ML20207T522
| ML20207T522 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/06/1986 |
| From: | Peranich M, Phillips H, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207T513 | List: |
| References | |
| 50-424-86-80, NUDOCS 8703240095 | |
| Download: ML20207T522 (27) | |
See also: IR 05000424/1986080
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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. Report No.:
50-424/86-80-
Licensee:
Georgia Power Company
P.O. Box 4545
Atlanta, GA 30302
Docket No.:
50-424
Construction Permit No.:
CPPR-108
Facility Name:
Vogtle, Unit 1
Module:
Appendix G, Measuring and
Test Equipment
Reviews Conducted:
May 12, 1986 - August 29, 1986
On-Site Inspections Conducted: May 12-18, 1986; June 2-6, 1986; and
August 4-8, 1986
NRC Offices Participating in Inspections / Reviews:
Office of Inspection and Enforcement (IE, Bethesda, MD)
Region II, Atlanta, GA
Reviewers:
H. W. Phillips, Reactor Construction Engineer, RCPB, IE
(Primary Reviewer)
.
D. C. Ford, Consultant
L. R. Moore, Reactor Inspector, Region II
Prepared By:
/8-/d --86
,
H/W. Philylps, Primary Review (r
Date Signed
Reactor Construction Programs Branch, IE
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898/N
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Approved By:
/
M. W. Peranich, Section Chief
Date Signed
Reactor Construction Programs Branch, IE
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M. V. Sinkule, Chief
Dap Signed
Projects Section 3C
Division of Reactor Projects, Region II
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
READINESS REVIEW PROGRAM
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT
CONTENTS
Topic
h
Summary ........................................................
1
Purpose and Scope of Review ....................................
3
Methodology ....................................................
4
NRC Staff Evaluation ...........................................
4
NRC Staff Findings .............................................
17
Statement of Module Acceptability (Conclusions) ................
17
References .....................................................
20
Tables .........................................................
21
List of Persons Contacted ......................................
24
Acronyms .......................................................
25
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
READINESS REVIEW PROGRAM
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT
SupMARY
The. Readiness Review Program is being conducted at the initiative ~of Georgia
Power Company (GPC) management to assure that design, construction, and
operational commitments have been properly identified and implemented at the
Vogtle Electric Generating Plant Unit 1.
Appendix G, which was submitted by
Georgia Power Company on March - 11, 1986, presents an assessment of-the com-
'
pliance of the Measuring and Test Equipment (MTE) program with Final Safety
Analysis Report (FSAR) commitments and regulatory requirements for the con-
struction phase.
This evaluation by the NRC was conducted to determine if the'
.
results of the program review of M TE presented in Appendix G represent an
effective and accurate assessment of the requirements, and that these require-
ments have been properly implemented.
This evaluation was performed by NRC reviewers from the Office of Inspection
and Enforcement (IE), and inspectors from Region II.
The evaluation consisted
of a detailed examination of each section of Appendix G, with particular
emphasis on Sections G.3, " Commitments and Implementation," and G.7, "Verifica-
tion of Project M TE Control Program," which for the purpose of this evaluation
were considered " Critical Elements." Specific NRC staff evaluation of each
Appendix G section is provided in Section 3.0 of this report.
In general, with the exception of the conditionally acceptable and unresolved
items listed below, the NRC evaluation indicates that the licensee's program
review was comprehensive and provides adequate assurance that construction MTE
- programs perform intended functions in accordance with FSAR commitments and
regulatory requirements.
The NRC review also indicates that the licensee
has taken appropriate actions with regard to licensee identified deficiencies
and that MTE program effectiveness has been enhanced by active management
participation.
The conclusions of the NRC evaluation are summarized by category as fM lows:
1.
Acceptable: Appendix G Sections:
G1 Scope, G2 Responsible
Organizations, G3 Commitments and Implementation, G4 Program
Description, G5 Audits and G6 Program Changes.
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2.
Conditionally Acceptable:
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a.
G7 Verification of Project MTE Control Program
(1) The NRC review resulted in the identification of a program
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deficiency with regard to the general lack of activity logs
or other usage records, and usage records for Pullman Power
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Products, automatic welding machines.
This deficiency is
discussed in detail in Section 3.g.(2)(e) of this report
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and was documented by NRC Inspection Report 50-424/86-77,
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Violation 424/86-77-01.
It will require additional licen-
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see attention and NRC review prior to full acceptance of
Appendix G.
(2) The NRC review identified Unresolved Item (UNR) 424/86-77-02
regarding a question concerning the overall MT&E program to
ensure that project FSAR and other commitments are
adequately implemented (including M&TE for both construc-
tion and operations support - construction acceptance
' tests, preoperational tests, startup and operations).
This
item is discussed in Section 3.g.(2)(e) of this report,
and it requires further action.
b.
G8 Program Assessment.
This section of Appendix G is generally
acceptable, pending further action to resolve Violation
424/86-77-01 and UNR 424/86-77-02 mentioned above.
3.
Unacceptable:
There were no unacceptable findings.
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1.
Purpose and Scope of Review
The purpose of this evaluation was to determine if the results of the
program review of Measuring and Test Equipment (M&TE) presented in
Appendix G, are an effective and accurate assessment of construction
requirements, and that these requirements have been properly implemented.
It is noted that the scope of Appendix G applies only to M&TE used during
construction, and does not cover the overall M&TE program.
Appendix G does
not include M&TE used for construction acceptance testing, preoperational
testing, startup and operation.
Throughout this report the terms " Measuring and Test Equipment (M&TE)" and
the "M&TE program" apply to items requiring calibration and control,
including certain tools, equipment and actual measuring and test
equipment.
