IR 05000348/1987003

Insp Repts 50-348/87-03 & 50-364/87-03 on 870126-30. Violation Noted:Failure to Follow Procedures in Measuring & Test Equipment Program

ML20205P116
Person / Time
Site:	Farley
Issue date:	03/09/1987
From:	Belisle G, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P053	List: IR 05000348/1987003 ML20205P051 ML20205P074 ML20205P116
References
50-348-87-03, 50-348-87-3, 50-364-87-03, 50-364-87-3, NUDOCS 8704030179
Preceding documents:	ML20214A160 (8 May 1987)
Download: ML20205P116 (9)

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Report Nos.: 50-348/87-03 and 50-364/87-03 L Licensee: Alabama Power Company 3 600 North 18th Street '

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Birmingham, AL' 35291-0400 ',, ,

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: January 26- , 1987 Inspector: Ne M. A. Scott d,

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Date Signed Approveo by: d a . t-N u

Cf 3--9-47 G. A. Belisle, Chief Date Signed Quality Assurance Programs Section' ~

Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was in the areas of licensee actions on previous enforcement matters, corrective action, and actions on previously identified inspection finding Results: One violation was identified - Failure to follow procedures in the measuring and test equipment (M&TE) program, Paragraph ,

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REPORT DETAILS Persons Contacted

Licensee Employees

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J. Brantley, Compliance Engineer

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C. Buck, Plant Modification Department (PMD) Supervisor

• T. Cherry, Instrument and Control (I&C) Supervisor

• M. Coleman, System Performance Supervisor H. Erbskorn, Maintenance Foreman H. Garland, Mechanical Maintenance Supervisor J. Hancock, Mechanical Maintenance Foreman C. Hanks, I&C Calibration Lab Supervisor

• R. Hill, Operations Manager H. Mahan, System Performance Engineer R. Martin, Safety Audit and Engineering Review (SAER) Auditor V. Murphy, SAER Auditor i J. Odom, Unit Supervisor i *J. Osterholtz, SAER Supervisor D. Sherer, Maintenance Planner

• L. Stinson, PMD Manager J. Thomas, System Performance Supervisor W. Van Landingham, Unit Supervisor

• L. Wtrd, Maintenance Manager -

R. Wiggins, Operations Training Supervisor

• J. Woodard, Plant Manager i Other licensee employees contacted included engineers, technicians, mechanics, security force members, and office personnel.

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NRC Resident Inspectors W. Bradford

• B. Bonser

• Attended exit interview Exit Irterview The inspection scope and findings were summarized on January 30, 1987, with those persons indicated in paragraph 1 above. The inspector described the

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areas inspected and discussed in detail the inspection finding Violation, Failure to Follow Procedures in the Measuring and Test

Equipment Program, paragraph The licensee had a dissenting comment on one example of the violation. This comment is addressed in paragraph 5.

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The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (92702) (Closed) Violation (348,364/85-21-01)

Failure To Li st Persons Contacted During Auditing Activ".ie The inspector reviewed correspondence on the subject violation. The licensee denied the violation in his letter of June 19, 198 In subsequent telephone conversations between Region II NRC staff and.the licensee which are indicated in NRC correspondence dated July 23, 1985, to the licensee, the NRC stated that the violation did occur as stated in the original Notice of Violation dated May 21, 198 The inspector examined licensee audit activities as part of a corrective action implementation revie The inspector reviewed tabulations of persons contacted in 'the following composite audit reports:

Report No. 86-25, dated December 30, 1986, (Contained eight audits issued in December)

Report No. 86-24, dated December 13, 1986, (Contained two audits issued in December)

Report No. 86-23, dated December 2, 1986, (Contained four audits issued in November)

The reports listed all site personnel required for the various audit No general staffing groups were indicate: 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 correspondence have been implemente (Closed) Violation (348, 364/86-25-01, b and c): Failure To Perform Evaluation Of Out-of-Tolerance Measuring And Test Equipment (M&TE).

The inspector reviewed the following correspondence on the subject violation. This correspondence also addressed violations indicated in paragraphs c and d:

Initiator Date Comment NRC Region II July 18, 1985 Notice of Violation Licensee August 16, 1985 Denial Letter for three of the four Violations

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NRC Region II October 1, 1985 Clarification /

response to licensee denial

• NRC Region II December 27, 1985 Meeting Summary between NRC and licensee Licensee January 15, 1986 Statement of acceptance of certain violations NRC Region I February 13, 1986 Acknowledgement letter

