ML19332E678
| ML19332E678 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/04/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-89-141, NUDOCS 8912110115 | |
| Download: ML19332E678 (18) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475. BALTlMORE, MARYLAND 21203 GEORGE C. CREEL vica Pngsiotwv Nuctraa ENEMOY s (300 soo+4asa December 4,1989 U. S. Nuclear Regulatory- Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant !
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 i Reniv to Notice of Violation. EA 89-141
REFERENCES:
(a) Letter from Mr. W. T. Russell (NRC) to Mr. G. C. Creet (BG&E),
dated November 2, 1989, Notice of Violation (NRC Inspection l Report Nos. 50-317/89-15; 50-318/89-16) !
S (b)- NRC Inspection Report Nos. 50-317/89-200; 50-318/89-200, Special Team Inspection Report, dated May 23, 1989 i
(c) NRC Inspection Report Nos. 50-317/89-15; 50-318/89-16, Special Inspection, dated July 10,1989 l l
(d) Letter from Mr. G. C. Creel (BG&E) to Document Control Desk l' (NRC), Response to luspection Report Nos. 50-317/89-200; 50-318/89-200 (Special Team Inspection), dated June 21, 1989 (e) Letter from Mr. G. C. McGowan (BG&E) to Mr. J. M. Taylor (NRC), i Performance Improvement Plan Implementation Program, dated ,
July 31,1989 j y
Gentlemen:
i Pursuant to the provisions of 10 CFR 2.201, Enclosure (1) is our reply to the i I
violations delineated in Reference (a). These violations were identified during a Special Team Inspection conducted during February 27 through March 31, 1989 (Reference b), and a follow-up special inspection conducted during May 22 through 26, and June :9 through 16,1989 (Reference c).
8912110115 991204 PDR ADOCK 05000317 O PNU g
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Do'cument C:ntr:I Desk December 4,1989 i Page 2 l
The Notice o'r Violation involves four areas:
o implementation of the Measuring and Test Equipment Program as required by our Quality Assurance Procedures, o Control of distribution of Technical Manuals to the operating staff, o Maintenance of reviewed and approved procedures for welding process activities, and 1
o implementation and control of the Quality Control Inspection Program.
As we discussed with you at the July 20, 1989 enforcement conference, the broader implications of these issues involve the procedures to control activities important to safety, and the resources to properly implement these procedures. We discussed our corrective actions for these issues at the enforcement conference, as well as in our response to the Special Team Inspection Report (Reference d).
1 Our long-term corrective actions associated with our Performance Improvement Plan (PIP) Implementation Program (Reference e) address the underlying causes associated with these issues, in addition, specific PIP action plans are in place which address-QC improvements, Technical Manual improvements, as well as - Procedure Upgrade. We are committed to providing ~ the resources and management attention necessar- to improve in these areas.
Should you have any further questions regarding this matter, we wil , sed to discuss them with you.
Very truly yours,
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GCC/LSL/bjd Enclosure cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC J. E. Beall, NRC T. Magette, DNR
. i V . - ENCL,OSURE (1)
BALTIMORE GAS AND ELECTRIC COMPANY l REPLY TO NOTICE OF VIOLATION EA 89-141 1
INSPECTION REPORT NOS, 50-317/89-15; 50-318/89-16 l
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l VIOLATION A Failure to assure that tools, gauges, and instruments, and other measuring and testing devices used in activities . affecting quality are properly controlled, calibrated, and i adjusted at specified periods to maintain accuracy within necessary limits (10 CFR Part 50, Appendix B, CRITERION XII).
Al. Contrary to Quality Assurance Procedure (QAP) -17 " Control and Calibration of Mea;uring and Test Equipment" Section 5.0, the supervisor of a group responsible for measuring and test equipment (M&TE) did not ensure approved procedures were used for control and calibration of test gauges. During performance of Surveillance Test Procedure (STP) 0-67-1, " Check Valve Operability Verification" on March 3, 1989, these uncontrolled gauges were used to test safety-related steam generator feedwater check valves.
