IR 05000317/1987013

Insp Repts 50-317/87-13 & 50-318/87-14 on 870511-15.Major Areas Inspected:Previously Identified Environ Qualifiaction Deficiencies.Concerns Raised Re Use of Lead & Sys Engineers & Interdivisional Communications

ML20235F156
Person / Time
Site:	Calvert Cliffs
Issue date:	06/29/1987
From:	Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235F142	List: IR 05000317/1987013 ML20235F140
References
50-317-87-13, 50-318-87-14, NUDOCS 8707130244
Download: ML20235F156 (20)

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i U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report: 50-317/87-13 License: DPR-53  !

50-318/87-14 DPR-69 Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plcnt, Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted: May 11-15, 1987 i

Inspectors: L. E. Tripp, Team Leader, Chief, Reactor Projects, Section 3A {

Region I '

T. Foley, Senior Resident Inspector,Calvert Cliffs, Units 1 and 2 H. J. Kaplan, Reactor Inspector, Region I  !

5. A. McNeil, Project Manager, PDI-1, NRR  !

R. J. Paolino, Lead Reactor Engineer, Region I l L. Prividy, Resident Inspector, Beaver Valley C D. S 11ers, Senior Metallurgist, EMTB, NRR Approved: 0

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L. E. Tripp, Chief, Reactor Projects Section 3A ' Date

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Inspection Summary: May 11-15, 1987 (Report Nos. 50-317/87-13; 50-318/87-14)

Areas Inspected: Special, announced on-site inspection reviewing (1) previously i

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identified environmental qualification deficiencies, (2) licensee identified in-appropriate use of commercial quality mechanical fasteners, (3) post-maintenance testing, (4) interdivisional interface and implementation of engineering require-ments, and (5) a review of quality assurance coverag Inspection hours totalled 30 Results: No violations cr deviations were noted. However, concerns were raised regarding the use of lead and system engineers and with respect to interdivisional communications between engineering and the fiel PDR G

ADOCK 05000317 PDR

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DETAILS ,

1. Persons Contacted Baltimore Gas and Electric Company

• R. Allen, Principal Engineer, Performance Engineering, Nuclear Engineering Services Division (NESD)

• B. Anuje, Supervisor, Quality Audits, Quality Assurance and Services Division (QASD)

• R. F. Ash, General Supervisor, Design Engineering, NESD i

• M. E. Bowman, General Supervisor, Technical Services, NESD '

J. E. Branyon, Operations Surveillance Coordinator, Nuclear Operations J Division (N00)

• J. T. Carroll, General Supervisor, Quality Assurance, QASD J. B. Couch, Engineer, Fuel Management, NESD

• T. Crinigan, General Supervisor, Chemistry, N00

• S. Davis, Principal Engineer, Major Projects, NESD S. Davis, Senior Engineer, Plants & Projects, NESD

• R. M. Douglas, Manager, QASD

• A. E. Edwards, Assistant General Supervisor, Admin Services, QASD '

• R. P. Heibel, General Supervisor, Operations, N0D

• J. R. Hill, Supervisor, Operations Training, QASD M. S. Kostelnik, Engineer,-Primary Systems, NESD W. Lange, Engineer, Primary Systems, NESD

• L. S. Larragoite, Licensing Engineer, NESD l

J. R. Lemons, Manager, N00  ;

• W. J. Lippold, Manager, NESD '

• C. R. Mahon, Principal Engineer, Primary Systems, NESD A. Marion, Senior Engineer, Licensing, NESD l

• W. P. McCaughey, Engineer, Licensing, NESD '

• C. L. Olsor, Principal Engineer, Mechanical Engineering, NESD

• Roberson, General Supervisor, Quality Control and Support, NMD

• K. Romney, Senior Engineer, Quality Assurance, QASD

• L. B. Russell, Manager, Nuclear Maintenance Division (NMD)

L. Salyards, Principal Engineer, Licensing, NESD

• K. H. Sebra, Principal Engineer, Electrical Engineering, NESD

• R. P. Sheranko, General Supervisor, Mechnical Maintenance, NMD j

• L. A. Sundquist, General Supervisor, Quality Control and Support, NMD

• A. R. Thornton, General Supervisor, Plants & Projects, NESD

• J. A. Tiernan, Vice President - Nuclear Energy

• E. F. Wasson, Supervisor, Procurement Quality, QASD

• L. Wenderlich, General Supervisor, Electrical and Controls, NMD l

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NRC C. Y. Cheng, Chief, Materials Engineering Branch, NRR

. ^J. Durr, Chief, Engineering Branch, Region I l M. R. Hum, Materials Engineering Branch, NRR

• C. Trimble, Resident Inspector

• C. Wenzinger, Chief, Reactor Projects Branch #3, Region I K. R. Wichman, Materials Engineering Branch, NRR

