IR 05000250/1984041

Insp Repts 50-250/84-41 & 50-251/84-42 on 841217-21. Violation Noted:Failure to Establish Measures for Removing Uncalibr Instrument from Svc

ML20127G046
Person / Time
Site:	Turkey Point
Issue date:	02/06/1985
From:	Casey Smith, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127F861	List: IR 05000250/1984041 ML20127F857 ML20127F966 ML20127F992 ML20127G019
References
50-250-84-41, 50-251-84-42, NUDOCS 8505200644
Download: ML20127G046 (13)

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o UNITE 3 STATES

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1. g Mo NUCLEAR REIULATORY COMMISSION

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REolON11 8 E - 101 MARIETTA STREET, # ATLANTA, GEORGIA 30303

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Report Nos.: 50-250/84-41 and 50-251/84-42 Licensee: Florida Power and Light Company -

9250 West Flagler Street-Miami,-FL 33101

Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and DPR-41

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Facility Name: Turkey Point 3 and 4 Inspection Conducted: December 17-21, 1984 Inspector: Md/ Ad '

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Approved by: M/f/f 2 f C.~M.UprighffSecffonChief ITatafSigned Division of Keact6f Safety

. SUMMARY Scope

This routine unannounced inspection involved 33 inspector-hours on site in the areas of Licensee Action on Previous Enforcement Matters, Surveillance Testing and Calibration Control Program, Test and Measurement Equipment Program, and Licensee Action on Previously Indentified Inspection Finding .

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Of the four areas inspected, no violations or - deviations were

.'identified Re sul in ts:three areas;- one apparent violation was found in one area (Failure to Establish Measures for Removing Uncalibrated Instruments From Service). i

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REPORT DETAILS . Licensee Employees Contacted

• J. Arias, Jr., Regulatory Compliance Supervisor J. Ferrare, QA Engineer B. Gorodetzer, QC Electrical I&C Supervisor

• K. Harris, Vice President-Turkey Point Plant

• E. Hayes, I&C Supervisor

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J. Kenny,. Mechanical Maintenance Supervisor D. Henry, QCSE W. Highfoot, System Performance Tech Dep *J. Kappes, Maintenance Supervisor C. Haughabrook, I&C Specialist

• J. Labarraque, Technical-Department Supervisor

• R. Longtemps, Mechanical Maintenance Supervisor F. Martone, Mechanical Maintenance Coordinator S. Matalosy, Electrical Maintenance J. Mosesso, I&C Specialist R. Reinhardt, QC Operations Inspection Supervisor H.-Schneider, Electrical Maintenance R. Sontag, I&C Measuring & Test Equipment Supervisor M. Wayland, Electrical Measuring & Test Equipment Supervisor W. Williams, Jr., Electrical Maintenance Asst. Superintendent NRC Resident Inspectors

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T. Peebles, Senior Resident Inspector

• D. Brewer, Resident Inspector

• Attended exit interview Exit Interview

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The inspection scope and findings were summarized on December 21, 1984, with those persons indicated in paragraph 1 above. The licensee acknowledged the following inspection result:

Violation, Failure to Establish Measures for Removing Uncalibrated Instruments From Service, paragraph Inability to perform surveillance of the Post Accident Hydrogen Monitoring (PAHM) system was initially identified as an Inspector Followup Ite Subsequent discussions between NRC staff and licensee management has resolved this issue by establishing temporary measures to perform the surveillance within the TS perio _- _ _ _ _

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! Licensee Action on Previous Enforcement Matters (Closed)~ Severity Level IV Violation (250, 251/83 ~.3-01): Response to Audit Findings are not Completely Adequat The licensee response - dated July 20, 1983, was considered acceptable by Region II. ~ The ' inspector reviewed Quality Assurance Procedure QP 16.1, which was revised. March 7,1984, in response to the violation. The revised-procedure paragraph 5.5, Corrective Actions for Audits Conducted by the .

