ML20132C244

Insp Rept 50-416/85-27 on 850729-0802.Violation Noted: Failure to Promptly Evaluate Measuring & Test Equipment Found Out of Calibr

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: ML20132C217 ML20132C233 ML20132C244
References
50-416-85-27, NUDOCS 8509260502
Download: ML20132C244 (11)

See also: IR 05000416/1985027

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SS R$c UNITED STATES

l oq'o NUCLEAR REGULATORY COMMISSION

O3 ^

REGION ll

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101 MARIETTA STREET, N.W.

• 2 ATLANTA, GEORGI A 30323

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! Report No.: 50-416/85-27

i Licensee: Mississippi Power and Light Company

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Jackson, MS 39205

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Docket No.: -50-416 License No.: NPF-29.

Facility Name: Grand Gulf

I Inspection Conducted: uly 21 - August 2, 1985 ..

Inspector:  ::LCV

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] M. F.L Runyan / _Dite signed

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Accompanying Personnel: 'J. H. corman, III, Region II

Approved by: .r . / / [-

G. AF Belisle, W ting Chief ~ D' ate igned .;

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Quality Assurance Programs Section

j Division of Reactor Safety

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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

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and test equipment found out of calibration.

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REPORT DETAILS

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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

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, 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

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action during a telephone ccnversation conducted on August 29, 1985.

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Unresolved Item, Evaluations of Installed Process Instruments,

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paragraph 7.

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The licensee did not identify as propri.etary any of the materials provided

to or reviewed by.the inspector during this inspection.

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3. Licensee Action on Previous Enforcement Matters

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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.

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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:

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Personnel responsible for preparing implementing procedures understand

the significance of changes to these procedures.

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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.

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6. QA/QC Aaministration (35751)

i Reference: 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

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The inspector reviewed the licensee QA/QC. administration program required by

l the reference to verify that activities were conducted in accordance with

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regulatory requirements. The following criteria were used during this

review to determine the overall acceptaoility of the established program:

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Licensee QA program documents identified those structures, systems,

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components, documents, and activities to which the QA program applies.

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• 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.

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Procedures and responsibilities were established for making changes to

these documents.

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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.

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Responsibilities were established to assure QA program review for

overall effectiveness.

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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

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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

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(c) ANSI N18.7-1976, Administrative Controls and Quality

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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:

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A master schedule for surveillance testing and calibration delineated

! test frequency, current status, and responsibilities for performance.

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The naster schedule reflected the latest revisions of the Technical

j Specifications and operating license.

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Responsibilities were assigned to maintain the master schedule

j up-to-date and to ensure that required tests are performed.

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Detailed procedures.with appropriate acceptance criteria were approved

i for all surveillance testing requirements.

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The program defined responsibilities for the evaluation of surveillance

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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:

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l MP&L Operational Quality Assurance Manual, MPL-TOP-IA, Revision 4

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Policy 5 Instructions, Procedures, and Drawings

! Policy 11 Test Control

' 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

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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

Implementation of Surveillance Procedure

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MAR 84-76

06-IC-1E51-0003, Suppression Pool High Water Level,

(RCIC) Functional Test, 5/22/84

MAR 84-78 Implementation of Surveillance Procedure

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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-

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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

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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

completion date, next due date, latest due date (considering grace periods),

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, 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.

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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 06-0P-1000-D-0001

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:

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06-0P-IE22-0-0005 HPCS Quarterly Functional Test, 3/9/85

4 06-IC-1B21-R-0008 Reactor Vessel Water Level, Channel E

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Calibration,

3/12/85

06-OP-1E12-M-0001 LFCS Monthly Functional Test, 5/11/85

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06-IC-IC51-Q-0002 Average Power Range Monitor Calibration, '

1/1/85

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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

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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

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Diesel Driven Fire Pump A Discharge Pressure PI-R008A

Suction Pressure PI-R004A

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Discharge Flow FI-R005

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RHR Pump A Flow FI-R603A and FI-R200A

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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.

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Within this area, one unresolved item was identified. The Operational

Quality Assurance Manual commits to Regulatory Guide 1.33 which endorses

ANSI N18.7-1976. 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

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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

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(b) Regulatory Guide 1.33, Quality Assurance Program

Requirements (Operations), Revision 2

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(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

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for the Installation, Inspection,'and Testing of

Instrumentation and Electric Equipment, August 11, 1972

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(e) ANSI N45.2.4-1972, IEEE Standard, Installation,

Inspection, and Testing Requirements for Instrumentation

and Electric Equipment During the Construction of

, Nuclear Power Generating Stations

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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:

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Responsibility was delegated and criteria established to assign and

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adjust calibration frequency for each type of M&TE.

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An equipment inventory list identified all M&TE used on safety-related

! components, the calibration frequency and standards, and the

calibration procedure,

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Farmal requirements existed for marking the latest calibration date on

each piece of equipnent.

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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

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Written requirements prohibit the use of M&TE which was not calibrated

within the prescribed frequency.

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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.

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The program assured that new M&TE was added to the inventory list and

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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

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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,

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Revision 2

07-5-43-102 Calibration of Mechanalysis Model 308 Sound / Vibration

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Meter, Revision 4

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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

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criteria was clearly stated. A problem concerning the stipulation of

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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.

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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

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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-

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trolled. Personnel in the lab understand the need to allow instrument

temperatures to stabilize prior to performing calibrations. However,

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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.

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