ML20133E737

Insp Repts 50-348/85-25 & 50-364/85-25 on 850603-07. Violations Noted:Failure to Evaluate out-of-tolerance Test & Measuring Equipment & Failure to Establish Environ Controls & Confirm Adequacy of Calibr of Subj Equipment

ML20133E737
Person / Time
Site:	Farley
Issue date:	07/15/1985
From:	Runyan M, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133E731	List: ML20133E729 ML20133E734 ML20133E737
References
50-348-85-25, 50-364-85-25, NUDOCS 8508080004
Download: ML20133E737 (14)

See also: IR 05000348/1985025

Text

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p re;g UNITED STATES

/j #

'o. NUCLEAR REGULATORY COMMISSION

[" n REGION 11

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-j 101 MARIETTA STREET, N.W.

's ATLANTA GEORGIA 30323

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Report Nos.: 50-348/85-25 and 50-364/85-25

Licensee: Alabama Power Company

600 North 18th Street

' Birmingham, AL 35291

Docket Nos.: '50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley Nuclear Plant

Inspection Conducted: June 3 - 7, 1985

Inspection at Farley site near Dothan, Alabama

Inspector: , hou u 7 IS 06

M. F. Run9a# [ Date Signed

Accompanying Personnel: M.-A. Scott, Region II

Approved by: MM M/ [ J f

C.-M. Upright,ycti ' Chief Date $1gned

-Division of Reactor afety

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SUMMARY

Scope: This routine, unannounced inspection entailed 68 inspector-hours on site

in the areas of surveillance testing and calibration control program, measuring

and test equipment. program, and licensee action on previously identified inspec-

' tion findings.

Results: ' Four violations were identified - Failure to Perform Evaluation of

Out-of-Tolerance Measuring and Test Equipment, Failure to Establish Environmental

Controls for Calibration of Measuring and Test Equipment, Failure to Confirm

Adequacy of Calibration Frequency of Measuring and Test Equipment, Failure to

Control Access and Assure Accountability of Measuring and Test Equipment.

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B508080004 850718

PDR ADOCK 05000348

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

B. Badham, Safety Audit and Engineering Review (SAER) Staff

• T. Cherry, I&C Supervisor

• R. Coleman, Systems Support Supervisor

L. Enfinger, Administrative Superintendent

T. Esteve, Planning Supervisor-

• H. Garland, Maintenance Superintendent

C. Hanks, I&C Control Technician

D. Heartline, Generating Plant Supervisor

• R. Hill, Operations Superintendent

D. Morey, Ass'stant Plant Manager, Operations

• C. Nesbitt, Technical Superintendent

J. Odom, Unit 1 Supervisor, Operations

'*W. Shipman, Assistant Plant Manager, Support

'J. Stutchman, I&C_ Planner

L. Ward, Maintenance Superintendent

• W. Ware, SAER Supervisor

L. Wiger, I&C Engineer

• J. Woodard, Plant Manager

Other licensee employees contacted included technicians and office

personnel.

NRC Resident Intoector

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• W. Bradford, Senfor Resident Inspector

• Attended exit in ;erview

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2. Exit Interview

The inspection scope and findings were summarized on June 7,1985, with

those persons indicated in paragraph 1 above. The licensee did not identify

as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection. The inspector described the areas

inspected and discussed in detail the inspection findings listed .below.

Violation: Failure to Perform Evaluations of Out-of-Tolerance

Measuring and Test Equipment, paragraph 5.a.

The licensee accepted the failure to evaluate mechanical equipment

found out of tolerance but did not agree that similar evaluations were

required for permanently installed plant instrumentation found out of

calibration.

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Violation: Failure to Establish Environmental Controls for Calibration

of Measuring and Test Equipment, paragraph 5.b.

Violation: Failure to Confirm Adequacy of Calibration Frequency of

Measuring and Test Equipment, paragraph 5.c.

Violation: Failure to Control Access and Assure Accountability of

Measuring and Test Equipment, paragraph 5.d.

' Inspector Followup Item: Certification of Individuals Qualified to

Calibrate Measuring and Test Equipment, paragraph 5.e.

