IR 05000317/1988015
| ML20151T951 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/08/1988 |
| From: | Blumberg N, Oliveira W, Prichett V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151T950 | List: |
| References | |
| 50-317-88-15, 50-318-88-15, NUDOCS 8808180342 | |
| Download: ML20151T951 (8) | |
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U.S. NUCLtAR REGULATORY COMMISSION
REGION I
Report Nos.
50-317/88-15 50-318/88-15 Docket Nos.
50-317 50-318 License Nos.
DPR-53 DPR-69 Licensee:
Baltimore Gas and Electric Company P.O. Scx 1475 Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Nuclear Power Plant, Units 1 & 2 Inspection At:
Lusby, Maryland Inspection Dates: July 5-8, 1988 Inspector:
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P WT 0liveira, Reactor fIgI~.r d d.e'
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,h-V/VhY V. Prichett, hesideg I/i pector date
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Approved by:
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N. J. Blumberg, Chieff 0perational Programs dite Section, Operations Branch, DRS
. Inspection Summary:
Routine unannounced inspection on July 5-8, 1988 (Combined Report Nos. 50-317/88-15 and 50-318/88-15)
Areas Inspected:
Implementation of the Design Changes and Modifications Program by the Design Engineering Section (DES) with special inspection emphasis on field -hange requests (FCRs). Also reviewed were the interface activities with the Training and Quality Assurance (QA) Sections.
Additionally, the inspector reviewed primary administrative procedures and instructions to assess implementation of the program for conformance to regulatory requirements.
Results:
No violations or deviations were identified.
The design changes and modifications program is in conformance with regulatory requirements.
The licensee is however, taking action to revise the primary administrative procedures, increase the DES staff and upgrade the training of the DES
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engineers in the FCR area.
8808180342 880810
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PDR ADOCK 05000317 Q
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OETAILS 1.0 Persons Contacted
- A. Anuje, Supervisor, Quality Assurance Unit
- S. Cowne, Licensing Engineer
"C. Cruse, Manager, Nuclear Engineering Support Department
- R. Douglass, Manager, Quality Assurance and Services Department
- M. Gahan, Systems Engineer
- P. Katz, General Supervisor, Design Engineering Section C. Mahon, Principal Engineer, Primary Systems Enginee-ing
- M. Milbrandt, Licensing Engineer
"L. Russell, Manager, Nuclear Maintenance Department United States Nuclear Regulatory Commission
- D. Trimble, Senior Resident Inspector
- V. Prichett, Resident Inspector
- Denotes those attending the exit meeting.
The inspectors also contacted other administrative and technical personnel during the inspection.
2.0 Design Changes and Modifications _P_rogram (27702)
2.1 Scope Fif teen out of fif ty facility change request (FCR) packages were selected from the "Must Do" section of the Design Engineering Job List. These "Must 00" FCRs contain NRC commitments and are scheduled to be completed by December 31, 1988. The inspectors reviewed these FCRs to determine whether:
Procedures establish controls and assign responsibilities
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for initiating and processing FCRs.
Procedures are administrative 1y controlled.
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Design Engineering Section (DES) engineers are knowledgeable
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of the procedures.
DES engineers are implementing approved and applicable
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procedures.
The activities for processing FCRs were assessed against primary administrative procedures such as Calvert Cliffs Instruction (CCl) 126, Nuclear Energy Division Control Procedure (NEDCP) 202, Design Engineering Section Procedures (CESP) 2, 7 and 14, and
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Quality Assurance Procedure (QAP) 15. Such activities were also assessed against the technical requirements and commitments such as Regulatory Guide 1.64 for Design Quality Assurance. These documents are listed in Attachment I.
2.2 Findings 2.2.1 Program Review.
The primary administrative procedures mentioned in paragraph 2.1 were reviewed by the inspectors. The procedures do not reflect the new management / organizational structure, and current FCR process. Action by the licensee is in progress to correct the procedures. Subsequent to discussing general procedural deficiencies with the licensee, the inspectors noted other FCR process deficiencies as follows:
CCI 126G: Description of the administrative control for
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the FCR process does not include: (1) activities of the Design Engineering Section (DES); (2) the assignment of responsibilities; (3) the project management process; and (4) step by step procedure for processing FCRs.
NEDCP 202: Description of the Project Management
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Process mentions but fails to describe the Work Management Committee's participation in the project management process. (see paragraph 3.0)
DESP-2: Instructions to the DES engineers are not clear
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for completing the checklist in their engineering discipline when the engineer participates in the safety analyses required by 10 CFR 50.59 (See paragraphs l
2.2.2 and 3.0 )
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DESP-14: Description of DES training does not address
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the guidelines for formal training, on-the-job training (0JT) or continuing training (see paragraph 3.0).
DES does not maintain a formal status of the FCRs
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listed in the Design Engineering Job List. A manpower and milestone chart is being developed by the licensee that will include the status of FCRs. Estimated completion of the chart is September 1988, and the chart will be monitored by DES periodically.
The above deficiencies are collectively considered an unresolved item pending the revision of the administrative procedures involved in the FCR process. (50-317/88-15-01 and 50-318/88-15-01)
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2.2.2 Facility Change Request (FCR) Review The inspectors met individually with each Lead Design Engineer (LDE) of a selected FCR to ascertain the DES engineer's familiarity with the FCR process as well as the DES engineer's training and qualifications. The results of the interviews and walkdowns of the FCR packages listed in Attachment I are as follows:
The engineers are technically knowledgeable with their
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FCR packages. Each of their design analyses included a review of the impact on the Technical Specification Design Bases.
