IR 05000317/1979016
| ML19296D210 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/30/1979 |
| From: | Kehoe D, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D204 | List: |
| References | |
| 50-317-79-16, 50-318-79-13, NUDOCS 8003030010 | |
| Download: ML19296D210 (10) | |
Text
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 50-317/79-16 Region I 50-318/79-13 50-317 Docket No. 50 m C
DPR-53 C
License No.npp_go Priority
-
Category Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland 21203 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Facility Name:
Inspection at:
Lusby, Maryland and Baltimore, Maryland Inspection conducted: October 1-5, 1979
\\\\-l-)
Inspectors:
.
-
date signed David V. Kehoe, Reactor Inspector date signed ate signed Approved by:
-
//% C 7
~
Fi. B. Kister,Dief, Nuclear Support date signed Section No. 2, R0&NS Branch Inspection Summary:
Inspection on October 1-5,1979 (Combined Report Nos. 50-317/79-16; 50-318/79-13)
Areas Inspected:
Routine, unannounced inspection by one regional based inspector and one NRR engineer of QA/QC Administration, Design Change / Modification Program, Design Chaage/ Modifications, Records Program and followup on previously identified inspection findings.
The inspection involved 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> on site and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> at the corporate offices by one NRC regional based inspector and one NRR engineer.
Results: 0 the four areas inspected, no itemr. of noncompliance were identified in three areas, one item of noncompliance was found in one area, Deficiency - use of nonsafety related platform when safety evaluation required safety related platform, paragraph 5.b(1)).
h h 8003030
'
Region I Form 167 (August 1979)
.
.
OETAILS 1.
Persons Contacted
- M. E. Bowman, Supervisor QA Auditing
- J. T. Carrol, Supervisor, Technical Support
- J. T. Carlson, Radiation Safety and Chemistry Foreman
- P. T. Crinigan, Performance Engineer
- R. M. Douglass, Manager-Quality Assurance T. Forgette, QA Auditor
- W. S. Gibson, Nuclear Plant Engineer Performance
- A. J. Kaupa, Radiation Safety and Chemistry Engineer
- J. R. Lemons, General Foreman - Nuclear
- E. T. Reimer, Plant Health Physics
- L. B. Russel, Chief Engineer
- J. R. Speciale, Radiation Safety and Chemistry Foreman
- L. A. Sundguist, Supervisor Engineering QA A. Thornton, Supervisor, Electrical Engineering
- R. Wenderlich, Training Cooruinator
- L. O. Wenger, Performance Engineer Other Accompanying NRC Personnel
- Denotes those present at the exit interview.
The inspector also contacted and interviewed other licensee station and corporate individuals.
They included Engineering, Quality Assurance, Operations, technical and clerical personnel.
2.
Licensee Action on Previously Identified Items (0 pen) Unresolved (318/78-11-01; 317/78-17-01):
Appropriateness and time-liness of corrective action to resolve findings of station audit 2-30-77.
The inspector toured the warehouse and noted no discrepancies with storage requirements.
The inspector also noted that the administrative controls necessary to resolve the station audit findings had been identified and were in the process of being defined in written procedures and implemented.
Further, the licensee stated that within 30 days he was implementing a monthly inspection of the warehouse for conditions adverse to quality, in the interim, until the program was fully defined in written procedures and implemented.
The licensee also stated that this program should be imple-mented within 8 months.
This item remains open pending review by NRC:RI of the fully implemented program.
(0 pen) Unresolved (318/78-11-04; 317/78-17-04):
Review implementation of corrective action of audit findings on ANSI N45.2.9 implementation.
The inspector reviewed the records program (see paragraph 4) and determined
.
.
that with the exception of the vault for non-microfilmable records, the records program appeared to be consistent with the requirements of the licensee's ANSI N45.2.9 commitment.
The licensee stated that the new administration building would contain a vault meeting the requirements of ANSI N45.2.9.
This item remains open pending review by NRC:RI of the vault subsequent to the transfer of non-microfilmable records to the vault.
