ML20205P116

Insp Repts 50-348/87-03 & 50-364/87-03 on 870126-30. Violation Noted:Failure to Follow Procedures in Measuring & Test Equipment Program

ML20205P116
Person / Time
Site:	Farley
Issue date:	03/09/1987
From:	Belisle G, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P053	List: IR 05000348/1987003 ML20205P051 ML20205P074 ML20205P116
References
50-348-87-03, 50-348-87-3, 50-364-87-03, 50-364-87-3, NUDOCS 8704030179
Download: ML20205P116 (9)

See also: IR 05000348/1987003

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Report Nos.: 50-348/87-03 and 50-364/87-03 L

Licensee: Alabama Power Company 3

600 North 18th Street '

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Birmingham, AL' 35291-0400 ',, ,

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2

Inspection Conducted: January 26- , 1987

Inspector: Ne

M. A. Scott

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Date Signed

Approveo by: d a . t-N

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G. A. Belisle, Chief Date Signed

Quality Assurance Programs Section' ~

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection was in the areas of licensee actions

on previous enforcement matters, corrective action, and actions on previously

identified inspection findings.

Results: One violation was identified - Failure to follow procedures in the

measuring and test equipment (M&TE) program, Paragraph 5.

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

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J. Brantley, Compliance Engineer

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C. Buck, Plant Modification Department (PMD) Supervisor

• T. Cherry, Instrument and Control (I&C) Supervisor

• M. Coleman, System Performance Supervisor

H. Erbskorn, Maintenance Foreman

H. Garland, Mechanical Maintenance Supervisor

J. Hancock, Mechanical Maintenance Foreman

C. Hanks, I&C Calibration Lab Supervisor

• R. Hill, Operations Manager

H. Mahan, System Performance Engineer

R. Martin, Safety Audit and Engineering Review (SAER) Auditor

V. Murphy, SAER Auditor

i J. Odom, Unit Supervisor

i *J. Osterholtz, SAER Supervisor

D. Sherer, Maintenance Planner

• L. Stinson, PMD Manager

J. Thomas, System Performance Supervisor

W. Van Landingham, Unit Supervisor

• L. Wtrd, Maintenance Manager -

R. Wiggins, Operations Training Supervisor

• J. Woodard, Plant Manager

i Other licensee employees contacted included engineers, technicians,

mechanics, security force members, and office personnel.

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NRC Resident Inspectors

W. Bradford

• B. Bonser

• Attended exit interview

2. Exit Irterview

The inspection scope and findings were summarized on January 30, 1987, with

those persons indicated in paragraph 1 above. The inspector described the

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areas inspected and discussed in detail the inspection findings.

Violation, Failure to Follow Procedures in the Measuring and Test

Equipment Program, paragraph 5.

The licensee had a dissenting comment on one example of the violation. This

comment is addressed in paragraph 5.

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The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

a. (Closed) Violation (348,364/85-21-01): Failure To Li st Persons

Contacted During Auditing Activ".ies.

The inspector reviewed correspondence on the subject violation. The

licensee denied the violation in his letter of June 19, 1985. In

subsequent telephone conversations between Region II NRC staff and.the

licensee which are indicated in NRC correspondence dated July 23, 1985,

to the licensee, the NRC stated that the violation did occur as stated

in the original Notice of Violation dated May 21, 1985.

The inspector examined licensee audit activities as part of a

corrective action implementation review. The inspector reviewed

tabulations of persons contacted in 'the following composite audit

reports:

Report No. 86-25, dated December 30, 1986, (Contained eight

audits issued in December)

Report No. 86-24, dated December 13, 1986, (Contained two

audits issued in December)

Report No. 86-23, dated December 2, 1986, (Contained four

audits issued in November)

The reports listed all site personnel required for the various audits.

No general staffing groups were indicate:1.

The inspector concluded that the licensee had determined the full

extent of the violation, taken action to correct current conditions,

and developed corrective actions needed to preclude recurrence of

similar problems. Corrective actions stated in the licensee

correspondence have been implemented.

b. (Closed) Violation (348, 364/86-25-01, b and c): Failure To Perform

Evaluation Of Out-of-Tolerance Measuring And Test Equipment (M&TE).

The inspector reviewed the following correspondence on the subject

violation. This correspondence also addressed violations indicated in

paragraphs c and d:

Initiator Date Comment

NRC Region II July 18, 1985 Notice of Violation

Licensee August 16, 1985 Denial Letter for

three of the four

Violations

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NRC Region II October 1, 1985 Clarification /

response to licensee

denial

• NRC Region II December 27, 1985 Meeting Summary

between NRC and

licensee

Licensee January 15, 1986 Statement of

acceptance of

certain violations

NRC Region II. February 13, 1986 Acknowledgement

letter

• This letter also addressed the violation of paragraph ~e.

The licensee's final response on the subject violation was considered

acceptable by Region II.

The inspector reviewed the site's programmatic controls involving

out-of-tolerance M&TE. Procedural controls which included AP-11 and

AP-15 appeared to be adequate in their content to close the violation.