Due to the heavy workload, management has approved an
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increase in the size of DES staff. Management is also providing the engineers technical guidance, resources and time to prepare for meetings, committee reviews and plant visits.
The engineers do not appear to have a thorough
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understanding of the FCR process.
For example, the engineers were not familiar with the flow path for processing FCRs, or when to perform a safety analysis.
See paragraph 3.1 for licensee's corrective actions.
The DES engineer's sign offs on the Form CC-2326
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checklist were inconsistent for verifying that a safety analysis has been completed by the cognizant engineer.
Variations of the sign off included: signatures or initials by the discipline engineers, LDE's initials, check marks, and the sign off block being left blank.
See paragraph 3.1 for the licensee's corrective action.
2.3 Conclusion The licensee is making progress in their effort to more effectively process FCRs. This conclusion is based on documentation reviewed, interviews conducted, licensee actions taken, and commitments such as:
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Developing and implementing the DEO Training Plan (see paragraph 3.1)
Increasing the size of the DES staff with trained and
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qualified engineers.
Revising the procedures to reflect the organizational
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changes and the current FCR process.
No viointions were identified,
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3.0 Training Interface With Design Changes and Modifications Program 3.1 Training Function DES and the Training Section are working together and have completed the INPO task analysis for DES training. They are de, eloping a DES Training Plan and will be revising procedure DESP-14. In the interim DES engineers have received or will receive training for processing FCRs such as:
The IN,0 accredited Engineer and Technical Staff Program
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Course for new engineers.
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The qualification card training for engineers.
The supervisory training for lead design engineers (LDEs).
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Teamwork within the Design Engineering Section training Cours?,
Teamwork with other Departments training course.
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The 10 CFR 50.59, "Changes, Tests and Experiments," training
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conducted by a contractor.
The Project Management training course.
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The IEEE Class 1 training courses.
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3.2 Conclusion Based on the interviews and the documentation reviewed, the DES and Training Section management are taking action to assure that the DES engineers are properly trained in processing FCRs.
No violations were identified.
4.0 QA/QC Interface With Design Changes and Modifications Program A safety system functional inspection (SSFI) of the Auxiliary Feedwater System (audit report no. 87-44) was reviewed. This audit was comprehensive and similar in format to the SSFIs conducted by the NRC.
The inspectors reviewed, with the DES representative, the report regarding the status of audit finding, as of May 31, 1988.
The inspectors found that the licensee was activery pursuing close out of ten delinquent findings.
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No violations were identified.
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5.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items or violations. Unresolved items are discussed in paragraph 2.0, 6.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance meeting conducted on July 5,1988. The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the July 8, 1988 exit interview (see paragraph 1 for attendees).
At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that oroprietary information was involved within the scope of this inspection, t
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ATTACHMENT I DOCUMENTS REVIEWED AND REFERENCE 0 2.0 Design Changes and Modifications Program Requirements 10CFR 50.59, Changes, Tests and Experiments. (Paragraph 2.2.2)
Regulatory Guide 1.64, Rev 2, June 1976, Quality Assurance Requirements for the Design of Nuclear Power Plants (Paragrapn 2.1)
Procedures Calvert Cliffs Instructions (CCIs) 126-G Administrative Control of Facility Request. (Paragraphs 2.1 and 2.2)
Nuclear Energy Division Control Procedure (NEDCP) 202, Project Management Process. (Paragraphs 2.1 and 2.2)
Desir.n Engineering Section Procedure (DESP) 2, Rev. 3, Control of Changes, Tests, and Experiments. (Paragraphs 2.1 and 2.2)
DESP-7, Rev 3, Design and Design Review. (Paragraphs 2.1 and 2.2)
DESP-14, Nuclear Related Indoctrination, Training and Qualification (Paragraphs 2.1 and 2.2)
Quality Assurance Procedure (QAP) 15 Changes, Tests, and Experiments.
(Paragraph 2.1)
Facility Change Requests (FCRs) (Paragraph 2.2.2)
84-0149, Add Time Delay to AFAS Actuation 84-1087, (R>G> 1.97 #8) SG Pressure 85-0085, Modify SW Piping ECCS Pump Room Coolers 86-0194, FSAR Change-RWT Temperature specification 86-0224, Replace Pressurizer Pressure Transmitters (PT-102A, etc)
87-0063, FSAR Change--Core Flush 87-0065, FSAR Change for Containment Integrity 87-0015, Install AFW Drain Tanks 87-0117, Replace Actuators on CV-100E/F
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j 87-0128, Replacel/2-SV-1587 and 1-SV-15SS (SRW to EDG)
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87-0144, Change Setpoint of Turbine Trip UV Relay j
8S-0022, Revise SMECO Breaker 252-2301 Overcurrent Protection 8S-0036, Replace Safety Injection Tank Level Transmitters
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3.0 Training Interface With Desian Chances and Modifications Program Requirement 10CFR 50.59, Changes, Tests and Experiments. (Paragraph 3.1)
Procedure _s DESP-14, Nuclear Related Indoctrination Training and Qualification (Paragraph 3.1)
4.0 OA/QC Interface With Design Changes and Modifications Program Safety System Functional Inspection (SSFI) Report No. 87-44. (Paragraph 4.0)
Status of Audit Findings Report of May 31,1988. (Paragraph 4.0)
Miscellaneous Design Engineering Job List. (Paragraph 2.2.1)