The review consisted of an examination of e_ach section of Appendix G and
was performed by reviewers assigned from the NRC Office of Inspection and
Enforcement (IE) and from NRC Region II.
The following is a list of the
sections of Appendix G:
G1
Scope
G2
Responsible Organizations
G3
Commitments and Implementation
G4
Program Description
G5. Audits
G6
Program Changes
G7
Verification of Project Measuring and Test
Equipment Control Program
.G8
Program Assessment.
Appendix G sections G1, G2, G4, G5, G6 and G8 presented licensee data on
the scope, responsible organizations, program descriptions, audits, changes
and conclusions regarding assessment of the Appendix.
These did not
require the review depth given to sections G3 and G7 which covered licensee
commitments and implementation, and Appendix verification.
The review of Appendix G included an examination of content; review of
findings, concerns, and observations; review of a sample of items reviewed
by the Georgia Power Company (GPC) Readiness Review Team (RRT); and an
examination by NRC/IE of an independently selected sample of records and
hardware critical elements.
The methodology used, and evaluation of each
section is provided in the discussion which follows.
2.
Methodology
a.
IE Review
The review and evaluation by the NRC Office of Inspection and
Enforcement (IE) focused on verification of the project M&TE
control program, which is described in Section 7 of Appendix G.
The purpose of the verification was to determine whether procedures
and practices in use at the Vogtle Electric Generating Plant (VEGP)
have met project commitments in this area.
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The IE evaluation was accomplished by on-site inspection during
the week of August 4-8, 1986.~ Activities included a review of
Section-7 for content and completeness, a review of relevant findings
and licensee corrective actions, and an examination of components
which comprise portions of the Georgia Power Company (GPC) and Pullman
Power Products-(PPP) measuring and test equipment programs.
The primary emphasis of the evaluation was on " critical elements"
within the Measuring and Test Equipment-(ETE) control systems.
A
critical element is that essential to the design, con:truction or
operational readiness of a safety-related structure, system or
component.. For purposes of this evaluation, the critical elements'.
were those items of construction MTE judged most crucj 31 to safety.
A sample of 26 of these critical construction M&TF elements was
selected for inspection as shown in Table 1.
TN 26 items include a
representative selection of critical elements ;or the major technical
disciplines involved in the construction MTE for Vogtle Unit 1.
This critical element sample was inspected for compliance with FSAR
requirements, and applicable codes and standards.. Relevant site
procedures and associated documentation were also reviewed. The
selection of critical elements was made based upon component func-
tion, and application to discipline construction activities. The
components selected represent an independent sample and were not
examined by the applicant during his RRT review of Appendix G.
,
b.
Region II Review
Review and evaluation by the NRC Region II evaluation team consisted
of an examination of each section of Appendix G.
The initial techni-
cal review was conducted in the Region II office during the week of
May 5, 1986, followed by on-site inspection activity during the weeks
of May 12-16 and June 2-6, 1986. An additional review of audits was
performed at the GPC corporate office in Atlanta on May 28, 1986.
On-site inspection included the program review by examination of
records, procedures and program description. The NRC inspector
examined a limited sample of records reviewed by the GPC Readiness
Review Staff (RRS) and an independent sample to examine various
findings and corrective actions.
The inspector reviewed procedures
and commitment implementation by Georgia Power Company, Pullman
Power Products, and Nuclear Installation Services Company (NISCO).
Records sampled during this review were limited to GPC records.
Audits relating to MTE programs for GPC and the two contractors
were reviewed and findings examined. The detail and depth of the
audit working checklists were reviewed.
3.
NRC Staff Evaluations
The evaluation of each Appendix section is provided in the following
discussion, using a section by section format which references the
applicant's Appendix G' Readiness Review Report.
Included are a description
of the section, what was reviewed, the basis for acceptance, and a state-
ment of any required follow-up or evalustion.
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.a.
'Section G1.0 - Scope
(1) Introduction and Section Evaluation
This section provides a description of the intent and content of
Appendix G.
The section discussed the boundaries to which M&TE
was evaluated by the applicants Readiness Review Team (RRT).
-Appendix G provided a description and evaluation of the programs
governing the control of M&TE utilized during construction
activities at the Vogtle Electric Generating Plant.
The M&TE
programs for GPC, PPP, and NISCO were described and evaluated.
Other-onsite contractors utilized GPC's calibrated equipment for.
determining inspection acceptance of construction activities.
Appendix G states that the nuclear operations M&TE program is
addressed in modules 3A, 5, 7, 9A, and 98.
The time period
involved in this evaluation by GPC was from early 1977 to
December 31, 1985.
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(2) Inspection Results
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This section was reviewed for background information only.
No
follow-up or evaluation of this section of Appendix G was
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required.
However, it was noted, on reviewing the interface
with operations M&TE, that specific evaluation of M&TE in
modules 3A, 5, 7, 9A and 98 was either not covered or only
generally mentioned, without information on actual M&TE hardware
inspections. This requires attention beyond the scope of
Appendix G.
b.
Section G2.0 - Responsible Organizations
(1) This section described the various construction organizations
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responsible for M&TE activities within the scope of Appendix G.
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GPC had overall quality responsibility for work performed at
VEGP including the M&TE program.
PPP products and NISCO each
maintained M&TE programs which were reviewed by the GPC Quality
Assurance (QA) organization.
This section also identified
contractors which utilized the GPC calibrated equipment.
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(2) Inspection Results
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This section was reviewed for background information. No follow-
up or evaluation of this section was required.
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c.
Section G3.0 - Commitments and Implementation
(1) Introduction and Section Evaluation
This section of Appendix G contains a listing of commitments
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and implementing documents which are displayed in two matrices.
