IR 05000333/1986008

Insp Rept 50-333/86-08 on 860602-06.No Violation or Deviation Noted.Major Areas Inspected:Tech Spec Surveillance Testing & Calibr Program,Calibr of safety-related Instruments & Measuring & Test Equipment Program

ML20211K954
Person / Time
Site:	FitzPatrick
Issue date:	06/24/1986
From:	Chaudhary S, Jerrica Johnson, Denise Wallace NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211K951	List: IR 05000333/1986008 ML20211K947
References
50-333-86-08, 50-333-86-8, NUDOCS 8607010026
Download: ML20211K954 (9)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-08 Docket N License N DPR-59 Licensee: Power Authority of the State of New York P.O. Box 41 Lycoming, New York 13093 Facility Name: James A. Fitzpatrick Nuclear Power Plant Inspection At: Scriba, New York Inspection Conducted: June 2-6, 1986

Inspectors: [ tar &#t/. hem 2 3,198G S. K. C7iaJdFiary,4.ead Reactor Engineer (/ date YMWWc-c M< 23 D. T. Wallace, Reactor Engineer date~ /986 Approved by: * k2Vl80 J. Johnson, Chief, Operational Programs date Section, 08, DRS Inspection Summary: Inspection on June 2-6, 1986 (Report No. 50-333/86-08)

l Areas Inspected: A routine unannounced inspection by two region-based inspectors

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of the Technical Specification surveillance testing and calibration program; calibration of safety-related instruments; and the measuring and test equipment

] control progra Results: No violations or deviations were identified.

8607010026 860625 PDR ADOCK 05000333 G PDR

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. DETAILS 1.0 Persons Contacted

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New York Power Authority

, *R. Converse, Resident Manager

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• Fernandez, Superintendent of Power

! *D. Lindsey, Operations Superintendent

• R. L. Patch, Quality Assurance Superintendent

• J. P. Flaherty, Assistant Instrumentation & Control Superintendent

• J. H. Kerfein, Quality Control Supervisor U. S. Nuclear Regulatory Commission A. Luptack, Senior Resident Inspector

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In addition to the above, the inspectors contacted, and held discussions with other licensee personnel (including engineers, supervisors, and con-trol room R0s and SR0s) during the course of this inspectio * indicates those present at the exit meeting held on June 6, 198 . Surveillance Testing and Calibration Control Program The inspector reviewed documentation to ascertain whether the licensee had developed and effectively implemented programs for surveillance testing, calibration, and inspections required by section 4 of the plant Technical Specification (TS). The program for calibration of other safety-related j; instrumentation, not covered by TS, was also examined for adequacy and l effectiveness. The inspector interviewed and held discussions with licen-

see personnel and cognizant plant management to assess their knowledge and

understanding of the program requirements, and to review responsibilities i

i assigned to various departments and sections of the licensee's organization.

! 2.1 Program Review

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The inspector reviewed the licensee's management controls for Instrumenta-tion and Control (I&C) calibrations. The I&C surveillance computer system is used to store and track instrument calibration surveillance informatio This information includes the last date that a surveillance was performed, the date of the next required surveillance, the latest possible date that this surveillance can be performed, the procedure number, the base number l of days between calibrations and the amount of time used as a " cushion" to determine the latest allowable date for calibration.

The inspector verified that access to the program is controlled by the I&C supervisor, who alone possessed the program access code. The same I&C .

supervisor is responsible for entering data into the syste The computer

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program has several features which minimize the possibility of introducing mistakes while entering data that would be carried into the next calibra-I tion period. Spot checks are also performed periodically by the I&C de-partment as well as formal audits by Quality Assurance. These audits fur-ther ensure that calibration frequencies and other data are correct as stated on the computer program output The inspector also witnessed a mock-up change to the computer program which involved a proposed TS change and the associated calibration frequency change that would need to be reflected in the I&C program. New surveil-lance information was inputed into the computer program. The program was then initiated to calculate the next calibration date, the inspector veri-fied that the new calculated dates were correct. The inspector did not observe any difficulties in the performance of the chang '

