ML20198H372

Responds to NRC Re Violations Noted in Insp Repts 50-348/85-25 & 50-364/85-25.Corrective actions:FNP-O-AP-15 Re Maint,Conduct of Operations & Individual Calibr Procedures Revised

ML20198H372
Person / Time
Site:	Farley
Issue date:	01/15/1986
From:	Mcdonald R ALABAMA POWER CO.
To:	Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8601310014
Download: ML20198H372 (4)

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lll#ch M:lling A'%r:ss Alabama Power Compan/

600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President Fl.ntodge Building g,,,b o< ~,

,1 [ ,= gyg pg.g January 15, 1986 Docket No. 50-348 Docket No. 50-364 Mr. D. M. Verrelli U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 3100 Atlanta, CA 30323

SUBJECT:

J.M. Farley Nuclear Plant NRC Inspection of June 3 - 7, 1985 Re: Report Numbers 50-348/85-25 50-364/85-25

Dear Mr. Verrelli:

By letter dated December 27, 1985, Alabama Power Company (APCo) was requested to resubmit the response to inspection reports 50-348/85-25 and 50-364/85-25. This letter refers to the NRC Notice of Violations dated July 18, 1985, the letter from the NRC to APCo dated October 1, 1985, and the letter from the NRC to APCo dated December 27, 1985.

"The following violations were identified during an inspection conducted on June 3-7, 1985. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1. 10 CFR 50, Appendix B, criterion xvI, and the accepted QA program require establishing measures that conditions adverse to quality are promptly identified and corrected. The accepted QA program comits to Regulatory Guide 1.30 which endorses ANSI N45.2.4 - 1972, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations. Section 2.5.2 of this standard states that an evaluation shall be made concerning the validity of previous tests and acceptability of devices previously tested from the time of the previous calibration when inspection and testing equipnent is found out of calibration.

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Contrary to the above, adequate measures have not been established to assure that these evaluations are properly performed. %e following examples were identified:

b. Contrary to AP-15, Maintenance conduct of Operations, Revision 8, Section 7.4, evaluations were not performed when mechanical measuring and test equipment was found out of tolerance,

c. he timeliness of evaluations perforned by the I&C laboratory was not specified and evaluations were not promptly completed. An informal U me limit of three weeks was in use at the working level but had not been specifically approved by management and does not provide a prompt assessment of safety significance for measuring and test devices found out of calibration.

his informal limit was often exceeded with several evaluations taking about three months to complete.

his is a Severity Level y violation (Supplement I).

2. 10 CFR 50, Appendix B, Criterion II, and the accepted m program require that activities affecting quality shall be accomplished under suitably controlled conditions, including suitable environmental conditions for accomplishing the activity.

Contrary to the above, measures have not been established to assure suitable environmental conditions for calibrating measuring and test equipment.

a. n aperature and humidity indication was provided in the I&C laboratory but not verified or recorded prior to performing environmentally sensitive calibrations.

Acceptance standards for laboratory environmental conditions were not established.

Wia is a Severity Level V violation (Supplement I).

3. 10 CFR 50, Appendix B, criterion XII, and the accepted m program collectively require that measures be established to assure that measuring and testing devices are properly calibrated with sufficient frequency to assure that accuracy is maintained. %e accepted @ program commits to Regulatory Guide 1.33 which endorses ANSI N18.7 - 1972, American National Standard for Administrative Controls for Nuclear Power Plants. Section 5.3.6 of this standard requires that procedures be provided for proper control of measuring and test equipment to confirm the adequacy of calibration frequency. Procedure AP-ll, Control and Calibration of Test Equipment, h st Instrumentation and Plant Instrumentation, Revision 5, Section 4.6.2.2, requires that equipment data obtained from calibration checks be analyzed to optimize calibration check intervals.

Contrary to the abova, adequata menurss hava not be:n established to assure that measuring and testing devices are calibrated with sufficient frequency to assure that accuracy is maintained. Historical calibration records are not maintained and analyzed to confirm the adequacy of calibration frequency. As an example, the Keithley Picoampere Source Model 261 was changed from the vendor calibration frequency of three months to six months without documented justification. Subsequently, the device was found out of tolerance at least twice in two years without reassessment of the calibration frequency.

This is a Severity Level IV violation (Supplement I)."

Reason for Violation With regard to violation 1, part b, this violation was caused by procedural inadequacy in that evaluations have not been routinely performed when mechanical test equipment is found out of calibration.

With regard to violation 1, part c, this violation was caused by procedural inadequacy in that a time limit for out of calibration I&C test equipment has not been specified and evaluations have not been performed promptly.

With regard to violation 2, part a, this violation was caused by procedural inadequacy in that measures have not been established to assure suitable environmental conditions for calibrating I&C measuring and test equipment.

1 With regard to violation 3, this violation was caused by procedural inadequacy. Although INP-O-AP-ll does include a requirement for optimizing calibration frequencies, it does not provide specific guidance for performing this evaluation.

Steps Taken to Avoid Further Violations lb. ENP-O-AP-15, Maintenance Conduct of Operations, and the individual calibration procedures have been revised to require evaluations of mechanical test equipment found out of calibration and to document these evaluations properly. In addition, appropriate supervisory personnel will be trained on these procedures.

1c. fWP-O-AP-ll, Control and Calibration of Test Equipment, ,

l l

i Test Instrumentation and Plant Instrumentation, will be I revised to include an administrative time limit for evaluating 5% of calibration test equipment.

2a. ENP-O-AP-ll and the individual calibration procedures will be revised to require verification and documentation of proper environmental conditions prior to test equipment calibration for equipment that is sensitive to temperature and humidity.

3. ENP-O-AP-11 will be revised to specify how to perform the analysis of calibration frequency, when to perform the analysis of calibration frequency and to require I

documentation of the analysis.

1 I

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Date of Full Compliance Ib. January 31, 1986 1c. January 31, 1986 2a. June 30, 1986

3. January 31, 1986 Affirmation I affirm that this response is true and complete to the best of my knowledge, information and belief.

The information contained in this letter is not considered to be of a proprietary nature.

Yours very t y, n/ I'

'~

f'L

.' . Mcdonald Nc/ 7 RPPVAHC:emb

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