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 (Operation)

(c) ANSI N18.7-1972, Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power

Plants

(d) Technical Specifications, Section 4

The inspectcr 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 delineated

test frequency, current status, and responsibilities for performance.

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The master schedule reflected the latest revisions of the Technical

Specifications and operating license.

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

date and to ensure that required tests were performed.

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Detailed procedures with appropriate acceptance criteria had been

approved for all surveillance testing requirements.

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The program defined responsibilities for the evaluation of surveillance

test data as well as the method of reporting deficiencies and

malfunctions.

The inspector also verified that similar controls had been established for

calibration of instruments used to verify safety functions but not

specifically identified in the Technical Specifications. The documents

listed below were reviewed to verify that these criteria had been incor-

parated into the surveillance testing and calibration control program:

QAM, Chapter 5 Instructions, Procedures, and Drawings, Revision 22

QAM, Chapter 10 Inspection, Revision 22

QAM, Chapter 11 Test Control, Revision 22

QAM, Chapter 16 Corrective Action, Revision 22

QAM, Appendix A Q-List, Revision 20

AP-5 Surveillance Program Administrative Control,

Revision 7

AP-11 Control and Calibration of Test Equipment, Test

Instrumentation, and Plant Instrumentation,.

Revision 5

AP-15 Maintenance Conduct of Operations, Revision 8

AP-51 Instrumentation and Control Group Conduct of

Operations, Revision 6

AP-57 Preservice and Inservice Inspections, Revision 3

The following site audit reports were' reviewed to identify those areas in

which the licensee had discovered problems with the surveillance testing and

calibration program:

84-15, Maintenance STPs, June 12, 1984

84-17, Operations STPs, July 11, 1984

84-21, Health Physics STPs, October 5, 1984

84-22, Chemistry STPs, October 19, 1984

84-24, Systems Performance STPs, January 2, 1985

85-06, Inservice Inspection - Unit 2, April 23, 1985

85-08, Technical Group STPs, May 2, 1985

The more significant problems were identified as noncompliances while those

of lesser importance were addressed as comments by the QA staff. Among the

types of noncompliances of greatest concern were:

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Failure to comply with notes or line items in the TS.

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Procedural errors while performing surveillance tests.

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Certification of qualification expired for persons performing

surveillance tests.

Corrective action on these and other items appeared to be complete and

expedient. Several of the comments appeared to be borderline noncompliances

but the inspector determined that corrective action was satisfactory in

these cases.

To verify implementation of the surveillance test program, the master test

schedule was reviewed. This schedule was broken into two parts; Schedule A

for test frequencies greater than one month, and Schedule B for monthly and

more frequent tests. .These manual schedules were updated monthly and sent

to the control room where test scheduling and compliance was monitored.

Test completion was documented on the schedules which were returned to the

Planning Group at the end of the month. This was a unique but apparently

effective system for ensuring that all required tests were performed as

prescribed by the TS. The schedules were randomly checked against the TS

for test inclusion and scheduling frequency as well as proper use of grace

periods.

The following surveillance test procedures and packages which include

inservice pump tests were reviewed for completeness and adequacy:

FNP-1-STP-215.3B Main Feedwater FT-486 Functional Test, performed

October 8, 1984

FNP-1-STP-416 Baron Concentration Determination of the Refueling

Water Storage Tank, performed July 9, 1984

FNP-1-STP-408 Dissolved Oxygen Determination for the Reactor

Coolant System, performed August 24, 1984

FNP-1-STP-121 Power Range Axial Offset Calibration, performed

March 9, 1985

FNP-2-STP-121 Power Range Axial Offset Calibration, performed

December 12, 1984

FNP-2-STP-23.5 Component Cooling Water Pump 2B Annual Inservice

Test, performed November 22, 1983

FNP-2-STP-23.4 Component Cooling Water Pump 2A Annual Inservice

Test, performed March 2, 1985

FNP-2-STP-4.4 Charging Pump _2A Annual Inservice Test, performed

i February 20, 1985

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FNP-2-STP-4.1 Charging Pump 2A Inservice Test, performed

l January 14, 1985

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FNP-1-STP-201.18B Reactor Coolant System TE-412A and TE-412D

Functional Test, performed November 25, 1984

FNP-1-STP-215.3A Main Feedwater FT-486 Loop Calibration, performed

October 8, 1984

FNP-1-STP-201.18A Reactor Coolant System TE-412A and TE-412D Loop

Calibration, performed November 25, 1984

Reference values for pump differential pressure and component vibration

datum (Pr and Vr, respectively) established during design and preoperational

testing in accordance with Sections III and XI of the ASME Boiler and

Pressure Vessel Code were not found in the surveillance tests examined.

