ML20133E734

Notice of Violation from Insp on 850603-07

ML20133E734
Person / Time
Site:	Farley
Issue date:	07/18/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133E731	List: ML20133E729 ML20133E734 ML20133E737
References
50-348-85-25, 50-364-85-25, NUDOCS 8508080003
Download: ML20133E734 (3)

Text

- . l ENCLOSURE 1 NOTICE OF VIOLATION Alabama Power Company Docket Nos. 50-348 and 50-364 Farley 1 and 2 License Nos. NPF-2 and NPF-8 The following violations were identified during an inspection conducted on June 3-7, 1985. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1. 10 CFR 50, Appendix B, Criterion XVI, and the accepted QA program require establishing measures to assure that conditions adverse to quality are promptly identified and corrected. The accepted QA program commits to Regulatory Guide 1.30 which endorses ANSI N45.2.4 - 1972, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.

Section 2.5.2 of this standard states that an evaluation shall be made concerning the validity of previous tests and acceptability of devices previously tested from the time of the previous calibration when inspection and testing equipment is found out of calibration.

Contrary to the above, adequate measures have not been established to assure that these evaluations are properly performed. The following examples were identified:

a. Evaluations were not required or perfonned when installed process instruments used to verify Technical Specification operability requirements were subsequently found out of tolerance.

b. Contrary to AP-15, Maintenance Conduct of Operations, Revision 8, Section 7.4, evaluations were not performed when mechanical measuring and test equipment was found out of tolerance.

c. The timeliness of evaluations performed by the I&C laboratory was not specified and evaluations were not promptly completed. An informal time limit of three weeks was in use at the working level but had not been specifically approved by management and does not provide a prompt assessment of safety significance for measuring and test devices found out of calibration. This informal limit was often exceeded with several evaluations taking about three months to complete.

This is a Severity Level IV violation (Supplement I).

2. 10 CFR 50, Appendix B, Criterion II, and the accepted QA program require that activities affecting quality shall be accomplished under suitably controlled conditions, including suitable environmental conditions for accomplishing the activity.

8508000003 850718 PDR ADOCK 05000348 G PDR

I. . l Alabama Power Company 2 Docket Nos. 50-348 and 50-364 Farley 1 and 2 License Nos. NPF-2 and NPF-8 Contrary to the above, measures have not been established to assure suitable environmental conditions for calibrating measuring and test equipment.

a. Temperature and humidity indication was provided in the I&C laboratory but not verified or recorded prior to performing environmentally sen-sitive calibrations. Acceptance standards for laboratory environmental conditions were not established.

b. In the mechanical shop, calibration activities were performed in ambient conditions at three locations within the shop. Measures were not established to define and provide acceptable environmental condi-tions for calibration activities.

This is a Severity Level IV violation (Supplement I).

3. 10 CFR 50, Appendix B, Criterion XII, and the accepted QA program collectively require that measures be established to assure that measuring and testing devices are properly calibrated with sufficient frequency to assure that accuracy is maintained. The accepted QA program commits to Regulatory Guide 1.33 which endorses ANSI N18.7 - 1972, American National Standard for Administrative Controls for Nuclear Power Plants.

Section 5.3.6 of this standard requires that procedures be provided for proper control of measuring and test equipment to confirm the adequacy of calibration frequency. Procedure AP-11, Control and Calibration of Test Equipment, Test Instrumentation and Plant Instrumentation, Revision 5, Section 4.6.2.2, requires that equipment data obtained from calibration checks be analyzed to optimize calibration check intervals.

Contrary to the above, adequate measures have not been established to assure that measuring and testing devices are calibrated with sufficient frequency to assure that accuracy is maintained. Historical calibration records are not maintained and analyzed to confirm the adequacy of calibration frequency. As an example, the Keithley Picoampere Source Model 261 was changed from the vendor calibration frequency of three months to six months without documented justification. Subsequently, the device was found out of tolerance at least twice in two years without reassessment of the cali-bration frequency.

This is a Severity Level IV violation (Supplement I).

4. 10 CFR 50, Appendix B, Criterion XII, and the accepted QA program require that measures be established to assure that measuring and testing devices are properly controlled. Procedure AP-11, Control and Calibration of Test Equipment, Test Instrumentation and Plant Instrumentation, Revision 5, Section 4.8.3, requires that daily access to test equipment will generally be limited to those personnel assigned to the calibration lab for calibration and test equipment checkout activities.

Contrary to the above, adequate measures have not been established to control access in the I&C calibration lab. The lab is routinely left unlocked at all hours, attended only intermittently during normal working

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Alabama Power Company 3 Docket Nos. 50-348 and 50-364 Farley 1 and 2 License Nos. NPF-2 and NPF-8 hours, and located in an area where visitors may gain unescorted access.

Therefore, the licensee does not have positive control over equipment checkout and documentation procedures or the ultimate security of NBS-traceable shop standards which are left unlocked and unattended.

This is a Severity Level IV violation (Supplement I).

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

Date: JUL 181985 i

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