IR 05000317/1989030
| ML20011E095 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/29/1990 |
| From: | Gray E, Moy D, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011E094 | List: |
| References | |
| 50-317-89-30, 50-318-89-31, NUDOCS 9002070319 | |
| Download: ML20011E095 (8) | |
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REGION I
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50-317/89-30 Report Nos. 50-318/89-31
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U 50-317 Docket Nos.
50-318 k
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License Nos. DPR-69
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.i Licensee:
Baltimore Gas ~ & Electric Company
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P.O. Box 1475 Baltimore, Maryland 21203
Facility' Name: ~ Calvert Cliffs Nuclear Power Plant, Units 1 & 2
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Inspection At:- Lusby, Maryland Inspection Conducted: December 18-22, 1989 Inspectors:
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E. H.
ray,-Senior R6Tctor Engineer -
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DgT. Moy R actor Engineer date-
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-Approved by:
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/ / R. Strosnider, Chief Materials date
C/and Processes Section, DRS
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v Inspection Summary:
Routine announced inspection on December 18-22, 1989'
(Combirie~d Inspection Reports 50-317/89-30 and 50-318/89-31)
-Areas Inspected: The engineering and technical' support for Calvert Cliffs
. Units:1&2. The areas inspected included organization, staffing, quality-assurance audits of engineering, NCRs, plant modifications, technical training and management support.
Results:
No violations were identified.. The inspectors concluded that--
s engineering support to plant operations had improved significantly during the
.past year. However, several' weaknesses were noted as detailed in Section 6.0.
9002070319 900130 PDR ADOCK 05000317
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DETAILS
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1.0 Persons Contacted
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- A. Anuje,,QA Supervisor T. Camiller, Maintenance Superintendent
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- C.. Cruse, Nuclear Engineering Manager
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- P. Katz, Design Engineering.--General Supervisor r
J. Lippold, Technical Services Engineering General Supervisor
- W. McCaughey, Licensing
- B. Hontgomery, Licensing, Principal Engineer
- B.LMorrison, Engineering Planning K. Romney, Quality Control Supervisor
- A. Thornton, Plant Engineering, General Supervisor J. Wood, Quality Assurance J. Yoe, Training-Supervisor E. Zumwalt, Project Management, Principal Engineer
- Indicates those attending.the exit meeting.
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The inspectors also contacted other administrative and technical
Jersonnel during the inspection.
2.0 Scopo The scope of the inspection was to review and evaluate the effectiveness of. the engineering organization in supportinn plant operations, mainte-g%.
nance, and modifications and to assure that these activities.are in confor-
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mance with the Technical Specifications, Final Safety Analysis Iteport and
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Ti regulatory requirements.
Staffing, personnel qualifications, planned and N
completed activities, project status and backlog, interface between different plant engineering organizations and management control were
' reviewed in the inspection.
3.0 Engineering Organization (37700)
The Nuclear Engineering Service Department (NESD)- includes-the Design
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Er.gineering Section (DES),. Plant Engineering (PE), Technical Services Engineering and Plant and Project Management. This structure puts engineering departments that support plant operations, maintenance, m6difications and design analysis under one manager. Outage planning and major long term projects including the diesel generator project and the spent. fuel storage project are responsibilities of the Nuclear Outage Management Department.
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Engineering review of modifications is performed by the Design Engineering Section in accordance with Design Engineering Section Procedure (DESP-7).
This design procedure applies to any design change activity relating to l
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safety related structure, systems and components anc' non-safety-related systems described -in the FSAR.
Design Engineering performs calculations cand design work for minor and major modifications, interfaces with Plant System-Engineers, and i_s cognizant and involved with the modification installation.
The interfaces with System Engineering provide Design Engineering input to the maintenance and operations Departments.
Staffing levels of the Nuclear Engineering Service Department have been increased to further improve this organization's capability.
The NESD staffing was increased during 1989 to supplement the DES and PE sections.
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To provide additional capability in both Design Engineering and Systems Engineering coverage to meet projected engineering support needs, staffing
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inci eases in NESD are planned for 1990.
The System Engineer support group was found' proficient and capable in handling their assignments.
However, the licensee acknowledged that their system engineers' wcrk load is high
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based on tht.-responsibilities defined in the system engineer's job descrip-tion dated August 14, 1989.
The 110 plant systems and 65 component and non-system responsibilities are divided between 39 system engineers including first; level supervisors.
However, the licensee is instituting measures to ease the staff engineers work load in the future.
For example, the licensee
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is in the process af increasing the system engineering staff size.
In each of the engineering areas, constant communications and interfacing were evident between the engineering organizations and plant departments, r
The inspector concluded that the engineering organizational changes implemented by the licensee have improved responsibility' and account-
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ability of nuclear engineering activities.
-3.1.Engi.4.ering Modif1 cations Design : criteria and safety analysis details for several minor engineering modification projects were reviewed by the' inspector.
These project packages included the following.
