ML20023E003

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IE Insp Rept 50-333/83-09 on 830401-30.Noncompliance Noted: Failure to Implement or Establish Adequate Measuring & Test Equipment Controls Properly
ML20023E003
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/17/1983
From: Doerflein L, Kister H, Linville J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20023D995 List:
References
50-333-83-09, 50-333-83-9, NUDOCS 8306060237
Download: ML20023E003 (14)


See also: IR 05000333/1983009

Text

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DCS Numbers

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50333-830408

50333-830412

50333-830414

Report No.

83-09

Docket No.

50-333

DPR-59

C

License No.

Priority

Category

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Licensee:

Power Authority of the State of New York

P. O. Box 41

Lycoming, New York

13093

Facility Name:

James A. FitzPatrick Nuclear Power Plant

Inspection At:

Scriba, New York

Inspection Conducted:

April 1-30,1983

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Inspectors:

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Senior Resident Inspector

'date

@J. C. Linville,

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dn /n

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L. T. Doerflei , Resident Inspector

' date

Approved by:

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H.' B. Kister> Chief, Reactor Projects Section 1C

date'

Inspection Summary:

Inspection on April 1-30, 1983 (Report No. 50-333/83-09)

Areas Inspected: Routine and reactive inspection during day and backshift

hours by two resident inspectors (173 hours0.002 days <br />0.0481 hours <br />2.86045e-4 weeks <br />6.58265e-5 months <br />) of licensee action on previous

inspection findings, licensee event report review, operational safety verification,

surveillance observations, maintenance observations, refueling preparations,

calibration, procurement, and review of periodic and special reports.

Results: No violations were observed in eight of nine areas inspected. One

violation was observed in one area (Failure to control measuring and test

equipment, paragraph 9).

Region I Form 12

(Rev. February 1982)

n306060237 830523

PDR ADOCK 05000333

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PDR

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DETAILS

1.

Persons Contacted

  • R. Baker, Technical Services Superintendent
  • R. Converse, Superintendent of Power
  • M. Cosgrove, Quality Assurance Superintendent
  • M. Curling, Training Superintendent
  • W. Fernendez, Maintenance Superintendent
  • H. Keith, Instrument and Control Superintendent
  • R. Liseno, Operations Superintendent
  • C. McNeill, Resident Manager
  • E. Mulcahey, Radiological & Environmental Services Superintendent

T. Teifke, Security & Safety Superintendent

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The inspectors also interviewed other licensee personnel during this

inspection including shift supervisors, administrative, operations,

health physics, security, instrument and control, maintenance and

contractor personnel.

  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings

(Closed) VIOLATION (333/82-06-04): This violation involved failure

to establish controls to ensure proper valve alignment during the startup

following the 1981-1982 Refueling / Modification outage. The inspector

reviewed the changes in F-0P-ES, Startup and shutdown Procedure, Revision

14 and F-ST-15H, Primary Containment Integrity, Manual Isolation Valves

Position Verification, Revision 4 to ensure that the breathing air and

service manual containment isolation valves are checked closed just prior

to startup and found them accaptable.

In addition, the inspector found

acceptable the changes to Operations Department Standing Order No. 18,

Equipment Status Control, Revision 2, which provide more specific

requirements for checking, recording and reviewing valve and breaker

positions during startups following outages and during normal plant

operations.

(Closed)

INSPECTOR FOLLOWUP ITEM (333/82-12-04): The licensee

relabelled all valves in the Emergency Service Water (ESW) System.

In addition, the licensee revised the valve lineup checklist and the

drawings in the ESW System Operating Procedure so that the actual valve

numbering is consistent with the valve checklist and drawings.

(Closed)

INSPECTOR FOLLOWUP ITEM (333/82-01-05): The inspector

reviewed the licensee's test and measurement equipment program.

Details

of this inspection are documented in paragraph 9 of this report. One

violation for failure to properly control test and measuring equipment

was identified. This followup item is closed for administrative purposes.

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(Closed)

INSPECTOR FOLLOWUP ITEMdCJ3/t3-04-05): The licensee has

reviewedLand approved changes to the'Che Spray, Standby Liquid Control .

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and Recirculation Pump Trip survsfilance tests t6' correct the deficiencies

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identified during the inspection. "

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3.

Licensee Event Report (LER) Review

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The' inspector reviewed LER's to verify that the details 'of the events

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were clearly reported.s .The ' inspector determined that reporting re-

quirements haf beert met, the report was adequate to assess the event,

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the cause appe6re O ccurate and was supported by details, corrective

actionsappearedappropr$tetocorrectthecause,theformwascomplete

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and generic applicability to cther plants was not in question.

