ML20127G682
| ML20127G682 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/05/1985 |
| From: | Runyan M, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127G652 | List: |
| References | |
| 50-395-85-11, NUDOCS 8505210115 | |
| Download: ML20127G682 (12) | |
See also: IR 05000395/1985011
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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Report No.: 50-395/85-11
. Licensee: South Carolina Electric.and Gas Company
Columbia, SC 29218
Docket No.: 50-395
License No.: NPF-12
Facility Name: ' Summer
Inspection Conducted: March 4-8, 1985
Inspector:
Ikhw
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M. F. Runyah
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Date Signed
Accompanying Personnel:
L. R. Moore, Region II
Approved by:
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C. M. Upright,fSfctioyf hief
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j atjfSigned
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Division of Rerctor Mfety
SUMMARY
Scope: This routine, unannounced inspection entailed 72 inspector-hours at the-
site during normal duty hours in. the areas of licensee action on previous
enforcement matters, surveillance testing and calibration control program,
measuring and test equipment program, and licensee action on previously
-identified inspection items.
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'Results: One violation was identified. . Failure to Establish Measures to Assure
Prompt Evaluations of Out-of-Calibration Measuring and Test Equipment, paragraph 6.a.
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6505210115 850411
ADOCK 05000395
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REPORT DETAILS
.1.
. Persons Contacted
Licensee Employees
B. Brazell, Mechanical Calibration Laboratory Maintenance Technician
- J. Connelly, Deputy Director, Operations and Maintenance
- B. Crowley, Group Manager,~. Technical and Support Services
- R. Fowlkes, Regulatory Compliance
L. Fulmer, Supervisor, Maintenance
- S.' Hunt, Associate Manager, Surveillance Services
- M. .Irwin, Nuclear License Specialist
- A..Koon, Associate Manager,-Regulatory Compliance
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-- C. McKinney, Regulatory Compliance
- J. Parks,. Supervisor, RegulatoryfSupport
J. Proper, QA Supervisor of Operations
- G. Putt, Manager, Scheduling and Materials
- M. Quinton, Manager, Maintenance Services
H. Sherriff, Maintenance Supervisor, I&C
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G'. Soult, Associate Manager, Maintenance
P. Turbev111e, Mechanical Supervisor
'J.;Turkett, Engineer, Maintenance
G. Walker, Plant Supervisor, I&C
- K. Woodward, Manager,. Operations
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.0ther . licensee . employees contacted included technicians -and office
personnel.
NRC Resident Inspectors
- C.'.Hehl, Senior Resident Inspector
- Attended exit interview
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2.
Exit Interview ~
The . inspection scope and findings were summarized on March 8,1985, with
those persons indicated in paragraph 1 above. The inspector described the
rareas inspected and discussed in ~ detail the inspection- findings listed
below. -The licensee did not identify as proprietary any. of the materials
provided to or reviewed by the inspector during this inspection.
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Violation:
Failure to Establish Measures to Assure Prompt Evaluations
of Out-of-Calibration Measuring and Test Equipment, paragraph 6.a.
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Unresolved " Item: Accountability of Out-of-Calibration Evaluations in
the Mechanical Maintenance Calibration Laboratory, paragraph 6.b.
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Inspector Followup. Item: . Updating of Surveillance Test Master
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-Procedure, paragraph 5.
Inspector-Followup Item: . Verification of Lab' Temperature for Calibra-
tion of Site Standard Weights, paragraph 6.c.
3.
Licensee Action on Previous Enforcement Matters (92702)
a.
(Closed)- Severity Level IV Violation 395/83-08-02: Failure of-Audited
Organization to Provide Corrective Action' Dates for Audit Findings
The licensee response dated May_ 11, 1983, was considered acceptable by
Region II. This item was reviewed during inspection 84-18, July 9-13,
1984.
It was determined at that time that audited organizations were
still not providing corrective action schedules as required by ANSI
N45.2.12Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.12" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. This was identified as a violation ati the exit interview,
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but was later changed to Unresolved Item 84-18-01, when :further
'information was provided indicating that corrective action was 'in
progress. The _ licensee stated that Maintenance Directive 16, Response'
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- and Escalation of Surveillance / Audit Findings, was being revised to
include measures to ensure that audit responses would be timely and
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provide corrective action schedules.
The inspector reviewed the latest revision to Maintenance Directive 16,
(Revision 3,
8/6/84) which was generated. in = response to the NRC
findings. This revision amended Section 5.1, Need for Escalation, to
include as criteria for escalation both the : failure to respond by the
requested date and the failure to provide a schedule for corrective
action if not completed. by the initial response date. The inspector
' reviewed selected Type II audits issued after the above revision was
made effective.