The first is entitled, " Commitment Matrix" and presents a com-
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prehensive listing of commitments by the Georgia Power Company
for Vogtle 1 along with a source document reference for each
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commitment.
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The second'is entitled, " Implementation Matrix" and presents a
listing of source documents and requirement features referenced
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to within each commitment along with a document reference where
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the features have been implemented. The Region II review focused
on verifying that Vogtle's licensing commitments;and implementing
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documents comply with FSAR, Regulatory Guides, and Industry Codes
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and Standards.
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(2) Inspection Results
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The appendix appeared to adequately list commitments which
support an acceptable calibration program. Additionally,
commitment implementation was generally adequate.
However,-
several. inconsistencies or inaccuracies were identified by
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Region II, most of which involve earlier Revision 0 procedures.
- (a) Commitment 2911.09-07 - Records and Documentation
The implementation matrix references GD-A-04, Calibration and
Control, Revision 0, Section 9.1.10, for GPC.
This section does
not exist in this revision.
Section VI, Revision 0, delineates
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that calibration certification be forwarded to the document
control supervisor.
Further reference is not made to record
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storage, indexing, identification, etc.
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The implementation matrix for PPP references MTE procedure
XII-2, Calibration of Tools, Measurements, and Test Equipment,
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dated February 12, 1979, Section 10.3, as implementing this
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commitment on records and documentation.
This section does not
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exist in the procedure. Additionally, Section 3.3.1 requires
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that an equipment calibration record, Form 3,'be maintained.
This does not meet the extent of the commitment listed in the
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matrix. A revision dated July 19, 1982, references procedure
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XVII-1, QA Records, which would satisfy this requirement.
This
records procedure was' effective during the June 1979 period, but
was not referenced in the MTE procedure.
In both cases (GPC and PPP) adequate controls existed for
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calibration documentation in QA records procedures effective
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during this time period'although not accurately addressed in the
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implementation matrix.
The QA records control commitments,
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ANSI N45.2.9, Draft 11, Revision 0, was addressed more
adequately and appropriately in Appendix D of Readiness Review,
Document Control.
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(b) Commitment 4961.0 - Identification of Types MTE Controlled by
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Each Procedure
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The GPC matrix references GD-A-04, Calibration and Control,
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Sections III.C.1 and V.B.1 for Revision 0.
Section III.C.1
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requires a supervisor to submit to Document Control Center (DCC)
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a list of all M TE used by his personnel.
Section V.B.1
references an inventory control log which identifies all MTE
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utilized by construction.
Revision 11 of GD-A-04, Section
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5,4.1.8 requires that a calibration procedure be assigned for
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all new ETE,-if available, or one written. This implies.
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interpretation of this commitment to be both generic and.
specific.
In the earlier revision, all equipment controlled by.
the general ETE procedure, GO-A-04, were listed. The current'
revision implies identification of specific calibration
. procedures for each piece of equipment.
Discussions with readiness review personnel resulted in a-
generic interpretation which was implemented by the scope
(Section 1.0) of each procedure.
For example, in Rev. O, the
scope states that the procedure establishes and defines
methods "... for all ETE used for testing, inspecting, and
maintaining safety-related structures of nuclear power plants."
The scope becomes more definitive as GD-A-04 is revised, to the
point of indicating MTE used to verify conformance to design
specification requirements for Units 1 and 2.
If the generic
interpretation is accepted, then Section 1.0, Scope, should be
referenced and consistently interpreted through all procedure
revisions.
The procedures for PPP and NISCO have similar discrepancies with
regard to this commitment.
The later revision of PPP procedure
XII-2 refers to specific calibration instructions for individual
MTE while the referenced section in the earlier revision does
not address the commitment. The NISCO ETE procedure, ES-140,
Calibration and Control of Measuring and Test Equipment, does
not address this commitment in either the earlier or later
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revision sections referenced.
(c) Commitment 4962.0 - Calibration Procedure Used for Each Type
of ETE
The PPP implementation matrix references the ETE Procedure, XII-2
dated February 12, 1979, Section 6.2.D.
This section does not
exist in this procedure.
Section 4.0 of MTE Procedure, XII-2
lists specific calibration requirements for ETE, but no
calibration procedures were in use at that time.
In conclusion, the inaccuracies and inconsistencies noted under
3.c.(2)(a), (b) and (c) above do not appear to represent a
significant program failure nor compromise the quality of the
VEGP E TE usage during plant construction.
Document control and
QA records procedures identified calibration reports as QA
records and provided adequate controls.
Equipment calibrations
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were performed with the manufacturer's instructions and require-
ments specified in their procedures.
Deficiencies in initial
procedures revisions were identified and commitments adequately
met in the most recent procedures.
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Follow-up or additional evaluation for Section G3.0, other than
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noted above, was not required.
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e d.
Section G4.0 - Program Description
(1) Introduction and Section Examination
This section of Appendix G provided a description of three M&TE
programs used on site, GPC, PPP, and NISCO. -It also provided a
description of the procurement method for calibration services
and equipment from approved vendors.
The section was examined by Region II for content, background
a
for the review of later sections, and accuracy of the information
presented. The M&TE control program includes the following
activities:
I
Procurement of calibration equipment and services.
Equipment control and tracking.
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Calibration and recalibration.
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Out of calibration reporting and resolution.
Storage of documentation.
(2) Inspection Results
The evaluation did not disclose significant errors or a basis
for programmatic concerns.
However, several discrepancies were
identified and are detailed in the discussions which follow.
(a) Region II noted that activities involving record storage were
referred to the QA record storage procedure for the present
program and they were not addressed in the Revision 0 proca-
dures. Activities not adequately addressed in initial procedure
revisions were generally identified as audit findings and
incorporated into later revisions.
