ML20132C244
| ML20132C244 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 09/11/1985 |
| From: | Belisle G, Runyan M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132C223 | List: |
| References | |
| 50-416-85-27, NUDOCS 8509260502 | |
| Download: ML20132C244 (11) | |
See also: IR 05000416/1985027
Text
.-
,
.-
- ..
.-.
- -
.-. . - . . _ . . . . _ .
. . . - .
- . .
...
l
'
,
,
-
SS R$c
UNITED STATES
l
oq'o
NUCLEAR REGULATORY COMMISSION
O3
^
REGION ll
h
.
101 MARIETTA STREET, N.W.
,
2
ATLANTA, GEORGI A 30323
\\...../
-
I
I
!
Report No.:
50-416/85-27
i
Licensee: Mississippi Power and Light Company
Jackson, MS 39205
4
I
Docket No.: -50-416
License No.: NPF-29.
Facility Name: Grand Gulf
I
Inspection Conducted:
uly 21 - August 2, 1985
..
Inspector:
- L _ !/' 7
//
]
M. F.L Runyan
CV
/
_Dite signed
.
Accompanying Personnel: 'J.
H.
corman, III, Region II
/ [-
Approved by:
.r . /
~ D' ate igned
.;
G. AF Belisle, W ting Chief
Quality Assurance Programs Section
>
j
Division of Reactor Safety
l
.
+
"
SUMMARY
}
Scope: This routine, unannounced inspection entailed 68 inspector-hours on site
in the areas of QA program review, QA/QC administration, surveillance testing and
l
calibration control, and measuring and test equipment.
j
Results: One violation was ider.tified - Failure to promptly evaluate measuring
i
and test equipment found out of calibration.
<
I
i
!
-
i
,
.
.
i
1
-
.
m
,
l
.
-
.- - -
. - .-. - - - - .. - - . - - - - ...-.
-
._.
.
.
.
.
_
'
.
i
f
4
I
REPORT DETAILS
1.
Persons Contacted
'
Licensee Employees
j
M. Asmus, Instrumentation and Control (I&C) Planning Supervisor
- J. Bailey, Compliance Coordinator
- J. Cross, General Manager
- L. Daughtery, Compliance Superintendent
R. Harrison, Production Aide
J. Holder, I&C Supervisor
B. Lee, Quality Assurance (QA) Supervisor, Audits
i
A. Malone, In Service Inspection Coordinator
- R. Moomaw, I&C Superintendent
- J. Roberts, Technical Support Superintendent
- R. Rogers, Assistant to the General Manager
i
- S. Tanner, Manager, Nuclear Site QA
L. Temple, I&C Supervisor
J. Yelverton, Manager, Plant Support
G. Zinke, Technical Engineering Supervisor
NRC Resident Inspectors
- R. Butcher
,
J. Caldwell
- Attended exit interview
2.
Exit Interview
,
The inspection scope and findings were summarized on August 2,1985, with
~
those persons indicated in paragraph I above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
,
below.
Violation, Failure to Promptly Evaluate Measuring and Test Equipment
(M&TE) Found out of Calibration, paragraph 8.a.
Inspector Followup Item,
Environmental Conditions in the M&TE
Calibration Lab, paragraph 8.b.
.
As a result of Region II management review, a portion of the violation was
removed and made an unresolved item.
The licensee was informed of this
action during a telephone ccnversation conducted on August 29, 1985.
4
i
Unresolved Item,
Evaluations of Installed Process Instruments,
'
paragraph 7.
l
l
t
. - -
_
.- -.-.
--
-
--.. - _ .
-.
,
- . .
-
-.
. - .
_- -
_-
"
.
r
l
2
The licensee did not identify as propri.etary any of the materials provided
to or reviewed by.the inspector during this inspection.
t
3.
Licensee Action on Previous Enforcement Matters
,
This subject was not addressed-in the inspection.
4.
Unresolved Items *
One unresolved item was identified relating to evaluating installed process
instrumentation and is discussed in paragraph 7.
5.
QA Program Review (35701)
,
Reference:
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
The inspector reviewed the licensee QA Program required by the above
,
!
reference to verify that these activities were conducted in accordance with
regulatory requirements.
The following criteria were used during this
review to assess overall acceptability of the established program:
i
!
