IR 05000424/1986080
| ML20215G167 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/23/1986 |
| From: | Peranich M, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215G162 | List: |
| References | |
| 50-424-86-80, NUDOCS 8610200162 | |
| Download: ML20215G167 (27) | |
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g uni 1 ED STATES g
g NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555
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t Report No.:
50-424/86-80 Licensee:
Georgia Power Company P.O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424 Construction Permit No.:
CPPR-108 Facility Name:
Vogtle, Unit 1 Module:
Appendix G, Measuring and Test Equipment Reviews Conducted:
May 12, 1986 - August 29, 1986 On-Site Inspections Conducted:
May 12-18, 1986; June 2-6, 1986; and August 4-8, 1986 NRC Offices Participating in Inspections / Reviews:
Office of Inspection and Enforcement (IE, Bethesda, MD)
Region II, Atlanta, GA Reviewers:
H. W. Phillips, Reactor Construction Engineer, RCPB, IE (Primary Reviewer)
D. C. Ford,_ Consultant L. R. Moore, Reactor Inspector, Region II
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Prepared By:
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i' ZZ~ b W.W.PhiJ11ps,PrimaryR6 viewer Date Signed Reactor C'onstruction Programs Branch, IE Approved By:
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g.W.Peranich,SectionChief Date Signed Reactor Construction Programs Branch, IE M. V. Sinkule, Chief Date Signed Projects Section 3C Division of Reactor Projects, Region II e610200162 860923 DR ADOCK 0500
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT CONTENTS Topic h
Summary........................................................
Purpose and Scope of Review....................................
Methodology....................................................
NRC Staff Evaluation...........................................
NRC Staff Findings.............................................
Statement of Module Acceptability (Conclusions)................
References.....................................................
Tables.........................................................
List of Persons Contacted......................................
Acronyms.......................................................
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V0GLTE ELECTRIC GENERATING PLANT UNIT 1
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READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT SUMMARY The Readiness Review' Program is being conducted at the initiative of Georgia Power Company (GPC) management to assure that design, construction, and operational commitments have been properly identified and implemented at the Vogtle Electric Generating Plant Unit 1.
Appendix G which was submitted by Georgia Power Company on March 11, 1986, presents an assessment of the com-pliance of the Measuring and Test Equipment (M&TE) program with Final Safety Analysis Report (FSAR) commitments and regulatory requirements for the con-struction phase.
This evaluation by the NRC was conducted to determine if the results of the program review of M&TE presented in Appendix G represent an
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effective and accurate assessment of the requirements, and that these require-ments have been properly implemented.
This evaluation was performed by NRC reviewers from the Office of Inspection and Enforcement (IE), and inspectors from Region II.
The evaluation consisted of a detailed examination of each section of Appendix G, with particular emphasis on sections G.3, " Commitments and Implementation," and G.7, "Verifica-tion of Project M&TE Control Program," which for the purpose of this evaluation were considered " Critical Elements." Specific NRC staff evaluation of each Appendix G section is provided in section 3.0 of this report.
In general, with the exception of the conditionally acceptable and unresolved items listed below, the NRC evaluation indicates that the licensee's program review was comprehensive and provides adequate assurance that construction M&TE
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programs will perform intended functions in accordance with FSAR commitments and regulatory requirements.
The NRC review also indicates that the licensee has taken appropriate actions with regard to licensee identified deficiencies and that M&TE program effectiveness has been enhanced by active management participation.
The conclusions of the NRC evaluation are summarized by category as follows:
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1.
Acceptable: Appendix G Sections:
G1 Scope, G2 Responsible Organizations, G3 Commitments and Implementation, G4 Program Description, G5 Audits and G6 Program Changes.
2.
Conditionally Acceptable:
a.
G7 Verification of Project M&TE Control Program (1) The NRC review resulted in the identification of a program deficiency with regard to the lack of activity logs or other usage records, and usage records for Pullman Power Products, automatic welding machines.
This deficiency is discussed in detail in section 3.g.(2)(e) of this report and was documented by NRC inspection report 50-424/86-77, Violation 424/86-77-01.
It will require additional licen-see attention and NRC review prior to full acceptance Appendix G.
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(2) The NRC review identified unresolved item (UNR) 424/86-77-02 regarding a question concerning the overall MT&E program to ensure that project FSAR and other commitments are adequately implemented (including M&TE for both construc-tion and operations support - construction acceptance tests, preoperational tests, startup and operations).
This item is discussed in section 3.g.(2)(e) of this report, and it requires further action.
b.
G8 Program Assessment.
This section of Appendix G is generally acceptable, pending further action to resolve Violation 424/86-77-01 and UNR 424/86-77-02 mentioned above.
3.
Unacceptable:
There were no unacceptable findings.
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Purpose and Scope of Review
The purpose of this evaluation was to determine if the results of the program review of Measuring and Test Equipment (M&TE) presented in Appendix G, are an effective and accurate assessment of construction requirements, and that these requirements have been properly implemented.
It is noted that the scope of Appendix G applies only to M&TE used during construction, and does not cover the overall M&TE program.