These values are an integral part of component test acceptance criteria. Pr

and Vr values were indicated as being located in the surveillance test data

book in the control room. Existing site procedures did not identify use,

control, or alteration of the surveillance test data book.

In reviewing the test data package for surveillance test FNP-2-STP-23.5

(performed November 22, 1983), it was identified that new post repair

baselines for Pr and Vr were established for component cooling water pump

(CCWP) 28. The Inservice Test Program Manual, FNP-2-M-019, and the l

Inservice Plan for Pump and Valve Testing Manual, FNP-2-M-008, reference

Section XI of the ASME Boiler and Pressure Code but do not contain all of

the testing and testing time requirements of Section XI. Although site

procedures do not contain the specific 96-hour retest requirement for new

baseline of Article IWP-3000 of Section XI, CCWP 2B was retested during the

time allowed.

The licensee is required to establish a calibration program for installed

process instrumentation associated with safety-related systems or functions.

The calibration of these instruments was controlled within the preventive

maintenance program. The following plant instruments were chosen at random

from several surveillance test procedures to verify their inclusion in the

calibration program:

Charging Pump 2B

Charging Flow FI-122

Suction Pressure PI-152A

Discharge Pressure PI-152B

RHR Pump 2A

Flow FI-605A

Suction Pressure PI-601A

Discharge Pressure PI-600A

Auxiliary Feedwater Pump 2B

Suction Pressure PI-3211BB

Discharge Pressure PI-3213BB

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Containment Spray Pump 28

Suction Pressure PI-946A

Discharge Pressure PI-946B

The above instruments were included in the program. Scheduled calibration

frequencies appeared consistent with good engineering practice.

Within this area, no violations or deviations were identified.

5. Measuring and Test Equipment (M&TE) Program (61724)

References: (a) 10 CFR 50, Appendix B, Quality As:urance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

(b) Regulatory Guide 1.33, Quality Assurance Program

Requirements (Operations)

(c) ANSI N18.7-1972, Administrative Controls and Quality

Assurance of the Operational Phase of Nuclear Power

Plants

(d) Regulatory Guide 3.30, Quality Assurance Requirements

for the Installation, Inspection, and Testing of

Instrumentation and Electric Equipment, August 11, 1972

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

tion, and Testing Requirements for Instrumentation and '

Electric Equipment During the Construction of Nuclear

Power Generating Stations

The inspector reviewed the 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

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 standard, and the calibration

procedure.

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Formal requirements existed for marking the latest calibration date on

each piece of equipment.

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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 prohibited the use of M&TE which had not been

calibrated within the prescribed frequency.

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When M&TE was found out of calibration, the program required 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 assured that new M&TE was added to the inventory lists and

calibrated prior to use.

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

been incorporated into the M&TE program:

FNP FSAR, Section 17.2.12 Control of Measuring and Test Equipment

QAM, Chapter 12 Control of Measuring and Test Equipment,

Revision 22

QAM, Chapter 16 Corrective Action, Revision 22

AP-11 Control and Calibration of Test

Equipment, Test Instrumentation,

and Plant Instrumentation, Revision 5

AP-15 Maintenance Conduct of Operations,

Revision 8

AP-51 Instrumentation and Control Group

Conduct of Operations, Revision 6

The inspector reviewed site audit report 84-18, Control of Meastring and

Test Equipment, July 23, 1984, to identify problems the licensee had found

with their program. The findings included improper storage of instruments,

not marking contaminated tools, a test procedure not requiring the recording

of test equipment used and calibration due date, and the test equipment

master schedule'not containing the calibration procedure number or the last

calibration date. It appeared that the licensee had corrected these

deficiencies.