However, site personnel were not following these procedures which is

addressed in paragraph 5.

c. (Closed) Violation (348,364/85-25-02): Failure To Establish

Environmental Controls For Calibration Of Measuring And Test Equipment.

The inspector reviewed the licensee's response to the violatiun as

indicated in paragraph b. The response was considered acceptable by

Region II.

The inspector examined the programmatic controls that establish

environmental conditions for the calibration of M&TE. The procedures

appeared to be adequate. However, site personnel were not following

the procedures which is addressed in paragraph 5.

d. (Closed) Violation (348, 364/85-25-03): Failure To Confirm Adequacy

Of Calibration Frequency Of Measuring And Test Equipment.

The inspector reviewed the licensee's response to the violation as indicated

in paragraph b. The response was considered acceptable by Region II.

Site procedures had been revised to indicate a two year review cycle

regarding the adequacy of calibration frequency for M&TE. In

discussions with the licensee, M&TE calibration intervals had been

reviewed during the initial corrective action (December 1985). The I&C

second review had occurred just prior to this inspection. Mechanical

maintenance indicated that their second and subsequent review is

scheduled via the preventive maintenance program.

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The inspector concluded that the . licensee had determined the full

extent of the violation, taken action to correct conditions, and

developed corrective actions needed to preclude recurrence of similar

problems. Corrective actions stated in the licensee response have

been implemented.

e. Closed) Violation (348,364/85-32-02): Special ' Test Program

Non-compliance With Technical Specification.

The licensee's response dated October 21, 1985, for this violation was

considered acceptable by Region II.

The inspector exanined site r,rocedures and final signature authority on

current Special Test and Experiments (STE). Revision 19 of FNP-0-AP-1,

Development, Review and Approval of Plant Procedures, indicated that

the plant manager authorized STE. Site compliance indicated that three

STEs had been performed in 1986. The inspector reviewed two STEs and

identified that the plant manager had authorized both STEs.

The inspector concluded that the licensee had determined the full

extent of the violation, taken action to correct conditions, and

developed corrective actions needed to preclude recurrence of similar

problems. Corrective actions stated in the licensee's response have been

implemented.

f. (Closed) Unresolved Item (343, 364/85-25-06): Perform Evaluation of

Installed Process Instrumentation When Found Out-of-Calibration

This item was closed since process instrumentation out of-calibration

events during the performance of technical specification required that

surveillance tests would be identified. Although no regulatory

guidance requires process instrument evaluation and current site

procedures do not directly require deficient instrument evaluation,

many site procedures such as FNP-0-AP-11 and site practices will

capture process instrumentation related problems (NRC reference:

Report Number 348,364/85-25-01).

g. (0 pen) Unresolved Item, (343, 364/85-32-01): Design Changes Caused by

Plant Activities / Work Items

The item was left open pending issue of a new revision to FNP-0-AP-8,

Design Modification Control, and review of its implementation.

4. Unresolved Items

Unresolved items were not identified during this inspection.

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5. Corrective Action (92720)

i In reviewing implementation aspects of the site corrective actions for

violations addressed in paragraph 3, the inspector identified examples of

site personnel failing to follow procedures. The two examples are as

follows:

a. FNP-0-AP-11, Control and Calibration of Test Equipment, Test

Instrumentation and Plant Instrumentation (Revision 6, issued

February 7,1986), prescribed environmental conditions for calibration

of M&TE. Paragraph 4.11.1 of the procedure states, in part, that if

environmental conditions are not specified by the vendor, a relative

humidity of less than 70 percent and a temperature of 70110* F will be

used. The inspector found in excess of ten calibration data sheets

for I&C M&TE that had no temperature and humidity recorded. Examples

, of the M&TE were:

Identification Type of Date

Number M&TE Calibrated

FNP-HTG-8024 0-4000 psig 8/13/86

gauge

FNP-HTG-8516 0-500 psig 8/8/86

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gauge

FNP-HTG-8097 0-1500 psig 8/13/86

gauge ,

FNP-HTG-8514 0-500 psig 8/12/86

gauge

A note was typically annotated on the sheet indicating that Rad-Side;

Humidity / Temperature controls were not in place. In discussions with the

licensee, no portable temperature and humidity indicators were taken to

the Radiological Control Area (RCA/ Rad-Side) where the subject M&TE

were calibrated. It was stated by the licensee that there was air

conditioning present in the RCA space, but the unit does not work

sometimes and its humidity and temperature parameters are not routinely

checked,

b. Paragraph 4.8.1 of FNP-0-AP-11 prescribed evaluations for M&TE found

out-of-tolerance. The paragraph states, in part, that such evaluations

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shall be performed promptly to determine if safety-related activities

were involved and in all cases should be completed within 30 days.

The licensee stated that the "should" verb used in the above sentence

is interpreted to mean manditory/ imperative which was in agreement

with the statements made in their corrective action documentation

(Corrective Action Request 1041). After the calibration lab checks and

finds a piece of M&TE out-of-tolerance, the I&C lab personnel filled

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out a Test- Equipment Deficiency Report (TEDR) and routed it to the

user of the out-of-tolerance M&TE for evaluation. Paragraph 4.8.3 of

FNP-0-AP-11 allowed the user and/or foreman ten days from receipt of

the TEDR to complete the evaluation. The inspector reviewed completed

TEDRs and found in excess of ten TEDRs that had the limits exceeded.

