IR 05000269/1977006
| ML19322B812 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/26/1977 |
| From: | Alderson C, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322B813 | List: |
| References | |
| 50-269-77-06, 50-269-77-6, 50-270-77-06, 50-270-77-6, 50-287-77-06, NUDOCS 7912050797 | |
| Download: ML19322B812 (9) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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50-269/77-06; 50-270/77-06; 50-287/77-06 Docket Nos.
50-269; 50-270; 50-287 License Nos.
DPR 38, 47, 55 Licensee:
Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 Facility Name: Oconee Units 1, 2 and 3 Inspection at: Oconee Site, Seneca, South Carolina Inspection conducted: April 25-28, 1977 Inspector:
Carl E. Alder on TO dt7 D*2h*l7 Reviewed by:
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Richard C. Lewis, Chief Date
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Reactor Projects Section No. 2 I
Inspection Summary Inspection on April 25-28, 1977 (Report No. 50-269/77-06; 50-270/77-06; 50-287/77-06)
Areas Inspected:
Routine, unannounced inspection of calibration of instrumentation required by Technical Specifications; followup on IE Circulars; and tour of plant areas.
The inspection involved 33 inspector hours on site by one NRC inspector.
Results: Of the three areas inspected no items of noncompliance were found in two areas; two noncompliances (infraction - failure to follow calibration procedures - Para. 7.c and d; infraction - failure to take appropriate corrective action - Para. 7.1) and one deviation (instrument calibration acceptance criteria not in agreement with FSAR - Para. 7.a)
were identified in the third area.
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50-270/77-06 and 50-287/77-06 TOQM b'N'77 DETAILS I Prepared by:
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Carl E. Alderson, Reactor Inspector Date
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Dates of Inspection:
April 25-28, 1977 M
b'N" 7f Reviewed by:
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Richard C. Lewis, Chief Date Reactor Projects Section No. 2 1.
Persons Contacted J. E. Smith - Station Manager L. Schmid - Superintendent of Operations
- 0. Bradham - Superintendent of Maintenance
- R. Adams - Maintenance Engineer (I&E)
R. Knoerr - Assistant Engineer
- R. Bond - Technical Services Engineer T. Barr - Performance Engineer W. Brown - Chemist M. Thorne - Associate Health Physicist
- J. Bracket - Senior QA Engineer 2.
Licensee Action on Previous Inspection Findings Not inspected.
3.
Unresolved Items Unresolved items are matters about which more information is required in order e.o ascertain whether they are acceptable items, items of noncompliance, or deviations.
Two unresolved items disclosed during the inspection are discussed in Paragraphs 6 and 9 below.
4.
Exit Interview The inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on April 28, 1977.
The inspector summarized the purpose and scope of the inspection and the findings. With regard to the noncompliance items of failing to follow calibration procedures and failing to take appropriate corrective action, the licensee agreed that the non-compliances had occurred and stated that actions would be taken to
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O IE Rp t. Nos. 50-269/77-06, I-2 50-270/77-06 and 50-287/77-06
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assure that adequate review of completed procedures are made, that required evaluations are performed, and that discrepancies would be properly resolved. Concerning the deviation from acceptance criteria described in the FSAR, the licensee stated that the matter would be reviewed to determine the appropriate course of action.
5.
Followup on IE Circulars (IECs)
The inspector held discussions with licensee personnel and reviewed plant records to verify that the licensee had received copies of recently issued IECs.
The inspector determined that the licensee had received and forwarded copies of IECs 77-06 and 77-08 to appro-priate site personnel. The licensee had no record of having received IEC 77-05.
The inspector provided an unofficial copy of that Circular and stated that an official copy would be mailed to the licensee. The inspector had no further questions.
6.
Plant Tour The inspector toured various areas of the plant to observe opera-tions and activities in progress, to inspect the general state of
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cleanliness, housekeeping and adherence to fire protection rules, and to review with operators the reason for selected annunciated or indicated conditions.
The inspector noted that the main POWER ON indicating lamp for the Unit 3 fire detection system was not lit.