• Denotes personnel present at Exit Interview on May 15, 198 . Followup of Environmental Qualification Deficiencies i Background On March 23-27, 1987, an NRC inspection (50-317/87-07; 50-317/87-08) was conducted at Calvert Cliffs Units 1 and 2 to review the status of the licensee's EQ program. During the inspection, the NRC found that tape splices identified on electrical leads of certain safety related solenoid valves were not included on the list of electric equipment important to safety required to be maintained in accordance with 10 CFR 50.49, and there was no documentation in a qualification file to indicate that the splices were qualified to perform their intended function under postu-lated environmental condition In response to the NRC findings, the licensee conducted an immediate followup inspection of their EQ program at Unit 2 which was shutdown at the time. Based on their initial finding of additional unqualified tape splices at Unit 2, the licensee voluntarily commenced a shutdown of Unit 1 on April 1, 1987 to perform an evaluation of the EQ program at both units so as to determine the magnitude of the problem. During this evaluation, the licensee identified several other tape splices, as well as several other items of electrical equipment important to safety, which were either: (1) not included on the list required to be maintained in accordance with 10 CFR 50.49; or (2) not environmentally qualified in that there was no documentation available in a file to support qualifi-cation, or bot The purpose of this part of the inspection was to review the adequacy of the licensee's ongoing inspection, evaluation, rework, and interim maintenance program Inspection and Maintenance Program The inspector reviewed the licensee's inspection plan and approach to identification of in plant environmental qualification (EQ) deficiencie Design Engineering Section Procedure No. DESP-16, dated April 21, 1987, was developed as an interim procedure for performing reviews of EQ main-tenance packages and for the control and usu of the EQ master list. All activities associated with the design, procurement, installation, main-L_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

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tenance, and replacement of equipment on or affecting the EQ master list are governed by the requirements of this procedure. The procedure in- l l cludes checklist attachment B, C, D, and E which identify inspection parameters for splices, motor operated valves, solenoid operated valves,

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terminal blocks, switches., electrical penetrations, 480 volt motors, and i other EQ equipment in the inspection pla Using the interim procedures, the licensee inspected all electrical equipment listed on the 10 CFR 50.49 EQ master list with the exception !

of the reactor vessel level instrumentation which is not yet required l to be operationa A representative sample of EQ cables (26) were in-spected from the issuance (cable reel) to circuit us The inspection of resistance temperature detectors (RTDs) was limited to three RTDs as the RTD splices were installed by the' licensee under a surveillance pro-

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l gram to ensure proper selection and use of the qualified Raychem splices. )

The EQ maintenance package used in maintenance of environmentally quali- l fied equipment is controlled through Appendix 200.90 of Procedure No.

, CCI-200J. The maintenance package includes the EQ traveler, the quali-fication maintenance requirement sheet (QMRS), the E-406 installation ,

instructions, applicable inspection checklist (DESP-16, Attachment B, '

C, D, or E), and drawings. Quality Control (QC) reviews and verification ensure that the maintenance package contains the latest document revi-sions. The responsible Maintenance Group Supervisor (RMGS) reviews maintenance packages and assigns personnel to perform the work. The RMGS signifies his review by signing Section II of the EQ travele Upon 1 completion of the work, the RMGS reviews and signs the completed work I package with concurrence of QC and the Equipment Qualification Design I Enginee i Final EQ approval results when the maintenance order and travelers are l forwarded to operations as positive indication that the equipment is acceptable and ready for any applicable post-maintenance testin The NRC inspector reviewed the following maintenance orders verifying compliance with the established interim procedures:

Maintenance Order No M (#12 Auxiliary Feedwater Room Fan Motor)

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207-108-738C (Pressure Switch #1-PS-2085)

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207-101-471A (#11 MSIV Close Dump Valve)

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207-105-623A (#11 MSIV Pump Air Supply Valve)

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207-099-420A (Damper Motor #1-M0-5437)

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207-098-343A (Safety Injection Flow Transmitter)

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207-111-849A (Junction Box Drain Holes)

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207-113-906A (Junction Box Terminal Block Upgrade)

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i i Training The inspector reviewed records of the licensee's EQ training program for EQ inspectors. Training sessions were held on April 9 and 10, 1987 for all shift personnel involved in EQ inspection. Four sessions were held, each consisting of a 45 minute lecture on 50.49 requirements and use of l the EQ master list and a 15 minute question / answer sessio Attendance at these sessions included electrical and control personnel, electrical /

mechanical QC personnel, and planning and scheduling personne Additional training was held on April 21 and 22, and May 1, 1987 to dis-cuss inspection parameters for splices, nut / bolt connections, shims, motor connections, breakouts, and use of installation procedure E-40 Training on application of heat shrink tubing was held on October 9, 198 This was a three-hour session for QC and engineering personnel which included hands-on-application for licensee personnel of heat shrink tube splice In discussions with craft and supervisory personnel performing the EQ inspections, the NRC inspector found personnel to be knowledgeable and confident in the performance of the work assignments involving EQ in-spection operation Physical Walkdown The NRC inspector performed a visual inspection of select EQ equipment inside and outside containment to ascertain whether repair and/or re-placement work performed was in accordance with established procedures and instruction The inspector examined the following 50.49 equipment:

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Motor Operated Valve No. 2-MOV-626 located in East Penetration, elevation 27'-0", Unit Solenoid Valve No. 2-SV-3832 located in East Penetration, elevation 27'-0", Unit Solenoid Valve No. 1-SV-5177 located in Component Cooling Room,

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elevation 5'-0", Unit I

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No. 11 Charging Pump located in Charging Pump Room, elevation-10'-0", Unit j

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No. 21 Charging Pump located in Charging Pump Room, elevation-10'-0", Unit I i

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Electrical Penetration No. ZF12WE3 located in Containment, elevation l 45'-0", Unit 1.