Appendix G does not include M&TE used for construction acceptance testing, preoperational testing, startup and operation.
Throughout this report the terms " Measuring and Test Equipment (M&TE)" and the "M&TE program" apply to items requiring calibration and control, including certain tools, equipments and actual measuring and test equipment.
The review consisted of an examination of each section_of Appendix G and was performed by reviewers assigned from the NRC Office of Inspection and Enforcement (IE) and from NRC Region II. The following is a list of the sections of Appendix G:
G1 Scope G2 Responsible Organizations G3 Commitments and Implementation *
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G4 Program Description G5 Audits G6 Program Changes G7 Verification of Project Measuring and Test Equipment Control Program *
G8 Program Assessment.
- Critical elements Appendix G sections G1, G2, G4, G5, G6 and G8 presented licensee data on the scope, responsible organizations, program descriptions, audits, changes
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and conclusions regarding assessment of the Appendix.
These did not require the review depth given to sections G3 and G7 which covered licensee
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commitments and implementation, and Appendix verification.
For the purpose of this evaluation, sections G1, G2, G4, G5, G6 and G8 were considered program elements, while sections G3 and G7 were considered critical elements.
The review of Appendix G included an examination of content; review of findings, concerns, and observations; review of a sample of items reviewed by the Georgia Power Company (GPC) Readiness Review Team (RRT); and an examination by NRC/IE of an independently selected sample of records and hardware critical elements. The methodology used, and evaluation of each section is provided in the discussion which follows.
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2.
Methodology
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a.
IE Review The review and evaluation by the NRC Office of Inspection and Enforcement (IE) focused on verification of the project M&TE control program, which is described in Section 7 of Appendix G.
The purpose of the verification was to determine whether procedures and practices in use at the Vogtle Electric Generating Plant (VEGP)
have met project commitments in this area.
The IE evaluation was accomplished by on-site inspection during the week of August 4-8, 1986. -Activities included a review of
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Section 7 for content and completeness, a review of relevant findings and licensee corrective actions, and an examination of components which comprise portions of the Georgia Power Company (GPC) and Pullman Power Products (PPP) measuring and test equipment programs.
To accomplish these activities, 26 samples of M&TE hardware were selected as critical elements and inspected for compliance with FSAR requirements, and applicable codes and standards.
Relevant site procedures and associated documentation were also reviewed.
The selection of critical elements was made based upon component func-tion, and application to discipline construction activities. The components selected represent an independent sample and were not examined by the applicant during his RRT review of Appendix G.
Reference Table 1 shows a listing of GPC and PPP component critical element samples.
b.
Region II Review Review and evaluation by the NRC Region II evaluation team consisted of an examination of each section of Appendix G.
The initial techni-cal review was conducted in the Region II office during the week of May 5, 1986, followed by on-site inspection activity during the weeks of May 12-16 and June 2-6, 1986.
An additional review of audits was performed at the GPC corporate office in Atlanta on May 28, 1986.
On-site inspection included the program review by examination of records, procedures and program description.
The NRC inspector examined a limited sample of records reviewed by the GPC Readiness Review Staff (RRS) and an independent sample to examine various findings and corrective actions. The inspector reviewed procedures and commitment implementation by Georgia Power Company, Pullman Power Products, and Nuclear Installation Services Company (NISCO).
Records sampled during this review were limited to GPC records.
Audits relating to M&TE programs for GPC and the two contractors were reviewed and findings examined.
The detail and depth of the l
audit working checklists were reviewed.
3.
NRC Staff Evaluations The evaluation of each Appendix section is provided in the following
discussion, using a section by section format which references the applicant's Appendix G Readiness Review Report.
Included are a description l
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of the section, what was reviewed, the basis for acceptance, and a state-ment of any required follow-up or evaluation.
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a.
Section G1.0 - Scope (1)
Introduction and Section Evaluation This section provides a description of the intent and content of Appendix G.
The section discussed the boundaries to which M&TE was evaluated by the applicants Readiness Review Team (RRT).
Appendix G provided a description and evaluation of the programs governing the control of M&TE utilized during construction activities at the Vogtle Electric Generating Plant. The M&TE programs for GPC, PPP, and NISCO were described and evaluated.
Other onsite contractors utilized GPC's calibrated equipment for determining inspection acceptance of construction activities.
Appendix G states that the nuclear operations M&TE program is addressed in modules 3A, 5, 7, 9A, and 9B.
The time period involved in this evaluation by GPC was from early 1977 to December 31, 1985.
(2)
Inspection Results This section was reviewed for background information only.
No follow-up or evaluation of this section of Appendix G was required.
However, it was noted, on reviewing the interface with operations M&TE, that specific evaluation of M&TE in modules 3A, 5, 7, 9A and 9B was either not covered or only generally mentioned, without information-on actual M&TE hardware inspections.
This requ. ires attention beyond the scope of Appendix G.
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b.
Section G2.0 - Responsible Organizations (1) This section described the various construction organizations responsible for M&TE activities within the scope of Appendix G.
GPC had overall quality responsibility for work performed at VEGP including the M&TE program.
PPP products and NISCO each maintained M&TE programs which were reviewed by the GPC Quality Assurance (QA) organization.
