ML20127G380

Insp Rept 50-302/85-13 on 850318-22.Violations Noted:Failure to Control Environ Conditions in Calibr Lab & Evaluate out-of-tolerance Measuring & Test Equipment in Timely Manner

ML20127G380
Person / Time
Site:	Crystal River
Issue date:	04/19/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G362	List: ML20127G359 ML20127G369 ML20127G380
References
50-302-85-13, NUDOCS 8505210049
Download: ML20127G380 (10)

See also: IR 05000302/1985013

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REPORT DETAIL 3 .

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1. Persons Contacted *

Licensee Employees h

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• J. Alberdi, Manager, Site Nuclear Operations Technical Services -

• J. A. Frijouf, Acting Compliance Specialist

• D. G. Green, Nuclear Licensing Specialist -

• W. H. Herbert, Nuclear Technical Services, Compliance g

V. Hernandez, Senior Nuclear Quality Assurance Specialist, Nuclear

Operations m

• T. A. Kamann, Nuclear Operations Records Manager 7

• B. P. Komara, Nuclear Quality Assurance Supervisor -i

• K. F. Lanu ster, Manager, Site Nuclear Quality Assurance

• R. V. Mathews, Nuclear Calibration Lab Supervisor I

• P. F. McKee, Plant Manager  :

• S. C. Powell, Senior Nuclear Licensing Engineer '

• V. R. Roppel, Manager, Plant Engineering and Technical Services s

• W. L. Rossfield, Nuclear Compliance Manager

• D. T. Salute, Nuclear Compliance Specialist

• D. H. Smith, Nuclear Maintenance Supervisor

• J. T. Telford, Director, Quality Programs

• E. S. Wollesen, Nuclear Maintenance Specialist -

Other licensee employees contacted included technicians and office

personnel.

Other Organizations

R. Chackel, Surveillance Group, Impell Corporation d

NRC Resident Inspectors

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"T. F. Stetka, Senior Resident Inspector E

• J. E. Tedrow, Resident Inspector

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• Attended exit interview -l

2. Exit Interview

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The inspection scope and findings were summarized on March 22, 1985, with

those persons indicated in paragraph 1 above. The inspector described the -

areas inspected and discussed in detail the inspection findings listed _1

below. The licensee did not identify as proprietary any of the materials

provided to or reviewed by the inspector during this inspection.

Violation: Failure to Control Environmental Conditions in the Calibra-

tion Laboratory, paragraph 5.a.

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8505210049 890419

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Violation: Failure to ' Evaluate - Out-of-Tolerance M&TE in a Timely '

Manner, paragraph 5.b. This . item was presented as .an inspector

followup item but changed to a violation based on Region II management

review following the inspection. Licensee management was informed of l

this change on March 29, 1985.

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A potential violation =concerning inadequate calibration instructions

was changed at the exit' interview to an unresolved item based on

information 'provided. by licensee management.- This finding was

withdrawn following re-inspection in this area -on March 28, 1985.

Licensee raanagement was informed of Region II concurrence with ' their

-position on March 29, 1985.

3. Licensee Action on Previous Enforcement Matters

This subject was.not addressed in the inspection.

4. 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

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

Assurance for the Operational Phase of Nuclear Power

Plants

(d) Technical Specifications, Section 4

The inspector reviewed the licensee surveillance testing and calibration

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

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 delineates i

test frequency, current status, and responsibilities for performance. 1

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The master schedule reflects the latest revisions of the Technical

Specifications and operating license.

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Responsibilities are assigned to maintain the master schedule up-to-

date and to ensure that required tests are performed.

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Detailed procedures with appropriate acceptance criteria have been

approved for all surveillance testing requirements.

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The program defines responsibilities for the evaluation of surveillance -

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test data as well as the method of reporting deficiencies and malfunc-

tions.

L The inspector also verified that similar controls have been established for

calibration of instruments used to verify safety functions but not specifi- (

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cally identified in the Technical Specifications. The documents listed

below were reviewed to verify that these criteria had been incorporated into

the surveillance testing and calibration control program: l

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NQAP, Nonconformance Item Control and Corrective Actions, Revision 0 =

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l NQAP, Technical Specification Conformance, Revision 0 5

y NQAP, Testing, Revision 0 -

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SP-440, Unit Startup Surveillance Plan, Revision 43  ;

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l SP-441, Unit Shutdown Surveillance Plan, Revision 26

SP-442, Special Conditions Surveillance Plan, Revision 28 k

SP-443, Master Surveillance Plan, Revision 62 -

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CP-102, Inservice Inspection Pump and Valve Data Review and Corrective

l} Action, Revision 15  :

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L CP-111, Documenting, Reporting, and Reviewing Nonconforming Operations .

