IR 05000424/1986038

Insp Rept 50-424/86-38 on 860512-16 & 0602-06.No Violation or Deviation Noted.Major Areas Inspected:Readiness Review App G, Measuring & Testing Equipment

ML20207J921
Person / Time
Site:	Vogtle
Issue date:	07/15/1986
From:	Belisle G, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207J914	List: IR 05000424/1986038 ML20207J911
References
50-424-86-38, NUDOCS 8607290294
Download: ML20207J921 (10)

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praru UNITED STATES

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NUCLEAR REGULATORY COMMisslON

[ REGION li g j 101 MARIETTA STREET, * 2 ATLANTA, GEORGI A 30323

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Report No.: 50-424/86-38 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1 Inspection Conducted: May 12-16 and June 2-6, 1986 Inspector:

L. R. M60re O 67/7L 7!/f-!9 ~

'Date Signed

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Approved by: e f 7!/f G. A. BelislerActing Section Chief '/Date Signed Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of Readiness Review Appendix G, " Measuring and Test Equipment."

Results: No violations or deviations were identified.

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REPORT DETAILS Persons Contacted Licensee Employees C. Gardner, Technical Support Group Supervisor

• E. Groover, Quality Assurance (QA) Site Manager - Construction

• C. Hayes, Vogtle Quality Assurance Manager (VQAM)

H. Kattygut, Measuring and Test Equipment (M&TE) Supervisor - Construction P. Kyner, Lead Auditor - Bechtel Power Services (BPS)

• G. McCarley, Project Compliance Coordinator

• R. McManus, Assistant Project Construction Manager (APCM) II - Georgia PowerCompany(GPC)

T. Mitchell, Corporate QA Auditor

• • D. Sanderfer, Readiness Review Team Member H. Swain, Mechanical Control Section Quality Supervisor

• P. Thomas, Readiness Review Team Leader Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspector

• H. Livermore

• Exit interview on May 16, 1986

• • Exit interview on June 6, 1986 Exit Interview The inspection scope and findings were discussed on May 16, 1986, and also discussed on June 6,1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding 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. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection. Unresolved Items Unresolved items were not identified during the inspectio _ - _ _ _ . _. _ _ _ .

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5. Scope of Review This inspection consisted of an examination of each section of Appendix Sections 1.0, 2.0, 4.0, 6.0, and 8.0 presented data on the scope, responsi-ble organizations, program description, changes and conclusions regarding assessment of the appendix and required less detailed review than the remaining sections. The more significant aspects of the appendix were in Sections 3.0, 5.0, and 7.0 regarding licensee commitments and implementa-tion, audits and evaluations conducted, and appendix verification. The inspector examined a limited sample of records reviewed by the Readiness Review Staff (RRS) and an independent sample to examine various findings and corrective action The initia? technical review of Appendix G was conducted in the Region II Office during the week of May 5,1986, followed by onsite inspection activity during the weeks of May 12-16 and June 2-6, 1986. Additionally, the inspector reviewed audits at the GPC Corporate Office in Atlanta on May 28, 198 Onsite inspection included the program review by examination of procedures and program description. The inspector reviewed procedures and commitment implementation by Georgia Power Company (GPC), Pullman Power Products (PPP), ,

and Nuclear Installation Services Company (NISCO). Records sampled during this review were limited to GPC records. Audits relating to measuring and test equipment (M&TE) of each of the programs were reviewed and findings examine The detail and depth of the audit working checklists were reviewed for GPC and the two contractor programs.

6. Evaluation Section G 1 - Scope This section discussed the boundaries to which M&TE was evaluated by the RRS. This appendix provided a description and evaluation of the programs governing the control of M&TE utilized during the construction activities of the Vogtle Electric Generating Plant (VEGP). The M&TE programs for GPC, PPP, and NISCO were described and evaluate Other onsite contractors utilized GPC's calibrated equipment for determining inspection acceptance of construction activitie The Nuclear Operations M&TE program is addressed in Module The time period involved in this evaluation was from early 1977 to December 31, 198 This section was reviewed for background information only. No followup or evaluation of this section was require Section G.2 - Responsible Organizations This section described the various construction organizations responsible for M&TE activities within the scope of this appendix. GPC had overall quality responsibility for work performed at VEGP including the M&TE program. PPP products and NISCO each maintained M&TE programs

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which were reviewed by the GPC QA organization. This section also identified contractors which utilized the GPC calibrated equipmen This section was reviewed for background informatio No followup or evaluation of this section was required.