This was discussed with the operators on duty. The inspector observed activation of the system test switch and all indicating lamps except the main power lamp operated properly; however; replacing this lamp did not correct the problem. The licensee stated that a Work Request would be initiated to have the problem corrected.
The inspector met with representatives of the plant Operations Group and expressed concern that similar occurrences had been observed in two previous inspections (Ref:
IE Inspection Report 50-269/77-3, Details I, Paragraph 4.c and Details II, Paragraph 2.1, and IE Inspection Report 50-269/77-4, Details, Paragraph 8.c).
The inspector stated that it appeared that the operators were not sufficiently alert to losses of equipment status indication.
It also appears that existing procedures and administrative controls do not adequately address surveillance of status indicators to assure prompt identification and correction of such failures.
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IE Rpt. Nos. 50-269/77-06, I-3
50-270/77-06 and 50-287/77-06 Unresolved Item 77-06/I-1: Adequacy of surveillance requirements for equipment status indicators is designated as an unresolved item and will remain open pending further evaluation of existing adminis-trative controls in this area.
7.
Calibration The inspector selected ten components or systems for which calibra-tion requirements are specified in Section 4 of the Technical Specifications. For each of the components or systems selected, the inspector verified that the instruments had been calib?:ated at the required frequency, that Limiting Conditions for Operation were satisfied during performance of the calibrations and that the "as found" calibrations did not exceed Limiting Safety System Settings.
In addition, the procedures used for the most recent calibration of each of the selected components were reviewed to determine whether they had been properly reviewed and approved, that they contained appropriate instructions for performing the calibrations, and that they established adequate acceptance criteria.
i Within the areas inspected, the following discrepancies were
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identified:
Page 14A-19 of the Oconee FSAR provides the description of the a.
gas analyzer 3 be used to measure post-accident hydrogen concentrations in the reactor building stating that it has a range of 0-5 percent (volume) with an accuracy of + 2 percent of full scale.
In addition, Section 14A.4.3 of the FSAR provided justification for a control limit of 3.5 v/o H at
which purging would start.
In this justification the margin allowed for instrument error is 0.1 v/o H '
In reviewing procedure IP/0/A/210/4, " Chemical Addition and Sampling - Gas Analyzer" which was written and approved by the licensee in December 1972, the inspector noted that the established calibration tolerance was + 0.5% H which does not
agree with the accuracy specified in the FSAR.
This is a
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Deviation.
b.
In reviewing the copy of IP/0/A/210/4 used to perform the calibration of the Unit 3 Gas Analyzer in March 1977, the inspector noted that the technician had indicated a maximum
"as left" error of 0.04% H which was the maximum error for
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j IE Rpt. Nos. 50- 269/77-06, I-4 50-270/77-06 aad 50-287/77-06 the local indicator.
The data sheet indicated that the maximum error actually occurred in the computer indication and was 0.176% H. The licensee stated that calibration tolerances
and maximum error calculations normally addrecs instelled instruments rather than computer indications when both are available; however, the licensee agreed that computer errors are equally important since the computer provides certain alarm functions and may become the primary indication on failure of an installed instrument.
The licensee stated that this subject would be reviewed and acceptance criteria or tolerances for computer indications added to calibration procedures where appropriate. The inspector had no further questions.
c.
Section 10.0 of procedure IP/0/A/340/4 (Rev. 2), " Control Rod Drive Absolute Position Indication Calibration - API and RPI Group Average Calibration - Asymmetric Rod Calibration" con-tains a " Caution" statement which states "If any component calibration is out of tolerance by 2%, proceed to Maximum Tolerance Exceeded Sheet."
This sheet requires that the technician list those components which exceeded the 2% tol-erance and that the Instrument Supervisor evaluate these i
problems and describe the corrective action taken.
In reviewing the copy of this procedure used to complete the l
calibration performed on Unit 3 in October 1976 the inspector noted that an "as found" value was in error by greater than j
10% of the full scale value for the measured parameter and exceeded the specified tolerance of + 1.0 mV by a factor of almost four hundred.
The Maximum Tolerance Exceeded Sheet attached to the procedure containef no entries regarding this
"as found" condition.