3.
QA/QC Administration a.
References
.
QAP-1, Procedure Control, Revision 20
--
QAP-20, Training, Revision 9
--
QAP-21, Review and Audit of the Quality Assurance Program, Revi-
--
sion 9 QAP-26, Control of Conditions Adverse to Quality, Revision 22
--
--
QAP-28, Control of Items Covered by the Quality Assurance Program, Revision 11
--
QAP-31, Administrative Controls for Operating Nuclear Power Plants, Revision 4
--
QAP-35, Control of Technical Support Activities, Revision 3 OQASP-3, Preparation and Control of 0QASP's, Revision 3
--
0QASP-6, Training Quality Control Personnel, Revision 4
--
EEDP-1, Preparation and Control of Electrical Engineering
--
Department Procedures, Revision 3 EEDP-4, Establishment and Control of the List of Safety-
--
Related Items, Revision 5 EEDP-8, Nuclear Facility Training and Indoctrination,
--
Revision 6 EEDP-13, Design and Design Review, Revision 2
--
--
CCI-100C, Calvert Cliffs Nuclear Power Plant Instructions, Change 5 CCI-101F, Review and Approval Procedures for Proposed
--
Calvert Cliffs Procedures, Change 1 CCI-108E, Effective Calvert Cliffs Instructions, Change 5
--
.
.
--
CCI-120A, Calibration Program for Measuring and Test Equipment, Change (none)
CCI-122A, Control of Technical Manual, Change (none)
--
CCI-126, Administrative Control of Facility Change Requests,
--
Change (none)
--
CCI-132, Requirements for Preparation and Use of Technical Support Procedures, Change (none)
--
CCI-135, Administration of Inservice Inspection, Change 1
--
CCI-220C, Maintenance Requests, Change (none)
--
CCI-216, Contractor Maintenance and Modification Work, Change (none)
--
CCI-6008, On-Site Training of Calvert Cliffs Personel, Change (none)
CCI-602D, Calvert Cliffs Nuclear Power Plant General Orientation
--
Training, Change (none)
--
CCI-6038, Operator Training, Change (none)
CCI-604B, Licensed Operator Training, Change (none)
--
CCI-606B, Maintenance Personnel Training, Change (none)
--
CCI-607C, Radiation Safety and Chemistry Personnel Training,
--
Change (none)
--
CCI-608A, Radiation Monitoring Personnel Training, Change (none)
CCI-615, Contractor Training, Change 5
--
b.
Program Review The inspectors reviewed the referenced documents to verify that:
The scope and applicability of the QA Program is defined
--
Appropriate controls. are established to prepare, review
--
and approve QA Program procedures including changes thereto A mechanism was established to review and evaluate the QA
--
Program No items of noncompliance were identifie.
.
.
4.
Records a.
References
--
OQASP-5, Records for Quality Control Inspections, Revision 8 0QASP-ll, Record Receipt Control, Revision 4
--
0QASP-12, Record Storage, Preservation and Safekeeping,
--
Revision 3
--
0QASP-13, Records Administration, Revision 3
--
QAP-7, Records Management, Revision 10
--
EEDP-16, Record Retention, Revision 4 CCI-134, Tempo ary Storage of Technical Support Group Records,
--
Change 1
--
CCI-138, Aperture Card, Micro-Fische and Micro-Film Control, Change (none)
--
CCI-214A, Maintenance Records, Change (none)
In addition to the above all CCI's, EEDP's 0QASP's and QAP's were reviewed with respect to those paragraphs which address records retention.
b.
Program Review The documents referenced above were reviewed to determine that administrative controls for records management have incorporated the requirements as described in the Quality Assurance Manual, Revision 55.
No items of noncompliance were identified.
c.
Implementation Review The inspectors requested the records listed below at various times during this inspection and verified that they were retrievable and that they were maintained as required.
(1) FCR Packages listed in paragraph 5.c.