(b) During the applicant's evaluation of the section, several
findings were identified.
These findings and resolutions
involving evaluation and program changes are detailed in the
discussions which follows.
Finding G.15, Level II, addresses procurement of calibra-
tion services from unapproved vendors.
An initial review
identified 101 vendors whose qualifications were question-
able.
Ten of these vendors were on the Qualified Supplier
List.
The remaining vendors or equipment were evaluated
and placed in the following categories.
Category C -
Suppliers not evaluated.
Equipment
calibrated by these suppliers has been
recalibrated by a qualified supplier of
GPC.
Recalibration certificates include
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"as received" conditions of equipment thus
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eliminating the need to qualify the original
calibrator.
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Category D'-
Suppliers evaluated by an audit' performed
by Bechtel Power Services (BPS) Quality
Assurance Lead Auditors. Audit based on
applicable elements of 10 CFR 50, Appendix B.
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Category E -
Suppliers'did not require evaluations.
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Bases for this category include:
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- Supplier did not perform calibration
- No "Q" Application
- Federal / State Agency
Region II reviewed the equipment calibration records of 10
of the vendors identified in Category C, or approximately
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25 percent of this category.
Of these 10, 3 were
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dispositioned other than as stated in the response.
These
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inaccuracies did not connromise the work performed by this
equipment, but did indit te a need for the licensee to
reexamine the data in this category.
Examples of these
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discrepancies are as follows:
- Consolidated Devices was dispositioned as recalibrated
by GPC.
Records indicate these torque wrenches were
not used onsite.
After several attempts to calibrate
,
the wrenches and repeated inability to accurately
calibrate, these wrenches were released for availa-
bility offsite.
- E. Phil Harris was dispositioned as recalibrated by
Gage Labs, Incorporated.
No documentation was
identified in the records of a Gage Lab calibration.
This three-foot survey rod was broken with no
recalibration possible.
- Thread Forms, Incorporated was dispositioned as
recalibrated by Pittsburg Testing Labs (PTL). These
plug thread gages were recalibrated by Gage Labs,
Incorporated according to calibration certificates
on file.
In Category D, the inspector reviewed 17 of 28 audit
,
reports which qualified vendors.
Of 33 audits performed, 5
were rejected and required Category C disposition. The
audit group based acceptance on two requirements, and
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possession of either requirement qualified a vendor in
this category. The first factor was the identification of
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an established vendor QA program at the time of procurement
of equipment or services.
The second requirement was
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verifiable traceability to the National Bureau of Standards
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(NBS). The' traceability factor required certifications of
traceability for the individual equipment or service.
Some vendors had no documented QA program, but present .
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~ practices were evaluated by a checklist of items which, if
satisfied, would indicate an adequate, controlled,.calibra-
tion program.
Determination of an adequately controlled
calibration program currently utilized by the vendors
provided a. degree of reenforcement for qualifying vendors
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within this ' category.
This root cause for this use of unapproved vendors was;
attributed to a discrepancy between the'GPC field procedure
GD-A-04, and the Vogtle Procurement Policy and Procedure
Manual (VPPPM).
The field procedure required calibration
vendors to be on a Qualified Supplier List (QSL) and the
VPPPM did not. The VPPPM Revision 3,' incorporates require-
ments for M TE vendors supplying calibration to be on an
approved vendor list.
The corrective measures appeared
adequate to prevent reoccurrence of this issue.
The NRC
inspector reviewed a sample of purchase orders for M TE or.
services since corrective actions were initiated. All
N.
MTE vendors in this sample were on the approved vendors
P
list,
Based on the review of calibration reports and
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audits, the inspector did not identify any impact on
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safety-related equipment as a result of this finding.
Additionally, corrective action appeared adequate to
preclude recccurrence.
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Based upon this information, the present procurement method
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for MTE appears adequate even though these services had
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previously been procured from unapproved vendors.
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Finding G.2, Level II, addressed a lack of trace-
ability to the National Bureau of Standards for
electrical termination tools from AMP Products
Corporation. The licensee identified the cause of
this failure and performed an expanded sample of M&TE
to identify any other existing traceability discrepan-
cies.
Further discrepancies were not identified.
The
AMP corporation provfded documentation establishing
specific tool traceability designated by this finding.
Finding G.3, Level II, identified inadequate calibra-
L.
tion instructions for some M&TE. These instructions
did not state how to perform the calibration.
A
100 percent review by GPC of onsite calibration
instructions resulted in revisions to 67 of 172
calibration instructions.
The inspector reviewed a
sample of calibration instructions and determined
these instructions appeared adequate to perform
calibrations.
Review of calibration reports, by
the inspector, identified that there were not
deficiencies in previous calibrations with regard to
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correct reference standards utilized.
The project
response to this finding appeared adequate.
One noted deviation from the program descriptions was that all
calibrations on site, including those of PPP and NISCO, will be
performed by GPC, who will also be responsible for all site reference
standards.
This program change went into effect at the end of
May 1986. The onsite M&TE programs in effect at the time of the
Region II inspection (May 12-18,1986), appeared adequate and
conformed to the description of Section G4.
Later, during the IE inspection, the consolidation of M&TE calibra-
tion activities for construction was examined and found to be in
operation under direction of GPC.
It was noted that Pullman Power
Products still retains raisponsibility for calibration of automatic
welding equipment and certain temperature recorders.
Discussions
with several onsite users of the consolidated GPC calibration
facility indicated a satisfactory calibration service activity.
In
general, the consolidated GPC calibration activity was considered
acceptable.
