ML20207P647

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Rev 1 to Sequoyah Nuclear Plant Calibr Control
ML20207P647
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 01/05/1987
From: Gass K, Knightly J, Stewart D
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207P454 List:
References
SWEC-SQN-22-29, SWEC-SQN-22-29-R01, SWEC-SQN-22-29-R1, NUDOCS 8701160361
Download: ML20207P647 (6)
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o TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-22 cnd -29 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: SQN Calibration Control REASON FOR REVISION: To incorporate TAS and SRP conunents SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Comenission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. Concerns A02850226002-001 and A02850415004-001 will be ready for NRC closure following completion of corrective actions in progress. ,

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Title:

SQN Calibration Control Source Document: NRC Report 327, 328/85-05 SWEC Concerns: A02850226002-001 A02850415004-001 Report Numbers: SWEC-SQN-22 SWEC-SQN-29 B

Evaluator: kN lohQ[C i>!T ffh J. J. Knight 1'y i Date Reviewed By: ((/h K. R. Gass AL // '/- ei, Date Approved By: h 1.2 [9 / rg, A. G. DebbaMr Daf.e f 1730T l

Reports SWEC-SQN-22 and 29 SQN Calibration Control I. INTRODUCTION During the time period January 21-25, 1985 the Nuclear Regulatory l Commission (NRC) conducted a routine, unannounced inspection of the l Sequoyah Nuclear Plant (SQN) calibration control program (Reference 1). l During this inspection, NRC identified one violation (327, 328/85-05-01) lR1 which, along with later follow-up comments by NRC (Reference 2), was I addressed as two issues in the Stone & Webster Engineering Corporation I (SWEC) systematic analysis. These issues are as follows: l

.(1) A02850226002-001 Mechanical Measuring and Test Equipment (M&TE) Maintenance Untimely (2) A02850415004-001 M&TE Out of Calibration These two SWEC issues are combined in this report.

II. VERIFICATION OF THE SWEC ISSUES A. Background SQN Administrativo Instruction AI-31 (Reference 3) specified that when a calibration report received from TVA Central Laboratories is stamped "out of tolerance," an evaluation and investigation shall be made within 60 days. The purpose of this is to ensure that instruments are promptly recalibrated when required and that any measurement taken with out-of-calibration equipment is evaluated and corrected. Contrary to requirements, the NRC inspection found that 43 of 52 outstanding evaluations filed in the mechanical maintenance shop tool room exceeded the 60-day limit. Eight selected calibration reports stamped "out of tolerance" had been received at the plant from 129 to 497 days without completing the required evaluations. In a follow-up memorandum (Reference 2) to TVA, NRC stated their concern that systems or components may have been adjusted or verified using M&TE later found out of calibration without determining the actual safety significance of the condition for up to 60 days. TVA was informed that other facilities in Region II were determining the prior use and safety significance of out-of-calibration M&TE in a one or two weeks timeframe.

B. Corrective Actions Taken Corrective actions undertaken by SQN (Reference 4) included the following:

1. All delinquent reports were completed.
2. The computer tracking system for M&TE was revised to flag action items for the upcoming weet so that the appropriate section can be notified of any upcoming due dates.

Page 1 of 4

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.3. A section instruction letter was written to establish.

. guidelines for tracking and maintaining M&TE. These include management control deadlines for each section having a part in +

the evaluation.

4. AI-31. " Control of Measuring and Test Equipment" (Reference 3) lR1 was revised to include safety evaluations as part of the M&TE out-of-tolerance program. Lines of authority and responsibility for handling out-of-tolerance M&TE were established in this procedural revision.

SQN initiated and completed a six month evaluation of the M&TE out-of-calibration problem and reported results of the evaluation

, to the NRC November 1985 (Reference 4c). Their status report.

Indicated a reduction in the overall time required to complete. '

evaluations with slightly less than 30 days as the average elapsed time and with 50 percent accomplished under 15 days. This was attributed by SQN to the new tracking system and the monthly reports generated by the system which increased visibility for management attention. Trend analysis was also initiated on METE equipment to determine which instruments could no longer maintain desired toleranc< and should be retired and replaced.