This section also identified contractors which utilized the GPC calibrated equipment.
(2)
Inspection Results This section was reviewed for background information. No follow-up or evaluation of this section was required.
c.
Section G3.0 - Commitments and Implementation (1)
Introduction and Section Evaluation This section of Appendix G contains a listing of commitments and implementing documents which are displayed in two matrices.
The first is entitled, " Commitment Matrix" and presents a com-prehensive listing of ccmmitments by.the Georgia Power Company-5-
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for Vogtle 1 along with a source document reference for each
commitment.
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The second is entitled, " Implementation Matrix" and presents a listing of source documents and requirement features referenced
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to within each commitment along with a document reference where the features have been implemented.
The Region II review focused on verifying that Vogtle's licensing commitments and implementing
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documents comply with FSAR, Regulatory Guides, and Industry Codes and Standards.
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(2) Inspection Results J
The appendix appeared to adequately list comitments which
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support an acceptable calibration program.
Additionally, r
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comitment implementation was generally adequate.
However, j
several inconsistencies or inaccuracies were identified by
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Region II, most of which involve earlier Revision 0 procedures.
(a) Comitment 2911.09-07 - Records and Documentation The implementation matrix references GD-1-04, Calibration and i
Control, Revision 0, Section 9.1.10, for GPC. This section does
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not exist in this revision.
Section VI, Revision 0, delineates
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that calibration certification be forwarded to the document
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control supervisor.
Further reference is not made to record storage, indexing, identification, etc.
The implementation matrix for PPP references M&TE procedure X-2, Calibration of Tools, Measurements, and Test Equipment, dated February 12, 1979, Section 10.3, as implementing this comitment
on records and documentation.
This section does not exist in i
the procedure. Additionally, Section 3.3.1 requires an equip-ment calibration record, Form 3, shall be maintained. This
does not meet the extent of the 'comitment listed in the matrix.
A revision dated July 19, 1982, references procedure XVII-1, QA
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Records, which would satisfy this requirement.
This records
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procedure was effective during the June 1979 period, but was not referenced in the M&TE procedure.
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In both cases (GPC and PPP) adequate controls existed for (
calibration documentation in QA records procedures effective
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during this time period although not accurately addressed in the implementation matrix.
The QA records control comitments, ANSI N45.2.9, Draft 11, Revision 0, was addressed more adequately and appropriately in Appendix D of Readiness Review, i
Document Control.
l (b) Comitment 4961.0 - Identification of Types M&TE Controlled by Each Procedure The GPC matrix references GD-A-04, Calibration and Control, l
Sections III.C.1 and V.B.1 for Revision 0.
Section III.C.1 l
requires a supervisor to submit to Document Control Center (DCC)
a list of all M&TE used by his personnel.
Section V.B.1 r
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Revision 11 of GD-A-04, Section
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5.4.1.8 requires that a calibration procedure be assigned for
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all new M&TE,_if available, or one written.
This~ implies
interpretation of this commitment ~to be both generic and
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In the earlier revision, all equipment controlled by
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the general MTE procedure, GD-A-04, were listed.
The current revision implies identification of specific calibration
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procedures for each piece of equipment.
Discussions with readiness review personnel resulted in a
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generic interpretation which was implemented by the scope
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(Section 1.0) of each procedure.
For example, in Rev. O, the
scope states that the procedure establishes and defines
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methods "... for all M&TE used for testing, inspecting, and maintaining safety-related structures of nuclear power plants."
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The scope becomes more definitive as GD-A-04 is revised, to the point of indicating MTE used to verify conformance to design
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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
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revisions.
The procedures for PPP and NISCO have similar discrepancies with regard to this commitment.
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 comitment. The NISCO. ETE procedure, ES-140,
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Calibration and Control of Measuring and Test Equipment, does not address this comitment in either the ' earlier or later
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j-revision sections referenced.
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l (c) Comitment 4962.0 - Calibration Procedure Used for Each Type
of M&TE l
The PPP implementation matrix references the M&TE Procedure, X-2 dated February 12, 1979, Section 6.2.0.
This section does not
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exist in this procedure.
Section 4.0 of M&TE Procedure, X-2
lists specific calibration requirements for M&TE, but no j
' calibration procedures were in use at that time, i
In conclusion, the inaccuracies and inconsistencies noted under
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3.c.(2)(a), (b)'and (c) above do not appear to represent a significant program failure nor compromise the quality of the
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VEGP M&TE usage during plant construction.
Document control and
QA records procedures identified calibration reports as QA records and provided adequate controls.
Equipment calibration were performed with the manufacturer's instruction and require-
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ments specified in their procedures.
Deficiencies in initial
procedures revisions were identified and comitments adequately i
met in the most recent procedures.
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Follow-up or additional evaluation for Section G3.0, other than l
noted above, was not required.
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d.
Section G4.0 - Program Description
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(1) Introduction and Section Examination This section of Appendix G provided a description of three M&TE programs used on site, GPC, PPP, and NISCO.
it also provided a description of the procurement method for calibration services and equipment from approved vendors.