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Pressure Transmitter No. 1-PT-1013B located in Containment, eleva-tion 45'-0", Unit 1.

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Level Transmitter No. 1-LT-1114C located in Containment, elevation j 45'-0", Unit i

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Solenoid Valve No. 1-SV-611 located in Containment, elevation 45'-0", Unit Solenoid Valve No. 1-SV-4150 located in Containment, elevation 45'-0", Unit Junction Boxes (containing 50.49 circuits) located in Containment, elevation 45'-0", Unit No violations were identifie EQ Master List The inspector reviewed the licensee's EQ master list noting that the licensee does not differentiate between items important to safety and safety rclated equipment. The licensee's policy has been to classify items important to safety as safety-related items and includes these items in the master lis One recent addition (March 5, 1987) to'the EQ master list is the ECCS Room Fan Cooling System. Addition of this system has raised a number of questions on the qualification status of cable used, whether the cables are run in safety related cable trays and the qualification status of the position switches and pressure switches. The licensee has pro-vided a Justification for Continued Operation (JCO) to permit operation until these concerns are resolve No deficiencies were note Summary The licensee's programs for resolution of the E0 deficiencies were found to be thorough and provided reasonable assurance that EQ equipment in the plants was properly qualified. A more detailed NRC team inspection of the licensee's EQ program is being planned for later this calendar yea . Followup of ASME Code Replacement Parts Deficiencies As reported in detail 6 of Inspection Report 50-317/87-10; 50-318/87-11, the licensee informed NRC on April 23, 1987 that certain replacement items (principally threaded fasteners) not fully meeting construction code (ANSI e

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B31.7) requirements had been used in some Class 1, 2, and 3 component The replacement parts of concern had been precured for safety related applications as permitted by the licensee's QA program with certain well defined controls, but did not meet code requirements over and above the applicable ASTM mate-riais specifications. Such code requirements involved marking, certification, anc'/or nondestructive examinations. Unresolved item 50-317/87-10-01; 50-318/ ,

87 11-01 was opened pending licensee resolution of this problem including I

. determination of its safety significance.

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l The inspectors reviewed the licensee's identified deficiencies and corrective j

action plans regarding improper use of non-Code fasteners (without procer i certification and nondestructive examination (NDE)),'and involving the use f of the incorrect Code class of tubing materials (Class 2 vice Class 1). Fastener Screening Program Review The inspectors observed the licensee's ongoing program for screening approximately 30,000 maintenance requests / maintenance orders (MRs/M0s)

for pressure retaining and support components (e.g. , flange, fittings, valves & hangers) that potentially were replaced with new fasteners from commercial quality stock. The inspectors observed that the reviewers followed a prescribed flow plan featuring two independent review cycle l The review staff consisted of engineers, operators and engineering tech-nicians. The reviewers were furnished with written guidelines that they were required to read prior to initiating the review. During this pro- l cess the guidelines were available.at all times in the review area The screening process disclosed approximately 80 MRs/MOs that required fastener replacement because commercial quality fasteners were poten-tially used. The licensee was in the process of replacing all identified and potential commercial quality fasteners that were used improperly in safety-related Class 1, 2, and 3 systems with appropriate Code class fastener The inspectors noted that this deficiency was apparently the result of a misuse of freestock bolting materials when routine work was performed i that involved fastener replacement (s) and the correct materials (Mech Nos) were not specifically called out at the planning stage for the Maintenance Order (MO). It apparently stemmed from a misunderstanding

., of the term " safety-related" by the site personnel. They thought that l items procured for safety related applications, such as commercial grade ;

fasteners, were suitable for use anywhere in the plant including ASME '

cooe applications. This was described by the licensee as a training proble Maintenance Order Parts Replacement h iew The inspectors reviewed with the planners (personnel responsible for q planning the Mos) three M0s involving replacement of fasteners and three M0s involving materials and/or welding. The M0s were identified as 207-

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124-234A, 207-126-301A, 207-041-951A, 206-051-886A, 203-003-396A and 207-031-339 The planners appeared to be knowledgeable of and attentive to class designations as applied to materials described in the M0 Successful completion of the M0 tasks depends upon the planners initial assessment of the work and the materials required. M0s are initiated ,

by MRs generated by engineers or mechanic The pedigree of the mate--

rials is established initially in the MR as either a safety related (SR)

or a non-safety related (NSR) class. This is verified by the planner in the preparation of the M0s using the _"Q" List Manual. The planner then refers to P&I drawings for size, the M-601 manual Bechtel Code de-signations for specific Code class, the material requirements, and me-chanical numbers (Mech Nos). The Mech Nos are a computerized system of material categories that provide a grouping of parts with distinct mate-rial properties and NDE attributes as specified by Code requirement The Mech Nos are supported by applicable certified material test reports f (CMTRs) or certificates of compliance (C0Cs).

