IR 05000327/1987045
ML20237H989 | |
Person / Time | |
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Site: | Sequoyah ![]() |
Issue date: | 07/28/1987 |
From: | Belisle G, Moore R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20237H974 | List: |
References | |
50-327-87-45, 50-328-87-45, NUDOCS 8708170449 | |
Download: ML20237H989 (7) | |
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I kaatCu UNITED STATES (jt
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NUCLEAR REGULATORY COMMISSION.
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' 101 MARIETTA STAEET, N.W., SUITE 2000
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Report Nos.:
50-327/87-45 and 50-328/87-45
Licensee: Tennessee Valley Authority j
6N38 A Lookout Place
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1101 Market Street Chattanooga, TN 37402-2801
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a Docket Nos.:
50-327 and 50-328 License Nos.:' DPR-77'and DPR-79
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Facility Name: ~Sequoyah 1 and 2'
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Inspection Conducte : J ne 29 - July,2, 1987 s
Inspector:
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R.loore Dtite 58ign6d
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Accompanying Personnel; T. Cooper 7/8/87 Approved by:
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G. Belisle, Thief Sate Signed
2 Quality Assurance Programs Section
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Division of' Reactor Safety
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SUMMARY-i Scope:
This routine,' announced-inspection wa's conducted in the areas of i
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measuring and test equipment (M&TE).
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I Results: No violations or deviations were identified. ;
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8708170449 870811 j
PDR-ADOCK 05000327
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l REPORT DETAILS l
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Persons Contacted
Licensee Employees R. Camp, Calibration Services Central Laboratory (CSCL)
- B. Conwell, Senior Instrumentation Mechanic
- M. Crane, Materials Supervisor J. Erikson, CSCL
- J. Green, Materials Officer i
L. Green, Instrumentation Maintenance Section (IMS) M&TE Clerk
- T. Howard, Quality Assurance (QA) Manager
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- G. Kirk, Compliance Licensing Manager J
- C. Lafeuer, Assistant Instrument Engineering Supervisor
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- M. Purcell, licensing Engineer J. Ragsdale, QA Supervisor CSCL
- H. Rankin, Manager of Projects
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- G. Tiner, Plant Operations Review Staff (PORS)
- L. Wheeler, Materials Supervisor l
- W. Wilburn, Assistant to Maintenance Superintendent Other licensee employees contacted included engineers, technicians, mec h nics, and office personnel.
NRC Resident Inspector
- K. Poertner, Resident Inspector
- Attended exit interview i
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Exit Interview The inspection scope and findings were summarized on July 2,1987, with those perscns indicated in paragraph 1 above.
The inspector described the areas inspected and dircussed in detail the inspection findings.
No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
At the exit inter dew, an apparent violation involving failure to pe" form
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process instrumet.,ation out-of-calibration evaluations was discusnd.
Additional information was provided by cognizant TVA personnel durt 19. a l
telephone conversation with Region II personnel on July 9,1987.
Based on this additional information, the apparent violation was withdrawn.
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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
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Unresolved Items (
Unresolved items were not identified during this inspection.
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Measuring and Test Equipment (35750)
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 N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (d) Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection and Testing of
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Instrumentation and Electric Equipment
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(e) ANSI N45.2.4-1972, IEEE Standard, Installation, j
Inspection and Testing Requirements for l
Instrumentation and Electric Equipment During the
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Construction of Nuclear Power Generating Stations
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(f) ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants The inspector reviewed the licensee measuring and test equipment program required by references (a) through (f) 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:
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Criteria and responsibility for the assignment of calibration
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frequency have been established.
An equipment inventory list had been prepared which identified all
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test and measvement equipment whhh will be used on safety-related components, the calibration standard and frequency for each piece of equipment, and the calibration procedure used.
An inventory list had been prepared identifying all plant process
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instrumentation which provided a compliance of Technical Specificati^n function and controls requiring evaluation of out of tolerance conditions of this equipmen _ _
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l A written requirement had been established which prohibits the use of
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test and measuring equipment which has not been inspected and calibrated within the prescribed frequency and describes controls to prevent inadvertent use of such equipment.
Controls have been established requiring that when a piece of
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equipment is found to be out-of-calibration, the cause of j
out-of-calibration and the acceptability of items previously tested
will be evaluated.
M&TE generated QA records are properly stored and maintained.
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Documentation exists to trace M&TE from application to National Bureau
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of Standards reference standard.
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The documents listed below were reviewed to verify that these criteria-had been incorporated into the M&TE program:
NQAM, Part 1, Section 3.1, Calibration Services, Revision 0 NQAM, Part III, Section 3.1, Control of Measuring and Test Equipment,
l Revision 1 ID-QAP-12.2, Procurement, Calibration and Management of Measuring and
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Test Equipment Revision 0
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AI-21, Control of Measuring and Test Equipment, Revision 7
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SQE-8, Control of Installed Permanent Process Instrumentation, Revision 3 TI-54, Compliance Instruments, Unit 0,1, Revision 11 TI-54.2, Compliance Instruments, Unit 2, Revision 6 The inspector toured the mechanical maintenance toolroom, IMS, tool issue, and an area for storage of contaminated instruroents.
The inspector observed that access to the maintenance toolroom was limites to designated personnel for the purpose of equipment issue, or supervisory personnel.
Equipment was checked out only to personnel specified on an accepted list.
The mechanical maintenance toolrooms were provided coverage on all shifts with no open door policy at any time.
The accountability program for this group was computer based, with location, last calibration date, next calibration date, and next calibration due date maintained in the data base.
Computer terminals are located in the toolrooms and the database was routinely updated.