The section was examined by Region II for content, background for the review of later sections, and accuracy of the information presented.
The M&TE control program includes the following activities.
Procurement of calibration equipment and services.
- Equipment control and tracking.
- Calibration and recalibration.
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Out of calibration reporting and resolution.
- Storage of documentation.
(2) Inspection Results The evaluation did not disclose significant errors or a basis for programmatic concerns, however, several discrepancies were identified and are detailed in the discussions which follow.
(a) Region II 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 proce-dures.
Activities not adequately addressed in initial procedure revisions were generally identified as audit findings and incorporated into later revisions.
(b) During the applicant's evaluation of the section, several findings were identified.
These findings and resolutions involving evaluation and program changes are detailed in the discussions which follows.
Finding G.15, Level II, addresses procurement of calibra-tion services from unapproved vendors.
An initial review (
identified 101 vendors whose qualification were question-able.
Ten of these vendors were on the Qualified Supplier List.
The remaining vendors or equipment were evaluated and placed in the following categories.
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Suppliers not evaluated.
Equipment calibrated by these suppliers has been recalibrated by a qualified supplier of GPC.
Recalibration certificates include
"as received" conditions of equipment thus I-8-
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eliminating the need to qualify the original calibrator.
Category D -
Suppliers evaluated by an audit performed by Bechtel Power Services (BPS) Quality Lead Auditors. Audit based on applicable elements of 10 CFR 50, Appendix B.
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Category E -
Suppliers did not require evaluations.
Bases for this category includes:
- Supplier did not perform calibration,
- No "Q" Application, and
- Federal / State Agency.
Region II reviewed the equipment calibration records of 10 of the vendors identified in Category C, or approximately 25 percent of this category.
Of these 10, 3 were dispositioned other than as stated in the response.
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 category.
Examples of these
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discrepancies are as follows.
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- Consolidated Devices was dispositioned as recalibrated by GPC.
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 availa-bility offsite.
E. Phil Harris was dispositioned as recalibrated by Gage Labs, Incorporated.
No documentation were identified in the records of a Gage Lab calibration.
This three-foot survey rod was broken with no
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recalibration possible.
- Thread Forms, Incorporated was dispositioned as recalibrated by Pittsburg Testing Labs (PTL).
These plug thread gages were recalibrated by Gage Labs,
Incorporated according to calibration certificates on file.
In Category D the inspector reviewed 17 of 28 audit reports which, qualified vendors.
Of 33 audits performed, 5
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were rejected and required Category C disposition. The audit group based acceptance on two requirements, and possession of either requirement qualified a vendor in this category. The first factor was the identification of an established vendor QA program at the time of procurement of equipment or services.
The second requirement was verifiable traceability to the National Bureau of Standards l
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(NBS).
The traceability factor required certifications of
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traceability for the individual equipment or service.
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, calibra-tion program.
Determination of an adequately controlled calibration program currently utilized by the vendors provided a degree of reenforcement for qualifying vendors within this category.
This root cause for this use of unapproved vendors was attributed 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 require-ments for M&TE vendors supplying calibration to be on an approved vendor list.
The corrective measures appeared adequate to prevent reoccurrence of this issue.
The NRC inspector reviewed a sample of purchase orders for M&TE or services since corrective actions were initiated.
All 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 finding.
Additionally, corrective action appeared adequate to preclude reoccurrence.
Based upon this information, the present procurement method for M&TE appears adequate even through these services had previously been procured from unapproved vendors.
Finding G.2, Level II, addressed a lack of trace-ability to the National Bureau of Standards 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 discrepan-cies.
Further discrepancies were not identified.
The AMP corporation provided documentation establishing specific tool traceability designated by this finding.
Finding G.3, Level II, identified inadequate calibra-tion 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 calibrations.
Review of calibration reports, by the inspector, identified that there were not deficiencies in previous calibrations with r-agard to i-10-
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t correct reference standards utilized. The project response to this finding appeared adequate.
- One noted deviation from the program descriptions was that all calibrations on site, including those of PPP and NISCO, will be performed by GPC, who'will also be responsible for all site reference-standards.
This program change went into effect at the end of May-1986.
The onsite M&TE programs in effect at the time of the
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Region II inspection (May 12-18,1986), appeared adequate and conformed to the description of Section G4.
Later, during the IE inspection, the consolidation of M&TE calibra-
tion activities for construction was examined and found to be in operation under direction of GPC.
It was noted that Pullman Power Products still retains responsibility for calibration of automatic welding equipment and certain temperature recorders.
Discussions with several onsite users of the consolidated GPC calibration
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facility indicated a satisfactory calibration service activity.
In
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general, the consolidated GPC calibration activity was considered
acceptable, j
Follow-up or additional evaluation of Section G4.0 was not required.
e.
Section G5.0 - Audits (1) Introduction and Section Examination This section contained a review of the various audits and
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evaluations 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 Corporation.
The section was examined by the inspectors to confirm the i
adequacy and effectiveness of these reviews and to assure that proper reporting methods were observed.
(2) Inspection Results Thirty-eight findings were noted during the audits and investi-i gations.