Admission Or Denial Of The Alleced Violation The violation occurred as stated.
Reasons For Violation Instrument Maintenance (IM) technicians, rather than the M&TE technicians, were calibrating temporarily installed gauges. These gauges were used for monitoring plant parameters during the performance of STPs. The gauges were not controlled as required by CCI-120D, " Calibration Program for Measuring and Test Equipment." Neither a post-use calibration was performed or a usage log was maintained, lastead, on a quarterly interval, the gauges were compared to more precise gauges that were calibrated to traceable standards. The Instrument Maintenance Shop ~ did not realize this practice should have been controlled by procedures.
The root cause for the discrepancy is insufficient communication of expectations and performance standards. Specifically, the IM technicians deviated from the requirements of CCI- 120, because appropriate expectations as to procedural adherence in this area were not promulgated.
Corrective Stens That Have Been Taken A nd The Results Achieved immediately after the issue was identified, the following actions were taken.
The temporarily installed gauges, maintained by the IM Shop were immediately checked. -None were found out-of-calibration. A Shop / Lab Memorandum I-89-1, Revision 0, was issued, from the Assistant General Supervisor - IM, to all IM
- ~Tp ENCLOSURE f1)
IIALTIMORE GAF AND ELECTRIC COMPANY REPLY TO NOTICE OF YlOLATION EA 89141 INSPECrlON REPORT NOS. 50-317/89-15; 50-318/89-16 Shop personnel, directing them to check all gauges for calibration immediately before an0 after each installation. The following additional corrective actions have been completed; o A non-conformance report (NCR) which addressed use of uncontrolled M&TE gauges installed by the IM Shop was issued. The NCR addressed actions to control the M&TE gauges and to check completed STPs for unusual data, o New M&TE gauges were ordered and received. These gauges are maintained o by the Test Equipment Unit and issued from the Test Equipment cage.
o Through a revision to Shop / Lab Memorandum I 89-1, Instrument Maintenance technicians and planners were instructed to use only Instrumentation that is controlled and calibrated by the Test Equipment Unit. A usage control system (u:ing a tag attached to the gauge) was developed for these gauges and their serial numbers are being recorded on the maintenance and/or test documents.
c We have developed a method to calibrate those gauges, used in primary f systems, which cannot be decontaminated and released from a radiologically controlled area. A usage control system has also been developed for these gauges, o A Quality Assurance Surveillance was requested to verify that facets sf CCI-120D were complied with for temporarily installed test equipment.
This was completed on July 31, 1989, tel verified that the original concern ,
- has been satisfactorily addressed.
i Corrective Stem That Will lie Taken To Avoid Further Violations !
Calvert Cliffs Instruction - 120 will be revised to more clearly delineate the '
responsibilities of the various site organizations which use or calibrate M&TE.
The i.evision w ill include clernents of INPO Good Practices, " Control and Calibration of Measuring and Test Equipment?
D;tte When Full Comoliance Will lie Achieved Full compliance was achieved on August 23, 1989. ,
A 2. Quality Assurance Procedure - 17, Section 12.1.2, requires that when test equipment is known to be defective or proven to be outside the acceptable calibration tolerances, a non-conformance- report shall be prepared promptly.
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ENCLOSURE Q)
IIALTIMORE GAS AND ELECTRIC COMPANY ,
REPLY TO NOTICE OF YlOLATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; 50-318/89-16 Contrary to this, on two occasions (January 11 and May 1,1989) an instrument (Fluke Multimeter) that had been used in the performance of work on a safety-related system was found to be out of tolerance and non-conformance reports were not prepared.
Admission Or Denial Of The Alleted Violation The violation occurred as stated.
Reasons For Violation The cause of the violation was inattention to detail by the Test Equipment Supervisor when reviewing these two calibration data sheets. This can be attributed to insufficient resources (personnel) allocated to the M&TE Shop.