Where : corrective action was not completed by the
required response date, the audited organizations had complied with the
requirement to provide a schedule of corrective action. The-inspector
expressed a concern that many of.the initial responses were approximately
three days late.
The licensee explained that since the required
response date was always a Friday, responses'were often held up in the
intrastation - mail system until Monday.
The inspector concluded that
the licensee had corrected the previous problem and developed corrective
action to preclude recurrence of similar problems. Corrective actions
stated in the licensee response have been implemented,
b.
-(Closed) Unresolved Item 395/84-18-01:
Management Directive 16
Inadequacies
This unresolved item is - closed based on the action described in -
paragraph 3.a.
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'4.
Unresolved Items
An Unresolved Item is a matter about.which more information is required-to
determine whether it is acceptable or may involve a violation or deviation,
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AL new unresolved . item identified during this inspection is discussed in
- paragraph 6.b.
.5.
' Surveillance Testing and Calibration Control (61725)
References:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plant and Fuel Reprocessing Plants
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Quality Assurance Program
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, Requirements (Operations), Revision 2
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(c) ANSI N18.7-1976, Administ'rative Controls and . Quality
Assurance for the Operational Phase of ' Nuclear- Power
Plants.
(d) Technical Specifications, Section 4
- The . inspector reviewed the licensee surveillance testing and ' calibration
control program required by references (a) through (d)~ to verify that the
program had been established in accordance with regulatory requirements,
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. industry guides and standards, and Technical _ Specifications. The following-
c'riteria were used~during this review to determine the overall acceptability
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of the established program:
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. A master schedule for' surveillance testing and calibration has been -
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established which includes frequency, responsibilities for performance,
and testing status.
The master schedule has been updated to reflect-Technical Specification
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or license revisions.
Responsibilities have been assigned to maintain the master: schedule
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Lup-to-date.
Requirements have been established for conducting surveillance 1 testing
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in accordance with approved procedures ~ which include appropriate
. acceptance criteria.
Formal . methods and responsibilities have been defined for review and
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evaluation of surveillance test data, including procedures for
reporting deficiencies, failures, and malfunctions.
Responsibilities have' been assigned for assuring that required
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schedules for surveillance are satisfied.
The inspector also verified that similar controls have been established for
- calibration of instruments .not specifically identified in the Technical
Specifications. -The documents ' listed below were reviewed to verify that
these . criteria had been -incorporated into the surveillance testing and
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' calibration control program:
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QAP, Section:12.0, Nonconformance and Corrective Action Control,
Revision 12
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GTP-701, Surveillance Test Master, Revision 3
GTP-702, Surveillance Activities Tracking and Triggering, Revision 3
SAP-134, Control of-Station Surveillance Test Activities, Revision 2
SAP-139,- Procedure Development,
Review, Approval, and Control,
Revision 6
SAP-206,. Technical Specification Cross-Reference Computer Program,
Revision 0
SAP-301, . Implementation of ' Maintenance Work Requests, Preventive
Maintenance and Surveillance Test Task Sheets, and Shop Work Orders,
Revision 1
SAP-605, Application of CHAMPS at V.C. Summer, Revision 0
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SAP-620, Conduct of Scheduling and Outage Management, Revision 0
GTP-301, General Procedure for Inservice Testing of Pumps, Revision 0
GTP-302, General Procedure for Inservice Testing of Valves, Revision 0
The inspector reviewed the following onsite QA surveillance reports to
. ascertain problems identified by the licensee in this area and the status of
measures taken to correct deficiencies:
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II-21-84-Q, Surveillance Test and Operating License Conditions,
8/15/84
04-MAG-83-E, Off-Normal Occurrence Report No.83-020, 5/24/83
02-RGS-84-Q, STP 105.007, 3/15/84
04-CDT-84-Q, V. C. Summer TS Surveillance Requirement 4.8.4.2.b.,
4/19/84
03-JRN-84-P, ISI Activities by NES, 10/24/84
02-AEC-85-Q, STP-105.007, Accumulator Isolation Valve Verification
Test, 2/19/85
The licensee appeared to . have taken positive action on the findings
identified in these surveillances.
The master surveillance test schedule is composed of two elements. One is a
handwritten quarterly schedule which segregates tests by frequency and
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indicates last performance date, mode requirements, next due date, and the
extension allowed by the Technical-Specifications. The_other is a computer
data base, termed CHAMPS, which lists essentially the same information. The
handwritten schedule is used to satisfy the requirement to maintain a master
surveillance schedule. The inspector checked for consistency between the
handwritten schedule and CHAMPS and also verified that .the tests listed in
GTP-701, Surveillance Test Master, were scheduled to be performed. Although
it appeared that all required surveillance tests were being accomplished on
time, a discrepancy was discovered with GTP-701 and is identified as an
inspector followup item at the end of this paragraph.