Quality. Assurance Department, delineates the requirements for responses from audited ' organizations. Additionally, requirements for the scheduling of corrective actions-have been addressed in paragraph 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 probels Corrective actions stated in the licensee response have been implemente (Closed) Severity Level IV Violation (250, 251/83-36-01): Failure to provide procedures to assure purchased materials meet or exceed original requirements; resolve differences between staff relative to safety classi-fication The licensee response dated January 23, 1984, was considered acceptable by Region II. The inspector reviewed Quality Assurance procedure QP 4.1 which was revised May 24, 1984, in response to the violation. This procedure assigns responsibility to the Plant QC Supervisor for specifying the quality level of items which are consistent with the original requirements or as modified by design related document. Additional requirements are delineated throughout the body of the procedure. Administrative procedure AP 0190.4, Procurement Document Control, last revised on November 21, 1984, also addresses the requirements in paragraphs 5.1.8, 8.4.1.3 and Appendix B to assure that replacement parts are at least equal to the origina 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 problem Corrective actions stated in the licensee response have been implemente (Closed) Severity Level V Violation (250, 251/82-07-01): Failure to include acceptance criteria in a maintenance procedur The licensee response dated May 17, 1982, was considered acceptable by Region II. The inspector reviewed maintenance procedure 1207.1, Pressurizer Safety Valve Repair, Test and Setting, wherein Step 9.14.21 delineates the quantitative values for torquing the pressurizer safety valve inlet flange bolts. The flange bolting criteria calls for tightening the bolts to obtain an even compression of the gasket. The basis for this criteria is that the

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outlet flange does not constitute a high energy barrier, because the outlet side'of the Pressurizer Safety Valve is not safety-related. Step 9.14.21 of MP 1207.1 specifies the size of the impact wrench and the approximate torque to be applie 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 problem Corrective actions stated in the licensee response have been implemente . Unresolved Items Unresolved items were not identified during this inspectio . Surveillance Testing and Calibration Program (61725)

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 (c) ANSI N13.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (d) Technical Specifications, Section 4 and 6 (e) Topical Quality Assurance Report, TQR 11.0, Test Control, Revision 1 The inspector reviewed the licensee surveillance testing and calibra-tion control program required by references (a) through (e) to verify that it had been established in accordance. with regulatory require-ments, industry guides and standards, and Technical Specification The following criteria were' used during this review to determine the overall acceptability of the established progra A master schedule for surveillance testing and calibration has a been established which includes: frequency; responsibilities for performance; and testing statu The master schedule has been updated to reflect Technical Specification or license revisions.

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Responsibilities have been assigned to maintain this schedule up-to-date.

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' Requirements have been established -for conducting surveillance testing in accordance with approved procedures which include appropriate acceptable criteri Responsibilities have been assigned for review and evaluation of test dat Responsibilities have been assigned for assuring that required schedules for surveillance are satisfie .'he inspector also verified that similar controls have been established for calibration of instrumentation not specifically identified in Technical Specifications. The documents listed below were reviewed to verify that these criteria had been incorporated into surveillance testing and calibration control activitie OP 0204.2, Schedule of Periodic Tests, Checks, and Operating Evolutions, dated October 24, 1984 QP 12.2, Calibration Control of Installed Plant Instrumentation and Control Equipment, dated July 15. 1977 AP190.16, Scheduling and Surveillance of Periodic Tests and Checks Required by Technical Specification, dated August 19, 1982 AP190.73, Quality Control Surveillance Program, dated August 3, 1983 )

AP 190.19, Control of Maintenance on Nuclear Safety Related and Fire Protection System dated March 24, 1984 AP 0103.18, Facility Operating License Amendment and/or Changes, dated August 29, 1984 AP 0103.18, Facility Operating License Amendment and/or Changes, dated August 29, 1984 AP 0190.27, Electrical Department Installed Instrument Calibration Program, dated September 26, 1979 j OP 0209.1, Valve Exercising Procedure, dated September 28, 1984

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AP 0190.26, Calibration Control of Installed Nuclear Safety Related Instrumentation and Control Equipment, dated October 24, 1984 The inrpector interviewed QC personnel and reviewed several surveil-lance reports of activities conducted by the Instrumentation and Control (I&C) department. The follo, wing surveillance reports and findings were reviewed by the inspector.