[ Reports, Revision 30

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CP-125, Corrective Action Procedure, Revision 4 r

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r AI-701, Conduct of Inservice Inspection, Revision 2

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PM-200, Instrument Calibration Recall Program, Revision 0  :-

h The inspector reviewed two recent site QA inspections in this area.

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Surveillance report, QPSR 84-020, CR-3 HVAC System Surveillance, August 9, r

[ 1984, identified that in plant process instruments used for this test were -

F erroneously identified as Category 3 (balance of plant) instead of -

Category 2A (Technical Specification surveillance procedure related instru- "

mentation). Therefore, these instruments were on a longer calibration cycle

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y than had they been correctly identified. The licensee corrected the problem  ;

F by calibrating the subject instruments and investigating the calibration

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status of all safety-related HVAC system instrumentation, revising i

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categories where necessary. A broader review is in progress to ensure =

that all safety-related instruments are on a proper calibration schedule.

The inspector also reviewed QA Audit QP-257, Operational Technical Specifi-

cations Conformance, August 22, 1984. The licensee appeared to be taking -

positive actions on the findings identified in this audit.

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The licensee's master surveillance test schedule, SP-443, is a manual system -

which divides quarters into three four-week " months" plus an extra " dead" -5

week at the end. Surveillance tests are scheduled for specific days of the I

week, specific weeks in the month, and specific months in the quarter. This

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system is effective but presents a slight problem for monthly tests. Due to

the " dead" week at the end of the quarter, every third monthly test is  ;

scheduled 35 days (instead of 28) after the previous performance date. The i

maximum interval allowed by the Technical Specifications is 1.25x31 days, or E:

38.75 days. This means that a combined period of four days resulting from f

early performance of the previous test and late performance of the next test 4

would exceed Technical Specification limits. Due to this built-in margin C

reduction, the inspector extensively surveyed performance dates for monthly hf-

tests. The licensee appeared to properly control extensions for monthly i

tests as well as tests at other frequencies. -

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A representative sample of surveillance requirements from the Technical i:

Specifications were selected. In each case, surveillance procedures existed i

and the tests were scheduled on the master schedule at the proper frequency. ]

The following surveillance test procedures were reviewed for completeness,

consistency, and acceptance criteria requirements:

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SP-305, TSG Tubes Eddy Current Inspection, Revision 10 s

SP-320, Operability of Boron Injection Sources and Pumps, Revision 47 Y

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SP-351, Nuclear Services Flow Path Operability, Revision 10 -

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SP-353, Control Room Emergency Ventilation System Monthly Test,

Revision 5 4

SP-354A, Emergency Diesel Fuel Oil Quality and Diesel Generator 3A =

Monthly Test, Revision 6  ;

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SP-357, High Pressure Injection and Low Pressure Injection ES Manual -

Initiation Test, Revision 2 E

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SP-362, Feedwater Pump Turbine Tachometer Overspeed Trip and Emergency f'

DC Lube Oil Pump Auto Start Tests, Revision 8 =

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SP-366, Fire System Annual Valve Surveillance, Revision 9 -

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SP-370, Quarterly Cycling of Valves, Revision 30 1

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SP-390, Startup Surveillance Plan, Revision 9

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SP-402, Core Flooding System Isolation Valves Alarms Actuation,

Revision 4 3

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The above test procedure were clearly written, guided the technician to j

return the system to its original state, and stated acceptance criteria -

consistent with the Technical Specifications. S

The inspector selected the following completed surveillance test work i

packages for a detailed review of program implementation. 1

SP-317, RC System Water Inventory Balance, March 1,1985 -

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SP-332, Monthly Feedwater Isolation Function Tests, February 10, 1985  ;

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• SP-340, ECCS Pump Operability, February 20 and March 6,1985 -