(2) The below listed drawings:
M-73, 62-730-E, M-72, M-572A, M-502C, M-348, M-462, M-74, FSK-1878, FSK-1879, FSK-1880, FSK-1881, M-582, and 60-617-..
..
.
(3) The below listed Maintenance Requests (MR)
MR-78-207, -3059, -3069, -3057, -3115, -3044, -3116, -3089,
-3090, -3091, -3092, -3168, -3171, -3169, -3170, -3059, -
3063, -3065, -3067, and -3077, E-177-163, and CWP 75-1071-1520.
(4) The QC inspection reports associated with each MR listed in paragraph c.(3)
(5) The below listed Purchase Orders (PO)
P0-6750-F-5631, P0-988 16-6X, and P0-6750-E-7 No items of noncompliance were observed.
5.
Design / Modification Control a.
References 0QASP-2, Receiving and Inspecting Safety Related Material,
--
Revision 10
--
OQASP-8, Review of Plant Maintenance and Functional Test Procedures, Revision 3
--
0QASP-15, Control of Prints, Revision 1
--
QAP-14, Plant Maintenance, Revision 13
--
QAP-15, Changes, Tests, and Experiments, Revision 23 QAP-16, Surveillance Testing, Revision 12
--
EEDP-2, Control of Changes, Tests and Experiments, Revision
--
EEDP-4, Establishment and Control of the List of Safety-
--
Related Items, Revision 5 EEDP-9, Calculations, Revision 0
--
EEDP-13, Design and Design Review, Revision 2
--
CCI-126A, Administrative Control of Facility Change Request,
--
Change (none)
CCI-216, Contractor Maintenance and Modification Work,
--
Change (none)
.
.
.
-
b.
Program Review
,
The documents referenced above were reviewed to determine whether administrative controls for design changes / modifications have incorporated the requirements as described in the Calvert Cliffs QA Manual, Revision 55.
The review determined that administrative controls have been established which verify the following:
--
procedures for control of design changes / modifications have been developed design droment control has been established
--
--
channels of communications between the design organization and the individual responsible for implementation exist
--
d,ign change / modification packages are being converted into plant records.
methods exist for identifying and reporting those desiga
--
changes / modifications which are within the scope of 10 CFR 50.59
--
procedural controls exist for temporary modifications, lifted leads and jumpers responsibilities have been delineated in writing to assure
--
the implementation of the above.
One item of noncompliance and one unresolved item are discussed below.
(1) During the inspector's review of FCR 78-26, Fabrication and Installation of Sleeving Platform, it was noted that the platform was fabricated and installed as non-safety related even though the 10 CFR 50.59 safety evaluation required the platform to be fabricated and installed to Seismic I safety related requirements.
After further review, the inspector established that the follow-ing sequence of events had occurred.
During a refueling outage, the licensee determined that sleeving of the guide tubes due to guide tube wear was required.
The licensee also determined that in order to accomplish this, a sleeving platform would have to be fabricated and installed.
The licensee's Engineering Department performed a 10 CFR 50.59 safety evaluation and determined that there was no unreviewed safety question involved and further determined that the platform was not required to be safety relate.
The sleeving platform was tiien fabricated and installed outside the purvue of the QA Program (e.g., no QC inspections, no safety-related materials and non safety related maintenance requests) with the exception of the bolt holes.
Subsequent to the installation of the, platform, the licensee determined that the sleeving ple.tform did indeed constitute a facility modification.within the context of the QA Program.
A Facility Change Request (FCR} was then initiated and processed through the station and corporate engineering in one day.
At this time the corporate engineering department made the determination that the original safety evaluation and determination that the platform need not be safety related were incorrect.
A new safety evaluation was issued which stated that the platfom did not involve an unreviewed safety question as it was fabricated and installed to Seismic I/ safety-related criteria.
Subsequent to the determination that the platform was required to be safety related, it remained in use thru the completion of Unit #1 sleeving (approximately 5 days)
without any additional evaluation to determine its adequacy as a safety related structure.