- Replacement of level and pressure tranamitters on the Reactor Coolant i
Drain Tank (RCDT) FCR-87-120. The RCDT is occasionally operated at L
vacuum conditions. This has resulted in calibration shifts and damage-l to the level and pressure transmitter.
The replacement transmitters a
l are designed to withstand these vacuum conditions.
I Replacement of the existing 8.875" Reactor Coolant Pump (RCP) seals
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with 8.750" seals (FCR 87-0074).
The old seal had a specified design life of three years. However, this was not achieved at the Calvert Cliffs site. With the 24-month refueling cycle adopted at Calvert g.L, Cliffs, a reliable seal is required to minimize unscheduled shutdowns.
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-Replacement of safety related instrumentation per Regulatory Guide
1.97 (FCR-83-0024). This modification replaces the unqualified
resistance temperature detector (RTD). assemblies, temperature trans-mitters' and temperature recorders for Shutdown Cooling System
. Temperature with environmentally qualified units in accordance with i
Regulatory Guide 1.97, Category-2 requirements.
Design longer studs for Steam Generator Secondary.Manways
(FEC 89-01-402).
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Modification to the flushing connection on the Low Pressure Safety
Injection (LPCI)-pumps to allow periodic venting (FCR 89-98-140).
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Proper LPCI pump operation may require periodic venting of. the pump casing to prevent vapor binding. This modification will:not impact the ability to flush the LPCI pumps. When pump venting is required the cap-is removed and tygon tubing is run from the flush line to a
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floor drain;
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The inspector reviewed the safety analysis for each of the above modification projects.
The inspector noted that in each case the safety.
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analysis described.the consequences of the proposed modification and
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concluded with a safety evaluation reflecting the provision of 10 CFR 50.59 as implemented by procedure DESP 7.
The inspector concluded that the safety analyses appropriately considered the 10 CFR 50.59 provisions.
3.2 Independent Review of Engineering Documents
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The NRC inspection 88-28 identified a concern (Violations 317/88-28-01 and 318/88-28-02) related to the verification of. engineering work being conducted
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by an individual-not independent of.those performing the original work.
The licensee completed root' cause analysis and corrective actions to establish the extent of the problem and to prevent recurrence. During this inspec-tion, the Design Engineering Section Procedure DESP-7, which defines the attributes of an independent review and a sample of engineering documents L
(FCR'87-30-1) requiring review were examined. Based on these reviews the-h inspectors concluded that corrective actions are being effectively implemented l-and independent reviews are being performed adequately. Violations (
317/88-28-01 and 318/88-28-01 are elosed.
l 3.3 Engineering Interfaces I-The inspectors reviewed the communications between the Design Engineers and System Engineers, who coordinate the implementation of engineering modifications, and the plant staff. The Design Engineers conduct the
. engineering design portion of the modification and the System Engineer Group implement installation in the field. Both of these groups report to
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the manager of Engineering. The inspectors concluded communications have L
improved between Design Engineering, Plant Engineering, Maintenance and L
operations during the past year. -On December 21, 1989, the inspectors E
attended the licensee's Daily Plant Meeting on site. The purpose of the meeting was to inform the operating staff and others including engineering h
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i on the_ daily activities. The inspectors found the meeting was well. organized
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and provided.a means for communication of current plant issues between
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plant managers and staff. Additional-scheduled daily meetings.are held involving engineering and other plant departments including operations, maintenance and management.
3.4 Training
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The licensee's training program was inspected to evaluate the adequacy of training for the engineering support personnel. The inspector discussed
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the program with the training supervisor and reviewed the procedures and.
records. The technical staff training program is designed to provide
Calvert Cliffs professional personnel with supplemental training to perform engineering activities properly, and in a safe, effective and efficient ma nne r-.
The program for new employees includes a fourteen weeks engineering
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course addressing plant operation. Additionally, each one of the technical staff positions has been analyzed and a unit-specific qualification card
'is being developed and is scheduled to be completed by Spring of 1990.
Qualification cards are being developed for individual systems to train new Systems Engineering staff.
4.0 Non-Conformance' Report Requirements The review of Non-Conformance Reports (NCR) for reportability was an unresolved item in engineering inspection 50-317/88-28.
In response to this: unresolved item, the licensee initiated procedural controls on the initiation and review of NCRs to define the responsibility for review for
.t potiential reportability of an issue to the NRC and to provide for_documenta-tion that the review was performed. Quality Control was defined to be the focal point for NCR processing.
The following actions were taken by the licensee in this process:
(1) Calvert Cliffs. Instruction 116, " Control of Deficiencies and Non-Conformance Reports" was revised to incorporate more structured steps-to address _the reportability assessment.
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(2) Quality Assurance Procedure 26, " Control-of Conditions Adverse to Quality" Revision 41, dated April 28,1989, was-updated to provide controls to prevent the inadvertent use of non-conforming items in Safety-Related Systems and components as 'part of the NCR process.