LER's 83-015*,83-016, and 83-017 were reviewed. "

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  • LER's selected for onsite followup.

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LER 83-015 reported that the B Reactor Recirculation'Bamp hst Switch

was found in the Test Mode D position rather than th'e yorwilosition

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during the perfonnance of surveillance test F-ST/F, thus reducing

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the number of channels which can produce an Anticipitof Transient

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Without Scram trip of B Reactor Recirculation $ tor Genifatdr set

field breaker trip from two channels to one charnel. 'M noted ir

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paragraph 5, the inspector observid the performance of F-S1 1D b0t

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did not specifically note that the switch was cut of position. The

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inspector reviewed the Generar.' Electric drawings to verify the switch

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functioned as reported by the licensee. Thei inspecs.or agree's that_

tt'e switch was out of position due to personhel error and will review ,

the revisions to F-ST-10 and F-ISP-3-1 when they are received to ensure

that a second verification of the switch position is now required

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(33?/63-09-01).

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4.

Operational Sciety Verification

a.

Control Room Observations

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Daily, the inspectors verified selected plant parameters and

equipment availanility to ensure compliance with limiting conditions

for operation of the plant Technical Specifications. Selected lit

annunciators were discussed with control room operators to verify

that the reasons for them were understood and corrective action,

if required, was being taken. The inspector observed shift turn-

overs biweekly to ensure proper control room and shift manning.

The inspectors directly observed routine power operations to ensure

adherence to approved procedures.

b.

Shift Logs and Operating Records

Selected shift logs and operating records were reviewed to obtain

information on plant problems and operations, detect changes and

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trends in performance, detect possible conflicts with Technical

Specifications or regulatory requirements, detennine that records

are being maintained and reviewed as required, and assess the

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effe.tiveness of the communications provided by the logs.

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Plant Tours,

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During the inspection period, the inspectors made observations

and conducted. tours of the plant. During the plant tours, the

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sinspectors conducted a visual inspection of selected piping

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!batween containment and the isolation valves for leakage or

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leakage paths. This included verification that manual valves

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were shut, capped and locked when required and that motor

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operated valves were not mechanically blocked. The inspectors

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-also checked fire protection, housekeeping /cleanlinets, radiation

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protection, and physical security conditions to ensure compliance

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_with plant procedures and regulatory requirements.

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d. ' Tagout Verification

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The inspectors verified that the following safety-related

protective tagout records (PTR's) were proper by observing the

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positions of breakers, switches and/or valves.

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PTR 830289 on the High Pressure Ceolant Injection System

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PTR 830266 on the Diesel Fire Pump

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PTR 830305 on the A Standby Gas Treatment Train

e.

Emergency System Operability

The inspectors verified operability of the following systems by

ensuring that each accessible valve in the primary flow path was

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in the correct position, by confirming that power supplies and

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breakers were properly aligned for components that must activate

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upon an initiation signal, and by visual inspection of the major

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components for leakage and other conditions which might prevent

fulfillment of their functionti requirements.

Standby Liquid Control System

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Emergency Service Water System

Reactor Core Isolation Cooling System

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125V DC Power System

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No violations were observed.

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5.

Surveillance Observations

a.

The inspector observed portions of the surveillance procedures

listed below to verify that the test instrumentation was properly

calibrated, approved procedures were used, the work was performed

by qualified personnel, limiting conditions for operation were

met, and the system was correctly restored following the testing:

F-ST-lD, MSIV's, Main Steam Line Drain Valves and Reactor

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Water Sample Valves Logic Functional Test, Revision 8, dated

May 19, 1982, performed on April 8,1983.

F-ST-1L, Main Turbine Control Valve Instrument Channel and

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Valve Operability Check, Revision 10, dated March 9,1983,

performed on April 1, 1983.

F-ST-76C, Diesel Fire Pump Operational Check, Revision 4,

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dated January 12, 1983, perfonned on April 8,1983.

F-ISP-64-1, Main Steam Line (MSL) Radiation Monitor Instrument

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Calibration, Revision 11, dated August 27, 1982, performed

on A MSL Radiation Monitor on April 20, 1983.

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NCS-375, In Place Testing of HEPA Filters and Iodine Adsorbers,

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Revision 4, dated May 15, 1982, performed on April 26-29, 1983.

b.

On April 26, 1983, a Nuclear Containment System (NCS) contractor

performed a freon test on the A train of the Stendby Gas Treatment

System (SGTS) as required by Technical Specification (TS) 4.7.B.l.b(2). The results of this test, which was performed using

a prototype Freon R-11 monitor designed by NCS and identified as

model LMP-10, indicated gross failure of the A SGTS.