Implementation of the licensee's M&TE program was assessed in the I&C and

Mechanical calibration labs. In the I&C lab, the following items of M&TE

were selected randomly to determine the adequacy of storage and the

effectiveness of documentation accounting for the equipment:

FNP-IRD-6003 Vibration Meter

FNP-LNRS-0150 Ratio Test Set

FNP-FDM-1139 DVM Fluke 8020A

FNP-LNK-3030 . Kelvin Bridge L&N

FNP-LNC-3055 Control Loop Tester

FNP-GRS-5000 Strobotac

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FNP-BFM-5141 2.5 gpn Flowmeter

FNP-FDM-1155 DVM Fluke 8600A

FNP-ATTG-8345 100 psi Gauge

The above equipment was either properly stored or documented as being

checked out or at another location with the exception of the 100 psi gauge.

This piece of- equipment was listed as missing. This appeared to be an ,

isolated case.

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The following calibration procedures were reviewed:

IMP-021 Fluke 8600A DMM Calibration Check, Revision 3

IMP-007~ Heise Gauge Calibration, Revision 0

IMP-012 Hickok 3300 Digital Multimeter, Revision 0

IMP-031 Keithley Picoampere Source Model 261 Calibration Check,

Revision 2

IMP-061 Wallace and Tiernan FA-187 Precision Manometer Calibration,

Revision 1

The above calibration procedures appeared adequate in that they clearly

defined a step-by-step procedure and criteria by which to determine the

. acceptability of the device. . A problem concerning test conditions for

calibration is discussed as a violation below.

The licensee is required to evaluate previous tests performed with M&TE

- later found out of tolerance during calibration. The following evaluations

were reviewed:

Date Found Evaluation

ID No. Instrument Type Out-of-Tolerance Completed

HTG-8501 Heise Test Gauge 9/18/84 1/18/85

ATG-8573 Ashcroft Gauge 1/25/85 4/08/85

HTG-8507 Heise Test Gauge 1/27/85 5/08/85

HTG-8096 Heise Test Gauge 4/02/85 Open

HTG-8586 Heise Test Gauge 5/12/85 Open

The timeliness of conducting these reviews is discussed as a portion of a

violation described below.

A similar inspection was performed in the Mechanical Tool Room where the

following tools were randomly selected from the master index:

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SMI6760 Outside Micrometer

BSD6301 Dial Indicator

BSJB6216 Jo Block

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SDG6209 Depth Gauge

BCT6726- Crimping Tool

STW6420 Torque Wrench

PDT6700 Power Dyne Torque Wrench

Storage of the above equipment appeared adequate and items not located in

the shop were well documented as to their status. Calibration stickers

agreed with the information provided on the master index. The following

calibration procedures were reviewed:

GMP-33.0 Torque Tester, Model TT-7045 Calibration Check Instructions,

Revision 1

GMP-33.1 Torque Tester, Model TT-7085 Calibration Check Instructions,

Revision 0

GMP-34.1 Calibration Check for Metric Dial Indicators (Strain Gauge),

Revision 0

GMP-35.0 Calibration Check of Outside Micrometers and Micrometer

Depth Gauges, Revision 1

GMP-35.1 Calibration Check of Inside Micrometers, Revision 0

GMP-36.0 Torque Wrench Calibration Check Instructions, Revision 0

These procedures appeared adequate to control the quality of calibration

activities with the exception of environmental controls as discussed in a

violation below.

Within this area, four violations and one inspector followup item were

identified and are discussed in the following paragraphs.

a. Failure to Perform Evaluations of Out-of-Tolerance Measuring and Test

Equipment

The licensee is committed to ANSI N45.2.4-1972. Section 2.5.2 states

that when inspection and testing equipment are found out of calibra-

tion, an evaluation shall be made of the validity of previous

inspection or test results and of the acceptability of items previously

inspected or. tested. The following areas of noncompliance with this

requirement were identified and are discussed in the following

paragraphs:

Required evaluations are not typically performed for mechanical

equipment such as torque wrenches and micrometers. The

controlling procedure AP-11, Control and Calibration of Test

Equipment, Test Instrumentation and Plant Instrumentation,

Revision 5, only requires evaluations as such to be performed by

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the I&C Group. AP-15, Maintenance Conduct of Operations,

Revision 8, Section 7.4, mentions the requirement to perform the

evaluation but does not provide guidance or a format for their

performance. As a result, evaluations were only occasionally

performed and they were not maintained as quality records.