- Section G.3 - Commitments and Implementation This section contains the licensing and project commitments and the corresponding documents which implement these commitments. It was noted by the inspector that the commitment relating to records and documentation was inconsistently addressed in the implementing documentatio This commitment was also addressed in Appendix D QA Records and Document Control. This deficiency will be discussed in the evaluation section of this repor The RRS reviewed the historical file of project procedures (sunmarized in the Implementation Matrix) to determine whether applicable commitments were contained within the program Although all commitments appeared to be addressed, the inspector noted implementation references which did not adequately address an associated commitment. This issue will be discussed in the evaluation section of this repor Review of this section by the RRS and NRC inspectors identified that Vogtle's licensing commitments and implementing documents comply with the FSAR Regulatory Guides and industry codes and standard Section G.4 - Program Description This section of the appendix provided a description of three M&TE programs used on site, GPC, PPP, and NISC It also provided a

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description of the procurement method for calibration services and equipment from approved vendors. The present procurement method for M&TE appears adequate even though these services had previously been procured from unapproved vendor Discussion of this finding (RRF 21-15G) and resolution involving evaluation and program changes are detailed in the verification section of this repor The M&TE control program includes the following activities:

Procurement of calibration equipment and services Equipment control and tracking Calibration and recalibration Out of calibration reporting and resolution Storage of documentation The inspector noted that activities involving record storage were referred to the QA record storage procedure for the present program and they were not addressed in the Revision 0 procedures. Activities not

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adequately addressed in initial procedure revisions were generally identified as audit findings and incorporated into later revision Implementation of these programs requires further review by the inspecto One noted deviation from the program descriptions was that i

, all calibrations on site, including those for PPP and NISCO, will be

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performed by GPC, who will also be responsible for all site reference standard This program change was to be incorporated at the end of May, 198 The onsite M&TE programs in effect at the date of this inspection (May 12-18) appear adequate and conform to the description

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of Section ! Section G.5 - Audits This section contained a review of the various audits and evaluations 4 conducted by GPC and NRC Inspection and Enforcement personnel and a self-initiated evaluation (SIE) performed by off-project personnel from GPC, Southern Company Services, and Bechtel Power Corporatio Thirty-eight findings were noted. Six findings resulted in changes to procedures and one significant finding identified untimely recording of

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nonconformance reports (NCR) at PPP associated with out-of-calibration M&TE. The inspector did not identify significant findings contained in the audits which were not previously addressed in thr appendix, j therefore, this section represented accurate presentation of the

deficiencies identified against the audit program, Section G.6 - Program Changes M&TE procedures have been subjected to various changes as the project i design and construction process accelerated and the volume of

, calibration equipment and usage increased. These changes were required

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to provide better guidance for M&TE issue, control, and trackin Internal reviews, NRC inspections, and QA audits identified weaknesses in program implementation . Corrective action for these weaknesses i provided tighter equipment inventory control and improved guidelines i for reporting and evaluating activities associated with identified

! out-of-calibration equipmen Review of the changes indicated M&TE j program enhancements with no reduction in commitments.

i Section G.7 - Verification of Project M&TE Control Program This section describes the Readiness Review process for M&TE program verification during the VEGP construction phase. The purpose of

the verification was to determine whether procedures and practices in

! Use at VEGP have met project commitments in this are (1) Commitments and Impleme1tation

! The appendix appeared to adequately list all comitments which

supported an acceptable calibration program. Additionally, i commitment implementation was generally adequate. The following i

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inconsistencies or inaccuracies were identified by the inspector, most of which involved the earlier, Revision 0 procedures:

(a) Commi tment 2911.01-07 Records and Documentation The implementation matrix references GD-A-04 Calibration and Control, Revision 0, Section 9.1.10, for GPC. This section does not exist in this revisio Section VI, Revision 0, delineates that calibration certification be forwarded to the document control superviso Further reference is not made to record storage, indexing, identification, et The implementation matrix for PPP references M&TE procedure XII-2, Calibration of Tools, Measurements and Test Equipment, dated 2/12/79, Section 10.3, as implementing this commitment on records and documentation. This section does not exist in the procedure. Additionallly, Section 3.3.1 requires an equipment calibration record, Form 33, shall be maintaine This does not meet the extent of the commitment listed in the matrix. A revision dated July 19, 1982, references procedure XVII-1, QA Records, which would satisfy this requirement. This records procedure was effective during the June 1979 period but was not referenced in the M&TE procedur In both cases (GPC and PPP) adequate controls existed for calibration documentation in QA records procedures effective during this time period although not accurately addressed in the implementation matrix. The QA records control commit-ment, ANSI N45.2.9, Draft 11, Revision 0, was addressed more adequately and appropriately in Appendix D of Readiness Review, Document Contro (b) Commitment 4961.0, Identification of Types of M&TE Controlled by Each Procedure The GPC matrix references GD-A-04, Calibration and Control, Sections III.C.1 and V.B.1 for Revision Section III.C.1 requires a supervisor to submit to Document Control Center (DCC) a list of all M&TE used by his personne Section V.B.1 references an inventory control log which identifies all M&TE utilized by constructio The most recent revision of GD-A-04 references Section 5.4. (Revision 11) requiring that a calibration procedure be assigned for all new M&TE if available, or one written. This implies interpretation of this connitment to be both generic and specifi In the earlier revision, all equipment controlled by the general M&TE procedure, GD-A-04, were liste The current revision implies identification of specific calibration procedures for each piece of equipmen .

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Discussions with readiness review personnel resulted in a generic interpretation which was implemented by the scope (Section 1.0) of each procedure. For example, in the earlier revision, the scope states that the procedure establishes and defines methods... for all M&TE used for testing, inspecting, and maintaining safety related structures of nuclear power plants. The scope becomes more definitive as GD-A-04 (for GPC) is revised, to the point of M&TE used to verify conformance to design specification requirements for Units 1 and 2. If the generic interpretation is accepted, then Section 1.0, Scope, should be referenced and consistently interpreted through all procedure revision The procedures for PPP and NISCO have similar discrepancies with regard to this commitmen The later revision of PPP procedure XII-2 refers to specific calibration instructions for individual M&TE while the referenced section in the earlier revision does not address the commitment. The NISCO M&TE procedure, ES-140, Calibration and Control of Measuring and Test Equipment, is consistent in that it dces not address this commitment in either the earlier or later revision ,

sections reference (c) Comitment 4962.0 Calibration Procedure Used for Each Type of M&TE The PPP implementation matrix references the M&TE Procedure, XII-2 dated February 12, 1979, section 6.2.D. This section does not exist in this procedur Section 4.0 of this procedure lists specific calibration requirements for M&TE but no calibration procedures were in use at the tim In conclusion, the inaccuracies and inconsistencies noted above do not appear to represent a significant program failure nor compromise the quality of the VEGP M&TE usage during plant constructio Document control and QA records procedures identified calibration reports as QA records and provided adequate l control Equipment calibrations were performed with the l manufacturer's instructions and requirements specified in their

' procedures. Deficiencies in initial procedures revisions were identified and commitments adequately met in the most recent procedure (2) RRS Findings and Correctiv.c Actions The inspector's examination of the 22 findings determined that

, they appeared to be properly categorized and the proposed l resolutions to these findings were satisfactory. The majority of l the RRS findings were Level III findings which were violations of project procedures with no safety concern Three Level II findings, those which violated licensing commitments or l