Based on the

results of this test, the licensee declared A SGTS inoperable per

TS 3.7.B.2.a at 5:30 p.m. on April 26, 1983 and decided to replace

the charcoal in A SGTS and retest it the next day. While the

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charcoal replacement was in progress, the A train of the Control

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Room Emergency Ventilation (CREV) system also grossly failed the

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freon test while the Technical Support Center filter train passed

the test with the same test equipment. When the A train of the

SGTS failed the test again, after the charcoal had been replaced,

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the contractor and the licensee concluded that the new equipment

was too sensitive to provide meaningful test data because of the

high background in the older filter trains and the contractor

redid the tast with the less sensitive Freon Leak Tester identified

as Halocarbon Monitor Model 1000, which had been used by NCS to

perfonn this freon test on the charcoal filter trains since the

initial operation of the facility.

Another proven monitor identi-

fied as SBA N500 Portable Gas Chromatograph serial 6372 used on B

SGTS and both CREV filter trains yielded satisfactory results.

The contractor took a sample of the charcoal removed from the A

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SGTS train and returned it to the NCS laboratory for a methyl

iodide adsorption analysis to verify the conclusion that the

test failure was caused by the oversensitivity of the prototype

Freon R-ll monitor and not by a reduction in charcoal filter

removal efficiency. The inspector will review the test and

analysis reports when they are received from NCS (333/83-09-02).

c.

The inspector also witnessed all aspects of the following

surveillance test to verify that the surveillance procedure

confonned to technical specification requirements and had been

properly approved, limiting conditions for operation for removing

equipment from service were met, testing was performed by qualified

personnel, test results met technical specification requirements,

the surveillance test documentation was reviewed, and equipment

was properly restored to service following the test.

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F-ST-9B, EDG Full Load Test and ESW Pump Operability Test

(ISI), Revision 17, dated November 4,1982, performed on

April 26,1983.

6.

Maintenance Observations

a.

The inspectors observed portions of variou: safety-related

maintenance activities to determine that redundant components

were operable, these activities did not violate the limiting

conditions for operation, required administrative approvals

and tagouts were obtained prior to initiating the work, approved

procedures were used or the activity was within the " skills of

the trade," appropriate radiological controls were properly

implemented, ignition / fire prevention controls were properly

implemented, and equipment was properly tested prior to

returning it to service,

b.

During this inspection period, the following activities were

observed:

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WR 76/24461 on repair of cooling water leak in the Diesel

Fire Pump gear box

WR 71/24463 on replacement of B Station Battery Cells

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WR 23/19467 on repacking a High Pressure Coolant Injection

(HPCI) System vent valve

WR 23/24490 on the repair of HPCI system level switch 23LS90

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WR 17/24482 on the troubleshooting of A Main Steam Line

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Radiation Monitor

WR 01-125/24833 on the replacerrent of A Standby Gas

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Treatment train charcoal

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c.

On April 2,1983, ground indication was received on B station

battery due to leaking cells. Since the battery was able to

meet the acceptance criteria of the routine surveillance tests,

the licensee did not declare it inoperable. However, after

careful review of IE Information Notice 83-13 regarding the

seismic qualification of cracked battery cells, the licensee

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declared B station battery inoperable at 3:00 p.m. on April 8,

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1983. Subsequently, the licensee determined that part of the

- ground indication was caused by a ground on High Pressure

Coolant Injection System level switch 23LS90. The licensee

isolated this ground and implemented periodic manual blowdowns

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of the steam line to compensate for the failed level switch.

Detailed inspection of the bottom of the cells in the station

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batteries revealed that 4 cells in B battery were leaking and

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about one third of the 60 cells in each battery exhibited some

cracking. To restore the B battery to an operable status, the

licensee decided to remove the four leaking Gould NCX2250 cells

and replaced two of them with cells fror, the A battery leaving

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both batteries with 58 cells, two short of the normal 60. The

blank spaces in the racks were to be filled by wooden spacers.

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This plan was documented and justified in Nuclear Safety

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Evaluation JAF-SE-83-009. WorkRequest(WR) 71/24463 and

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Temporary Procedure (TP) 64 were issued to carry out the plan

which was reviewed by the Plant Operations Review Committee

in meeting 83-018 on April 6, 1983.