In addition, a manual log for each piece of M&TE was maintained to allow traceability of usage.
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l Calibration and usage logs for 35 pieces of M&TE were examined to
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In addition, l
out-of-tolerance reports and investigation of M&TE nonconformance reports were reviewed to verify that appropriate safety aspects were addressed.
The inspector did not identify any weaknesses in this review and it appeared that utilization of a dedicated staff for the distribution of M&TE provided the mechanical maintenance section positive M&TE control.
The inspector observed that the IMS method of equipment issue appeared less formally controlled than the Mechanical Maintenance Section.
IMS required all shop personnel to adhere to the check out procedure.
Any instrument maintenance section personnel can enter the tool issue room and self issue a tool by filling out a checkout tag.
A portion of this tag accompanied the equipment and the remaining portion was filed in the equipment issue room.
Upon return of the instrument to the issue room, the clerk reviews the work document utilized by the technician and records the M&TE usage on an activity usage sheet.
This system's acceptability is dependent on shop personnel adherence to procedures, i.e., utilizing tag system for equipment checkout.
However, during discussions with the tool issue personnel, the inspector observed shop personnel removing a piece of equipment without utilizing the tag system.
The safety significance of the equipment (stopwatch) and its usage may have been minimal or nonexistent, however, the reliability of this accountability system appears questionable.
The inspector reviewed a sample of evaluations for out-of-tolerance and retired or lost M&TE.
These evaluations appeared
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adequate and completed within accepted programmatic time periods.
Inspection of the Hot Instrument Shop identified this area was poorly controlled.
This shop was a room containing equipment used by the Engineering Test Section, Electric Shop, and IMS for storage of contaminated tools and equipment.
Equipment in the area was in and out of calibration and inconsistently marked.
Control of the area was minimal, i.e., no access control, calibrated equipment not separated or labeled to i
l indicate status from out-of-calibrated equipment.
Essentially, the hot l
instrument room acts as a holding area for contaminated equipment and the I
potential exists for any personnel to access and remove equipment.
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potential for uncontrolled M&TE use would escalate during an increased maintenance period such as an outage.
It was additionally noted by the inspector that the IMS equipment inventory did not reflect the actual
location of some of the equipment in this area.
This condition represents a poor practice and more definitive controls and responsibilities need to be established for the use of the Hot Instrument Shop. This apparent lack of management control and involvement will be pursued during future inspections.
The inspector reviewed the Process Instrumentation (PI) calibration control program which was an IMS responsibility.
Calibrations for Technical Specification; Compliance; and Critical Structures, Systems and Components (CSSC) instrumentation were performed at 18 month intervals.
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These calibrations were performed via a Surveillance Instruction (SI) or
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other work document.
Calibration cards are maintained for each.
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These cards listed the calibration setpoints and provide space for. recording 6 instrument calibrations.
The calibration was performed and recorded on the work document datasheet, then recorded on.
calibration cards.
Data sheets are maintained as. QA records.
Fifty calibration cards were-reviewed for completeness and -accuracy.
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Approximately 20 percent.of' the PI exceeded the nominal 1 calibration
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frequency but were within the interval plus. 25 percent.
The'IMS supervisor contacted stated that extensions were granted within IMS up to-the 25 percent limit and when necessary, as determined by engineering to be not required by the operating mode,~beyond the 25 percent grace period.
The supervisor indicated these evaluations were - not specifically documented.
As the plant was shutdown and these items were identified as requiring resolution prior to entering power operational modes, this did not appear to be a problem.
The PI calibration program, per SQE-8, TI-54 and TI-54.2, required that out-of-tolerance PI conditions be evaluated and if specific compliance instrumentation listed in TI-54 and 54.2' identified to exceed the given acceptance criteria, that a Probable Reportable Occurrence (PRO) be initiated to evaluated the safety significance of the. condition.
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inspector selected a sample of 10 out-of-tolerance PI calibration cards to verify performance of these evaluations for identified out-of-tolerance-
conditions.
Ths following lists these instruments and calibration dates:
2FT63173C February 15, 1985 ILT77411 September 21, 1985 2TM63132 October 17, 1985
2LT63129 October 3, 1985 l
2LT3164 January 5,1987 i
ITM6843P July 29, 1985 ITM7438C September 5, 1985 2FI62278 January 6,1986 2 TIC 6785 July 26, 1986 Two of the above instruments were outside the specified tolerance and appeared to require evaluation of the condition and initiation of a PRO.
The remaining eight did not have specified acceptance criteria or were not listed as compliance instruments.
It was not evident to the inspector that this evaluation had occurred.
The remaining two instruments, ILT77411, Safety Injection Instrumentation, and 2TM63132, Reactor Coolant Leakage Detection Instrumentation appeared to require further evaluation.
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l These instruments were beyond the-specified criteria in the applicable Technical Instruction listing and per procedure required initiation of a PRO.
Documentation of these evaluations or initiation of a PR0 were not available for review.
The data page coversheet' for the calibration contained a check-off indicating that all surveillance instruction data met acceptance criteria.
This check-off did not indicate the scope of the
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review, its application to the out-of-tolerance data, nor indication of which data was represented, i.e., as found or as left.
The licensee stated in a teleconference on July 9,1987, with the Regional inspector that the revisions of the applicable procedures current at the date of calibration performance did not include the two instruments discussed above as requiring further evaluation, i.e., PRO initiation.
Of the ten items selected, none could be shown to have an impact on safety-related equipment ;r tests.
Therefore, a violation involving failure to perform process instrumentation out-of-calibration evaluations is not being considered.
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