Six findings resulted in changes to procedures and one significant finding identified untimely recording of nonconform-
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ance reports (NCRs) at PPP associated with out-of-calibration M&TE.
The NRC inspector did not identify significant findings contained in the audits which were not previously addressed in Appendix G.
The examination did not disclose significant verification errors or a basis for programmatic concern.
Follow-up or additional evaluation of Section G5.0 was not required.
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Section G6.0 - Program Changes
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(1) Introduction and Section Evaluation M&TE procedures have been subjected to various changes as the
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project design and construction process accelerated and the volume of calibration equipment and usage increased.
These changes were required to provide better guidance for M&TE issue, control, and tracking.
Internal reviews, NRC inspection, and i
QA audits identified weaknesses in program implementation.
Corrective action for these weaknesses provided tighter equip-ment inventory control and improved guidelines for reporting and
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evaluating activities associated with identified out-of-cali-
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bration equipment.
(2) Inspection Results
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Review of the changes indicated M&TE program enhancements with no reduction in commitments.
No further evaluation or follow-up s
j of Section G6.0 was required.
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g.
Section G7.0 - Verification of Project M&TE Control Program
(1) Introduction and Section Evaluation
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This section describes the Readiness Review process for M&TE l
program verification during the Vogtle Electric Generating Plant construction phase.
The purpose of the verification was to
determine whether procedures and practices in use at VEGP have met project commitments in this area.
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A technical appraisal by NRC reviewers of Readiness Review Module Appendix G is provided below.
The primary emphasis of
l the eva?uation was on " critical elements" within the Measuring i
and Test Equipment (M&TE) control systems. While an overview of
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rogram requirements is included, the detailed evaluation of p' program elements" is provided in previous sections.
.The review, which consisted of a examination of components which
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comprise portions of the Georgia Power and Pullman Power Products M&TE programs was performed by inspectors from the Office of Inspection and Enforcement in Bethesda, Maryland.
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Twenty-six samples of M&TE were selected as critical elements
and examined for compliance with FSAR requirements, and i
applicable codes and standards.
Relevant site procedures and (
associated documentation were also reviewed. The selection of
critical elements was made based upon component function and
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application to discipline construction activities. The com-ponents selected represent an independent sample and were not
examined by the applicant during his Appendix G review.
i A list which details critical elements selected and examined from the Georgia Power Company and Pullman Power Products M&TE control systems is shown in Table 1.
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(2) Inspection Results
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This section provides a technical evaluation by NRC reviewers of Appendix G activities.
The evaluation consisted of a comparison of the selected critical elements to the specific technical requirements detailed below.
Applicant and contractor programs were evaluated to determine how effectively they implement these requirements.
Results of the NRC technical evaluation are as follows.
(a) Adequacy of Standards
Reference standards used by the applicant for calibrating measuring and test equipment shall have the capabilities for accuracy, stability, and range required for intended use.
The review of relevant document packages, indicates that the applicants reference standards have been purchased and main-tained in accordance with requirements.
Calibration activities are traceable to national standards and are documented in accordance with approved procedures.
The NRC inspector also reviewed calibration data reports and manufacturer's specifica-tions and concluded that the reference standards examined demonstrate the accuracy and range required to perform their intended function.
The applicant was unable to produce one of the three reference standards selected for examination.
The " AMP" Crimping Die Calibration Master could not be located at GPC calibration lab or at the M&TE issue station. The NRC inspector noted that records associated with this equipment indicate that it had never been used to perform calibration activities.
Additional research will be required by the applicant to determine the
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status of this equipment.
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No other deficiencies were observed in this area.
(b) Environmental Controls Measuring and test equipment shall be calibrated in an environ-ment controlled to assure required accuracy.
Consideration should be given to items such as temperature, humidity, vibra-tion, and cleanliness.
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The review of applicable calibration records indicates that I
calibration facility environmental conditions have been con-sidered and controlled in accordance with procedures.
Cali-brated temperature and humidity records were present, and monitored daily by department personnel.
Records, which reflect calibration at off-site facilities, provided objective evidence that environmental controls were in place.
The applicant has effectively implemented program requirements in this area.
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(c) Intervals of Calibration
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Measuring and test equipment and Reference Standards shall be calibrated at intervals established on the basis of stability, purpose, and degree of usage.
Calibration frequencies have been established by the applicant in " Calibration Instructions." The instructions are unique to each type of equipment and specify frequencies which are based on industry standards or engineering evaluation. The inspector reviewed calibration records for the sample of M&TE selected and noted that the calibration intervals specified, accuracy reflect those' prescribed in the applicable calibration instructions.
The inspector also observed that controls are in place to assure that M&TE will be withdrawn from service prior to exceeding specified calibration intervals.
During the examination of documents associated with GPC Reference Standard C-1151, a "Starrett" Master Gauge Block set.
The NRC inspector noted that the equipment calibration log incorrectly specifies a calibration frequency of five years, instead of annual frequency required by calibration instruction MRS-2, Revision 1.
This appears to have been a clerical error and was corrected by GPC personnel during this evaluation.