2.2 Findings Based on the above review, examination, and discussions with cognizant personnel, the inspector determined that: A master schedule for TS calibration and functional testing of instru-mentation and systems was established; the schedule included frequency of each test / calibration and/or inspection, the responsibility for

, implementation, and the surveillance test / calibration status of the item or syste . The responsibility for maintaining and up-dating the schedule was established and assigned by procedur . The current master schedule reflected the TS requirements for such tests and/or calibration, and The responsibilities for review and evaluation of data, reporting and controlling deficiencies, and ensuring the required surveillance test / calibration was satisfied had been established by procedure However, in addition to the above general findings, the inspector specifi-cally noted that the licensee's surveillance test / calibration program ap-peared to be divided in several small parts. The responsibility for imple-mentation of each part was assigned to different organizational units of the plant staff. The program, as a whole, appeared to lack a centralized,

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structured overview and/or direction. Furthermore, the control room opera-tors did not have ready access to information regarding the calibration i

status of installed instrumentation in the control room for which the re-sponsibility was assigned to the I&C department. The inspector informed the licensee that the lack of information regarding the calibration status

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of the installed instruments in the control room was a concern to the l inspector; because, if any instrument covered by TS was not calibrated )

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and/or functionally tested on schedule, the system might have to be de-clared inoperable, and TS action statement had to be implemented. There-fore, without a ready access to this information, control room operators may have difficulty determining the operability of any such syste The licensee acknowledged the inspectcr's above concern and immediately provided a copy of the master schedule and status of such instruments to the control room, and committed to review and evaluate the program to make the information available to the control room in the most efficient and effective manne The inspector further observed that the surveillance test program portion assigned to the operations department was currently undergoing a major change to strengthen controls and oversight. The new procedures in this area were in a review and approval cycle. The inspector reviewed some draft procedures. They appeared to provide more direction, however, other controls were needed to assure accuracy and corrections of schedule up-dates. The licensee management acknowledged the inspector's comment, and .

stated that similar comments had been received in the internal review; therefore, improvements would be made before final approva The inspector had no further questions in this are No violations were identifie :

3. Calibration of Safety-Related Components Not Covered by Technical Specification The inspector reviewed the program description and examined records to determine if calibration requirements had been established for components associated with safety-related systems and/or functions, but that were not specified in the TS and if a master schedule had been developed that in-cluded calibration frequency, rasponsibility for implementation, and the calibration status of each componen The inspector determined that a calibration program had been established for such safety-related components. A master schedule had been developed to show the responsibility, frequency, and the status of calibration for each safety-related component not covered by the Technical Specification, as well as to ensure adequate records were maintaine i No violations were identifie . Surveillance Procedure and Records The inspector reviewed procedures and records to verify that the surveil-lance of safety-related systems and components were being conducted in accordance with approved procedures as required by TS; and also if these procedures were adequate to accomplish the safety intent of the TS require-ment, thus assuring operational safety of the plan .

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t The inspector selected at least two tests from each of the following sys-tems to verify the adequacy of conformance to the above requirements. The tests were randomly selected from the master schedule for surveillance tests. Documents reviewed are listed in section 8 of this repor Systems included were:

Reactivity Control and Power Distribution, Reactor Coolant System, Emergency Core Cooling System,

Containment System, and Plant Electrical Power System.