Follow-up or additional evaluation of Section G4.0 was not required.
e.
Section G5.0 - Audits
(1) Introduction and Section Examination
This section contained a review of the various audits and
evaluations conducted by GPC and NRC Inspection and Enforcement
personnel and a self-initiated evaluation (SIE) performed by
off project personnel from GPC, Southern Company Services, and
Bechtel Power Corporation.
The section was examined by the inspectors to confirm the
adequacy and effectiveness of these reviews and to assure that
proper reporting methods were observed.
(2)
Inspection Results
Thirty-eight findings were noted during the audits and investi-
gations.
Six findings resulted in changes to procedures and one
significant finding identified untimely recording of nonconform-
ance reports (NCRs) at PPP associated with out-of-calibration
M&TE. The NRC inspector did not identify significant findings
contained in the audits which were not previously addressed in
Appendix G.
The examination did not disclose significant verification errors
or a basis for programmatic concern.
Follow-up or additional
evaluation of Section G5.0 was not required.
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f.
Section G6.0 - Program Changes
(1) Introduction and Section Evaluation
M&TE procedures have been subjected to various changes as the
project design and construction process' accelerated and the
volume of calibration equipment and usage increased. These
changes were required to provide better guidance for M&TE issue,
control, and tracking.
Internal reviews, NRC inspection, and
QA audits identified weaknesses in program implementation.
Corrective action for these weaknesses provided tighter equip-
ment inventory control and improved guidelines for reporting and
evaluating activities associated with identified out-of-cali-
bration equipment.
(2) Inspection Results
Review of the changes indicated M&TE program enhancements with
no reduction in commitments.
No further evaluation or follow-up
of Section G6.0 was required.
g.
'Section G7.0 - Verification of Project M&TE Control Program
(1) Introduction and Section Evaluation
This section describes the Readiness Review process for M&TE
program verification during the Vogtle Electric Generating Plant
construction phase. The purpose of the verification was to
determine whether procedures and practices in use at VEGP have
met project commitments in this area.
A technical appraisal by NRC reviewers of Readiness Review
Module Appendix G is provided below.
The primary emphasis of
the evaluation was on " critical elements" within the Measuring
and Test Equipment (M&TE) control systems as discussed in
paragraph 2.a of this report.
The review, which consisted of an examination of components which
comprise portions of the Georgia Power and Pullman Power
Products M&TE programs was performed by inspectors from the
Office of Inspection and Enforcement in Bethesda, Maryland.
A list which details critical elements stdacted and examined
from the Georgia Power Company and Pullman Power Products M&TE
control systems is shown in Table 1.
(2) Inspection Results
This section provides a technical evaluation by NRC reviewers of
Appendix G activities.
The evaluation consisted of a comparison
of the selected critical elements to the specific technical
requirements detailed below.
Applicant and contractor programs
were evaluated to determine how effectively they implement these
requirements.
Results of the NRC technical evaluation are as
follows:
-12-
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(a) Adequacy of-Standards
Reference standards used by the applicant for calibrating
L
measuring and test equipment shall have the capabilities for
accuracy, stability, and range required for intended use,
l
~ The review'of relevant._ document packages, indicates that~the
applicants reference standards have been purchased and main-
tained in accordance with requirements.
Calibration activities
are traceable to natianal standards and are documented in
4
accordance with approved procedures. The NRC inspector also
reviewed calibration data reports and manufacturer's specifica-
tions and concluded that the reference standards examined.
demonstrate the accuracy and range required to perform their
,
intended function.
~'The' applicant was unable to produce one of the three reference
standards selected for examination. The " AMP" Crimping Die
Calibration Master could not be located at GPC calibration lab
or at the M&TE issue station.
The NRC inspector noted that
records associated with this equipment indicate that it had
never been used to perform calibration activities.
No other. deficiencies were observed in this area.
(b) Environmental Controls
Measuring'and test equipment shall be calibrated'in an environ-
ment controlled to assure required accuracy.
Consideration
-
should be given to items such as temperature, humidity, vibra-
tion, and cleanliness.
The review of applicable calibration records indicates that
,
calibration facility environmental conditions have been con-
'sidered and controlled in accordance with appropriate
.
procedures.
Calibrated temperature and humidity records were
' -
present, and monitored daily by department personnel.
Records,
which reflect calib' ration at off-site facilities, provided
'
objective evidence that environmental controls were in place.
The applicant has effectively implemented program requirements
in this area.
(c) Intervals of Calibration
,
Measuring and test equipment and Reference Standards shall be
calibrated at intervals established on the basis of stability,
purpose, and degree of usage.
Calibration frequencies have been established by the applicant
in " Calibration Instructions." The instructions are unique to
each type of equipment and specify frequencies which are based
(
on industry standards or engineering evaluation. The inspector
reviewed calibration records for the sample of M&TE selected and
noted that the calibration inteevals specified, accurately reflect
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thoseprescribed.inth$applicablecalibrationinstructions.
The inspector also. observed that controls are,in place _to assure
that M&TE will be withdrawn from service prior to. exceeding
specified calibration intervals.
During the examination of documents associated with GPC
Reference Standard'C-1151,'a "Starrett" Master Gauge Block set,-
the NRC inspector noted that the equipment calibration log
7
' incorrectly. specifies a calibration frequency of five years,
instead of annual frequency required by calibration instruction
c
'MRS-2, Revision 1.
This appears to have been a clerical error
and was corrected by GPC personnel during this evaluation.