Corrective Signs That llave fleen Taken And The Results Achieved A review of calibration records of Test Equipment files was conducted. Folders containing 5,502 calibration data sheets were checked. Two additional calibration data sheets were found that needed NCRs, The NCRs were written and issued for resolution. Additionally, the Test Equipment Supervisor conducted training for Instrument Repair Technicians and Test Equipment Shop personnel on this issue.
For test equipment calibrated but not controlled by the Test Equipment Shop (e.g., Performance E igineering controlled test equipment), as the walk-in calibrations are found out-of-tolerance, an NCR is initiated.
Corrective Stens That Will fle Taken To Avoid Further Violation As discussed in response to Violation A.1 above, CCI-120 is being revised to further clarify the responsibilities of various site organizations which use or calibrate M&TE. In addition, the Test Equipment Shop personnel complement is being increased.
1 Date When Full Comnlinnee Will lie Achieved Full compliance was achieved on August 28, 1989.
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ENCLOSURE (1)
BALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOI.ATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; 50-318/89-16 A 3. Quality Assurance Procedure - 17 Section 8.1.3, requires that uncalibrated M&TE be physically segregated from calibrated equipment. Section 9.0, further requires that storage conditions shall protect cleanliness and meet suitable s; environmental conditions. Contrary to this, calibrated Performance Engineering Unit (PEU) M&TE, stored in a large equipment cage located at the 12-foot level of the Water Treatment Building,- was neither segregated from uncelibrated M&TE nor stored in a controlled area with suitable environmental conditions. ;
6dmission Or Denial Of The Alleced Violation The violatiori occurred as stated, llowever, the PEU was applying a "" REJECTED" sticker to clearly identify the status of uncalibrated MATE.
Reasons For Violation The failure to meet these requirements of the Calibration Program can be attributed to poor accountability of M&TE Program Managers.
Corrective Steos That flave Been Taken And The Results Achieved On July 17, 1989, applicable PEU M&TE was moved to a clean, dedicated, '
environmentally controlled location. Access to the new location is controlled by the PEU. Additional storage exists within the PEU office space. This storage area also meets the requirements for cleanliness, suitable environmental conditions, and controlled location.
The segregation of calibrated versus out-of calibration M&TE is currently being met and shall continue to be met by placing a REJECT sticker on the out-of-calibration equipment in accordance with Q AP- 17. In addition, a designated location has been reserved in the new storage room for out-of-calibration equipment.
The unit control procedure, PEUI-101, " Performance Engineering Unit Equipment Control and Calibration Program," was revised and approved on August 24, 1989.
This revision clarifies the requirements of QAP-17 and the unit's policies in reference to the M&TE Program. Unit personnel who use the M&TE were trained on the latest requirements of PEUI-101 on August 25, 1989.
Corrective Steos That Will De Taken To Avoid Further Violationt ,
l All corrective steps to avoid further violations have been taken.
l ENCLOSURE (1) ,
BALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOLATION EA 89-141 .
INSPECTION REPORT NOS. 50-317/89-15; 50-318/89-16 Date When Full ComDliance Will Be Achieved
- Full compliance was achieved on August 25, 1989.
VIOLATION B:
Failure to ensure that activities affecting quality are prescribed by documented instructions and accomplished in accordance with these instructions (10 CFR Part 50, Appendix B, Criterion V).
Bl. Contrary to CCI-122E, ' Control of Technical Manuals,"Section V.B., technical manual turnover ccver sheets were not being maintained in the Technical Library for the life of the component for the following technical manuals:
o " Woodward Booster Servomotor," dated March 24, 1988, o
- Lambda - Regulated Power Suppliet (LQ 412-42341)," dated March 24, 1988, o " Target Rock Technical Manual (TM100-01-01)," dated January 18, 1989, o "American Warming and Ventilation 184," dated November 4,1988, and o " Smoke Ejector, Super Van - Super Yacuum #2989," dated November 14, 1988.