-
Personnel responsible for preparing implementing procedures understand
the significance of changes to these procedures.
3
-
Licensee procedures were in conformance with the QA Program.
The procedures discussed throughout this report were reviewed to verify
conformance with the QA Program.
The inspectors reviewed QA Program
- '
implementation as a part of the inspection. Each specific area is detailed
in other paragraphs of this report.
Problem areas, if identi fied, are
detai. led in the specific area inspected.
,
6.
QA/QC Aaministration (35751)
i
Reference:
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
'
The inspector reviewed the licensee QA/QC. administration program required by
l
the reference to verify that activities were conducted in accordance with
i
regulatory requirements.
The following criteria were used during this
review to determine the overall acceptaoility of the established program:
'
Licensee QA program documents identified those structures, systems,
-
components, documents, and activities to which the QA program applies.
,
,
1
- An Unresoived Item is a matter about which more information is required to
determine wrether it is acceptable or may involve a violation or deviation.
1
- -
--
,n
,
-
- - -
, , .
---
-
,,
-
-
3
-
Procedures and responsibilities were established for making changes to
these documents.
-
Administrative controls were established for QA/QC department procedure
review, inspection, and auditing.
These controls assured review and
approval prior to implementation, provided methods to make changes and
I
revisions, and established methods for distribution and obsolete
procedure recall.
-
Responsibilities were established to assure QA program review for
overall effectiveness.
-
Administrative controls were established wu .mdisy the QA program based
on identified problems areas.
The. documents listed below were reviewed to verify that these criteria were
incorporated into the licensee's administrative procedures for QA/QC
administrative activities.
MP&L Operational Quality Assurance Manual, MPL-TOP-1A, Revision 4
Policy 2
Quality Assurance Program
Policy 5
Instructions, Procedures, and Drawings
Policy 8
Identification and Control of Materials, Parts and
Components
Policy 16
Corrective Action
Policy 18
Audits
QAP 2.10
Quality Assurance Status Report to Management,
Revision 5
QAP 5.10
Procedure Preparation; Procedure and Manual
Revision, Distribution, and Control, Revision 13
QAP 6.10
Performance and Documentation of Rev'iews,
Revision 18
QAP 18.10
Quality Assurance Audits, Revision 16
QAP 18.14
Quality Assirance Monitoring Audits, Revision 9
_
The site Quality Assurance department was recently reorganized to encompass
the function of the Plant Quality department.
It appears that this
reorganization will have a positi /e effect on the function of quality
inspections.
Within this area no violations or deviations were identified.
7.
Surveillance Testing and Calibration Control (61725)
References:
(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
__ _ - __ - _ _ __________________ _ - -_-_ ___-.
-
_=.
-.
.
-
.
- . . .
-
.
.
'
-
4
,
d
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuc.laar Power
'
Plants
(d) Technical Specifications, Section 4
The inspector reviewed the licensee surveillance testing and calibation
control program required by references (a) through (d) to verify that the
program had been established in accordance with regulatory requirements,
industry guides and standards, and Technical Specifications.
The following
!
l
criteria were used during this review to determine the overall acceptability
of the established program:
-
A master schedule for surveillance testing and calibration delineated
!
test frequency, current status, and responsibilities for performance.
1
l
-
The naster schedule reflected the latest revisions of the Technical
j
Specifications and operating license.
-
Responsibilities were assigned to maintain the master schedule
j
up-to-date and to ensure that required tests are performed.
l
Detailed procedures.with appropriate acceptance criteria were approved
-
i
for all surveillance testing requirements.
l
j
The program defined responsibilities for the evaluation of surveillance
-
test data as well as the method of reporting deficiencies and
'
malfunctions.
l
The inspector also verified that similar controls were established for
calibrating instruments used to verify safety functions but not specifically
1
identified in the Technical Specifications (TS). The documents listed below
were reviewed to verify that these criteria were incorporated into the
,
surveillance testing and calibration control program:
!
l
MP&L Operational Quality Assurance Manual, MPL-TOP-IA, Revision 4
Policy 5
Instructions, Procedures, and Drawings
'
!