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QC Surveillance Report'84-3240, Steam Ge'nerator Protection Channel Periodic Test, dated December- 13, 1984 QC Surveillance Report 84-3134, Source Range Instrumentation

' Adjustments, dated November 26,'1984 QC Surveillance Report 83-3111, Tavg and AT Control Loop Calibra-tion Check and Adjustments The inspector interviewed licensee personnel within the Technical Department to verify that inservice inspaction and testing of pumps and

- valves as required by 10 'CFR 50.55a(g) are performed. The inspector-

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reviewed the following documents in connection with this program:

FP&L letter number -L-84-84, dated ' March 30,. 1984, from J. W. Williams, Jr. , Gre;p Vice President Nuclear Energy to D. G. Eisenhut, Director, Division of Licensing, NRC, Subject:

Revisions to Inservice Test Program for-Pumps and Valve FP&L letter number L-84-190, dated July 26, 1984, from J. W. Williams, Jr. , Group Vice President Nuclear Energy to D. G. Eisenhut, -Director, Division of Licensing, NRC, Subject:

Revisions to Inservice Test Program for Pumps and Valve Letter from Steven A. Varga, Branch Chief, Operating Reactors Branch #1, Division of Licensing, to J. W. Williams, Jr. , Vice President Nuclear Energy Department, FP&L, dated August 17, 1984, Subject: Inservice Inspection - Second 10 Year Summary Progra The inspector determined that .the licensee is - conducting inservice inspection and testing of pumps and . valves. This program has not yet received final approval from the Division of Licensing, Office of Nuclear Reactor Regulation. The following procedures were reviewed by the inspector:

Cperating Procedure 3104.1, Component Cooling Water System -

Periodic Test of Pump, dated October 30, 1984 Operating Procedure 3204.1, Residual Heat Removal System -

Periodic Test, dated September 18, 1984 Operating Procedure 4004.1, Containment Spray Pumps - Periodic Test, dated September 18, 1984 The inspector interviewed licensee personnel to verify that TS amendments are incorporated within the surveillance testing and calibration progra The inspector determined that AP 0103.18'

delineates the administratve controls which ensure proper plant review,'

approval and implementation of license amendments and/or TS change e

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L License TS was amended pursuant to the issue of Amendment No.110

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to Facility Operating License No. DPR-31, and Amendment llo.104 to Facility Operating License No. DPR-41. These amendments. revised the-TS for the TMI- items in - response to generic letter 83-37, and became effective on December 17, 1984. The inspector verified implementation of the administrative controls delineated in AP0103.18 relative to the incorporation of the following items in the surveillance testing and calibration program:

Containment High-Range Radiation Monitor Containment Pressure Monitor Containment Water Level Monitor Containment Hydroge'n Monitor

.The inspector verified that implementing procedures for conduct of the TS required activities had been prepared, and the activities had been -

incorporated in licensee surveillance testing and calibration progra The . inspector reviewed the following documents in connection with TS

. amendment numbers 110 and 10 ;(1) FP&L Interoffice correspondence from J. A. Labarraque to S. G. Brian,-dated December 6, 1983 (2) FP&L interoffice correspondnece from J. A. Labarraque to J. P. Mendieta, dated June 8, 1984, Title: Calibration Flowpath Addition to PAHM AE-3-6307A and AE-3-6307B (3) FP&L interoffice correspondence from C. J. Baker to J. P. Mendieta, dated (none), Subject: Implementation of Attached PC/M 84-10 (4) Letter from Daniel G. Mcdonald, Jr., Project Manager, Operating Reactors Branch #1, Division of Licensing, NRC, to Mr. J. W. Williams, Jr. , Vice President, Nuclear Energy i