This is contrary to Technical Specification 6.4.1 which requires that the station be operated and maintained in accordance with approved procedures and is an Infraction.
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d.
Section 2.0 of procedure IP/0/A/305/1M contained a list of reference drawings for Units 1 and 2 but had not been revised
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to include the appropriate references to Unit 3 drawings.
j Step 4.5 of the procedure requires that the technician verify that drawings in the Master Instrument File agree with re-ferenced drawings specified in the procedure, l
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IE Rp t. Nos. 50-260/77-06, I-5 50-270/77-06 and 50-287/77-06
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In reviewing the copy of this procedure used to accomplish the calibration on Unit 3 in October 1976 the inspector noted that Step 4.5 had been signed off as being completed even though the procedure did not contain the list of referenced drawings for Unit 3.
This is another example of failing to operate and maintain the plant in accordance with approved procedures.
e.
Data Sheets No. 2, 3 and 4 of procedure IP/0/A/280/12,
" Turbine-Generator Trips" specify the acceptable range of values for the overspeed trip; however, the data sheets do not require documentation of the actual "as found" and "as left" trip point values.
The inspector stated that this did not appear to meet the intent of the administrative requirements specified in Paragraph 3.3.3.2(b) of the Administrative Policy Manual with regard to documentation of operational accepta-bility. A licensee representative stated that the data sheets would be revised to require such information be entered. The inspector had no further questions.
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f.
During review of the copy of IP/0/A/280/12 used to accomplish i
testing on the Unit 1 turbine-generator the inspector noted that the Work Request initiating the procedure was dated March 7, 1976, and, with one exception, all steps in the
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procedure were signed off as having been completed in March 1976. The exception was the step covering the overspeed trip test which was signed off as having been completed on November 7, 1975. The inspector also determined that the computer system used to schedule required surveillance indicated that the procedure was last completed on March 22, 1977. The inspector stated that this discrepancy could lead to failure to perform surveillance at the frequency required by Technical Specifica-tions in that the procedure completion date is used to schedule the next required testing or calibration date, whereas the actual date of completion of the overspeed trip test would be used in determining conformance to the annual test requirement.
The inspector also pointed out that the licensee would be in noncompliance with Technical Specification 4.1.1 if overspeed trip testing of Unit I was not performed prior to May 8, 1977.
Licensee representatives agreed that to assure that surveil-lance requirements are met, the date to be entered into the computer should be the procedure initiation date rather than completion date and stated that administrative controls would be provided to accomplish this.
The licensee's corrective
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action will be reviewed during future inspections.
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I IE Rp t. Nos. 50-260/77-06, I-6 50-270/77-06 and 50-287/77-06 g.
Several of the procedures reviewed contained spaces on the data sheets to log "as found" values for the entire instrument string, but the body of the procedure did not contain instruc-tions in the appropriate place to obtain this information before any individual component was calibrated.
In reviewing completed copies of these procedures it appeared that "as found" values for the string were not being measured until after all individual components had been calibrated.
The inspector stated that this approach made the "as found" values meaningless and complicated any evaluations required when individual components were found out of tolerance.
The licensee agreed with these comments and stated that corrective action would be taken to assure that "as found" calibration data is properly recorded. The corrective action will be reviewed during future inspections.
h.
Two procedures, IP/0/A/231/7 and IP/0/A/280/12A, did not contain detailed instructions for performing the required calibrations. The body of the procedures contained only a list of instruments to be calibrated or tested and referenced
the data sheet (s) to be used.
The licensee stated that most non-safety-related calibration procedures were written this vay and these had been rede-signated as type-A procedures as a result of changes to the Technical Specifications, but had not been rewritten.
The licensee further stated that all such procedures would be identified and upgraded.
This will be reviewed during future inspections.
1.
In reviewing completed procedures, the inspector identified several discrepancies in the recorded data in addition to those described in paragraphs b, c, d, f and g above.
These included the following:
IP/3/A/210/4 (March 1977) - Certain calibration data required by Data Sheets No. 1 & 2 had not been entered.