Policy 11
Test Control
l
Policy 15
Nonconforming Materials, Parts, or Components
Policy 16
Corrective Action
'
01-S-03-3
Material Nonconformance Reports, Revision. 14
i
01-5-06-12
GGNS Surveillance Program, Revision 9
01-5-07-8
Control of Permanent Plant I&C Equipment
,
l
Calibration, Revision 6
01-S-07-10
Preservice and Inservice Inspection., Revision 2
i
i
!
i
,
._ - - - ,. -. ,_- , , , -
-
- - . - - . . .
.
. . - - - _ _ - - - _ - , , - . _ - -
-. - - - . - , -
__
.
.
_ _
_
..
1
5
,
The following site QA audits were reviewed as a means of determining where
the licensee had discovered problems in the area of surveillance testing and
calibration:
MAR 84-30
Emergency Core Cooling System, 3/14/84
MAR S4-69
Control of Permanent Plant I&C Equipment Calibration,
5/18/84
MAR 84-75
Implementation of Surveillance Procedure
06-IC-1E12-M-1010, Interface Valve Pressure Functional
'
Test, 5/9/84
~
MAR 84-76
Implementation of Surveillance Procedure
06-IC-1E51-0003, Suppression Pool High Water Level,
(RCIC) Functional Test, 5/22/84
MAR 84-78
Implementation of Surveillance Procedure
'
06-IC-1E12-R-0002, RHR Pump Discharge Pressure (ADS),
5/14/84
MAR 84-82
Implementation of Surveillance Procedure
4
06-0P-1E21-M-0001, LPCS Monthly Functional Test,
j
5/9/84
MAR 84-103
Implementation of Surveillance Procedure
06-IC-1C51-0-0002, Average Power. Range Monitor
Calibration, 7/23/84
MAR 84-116
Control of Permanent Plant I&C Equipment Instrumenta-
!
tion, 7/12/84
'
MAR 84-123
ASME,Section XI, Repair /Replacment Program, 9/20/84
MAR 84-139
Control of Permanent Plant I&C Functional Testing,
8/23/84
.
MAR 85-34
Seismic Monitoring Instrumentation Set points, 5/9/85
MAR 85-39
Radiation Monitoring Instrumentation, 4/17/85
An incident report identified that a data package was re' viewed and found to
i
have previously undiscovered "as-found" data exceeding TS limits. Another
i
discrepancy involved the use of a superseded surveillance test procedure.
,
Further licensee investigation identified that procedure change routing
!
slips were not being returned to Document Control. Other discrepancies were
i
primarily administrative in nature and corrective action appeared to be
I
adequate.
The inspector reviewed the surveillance test master schedule which consisted
of a computer data base for TS, inservice inspection (ISI), and industry
requirements. For each procedure, the standing maintenance work order, last
i
completion date, next due date, latest due date (considering grace periods),
and applicable plant modes were delineated. Methods used to schedule tests,
,
verify completion, and anticipate testing requirements for changing plant
,
~
modes appeared to be adequate.
i
!
l
l
,
-
_
_
_,
.
_ _
___ _
.__ -.
_ _ _ _ _ _ _ . _
._ _ _
_
. _
_ _ _ _
'
..
6
i
To evaluate the surveillance test program implementation, the following TS
requirements were traced to plant. procedures and the master schedule:
TS
Plant Procedure
4.2.1.a
- 06-RE-1J11-V-0001
A.3.2.1
4.4.1.2.1
- 06-RE-1833-D-0001
4.4.2.2.1
- 06-IC-1B21-M-1001
4.5.1.d.1
- 06-0P-1821-R-0009
4.6.1.2.f
06-ME-1M61-V-0001
4.7.1.2.a
06-OP-1P41-M-0001
4.8.1.1.2.a.5
- 06-0P-IP75-M-0001
All plant procedures reviewed above were scheduled for periodic performance'
at the frequency specified by TS. Those procedures marked with an asterisk
were specifically reviewed and determined to meet the intent of the
!
corresponding TS reouirement.
The following completed surveillance test data packages were reviewed for
administrative and technical adequacy:
!
HPCS Quarterly Functional Test, 3/9/85
06-IC-1B21-R-0008
Reactor
Vessel
Water
Level,
Channel
E
4
Calibration,
1
'
3/12/85
06-OP-1E12-M-0001
LFCS Monthly Functional Test, 5/11/85
06-IC-IC51-Q-0002
Average Power Range Monitor Calibration,
'
'
1/1/85
'
The above data packages were complete, properly reviewed, and met stated TS
>
acceptance criteria.