The inspectors found that the replacement parts retained their Mech Nos and traceability through storage, distribution, and final usage through ,

use of tags. After the M0s are prepared by the planners, they are screened prior to and post implementation by a panel of reviewers with j significant maintenance expertise as a recent initiative. The inspectors interviewed a QC inspector who has participated in the review plan. He was found to be knowledgeable of material classification requirements and demonstrated how this review is guided by GL-32 which provides Guidelines for pre-review of NSR and SR M0s.

I The inspectors noted that new fasteners being used in the corrective

, action replacement program were being handled as a special case to ensure traceability and proper material to prevent recurrence of the Mechanical l

Commercial Quality (MCQ) proble '

The inspector noted in his review of the aforementioned M0s that bolts and nuts were identified with heat numbers and were traceable to CMTRs furnished by the supplier, A&G Engineering. A review of the CMTRs indi-cated conformance to bolting and nut specifications and ASME Code Section III Class 1 requirements. A & G, who holds on ASME QSC "45J" was audited by BG&E in Oct. 16-17 1986. The inspector reviewed the audit report and found it to be a generally thorough quality assurance audit. One finding was cited and was closed on 1/16/8 A warehouse inspection was conducted by randomly selecting six parts identified with SR Mech Nos to determine if the accompanying CMTRs were retrievable. The inspector found that the CMTRs were readily retrievabl j

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The inspector also reviewed three Bechtel material purchase orders with respect to the pedigree of originally installed ANSI B31.7 fastener All three purchase orders correctively specified ASTM A193G7 bolts and ASTM A1941H nuts. In addition, the purchasing order packages contained CMTRs or COCs as require I No violations or deviations were note l l

c ., Test Instrumentation Review The inspectors verified the accuracy of various instruments and equipment intended for testing fasteners in-situ er in the laboratory. These in-cluded instrumentation and equipment for determining chemical constitu-ents, hardness and quality. The chemical analyzers used optical emission spectrography and x ray fluorescence. These instruments provided the correct results when tested using known chemistry samples provided by the NRC. These samples represented three grades of steel. The optical emission instrumentation provided quantitative results yielding results very similar to the NRC spectrographic concentrations. The X-ray an-alyses provided semi quantita'.ive results (i.e., it indicated conformance or non-conformance when compaied to its alloy data bank with permissible ranges of constituents as pres:ribed by applicable materials r ecifica-tions). With regard to hardne: s, the licensee's stationary Rockwell machine produced hardness results which compared favorably with the NRC results. The licensee's portable hardness tester (EQU0-TIP) also proved to be accurate. It produced values that were similar to the NRC results from an A193 B7 sample and with its own calibration sample. The ultra-sonic procedure, "UT Informative And Pressure Retaining Stud Material" using the longitudinal wave was successfully demonstrated by the licensee using calibration samples of various bolt sizes. The inspectors con-cluded that the licensee's laboratory equipment and instruments were capable of producing accurate results in the areas of chemical analyses, hardness testing, and quality as determined by ultrasonic testin Tubing Review The licensee reviewed the application of Class 2 tubing vice Class 1 tubing and was able to justify its continued in place use by performing a stress analysis on the fittings to prove that they met applicable requirement Summary The inspectors found that the licensee's use of commercial quality fast-eners was apparently due to the unintentional disregard of the Code (B31.7) by the licensee's staff. The licensee's decision to categorize fasteners as commercial quality was never challenged by the licensee's staff possibly due to the lack of trained personnel knowledgeable of Code requirement The problem appears to have been rooted in the myriad of  ;

terms and classes which were promulgated by the three Codes (B31.1, B3 '

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& ASME Classes 1, 2, & 3) at the time the decision was made to categorize fasteners as commercial quality. Although such categories as safety class, non-safety class, safety related, non-safety related and ASME III Class 1, 2, & 3 still persist today, the decision to utilize ASME III Class 1 fasteners for the present replacement program and the licensee's increased attention to Code classification and requirements should pre-l clude a recurrence of the fastener problem. In addition, the licensee l has established a task committee to develop permanent corrective actions to preclude recurrence of this problem. These actions will be examined in future routine inspection I Unresolved item 317/87-10-01; 318/87-11-01 remains open pending licensee l examinations to establish the materials properties of replaced commercial {

quality fastener . Post Maintenance Testing I Post Maintenance Testing (PMT) is required by Calvert Cliffs Instructions (CCI) 200 " Nuclear Maintenance System" , specifically 200.50 " Operational Testing". This instruction permits insertion of test requirements by the maintenance planners, supervisors, the Operations Maintenance Coordinator, and the Control Room Supervisor, to be incorporated into the Maintenance Order Package. Test requirements, however, are not mandated by procedure. The procedure, CCI 200.50, specifies that the Operations Maintenance Coordinator or the Control Room Supervisor determines if a PMT is required and when con-ditions are appropriate for testing. No other pertinent direction is provided by this procedure regarding PMT. Operations Unit Administrative Policy 65-4, a document provided for use solely by control room operators, provides guid-

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ance on Post Maintenance Testing. The policy provides various maintenance practices and appropriate types of testing. However, in the tests there are no acceptance criteria, with the exception of portions of surveillance tests which are required for Technical Specification related components. However, for work packages utilizing the Field Change Request (FCR) process, the in-spector found that thorough PMTs were implemente A review was conducted of about 100 maintenance packages being processed through the Control Room. About 90% of these M0s required a functional or operational test without any further criteria or guidance. Operations Policy ,