D2. Contrary to paragraph V B.3f of CCI-122E, 51 vendor manuals or changes to these manuals, which were forwarded to the General Supervisor, Plant and Project Engineering (GS-P&PE) for technical review and approval prior to being returned to the technical library, were not reviewed within the required 15-day period.
B3. Contrary to paragraph V.B.5 of CCI-122E, at least 45 copies of unreviewed/
unapproved technical manuals had been forwarded to the on-site operating organization designated manual holders.
Admission Or Denial Of The Alleced Violations l
The alleged _ violations occurred as stated.
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ENCLOSURE (1)
BALTIMORE GAS AND ELECTRIC COMPANY REPLY 10 NOTICE OF YlOLATION EA 89-141 INSPECrlON REPORT NOS. 50-317/89-15; 50-318/89-16
}{casons For Violations One reason for unreviewed manuals is that CCl-122 did not provide adequate direction for technical review. This made technical review difficult to implement and contributed to the backlog. A contributing cause for lack of technical review is failure to allocate sufficient resources to support what was required. The large number of new and revised manuals to be processed and the substantial time required for technical reviews overtaxed existing resources, in addition, those individuals that were involved with control of vendor technical manuals were not held accountable for implementing the direction that was provided by CCI-122. This includes warehouse, document control, and
- engineering personnel.
These reasons are examples of a combination of root causes, including insufficient expectations and performance standards, insufficient resource allocation, and insufficient accountability.
Corrective Stens That llave Been Taken And The Results Achieved A Vendor Technical Manual Upgrade Project was formed, initial project activities included problem assessment and identification of preliminary corrective action.
Completed corrective ac: ions include the following:
o Document Control Unit Procedure (DCUP) - 13, " Processing and Control of Technical Manuals," was revised and now instructs Document Control to hold Technical Library copies of vendor technical information until dccumented verification of completed technical review has been received, o The GS-P& PE issued interim direction until CCI-122E is revised. This re-emphasized the necessity of technical review of vendor technical information, established a review checklist to be used during technical review, and specified that the review checklist be completed and returned to the Technical Library within 15 worki.ig days, o The necessity for and the use of turnover cover sheets was discussed with the warehouse supervisor and Quality Assurance (QA) receipt inspectors.
o All unreviewed manuals were identified. Out of approximately 4,000 manuals in the Technical Library, 429 manuals were determined to be unreviewed.
The locations and the custodians for each unreviewed manual were determined.
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- ENCLOSURE (1)
- liALTIMORE GAS AND ELECTRIC COMPANY REPLY 'IO NOTICE OF VIOLATION EA 89-141 INSPECPION REPORT NOS. 50-317/89-l$; $0-318/89-16 o Unreviewed manuals that had been issued to the field were re-called.
Custodians certified that re called manuals were returned Remaining unreviewed manuals were removed from potential circulation by Document Control, o Each backlogged manual was given a preliminary evaluation to determine potential safety-significance using a Preliminary Evaluation For m. linsed on the results of the preliminary evaluation, each manual was placed in one
- of three priority categories (i.e., Priority 1, 2, or 3). 'I he categories reflected the priority for performing a detailed technical review.
Priority I manuals include potentially safety-significant manuals and new manuals, or major revisions to existing manuals which are applicable to installed safety related plant equipment. Priority 2 manuals include minor revisions to existing vendor manuals which are applicable to installed safety-related plant equipment or revisions to non safety-related plant equipment. Priority 3 manuals include all other unreviewed manuals (e.g.,
equipment which is not installed in the plant). There are 91 Priority 1, 192 Priority 2, and 146 Priority 3 manuals.
o Priority I and Priority 2 manuals were ev;lunted using a Safety-Significant Review Checklist. As a result, 24 manuals were determined to be safety-significant. All of these manuals had been categorized Priority 1, The 24 safety-significant mancals received detailed technical review in accordance with the new, approved engineering review guidelines.
