintendent, I&C
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J. Purvis, I&C Foreman
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- T. Seitz, Maintenance Manager
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H. Scarborough, Maintenance Supervisor
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- C. Stancil, Engineer, Regulatory Compliance
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- L. Sumner, Operations Manager
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- S. Tipps, Superintendent, Regulatory Compliance
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Other licensee employees contacted included technicians and office
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personnel.
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NRC Resident Inspector
- P. Holmes-Ray, Senior Resident Inspector
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- Attended exit interview
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2.
Exit Interview
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The inspection scope and findings were summarized on May 3, 1985, with those
persons indicated in paragraph I above. The inspector described the areas
inspected and discussed in detail the inspection findings Itsted below,
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Violation:
Inadequate Calibration Procedures in the Maintenance Tool
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Shop, paragraph 5.a.
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Violation: Noncompliance with Unit 1 Technical Specification Surveil-
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lance Test Frequencies, paragraph 4.
The licensee denied the violation
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on the basis that their interpretation of the Technical Specification
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was consistent with the wording provided.
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Inspector Followup Item: Promptness of Evaluations of Out of-Tolerance
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Measuring and Test Equipment, paragraph 5.b.
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Inspector Followup Item: Method of Verifying Validity of Previous Test
Results for Out of-Tolerance Measuring and Test Equipment, paragraph
5.c.
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The licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Severity Level IV Violation 321, 366/84-33-01:
Failure to Issue
Audits Within TS Required Timeframes.
The licensee response dated November 5,1984, was considered acceptable by
Region II. The post audit conference is now considered the completion of
the audit as prescribed by the ANSI Standard.
The QA Site Manager is
required to ensure the timely issuance of the audit and uses a checklist to
this end. Procedure QA-05-01 was revised to clearly define the Technical
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Specification requirement to issue audits within 30 days of completion.
From a review of six audits since the citation, all were issued within
30 days of completion.
The inspector concluded that the licensee had
determined the full extent of the violation, taken action to correct current
conditions, and developed corrective actions needed to preclude recurrence
of similar problems.
Corrective actions stated in the licensee response
have been implemented.
4.
Surveillance Testing and Calibration Control (61725)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
Quality Assurance Program
Requirements (0perations), Revision I
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(d) Technical Specifications, Section 4
The inspector reviewed the licensee surveillance testing and calibration
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:
A master schedule for surveillance testing and calibration delineates
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test frequency, current status, and responsibilities for performance.
The master schedule reflects the latest revisions of the Technical
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Specifications and operating license.
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Responsibilities are assigned to maintain the master schedule up-to-
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date and to ensure that required tests are performed.
Detailed procedures with appropriate acceptance criteria have been
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approved for all surveillance testing requirements.
The program defines responsibilities for the evaluation of surveillance
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test data as well as the method of reporting deficiencies and
malfunctions.
The inspector also verified that similar controls have been established for
calibration of instruments used to verify safety functions but not spect-
fically 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:
QAM, Section 5, Instructions, Procedures, and Drawings, Revision 36
QAM, Section 16, Corrective Action, Revision 36
QAM, Appendix B, Safety Related Items
"Q" List, Revision 36
40AC-REG 01-0, Technical Specifications Surveillance Program,
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Revision 0
40AC-ENG01-0, Inservice Inspection Program, Revision 0
10AC-MGR03-0, Preparation and Control of Procedures, Revision 2
SIGM-CALO3-0, Calibration Program for LCO/B0P Instrumentation,
Revision 0
The master schedule for Technical Specification (TS) surveillance testing
and inservice inspection of pumps and valves consists of a computer data
base for each unit. This data base lists the procedure number, responsible
group, test type, required frequency, grace period, TS requirement, due
date, and ten previous performance dates for each required test. The data
base was recently audited by an outside consultant after several errors were
found.
The licensee submitted licensee event reports (LER) to document
problems such as failing to revise the data base correctly for a TS amend-
ment. The independent audit and intensive efforts by the licensee provide
reasonable assurance that the data base is now consistent with the TS.
Additional problems were identified with implementation of the program. In
one case, the licensee waited until the last permissible date to perform a
test, then incurred problems with badging personnel essential for its
performance, and thus exceeded the limit.