85-4 requires that operators use the guidance to document the type of func- i tional test to be performed (i.e., for a fan motor - a phase rotation check l and running fan and blade direction checks should be performed). The guidance j does not provide the order of phase rotation, conditions to be noted while '

running the fan, the direction of blade rotation or any other discrete accept- l ance criteri '

Additionally, Policy 85-4 itself appears to be inadequate in that it only specifies a functional check of the equipment after maintenance. For example, after repacking a citarging pump a functional test is recommended. No guidance

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is given to observe the packino or criteria provided to determine how much leakage is necessary to cool the packing and how much is excessive. Due to

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the vagueness of the stated test (i.e., operational test or functional test)

both being undefined, the only results obtained are satisfactory or unsatis-factory. No concrete, usable data is obtained for comparison, reference, trending or equipment history. Performance data is not recorde Because of the lack of discrete tests for each component, and pre-established acceptance criteria, the testing performance provides only a low confidence level of general operability. This lends itself to being quite inefficient -

and inhibits the ability to predict equipment failure Regardless of the deficiencies within the provided guidance, the Control Room Supervisors (CRSs) do not use consistently the guidance that is provided thus resulting in non-uniformity in the performance of the same type tests on similar component The CRSs provide the last opportunity for input of any PMT into the mainten-ance package. This provides no review of the proposed test before it is im-plemented. The CRS is one of the busiest' positions on site. It would appear that the responsibility for incorporating appropriate PMT requirements might be better suited to another positio This weakness was discussed with the licensee representatives who stated that improvements would be made regarding clarity of tests to be performed, accept-ance criteria, and the administration of the PMT program. Program improve-ments will be reviewed during subsequent resident inspector observations of PMTs; this item is Unresolved Item No 50-317/87-13-01; 50-318/87-14-0 No violations or deviations were note . Interdivisional Implementation of Engineering Requirements The inspectors performed a review of the licensee's methodology for ensuring compliance with engineering requirements of a scope necessitating interdi-visional coordination. The tour aspects reviewed were 1) Engineering func-tions and requirements, 2) Engineering interface with the field (Operations, Maintenance and Quality Assurance), 3) field implementation of engineering requirements, and 4) field feedback to Engineerin i Engineering Functions and Requirements The current Nuclear Engineering Services Division (NESD) was created '

through a licensee reorganization that became effective on December 30, .

1985. NESD is comprised of three sections: Design Engineering, Plans ;

& Projects Engineering, and Technical Services Engineerin !

The inspectors found that the procedures governing the functions and performance of NESD are the " Quality Assurance Procedures" (QAPs), the 1

"Calvert Cliffs Instructions" (CCIs), the " Design Engineering Section

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Procedures" (DESPs) and the " Nuclear Engineering Procedures" (NEPs) and

" Nuclear Engineering Operations Guidelines" (NE0Gs). The CCIs and QAPs

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are generically applicable to NESD, Operations (N0D), Maintenance (NMD)

and Quality Assurance (QA). These procedures govern all site functions and activities. The NEPs and NE0Gs control nuclear testing as performed ,

by Technical Services Engineering. The DESPs are applicable only to the Design Engineering Section. Apparently, there are no other procedures applicable to NESD functions or to the performance of engineering re-quirement During the December 1985 reorganization, the licensee established the .

role of " system engineer" whose apparent function is to become the system I expert with regards to system design basis, function, operation, surveil-lance, testing, modifications / changes, and maintenance. Also, the system ,

engineer is apparently tasked with responsibility for ensuring system j compliance with all regulatory and engineering requirements. System engineers are generally assigned 2 or 3 systems, which often are un-related in any way. One may be electrical and the other mechanica Similarly, the licensee has lead engineers apparently assigned the re-sponsibility for performance and compliance with respect to requirements that cut across interdivisional boundaries (e.g., environmental qualifi- I cation).

The inspectors noted that the aforementioned functions and responsibili-ties of the system engineers and lead engineers are only apparent func-tions and responsibilities as they are not described in any licensee procedure or document or via any programmatic training, though the role of system engineer has existed for well over a yea The licensee stated during the course of this inspection that they intend to establish a training program for system engineers at some future, un-defined dat Through discussions with several system engineers, the inspector found that the system engineers currently perform what they assume are their duties through the use of QAPs and CCIs that specifically govern sur-veillance testing, maintenance, modifications and other applicable evolu-tions. However, many of these procedures have not been revised ade-quately to reflect the role of the system engineer and, as such, provide little specific guidanc There currently exists no firm mechanism or system to ensure that the system engineers are aware of applicable engineering or regulatory re-quirements or of any changes that may occur in these requirement Generally, they are informed by Licensing via a Facility Change Request (FCR) or memo that a regulatory requirement has changed and that proce-dural revision may be necessary. Similarly, they sometimes are routed copies of vendor technical manual revisions applicable to their system Any other knowledge of engineering or regulatory requirements is achieved through independent study or on-the-job experienc . - _ _ _ _ - _ -