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engineering requirements with no safety concerns, were examined by the inspector to assure that corrective actions appeared adequat No Level I findings, those with safety concerns, were identified in this appendi Finding G.2, Level II, addressed a lack of traceability to the National Bureau of Standards (NBS) for electrical termination tools from AMP Products Corporation. The licensee identified the cause of this failure and performed an expanded sample of M&TE to identify any other existing traceability discrepancies. Further discrepancies were not identified. The AMP corporation provided documentation establishing specific tool traceability designated by this findin Finding G.3, Level II, identified inadequate calibration instructions for some M&TE. These instructions did not state how to perform the calibration. A 100 percent review by GPC of onsite calibration instructions resulted in revisions to 67 of 172 calibration instructions. The inspector reviewed a sample of calibration instructions and determined these instructions appeared adequate to perform calibration Review of calibration reports, by the inspector, identified that there were no deficiencies in previous calibrations with regard to correct reference standards utilized. The project response to this finding appeared adequat Finding G.15, Level II, addresses procurement of calibration services from unapproved vendor An initial review, identified 101 vendors whose qualifications were questionable. Ten of these vendors were on supplier listings. The remaining vendors or equipment were evaluated and placed in the following categories:

- Category C - Suppliers not evaluated, equipment calibrated by these suppliers has been recalibrated by a qualified supplier or GP Recalibration certificates include "as received" conditions of equipment thus eliminating the need to qualify the original calibrato Category D - Suppliers evaluated by an audit performed by BPS Quality Lead Auditors. Audit based on applicable elements of 10 CFR 50, Appendix P

- Category E - Suppliers did not require evaluation Bases for this category includes:

Supplier did not perform calibration No "Q" Application Federal / State Agency l

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The inspector reviewed the equipment calibration records of ten of the vendors identified in Category C, or approximately 25 percent of this categor Of these ten, three were dispositioned other than as stated in the respons These inaccuracies did not compromise the work performed by this equipment but did indicate a need for the licensee to reexamine the data in this categor Examples of these discrepancies are as follows:

(a) Consolidated Devices was dispositioned as recalibrated by GP Records indicate these torque wrenches were not used onsite. After several attempts to calibrate the wrenches and repeated inability to accurately calibrate, these wrenches were released for availability offsit (b) E. Phil Harris was dispositioned as recalibrated by Gage Labs, In No documentation were identified in the records of a Gage Lab calibration. This three foot survey rod was broken with no recalibration possibl (c) Thread Forms, Inc. was dispositioned as recalibrated by Pittsburg Testing Labs (PTL). These plug thread gages were recalibrated by Gage Labs, Inc. according to calibration certificates on fil In Category D, the inspector reviewed 17 of 28 audit reports which qualified vendors. Of 33 audits performed, 5 were rejected and required Category C disposition. The audit group based acceptance on two requirements. Possession of either requirement qualified a vendor in this category. The first factor was the identification of an establish vendor QA program at the time of procurement of equipment or services. The second requirement was verifiable traceability to the NB The traceability factor required certifications of traceability for the individual equipment or servic Some vendors had no documented QA program but present practices were evaluated by a checklist of items which, if satisfied, would

indicate an adequate, controlled, calibration progra Determination of adequately controlled calibration programs currently utilized by the vendors provided a degree of reenforce- *

ment for qualifying vendors within this categor The root cause for this use of unapproved vendors was attributed

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to a discrepancy between the GPC field procedure GD-A-04, and the Vogtle Procurement Policy and Procedure Manual (VPPPM). The field

' procedure required calibration vendors to be on a Qualified Supplier List (QSL) and the VPPPM did not. The VPPPM Revision 3, incorporates requirements for M&TE vendors supplying calibration i to be on an approved vendor lis The corrective measures 1 appeared adequate to prevent reoccurrence of this issue. This

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inspector reviewed a sample of purchase orders for M&TE or l

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services since corrective actions were initiate A'1 M&TE vendors in this sample were on the approved vendors list. Based on the review of calibration reports and audits, the inspector did not identify any impact on safety related equipment as a result of this findin Additionally, corrective action appeared adequate to preclude reoccurrenc No violations or deviations were identified.

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