However, the NRC inspector noted that Revision 1, of calibration instruction MRS-2 which changes the calibration frequency from five years to annually, was issued on July 18, 1985 and that recalibration of this equipment did not take place until October 8, 1985.
As a result, the equipment was out of calibra-tion (beyond the recalibration date) during this period.
A review of the applicable activity log indicates that the equip-ment had been used to calibrate 14 M&TE components during the period between these dates.
With the exception of the deficiency identified above, the applicant has effectively implemented program requirements in this area.
(d) Calibration Procedures Written procedures shall be prepared and used for calibration of all measuring and test equipment.
The inspector reviewed Georgia Power Company procedure GD-A-04, entitled " Calibration and Control" and Pullman Power Products procedure, X-II, entitled " Procedure for the Calibration of Tools, Measurements, and Test Equipment." These procedures establish basic requirements for calibration of M&TE at the Vogtle site.
The content of the procedures appears adequate to assure control of M&TE calibration processes. The inspector also reviewed some 20 GPC calibration instructions. These instruc-tion have been developed to give specific guidance for calibra-tion of various M&TE components.
The inspector observed that calibration instructions had been developed for each of the M&TE categories at site and are referenced in the equipment
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calibration folders.
The instructions appear thorough and
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well as specific technical requirements which include; calibration points, environmental and accuracy requirements.
No deficiencies were identified in this area.
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(e) Records
.The applicant shall maintain records which provide objective evidence that calibration schedules are complied with and that the accuracy of equipment is being maintained.
The review of document packages associated with the selected ETE sample, indicates the applicants program provides an effective record of calibration activities.
Calibration logs,
issue logs, activity sheets, and reference material were included in ETE component packages.
These documents appear to i
provide an accurate and thorough record of E TE history,
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present location, calibration internal, reference to calibration procedure, actual calibration values, and corrective actions where required.
Records are maintained in locked, fire-rated cabinets and access is limited to authorized personnel.
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During the review of document packages and inspector identified
i a number of files containing a memo which had been used to provide a " Conditional: Release" for E TE which did not met program requirements.
The use of a memo as a " conditional
release" is not in accordance with site requirements, and does
not provide a effective method of tracking equipment deficien-cies.
This condition was observed in the following M TE and
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reference standard (RS) packages.
- Flow Test Orifice Tube C-4230 E~E
Master Guage Blocks C-1151 RS
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During the review of records associated with " Gold Track II" automatic welders the NRC inspectors noted that activity-logs or
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other records of usage had not been maintained.
The automatic
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welders are part of the Pullman Power Products ETE program and
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Procedure X-II.
The failure to maintain an activity log or l
other usage record for this equipment represents a deficiency l
in that evaluation of previous work could not be accomplished.
i As a result of this observation the inspector reviewed document l
packages associated with each of the 13 automatic welders used i
by Pullman at the Vogtle site.
The review indicates that three of the welders exhibited an "Out-of-Tolerance" condition.
l This condition was identified by Pullman on appropriate documents and subsequently evaluated as " acceptable" by site engineering.
However, corrective action to provide for activity or other records of usage was not taken.
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As a result of thm NRC insp:ctor's cbservation, this matter was documented in NRC inspection report 50-424/86-77, and further action was required.
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-In addition, a question was raised as to the licensee's program to ensure that project regulatory commitments, particularly regarding the overall M&TE program, are adequately implemented.
Additional information is required concerning the overall MT&E program (for both construction and operations) and the Quality Assurance program specified for the program. The NRC inspector identified this as Unresolved Item (UNR) 424/86-77-02," Quality Assurance for Measuring and Test Equipment."
(f) Lacel_ing Measuring and test equipment shall be labeled to indicate identification, date of.last calibration, by whom it was cali-brated and when the next calibration is due.
The physical inspection of the selected sample of reference
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standards and M&TE indicates that these components have been labeled in accordance with requirements.
Label information, such as identification,' calibration date, and calibration due
date, was found to. accurately reflect the data on associated calibration records.
The applicant has effectively implemented program requirements in this area.
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Section G8.0 - Program Assessment (1) Introduction and Section Evaluation
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This section provided a summary of open corrective actions, quality assurance statement, resumes, statement by the Vice President of Project Construction, and statement by the Readiness Review Board.
(2) Inspection Results The material submitted is generally acceptable, but further action is required to cover corrective action for the program deficiency mentioned under 3.g.(2)(e) and identified in NRC inspection. report 50-424/86-77 regarding the lack of activity
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!ags or other usage records for automatic welding machines.
Also, further action is required to asstre that other project commitments are adequately implemented (including M&TE for i
operations support - construction acceptance tests, preopera-
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tional tests, startup and operations).
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NRC Staff Findings The following findings were identified during the NRC evaluation of Appendix G.
With the exception of item 1, each of the deficiencies noted is considered to have minimal safety significance.
a.
Deficiency (Violation 424/86-77-01) - M&TE Activity Logs - Failure to maintain equipment activity logs or other usage records for Pullman Power Products automatic welding machines.
Reference section 3.g.(2)(e) of this report for details.
b.
Commitment Reference - Project commitment 2911.01-07 is inaccurately
- referenced in the Appendix G, " Implementation Matrix." Reference section 3.c.(2)(a) of this report for details.
c.
