ML20127G682

Insp Rept 50-395/85-11 on 850304-08.Violation Noted:Failure to Establish Measures to Assure Prompt Evaluations of out-of-calibr Measuring & Test Equipment

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: ML20127G648 ML20127G671 ML20127G682
References
50-395-85-11, NUDOCS 8505210115
Download: ML20127G682 (12)

See also: IR 05000395/1985011

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>R Rf rog ' UNITED STATES

NUCLEAR REGULATORY COMMISSION

.[. p REGloN 11

101 MARIETTA STREET,N.W.

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• 2 ATLANTA, GEORGI A 30323

5._...../

Report No.: 50-395/85-11

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. 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

M. F. Runyah

4 85

Date Signed

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Accompanying Personnel: L. R. Moore, Region II

Approved by: [0 ~

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C. M. Upright,fSfctioyfChief j atjfSigned

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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PDR 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 <

-- C. McKinney, Regulatory Compliance

• J. Parks,. Supervisor, RegulatoryfSupport l

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 I

of Out-of-Calibration Measuring and Test Equipment, paragraph 6.a.

! 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 j

-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

N45.2.12. This was identified as a violation ati the exit interview, '

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'

- 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

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Nuclear Power Plant and Fuel Reprocessing Plants

V- , (b) Regulatory Guide 1.33, Quality Assurance Program *

, 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, i

. industry guides and standards, and Technical _ Specifications. The following-

c'riteria were used~during this review to determine the overall acceptability -

of the established program: '

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. A master schedule for' surveillance testing and calibration has been -

established which includes frequency, responsibilities for performance,

and testing status.

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The master schedule has been updated to reflect-Technical Specification

or license revisions.

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Responsibilities have been assigned to maintain the master: schedule

Lup-to-date.

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Requirements have been established for conducting surveillance 1 testing

in accordance with approved procedures ~ which include appropriate

. acceptance criteria.

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Formal . methods and responsibilities have been defined for review and

evaluation of surveillance test data, including procedures for

reporting deficiencies, failures, and malfunctions.

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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 i

' calibration control program: '

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QAP, Section:12.0, Nonconformance and Corrective Action Control,

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Revision 12

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: '

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. SAP-134,

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.

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:

r (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

(b) Regulatory Guide 1.33, 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 N45.2.4-1972, 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:

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Criteria and responsibility for assigning calibration frequency have

been established.

.- An equipment inventory list identifies all M&TE used on safety-related

components, the calibration frequency and standard for each piece of

equipment, and the calibration procedure.

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Formal requirements exist for marking the latest calibration date on

each piece of equipment.

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The- system assures that each piece of equipment is calibrated on or

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

evaluations to determine'the cause of the out-of-calibration condition

and the acceptability of items previously tested.

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A formal system assures that new M&TE will be added to the inventory

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. The licensee

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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

,1 ' 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

MOM-010 Outside Micrometer

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. MOM-102 Outside Micrometer

-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

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'from the' equipment check-out log or, if not checked out, from a quick search.

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 l

-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

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223 05/10/84

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-

1972 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

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: Regulatory Guide 1.88

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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