IR 05000413/1986046
| ML20215E476 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/03/1986 |
| From: | Belisle G, Runyan M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215E450 | List: |
| References | |
| 50-413-86-46, 50-414-86-49, NUDOCS 8612220330 | |
| Download: ML20215E476 (13) | |
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. UNITE 3 STATES
[Sn neep Do NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARICTTA STREET,N.W.
- t ATLANTt GEORGIA 30323
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Report Nos.:
50-413/86-46 and 50-414/86-49 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.:
50-413 and 50-414 License Nos.:
NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conducted: November 3-7, 1986 3!86 Inspector: hI.d.
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M. F. Runyan
Date Signed I*N T d.
Mb Ik3[84 Approved by:
G. A. Belisle, Sect 40n Chief Date Signed Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of tests and experiments, quality assurance (QA) for the startup test program, and measuring and test equipment (M&TE).
Results: One violation was identified - Failure to report 10 CFR 50.59 Informa-tion.
8612220330 861215 PDR ADOCK 05000413 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Aycock, Projects Engineering
- W. Bradly, QA Supervisor M. Brady, Operations H. Britton, Tool Control Technician B. Brown, Tool Control Technician
- T. Crawford, Superintendent of Integrated Scheduling
- M. Criminger, QA Surveillance Specialist B. East, Instrumentation and Electrical (IAE) Specialist C. Gregory, IAE Support Engineer
- C. Hartzell, Compliance Engineer R. Johnson, IAE Specialist
- J. Knuti, Operations Engineer
- P. LeRoy, Licensing Engineer G. Lyon, IAE Specialist
- F. Mack, Projects Engineer J. McCoy, Surveillance Associate G. Robinson, Technical Suppo-t Supervisor
- G. Rogers, Projects Engineer F. Shiffley, Licensing Engineer
- J. Stackly, IAE Supervisor
- D. Tower, Shift Operating Engineer J. Williams, Maintenance Supervisor J. Willis, Senior QA Engineer Z. Taylor, Associate Engineer, Performance Other licensee employees contacted included technicians and office personnel.
NRC Resident Inspectors
K. Van Doorn
"P. Skinner
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- M. Lesser
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- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on November 7,1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
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i Violation:
Failure to Report 10 CFR 50.59 Information, para-graph 5.
Inspector Followup Item:
QA Involvement in Plant Activities, paragraph 6 Inspector Followup Item:
Documented Usage of M&TE, paragraph 7 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
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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 the inspection.
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Tests and Experiments (37703, 35749)
References:
(a)
10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
10 CFR 50.59, Changes, Tests, and Experiments (c) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Section 17.2.11, Amendment 9 (d) Technical Specifications, Section 6.5, Review and Audit (e) Regulatory Guide 1.33, Quality Assurance Requirements (Operations)
(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (g)
10 CFR 50.54(a)(1) Conditions of Licenses
The inspector reviewed the licensee's test and experiment program required by references (a) through (g) to determine if the program was in conformance
with regulatory requirements, commitments in the application, and industry guides and standards. The following criteria were used during this review to assess the overall acceptability of the established program:
A formal method has been established to handle all requests or
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proposals for conducting plant tests involving safety-related compon-ents.
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Provisions have been made to assure that all tests will be performed in
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accordance with approved written procedures.
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Responsibilities have been assigned for reviewing and approving test
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A formal system, including assignment of responsibility, has been
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i established to assure that all proposed tests will be reviewed to determine whether they are as described in the FSAR.
Responsibilities have been assigned to assure that a written safety
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l evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specifications.
The documents listed below were reviewed to determine if the previously l
listed criteria had been incorporated into the licensee's tests and experi-ments program.
Administrative Policy Manual (APM) Revision 23 Section 3.2.3, Special Testing
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Section 4.3, Administrative Instructions for Temporary Station Procedures Final Safety Analysis Report (FSAR), Chapter 14.0 Initial Test Program Section 14.2.12.2, Initial Startup Testing
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SD 4.2.2, Independent Verification Requirements, Revision 1 The licensee's test and experiment program is described in APM Section 3.2.3 and consists of temporary instrument procedures and temporary test proce-dures.
Temporary procedures are controlled administratively by APM l
Section 4.3.
These two procedures provide a formal method for conducting plant tests and ensure the development of safety evaluations and proper reviews.
However, the APM is not considered to be a procedure by the licensee, i.e., not required to be reviewed regularly.