Commitment Interpretation - Project commitment 4961.0, is inconsis-tently interpreted in site implementation procedures.
Reference section 3.c.(2)(b) of this report for details.
d.
Commitment Reference - Project commitment 4692.0, is inaccurately referenced in the Pullman Power Products " Implementation Matrix."
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Reference section 3.c.(2)(c) of this report for details.
e.
Lost Reference Standard - (GPC) Reference Standard C-3454, an " AMP" Crimping Die Calibration Master could not be located by the licensee.
Reference section 3.g.(2)(a) of this report for details, f.
Calibration Records - The calibration log for (GPC) Reference Standard C-1151 details a calibration frequency which differs from the frequency specified by applicable procedures.
Reference section 3.g.(2)(c) of this report for details.
The actions taken by the licensee regarding the above items were found to be satisfactory, except for item 4.a above, which was documented by NRC inspection report 50-424/86-77 and requires further action.
Also, NRC inspection report 50-424/86-77 described an Unresolved Item (UNR)
424/86-77-02 regarding a question concerning the overall MT&E program to ensure that project FSAR and other commitments are adequately implemented.
This matter required further action.
5.
Statement of Module Acceptability (Conclusions)
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Based upon the review provided within the scope of this appendix, the NRC Staff has reached the following conclusions with regard to Measuring and Test Equipment activities at Vogtle Electric Generating Station Unit 1.
With the exception of those items specifically detailed in previous sections of this report, the following areas of Appendix G have been determined to be " Acceptable."
G1 Scope - The scope, content, and interface between Appendix G and other modules, as detailed in Section G1 were reviewed and found to provide a comprehensive and accurate program overview for Appendix G.
However, l
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specific evaluation by GPC of MTE_ for operations in modules 3A, 5, 7, 9A and 9B was either not covered or only generally mentioned,
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without information on actual MTE hardware inspection.
G2 Responsible Organizations - The description of organization and responsibilities for project activities as detailed in Section G.2 was reviewed and found to be accurate and thorough.
G3 Commitments and Implementation - The commitments as detailed in Section G3 were reviewed and found to be complete. With the exception of the deficiencies identified in section.3.c for commitments 2911.01-07, 4961.0, and 4962.0, the licensing commit-ments and implementing documents were determined to be in compliance with FSAR, Regulatory Guides, and applicable industry codes and standards.
G4 Program Description - Section G4 details the MTE programs imple-mented on site and also provides a description of the method used for procurement of calibration services from off site vendors.
These areas were reviewed, and with the exception of the NRC staff comments provided in section 3.d.(2)(b) of this report, were determined to be in accordance with requirements.
G5 Audits - The overview provided in section G5 represents an accurate and thorough presentation of GPC, and NRC audit and evaluation findings.
Also discussed are results from the licensee's self-initiated evaluation (SIE).
G6 Program Changes - Section G6 describes the various procedural changes which have been implemented during the course of construction activity.
The review of this area indicates that these changes are prudent and have' provided better guidance for MTE issue, calibration, control, and tracking.
Based upon the NRC staff evaluation the following areas have been deter-mined to be " Conditionally Acceptable."
G7 Verification of Project M&TE Control Program - The NRC staff review of Section G7 consisted of an overview of the licensee's evaluation, and a separate evaluation of selected " Critical Elements." In general, the review indicates that licensee's MTE programs have been effective and comply with project commitments in this area.
However, the NRC review resulted in the identification of a program deficiency with regard to the lack of activity logs or other usage records, and l
the failure to take corrective action to provide for appropriate usage records for Pullman Power Products, automatic welding machines.
This deficiency is discussed in detail in section 3.g.(2)(e) of this report and was documented by NRC inspection report 50-424/86-77, violation 424/86-77-01.
It will require additional licensee attention and NRC review prior to full acceptance of Appendix G.
In addition, unresolved item (UNR) 424/86-77-02 regarding a question concerning the overall MT&E program to ensure that project FSAR and i
other commitments are adequately implemented (including M&TE for both l
construction and operations support - construction acceptance tests, j
preoperational tests, startup and operations) requires further action.
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G8 Program Assessment - Section G8 is considered reasonable, pending further action to resolve the deficiency and unresolved item
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mentioned above and documented by NRC inspection report 50-424/86-77.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT REFERENCES i
Vogtle Electric Generating Plant, Readiness Review, Appendix G, Measuring and Test Equipment.
March 11, 1986, letter from D. O. Foster, Vice President, Vogtle Project, Georgia Power Company forwarding Appendix G for NRC evaluation.
March 31, 1986, letter from D. O. Foster forwarding corrections to Appendix G.
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NRC Inspection Report No. 50-424/86-38 covering inspections conducted on May 12-18 and June 2-6, 1986.
NRC Inspection Report No. 50-424/86-77 covering inspection conducted on August 4-8, 1986.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT TABLES 1.
Vogtle M&TE Critical Element Inspection Sample 2.