Operating, engineering, and maintenance procedures that are based on these safety-significant unreviewed manuals were identified, o Forty-two procedures were identified as possibly being affected by the 24 safety-significant manuals. Out of the 42 procedures, only one procedure (PUMP-9) was determined to require revision. This procedure contains information from the "Inside Durascal" technical manual (15523-01) regarding the change out of Durametallic low pressure safety injection (LPSI) pump seals. An NCR addressing the discrepancy between the technical manual and PUMP 9 was initiated by the project. Revised procedure pages were developed and are being incorporated into Revision I to PUMP-9.
o A check was made by the project to determine the effectiveness of short-term corrective actions. Turnover Cover Sheets are being properly used. New and revised manuals entering the system ate receiving technical review. No unreviewed manuals have been issued.
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ENCLOSURE (1) 4 HALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOLATION EA 89-141 INSPECTION REPORT NOS. $0-317/89-15; 50-318/89-16 Corrective Steos That Will Be Taken To Avoid Further Violatigfla CCI-122 is being revi>ed. The scope is being expanded to include controls for vendor technical manual information other than that included in technical manuals, such as Service Advice Letters, Technical Information Bulletins, etc.,
which may contain information pertinent to equipment installed or about to be installed at the plant. It will also provide detailed engineering guidance for conducting and documenting the required technical review. Finally, the proposed revision to CCI-122 will contain restructured time limitations based on a set of priorities.
l l Remaining backlogged manuals will continue to be reviewed, as appropriate, until all are properly issued and associated procedures are identified, reviewed, and revised, as necessary.
These long-term corrective actions are associated with Section 5.3.3 (Technical Manual improvements) of the Performance improvement Plan (PIP) Implementation j l
Program.
1 Date When Full Comoliance Will He Achieved Full compliance will be achieved in September 1990 when the remaining backlogged i
manuals are expected to be reviewed.
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l VIOI.ATION C:
Failure to establish measures to assure that special processes, including welding, are controlled and accomplished by qualified perumnel using qualified procedures in accordance- with applicable codes, standards, specifications, criteria, and other special requirements (10 CFR Part 50, Appendix B, Criterion IX).
l The measures established to assure that welding was controlled and accomplished in accordance with applicable codes, standards, and specifications were inadequate.
Specifically, a sketch posted adjacent to a weld rod bake oven, a measure designed to ensure such control, incorrectly depicted the location of the following three types of weld rod available in the oven, which could result in the failure to use the proper material required by various welding codes, standards or specifications.
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ENCLOSURE (1)
HALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOLATION EA 89-141 INSPECrlON REPORT NOS. 50-317/89-15; $0-318/89-16 Identification on Sketch Actually in Oven Stellite 215L, 1/8" Stellite 21 E 316-15,1/8" E 136 L-15,1/8" EV ICR-FE, 3/32" E 309 L-16,1/8" Admission Or Denial Of The Aller.ed Violation The alleged violation occurred as stated, llowever, the above mentioned sketch was only used as un aid to the attendant to give direction to the proper oven (i.e.. Austenitic, Carbon Alloys, etc.), it was not used to ensure proper rod issuance, control or traceability. Our filler material control tags were used to ensure correct control of welding rod / wire and are signed by the weld rod attendant as well as the welder. Each rod is individually verified and usage is accounted for upon return.
Reason For Viointion Although the sketches were only used as an aid to the attendant, no guidance had been established to verify the accuracy of the attendant's aid, Corrective Steos Taken And Resnus Achieve 11 in response to this item and in order to reduce possible future confusion, the sketches have been removed and discarded, Corrective Stens Thnf Will lic Taken To Avoid Further Violations Through the implemtntation of our Supervisory Job Observation Program, appropriate work practices will be observed in the field on a periodic basis.
IDie When Full Compliance Will lie Achieved i
We feel our material control tags ensured we met the requirements of I Criterion IX, llowever, the sketches were removed following this issue being brought to our attention. Therefore, we are in full compliance.
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ENCLOSURE (1)
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HALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOLATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; $0-318/89-16 VIOLATION D:
Failure to require activities affecting safety be prescribed by appropriate written procedures and be accomplished in accordance with these procedures (10 CFR Part 50, Appendix B, Criterion V).