Although improvements were reported in November 1985, additional l improvement was still needed. TVA's quality assurance audit l QSQ-A-86-003, dated February 28, 1986 identified a deviation i

.(QSQ-A-86-003-D02) for not completing out-of-tolerance l investigations in a timely manner. The preliminary findings of l the quality assurance surveillance follow-up to this audit, dated l December 3, 1986, were reviewed with ECTG. These findings will be l reported later in December 1986. This surveillance found that l i

further improvements had been accomplished in the overall time i required to complete evaluations with "most" now under 15 days, but '

that additional improvement was still needed. 1 I lR1 M&TE out-of-tolerance investigations conducted in accordance with 1 SQN administrative instruction AI-31 (reference 3) include a safety l evaluation "to determine if the effects / consequences of using 'l t out-of-tolerance test equipment to perform the tasks listed in the I evaluation package create an unsafe condition for plant operation." l The evaluation packages include the documented evidence of these l r evaluations. The December 3, 1986 quality assurance surveillance l I

identified general compilance but isolated instances where the i evaluation may not have been properly accomplished. I

! l

[ SQN's Nuclear Performance Plan commitment to timely and effective l out-of-calibration investigations for M&TE is included in section l II.4.3.4 (reference 6). l C. Verification Methodology The SWEC concerns identified for Employee Concerns Task Group lR1 (ECTG) verification were stated as follows: l Page 2 of 4 l _ ._. ._ _ . , _ _ . _

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RIMS Number Issue RIMS Item A02850226002 43 out of 52 outstanding evaluations -001 filed in the Mechanical Maintenance Shop Tool Room exceeded 60 day limit. M&TE equipment.

102850415004 Concern that systems or components may -001 have been adjusted or verified using M&TE later found out of calibration.

A review was conducted of Sequoyah Compliance Correspondence NRC inspection reports and status reports, and the applicable SQN procedure concerning M&Tr calibrations. Calibration data May-October 1985 lR1 maintained by the SQN Materials Unit was reviewed to determine progress in the reduction of average time to perform evaluations. The 1986 l quality assurance audit and surveillance data concerning calibrations lR1 was reviewed with quality assurance personnel. l D. Verification Analysis Based on the ECTG verification activities described in II-C. it was determined that SQN corrective actions are being implemented; and l that the SWEC issues on calibration are being resolved. At the time l of this ECTG Verification, the NRC violation remained open; however. lR1 the SQN plant responses have been found acceptable to the NRC l (reference 5) and corrective actions are in progress. l E. Completion Status Based on SQNs implementation of a suitable tracking and reporting system for calibrations, management controls including notifications and periodic reviews, procedural revisions, and trending activities, the SQN M&TE calibration program is assessed to be progressing satisfactorily in most cases. These issues will be considered l complete and ready for NRC closure following additional evidence of lR1 program adequacy. These SWEC items remain open. ,

l III. REFERENCES

1. NRC Inspection Report Nos. 50-327/85-05 and 50-328/85-05 dated February 22, 1985, from R. D. Walker to H. G. Parris (SQN CATS Number 85449).
2. NRC Memorandum, " Report Nos. 50-327/85-05 and 50-328/85-05" dated lR1 April ll, 1985, from R. D. Walker to H. G. Parris.
3. AI-31, " Control of Measuring and Test Equipment," Revision 2. lR1 Current revision 6 is dated October 14, 1986. l Page 3 of 4

= 4. TVA Memorandum (a) "Sequoyah Nuclear Plant Units 1 and 2 - NRC

- -0IR, Region II Inspection Report 50-327/85-05 and 50-328/85 Response to Violation," dated March 22, 1985; (b) " Supplemental Response to Violation," dated May 10, 1985, from J. A. Domer to J.N. Grace," and (c) " Supplemental Response to Violation," dated November 15, 1985, from R. H. Shell to J. N. Grace.

5. NRC Memorandum, " Report Nos. 50-327/85-05 and 50-328/85-05" dated l January 3, 1986, from R. D. Walker to H. G. Parris. IR1 1
6. TVA Nuclear Performance Plan, Volume 2, dated July 17, 1986. l 6

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