It is considered a policy statement upon which the plant formulates station directives.
To date, a station directive has not been written to incorporate the policy statements of APM 3.2.3 and APM 4.3.
A violation is not being issued for failure to have a procedure for conducting tests and,xperiments since this issue is being followed by the resident inspectors and is discussed in NRC Inspection Report Nos. 50-413/86-47 and 50-414/86-50.
The content of each completed temporary test procedure package is required to include the following elements:
purpose, references, estimated time required, prerequisite tests, test equipment, limits and precautions, required station status, prerequisite system conditions, test method, L
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acceptance criteria, procedure, data sheets, and independent verification documentation. The inspector randomly selected the following test packages to verify APM administrative control compliance and to assess the adequacy of the 10 CFR 50.59 safety evaluations:
Temporary Test Test Procedure No.
Test Title Dates Performed TT/1/A/1200/15A Mechanical Penetration 01/25/85 Bellows Integrity Temporary Test TT/1/A/9100/15 DG Voltage Regulator Test 08/15/85 TT/0/A/9100/11 Nuclear Service Water Pump 11/T7/85 to Annubar Calibration 12/06/85 TT/1/A/9100/20 Sequencer Actuation of VZ Fans 01/27/86 TT/1/A/9100/16 VA Rebalance Flow Monitoring 02/05/86 to 03/27/86 TT/1/A/9100/32 Reactor Makeup Water Storage 07/10/86 Tank Recirculation Time Test TT/1/A/9100/35 Refueling Water Storage Tank 07/10/86 Recirculation Time Test Each test procedure adequately addressed the required administrative elements.
The 10 CFR 50.59 safety evaluations were only marginally adequate.
Safety evaluations for tests conducted in 1985 consisted of checklists without documentation of the bases for determining that an unreviewed safety question did not exist.
The procedural guidelines were upgraded in 1986 to require a written explanation for each line item.
However, the inspector found that several of the newer safety evaluations still lacked a complete and conclusive justification for the evaluation determination, fhis issue was discussed with the resident inspectors and a clear improvement trend is in progress; consequently a finding is not warranted in this inspection.
However, safety reviews will be reviewed during subsequent inspections.
The licensee is required, by $D 4.2.2, to independently verify the removal from and restoration to operability of all systems or components which af fect the ability of a system to perform a safety related function required for the immediate mitigation of accidents.
The procedure defines the verifiability requirements to apply to all removal and restoration actions of the applicable systems. The inspector questioned the licensee's practice of verifying as-found and as-lef t conditions but not the intermediate test lineup, and expressed a concern that since the test lineup was not verified,
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an improper lineup could result in an unreviewed lineup configuration. This question was adequately resolved when the licensee explained that this activity is procedurally controlled to require the independent verifier to be on-the-scene at the time of the as-found determination, and that the manipulation to the test configuration follows immediately, thus practically eliminating the chance for the wrong component to be adjusted.
Within this area, one violation was identified. 10 CFR 50.59 requires the licensee to submit at least annually a report containing a brief description of tests not described in the Safety Analysis Report (SAR) and a summary of the safety evaluation of each. The July 1, 1986, 10 CFR 50.59 annual report submittal to Region II, covering calendar year 1985, did not list any tests performed. The inspector discovered that a minimum of eight special tests were conducted in 1985 and they are listed below:
i Temporary Test j
Procedure Title Date Performed i
i TT/1/A/1200/15A Mechanical Penetration Bellows 01/25/85 Integrity Temporary Test
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i TT/1/B/9100/10 Condenser Sulfur Hexafluoride 04/17/85 i
Test Injection *
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TT/1/A/1250/04A Auxiliary Feedwater Automatic 05/1,4/85
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Start Temperature Test
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TT/0/A/9100/07 Leak Test of 1RF 356 05/03/85 j
and 2RF 356 TT/1/A/9100/05 Operability of Diesel Engine 05/03/85
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Stop-Run Valve l
TT/1/A/9100/09 Component Cooling ESF 05/31/85 l
Flow Balance i
TT/1/A/6100/03 Decreasing NC Pressure for NCP 09/30/85 Seal Leakoff Reduction *
TT/1/A/9100/16 VA Rebalance Flow Monitoring 12/05/85 i
This list is not intended to be all inclusive.