Evaluations are not performed when an installed process instrument

is found out of tolerance. In this case, an installed instrument

used to verify acceptance criteria for a safety-related surveil-

lance test is performing the same function as a portable item of

M&TE and subject to this requirement. As an example, if a pump

discharge pressure gauge is found out of tolerance, the validity

of the last pump operability test is in question and an evaluation

is required to determine whether the test should be re performed.

Test results derived from installed process instrumentation

determined to be out of tolerance could, when reevaluated,

identify an unsafe condition which requires further action in

accordance with 10 CFR 50 regulations or TS requirements.

Measures have not been established to assure that out-of-tolerance

evaluations are completed within a reasonable time period. Though

ANSI N45.2.4 does not specify timeliness of evaluations, this is

an important consideration because invalid settings, test data, or

calibrations could invoke TS limiting conditions for operation.

The I&C Control Technician in charge of the lab has determined on

his own that these evaluations should be completed in three weeks.

However, this time limit is not in a procedure and the istue has

not been evaluated by higher levels of management. Also, this

informal time constraint is often exceeded as several evaluations

were observed to have taken approximately three months to

complete. Some plants have established a seven-day . limit which

has been generally accepted as a reasonable time to screen

out-of-calibration M&TE results to determine prior use and

immediate action needed en safety-related components.

Failure to perform and control evaluations of out-of-tolerance M&TE is

identified as violation 348, 364/85-25-01.

b. Failure to Establish Environmental Controls for Calibration of

Measuring and Test Equipment

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

quality shall be accomplished under suitable environmental conditions.

For the calibration of certain items of M&TE, vendor manuals specify

conditions under which calibration activities should take place.

However, in the I&C and the maintenance calibration facilities,

measures had not been established to assure proper environmental

controls for calibration.

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In the I&C calibration lab, two examples of vendor calibration

requirements were given for the Fluke 8600A and 8120A digital

multimeters. Calibration test conditions were 23 5 degrees C at less

than 80-percent humidity and 25 5 degrees C at less than 70 percent

humidity, respectively. Although temperature and humidity were

continuously measured on a strip chart recorder, administrative limits

had not been established and personnel who perform calibrations do not

check or record conditions while performing calibrations. On at least

one occasion in the last year, humidity exceeded 70 percent in the lab.

Though Fluke test conditions were almost always met based on strip

chart records, measures had not been established to preclude calibra-

tion in the event that they were not met. Also, there may be other

pieces of equipment that were sensitive to temperature and humidity and

which may require conditions not currently being provided. A complete

review of all potentially affected equipment should be completed as

well as the establishment of administrative limits to control

environmental conditions during calibration.

In the maintenance shop, the same problem existed with the exception

that temperature and humidity indication was not provided. Provisions

had not been established to control temperature for the calibration of

precision measuring equipment nor were requirements in place to ensure

that the internal temperature of the field instrument and shop standard

had stabilized and equalized prior to calibration. In addition,

calibration was performed in three separate locations each with its own

environmental characteristics. Failure to control environmental

conditions for the calibration of M&TE is identified as violation 348,

364/85-25-02.

c. Failure to Confirm Adequacy of Calibration Frequency of Measuring and

Test Equipment

The licensee is committed to ANSI N18.7-1972 which states in Section

5.3.6 that procedures shall be provided for proper control and periodic

calibration and adjustment of measuring and test equipment to maintain

accuracy within necessary limits, and to confirm the adequacy of

calibration frequency. Procedure AP-11, Section 4.6.2.2, states that

equipment data obtained from calibration checks shall be analyzed to

optimize calibration check intervals. This implies that calibration

records should be examined periodically to determine whethar items of

M&TE should be calibrated more frequently or, in the case where

failures are very rare, less frequently. The licensee had failed to

established measures to assure the performance of this function in a

systematic or effective manner. The calibration history of a device

was not compiled tabularly and calibration records were scattered

throughout the document control system. A method of analyzing calibra-

tion history was not prescribed and, as a result, calibration trend

analysis was not performed. A specific example of this problem

involves the Keithley Picoampere Source Model 261. The vendor manual

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informs the user to calibrate this device every three months. The