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• SP-344, Nuclear Services Cooling Water System Operability, February 27 4

and March 13, 1985 -

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These work packages were complete, properly approved, and met acceptance -

criteria. Those marked with an asterisk are included in the inservice  ;

inspection (ISI) of pumps and valves as required by ASME Code Section XI, J

Subsections IWP and IWV. The latest amendment to the licensee's ISI program j

was submitted May 23, 1983, and is pending approval from the Division of j

Licensing, NRC. ,

The inspector reviewed the licensee's calibration program for in plant I

process instruments associated with safety-related systems. The calibration 3

of all plant instruments is controlled by PM-200, Instrument Calibration j

Recall P.rog ram. Those instruments designated Category 1, 2A, or 28 are  ?

safety related or associated with testing required by the Technical

Specifications. Those designated Category 3 or higher are non-safety L

related and calibrated less frequently. A computer printout was reviewed 2

listing all instruments in the program, their category designation, 2

calibration frequency, current calibration status, and other information. 3

The following instruments employed by several surveillance procedures to

verify acceptance criteria were selected for review:

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RW-33-TI ECCS Heat Exchanger Temperature 2

RW-13-TI ECCS Heat Exchanger Temperature 2i

DH-39-TI ECCS Heat Exchanger Temperat' re si

DH-6-TI ECCS Heat Exchanger Temperature j

RW-17-TI NSCCC Cooler Outlet Temperature

RW-24-TI NSCCC Cooler Outlet Temperature  :

RW-25-TI NSCCC Cooler Outlet Temperature f

EF-1-PI Emergency Feedwater Pump Suction Pressure

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EF-2-PI Emergency Feedwater Pump Discharge Pressure 1

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The above instruments were included in the program, properly categorized, i

and calibrated at the required frequency. The inspector expressed a concern 2

that calibration due dates of plant instruments used for surveillance tests =

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were not documented on test data sheets. This is often recorded as a means

of verifying that instrument calibrations are not expired. The licensee 1

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stated that the PM-200 program is designed to calibrate all instruments at

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the ' proper frequency. In addition, calibration stickers are placed

routinely'on. installed gauges such that the individual performing the test

can' verify the calibration status.

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Within_this' area, no violations or deviations were_ identified.

, 5-. Measuring and Test Equipment Program (61724)

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

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Requirements (Operations), Revision 2

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

Assurance of the- Operational Dhase ' of Nuclear Power.

Plants

(d) Regulatory Guide 1.30, Quality Assurance Requirements

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

The inspector reviewed the licensee measuring and . test equipment (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 is delegated and criteria established to assign and

adjust calibration frequency for each type of M&TE.

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

components, the calibration frequency and standard, and the calibration

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Formal requirements exist for marking the latest calibration date on i

each piece of equipment.

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The program assures that each piece of equipment is calibrated on or

before the date required or stored in a location separate from

in-service M&TE.

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Written requirements prohibit the use of M&TE which has not been

calibrated within the prescribed frequency.

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_W hen M&TE is found out of calibration, the program requires documented

- evaluations to determine the cause of the out-of-calibration condition

and the acceptability of items previously tested.

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.The program. assures that new M&TE is added . to the inventory itst' and

calibrated prior to'use.

The documents listed below were. reviewed to verify that these criteria had

been incorporated into the measuring and test equipment program:

-Crystal. River Quality' Assurance Program, Section 1.7.1.12,. Control.of

-Measurement and Test Equipment, June 10, 1983

-NQAP, Measurement and Test' Equipment Program, Revision 0-

NCL-01, Test-Equipment, Standards, and Calibration Control, Revision 6

CP-125, Corrective Action Procedure, Revision 4

NQC'04, Control of Calibrated Instruments Assigned to Nuclear Quality

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Control, Revision 4

The inspector reviewed QA audit . 0P-252, Measurement and Test Equipment

Control, L June 8, 1984. ._The licensee had completed corrective action

recommended.for the identified findings. ,

The ' inspector toured the calibration laboratory where both electric and ,

mechanical equipment is calibrated. Because of a recent move, the lab' was '

-somewhat disorganized. and unkempt. However, ; tool storage appeared- to bel

adequateJ and rejected equipment was properly segregated from in-service

, equipment. 'A computer master listing of all available M&TE was obtained and

the' following tools were selected- to check equipment control and account-

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'TI'1458 Surface Probe

TI 171B- Volt Ohm Meter

TI 215A Digital Thermometer

TI 300 Pulse Generator

-TI 389 -Power Supply

TI 449 Immersible Probe

TI:496A Calibrated Thermocouple

TI 532 DC Tester

'TI'583 . Battery Charge System

TI-721 Digital Multimeter

TI 810 Gas Detector

TI 908' Digital-Multimeter

TI 1023. . Amplifier

TI 1134 R-Meter

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The_ above equipment was either stored properly in the lab, checked out, or

documented at another location. In some cases, the master ' list did not

reflect .the_ latest calibration status of the equipment. This is due to a

backlog in updating the computer.