Paragraph 7.0 of licensee Welding Program Procedure (WPP) 6,009 specifies that the temperature in the weld rod oven should be maintained between 225 F and 3500F.
Contrary to this, on March 28, 1989, the temperature in weld rod oven T-21 was 2200F, as indicated by the thermometer in the oven.
Admhsion Or Denial Of The Alleced Violation The violation occursed as stated. The oven referred to in this item was equipped from the manufacturer with a low quality gauge with readings in large increments and an accuracy range of 110 F. The purpose of these gauges is to give indication that the oven is powered and functioning generally in the right temperature range. The verification process used to ensure an oven setting was correct was a semi-annual calibration check. To date, during the course of these semi-annual calibration checks, there have been no known failures. The gauge of the oven in question was immediately verified as indicating 15 F lower than ,
actual. In reality, the temperature was 235 F and the oven temperature was, {
therefore, being maintained within the required range of 225 F to 350 0F. ]
Reason For Violation This was discussed above. ,
i Corrective Stens Taken And Results Achieved The defective gauge was replaced. As a conservative response to this issue, we have increased the periodicity of our oven calibration checks to quarterly. We have also included a requirement to verify oven temperature prior to electrode issue in our CCI-226,
- Filler Material- Control."
Corrective Stens That Will Be Taken To Avoid Further Violation All measures to prevent further violations have been taken.
ENCLOSURE (1) ,
IIALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF YlOLATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; $0-318/89-16 Date When Full Comotinnee. Will Be Achieved As discussed above, the oven was verified to have been within the required range.
Therefore, we are in full compliance.
ylOLATION E:
Failure to comply with Technical Specifications 6.8.l.a and 6.8.2, Contrary to Technical Specifications 6.8.1.a and 6.8.2, procedures were not established or maintained for controlling certain weld processes (which are used as part of maintenance, repair, replacement or modification work), and certain procedures, although established, were not reviewed by the Plant Operations and Safety Review Committee (POSRC), as evidenced by the following examples:
El. Procedure CCI-222, "Calvert Cliffs Control of Welding Activities" was cancelled by the licensee on November i1,1988, and was not replaced by an approved procedure to control welding activities.
E2. Shop / Lab Memorandum No, M-64, Revision 0, which replaced CCI-222 and delineated the requirements for filler metal control was not reviewed by the POSRC prior to issuance on February 14, 1989. This Shop / Lab Memorandum referenced Welding Program Procedures 6.006 and 6,009 (Revisions 9 and 10, respectively).
E3, Welding Program Procedures 6.006 Revision 9, and 6.009 Revision 10, had not i been reviewed by the POSRC.
Admission Or Denial Of The Alleced Violations !
The violation occurred as stated with one exception. November 11, 1988 was the date the last revision to CCl-222 was annroved. This CCI was cancelled on Febreary 28, 1989, subsequent to the issuance of Shop / Lab Memorandum No, M-64, Revision 0. Therefore, commencing on February 28, 1989, no POSRC-reviewed procedure existed which controlled the issue of weld rod filler material, I
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ENCLOSURE (1)
IIALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF YlOLATION EA 89-141 INSPECrlON REPORT NOS. 50-317/89-15; $0-318/89-16 I
Reasons For Violations Calvert Cliffs Instruction-222 was cancelled and inappropriately replaced by a .
non-POSRC-reviewed Shop / Lab Memorandum since portions of the CCI were outdated.
This was due to our interpretation of Technical Specification 6.8.1.a relative to Welding Program Procedures (WPPs). It was our opinion that (WPPs) were not required to be reviewed by our POSRC as required by Technical Specifica.
tions 6.8.1.a and 6.8.2. Our reasons were as follows:
- 1. Controls in accordance with 10 CFR 50, Appenuix 11 have been established for writing, qualifying, approving and issuing procedures to control special processes such as welding. These controls are defined in our QAPs. Our QAP-6, " Welding," meets the 10 CFR 50, Appendix il standards for review, distribution and revision of WPPs and assigns the Principal Metallurgist of IIG&E with the responsibility and control of the technical elements of the welding program.