The safety evaluation for the two asterisked tests stated that the test was not contained in the SAR, I
which would make it reportable under 10 CFR 50.59. The evaluations for the
other six tests stated that the tests were contained in the SAR, even though
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this was apparently not the case.
The licensee's interpretation of the i
reportability of tests and experiments is that unless operations outside the
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normal bounds described in the SAR occurs, the test is not reportable.
However, 10 CFR 50.59 clearly states that any test or experiment not described in the SAR is reportable.
Even from the licensee's perspective
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the two asterisked tests above were reportable and not submitted. Failure to submit information required by 10 CFR 50.59 is identified as violation 413/86-46-01, Failure to Report 10 CFR 50.59 Information, and applies to Unit 1 only.
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6.
QA for Start-up Test Program (35501)
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References:
(a)
10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
,t (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9, Section 17.2, Quality Assurance for Station Operation (c) Regulatory Guide 1.33 Quality Assurance Program Require-ments (Operation)
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i (d) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (e) Regulatory Guide 1.68 Initial Test Program for Water Cooled Nuclear Power Plant
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The inspector reviewed the licensee quality assurance program for start-up testing required by references (a) through (e) to determine if activities are in conformance with regulatory requirements, commitments in the applica-
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tion, and industry guides and standards.
The following criteria were used
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during this review:
Requirements have been established and procedures or checklists
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developed for inspection of the following activities on a regular basis
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by the onsite Quality Assurance organization:
Conduct of testing; Tracking of test deficiencies; Test documentation; and Control of measuring and test equipment.
The documents listed below were reviewed to determine if the previously itsted criteria had been incorporated into the licensee QA program for star'.up testing.
Catawba FSAR, Section 14.0, Initial Test and Operation QA-130 Qualifications and Training of Auditors, Revision 14 QA-131 QA Training, Revision 9 QA-150 Trend Analysis, Revision 6 QA-160 Performance of Corporate QA Audits Revision 2 QA-500 Operations Division Surveillance Program, Revision 18 QA-502 Evaluating and Approving QC Inspection Records, Revision 5
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QA-509 Preparation and Issue of Quality Control Procedures, Revision 11 The startup test phase follows the preoperatioral test phase and precedes r
commercial operations.
It consists of initial fuel load, precritical
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checks, initial criticality, low power testing, and power ascension testing.
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I The inspector interviewed site QA personnel and reviewed inspection
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d documents to determine the extent and finaings of QA inspections in the Unit 2 startup test program.
Apparently, corporate audits were not performed in this area; however, site QA performed one surveillance and observed startup activities as part of regularly scheduled tour surveill-ances.
l The inspector reviewed surveillance report CN-86-21, Initial Unit 2 Startup, lr conducted April 1, 1986, to June 20, 1986, and issued June 23, 1986. This
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surveillance involved eighteen checklist items covering precritical checks ei.
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and initial criticality. Deficiencies identified and corrected included an f
improper pressure limit in a procedure, improper procedural references, and
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uncontrolled procedures in use.
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Tour surveillances are conducted by site QA inspectors each shift except s
weekends.
The inspector reviewed a sample of tour surveillance reports during the period of Unit 2 startup. Tour inspections of startup activities
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were mostly observational and impromptu, and did not involve systemmatic
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(i.e, checklist) inspection practices.
Nevertheless, tour surveillance findings were substantial and commendable.
From FSAR Table 14.2.12-2, Initial Startup Testing, the inspector reviewed
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',r the following three startup test packages:
TP/2/A/2650/05 Unit Load Transient Test 7/14 to 8/20/86 TP/2/A/4150/09 RTD Bypass Flow Verification 4,5/86 TP/2/A/2650/01 Initial Fuel Load 2/24 - 3/2/86
The test packages appeared complete and properly reviewed.
Based on
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interviews with QA management, QA did not review any startup test packages.
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Within this area, one inspector followup item was identified. The overall depth of QA involvement in the Unit 2 startup test program was shallow. One site surveillance covering precritical checks and initial criticality (not initial f uel load, low power testing, or power ascension testing) and no s
l corporate audits were conducted. As an item for followup, a future inspec-t'on will review this issue from a more generic perspective to determine if other safety-significant areas are being deleted or lightly treated by the licensee's QA staff. Until this review is completed, this is identified as inspector Followap Item 414/86-49-02, QA Involvement in Plant Activitie _ _ _ _ _ _ - _ _ _ _ _
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Measuring And Test Equipment Program (61724, 35745)
References:
(a) 10 CFR 50.54(a)(1), Conditions of Licenses (
t (b) Duke Power Company Topical Report Quality Assurance
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Program, DUKE-1-A, Amendment 9 (c)
l'O CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide 1.33, Quality Assurance Program (
Requirements (Operations)
(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of f
Instrumentation and Electric Equipment L
(g) ANSI N45.2.4-1972, IEEE Standard, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of
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Nuclear Power Generating Stations The inspector reviewed the licensee M&TE program required by references (a)
through (g) to determine if the program had been established in accordance with regulatory requirements 'and industry guides and standards.