The following is a sample of the deficient M&TE identified on the

t TEDRs:

Identification TEDR Evaluation

Number Initial Date Review Date

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FNP-WTC-8156

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04/08/86 06/30/86

FNP-HTG-8510 07/02/86 08/08/86

FNP-ATG-8573 07/21/86 08/11/86

FNP-ATG-8467 04/12/86 07/02/86

The deficient TEDRs exceeded the limits from a few days to greater than

60 days. The deficient I&C TEDRs were marked serially as repeat

re-issues to the user for evaluation. The earliest deficient TEDR

observed was from April 1986, and they continued through to the period

i of the inspection. It was found in reviewing the mechanical group

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TEDRs that none of these exceeded similar limits. The licensee stated

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that management was aware of the problem and had a draft FNP-0-AP-11 in

routing which was stated to extend the time limit to 40 days total (20

2 days for user evaluation) and would require a tickle copy of the tardy

TEDR to I&C Supervisor for additional action.

During the exit interview, the licensee stated that they would probably

object to this example of the violation based on the existence of the

draft procedure. Due to the following, the inspector let the enmple

stand:

(1) The length of time that deficient TEDRs had _been occurring (at

least nine months)

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(2) The fact that the mechanical group TEDRs were being evaluated

within similar time limits

(3) The fact that the draft procedure proposed time limit would not

have captured the more tardy of the deficient TEDRs

(4) The fact the deficient condition did not meet the regairements of

10 CFR Part 2, Appendix C.V.A, for licensee identified

deficiencies

The above two examples constitute violation 348, 364/87-03-01, Failure

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to Follow Procedure.

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6. Licensee Actions on Previously Identified Inspection Findings (92701)

a. (Closed) Inspector Followup Item (348, 364/85-21-02): Cheater Bar

Usage

The licensee issued FNP-0-SOP-0, General Instructions to Operations

Personnel, Revision 19, which provided instructions on the use of

cheater bars (manual torque multipliers) on manual valves. The

procedure required that a work request be written on the valves that

would require torque which could not be explained or was questionable.

The work request would be the vehicle for a valve evaluation. The

licensee stated that operations would request System Performance

perform the evaluation. Operations had received training on the

procedure.

b. (Closed) Inspector Followup Item (348, 364/85-21-03): 10 CFR 21

Reporting

The inspector reviewed FNP-0-AP-62, Evaluations of Defects and

Noncompliances Potentially Reportable Under 10 CFR 21, Revision 2. The

revision incorporated all the comments indicated in report number

50-348, 364/85-21.

c. (0 pen) Inspector Followup Item (348, 364/85-25-05): Certification of

Individuals Qualified to Calibrate Measuring and Test Equipment

This item will remain open pending NRC review of maintenance training

at a later date.

d. (Closed) Inspector Followup Item (348, 364/85-30-01): Review Process

to Determine Safety Operating Plant Based on System Availability

The inspector examined safety-related pump test program changes in

light of FSAR (paragraph 13.5.4.2) and regulatory requirements.

FNP-0-AP-63, Conduct of Operations - System Performance Group, Revision

2, had been changed to upgrade and clarify the program. The Systems

Performance Group (SPG) is more involved in trending and evaluating

pump performance. The SPG has altered how data is analyzed and has

upgraded the data acquisition methodology. The SPG, in conjunction

with plant maintenance and operations is developing new techniques in

vibration analysis. The inspector reviewed tabulated / computerized data

on pump performance and found some minor errors that were corrected by

the SPG during the inspection.

e. (Closed) Inspector Followup Item (348, 364/85-30-02): Pump Vibration

Testing

The inspector reviewed pump vibration testing program changes since

the last inspection in this area. Site personnel are changing how

vibration analysis is now being performed. As stated by the licensee,

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permanent vibration monitoring points have been attached to pumps which

were under analysis. Although retraining has not occurred for the

4 unit operators, pump vibration data error has dropped significantly

with these fixed data collection points. In reviewing the_ data, the

inspector identified what appeared to be a data collector error which

was spurious but did not void the test results. The noted error was

probably caused by the use of hand held probes which could cause

trending problems. The licensee stated that new, more sophisticated

vibration gear is being integrated into the program which will

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eventually replace the hand held probes.

f. (Closed) Inspector Followup Item (348,364/85-32-03): Section

Instructions for the Plant Modification and Maintenance Support Group

The inspector reviewed section instructions and other documents used by

the Plant Modification Department (PMD) to close this item. The

guidances varied from a letter on lubricants to typed checklists. The

guidance was stated to be controlled within PMD and the loose leaf

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binders containing the guidance were given to each PMD engineer. Three

of the eight documents reviewed were dated or had revision numbers.

The PMD manager indicated that dating the remainder of the guidance

would occur. The primary instructions ET-001 and ET-002 (Design Change

Engineering Evaluation Preparation, Revision 0, and Engineering

Completion Reviews, dated January 20, 1986, respectively) had been

issued since the last inspection this area.

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