, 4.1 Findings

! Based on the above review and examinations, the inspector determined that the procedures were adequate to direct and control surveillance testin Procedures included required prerequisites and preparations for test; ac-ceptance criteria; instructions and steps to assure that the system or components were restored to operating condition after the test; and respon-sibilities for review and approval for the test dat Procedures appeared to meet the intent of the TS surveillance testing requirement The inspector also determined that the records maintained for these tests were adequat They showed that the completed tests were reviewed for acceptability of results; met the testing frequency; and were in conform-ance with the TS requirements for the surveillance / test No violations were identifie . Quality Assurance Program for Measuring and Test Equipment The inspector reviewed the licensee's QA program to ascertain if: the pro-gram adequately provided administrative controls over measuring and test equipment (M&TE); the controls provided were in conformance with regulatory requirements, commitments, and industry standard The program review consisted of verification of licensee's commitments in the Final Safety Analysis Report (FSAR) for conformance with regulatory requirements, and review of procedures for adequacy. The inspector deter-mined that the licensee's commitments in the FSAR were generally adequate to fulfill regulatory requirements. The procedures contained criteria and responsibilities for calibration frequency; method for placing in or re-meving equipment from service; and the calibration status of-the equipmen '

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5 The procedures also included methods of documenting calibration history ,

of equipment, including:

Traceability to calibration source,  :

As-found and as-calibrated data, i

Identification of standards used, .

I Identification of calibration procedure used, and its traceability to a national standard, Date of calibration, and

Name of person performing calibratio The procedure also specified that M&TE equipment must have accuracy four ;

times greater than the equipment which was being calibrated. A system, '

very similar to the master schedule used for TS calibration, was in use for controlling the calibration frequency and recall of equipment. Re-quirements for the history of use, and controls to prevent inadvertent use of equipment beyond calibration frequency were also established. The pro- 1 cedure also required an investigation and evaluation of data recorded by

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the M&TE prior to scheduled calibration if the M&T Equipment was found to be out of calibration. The inspector also questioned the responsible I&C supervisor to assess his knowlege and understanding of the program, and found him to be knowledgeabl No violations were identifie .0 Quality Assurance (QA) Department Involvement in Surveillance / Calibration Program The inspector examined documents, and held discussions with QA supervisors and cognizant personnel to assess the understanding of their responsibi-lities 'n this area, and their involvement in the implementation of this progra Based on the above discussions and the examination of QA records, the in-spector determined that the plant QA department performed planned structur-ed program audits. Additionally, QA personnel perform surveillance inspec-tions routinely. The surveillance inspections are not comprehensive, structured inspections, but are limited scope inspections covering indivi-dual items, activities or a small part of the program. These surveillance inspections are designed to verify the overall implementation of calibra-tion and TS surveillance test progra Based on the above examination and discussions, the inspector determined that Quality Assurance management and staff were aware of their responsi-bilities; the planned audits were comprehensive, and were well documente The inspector however, observed the following:

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6 The installed instruments in the plant had calibration stickers affixed on them, but the stickers did not contain the same informa-tion on all plant instruments. Different instruments had different stickers with different data inscribed on them. The inspector had verified earlier in the plant instrumentation calibration program review that stickers were not required by procedure to be affixed to installed instruments; and, because of this absence of stickers the control room operators were unable to ascertain the calibration status of the plant instrumentation. The QA department was aware of these nonstandard stickers but had not taken steps either to get them removed or standardize the sticker program. The inspector informed the licensee that if stickers were needed to indicate instrument status, then they should be standardized by procedures and be con-sistent; or, if they were not needed, then they should be removed to eliminate any confusion and potential misinformation. The licensee management acknowledged the inspector's comments and committed to review and evaluate the oroblem, and adjust the program accordingl The plant Quality Assurance department has performed comprehensive audits and surveillances of the calibration program in the last two years and has identified many weaknesses in the program. Also, an internal appraisal of plant M&TE program was conducted in late 1983 (Report #83-02) which recommended several improvements. However, the plant management has not acted on these recommendations. It appears that the licensee has been somewhat slow in responding to and/or implementing their own recommended improvements and the QA finding The licensee acknowledged the inspector's comments, and indicated that this are would receive additional management attertio 'No violations were identifie .0 Management Meeting

At the conclusion of the inspection, the inspector met with licensee management (identified in paragraph I with a *), at which time the inspectors summarized the purpose, scope, and the findings of the inspection. The licensee acknowledged the inspectors' finding At no time during this inspection, did inspectors provide written material to the license .0 Documents Reviewed / Audited

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Technical Specification, Chapter 17, Section 2.12, Rev. 2, Control of Measuring and Test Equipment

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Technical Specification, Table 4.1-2, Amendment 89, Reactor Protection System (SCRAM) Instrument Calibration Minimum Calibration Frequencies for Reactor Protection Instrument Channel i -

Corporate Audit SA-86-07, 1986, Pertaining to Criterion X (Inspection), '

Criterion XI (Test Control, and Criterion XIV (Inspection, Test and

. Operating Status).