In another case, an inadvertent
sign-off of a tracking sheet was lined out inconspicuously such that
personnel missed the fact that it had not been performed.
LERs were
submitted for these and similar problems.
Several NRC violations were
submitted for both licensee-identified and NRC-identified deficiencies.
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Other areas of program deficiencies were recently identified in the
following site QA audits:
QA-84-539, QA Audit of the Surveillance Program, December 13, 1984
QA-85-66, QA Audit of the Site Chemistry Program, February 21, 1985
QA-85-069, QA Audit of Reactor Physics, March 5, 1985
QA-85-146, QA Audit of Test Equipment, April 8, 1985
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Among the problems identified by these audits were procedures not fully
implementing the TS, failure to review test data, and errors in testing
frequency.
The licensee is aggressively pursuing the closing of these
items.
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The following surveillance test work packages were reviewed to check program
implementation:
HNP-1-3117-M, Reactor Water Level Loop Calibration, 1/8/85
HNP-1-3966-1, Air Test on Torus Headers and Nozzles, 6/5/84
HNP-1-3006-1, Main Steam Valves Closure Test, 4/6/85
These work packages appeared complete, met acceptance criteria, were
properly reviewed, and were performed on the dates specified by the data
base.
The licensee's program of inservice inspection (ISI) of pumps and valves as
required by ASME Code Section XI, Subsections IWP and IWV, is pending
approval from the Division of Licensing, NRC.
The following ISI work
packages were verified complete and found to meet procedural acceptance
criteria.
HNP-1-3405-1, RCIC Pump Operability, 1/10/85
HNP-1-3303-1,2,3, HPCI Pump Operability, 2/22/85
HNP-1-3201-1,2, Core Spray Pump Operability, 3/14/85
The licensee is required to establish a calibration program for in plant
process instrumentation associated with safety-related systems or functions.
A master calibration schedule addresses both safety-related and balance-of-
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plant instrumentation and provides information similar to the surveillance
test schedule. The following plant instruments were chosen at random from
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several ISI and surveillance test procedures to verify their inclusion in
the calibration program:
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IE41-R601
HPCI Pump Discharge Pressure
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HPCI Pump Flow Rate
E21-R600
Core Spray Pump Discharge Pressure
E21-R601
Core Spray Pump Flow Rate
B21-R607
Vessel Shell and Flange Temperature Recorder
E11-N015A-B
RHR Loop Flow Transmitter
C41-N003
Standby Liquid Control Tank Temperature
The above instruments were included in the program. Calibration frequencies
appeared consistent with instrument type and good engineering practice.
Within this area, one violation was identified. Unit 1 TS 1.0-II states,
" Periodic surveillance tests, checks, calibrations, and examinations shall
be performed within the specified surveillance intervals.
These intervals
may be adjusted plus or minus 25%."
The licensee disagreed with this
violation on the basis that their program to control surveillance test
frequency was developed to assure consistency with the specific TS wording.
Region II management discussed this issue with NRC headquarters and deter-
mined that this TS is intended to limit the time between any two tests to
125 percent of the specified interval.
The licensee interpreted that the
plus or minus 25 percent could be applied independently to fixed scheduled
intervals in such a manner that a test performed 25 percent early, then 25
percent late the next time, could result in 150 percent of the TS interval
between two tests. Other Region II facilities having similar TS wording are
testing in compliance with the NRC intent stated above.
The following
examples are monthly tests which exceeded the maximum performance interval
of 38.75 days required by TS 1.0-II:
Residual Heat Removal Pump Flow (LPCI Flow Switch) Test required by TS
Table 4.2-5(7) performed 1/7/85 and 2/20/85 or 44 days between tests.
Main Steam Isolation Valve Closure Test required by TS Table 4.1-1 (10)
performed 7/26/84 and 9/5/84 or 41 days between tests.
High Drywell Pressure Instrument Test required by TS Table 4.1-1(5)
performed 1/3/85 and 2/12/85 or 40 days between tests.
The performance of these tests were not affected by plant condition or
operating mode. These examples are not all inclusive. Failure to comply
with Unit 1 TS surveillance test frequencies is identified as violation
321/85-12-01.
5.