The inspector also noted that physical modifications were required to the Sleeving Platfom to upgrade it to a seismic structure subsequent to its use on the other unit.
The inspector ider.tified the following concerns to the licensee:
What programatic weakness lead to the initial determination
--
that the platform was not safety related?
What programatic weakness permitted the platfom to be
--
used subsequent to the determination that it was required to be safety related.
The failure to use a safety related platform as required by the safety evaluation performed pursuant to 10 CFR 50.59 is a deficiency level item of noncompliance (317/79-16-01; 318/79-13-01).
(2) The mechanism by which acceptance testing reautred as a result of a modification is specified, the work package cover sheet, has been deleted from OAP-15.
The inspector questioned the licensee as to how this requirement of ANSI N45.2.ll was being implemented.
The licensee stated that the work package cover sheet was still being used, and is to be incorporated into CCI-126 no later than December 1,1979.
This item is unresolved pending review by NRC:RI of the above procedure change.
(317/79-16-02; 318/79-13-02).
.
.
c.
Implementation Review The inspector reviewed the following modification packages.
FCR 75-244, Installati.on of Charging Pump Veat Valves
--
FCR 75-1071, Installation of Pressurizer eressure Instrumentation
--
FCE 77-152, Changing Safety Injection Tank Relief Valve
--
Connections From Welded to Flanged FCR 77-1001, Installation of Ambient Compensated Overload
--
Relays on Safety Related 480 v Control Centers FCR 78-4, Change Location of Rigid Pipe Hanger on SG #11
--
Bottom Blowdown Line
--
FCR 78-26, Fabrication and Installation of Sheeving Platform in Spent Fuel Pool
--
FCR 78-143, Repair of Anchor Bolt on Charging Pump Suction Header Hanger The modifications listed above were reviewed to verify that the following requirements have been implemented.
10 CFR 50.59 reviews were performed and documented
--
design changes modifications were reviewed in accordance
--
with the requirements of the Technical Specifications and the QA Program.
--
design changes modifications were accomplished in accordance with written procedures acceptance testing was accomplished and deemed satisfactory
--
procedures and drawings required to be changed or generated
--
as a result of the design change / mech faction were updated or generated the design change / modification package has been transmitted
--
to the record retrieval department for incorporation as a plant record.
No items of noncompliance were identified, however, cas mresolved item is discussed belo (1) The inspector requested to see the design input documentation for the following FCR packages:
FCR-75-244;-75-101 ;-77-152; -77-1001 ; -78-4; and, -78-26.
The licensee stated that the design work for these modifications were performed by contracted engineering finns and that these firms maintain the design input documentation.
The licensee further stated that this information would be retrieved for the NRC's review on a future inspection.
This item is unresolved pending review of the design input documentation by NRC:RI during a subsequent inspection.
(317/79-16-03; 318/79-13-03)
6.
Station Organization The inspector noted that Memc J. B. Bullock to All Electric Production Department Employees propagated an organizational change at the Calvert Cliffs Nuclear Power Station which was implemented on July 1,1979.
Further investigation identified that the organizational change constituted a change to the Unit 1 and 2 Technical Specifications, Section 6.2.2.
It was also identified that on July 24, 1979, the station had submitted an application for amendment to their licensee to change the Technical Specifications to reflect the organizational change.
10 CFR 50.59 states that a licensee can not make changes to the facility as described in the FSAR without prior Commission approval if that change involves a change to the Technical Specifications.
This item is being forwarded to NRC management for determination as to its acceptability.
This item is unresolved pending the above determination (317/ 79-16-4; 318/79-13-04).
7.
Unresolved Items Unresolved items are matters about which more infonnation is required in order to ascertain whether they are acceptable items, items of non-compliance or deviations.
Unresolved items disclosed during this inspection are discussed in paragraph 5.
8.
Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on October 5,1979.
The inspectors summarized the purpose, scope, and findings of the inspection.
During this meeting, the unresolved items and items of noncompliance were identified.