However, the NRC inspector noted that Revision 1,-of. calibration
,.
instruction MRS-2 which changes the calibration frequency from
five years to annually, was issued on' July 18, 1985 and that
.recalibration of this equipment did not.take place until
October 8, 1985. As a result,'the equipment was beyond the
recalibration date during this period. ~A review of the appli-
cable activity log indicates that the equipment had been used to
calibrate 14 M&TE components during the period between these
dates, but no problem, resulted since the equipment was found to.
be. acceptable at the time of recalbration.
With the exception of the condition identified above, the
applicant has effectively implemented program requirements in
this area.
' '
(d) Calibration Procedures
-
Written procedures shall be prepared and used for calibration of
~ ll measuring and test equipment.
a
The inspector reviewed Georgia Power Company procedure GD-A-04,
entitled " Calibration and Control" and Pullman Power Products
procedure, XII-2, entitled " Procedure for the Calibration of-
Tools, Measurements, and Test Equipment." These procedures
establish basic requirements for_ calibration of M&TE at the
.
Vogtle site. The content of the procedures appears adequate to
'
assure control of M&TE calibration' processes. The inspector also
reviewed some 20 GPC calibration instructions.
These instruc-
tions have been developed to give specific guidance for calibra-
tion of various M&TE components.
The inspector observed that
calibration instructions had been developed for each of _the
M&TE categories at site and are referenced in the equipment
calibration folders. The instructions appear thorough and
provide a step by step description of calibration activities, as
well as specific technical requirements which include
calibration points, environmental and accuracy requirements.
No deficiencies were identified in this area.
.
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, e) Records
(
The applicant shall maintain records which provide objective
evidence that calibration schedules are complied with and that
'
- the accuracy of equipment is being maintained.
.
The review of document packages associated with the selected
MTE sample, indicates the applicants program provides an
effective-record of calibration activities.
Calibration logs,-
4
issue logs, activity sheets, and reference material were
included in MTE component packages.
These documents appear to
provide an accurate and thorough record of MTE history,
present location, calibration interval, reference to calibration
procedure, actual calibration values, and corrective actions
where required.
Records are maintained in locked, fire-rated
cabinets and access is limited to authorized personnel.
During the review of document packages and inspector identified
a' number of files containing a memo which had been used to
provide a " Conditional Release" for MTE which did not meet
'
program requirements. The use of a memo as a " conditional
release" is not-in accordance with site requirements, and does
not provide a effective method of tracking equipment deficien-
cies.
This condition was observed in the following M TE and
reference standard (RS) packages.
Flow Test Orifice Tube C-4230 MTE
Master _ Guage Blocks
C-1151 RS
During the review of records associated with " Gold Track II"
automatic welders the NRC inspectors noted that activity logs or
other records of usage had not been meintained.' The automatic
welders are part of the Pullman Pow w Products M TE program and
are controlled in accordance with the requirements of Pullman
. Procedure X-II.
The failure to maintain an activity log or
other usage reccrd for this equipment represents a deficiency
in that evaluation of prev <ous work could not be accomplished.
-As a result of this observation the inspector reviewed document
packages associated with each of the 13 automatic welders used
by Pullman at the Vogtle site.
The review indicates that three
of the welders exhibited an "Out-of-Tolerance" condition.
This condition was identified by Pullman on appropriate
documents and subsequently evaluated as " acceptable" by site
engineering.
However, corrective action to provide for
activity log or other records of usage was not taken.
'
As a result of the NRC inspector's observation, this matter was
>
documented in NRC inspection report 50-424/86-77, and further
action was required.
In addition, a question was raised as to the licensee's program
to ensure that project regulatory commitments, particularly
regarding the overall MTE program, are adequately implemented.
Additional information is required concerning the overall MTE
program (for both construction and operations) and the Quality
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Assurance program specified for the program.
The NRC inspector
- identified this as Unresolved Item (UNR) 424/86-77-02," Quality-
<
Assurance for Measuring and Test Equipment."
(f) Labelina
Measuring and test equipment shall be labeled to indicate
identification, date of last calibration, by whom it was cali-
brated,-and when the next calibration is due.
The physical inspection of the selected sample of reference
standards and M&TE indicates that these components have been.
labeled in accordance with requirements.
Label information,-
such as. identification, calibration date, and. calibration due
. date, was found to accurately reflect the data on associated
I
calibration records.
!
l
The applicant has effectively implemented program requirements
in this area.
h.
Section G8.0 - Program Assessment
(1) Introduction and Section Evaluation
This section provided a summary of open corrective actions,
a quality assurance statement, resumes, a statement by the Vice
President of Project Construction, and a statement by the
Readiness Review Board.
.
(2) Inspection Results
The material submitted is generally acceptable, but further
action is required to cover corrective action for-the program-
deficiency mentioned under 3.g.(2)(e) and identified in NRC
Inspection Report 50-424/86-77 regarding the lack of activity
logs or other usage records for automatic welding machines.
.
Also, further action is required to assure that other project
'
commitments are adequately implemented (including M&TE for
operations support - construction acceptance tests, preopera-
tional tests, startup and operations).
4.
NRC Staff Findinas
,
The following findings were identified during the NRC evaluation of
Appendix G.
With the exception of item a, each of the deficiencies noted
is considered to have minimal safety significance.
a.
Deficiency (Violation 424/86-77-01) - M&TE Activity Logs - Failure to
maintain equipment activity logs or other usage records for Pullman
Power Products automatic welding machines.
Reference section
3.g.(2)(e) of this report for details.
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b.
Commitment Reference - Project Commitment 2911.01-07 is inaccurately
referenced in the Appendix G, " Implementation Matrix." Reference
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section 3.c.(2)(a) of this report for details.
c.
Commitment Interpretation - Project Commitment 4961.0, is inconsis-
tently. interpreted in site implementation procedures.