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The system engineers do not directly revise operations or maintenance procedures that are performed to ensure compliance with current or new engineering and/or regulatory requirements. Rather, they must request that NOD or the procedures revision group for maintenance procedures up-date these procedures to reflect the necessary changes. Generally, they do not review these procedures to ensure that the required changes were actually made in a proper and timely manne Conversely, the inspectors noted that the functions and responsibilities of the design engineering staff, as provided in the DESPs generally were better defined, explained and controlled. Some of the areas controlled by the DESPs include design changes, procurement, equipment qualifica-tion, Q-list control, document and drawing control and seismic qualifi- i catio It should be noted however, that the EQ deficiencies were partially at-tributable to inadequacies in the DESP procedural guidance as discussed below, Engineering Interface with the Field The inspectors reviewed the system for communication interfaces between NESD (particularly the system and lead engineers) and the field for en-suring full compliance with engineering and regulatory requirement l The current interface system was found by the inspectors to be rather informal and undefined with potential for the loss of significant in-formation (e.g., the EQ and MCQ deficiencies previously noted).

The method of communication used by the system and lead engineers to ensure compliance by N0D or NMD with requirements or with changes in requirements was usually a memo from one engineer to another requesting that an action be taken. There is apparently no tracking system to en-sure compliance with or completion of these actions nor is a responding memo to the originator from the recipient required or generally performe This system is used by the lead and system engineers to request required operations and maintenance procedural revisions, to provide technical guidance and to provide clarifications to ensure regulatory complianc t i Field Implementation of Engineering Requirements A review was conducted of how the field, particularly NOD and NMD, comply with engineering requirements that are provided by NESD. Emphasis was placed upon the areas of EQ and MCQ where specific interface deficiencies had been previously note _ - - _ _ _ _ _ _ _ _ _ _ _ _ _

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I 1) Environmental Qualification Requirements Through discussions with electricians and supervisors and through the review of conflicting documents, the inspector ascertained that information communicated to the field from NESD regarding the ac-ceptability of the use of standard electrical tape in the field for environmental qualification purposes was unclea This was clearly a contributing factor in the use of non qualified tape splices in the fiel A memo dated December 5, 1986 to K. Pickering from J. P. Perkins regarding Non-Conformance Report 3915 clearly indicates that for some applications, use of electrical tape was considered acceptable, yet another memo dated July 19, 1985 from A. Marion to the depart-ment heads, requires the use of heat shrink tubing on safety related low voltage terminations in harsh environments. This memo also acknowledges the use of tape is acceptable "only if the tape compo-sition is known". The memo further indicates that tape would be acceptable "for selected applications". "However, the E-406 (elec-trical construction standard) would be revised to detail the re-quirements to utilize Ray Chem shrink tubing c:; a standard." Sub-sequently, though the standard was revised in March 1987, the engi-neering requirements were still confusing in that: E-406 11.3 " Ray Chem Installation Standard" (A) Ray Chem for Instrument and Control connections and (B) Ray Chem for motor connections both state " Refer to the Comp. No. versus Qual. No. List in CCI 208 for the QMR (qualification maintenance requirements) sheet that gives the splice connection method".  ;

I Three independent electricians attempted to walk the inspector l through the above instructions without success. Later the inspector I determined that (1) a Comp. No. versus Qual. No. List does not exist .

in CCI 208; (2) both a Comp. No. and a Qual. No. are found in the i 50:49 List; and (3) only the QMR sheets are found in CCI 208. The l instructions would be clearer if worded "use the component number !

found in the 50:49 List to reference the qualification number. Use '

this qualification number to find the appropriate QMR sheet in CCI 208 that should provide the appropriate splice connection method."

Further, reviews of several of the QMRs of CCI 208 " Qualification Maintenance Programs", revealed that none had any requirements for splicing methods, for the use of Ray Chem heat shrink tubing, or for torquing transmitter covers, junction boxes or other EQ water tight enclosures. Additionally, though a section for post mainten-ance testing exists, in almost every case no testing was require Improvements in this area are neede The inspector also noted that past Field Change Request (FCR) re-quirements formulated by NESD with regard to EQ were inappropriate to the circumstances in that FCR 83-1033 was written by NFSD to up-grade solenoid valves to EQ standards. The FCR's title, " Procedure

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l l for Installing Environmentally Qualified Rebuild Kits for In-Con-tainment Solenoid Valves," mislead the electricians into believing that only a kit was to be installed into-the existing solenoid valves. However, a note at the beginning of the procedure stating

" solenoid valve should already be removed from control valve and taken to a suitable work area." was overlooked (possibly due to the apparent simplicity of installation of the upgrade kit). Instruc-tions were followed during the installation of the kits except that reinstallation of the solenoid was not performed since they had not -

been removed from containment, the kit was installed with the valve !

in place and, therefore, step 9 of the procedure was not performe j This step required reinstallation of the solenoid and sealing it j with a Ray Chem environmentally qualified seal assembl Addition- I ally, Ray Chem tubing was not provided with the rebuild kits. More clarity was necessary in the FCR package to emphasize the need to upgrade the splices as well as the valve The licensee acknowledged these problem They had previously com-mitted to revise / clarify such procedures before interim measures l (DESP-16 as discussed in Section 2.a) are discontinued.

l 2) Material Qualification Requirements Engineering requirements in the field regarding material specifica- <

tions are found on plant drawings and in QAP 15 " Changes, Tests, j and Experiments". In both cases, the requirements are very general and simply reference other drawings where specifications can be found (i.e. M-600 and 601). Engineering requirements also are found l on FCR packages and in the Control Work Package (CWP). Both clearly ,

define the required specifications. Only in the Maintenance Order / '

Maintenance Request systems do the specifications become vagu This appears due to the lack of detailed instructions to the main-tenance planners who compile the M0 package.