• This letter also addressed the violation of paragraph ~ The licensee's final response on the subject violation was considered acceptable by Region I The inspector reviewed the site's programmatic controls involving out-of-tolerance M&TE. Procedural controls which included AP-11 and AP-15 appeared to be adequate in their content to close the violatio However, site personnel were not following these procedures which is addressed in paragraph c. (Closed) Violation (348,364/85-25-02): Failure To Establish Environmental Controls For Calibration Of Measuring And Test Equipmen The inspector reviewed the licensee's response to the violatiun as indicated in paragraph The response was considered acceptable by Region I The inspector examined the programmatic controls that establish environmental conditions for the calibration of M&T The procedures appeared to be adequate. However, site personnel were not following the procedures which is addressed in paragraph d. (Closed) Violation (348, 364/85-25-03): Failure To Confirm Adequacy Of Calibration Frequency Of Measuring And Test Equipmen The inspector reviewed the licensee's response to the violation as indicated in paragraph The response was considered acceptable by Region I Site procedures had been revised to indicate a two year review cycle regarding the adequacy of calibration frequency for M&T In discussions with the licensee, M&TE calibration intervals had been reviewed during the initial corrective action (December 1985). The I&C second review had occurred just prior to this inspectio Mechanical maintenance indicated that their second and subsequent review is scheduled via the preventive maintenance progra _ __

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The inspector concluded that the . licensee had determined the full extent of the violation, taken action to correct conditions, and developed corrective actions needed to preclude recurrence of similar problems. Corrective actions stated in the licensee response have been implemente Closed) Violation (348,364/85-32-02): Special ' Test Program Non-compliance With Technical Specificatio The licensee's response dated October 21, 1985, for this violation was considered acceptable by Region I The inspector exanined site r,rocedures and final signature authority on current Special Test and Experiments (STE). Revision 19 of FNP-0-AP-1, Development, Review and Approval of Plant Procedures, indicated that the plant manager authorized STE. Site compliance indicated that three STEs had been performed in 1986. The inspector reviewed two STEs and identified that the plant manager had authorized both STE The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct conditions, and developed corrective actions needed to preclude recurrence of similar problems. Corrective actions stated in the licensee's response have been implemente (Closed) Unresolved Item (343, 364/85-25-06): Perform Evaluation of Installed Process Instrumentation When Found Out-of-Calibration This item was closed since process instrumentation out of-calibration events during the performance of technical specification required that surveillance tests would be identified. Although no regulatory guidance requires process instrument evaluation and current site procedures do not directly require deficient instrument evaluation, many site procedures such as FNP-0-AP-11 and site practices will capture process instrumentation related problems (NRC reference:

Report Number 348,364/85-25-01). (0 pen) Unresolved Item, (343, 364/85-32-01): Design Changes Caused by Plant Activities / Work Items The item was left open pending issue of a new revision to FNP-0-AP-8, Design Modification Control, and review of its implementatio . Unresolved Items Unresolved items were not identified during this inspectio .

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5 Corrective Action (92720)

i In reviewing implementation aspects of the site corrective actions for violations addressed in paragraph 3, the inspector identified examples of site personnel failing to follow procedure The two examples are as follows: FNP-0-AP-11, Control and Calibration of Test Equipment, Test Instrumentation and Plant Instrumentation (Revision 6, issued February 7,1986), prescribed environmental conditions for calibration of M&T Paragraph 4.11.1 of the procedure states, in part, that if environmental conditions are not specified by the vendor, a relative humidity of less than 70 percent and a temperature of 70110* F will be used. The inspector found in excess of ten calibration data sheets for I&C M&TE that had no temperature and humidity recorde Examples

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Identification Type of Date Number M&TE Calibrated FNP-HTG-8024 0-4000 psig 8/13/86 gauge FNP-HTG-8516 0-500 psig 8/8/86

gauge FNP-HTG-8097 0-1500 psig 8/13/86 gauge ,

FNP-HTG-8514 0-500 psig 8/12/86 gauge A note was typically annotated on the sheet indicating that Rad-Side; Humidity / Temperature controls were not in place. In discussions with the licensee, no portable temperature and humidity indicators were taken to the Radiological Control Area (RCA/ Rad-Side) where the subject M&TE were calibrated. It was stated by the licensee that there was air conditioning present in the RCA space, but the unit does not work sometimes and its humidity and temperature parameters are not routinely checked, Paragraph 4.8.1 of FNP-0-AP-11 prescribed evaluations for M&TE found out-of-tolerance. The paragraph states, in part, that such evaluations

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shall be performed promptly to determine if safety-related activities were involved and in all cases should be completed within 30 day The licensee stated that the "should" verb used in the above sentence is interpreted to mean manditory/ imperative which was in agreement

with the statements made in their corrective action documentation (Corrective Action Request 1041). After the calibration lab checks and finds a piece of M&TE out-of-tolerance, the I&C lab personnel filled

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L out a Test- Equipment Deficiency Report (TEDR) and routed it to the user of the out-of-tolerance M&TE for evaluation. Paragraph 4.8.3 of