Department, FP&L, dated October- 17, 198 (5) FP&L Letter number L-84-329 from J. W. Williams, Jr. , Group Vice President Nuclear Energy Department to Mr. J. P. O'Reilly, Regional Administrator, Region II, NR In reference number 1, the licensee identified an inability to perform calibration . testing of the Post Accident Hydrogen Monitoring (PAHM)

System during normal power operation. This inability is caused by the

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need to maintain containment integrity and isolation in accordance with the TS requirements. Reference 1 further states that the Post Accident Sampling System (PASS) is similarly affected by the TS constraints, and in addition, the Post Accident Containment Ventilation (PACV) System cannot be run to perform operational checks and trouble shooting tasks during normal operation.

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References 2-and 3 address the preparation.and implementation of Plant-Change / Modification (PC/M) No.84-101 intended to provide a calibration flow path addition to Post Accident Hydrogen Monitors AE-3-6307A

- and AE3-63078. . This PC/M was prepared specifically for Unit 3. The inspector was informed that the implementation of this PC/M would enable the surveillance requirements of TS Table 4.1-1 to be performed for the containment hydrogen monitors, without the breaching of containment integrit The inspector reviewed the following P& ids:

Dwg #5610-T-E-4534, Post Accident Containment Vent and Sampling System,. Revision 5 Dwg # JPE-M-84-101/102-002, Turkey Point Unit 3 and 4 Calibration Flow Path Addition to PAHMs, Revision 1 Dwg # 5610-M-381, Hydrogen Analyzer Calibration Gas Supply These drawings showed the modifications to be made to the PAHM -system via the' implementation of PC/M 84101/102 for Units 3 and 4, which would enable the- performance of TS required surveillances without breach of

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the containment integrity. The inspector determined that a problem existed in connection with the delivery of valves required for implementation of PC/M 84-101/132. Consequent to the late delivery (Mid February 1985) of these valves, licensee management confirmed that one channel of the Hydrogen Monitoring system for Units 3 and .4 is incapable of being calibrated or tested in accordance with the require-ments of TS Table 4.1- Reference 5 addresses the submittal of a proposed TS change to allow breaching of containment integrity of a unit at power or refueling by opening certain va.1ves under administrative control The licensee

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, committed to a submittal date of January 15, 1985, for the proposed TS changes reques Pursuant to the implementation date (December 17, 1984) of TS amend-ments numbers 110 and 104, and the licensee not having submitted a request for a TS change waiving the surveillance requirements for the

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PAHM system, licensee was in a Limiting Condition of Operation (LCO),

- and was subjected to the following Action Statement for Unit 4 which was operating at 100"? power on December 17, 1984:

Action 6 With one hydrogen monitor operable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Unit 3 on December 17, 1984, was not in operation because of repairs

being made to the generator exciter system. The inspector determined that both PAHM channels for Unit 3 was inoperable at this time, v

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Licensee management stated that repairs would be made to the modified

' channel prior to startup of the uni Upon unit startup, a LC0 will exist and Action Statement 6 will be applicabl The issue of licensee inability to perform surveillance of the PAHM

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system was discussed with regional management. Subsequent discussions between NRC staff and licensee management resolved this issue, in that temporary measures have been established to- perform the surveillance within the required TS perio Within this area, no violations or deviations were identifie . Test and Measurement Equipment Program (61724)

References: (a) _10 CFR 50 Appendix _ B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criteria II and XII (b) Regulatory Guide 1.33, 1978, Quality Assurance Program Requirements (Operation)

(c) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the _ Operational Phase of Nuclear Power i'

, Plants (d) Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (e) ANSI N45.2.4-1972, IEEE Standard Installation, Inspec-tion, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations The inspector reviewed the licensee test and measurement equipment program required by references (a) through (e) to verify that it had been estab-lished in accordance with regulatory requirements, commitments in the application, and industry guides and standards. The following criteria were used during this review to determine the overall acceptability of the established progra An equipment inventory list or equivalent has been prepared which identifies the following:

All . test and measurement equipment which will be used for any reason on safety-related structures, systems, or components

The calibration adjustment frequency for each piece of equipment

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The calibration standard (national standard (s)) if applicable for each piece of equipment

.A calibration procedure to be used for each' piece of equipment

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Formal requirments exist for marking the latest inspection / calibration date on each piece of equipment or otherwise identifying the status of calibratio A system has been provided for assuring that each piece of equipment is calibrated and adjusted on or before the date require A written recuirement has been ' established which prohibits the use of test and measuring equipment which has not been calibrated within.the prescribed frequency and describes controls to prevent inadvertent use of such equip-men Out-of-calibration controls have been established which require the following:

When a piece of equipment is found to be out-of-calibration, the acceptability of items previously tested or measured will . be evaluated and documented

Evaluation of cause of out-of-calibration

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A formal system has been established to assure that new test and measurement equipment will be added to the inventory list and-calibrated prior to being placed in servic The following documents were reviewed to verify that previously listed

- criteria had been incorporated into the licensee test and measurement equipment progra QP 12.1, Calibration and Control of Measuring and Test Equipment, Revision 4 AP 0190.9, Control of Measuring and Test Equipment, dated May 18, 1984 AP 0190.23, Electrical Department Instrument Calibration Program, dated September 18, 1984 Maintenance Procedure 0731, Calibration of Mechanical Maintenance ,

Department Measuring and Test Equipment, dated May 18, 1984 The inspector reviewed the following QA audits and associated findings for

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audits conducted in this functional area by the on-site QA staf Audit Number: -QAO-PTP-84-597 Date of Audit: November 26, 1984 i

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Audit Scope: This activity audit was conducted to verify the adequacy, ,

of control of Measuring and Test Equipment by the Plant Technical Department in accordance with Administrative Procedure 019 .- Audit Number: QAO-PTP-84-555 Date of. Audit: May 24, 1984 Audit Scope: Electrical Department Instrumentation Calibration Progra Verification of Administrative Procedure 0190.23 Audit Number: QAO-PTP-84-02-532 Date of Audit: March 20, 1984 Audit Scope: Mechanical Maintenance Department Measuring and Test Equipment Calibration Progra The inspector determined that adequate administrative controls are being

' implemented within the Instrumentation and Control (I&C) calibration

. department relative to the calibration of M&TE. Additionally, this depart-ment has implemented a training program which provides certification of personnel who conducts calibration activities in this functional are These I&C Specialists are trained in test equipment repair and calibration activitie The inspector determined that other than calibration of crimping tools, no calibration activities are conducted within the Electrical Department. The licensee presently uses the service of an off-site contractor for the calibration of electrical measuring and test equipment. The inspector verified that a Certificate of Calibration is provided which includes information concerning calibration equipment and reference standard.used for calibrating each instrumen The inspector reviewed the administrative controls and its implementation within the Mechanical Maintenance Department Measuring and Test Equipment

. (; calibration progra Within this area, one violation was identified, and is discussed in the following paragraph The inspector reviewed the PTP tool room M&TE Information Log to verify the implementation of the calibration program for mechanical M&TE. The inspector found numerous examples of instruments that were beyond the past due date for, the next calibration, without any records to indicate whether or not these instruments were removed from the program and placed in an out-of-calibration statu Instruments were identified for which the records indicate calibration having been performed beyond the "next due date", without any records to indicate whether the instruments were removed from service during the period they were past due calibration. The root m .- -.