The inspector selected the following Technical Specification surveillance
test requirements for a detailed review of program implementation:
STP 106.001, Moveable Rod Insertion Test, 2/1/85
STP 125.007, D/G A Operability Test, 2/3/85
For the above, completed work packages were reviewed to verify that data had
been recorded, had met acceptance criteria, and had been approved.
'he following inservice test data packages were reviewed for completeness
and acceptability.
STP 120.001, Emergency Feedwater Pump A Test, 2/10/85
STP 104.005, Boric Acid Transfer Pump A Test, 12/18/84
STP 115.007, Safety Injection Valve Leak Test, 9/21/84
STP 105.001, Charging Pump C Test, 12/6/84
Considering the above review, the licensee appeared to have fully
' implemented its inservice testing program for pumps and valves as required
by ASME Code Section XI, Subsections IWP and IWV. The licensee's updated
program, Revision 2, was submitted on May 18, 1983, and is pending approval
by the Division of Licensing, NRC. The inspector also reviewed instrument
data associated with the above tests to verify implementation of calibration
requirements established for components associated with safety-related
systems or functions not specified in the Technical Specifications as
requiring calibration. The pressure and temperature gauges used to verify
acceptance of the above tests were included in a formal calibration program
and calibration due dates were recorded on the work packages.
The inspector reviewed the history of Technical Specification amendments and
selected for review those which had a direct impact on the surveillance test
program.
Amendment 34, 11/30/84, allows installation of a P-9 interlock which
would prevent a direct reactor trip following a turbine trip at or
below 50% reactor power.
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Amendment 25, 7/2/84, adds surveillance requirement for a channel check
to be performed at least once per twelve hours.
Amendment 21, 2/3/84, transfers certain surveillance requirements from
the Service Water System to the Reactor Building Cooling Water System.
The inspector verified that the revisions to the surveillance test program
' required by the above amendments had been accomplished.
Within this area, one inspector followup item was identified.
Control of Station Surveillance Test Activities, Revision 2, requires that
GPT-701, Surveillance Test Master, be revised every .92 days as required.
"As required" means the revision is necessary only if charges have occurred
within the period. The inspector discovered that the surveillance require-
ments associated with the P-9 interlock as generated by Technical Specifica-
tion. Amendment 34, 11/30/84, were not included in GTP-701.
The latest
revision of GTP-701 was October 12, 1984, and therefore should have been
-revised by January 12, 1985.
The licensee provided - evidence that the
discrepancy had been identified by a recent QA audit, II-4-85-J, 2/28/85.
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The recommendation of this audit is to " revise GTP-701 to reflect current
surveillance requirements and devise a tracking method by which to
incorporate changes within the 92 day requirement". The commitment date to
- QA for corrective action is March 28, 1985. Until GTP-701 is revised and
methods are established to maintain it current, this is identified as
Inspector Followup Item 395/85-11-03, Updating of Surveillance Test Master
Procedure.
6.
Measuring and Test Equipment Program (61724)
Refe'ences:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
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Nuclear Power Plants and Fuel Reprocessing Plants
Quality Assurance Program
Requirements (Operations), Revision 2
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance of the Operational Phase of Nuclear Power
Plants
(d) Regulatory Guide 1.30, Quality Assurance Requirements
for the Installation, Inspection, and Testing of
Instrumentation and Electric Equipment, August 11, 1972
(e) ANSI
N45.2.4-1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.4-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
IEEE
Standard,
Installation,
Inspection, and Testing Requirements for Instrumentation
and Electric Equipment During the Construction of
Nuclear Power Generating Stations
The inspector reviewed the licensee measuring and test equipment (M&TE)
program required by references (a) through (e) to verify that the program
had been established in accordance with regulatory requirements and industry
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guides .and standards. The following criteria were used during this review
to determine the overall acceptability of the established program:
Criteria and responsibility for assigning calibration frequency have
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been established.
An equipment inventory list identifies all M&TE used on safety-related
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components, the calibration frequency and standard for each piece of
equipment, and the calibration procedure.
Formal requirements exist for marking the latest calibration date on
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each piece of equipment.
The- system assures that each piece of equipment is calibrated on or
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before the date required.
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Written requirements prohibit the use of M&TE which has not been
calibrated within the prescribed frequency.