Reference
section 3.c.(2)(b) of this report for details.
d.
Commitment Reference - Project Commitment 4692.0, is inaccurately
referenced in the Pullman Power Products " Implementation Matrix."
Reference section 3.c.(2)(c) of this report for details,
Lost Reference Standard - (GPC) Reference Standard C-3454, an " AMP"
l
e.
Crimping Die Calibration Master could not be located by the licensee.
Reference section 3.g.(2)(a) of this report for details.
f.
Calibration Records - The calibration log for (GPC) Reference
Standard C-1151 details a calibration frequency which differs from
the frequency specified by applicable procedures.
Reference section
3.g.(2)(c) of this report for details.
The actions taken by the licensee regarding the above items were found to
be satisfactory, except for item 4.a above, which was documented by NRC
Inspection Report 50-424/86-77 and requires further action.
Also, NRC inspection report 50-424/86-77 described an Unresolved Item (UNR)
424/86-77-02 regarding a question concerning the operational MT&E program
to ensure that project FSAR and other commitments are adequately imple-
mented. This matter required further action.
5.
Statement ~of Module Acceptability (Conclusions)
Based upon the review provided within the scope of this appendix, the NRC
Staff has reached the following conclusions with regard to Measuring and
Test Equipment activities at Vogtle Electric Generating Station Unit 1.
~
With the exception of those items specifically detailed in previous sections
of this report, the following areas of Appendix G have been determined to
-
be " Acceptable."
l
G1
Scope - The scope, content, and interface between Appendix G and other
modules, as detailed in Section G1 were reviewed and found to provide
i
a comprehensive and accurate program overview for Appendix G.
However,
specific evaluation by GPC of M&TE for operations in Modules 3A,
l
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5, 7, 9A and 98 was either not covered or only generally mentioned,
without information on actual M&TE hardware inspection.
G2
Responsible Organizations - The description of organization and
responsibilities for project activities as detailed in Section G.2
was reviewed and found to be accurate and thorough.
G3
Commitments and Implementation - The commitments as detailed in
Section G3 were reviewed and found to be complete.
With the
exception of the deficiencies identified in section 3.c for
commitments 2911.01-07, 4961.0, and 4962.0, the licensing commit-
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ments and implementing documents were determined to be in compliance
with FSAR, Regulatory Guides, and applicable industry codes and
standards.
'
G4,
Program Description - Section G4 details the M&TE programs imple-
mented on site and also provides a description of the method used
for procurement of.calitration services from off site vendors.
These
areas were reviewed,-and with the exception of the NRC staff comments
provided in Section 3.d.(2)(b) of this report, were determined to be
in accordance with requirements.
G5
Audits - The overview provided in section G5 represents an accurate
and thorough presentation of GPC, and NRC audit and evaluation findings.
Also discussed are results from the licensee's self-initiated evaluation
(SIE).
G6
Program Changes - Section G6 describes the various procedural changes
which.have been implemented during the course of construction activity.
~The review of this area indicates'that these changes are prudent and
have provided better guidance for M&TE issue, calibration, control,
and tracking.
Based upon the NRC staff evaluation the following areas have been deter-
mined to be " Conditionally Acceptable":
G7
Verification of Project M&TE Control Program - The NRC staff review
.
of Section G7 consisted of an overview of the licensee's evaluation,.
(
and a separate evaluation of selected " Critical Elements." In
general, the review indicates that licensee's M&TE programs have been
effective and comply with project commitments in this area.
However,
the NRC review resulted in the identification of a program-deficiency
with regard to the lack of activity logs or other usage records, and
the failure to take corrective action to provide for appropriate
usage records for Pullman Power Products, autamatic welding machines.
This deficiency is discussed in detail in Section 3.g.(2)(e) of this
report and was documented by NRC Inspection Report 50-424/86-77,
Violation 424/86-77-01.
It will require additional licensee attention
and NRC review prior to full acceptance of Appendix G.
In addition, Unresolved Item (UNR) 424/86-77-02 regarding a question
concerning the overall MT&E program to ensure that project FSAR and
_
other commitments are adequately implemented (including M&TE for both
construction and operations support - construction acceptance tests,
preoperational tests, startup and operations) requires further action.
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G8
Program Assessment - Section G8 is considered reasonable, pending
further action to resolve the deficiency and unresolved item
mentioned above and documented by NRC Inspection Report 50-424/86-77.
,
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V0GTLE ELECTRIC GENERATING PLANT UNIT l'
READINESS REVIEW PROGRAM-
-MODULE APPENDIX G-
MEASURING AND TEST EQUIPMENT
'
' REFERENCES'
LVogtle Electric Generating Plant, Readiness Review, Appendix G, Measuring and
Test Equipment.
March 11, 1986, letter from D. O. Foster,. Vice President, .Vogtle Project,
Georgi- Power Company forwarding Appendix G for NRC evaluation.
March 31, 1986, letter from D. O. Foster forwarding corrections to Appendix G.
- NRC Inspection Report No. 50-424/86-38 covering inspections conducted on May
12-18 and June 2-6.-1986.
NRC Inspection Report No. 50-424/86-77 covering inspection conducted on August
4-8, 1986.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
~ READINESS REVIEW PROGRAM'
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT
TABLES
1.
Vogtle M&TE Critical Element Inspection Sample
2.
Pullman Automatic Welders
4
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V0GTLE ELECTRIC GENERATING PLANT UNIT-1
READINESS REVIEW PROGRAM
MODULE APPENDIX G~
MEASURING AND TEST EQUIPMENT:
'
TABLE 1
'
V0GTLE M&TE CRITICAL-ELEMENT INSPECTION SAMPLE
Discipline
Critical Element
Identification-
Procedure
Electrical /
Insulation Tester
C-2084
M&TE-I-033
'
_ Digital Multimeter
C-2089
M&TE-I-063
Hi-Pot Insulation
C-3694
M&TE-I-082?