FNP-0-AP-11 allowed the user and/or foreman ten days from receipt of the TEDR to complete the evaluation. The inspector reviewed completed TEDRs and found in excess of ten TEDRs that had the limits exceede The following is a sample of the deficient M&TE identified on the t TEDRs:

Identification TEDR Evaluation Number Initial Date Review Date

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FNP-WTC-8156

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04/08/86 06/30/86 FNP-HTG-8510 07/02/86 08/08/86 FNP-ATG-8573 07/21/86 08/11/86 FNP-ATG-8467 04/12/86 07/02/86 The deficient TEDRs exceeded the limits from a few days to greater than 60 days. The deficient I&C TEDRs were marked serially as repeat re-issues to the user for evaluatio The earliest deficient TEDR observed was from April 1986, and they continued through to the period i of the inspection. It was found in reviewing the mechanical group

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TEDRs that none of these exceeded similar limits. The licensee stated

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that management was aware of the problem and had a draft FNP-0-AP-11 in routing which was stated to extend the time limit to 40 days total (20 2 days for user evaluation) and would require a tickle copy of the tardy TEDR to I&C Supervisor for additional actio During the exit interview, the licensee stated that they would probably object to this example of the violation based on the existence of the draft procedure. Due to the following, the inspector let the enmple stand:

(1) The length of time that deficient TEDRs had _been occurring (at least nine months)

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(2) The fact that the mechanical group TEDRs were being evaluated within similar time limits

(3) The fact that the draft procedure proposed time limit would not have captured the more tardy of the deficient TEDRs

(4) The fact the deficient condition did not meet the regairements of 10 CFR Part 2, Appendix C.V.A, for licensee identified deficiencies

The above two examples constitute violation 348, 364/87-03-01, Failure

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to Follow Procedure.

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6. Licensee Actions on Previously Identified Inspection Findings (92701) (Closed) Inspector Followup Item (348, 364/85-21-02): Cheater Bar Usage The licensee issued FNP-0-SOP-0, General Instructions to Operations Personnel, Revision 19, which provided instructions on the use of cheater bars (manual torque multipliers) on manual valves. The procedure required that a work request be written on the valves that would require torque which could not be explained or was questionabl The work request would be the vehicle for a valve evaluation. The licensee stated that operations would request System Performance perform the evaluation. Operations had received training on the procedur (Closed) Inspector Followup Item (348, 364/85-21-03): 10 CFR 21 Reporting The inspector reviewed FNP-0-AP-62, Evaluations of Defects and Noncompliances Potentially Reportable Under 10 CFR 21, Revision The revision incorporated all the comments indicated in report number 50-348, 364/85-2 (0 pen) Inspector Followup Item (348, 364/85-25-05): Certification of Individuals Qualified to Calibrate Measuring and Test Equipment This item will remain open pending NRC review of maintenance training at a later dat (Closed) Inspector Followup Item (348, 364/85-30-01): Review Process to Determine Safety Operating Plant Based on System Availability The inspector examined safety-related pump test program changes in light of FSAR (paragraph 13.5.4.2) and regulatory requirement FNP-0-AP-63, Conduct of Operations - System Performance Group, Revision 2, had been changed to upgrade and clarify the progra The Systems Performance Group (SPG) is more involved in trending and evaluating pump performanc The SPG has altered how data is analyzed and has upgraded the data acquisition methodology. The SPG, in conjunction with plant maintenance and operations is developing new techniques in vibration analysis. The inspector reviewed tabulated / computerized data on pump performance and found some minor errors that were corrected by the SPG during the inspectio (Closed) Inspector Followup Item (348, 364/85-30-02): Pump Vibration Testing The inspector reviewed pump vibration testing program changes since the last inspection in this area. Site personnel are changing how vibration analysis is now being performed. As stated by the licensee,

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permanent vibration monitoring points have been attached to pumps which were under analysi Although retraining has not occurred for the 4 unit operators, pump vibration data error has dropped significantly with these fixed data collection point In reviewing the_ data, the inspector identified what appeared to be a data collector error which was spurious but did not void the test results. The noted error was probably caused by the use of hand held probes which could cause trending problems. The licensee stated that new, more sophisticated vibration gear is being integrated into the program which will

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eventually replace the hand held probe (Closed) Inspector Followup Item (348,364/85-32-03): Section Instructions for the Plant Modification and Maintenance Support Group The inspector reviewed section instructions and other documents used by the Plant Modification Department (PMD) to close this item. The guidances varied from a letter on lubricants to typed checklists. The guidance was stated to be controlled within PMD and the loose leaf l

binders containing the guidance were given to each PMD engineer. Three of the eight documents reviewed were dated or had revision number The PMD manager indicated that dating the remainder of the guidance would occur. The primary instructions ET-001 and ET-002 (Design Change Engineering Evaluation Preparation, Revision 0, and Engineering Completion Reviews, dated January 20, 1986, respectively) had been issued since the last inspection this are <,

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