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Documents Reviewed (cont.)

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Technical Specification Sections 4.6-4.12, TD 536, 1985 s

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Procedure for Department Surveillance Tests, Procedure No. AP 4.1, Revisions 4 and 5

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Control of Measuring and Test Equipment, Procedure No. 4.2, l Revision 2

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Instrument Surveillance Test Program, Procedure No. IC50-13, Rev. O, Draft

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Instrument Surveillance Test Audit, Procedure No. ICS0-14, Rev. 0 :

Draft

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Completed Surveillance Tests-S1041-ST-7C, 1985 ,

-S996-ST-90, 1985-S1066-ST-26I, 1985-S997-ST-26M, 1985-S1052-ST-358, 1985 -

i -S1014-ST-398-LLRT, 1985-S1021-ST-39B-LLRT, 1985-S1024-ST-39F-PCILRT, 1985-STD566-ST-76I, 1985 and S1015-ST-76TA, 1985-S1016-ST-76TB, 1985-S1017-ST-76TE, 1985-S1095-ST-OLD, 1986-S1099-ST-028, 1986-51074-ST-03A, 1986 l -S1102-ST-05B, 1986-S1078-ST-073, 1986 i -51086-ST-08H, 1986-S1096-ST-12E, 1986-S1077-ST-26J, 1986-S1091-ST-398-LLRT, 1986-S1101-ST-40J, 1986-S1033-MP-71.14, 1985-S1034-MP71.10, 1985-S1035-MP71.12, 1985 >

-S1048-ISP-20, 1985-S1030-ISP-49, 1985-S1005-ISP-71, 1985-S1060-ISP-1000, 1985-S1044-ISP-1258, 1985-S1071-ISP-175B, 1985-S1103-ISP-5-1, 1986 ,

-S1070-ISP-20, 1985

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Documents Reviewed (cont.)

-S1097-ISP-29, 1986

, -S1100-ISP-75, 1986

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-S1090-ISP-44, 1986 '

-51030-ISP-1008, 1986 l -S1071-ISP-1758, 1986

, -STD 549, 0.T.S Surveillance, 1985

-STD 580, 0.T.S. Surveillance, 1986-STD 558, Criterion XII (Control of M&TE), 1985

-51032, Nine Mile Meteorological Equipment Calibration,1985

-02-3-LT-101A, ISP-201A, 5/1/85

-02-SQRT-152H, ISP-63-1, 4/22/85 1 -03-LS-231B, ISP-66-1, 5/20/86

, -05-PT-14A, ISP-200A, 4/29/85 j -07-RBM-A, ISP-24, 5/27/86-14-DPIS-438, ISP-8, 5/19/86-23-LS-&sA, ISP-75, 5/7/86-27-PT-102A, ISP-4.4, 5/17/86-68-TS-106, ISP-27, 4/17/86-71-500-27-TI-1, ISP-91, 3/17/86-71-600-27AB-1, ISP-90, 3/17/86-76-LI, PI-10 TON, ISP-76, 7/11/85-RPS-EPA-182G, ISP-94, 3/13/86-NYDA Standard Audit #580, 5/30/86-Surveillance Report / Audit #1102, 5/27/86-Surveillance Report / Audit #1101, 5/27/86-Surveillance Report / Audit #1100, 5/13/86-Surveillance Report / Audit #1044, 5/15/86-Sarveillance Report / Audit #1098, 5/9/86 i-Surveillance Report / Audit #1097, 5/12/86-NYPA Standard Audit #558, 9/11/85

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