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When M&TE is found out of calibration, controls require documented
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evaluations to determine'the cause of the out-of-calibration condition
and the acceptability of items previously tested.
A formal system assures that new M&TE will be added to the inventory
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list and calibrated prior to use.
The documents listed below were reviewed to verify that these criteria had
been incorporated into the M&TE program:
'SCE&G Topical QA Report, Section 17.2.12, Control of Measuring and Test
Equipment, Amendment 29.
QAP, Section 10, Measuring and Test Equipment, Revision 9
SAP-141, Control and Calibration of Measuring and Test Equipment,
Revision 2
SAP-605, Application of CHAMPS at V. C. Summer, Revision 0
The inspector toured the I&C shop toolroom and calibration facility. The
calibration of M&TE was supported by individual calibration procedures. The
temperature and humidity of the laboratory were monitored on a strip chart
recorder and recorded on calibration data sheets.
The inspector obtained a master equipment index and selected the following
tools for a detailed assessment of equipment accountability.
System ID
Description
FS1060
DC Power Supply
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FS1116'
0-3000# Test Gauge
FS1158
Mercury Thermometers
FS1643
Fluke 8600A Digital Multimeter
FS1893
0-400# Heise Gauge
The above M&TE were observed to be properly stored, easily retrievable, and
marked with calibration due dates consistent with the master equipment
!ndex.
The licensee is required to evaluate the effect out-of-calibration M&TE has
on previous tests performed with this equipment. The inspector reviewed the
following defective precision instrument reports (DPIR) in the I&C shop to
ensure that this reouirement has been met:
DPIR-465, 1/30/85, FS-1957, Dana Model 2000A Danameter
DPIR-439, 12/25/84, FS-2351, Ashcroft Test Gauge
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DPIR-430, 12/20/84, FS-2488, Ashcroft Test Gauge
DPIR-412,11/24/84, .FS-2310, Fluke 8600A Digital Multimeter
The above reports appeared to have adequately analyzed the safety.
significance of the out-of-calibration M&TE.
The inspector toured the mechanical maintenance shop toolroom and calibra-
tion facility. The following procedures were reviewed:
MMP-285.001, Control, Storage and Issue of Calibrated Mechanical
Equipment, Revision 3
MMP-285.002, Calibration of Precision Mechanical Measuring Tools,
Revision 4
MMP-285.003, Calibration of Torque Wrenches, Revision 4
MMP-285.005, Calibration of Torque Transducers, Amplifiers, and
Analyzers, Revision 1
MMP-285.006, Calibration of Site Standard Weights, Revision 1
~MMP-285.007, Calibration of Spring, Beam, and Balance Scales,
Revision 1
' The inspector determined that, with the exception of the site standard
weights calibration, there were no procedural requirements for temperature
control in the mechanical calibration facility. Most calibration procedures
simply required a two-hour temperature stabilization period.
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. stated l that the existing heating and cooling system L in the laboratory.
maintained temperature in a range consistent with good engineering practice.
A search of -standards and reference documents did not' yield 'a recommended -
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temperature range. In the absence of specific guidelines, the licensee will
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' consider. the technical basis' and' establish overall._ upper and lower
temperature limits for all calibration activities.
The inspector obtained a master tool .index and- selected the following tools -
to assess ~overall_ control and accountability.
In addition, the selected .
' tools'either-weregor had been uncalibrated beyond the calibration due date
as-indicated on the master index.
MDI-004'
Dial indicator
MOI-105
Dial Indicator
MDI-106
Dial Indicator
MDM-001
Depth Micrometer
=MDM-002
Depth Micrometer
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MOM-010
Outside Micrometer
MOM-102
Outside Micrometer
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-MTE-004
Mechanical Test Equipment
MTE-010
Mechanical Test Equipment
MTW-004
Torque Wrench
MTW-012.
Torque Wrench
MTW-014
Torque Wrench
MTW-026
Torque Wrench
MTW-057
Torque ~ Wrench
MVC-001
Vernier Calipers
MVC-016
Vernier Calipers
-Equipment history files were checked to determine whether beyond-calibration
tools -had L been used in the plant.
Based on this review, the equipment
management system apparently ensured that M&TE was not used after the -
calibration period had lapsed. The inspector selected several of the above
tools for a check fof storage procedures and calibration stickers. Though
' equipment was properly stored and segregated as required by procedure and
calibration stickers appeared uniformly accurate, the master list or other
controls did not differentiate tool location between the clean toolroom and
the hot. toolroom. Laboratory personnel indicated that despite the lack of a.
.real-time location -documentation system, tool location could be determined
'from the' equipment check-out log or, if not checked out, from a quick search.