- Measuring and Test Equipment Program (61724)
References:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
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Quality Assurance Program
Requirements (Operations), Revision 2
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(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
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for the Installation, Inspection, and Testing of
Instrumentation and Electric Equipment, August 11, 1972
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(e) ANSI _ N45.2.4-1972,'
IEEE
Standard,
Installation,
Inspection, and Testing Requirements for Instrumentation
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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
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had been established in accordance with regulatory requirements and industry
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guides and standards. The followf ag criteria were used during this review
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to determine the overall acceptability of the established program:
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Responsibility is_ delegated and criteria established to assign and
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adjust calibration frequency for each type of M&TE.
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An equipment inventory list identifies all M&TE used on safety-related
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components, the calibration frequency and standard, and the calibration
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procedure.
Formal requirements exist for marking -the latest calibration date on
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each piece of equipment.
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The program assures that each piece of equipment is calibrated on or
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before the date required or stored in a location separate from in-
service M&TE.
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Written requirements - prohibit the use of M&TE which has not been
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calibrated within the prescribed frequency.
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_ When M&TE is found out of calibration, the program requires documented
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evaluations to determine the cause of the out of-calibration condition
and the acceptability of items previously tested.
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The program . assures that new M&TE is added to_ the inventory list and
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calibrated prior to use.
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- The documents ' listed below were reviewed to : verify that these criteria had
been incorporated-into the M&TE program:
.FSAR, Section 17.2.12, Control of Measuring and Test. Equipment-
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QAM, Section 12, Control of Measuring and Test Equipment, Revision 31
QAM, Section 16, Corrective Action, Revision 36
50AC-MNT02-0, Control of Measuring and Test Equipment, Revision 0
51GM-CAL 01-0, Control of Test Shop Instrumentation, Revision 0
51GM-MNT02-0, Maintenance Housekeeping and Tool Control, Revision 0
51GM-CALO2-0, Maintenance Shop Measuring and Test Equipment, Revision 0
The inspector reviewed QA-85-146, QA Audit of Test Equipment, April
8~, 1985.
The response date for the audited groups is May 8,
1985.
This audit
identified deficiencies addressed as inspector followup items below.
The I&C shop is the control and issue point for the bulk of the plant's
M&TE. Most equipment is sent off site for calibration. The exceptions are
pressure gages, thermometers, and stop watches.
This equipment is
calibrated according to the following procedures:
HNP-0-5936, Fluke 2160A Digital Thermometer Calibration
HNP-0-5913, Stop Watch Calibration Check
HNP-0-5901, Bourdon Tube Style Test Gauge
The above procedures provided appropriate guidance for performing the
calibration and included specified acceptance criteria.
As a check of control and accountability, the following items of M&TE were
selected from the master equipment index:
MPL No.
Description
L51-E802
Oscilloscope
L51-E827
Ammeter
L51-E840
High Resistance Meter
L51-E864
Tachometer
L51-F888
Digital Multimeter
L51-F892
Digital Multimeter
L51-F900:
Digital Multimeter
L51-F921
Digital Thermometer
L51-G506
Digital Pressure Indicator
L51-P813
Wheatstone Bridge
L51-W805
Deadweight Tester
The above equipment was properly stored, tagged, and documented or could be
accounted for with the exception of the digital thermometer. Apparently, it
had been checked out without documentation on the maintenance history card.
This appeared to be an isolated occurrence.
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The licensee .is required to evaluate previous tests performed with M&TE
found out-of-tolerance during calibration. The following evaluations were
reviewed:
Date Found
Date of
MPL No.
Instrument Type
Out-of-Tolerance
Review
L51-F895
Digital.Multimeter
10/11/84
11/29/84
L51-F911
Digital Multimeter
11/15/84
1/4/85
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L51-F912
Digital Multimeter
2/5/85
2/21/85
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Both the timeliness and the method of conducting these reviews are addressed
as inspector followup items below.
The calibration and issuance of mechanical test equipment is conducted in
the maintenance shop. The following tools were selected from the equipment
index to check control and accountability:
MPL No.
Description
24" Vernier Caliper
Micrometer 1-2"
Micrometer 5-6"
Amp Crimping Tool
Test Stand Dial Indicator
Torque Wrench
Hydraulic Torque Wrench
Dial Indicator 0-2"
The above tools were either properly stored or checked out. Calibration
stickers agreed with information provided on the master index.