Pullman Automatic Welders
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READIRESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT TABLE 1 V0GTLE M&TE CRITICAL 2LEMENT INSPECTION SAMPLE Discipline Critical Element
, Identification Procedure Electricel/
Insulation Tester C-2084 M&TE-I-033
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1&C Digital Multimeter C-2089 M&TE-I-063 Hi-Pot Insulation J-3694 M&TE-I-082 Tester Hand Crimping Teol C-2i13 M&TE-I-087 Amprobe Volt / Amp /0hm C-4)e3 M&TE-I-093 Meter Mechanical Dial Calipers C-4469 M&TE-I-017 Pressure Guage C-1150 ESTE-I-018 Torque Wrench C-3208 Mbif-I-027 Micrometer C-4456 M&Ti-1 028 Hardness Tester C-3193 M&TE-I-CbI HVAC Flow Test Orifice Tube C-4230 C-CI-60 Gas Flow Meter C-4051 M&TE-I-090 Welding /
Mag. Particle Tester NDE-13 M&TE-I-023 NDE U. T. Machine NDE-24 M&TE-I-039 Dry Film Guage C-4689 M&TE-I-096
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Weld Current / Weld Time C-0824 M&TE-I-049 Analyzer l
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Bolt Tensioner C-1508 M&TE-I-025 Structural Sling Pyschrometer C-2252 C-CI-28 Slump Cone C-0901 C-CI-40 Windsor Probe Test System C-2408 M&TE-I-065 Reference Guage Blocks C-1151 Standard 2 Standards Micrometer Standard C-2140 Standard 15 Crimping Fixture C-3454 Standard 16 Welding Automatic Welder B-26-4 X-II Automatic Welder B-26-10 X-II Temperature Recorder B-13-9 X-II
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT TABLE 2 PULLMAN AUTOMATIC WELDERS Mo'el Comments Pullman ID Manufacturer d
B-26-1 Dimetrics/ Gold Track ETW-F B-26-2 Dimetrics/ Gold Track ETW-F B-26-3 Dimetrics/ Gold Track ETW-F B-26-4 Dimetrics/ Gold Track ETW-F (1)
B-26-5 Dimetrics/ Gold Track ETW-F 8-26-6 Dimetrics/ Gold Track ETW-F (2) DR 10802 B-26-7 Dimetrics/ Gold Track ETW-F (2) NCR 6214 B-26-8 Dimetrics/ Gold Track ETW-F (2) NCR 6213 B-26-9 Dimetrics/ Gold Track ETW-F B-26-10 Dimetrics/ Gold Track ETW-F (1)
B-26-11 Dimetrics/ Gold Track ETW-F B-26-12 Dimetrics/ Gold Track ETW-F B-26-13 Dimetrics/ Gold Track ETW-F N3TES (1) The initial NRC inspection sample included Pullman automatic welders B-26-4 and B-26-10.
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(2) Pullman Automatic welders B-26-6, B-26-7, and B-26-8 were found to be out-of-tolerance during calibration.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT LIST OF PERSONS CONTACTED Name Organization / Activity C. Gardner GPC/ Technical Support M. Googe GPC/ Construction E. Groover GPC/ Quality Assurance C. Hayes GPC/ Quality Assurance H. Kattegat GPC/ Mech. QC, M&TE G. McCarley GPC/ Construction R. McManus GPC/ Readiness Review T. Mitchell GPC/ Corporate QA Auditor R. Pinson GPC/ Construction, V.P.
P. Thomas GPC/ Mech. QC P. Kyner Bechtel/ Lead Auditor F. Marsh Bechtel/ Project Engineering D. Sanderfer Bechtel/ Readiness Review R. Sommerfield Bechtel/ Readiness Review R.'Mehghi Westinghouse /Elec. Technician L. Moiser Westinghouse / Engineering E. Owens Westinghouse / Engineering D. Walker Westinghouse / Engineering J. Baxley Pullman Power Products /M&TE V. Miller Pullman Power Products /QA T. Murray Pullman Power Products / Tool & Tage H. Tucker Pullman Power Products / Welding L. Barton Cleveland Consolidated / Quality Concern B. Skinner Ingalls/Mosher Steel /QC H. Schadel Walsh Construction / Engineering J. Pruitt NISC0/ Field QA/QC W. Crestsinger NISC0/ Lead Engineer H. Livermore NRC/ SRI-C J. Rogge NRC/ SRI-0 R. Schepans NRC/RI Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE APPENDIX G MEASURING AND TEST EQUIPMENT ACRONYMS BPS Bechtel Pcwer Services DCC Document Control Center FSAR Final Safety Analysis Report GPC Georgia Power Company IE NRC Office of Inspection and Enforcement M&TE Measuring and Test Equipment NBS National Bureau of Standards NCR Nonconformance Report NISCO Nuclear Installation Services Company NRC U.S. Nuclear Regulatory Commission FPP Pullman Power-Products QA Quality Assurance QSL Qualified Supplier List RRS Readiness Review Staff (GPC)
RRT Readiness Review Team (GPC)
RS Reference Standard SIE Self-Initiated Evaluation UNR Unresolved Item VEGP Vogtle Electric' Generating Plant VPPPM Vogtle Procurement Policy and Procedure Manual
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