licensee changed the frequency to every six months _in 1978, evidently

because it had to be sent off site for a month to be calibrated. Thus,

-by increasing the time between calibrations, it had a higher use

factor. However, the licensee did not have a technical evaluation or

trend analysis to support this change. The inspector reviewed the

following calibration certificates for Kiethley Model 261 M&TE:

Serial No. Calibration Date As Found Condition

86962 4/03/80 Out of tolerance

86962 10/20/80 Wires burned open

86962 10/22/82 Out of tolerance

4028 07/16/84 In tolerance

Although this was a small sample of the total (six calibrations were

performed on three sources yearly), it clearly indicated that a

six-month frequency may not be acceptable. Failure to confirm the

adequacy of calibration frequency of M&TE is identified as violation

348, 364/85-25-03.

d. Failure to Control Access and Assure Accountability of Measuring and -

Test Equipment

10 CFR 50, Appendix B, Criterion XII, states that measures shall be

. established to assure that measuring and testing devices used in

activities affecting quality are properly controlled. In the I&C

calibration lab, access control is not provided. As a result,

l reliability of equipment documentation and shop standard security were

not assured. The lab was unlocked around the clock and staffed by I&C

l personnel only periodically on the day shift. The lab is located in an

area where visitors and contractor personnel had unescorted access.

This created several situations that could be adverse to quality.

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Equipment checkout documentation was vulnerable to an honor system

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which may be violated by plant personnel or by personnel working for

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another organization. When equipment was found out of calibration, the

licensee does not have assurance that every prior use of that equipment

was identified which is needed for the required evaluation. Extremely

sensitive shop calibraticn standards were left unattended on desk tops

without any security against potential tampering. Tampering with a

shop standard, whether advertently or not, may not be known for several

years depending on the calibration frequency. A countless number of

flawed calibrations of field equipment may occur and seriously degrade

the safety of the plant. M&TE could be removed from the lab without

being signed out and used after exceeding its calibration interval

without a means of locating it. Failure to control access and assure

accountability of M&TE is identified as violation 348, 364/85-25-04.

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e. Certification of Individuals Qualified to Calibrate Measuring and Test

Equipment

The licensee could not demonstrate a qualification program or formal

training for personnel who routinely calibrate M&TE. In the I&C lab,

journeymen perform the calibrations by using procedures and by

observing others. In the mechanical lab, any mechanic was assumed to

be qualified to calibrate M&TE. This informal approach to training and

qualification may not be sufficient to assure the repeatability and

.acctracy of M&TE calibrations. The licensee acknowledged this concern

and provided the following response to the inspector following the

inspection:

Intracompany correspondence, FNP-85-0624, Certification and

Re-Certification of Personnel Performing Calibration of Equipment

or Instruments, dated June 12, 1985. This response stated that

personnel performing calibrations meet the Level II Qualification

requirements of FNP-0-AP-31 and are certified to perform

activities associated with their respective classification,

including calibrating or establishing the validity of calibration

of measuring equipment. The response further stated that

calibration activities performed by these personnel fall well

within the skills of the classification; therefore, no periodic

training is necessary.

Until the qualification requirements of FNP-0-AP-31 are reviewed and

are observed to be adequate, the item is identified as Inspector

Followup Item 348, 364/85-25-05.

7. Licensee Action On Previously Identified Inspection Findings (92701)

(0 pen) Inspector Followup Item 348, 364/85-21-02: Cheater Bar Usage.

At the time of this inspection, a composite audit report had been

issued with the cheater bar noncompliance identified as an open item.

The appropriate corporate and site personnel had not responded.

(0 pen) Inspector Followup Item 348, 364/85-21-03: 10 CFR 21 Requirements.

Administrative Procedure 62 had been amended to incorporate the

necessary changes. The procedure is at the corporate office for

approval.

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