The following criteria were useo during this review to determine the overall acceptability of the established program:
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Responsibility was delegated and criteria established to assign and adjust calibration frequency for each type of M&TE.
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An equipment inventory list identified all M&TE used on safety-related components, the calibration frequency and standards, and the calibra-tion procedure.
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Formal requirements existed for marking the latest calibration date on each piece of equipment.
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The program assured that each piece of equipment was calibrated on or before the date required or stored in a location separate from inservice M&TE.
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Written requirements prohibit the use of M&TE which was not calibrated within the prescribed frequency.
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,1 When M&TE was'found out of calibration, the program required documer.ted
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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 assured that new M&TE was added to the inventory list and
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calibrated prior to use.
The documents listed below were reviewed to determine if these criteria had been incorporated into the M&TE program:
APM, Section 2.3, Control of Measuring and Test Equipment, Revision 23 Quality Control Procedures Manual, Section QC B-1, Control of Measuring Equipment and Calibration and Test Standards, Revision 22 SD 2.3.1, Control of Measuring and Test Equipment, Revision 9 The inspector reviewed the following corporate QA audits, each of which addressed measuring and test equipment used by the specified group:
NP-86-3(N)(1)
Performance Group 2/17/86 NP-86-4(CN)
Chemistry Group 3/21/86 NP-86-6(N)
Maintenance and On-Site 4/10/86 Transmission
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NP-86-8(N)
Health Physics and 5/16/86 Environmental Group i
These audits did not identify deficiencies in the area of measuring and test l
equipment.
The inspector reviewed the following site QA surveillances:
CN-86-14, Measuring and Test Equipment, IAE, 4/11/86
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l CN-86-23, Measuring and Test Equipment, Mechanical Maintenance, 5/29/86 CN-86-28, Measuring and Test Equipment, Performance 7/1/86 3everal significant deficiencies were identified by these surveillances.
One concerned a recurring problem in the mechanical maintenance area where work requests referenced the M&TE used, but the M&TE issue cards did not list the work request. This problem, which would become significant in case the M&TE is found out of tolerance, is discussed as an inspector followup item at the end of this paragraph. Other problems included the assignment of incorrect calibration intervals and not meeting time requirements for completing out-of-tolerance reports.
Each of these items had been satis-factorily closed or corrective action was in progress to obtain resolution.
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The inspector selected the following types of M&TE in the IAE lab to determine whether they were being calibrated at the frequency prescribed in SD 2.3.1, Attachment #1:
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Calibration Frequency Decade Resistance Boxes 1 year
Hydrometer 1 year
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Digigauge 6 months Dead Weights 1 year Digital Multimeter 3 months Vibration Analyzer 1 year Heise Gauge 3 months Ashcroft Test Gauge 3 months The above instruments were being calibrated at the correct frequency.
The licensee is required to evaluate the effect of out-of-tolerance M&TE on the acceptability of previous test results when the instrument was used on safety-related equipment since the last calibration. The inspector reviewed out-of-tolerance reports for both IAE (CNIAC) and Mechanical Maintenance (CNMNT) M&TE.