Within this area, -one violation and two inspector followup items were
identified and are discussed in the following paragraphs.
a.
Inadequate-Calibration Procedures in the Maintenance Tool Shop
10 CFR 50, Appendix B, Criterion XII,- requires that measures shall be
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established to assure that measuring and testing -devices are properly
calibrated. 10 CFR 50, Appendix B, Criterion V, states that activities
affecting quality shall be prescribed by procedures appropriate to. the
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circumstances which include quantitive or qualitative acceptance
criteria.
Procedures for the calibration of test equipment in the
maintenance tool shop were reviewed.
Major.-deficiencies .were found
with procedure HNP-6943, Calibration Check on Precision Measuring
Equipment,. Revision 1.
This procedure, which addresses calibration of
, micrometers, vernier calipers, depth gauges, and dial indicators, does
not provide. 'prerequi sites such as environmental controls for. the
calibration, step-by-step instructions explaining how to perform the-
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calibration, or criteria by which to determine the acceptable tolerance
of the device. Neither vendor manuals nor other manufacturer's data
were availcble to provide this information. Calibration of precision
measuring equipment is sensitive to tn erature, rates of temperature
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change, and possibly other factors so n as humidity, dust, and vibration.
This can best be controlled by esttalishing environmental conditions
satisfactory for all calibration activities conducted in the shop.
Step-by-step instructions are necessary for quality control of any
activity directly affecting safety. Acceptance criteria must establish
tolerance bands within which the device will be considered acceptable.
Though the calibration procedure for precision measuring equipment has
been specifically discussed above, all calibration procedures in the
shop should be reviewed as a generic issue.
Failure to provide
adequate calibration procedures in the maintenance tool shop is
identified as violation 321, 366/85-12-02.
b.
Promptness of Evaluations of Out-of-Tolerance Measuring and Test
Equipment
The . licensee is committed to ANSI N18.7-1976, Section 5.2.16, which
states, "When calibration, testing, or other measuring devices are
found to be out of calibration, an evaluation shall be made and
documented concerning the validity of previous tests and the accept-
ability of devices previously tested from the time of the previous
calibration." Though the standard does not mention the timeliness of
these evaluations, this is an important consideration because invalid
settings, test data, or calibrations could invoke limiting conditions
of operation. In both the I&C and maintenance shops, many evaluations
had taken from one to three months to complete. Lengthy delays are due
in part to procedures which do not provide a.necessary time constraint.
-Site QA identified this problem in a recent audit and is awaiting
initial responses.
Until the timeliness of out-of-tolerance evalua-
tions is procedurally and effectively controlled, this is identified as
inspector followup item 321, 366/85-12-03.
c.
Method of Verifying Validity of Previous Test Results for
Out-of-Tolerance Measuring and Test Equipment
51GM-CAL 01-0, Control of Test Shop Instrumentation (I&C), Revision 0,
states'that when M&TE is found out of calibration and a review reveals
that previous tests are in question, plant instrumentation will be
retested, beginning with the most recent calibrations, until three
consecutive instruments have been checked to ensure the quality of the
remaining calibrations.
However, an item of M&TE may be out of
calibration' on several scales.
The last three tests may have been
affected by a scale only slightly out of tolerance while previous tests
may have been affected by another scale greatly out of tolerance. In
this case, the assumption that previous test are acceptable may be
erroneous.
In the maintenance shop, only the last affected test is
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rechecked though this policy is not written.
These problems were
recently identified by site QA and corrective action is in progress.
Until the program is revised to ensure that evaluations of out-of-
tolerance M&TE address the issue of multiple scales and a uniform
policy on previous usage, this item is identified as inspector followup
item 321, 366/85-12-04.
6.
Licensee Action on Previously Identified Inspection Findings (92701)
(Closed) Inspector Followup Item 321, 366/84-33-02: Management Attention to
Oetail
The QA site manager is now required to ensure that a response date is
specified in the transmittal letter to all affected groups. A sample of six
recent audits confirmed compliance with this requirement.
Procedure
QA-05-01 was revised to state TS requirements for issuing audits and to
clarify the QA escalation process.