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of the storage areas in both locations.
The ' inspector verified that this
' level of control was provided.
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-Within this : area one violation, one unresolved item, and one inspector
followup item were identified and are discussed in the following paragraphs,
a.
Failure to Establish Measures to Assure Prompt Evaluations of Out-of-
Calibration Measuring and Test Equipment
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-The inspector reviewed SAP-141, Control and Calibration of Measuring
and Test Equipment, Revision 2.
This procedure requires evaluations to
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determine the effect out-of-calibration M&TE has on previous tests
performed with such equipment. However, no time limit is specified for
this evaluation.
The inspector reviewed the defective precision
instrument report (DPIR) log in the I&C shop to determine whether this
-lack of procedural control resulted in lengthy delays in the completion
of these evaluations. The inspector chose a block of out-of-calibra-
tion reports filed between December 1983 and December 1984. Out of the
427 reports filed during this period, 62 evaluations had not been
completed within three months, an interval chosen arbitrarily but
clearly beyond an acceptable period of time. Out of the 62 reports
exceeding three months, 36 were still outstanding including one for
greater than one year and 15 between six months and a year.
The 16
most delinquent reports as of March 7,1985, are documented below:
DPIR Number
Date Out-of-Calibration Reported
110
12/22/83
198
04/12/84
207
04/23/84
220
05/04/84
223
05/10/84
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234
05/25/84
245
06/13/84
267
07/06/84
268
07/09/84
282
07/23/84
283
07/24/84
298
07/27/84
311
08/15/84
313
08/24/84
320
09/07/84
321
09/07/84
This problem resulted from a procedural deficiency with SAP-141, in
that a necessary time constraint was not provided.
This failure to
establish measures to assure that conditions adverse to quality are
promptly
identified and corrected is identified as violation
395/85-11-01.
b.
Accountability of Out-of-Calibration Evaluations in the Mechanical
Maintenance Calibration Laboratory.
The inspector requested documentation of out-of-calibration reports
filed in the mechanical maintenance calibration laboratory. There did
not appear to be a formal system of accounting for the evaluation
reports in that the laboratory could not document or trace the course
or completeness of the evaluations. From the explanation offered, the
method _ employed to process these reports appeared to be an open-loop
system. The originator sends a copy to a responsible supervisor who
completes the evaluation and sends the information to microfilming
which, in turn, sends the information to document control. During this
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process, :the laboratory has either not received feedback or has not
maintained an adequate filing system to ensure that the evaluations are
complete. .The inspector's efforts to document the completion of an
evaluation were frustrated by the fact that data pertaining to a single
evaluation was scattered throughout the document control system.
Although it was clear _ that evaluations were being performed, their
completeness or adequacy could not .be readily determined.
The
inspector, therefore, could not verify compliance with ANSI N45.2.4-
1972Property "ANSI code" (as page type) with input value "ANSI N45.2.4-</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. or the licensee's QA program.
Licensee personnel indicated that further information could be provided
to clarify this issue but that enough time was not available given
short notice prior to the exit interview.
The inspector understood
that the licensee will investigate this matter and inform NRC of their
conclusions by June 1,
1985.-
Pending this response and until a
subsequent review indicates proper accountability of the evaluations,
this item is identified as Unresolved Item 395/85-11-02.
c.
Verification of Lab Temperature for Calibration of Site Standard
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Weights
Mechanical Maintenance Procedure MMP-285.006, Calibration of Site
Standard Weights, Revision 1, states in Section 3.1, as a prerequisite.
.that the calibration lab should be maintained at a temperature of
7214'F.
The inspector observed a calibrated thermometer in the lab;
however, the temperature was not recorded on the calibration data
sheet. The inspector inter /tewed the lab technician who stated that
since the word "should" is used, -it is not a requirement.
Licensee
management objected to his interpretation of a "should" statement and
further stated that the lab is kept in this temperature range for this
calibration. However, the licensee agreed that the temperature should
be recorded on the data sheet as a means of verifying the temperature
prior to a calibration. Until MMP-285.006 is revised to require lab
temperature to be recorded for the calibration _ of site standard
weights, this item is identified as Inspector Followup Item 395/85-11-04.
7.
Licensee Action on Previously Identified Inspection Findings (92701)
(Closed) Inspector Followup Item 395/84-18-02:
Clarification
The inspector reviewed " Final Report on Temporary Records Storage Facility
Fire Load Analysis," October 30, '984.
This report concluded that "all
temporary records storage facilitt 's in fire resistive buildings have fire
loads which allow the use of one hour rated equipment." The report concluded
that all one-hour fire-retardant cabinets were located satisfactorily.
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