Tester.
Hand Crimping _ Tool
C-3913
M&TE-I-087
Amprobe Volt / Amp /0hm
C-4729
M&TE-I-093
Meter
Mechanical
Dial Calipers
C-4469
M&TE-I-017
Pressure Guage
C-1150
M&TE-I-018
Torque Wrench
C-3208
M&TE-I-027
Micrometer-
C-4456
M&TE-I-028
Hardness Tester
C-3193
M&TE-I-062
,
Flow Test Orifice Tube
C-4230
C-CI-60
Gas Flow Meter
C-4051
M&TE-I-090
Welding /
Mag. Particle Tester
NDE-13
M&TE-I-023
U. T. Machine
NDE-24
M&TE-I-039.
Dry Film Guage
C-4689
M&TE-I-096
C-0824
M&TE-I-049
Analyzer
Civil /
Bolt Tensioner
C-1508
M&TE-I-025
Structural
Sling Pyschrometer
C-2252
C-CI-28
Slump Cone
C-0901
C-CI-40
,
Windsor Probe Test System
C-2408
M&TE-I-065
4
Reference
Guage Blocks
C-1151
Standard 2
Standards
Micrometer Standard
C-2140
Standard 15
Crimping Fixture
C-3454
Standard 16
Welding
Automatic Welder
B-26-4
X-II
Automatic Welder
B-26-10
X-II
Temperature Recorder
B-13-9
X-II
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
READINESS REVIEW PROGRAM
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT
TABLE 2
PULLMAN AUTOMATIC WELDERS
Pullman ID-
Manufacturer
Model
Comments
B-26-1
Dimetrics/ Gold Track
ETW-F
B-26-2
Dimetrics/ Gold Track
ETW-F
B-26-3
Dimetrics/ Gold Track
ETW-F
B-26-4-
Dimetrics/ Gold Track
ETW-F
(1)
B-26-5
Dimetrics/ Gold Track
ETW-F
B-26-6
Dimetrics/ Gold Track
ETW-F
(2) DR 10802
B-26-7
Dimetrics/ Gold Track
ETW-F
(2) NCR 6214
B-26-8
Dimetrics/ Gold Track
ETW-F
(2) NCR 6213
i
B-26-9
Dimetrics/ Gold Track
ETW-F
.
.
L
B-26-10
Dimetrics/ Gold Track
ETW-F
(1)
B-26-11.
Dimetrics/ Gold Track
ETW-F
B-26-12
Dimetrics/ Gold Track
ETW-F
B-26-13
Dimetrics/ Gold Track
ETW-F
NOTES
(1) The initial NRC inspection sample included Pullman automatic welders
B-26-4 and B-26-10.
(2) Pullman Automatic welders B-26-6, B-26-7, and B-26-8 were found to be
out-of-tolerance during calibration.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
READINESS REVIEW PROGRAM
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT
LIST OF PERSONS CONTACTED
Name
Organization / Activity
C. Gardner
GPC/ Technical Support
M. Googe
GPC/ Construction
E. Groover
GPC/ Quality Assurance
C. Hayes
GPC/ Quality Assurance
H. Kattegat
G. McCarley
GPC/ Construction
R. McManus
GPC/ Readiness Review
T. Mitchell
GPC/ Corporate QA Auditor
R. Pinson
GPC/ Construction, V.P.
P. Thomas
GPC/ Mech. QC
P. Kyner
Bechtel/ Lead Auditor
F. Marsh
Bechtel/ Project Engineering
.D. Sanderfer
Bechtel/ Readiness Review
R. Sommerfield
Bechtel/ Readiness Review
R. Mehghi
Westinghouse /Elec. Technician
L. Moiser
Westinghouse / Engineering
E. Owens
Westinghouse / Engineering
D. Walker
Westinghouse / Engineering
J. Baxley
Pullman Power Products /M&TE
V. Miller
Pullman Power Products /QA
T. Murray
Pullman Power Products / Tool & Tage
H. Tucker
Pullman Power Products / Welding
L. Barton
Cleveland Consolidated / Quality Concern
B. Skinner
Ingalls/Mosher Steel /QC
H. Schadel
Walsh Construction / Engineering
,
J. Pruitt
NISC0/ Field QA/QC
W. Crestsinger
flISC0/ Lead Engineer
H. Livermore
ilRC/ SRI-C
J. Rogge
ilRC/ SRI-0
R. Schepans
flRC/RI
Other licensee employees contacted included construction craftsmen, engineers,
technicians, operators, mechanics, security force members, and office
personnel.
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1
READINESS REVIEW PROGRAM
MODULE APPENDIX G
MEASURING AND TEST EQUIPMENT-
,
,
,
BPS
Bechtel Power Services
DCC
Document Control Center
Final Safety Analysis Report
GPC-
Georgia Power Company
NRC Office of Inspection and Enforcement
Measuring and Test Equipment
N8S
National Bureau of Standards
-Nonconformance Report
NISCO
. Nuclear Installation Services Company
NRC-
U.S. Nuclear Regulatory Commission
PPP
Pullman Power Products
Quality Assurance
Qualified Supplier List
Readiness Review Staff (GPC)
.RRT
Readiness. Review Team (GPC)
RS
Reference Standard
SIE
Self-Initiated Evaluation
Unresolved Item
VEGP-
Vogtle Electric Generating Plant
VPPPM
Vogtle Procurement Policy and Procedure Manual
-25-
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