- 2. All WPPs are designed to provide the administration and controls to meet code and regulatory requirements with respect to the narrow technical ;
fields of welding and metallurgical engineering. These procedures are prepared in accordance with applicable coaes, standards, specifications, criteria, and other special well-defined requireinents.
- 3. 11G&E has always maintained these well-defined administrative and technical implementing procedures under the guidance and control of the Principal Metallurgist. Welding Program No. 6 (as defined by QAP-6) is active and audited. Welding Program No. 6 is intended to meet the guidance of Regulatory Guide (RG) 1.33 and referenced standards.
- 4. Finally, Appendix 'A' to RG 1.33 has no reference to welding. Although we acknowledged welding as an element of maintenance, as stated above, our opinion had been that the focused nature of these procedures within a specific technical discipline did not require POSRC review. We have reassessed RG 1.33 and now feel there are elements within the WPPs which fall under the scope of Appendix "A."
Corrective Stens Taken And The Results Achieved Calvert Cliffs Instruction - 226,
- Filler Material Control,' was reviewed by our POSRC and subsequently approved on July 17, 1989, and Shop / Lab Memorandum No. M-64 was subsequently cancelled. This CCI more appropriately delineates the steps that are taken to ensure IlG&E personnel and contractors at Calvert Cliffs control the issue of weld rod filler material.
- - ENCLOSURE (1)
HALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF YlOLATION EA 89-141 .
i INSPECTION REPORT NOS. 50-317/89-15; 50-318/89-16 Corrective Stros That Will He Taken To Avoid Further Violations i
All WPPs, and Welding /Braring Instructions (WBis) are currently being reassessed relative to RG 1.33, Appendix A. Any additional WPPs or WBis whkh meet the criteria of procedures within the scope of RG 1.33, Appendix 'A' will be reviewed by our POSRC and approved by the Manager-CCNPPD.
Date When Full Comollance Will De Achieved The above screening, review, and approval of WPPs and WBis should be completed by December 29, 1989, and January 31, 1990, respectively.
VIOLATION F:
Failure to require that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activities to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity (10 CFR Part 50, Appendix B, Criterion X).
The Calvert Cliffs Quality Assurance Policy, Section 18.10, ' Inspection," states that activities that affect the quality of safety-related items are inspected as specified in approved instructions, procedures, and plans that specify requirements and <
acceptance criteria to ensure that work is done in conformance with particular requirements, Contrary to this, approved instructions, procedures and plans specifying requirements and acceptance criteria for the Quality Assurance Department's inspection of safety-related activities were not established to ensure that work was done in conformance with requirements.
Admission Or Denial Of The Alleced Violation The violation occurred as stated in that Calvert Cliffs did not have procedures for controlling, implementing, or documenting QC inspections that were specifically for Quality Control. Ilowever, Quality Control activities and requirements are included in the Quality Assurance Policy, Quality Assurance Procedures (14, 15, 16, 26, and 35); and CCis (101, 104, i16, 119, 133, 150, 152, 200, 201, 204, 208, 210, 211, 212, 218, 220, 410, 613, 620, 700, 701, 803, and 805). Although independent procedures for QC did not exist, abundant evidence of independent inspections is available in the documentation of Maintenance Orders (MOs), Controlled Wo.rk Packages, Non-Destructive Examination Reports, inspection Report, and Non-Conformance Reports (NCRs).
i ENCLOSURE (1)
I IIALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF YlOLATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; $0-318/89-16 Reasons For The Violation The failure to provide instructions, procedures, or plans is an example of insufficient monitoring, follow-up and trending. Also contributing to this was insufficient expectations and performance standards, in that priorities for QC coverage and sufficiently detailed inspection procedures were not provided.