In the HPCS Functional Test, a HPCS Jockey pump is
,
correctly identified as being in the required action range for differential
'
pressure.
Corrective measures for this event are identified in the ISI
program for pumps and valves and ASME Code XI, Sections IWP and IWV.
The
r
latest ISI program submittal was made Jure 28, 1985, as Revision 1 and is
pending approval from Division of Licensing, NRR.
The licensee is required to establish a calibration program for installed
process instrumentation associated with safety related systems or functions.
The following instruments were chosen at random and verified to be contained
l
within the program.
Diesel Driven Fire Pump A
Discharge Pressure PI-R008A
Suction Pressure PI-R004A
,
Discharge Flow FI-R005
l
RHR Pump A
Flow FI-R603A and FI-R200A
1,
Safety related instruments were calibrated every 18 months while non-safety-
related instruments were calibrated every 36 months. These frequencies were
consistent with good engineering practice.
i
l
- - - - --
-
.-
.-
--
-
-=
_ - - _ .
--
l
'
.
_
7
Within this area, one unresolved item was identified.
The Operational
Quality Assurance Manual commits to Regulatory Guide 1.33 which endorses
Section 5.2.16 of this standard requires that when
calibration, testing, or other measuring devices are found out of
calibration, an evaluation shall be made and documented concerning the
validity of previous tests and the acceptability of devices previously
tested from the time of'the previous calibration. Evaluations are not being
performed when installed process instruments used to verify TS acceptance
criteria are found out of calibration.
Plant installed process instru-
mentation used to verify saf ety-related activities (i.e. . . those required by
TS) should be under the control of this requirement in that test results
derived from this instrumentation could, when reevaluated, be identified as
an unsafe condition and require further action in accordance with 10 CFR 50
regulations and the TS.
However, due to the generic nature of this issue
and the need for further consideration by NRC, a violation is not warranted
at this time.
Pending further resolution, this item will be identifed as
Unresolved Item 416/85-27-02, Evaluations of Installed Process Instruments.
-
8.
Measuring and Test Equipment Program (61724)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
,
Quality Assurance Program
Requirements (Operations), Revision 2
1
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(d) Regulatory Guide 1.30, Quality Assurance Requirements
i
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 M&TE program required by references (a)
through (e) 'to verify that the program had been established in accordance
with regulatory requirements and industry guides and standards.
The
following criteria were used during this review to determine the overall
acceptability of the established program:
Responsibility was delegated and criteria established to assign and
-
adjust calibration frequency for each type of M&TE.
!
.
An equipment inventory list identified all M&TE used on safety-related
-
!
components, the calibration frequency and standards,
and
the
calibration procedure,
i
t
-
,,
,
,, - - - -
-
- -
.-
, ..
- _. .
-- - -.
.._
-
.
_.
'
-
l
'
8
,
d
-
Farmal requirements existed for marking the latest calibration date on
each piece of equipnent.
-
The program assured that each piece of equipment was calibrated on or
before the date required . or stored in a location separate from
inservice M&TE
-
Written requirements prohibit the use of M&TE which was not calibrated
within the prescribed frequency.
,
-
When M&TE wa, found out of calibration, the program required documented
i
evaluations b, determine .the cause of the out-of-calibration condition
and the acceptability of items previously tested.
The program assured that new M&TE was 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:
MP&L Operational Quality Assurance Manual, MPL-TOP-1A, Revision 4
Policy 12
Control of Measuring and Test Equipment
Policy IS
Nonconforming Materials, Parts, or Components
Policy 16
Corrective Action
01-S-03-3
Material Nonconformance Reports.(MNCRs), Revision 14
01-5-07-3
Calibration and Control of Measuring and Test
Equipment, Revision 6
The inspector reviewed site 0A audit MAR 84-157, Control and Calibration of
.
Measuring and Test Equipment, September 26, 1984.
The findings included a
plant standard which was not marked with an identifying. number or
calibration status, M&TE with " cal void if seal broken" stickers broken, and
M&TE utilization logs with improper entries.
Corrective action appeared
adequate.