Although entry into a

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twenty-four hour action statement normally requires a decla-

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ration of an Unusual Event under the requirements of the

licensee's Emergency Plan Notification Procedures, the licensee

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did not consider it necessary in this case because the entry

was deliberate to effect a repair. The Senior Resident

Inspector and his Section Chief concurred with the licensee's

assessment. The licensee did notify NRC headquarters of the

situation on the Emergency Notification System on the morning

of April 7,1983 as required by 10 CFR 50.72. The plan was

carried out without incident and the ground on B station

battery cleared. The licensee's long range plan is to purchase

sufficient cells to produce one completely new station battery

and one station battery without any cracked cells during the

refueling outage scheduled to start in June 1983. The inspector

will review this modification by the completion of the outage

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in August 1983 (333/83-09-03).

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7.

Procurement

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The inspeGor conducted a detailed review of the licensee's pro-

curement program including the area of receipt, storage and handling

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of safety-related parts and equipment. The inspection included review

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of 14 Work Activity Control Procedures, Plant Standing Orders and

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Quality Assurance Procedures (QAP's) associated with procurement

activities; toursof storage areas including the warehouse, butler

building, and store room; observation of a receipt inspection; and

verification of the adequacy of procurement documents for 5 selected

items in storage and for the services of the site maintenance

contractor.

Procedures were reviewed for conformance to the re-

quirements of ANSI 45.2.2-1972, Packaging, Shipping, Receiving,

Storage and Handling of Items for Nuclear Power Plants, and ANSI

45.2.13-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>45.2.13-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Quality Assurance Requirements For Control of Pro-

curement of Items and Services For Nuclear Power Plants.

Although the licensee had a qualified vendor list, the inspector

found that it had not been revised for several years and was not

controlled in any way. The licensee was aware of this deficiency

and showed the inspector a partial draft site Quality Assurance

Instruction (QAI) for Purchasing Control which was being developed

to provide detailed guidance for implementation of QAP 4.1, Pro-

curement Document Review, requirements. This QAI will provide

specifics on methods of vendor qualification, control of the

qualified vendor list, a QA requirement checklist to be attached

to purchase requisitions, etc. The inspector will review this

QAI when it is issued (333/83-09-04).

While observing the receipt inspection of reactor recirculation

system piping, the inspector and the Quality Control inspector

noted that Purchase Order P0 83/2565 and General Electric Speci-

fication GEP 1-2-151 called for 316K stainless steel pipe but that

the pipe was marked only 316. The licensee requested additional

Quality Control documentation from General Electric to resolve

this discrepancy. This item is unresolved pending inspector

review of this documentation and the completed documentation of

the receipt inspection (333/83-09-05).

During the tours, the inspector found the warehouse and butler

building in a general state of disarray with access to stored

items on shelves restricted by other items stored in aisles. The

licensee stated that this condition was temporary since a complete

inventory was scheduled in the near future as the first step in

getting better control of storage facilities. Subsequent steps

will include rearrangement of stored items and a reduction in

inventory of many unnecessary and unused items. This will be

followed by the development and implementation of a preventive

maintenance program for stored items which was documented as being

nonexistent in previous open item 333/82-28-06.

When the inspector questioned the licensee about control of limited

shelf life items, the licensee indicated that the only known items

of that type were Control Rod Drive Hydraulic System 0 rings and

gaskets, the expiration dates of which had been revised per a

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General Electric letter dated October 6,1982. The inspector

verified that the markings on the packages of the items in stock

had been revised according to the letter. At the exit meeting,

the licensee stated that he plans to implement a computerized

inventory system which will include provisions for controlling

limited shelf life items.

8.

Preparation for Refueling

The inspector reviewed procedures RAP 7.1.1, Receiving and Handling

of Unirradiated Fuel, Revision 3, dated March 9,1983 and RAP 7.1.2,

Inspecting and Channeling of Unirradiated Fuel, Revision 4, dated

March 9,1983 to verify that the licensee had technically adequate

and approved procedures covering the receipt, inspection and storage

of new fuel.

In addition, the inspector observed the inspection and

storage of six new fuel bundles to verify that it was performed in

accordance with these procedures. No deficiencies with the new fuel

were found during the fuel inspection by the licensee.

No violations were observed.

9.

Calibration and Control of Test Equipment

The inspector reviewed the licensee's program for the control of

measuring and test equipment implemented by Administrative Procedure

(AP) 4.2, Control of Measuring and Test Equipment, Revision 2, dated

June 13, 1979 to verify the following:

An equipment inventory list has been prepared which identifies

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all measuring and test equipment which will be used on safety-

related systems or components and the calibration frequency for

each piece of equipment;

Maintenance of calibration records identifying standards used

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which have traceability to the National Bureau of Standards or

other testing organizations;

Approved calibration procedures are available for each piece

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of equipment calibrated on site;

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Formal requirements exist for marking the latest calibration

date on each piece of equipment;

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A written requirement exists which prohibits the use of

measuring and test equipment which has not been calibrated

within the prescribed frequency; and

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Controls have been established to evaluate and document the

acceptability of items previously measured or tested when a

piece of equipment is found to be out of calibration.