Corrective Stens Tnken And The Results Achieved A
- Selection Criteria for QC Coverage, document was developed. The criteria document is a priority list for QC inspection coverage and includes requirements for waiving coverage. It was issued for use in March 1989, and was subsequently incorporated into QC administrative procedures, in July 1989, preparation and use of detailed inspection instructions began and a data base was developed to record application of the " Selection Criteria" and status of inspection procedure preparation. Quality Control administrative procedures were subsequently developed to control the preparation and use of inspection instructions.
To establish the longer-term goals for the QC inspection program, the Quality Audits Unit conducted a comprehensive evaluation of the QC process using a methodology similar to the NRC Maintenance inspection Guideline (dated June 1988). The evaluation identified several weaknesses in the Quality Control area, but it also noted that QC was performing an independent inspection of the work
_ process and was documenting the results of those inspections. Results of these evaluations have been factored into both the short and long term corrective )
actions. This situation was also noted in a follow-up NRC inspection ,
(Reference c), which concluded that ongoing work was being independently !
monitored and subjected to overview by QC personnel. The Quality Audits Unit also reviewed internal and external reports issued during the past two years for comments about QC, While an approach and direction for the QC inspection program has now been defined, Quality Control still requires management attention and increased resources to achieve our longer-term expectations. The following actions have already been accomplished. These are not all inclusive, nor are they the only l actions we will take to improve Quality Control.
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o The Vice President - Nuclear Energy Division (VP-NED) has identified QC j process improvements as a top priority project. j o A Quality Control Mission Statement has been issued.
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ENCLOSURE (1)
IIAtll'IMORE GAS AND ELECTRIC COMPANY REPLY 'IO NOTICE OF YlOLATION EA 89-141 INSPECTION REPORT NOS. 50-317/89-15; $0-318/89-16 o The General Supervisor - Quality Assurance periodiently reports to the VP-NED on the status of the QC improvements.
o Reorganization along functional craft lines has been accomplished. The reorganization includes a newly created position of Assistant General Supervisor - QC and a Quality Engineering (QE) Unit.
o Supervisors with outstanding technical and craft experience have been moved to QC.
o Several engineers have been added to provide technical support for the QC Units and to assist with QC improvements, o Revision *L" of CCI-200, *Nt. clear Maintenance System," was issued on July 10, 1989. It places QC in line for safety-related, Environmental Qualification, or welding MO review.
o Quality Control Procedures (QCPs) for preparation and control of administrative procedures, inspection activities, and inspection instructions have been issued. Development of other Administrative Procedures continues.
Corrective Steps Taken To Avoid Further Violations The commitment resulting from this item of the STI Inspection Report (89-200-09) was captured in the newly developed QCPs. Additional changes to the Purpose and Reference Sections, and the liases of these QCPs are being made to add references to QA policy requirements for maintaining approved instructions, procedures, and plans. This will ensure careful consideration of the QA policy prior to any future changes.
Date ~ When Full Compliance Will lie Achieved Development, issue, and use of Inspection Procedures began on July 1, 1989.
Inspection Procedures, now called Inspection Instructions, are prepared for each work document selected for inspection activity using the " Selection Criteria for QC Coverage " Compliance with this element was achieved on July 1,1989.
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- ENCL,OSURE (1)
IIALTIMORE GAS AND ELECTRIC COMPANY REPLY TO NOTICE OF VIOLATION EA 89-141 INSPECrlON REPORT NOS. 50-317/89-15; 50-318/89-16 Administrative Procedures QCP- 1, " Preparation and Control of Quality Control Procedures," QCP-2, " Quality Control Inspection Activities,* and QCP-4,
" Quality Control Inspection Instructions? were issued on July 13 November 15, and October 25, 1989, respectively. Of the eight Administrative Procedures issued or planned, these three ate directly related to providing approved instructions, procedures, and plans for inspection activities. Compliance with this element was achieved on November 15, 1989, when QCP-2 (the latest of the three QCP issue dates) was issued.
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