Previously, maintenance planners for the M0 package would research I the type of material required for a particular job utilizing the appropriate system drawings plus the use of the M-600 drawing which l provided correct material specifications (e.g., ASTM specification). '

However, no instructions or training was provided to make the planners aware of the use of the M-601 drawing in order to find the component ASME class (if appropriate).

Training or instructions were not provided to maintenance planners to detail the necessary methods to perform their tasks. In some cases, this resulted in not obtaining the ASME class of the replace-ment component and not seeking out the material number required in order to obtain the correct part from procurement which would in-clude the appropriate certification _ _ _ _ _ . _ _ . _ - _ _ _ _ _ _ _ - _ _ _ - - - - . _ _ _ _ - _ . - - -

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In this regard, engineering requirements were not fully implemented in the field. This was a contributing factor to the MCQ problem Other areas where communications weaknesses similar to those in the EQ and MCQ areas were noted was between engineering and operations depart-ments and between engineering and the PM program and surveillance pro-gram These areas need to-be evaluated by the licensee to establish better communication method d. Field Feedback to Engineering The inspectors reviewed the feedback process from the field (particularly N00) to engineering. They found that though the system (and lead) engi-neers were responsible for their assigned systems (tasks), very little feedback from the field is procedurally prescribed or. required. For example, CCI-104H, " Surveillance Test Program" provides the licensee's guidance and requirements concerning surveillance testing including in-terface with the system engineer. This procedure purposefully excludes the system engineer from involvement with many aspects of the surveil-lance program affecting his system. In reviewing the operations surveil-lance program, the inspectors found that the following information generally was not shared with the responsible system engineer:

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concurrence with or knowledge of revisions to operations surveil-lance test procedures

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scheduling of applicable system surveillance testing  ;

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parts replacement during surveillance testing

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temporary changes to surveillance test procedures

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out of specification test results, components adjustments or mal-functions during surveillance testing unless unable to correct during the performance of the test

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review of applicable operations surveillance test for system trending

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justifications for out of specification results including POSRC reviews of surveillance tests The inspectors found that information flow from NMD was better as the system engineers are included in the procedural review process and in the completed surveillance test review process. However, the inspectors did note that there existed a considerable time delay between the per-formance of these surveillance tests and the availability of the results to the system engineer for revie .. ..

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. Summary The inspectors concluded that though the system and lead engineers ap-parently are accountable for their systems / tasks, they a*e not provided with appropriate job definitions, training, procedures, information flow, and authority to ensure that their assigned systems perfori.' properly and are in compliance with applicable engineering and regulatory requirement )

The licensee needs to evaluate and take action to permit bette.' perform-ance of the functions of lead and system engineer l

{ Quality Assurance Review Review of Quality Assurance Coverage The inspector reviewed the licensee's QA Program with particular emphasis on Quality Assurance (QA) audits and other overview functions which could have identified the EQ and MCQ problems. In addition, observations were made concerning the overall QA audit program. Also, the inspector re-viewed the development of the QA audit group during the past two years in order to put into proper perspective the recent EQ and MCQ issue i The inspector noted that prior to January 1, 1986, the Quality Audits Unit (QAU) was divided in half with basically 6 auditors located on site and 6 auditors located in the Baltimore Office where the Engineering Section was also located. The off-site auditing group's primary task was to review the various engineering functions which included engineer-ing activities at Calvert Cliffs and at the licensee's fossil plant With this background established, the inspector reviewed the following:

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Audit personnel qualifications and trainin )

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General conduct of audits by the QAU including audit plans, sched-ules, reports and finding Specific audit files pertinent to the EQ and MCQ issue Finally, the inspector had several observations concerning the overall QA audit progra I Audit Personnel Qualifications and Training j

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Licensee management recognized several years ago that additional techn1- j cal expertise was needed in the QAU. This fact was reinforced in a pre- i vious NRC inspection where an unresolved item (50-317/85-22-04 and 50-318/85-20-04) addressed this issue. This issue was recently closed based on the licensee's commitment to include in QAU Procedure 3, " Audits",

a provision requiring technical expertise on an as-needed basis. The ,

inspector discussed this issue with several QA personnel and determined i

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l that the licensee was committed to developing in d ue, 1987, a firm list of technical consultants requirements of the QAU program. While the majority of these personnel would be licensee employees, it was recog-nized that certain audits may require outside consultants such as the EQ area which was probably the weakest technical area within the QAU grou The inspector reviewed the qualifications and training records of the 13 QAU auditors who conduct the audits. Only 3 of these auditors are not qualified as lead auditors and these personnel are recent (within the past year) additions to the QAU. The inspector noted that several rersonnel from other licensee working groups (Operations and Maintenance)

have joined the QAU since the licensee's reorganization of January 1, 1986. This should be a long term positive influence for the QAU. Also, 8 of the 13 auditors have been in the QAU since only 1984 which basically indicates that the current group is relatively ne However, it still has retained some valuable experienced personne Training for the auditors both on-site and off-site concerning selected subjects was planned annuall Based on these observations, it appears that the licensee's QAU is de-veloping its personnel such that improvements in the audits performed by the QAU should be expecte c. General Conduct of Audits The QAU follows the guidelines of QAUP 3, " Audits," for preparing audit plans. This guidance specifies a structured checklist which each auditor I must complete prior to performance of the audit. This checklist contains items such as:

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Review previous audit report

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Incorporate concerns of the Off Site Safety Review Committee (OSSRC)

reviewer

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Review Audit Information Book The inspector was advised that the Audit Information Book was one of the mechanisms used to coordinate miscellaneous important issues from various plant sources (e.g., Engineering, Quality Control). Knowledge of these important issues by the auditor would enable him to assess performance in this area. Also, the inspector was advised that the group being audited is usually given the opportunity in advance of the audit to have a particular area audited. These factors enable the auditor to prepare the audit plan with input from outside groups (e.g., OSSRC, audited group, etc.). The general approach by the QAU in preparing audit plans appears to be sound.

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The inspector reviewed the 1986 and 1987 audit schedules and several 1986 audit reports with their findings, recommendations and resolutions and had the following observations: '

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Basically, the same audits are being planned for 1987 as were per-i formed in 1986 with no change in audit frequenc Some audits have been eliminated for 198 Resolution of audit findings generally occur within agreed time limits but many time extensions were requeste More substantive recommendations were being generated in 1986 than in earlier audits which were generally well accepted by audited organizations. This leads to the conclusion that sudit depth and quality is improvin There were isolated cases where unusually high numbers of findings 4 or recommendations occurre {

l With this understanding of the general conduct of audits, the inspector reviewed specific audit activities pertinent to the EQ and MCQ issue ' Specific Audit Activities Concerning EQ and MCQ Issues 1) EQ Audits The licensee had performed annual audits of its EQ activities since 1981 with relatively insignificant audit findings through the 1985 audit. In 1982, there were 2 findings and in the other 4 years, i i

there was 1 finding each year. However, Audit 86-15 which was per-formed in March / April, 1986, had 6 findings. The inspector ques-tioned the responsible engineer in the Plant and Project Engineering Group concerning their initial response to these findings. In par-ticular, one of the findings was quite significant in that 12 of the 65 Qualification Maintenance Requirement Sheets (QMRSs) had problems or discrepancies that required correctio ,

The responsible 1 engineer indicated that he was surprised when 12 QMRSs were found to be deficient as he expected possibly 1 or 2 might have problem The inspector noted that the findings of Audit 86-15 supported and supplemented the recent NRC enforcement action concerning EQ. Fur-thermore, the inspector inquired with the QA Manager and QA General !

Supervisor concerning why QA had not independently recognized a deep i rooted EQ problem after Audit 86-15. As previously mentioned, the !

EQ area is the weakest in terms of technical expertise in the QAU l

and hence, QA felt that they were not in a position to make such a determination in 1986.

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l The inspector was concerned that possibly other audits had been ,

performed in 1986 and 1987 which might point to a potential, deep

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rooted program problem other than EQ. The inspector inquired with the QA General Supervisor if a structured review of 1986 and 1987 audits had been performed to address this concern. No such review had been performed and the licenses agreed that such a structured j review would be don i l

2) MCQ Audits j i

The licensee compiled a new surveillance report (S-87-11) to deter-mine the effectiveness of the corrective action program concerning ]

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the MCQ issues. This surveillance had just begun and was approxi-mately 30% complete at the end of the inspection. Therefore, only preliminary information was available. No significant findings had been generate Observations Concerning Overall QA Audit Program As previously mer.tioned, the licensee has made noted progress in the QAU' )

l group in developing its personnel. Also, the licensee noted that.it is  !

committed to performing a late 1987 audit of a safety system which will j be patterned after the Safety System Functional Inspection (SSFI) tech- '

niques conducted recently by NRC at other utilities. This indicated good initiative and commitment to quality by the licensee. While this SSFI audit is new, the inspector asked the QA General Supervisor if the QA audit program is reviewed annually to determine if new audits are war-ranted in response to noted weaknesses. For example, several different audits (e.g., corrective Maintenance and EQ) may be performed where two working groups (e.g., Engineering and Maintenance) have problems. Con-sequently, this situation could warrant a new audit to look at the engi-neering/ maintenance interface on all issue In response to this question, the licensee indicated that a trend report of QA audit program findings is developed every 6 months for OSSRC review but the trend report has not reached the point of recommending that new audits be performed in response to noted weaknesses. The QA General Supervisor agreed that an annual review of the QA audit program would be done to determine if such new audits are warrante . Exit Meeting The inspectors presented their findings to licensee management personnel at an exit meeting on May 15, 1987. The attendees are listed in Section At no time during this inspection was written material provided to the licen-see by the inspecto Based on the NRC review of this report and discussions held with the licensee representatives during this inspection, it was deter-mined that this report does not contain information subject to 10 CFR 2.790 restrictions.

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