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Identification Date Found Evaluation Number Description Out of Tolerance Complete i
CNIAC 18673 Process Calibrator 10-22-86 10-30-86 CNIAC 18582 ise Gauge 07-29-86 08-08-86 CNIAC 18251 Hydrometer 06-19-86 06-27-86 CNIAC 18265 Process Calibrator 10-16-86 10-23-86 CNIAC 18283 Decade Resistor Box 10-03-86 10-09-86 CNIAC 18319 Heise Test Gauge 10-06-86 10-08-86 CNIAC 19015 T/C Test Set 10-06-86 10-20-86 CNIAC 18421 Scalar Rate Meter 01-08-86 03-20-86 l
CNIAC 18397 Digital Pressure Indicator 08-11-86 Still Out r
CNIAC 18398 Compound Test Gauge 08-11-86 08-20-86 l
CNMNT 18201 Micrometer 01-06-86 02-03-86 CNMNT 18348 Micrometer 08-01-86 09-04-86 CNMNT 18388 Micrometer 04-14-86 06-06-86 CNMNT 18016 Torque Wrench 03-11-86 03-20-86 i
CNMNT 18212 Micrometer 08-06-86 08-18-86 The inspector reviewed the above reports for promptness and adequacy. SD 2.3.1, Section 3.7.0 requires that when M&TE used on safety-related systems is found out-of-tolerance, the users must be notified within four working days. They then have seven working days to evaluate the out-of-tolerance report and respond. Thus safety-related out-of-tolerance notices should be
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completed within eleven working days or usually about fifteen calendar days.
Several examples existed where this time period was exceeded. A finding was not issued based on extenuating circumstances for some items and the fact that this issue is being followed closely by site QA. An example of an extenuating circumstance is where an item of M&TE must be sent to an outside
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calibration facility after it is dropped or broken to determine as-found conditions. The above out of-tolerance reports appeared to be complete in terms of the analysis performed to identify safety concerns.
The inspector chose one out-of-tolerance report to perform a detailed review of the evaluation process.
Instrument CNIAC 18419, a Keithley Picoampere Source Model 261, was found out of tolerance on December 10, 1985.
On January 7,1986, the determination was made that the out-of-tolerance range was not used and a retest was not required. The instrument was out-of-tolerance on the 10 11 and 10 12 ampere ranges. Only one safety-related test, Nuclear Instrumentation System - Intermediate Range (3632 SWR), was performed since the last calibration.
The inspector reviewed the data sheets from this test and found that the picoampere source was used in the range of 1.5 x 10 11 to 2.5 x 10 11 amperes, in apparent contradiction to the evaluation conclusion.
However, after interviewing the person who performed the evaluation, it was determined that since the only adjustments that were made were in the 10 " and 10 7 ampere ranges, the out-of-toler-ance condition had no effect on the acceptability of the test results.
In the mechanical maintenance M&TE shop, the inspector selected the following M&TE to determine the status of tool accountability:
CNMNT 18007 Torque Wrench CNMNT 18153 Hydraulic Torque Wrench CNMNT 18178 Hydraulic Torque Wrench
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CNMNT 18204 Micrometer CNMNT 18392 Depth Micrometer CNMNT 18651 Dial Indicator CNMNT 18752 Digital Electronic Caliper l
CNMNT 18774 Dial Caliper l
CNMNT 18946 Heise Gauge The above equipment was either physically located in the shop or documented on equipment history cards as to its exact location. Equipment storage was commendable.
The calibration of certain items of M&TE takes place in the i
mechanical maintenance M&TE shop.
The inspector reviewed the following l
calibration orocedures:
i MP/0/B/7650/38 Calibration of Norbar Electronic l
Torque Tester, Change 2 MP/0/8/7650/10 Calibration of 0-60" Outside Micrometer, Change 0
These calibration procedures adequately delineate pre-calibration condi-l tions, step-by-step instructions, and acceptance criteria.
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Within this area, one inspector followup item was identified. The inspector reviewed a sample of recently completed safety-related surveillance test work packages and made note of the M&TE used for each test.
Then, the equipment history cards for these items of M&TE were reviewed to determine whether this usage had been properly documented.
This documentation is needea to identi fy safety-related usages of M&TE subsequently found out-of-tolerance. Out of a sample of 32 surveillance tests, the following five M&TE history cards apparently did not have proper documentation:
M&TE History Cards Work Request Missing Date CNIAC 18071 4150 SWR 08-03-86 CNIAC 18509 3814 SWR 10-30-86 CNMNT 18003 5495 SWR 10-10-86 CNMNT 18004 4585 SWR 07-24-86 CNMNT 18019 4586 SWR 08-01-86
A violation was not issued based on a similar finding identified in site surveillance report CN-86-23 dated May 29, 1986. A massive reinspection in this area was in progress during this inspection. The problem is apparently due, in part, to M&TE being checked out and documented for a certain job and then used for another job before being returned to the issue shop. As a result, the second usage is not documented. Until site QA determines the
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extent of the problem and proper resolution is achieved, this will be identified as Inspector Followup Item 413/86-46-03, 414/86-49-03, Documented Usage of M&TE.
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