Implementation of the M&TE control program was assessed in the calibration
laboratory and two M&TE issue facilities, the upper and lower I&C shops.
In
the calibration laboratory where all on-site M&TE was calibrated, the
,
following calibration procedures were chosen at random for review:
07-5-43-36
Calibration of the Fluke Model 8600A Digital Multimeter,
Revision 3
07-5-43-72
Calibration of the L&N 5300 Wheatstone Bridge,
Revision 2
I
07-5-43-102
Calibration of Mechanalysis Model 308 Sound / Vibration
Meter, Revision 4
-
2
07-5-43-114
Calibration of Torque Wrenches, Revision 4
07-5-43-158
Calibration of Pressure Gauges, Revision 4
.
07-S-43-159
Calibration of Micrometers, Revision 1
The above procedures were properly reviewed and ' approved and appeared to
provide suf ficient guidance for performing the calibrations.
Acceptance
criteria was clearly stated.
A problem concerning the stipulation of
-
1
,
-
,
,--
. - -
,n
=
9
prerequisite environmental conditions is addressed as an inspector followup
item at the end of this section.
The following M&TE was selected at random from master. listings at the Upper
and Lower I&C shops to assess overall control and accounr40ility:
Upper I&C
'
MP&L No.
Description
0311
Fluke 8600A Digital Multimeter
0642
R.M.S. Voltmeter
0347
Heise Gauge, 0-1500 psi
1334
Fluke 8600A Digital Multimeter
1693
Fluke 2180A RTD
5276
Fluke 8600A Ditigal Multimeter
7929
Microsystem Analyzer
Lower I&C
MP&L No.
Description
0360
Resistance Bridge
,
1634
Pre-Amp DC
3086
Fluke 8020A Digital Multimeter
5273
Fluke 8600A Digital Multimeter
5277
Fluke 8600A Digital Multimeter
5665
Digital Thermometer 450/AET
All M&TE items referenced above were either observed to be properly stored
or documented in another location.
Equipment utilization logs appeared
adequate and calibration dates affixed to the above equipment agreed with
the information on the master equipment index.
The . licensee was required to evaluate the effect M&TE found out of
calibration may have had on previous surveillance tests performed with this
equipment.
The following M&TE nonconformance reports were reviewed to
assess adherence to this requirement:
Report No
MP_&L No.
Description
1064
1985
Heise Gauge
1112
5257
Torque Multiplier
1120
3145
Heise Gauge
1132
3132
Dial Calfper
1189
0351
Heise Gauge
1244
0900
Digital Multimeter
Within this area, one violation and one inspector followup item were
identified and are discussed in the following paragraphs.
.
-
10
a.
Failure to Promptly Evaluate M&TE Found Out of Tolerance
10 CFR 50, Appendix B, Criterion XVI, states that measures shall be
established to assure that conditions adverse to quality are prompity
identified and corrected, The M&TE program does not contain measures
to assure that out-of-calibration evaluations are promptly completed.
Since December 1984, approx'imately 55 percent of the 151 evaluations
l
issued have taken over a month to complete, while 35 percent have
~
exceeded two months. Six evaluations have been open for greater than
six months.
Since these evaluations may result in safety-related
corrective action or limiting conditions for operation, these time
periods are not considered prompt for this activity. This failure to
promptly evaluate M&TE found out of calibration is identified as
violation 416/85-27-01.
b.
Environmental Conditions in the M&TE Calibration Lab
The M&TE calibration lab environmental conditions such as temperature
and humidity required for M&TE calibration are currently oeing con-
trolled. Personnel in the lab understand the need to allow instrument
'
temperatures to stabilize prior to performing calibrations. However,
existing written instructions do not assure that the beforementioned
.
actions ar,e accomplished and do not specifically identify acceptable
environmental condition criteria.
Until these items are delineated
procedurally, this item will be identified as inspector followup item
416/85-27-03.
9.
Licensee Action on Previously Identified Inspection Findings (92701)
(Closed). Insp.ector Followup Item 416/84-09-01:
Inclusion of QA Program
Adequacy in Semi-Annual Report
The inspector reviewed PMI-84/9900, QA Semi-Annual Report-to Management and
verified that it addressed QA program adequacy as required by QAP 2.10, QA
Status Report to Management.
t
l
l
,
.
,
-
__