The_ licensee is. required to evaluate-the effect out-of-calibration M&TE may.

have on' previous tests performed with this equipment since the last accept-

able calibration. The -following out-of-tolerance reports were selected to

determine compliance with this requirement:

-Instrument No. Work Sheet No'. Date

TG 68B 84-12-124 January 16,'1985

TG 112A 84-12-235 January 21, 1985

TG 117A 84-12-126 January 23, 1985

CT 13A 83-09-227 January 20,.1984

CT-1135 84-11-96 December 11, 1984

TI 29A 84-12-249 January 2,1985

TI 3271 84-12-176 . January 4, - 1985 -

In several cases, work requests were written to re perform a surveillance

test' which may have been adversely affected. Overall,.the reports appeared

to meet the intent of the requirement with the exception of a problem

identified as a violation below.

Within this' area, two violations were identified and are dis:ussed in the

following paragraphs.

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-a. Failure to Control Environmental Conditions in the Calibration Labora-

tory

10 CFR 50, Appendix B, Criterion II, states that activities affecting

quality shall be accomplished under suitable environmental conditions.

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For the calibration of M&TE, vendor technical manuals specify controls

for temperature, humidity, and other conditions. Neither calibration

instructions nor other controlling procedures specified requirements

for maintaining temperature and humidity within a suitable control band

to assure the accuracy of celibration activities. Furthermore,.there

_ were no means available for lab personnel. to assess the environmental

_ conditions in the lab. A strip chart recorder. for-- temperature and-

humidity was stored on a back shelf, but it was not operating and had

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not: been used routinely. Proper environmental conditions were not

' verified prior to . calibration of sensitive equipment such as digital

multimeters_and micrometers. Failure to ensure proper environmental

conditions in . the calibration - laboratory is- identified as violation

-302/85-13-01.

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b. -Failure to Evaluate Out-of-Tolerance M&TE in a Timely Manner

The~ licensee's accepted QA program commits to Regulatory Guide 1.30

which endorses ANSI N45.2.4-1972. This standard requires the licensee

to evaluate the safety implications when 14LTE is found out of cali-

bration. NCL-01, Test Equipment, Standards, and Calibration Control,

Section~ 6.7, describes the escalation policy used to ensure that the

--evaluations are.promptly completed. If the evaluation is not completed

-within two weeks, it is sent to the next higher level of supervision

and ultimately to the plant _ manager if necessary. This procedure

appeared to work well when implemented by the plant staff. When an

evaluation is required from a contractor who'used the suspect M&TE and

may have left the site, several evaluations have been significantly

-delinquent. The following incomplete evaluations were outstanding as

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of March 21, 1985:

Equipment No. Date Out of Tolerance

TG 29 October 6, 1983

CT 2681 October l 10, 1983

TG 190 January _27,.1984

TI 931 February 6, 1984

TG 103 March 19, 1984

CT 753 August 15, 1984

TI 784A August 28, 1984

TI 927 October 4, 1984

TI 327. , January 8, 1985

TG 112A January 22,'1985

Theilicensee retains the same responsibility to ensure that M&TE evaluations

are promptly completed whether. the assignment remains in-house or is

contracted out. Failure to ensure that - out-of-tolerance reports sent - to

contractors are promptly evaluated is identified as violation 302/85-13-02.

6. Licensee Action on Previously Identified Inspection Findings (92701)

(Closed) Inspector Followup Item 302/82-20-04: Inadequate Record Control

Procedures and Implementation.

The inspector reviewed the following licensee documents .to verify that

necessary interface procedures between document control and each department

met the intent of ANSI N45.2.9.

Nuclear Quality Assurance Plan DOCC, Revision 0

N00-04, Records Management Program, Revision 0

N00-05, Document Control Program, Revision 1

DC/RM-200, Operation Of The Central File, Revision 0

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The inspector- toured - the records vault and determined that the facility

appears to comply with the requirements of ANSI N45.2.9. Examination of t:ie-

records stored ~1n the vault as well as a programmatic. review indicated that

the current records management system complies with the handling, storage,

- and' collection requirements committed to by the licensee.

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