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During this program review, the inspector identified the following:

The calibration records for a three eighths inch Snap-On 0-100

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foot-pound torque wrench, serial number (S/N) C25556, had out

of tolerance values at 60 and 100 foot-pounds when it was calibrated

on January 27, 1983. These values were not identified as being out

of tolerance by the licensee and the torque wrench was available

for use. No log card to record usage was attached to the torque

wrench so it was impossible to determine if the torque wrench had

been used.

The calibration records for a three quarter inch Sweeney 0-400

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foot-pound drive beam torque wrench, S/N M-117, had out of tolerance

values at 80 and 320 foot-pounds when it was calibrated on

September 11, 1981. These values were not identified as being

out of tolerance by the licensee and the torque wrench was available

for use, however, the log card indicated that it had not been used.

No citr cat calibration records were available for two Snap-On

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torque wrenches S/N's BB24182 and 1144, although the log cards

indicated they had been calibrated on January 19 and 21, 1983

respectively.

In addition, the licensee was unable to locate

torque wrench S/N 1144 during an inventory on April 20, 1983.

Two torque wrenches, a Snap-On torque wrench, S/N AA01814, and a

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Williams torque wrench, S/N M-56, were found defective during

recalibration on January 27, 1983, and no evaluation was done to

determine the acceptability of items previously measured with

these torque wrenches.

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Three 0-600 foot-pound Williams torque wrenches, S/N's M-60,

A06254 and 180585A, were calibrated on equipment capable of

measuring only up to 500 foot-pounds. There was no identification

on these torque wrenches that they had only been calibrated up to

500 foot-pounds.

No current calibration records were available for six ammeters

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and one megohmmeter, listed below, even though these instruments

all had current calibration stickers attached and were in use.

Instrument

S/N

Manufacturer

Date Calibrated

Megohmeter

E-571

Biddle

December 17, 1982

Ameter

E-530

Westinghouse

December 23, 1982

Anuneter

E-550

Weston

February 25, 1983

Ammeter

E-561

Amprobe

October 15, 1982

Ameter

E-547

Ametek

November 23, 1982

Ammeter

E-579

Weston

February 22, 1983

Ammeter

E-549

Weston

December 17, 1982

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No evaluations were done and/or documented to determine the

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acceptability of items previously measured or tested with the

following equipment which was found to be out of calibration.

Instrument

S/N

Manufacturer

Date Calibrated

Ameter

E-697

Pacer

October 7,1982

Ammeter

E-698

Pacer

November 19, 1981

Multimeter

E-503

Fluke

October 5,1982

Multimeter

E-695

Fluke

September 21, 1982

Multimeter

E-693

Fluke

October 5,1982

The inspector informed the licensee that the above examples collectively

constitute a failure to properly implement or establish adequate controls

for measuring and test equipment and is a violation of 10 CFR 50, Appendix

B, Criterion XII, ANSI N45.2-1971, Quality Assurance Program Requirements

for Nuclear Power Plants, and Administrative Procedure 4.2 which require

that tools, gages, instruments and other measuring and testing devices

used in activities affecting quality are properly controlled, calibrated

and adjusted to maintain accuracy within necessary limits (333/83-09-06).

10.

Review of Periodic and Special Reports

Upon receipt, the inspector reviewed periodic and special reports. The

review included the following:

Inclusion of information required by the

NRC; test results and/or supporting information consistent with design

predictions and perfonnance specifications; planned corrective action

for resolution of problems, and reportability and validity of report

information. The following periodic report was reviewed:

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March 1983 Operating Status Report dated April 8,1983

No violations were observed.

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Unresolved Items

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Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

deviations. The unresolved item identified during this inspection is

discussed in paragraph 7.

12.

Exit Interview

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At periodic intervals during the course of this inspection, meetings

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were held with senior facility management to discuss inspection scope

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and findings. On April 29, 1983, the inspectors met with licensee

representatives (denoted in paragraph 1) and sumarized the scope and

findings of the inspection as they are described in this report.

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Transaction Type

M-3

NRC:1 fonn 6 Rev. Oct 80 (Side 1)

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OUTSTANDil1G ITEllS FILE

M0dIIY

SINr1E DOCKET EHIRY f0iill

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