IP/2/A/200/10 ( hy 1976) - Data Sheet No. 4 contained erroneous calibration data. Number entered should have been 98 instead of 198.
- Maximum (as lef t) error listed on Page 7S was 220 mV while allowable tolerance
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specified on the same page was t 100 m. _______
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IE Rpt. Nos. 50-260/77-06, I-7 50-270/77-06 and 50-287/77-06 IP/3/A/305/1M (October 1976) - Calibration data required on Page 13 not entered.
Section 17.2.16 of the Duke Power Company Topical Report - Quality Assurance Program (TRQAP) states that discrepancies revealed during the performance of station operations, maintenance and testing activities must be resolved prior to verification of the completion of the activity being performed.
Section 4.2.7 of the Administrative Policy Manual provides the administrative requirements and methods for processing completed procedures including completion verifica-tion, approval and resolution of discrepancies.
Specifically, this section requires verification that al'. checklists, blanks and data sheets have been completed and all acceptance criteria have been met.
In all cases listed here and the preceding paragraphs, the com-pleted procedures had a "Ccmpleted Procedure Process Record" attached which contained the signatures of at least two, and in some cases, three reviewers, indicating the requirements of Section 4.2.7 had been satisfied; however, the " Completed Procedure Process Record" for the procedures did not address the discrepancies and
" Procedure Discrepancies Process Records" had not been initiated as
required. This is an Infraction of Criterion V of Appendix B to 10 CFR 50 as implemented by Section 17.2.5 of the TRQAP.
8.
Licensee Internal Audits The inspector reviewed the audit reports, responses, and reaudit reports for Audit Nos. 76-71 and 77-8, both of which covered the area of instrument calibration.
The inspector noted that these audit reports indicated that all of the instrument procedures discussed in Paragraph 7 above, had been included in at least one of the two audits, and two had been included in both audits; however, the audit reports did not contain findings similar to those listed in Paragraph 7.
The audit reports and checklists were not specific as to the extent of the audit with regard to the individual procedures identified in the audit report. The inspector discussed this with licensee QA representatives and determined that the auditors had primarily addressed their attention to determining that the procedures had been accomplished at the required frequency and verifying that the completed procedures were available in the files. The auditor stated that the content of completed procedures was reviewed on a sample basis, but that identification of the procedures 12 viewed was not documented.
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50-270/77-06 and 50-287/77-06 Based on these discussions, it also appears that licensee audits have not included review of the technical adequacy of procedures and their acceptance criteria.
The licensee stated that additional guidance would be provided to auditors regarding detailed review of completed procedures and identification of those reviewed in the audit report.
The licensee further stated that the need to include technical adequacy and acceptance criteria of procedures in the audit program would be reviewed.
This item will be reviewed during future inspections.
9.
Test and Measuring Equipment During the review of completed instrument calibration procedures discussed in Paragraph 7 above, the inspector selected five pieces of test equipment which had been used to perform the calibrations.
Licensee documents were then reviewed to verify that each of the
selected pieces of test equipment had been calibrated at the required frequency, that the calibrations were traceable in dCCordance with Section 17.1.12 of the TRQAP, and that such equipment was teing properly tagged, controlled and stored.
Within the areas inspected, one discrepancy was identified.
In reviewing calibration data for the test equipment, it was noted that "as found" values exceeded the specified calibration tol-When licensee personnel were questioned concerning the erance.
evaluations of these out-of-calibration conditions which are required by Section 17.2.12 of the TRQAP, a copy of an intrastation memorandum addressing this subject was given to the inspector.
The memo defined a new value called an " Evaluation Tolerance" and established limits for various types of test equipment, above which the evaluation of previous use of the item would be accomplished.
The inspector noted that these " evaluation tolerances" were from three to twenty times larger than the associated calibration tolerances. The inspector stated that this did not appear to meet the requirement or the intent of Section 17.2.12 of the TRQAP and that the subject would be reviewed further.
Unresolved Item 77-6/I-2:
Adequacy of program to evaluate test equipment found out-of-calibration is designated an unresolved item pending further review by the NRC.