.(3) A sample of NCRs were reviewed by the Quality Assurance Department to assure that the reportability and safety issues were adequately identified.
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The inspector reviewed the licensee's'Calvert Cliff Instruction (CCI).116-and verified its use by discussion with.the responsible QC manager and
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review of a sample of NCRs. While review of NCRs for reportability is under
control, the inspector noted an excessive NCR backlog. The licensee
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acknowledged this problem but did not present a plan to provide for resolution.
In addition, the cognizant licensee personnel responsible for n
tracking the NCRs did not have an adequate means of identifying the open NCRs in a timely manner. As a result, the licensee representative was unable to provide an accurate' account of open NCRs to the NRC inspector.
NCRs that are required to be resolved' prior to startup (mode restraining)
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are tracked separately with emphasis to assure completion of these-prior.
to plant mode change. As part of the performance improvement program (PIP)
a strong effort was.made to have problems identified. The result of this was a: significant increase in the number of NCRs which are the means to document problems until they are closed out by analysis or other corrective
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actions. The backlog'of NCRs includes those that are mode change restraint,
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and other less.signficant NCRs, The number of NCRs that were mode change
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restraining on December 20, 1989 was 91 for Unit 1.
5.0 Quality Assurance Involvement in Technical Support The Quality Assurance area was reviewed by the inspectors to evaluate QA involvement in assessing the quality of engineering support services. The i
Quality Audit Section in Quality Assurance is responsible for conducting audits including engineering audits for Calvert Cliffs.
The followings QA audits of Engineering Department activities-were conducted during 1989:
QA Audit 89-12: June 27 to October 13, 1989-A Safety-System Functional Inspection of the Low Pressure Safety Injection. (LPCI) System including shutdown cooling was performed.
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QA Audit 89-11: April 4 to August 17, 1989
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An Outage Modification Inspection was performed during the Unit 2 Refueling Outage. The audit evaluated outage effectiveness to determine if improvements were warranted in planning, scheduling and implementing modification activities.
QA Audit 89-17 August 28 to October 6, 1989
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An audit was performed to evaluate the effectiveness of thb Environmental Qualification (EQ) program implementation and to verify compliance to 10 CFR 50.59.
The inspectors reviewed the summary of the above audits. All three QA audits had substantial findings which were appropriately addressed by the licensee.
Licensee followups resulted in improvements in plant procedures and practices.
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6.0 Conclusion Based on this inspection the inspectors concluded that management support for engineering is adequate. Management has supported improvements in engineering including increased staffing, Q list upgrading, QA audits,
. regular meetings that involve engineering in plant activities and promo-tion of an active program to identify problems for resolution.
Engineering has provided much input to resolve the issues identified in the previous TALP, and the 88-28 engineering and technical support inspection; although, work to bring these issues-to ccopletion will extend into 1990. The inspectors found that the. engineering staff as presently organized is capable of adequately supporting plant operations. ' Increased NESD staffing, particularly in systems engineering is planned to optimize engineering invo.lvement. The following weaknesses were identified by the inspectors.
(1) An excess number of Non Conformance Reports (NCR) presently are open.
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(2) Only approximately 40% of the Maintenance Orders (MO) for February and September of 1989 identified the System Engineer, suggesting less than full identification of the system engineer to those performing maintenance work.
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(3) The lack of review of SSF1 findings by Design and Systems Engineers to establish those findings that may be applicable to other plant systems.
_(4) The procedure DESP-6 on calculations emphasizes the computational aspect of a-calculation but does not clearly define other aspects of the calculation process such as statement of the problem, design basis considerations, and methodology.
(5) A Maintenance Order (Example M.0.299-161-825C) with an unsatisfactory
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post maintenance test is closed out on the basis of issuing another M0 or Maintenance Request (MR).
However, the original M0 is not shown
to be cleared when the Post Maintenance Test is later performed satis-factorily under the subsuqent M0 or MR. This practice is permitted
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by the procedure on M0 processing; however, the situation where test results remain noted as' unsatisfactory after they have been performed satisfactorily in subsequent work presents increased possibility of bypassing a required test.
7.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the beginning of the inspection.
The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee's management at the exit interview on i
December 21,1989 (see paragraph 1.0 for attendees).
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'The inspector provided the licensee a copy of NRC temporay instruction
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2515/97,~" Maintenance Inspection." The temporary instruction 2515/97,
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L Maintenance Inspection," is provided to a licensee in advance of a
' Maintenance Team Inspection so the licensee can prepare to properly e
p suppcrt the inspection. This preparation includes gathering documentation:
and procedures identified in the 2519/97 instruction and outlined in a.
separate listing titled " Enclosure."
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Except for the Temporary Instruction 2515/97 and " Enclosure" related to the announced maintenance team inspection to begin in February 1990, at r
no time during the inspection was written material provided to the
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licensee by the inspectors. ~The licensee did not indicate that proprietary
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bL information was involved'within the scope ofLthis inspection.
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