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cause appears to be a deficiency not only in the implementing procedure MP G703, but also in AP-0190.9. Typical examples are as'follows:

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. DIAL INDICATORS Calibration Due-Equipment Number Frequency -Date Status

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P-5 6 months 8/11/84 -Unknown P-3 6 months 12/3/84 Unknown

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, P-1 6 months 12/3/84 Unknown O. D. MICROMETERS Calibration Due Equipment Number Frequency Date Status P-111 6 months 9/4/84 2 mos. late P-112 6 months 9/4/84 2 mos. late P-113 6 months 9/4/84 2 mos. late >

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P-114 6 months 9/4/84 2 mos. late P-115 6 months 9/4/84 2 mos. late GI-39 6 monnths 8/3/84 10 days late

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GA-40 6 months 8/3/84 10 days late T .GI-41 6 months 8/3/84 10 days late V GI-42 6 months 8/3/84 10 days late GI-43 6 months 8/3/84 10 days late P-100 6 months 11/27/84 24 days late

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sP-101 6. months 11/27/84 24 days late

Administrative Procedure 0190.9, paragraph 8.5 states the requirements

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~for removal from service of any Measuring and Test Equipment (M&TE) that is out of calibration, past due calibration, or requiring s repai Additionally, paragraph 8.5.2 states that if the subject M&TE cannot be satisfactorily repaired and recalibrated, it shall be removed from' service by:

Removing its Equipment Calibration Record

Entering on the Equipment Calibration Control Log,

" Permanently removed from Service", and the date of such remova *

Disposition of the M&TE

, The implementing procedure for calibration of M&TE in the Mechanical T- Maintenance Department is MP 073 This procedure references 4 AP 019 It does not establish within the body of the procedure, administrative controls that are applicable to the removal from service, instruments that are out of calibration for whatever cause.

r Additionally, while AP 0190.9 delineates the programmatic controls applicable to the removal from service of instruments that cannot be

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repaired and recalibrated, it does not address the removal from service of instruments that are past due calibration, or are out of calibra-tio Instruments that. are past due calibration or exceed required

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calibration tolerances does not inherently mean the instrument is damaged and repairs and recalibration of the instrument is require The procedure does not address the removal from service of instruments that are past due calibration or are found to exceed required calibra-tion tolerance Quality Assurance audit GAO-PTP-84-02-532 finding IV, " Failure to follow procedure for removal from service", addresses programmatic deficiencies in the removal from service of broken and out of calibra-tion instruments. The corrective action delineated in FP&L interoffice correspondence from R. A. Longtemps to K. L. Jones dated May 14, 1984, does not address the root cause of the problem in that the distinction between the administrative controls applicable to removal from service of broken instruments, and the controls applicable to instruments that are past due calibration or are found to exceed required calibration tolerances, have not been addresse This failure to establish measures to assure that tools. gages,  ;

instruments, and other M&TE used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within limits is identified as Violation 250/84-41-01 and 251/84-42-0 . Licensee Action of Previously Identified Inspection Items (92701)

(Closed) Inspector Followup Item 250, 251/83-36-03, General Employee Training Procedure Inconsistency. The inspector reviewed Administrative Procedure 0304 which had been revised in response to the previously identfied inspection finding. Paragraph 8.5 has been upgraded to require that all employees who need to enter the plant protected area be given the General Employee Training Orientation. Additional requirements for Health Physics training and a description of the responsibilities assigned to the Health Physics Supervisor and the Security Supervisor have been addresse (Closed) Inspector Followup Item 250, 251/83-36-04 Upgrading of I&C Maintenance Department lesson Plans. The inspector reviewed the Steam Generator Level Lesson Plan PRA-IC-IV-4(e)-1, revised January 1984, and verified that the lesson plan had been upgraded to include changes implemented by Plant change / modification 79-33. Additionally, the inspector reviewed the Condensate System lesson plan PRA-IC-IV-5(D)-1, revised

, January 1984, and verified that the lesson plan had been upgraded to reflect (. changes to system configuration caused by design change k (Closed) Inspector Followup Item 250, 251/81-30-01, Safety-Related Instru-

ment Not on Calibration Schedule. The inspector reviewed the Document 1 Verification Actions / Feedback Sheet (page 48 of AP 0190.15) for PC/M-CPWO

\ No's81-314 and 81-113, and verified that BIT electrical heat tracing had j been disconnected. Pursuant to the BIT having also been isolsted from the

CVCS system by the above PC/M's, surveillances of BIT temperature instru-

) ments is no longer require \

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