ML20059K704

Ack Receipt of Util 900515 Response to Violations Noted in Insp Repts 50-317/90-01 & 50-318/90-01.Agrees That Thrust of Notice of Violation Not Accurate But That Actual Violation Was Failure to Comply w/10CFR50,App B,Criterion Xvi

ML20059K704
Person / Time
Site:	Calvert Cliffs
Issue date:	09/07/1990
From:	Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Creel G BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9009240189
Download: ML20059K704 (3)

See also: IR 05000317/1990001

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SEP 0 71990

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Docket Hos. 50-317

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50-318

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Baltimore Gas and Electric Company

ATTN: Mr. George C. Creel

Vice President

Nuclear Energy

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Calvert Cliffs Nuclear Power Plant

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MD Rts 2 & 4, P.O. Box 1535

Lusby, Maryland 20657

Gentle:nen:

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Subject:

Inspection Nos. 50-317/90-01 and 50-318/90-01

This refers to your letter dated May 15, 1990, in response to our letter, dated

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April.9, 1990, and to the telephone conversations on August 15 and 22, 1990.

We have reviewed your responses to the violations and note the corrective

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actions taken to restore compliance. Your actions will be reviewed in future.

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NRC inspections.

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In the subject response, you did not accept Violation A, Part 1, as stated in

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that your procedures permit the use of corrective action systems other than

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the nonconformance reporting system for controlling deficient welds'provided

- that tracking and followup through closure are commensurate.

Further, in your

response, you' stated that the system actually used to track and followup the

deficient welds required improvement to provide documentation of repair defi-

ciencies'after the final NDE process, assessment of preventive actions, and

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trending. As we discussed in the reference telephone conversations, we agree

that the thrust of the Notice of Violation was not accurate but that the actual

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violatior e the failure to comply with 10 CFR 50, Appendix B, Criterion XVI

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as descr,M a above.

Therefore, the violation, as previously transmitted, is

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hereby c u nged to invoke 10CFR 50, Appendix B, Criterion XVI.

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Your response also denied Violation B of-that same Notice regarding the length

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of experience required to qualify visual inspectors.

Your procedure implies

that an inspector can achieve VT-1,2,3 and 4 certification with only 3 months

of total experience collectively.

Subsequent discussions with your staff on

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this' matter concluded that the codes and associated standards are not clear

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regarding the intent of the requirements and that a code interpretation is

appropriate. We, therefore, will hold our decision in abeyance on the disposi-

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tion of this violation pending your receipt of the code interpretation and

-review by the NRC.

Your response to' Violation C of the same notice regarding the numbering and

location system for weldt in the erosion corrosion program was found

acceptable.

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OFFICIAL RECORD COPY

WINTERS 6/12/90 - 0001.0.0

90092401e9 900907

09/04/90

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ADOCK 05000317

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SEP 071990

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Baltimore Gas and Electric Co.

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Based on this and other related inspections, we note that the nondestructive

examiw. tion inspection program at Calvert Cliffs is composed of two distinct

elements, the onsite and the corporate inspection groups.

It appears that the

source of our concerns exist predominately with the corporate inspection group

that performs inspections for the fossil as well as the nuclear facilities.

Recognizing that the quality requirements for the fossil facilities are not as

stringent,.we believe that your attention is warranted to ensure that the

practices and procedures for nuclear work by this group are equivalent to

those employed by the onsite NDE group.

Your cooperation with us is appreciated.

Sincerely,

Originct Stnr) Cy:

Marvin W. Ilodscs

Marvin W. Hodges, Director

Division of Reactor Safety

cc w/er.ci:

R. McLeat Administrator, Nuclear Evaluations

J. Walter, Engineering Division, Public Service Commission of Marylana

G. Adams, Licensing (CCNPP)

K. Burger, Esquire, Maryland People's Counsel

P. Birnie, Maryland Safe Energy Coalition

Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of Maryland (2)

beu w/ enc 1:

Region I Docket Room (with concurrences)

R. Bellamy, DRSS

J. Linville. DRP

C. Cowgill, DRP

C, Lyon, DRP

D. Vito, DRP

B. Summers, DRP

M. Callahan, OCA

D. Mcdonald, NRR

R. Capra, NRR

J. Caldwell, EDO

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CHARLES CENTER * P.O. BOY 1975 * BALTIMORE. MARYLAND 21203 1475

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May 15,1990

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U. S. Nuclear Regulatory Commission

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Washington, DC 20555

ATTENTION:

Document Col. trol Desk

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SUBJECT:

Calvert Cliffs Nuclear Power Plant-

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Unit Nos.1 & 2; Docket Nos. 50-317E& $0-318

Combined insnection Renort Nos. 50-317/o0-Oli 50-318/90-01

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REFERENCES:

(a) Letter from Mr. M. W. Hodges (NRC) to Mr. G. C. Creel (BG&E),

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dated April 9,1990, same subject'

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Gentlemen:

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Reference (a) forwarded Nuclear Regulatory Commission (NRC) Region I Combined

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Inspection Report 50-317/90-01; 50-318/90-01. Appendix A to Reference (a)'is a Notice

of

Violation - regarding- deficiencies

related

to

non-destructive

examination

and

inservice

inspection

activities

at

Calvert

Cliffs.

Enclosure

(1)

provides ' our-

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response to the Notice of Violation.

Should you have any further questions regarding this matter, we will be pleased to

discuss them with you.

Very truly yours,

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GCC/MDM/bjd

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Enclosure

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May 15,1990

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Page 2

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cc:

D. A. Brune, Esquire

J. E.

Silberg, Esquire

R. A.Capra,NRC

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D. G. Mcdonald, Jr., NRC

J

1. T. Martin, NRC

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L. E. Nicholson, NRC

R. McLean, DNR

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ENCL (EUR.E (1)

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REPLY TO A NOTICE OF VIOLATION

INSPECTION REPORT 50-317/90-01: 50-318/90-01

VIOLATION A

Part 1:

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DESCRIPTION AND CAUSE OF THE EVENT

The first item contained in Violation A, of Nuclear Regulatory Commission (NRC)

Inspection Report 50-317/90-01; 50-318/90-01, indicates that welds determined to

be unacceptable by radiography, were not documented in a Non-Conformance Report

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(NCR)as required by Calvert Cliffs Quality Assurance Procedure (QAP) 26.

Examples included welds performed on the Auxiliary Feedwater System in the Fall

of 1982.

Baltimore Gas and Electric (BG&E) does not accept this violation. As stated in

the Inspection Report, Calvert Cliffs Quality Assurance Procedure (QAP) 26

Revision 41, Attachment B, lista deficient welding, under the category of

Deficient Workmanship, as a Condition Adverse to Quality. An NCR can be issued

for a Condition Adverse to Quality, however, Section 7.1 of QAP 26 states,

"An NCR is not required if the condition is reported through the

mechanism of another Corrective Action System that provides tracking

and follow-up through closure;

i.e.,

MR, LER, audits, etc."

The inspection Report states we were in non-compliance with QAP 26 because the

Non Destructive Examination (NDE) Program did not document welding defects

through an NCR. Instead, an NDE report was generated, as part of the welding

Maintenance Request (MR)/ Maintenance Order (MO) Package, to document and track

corrective actions. We believe this was consistent with the allowed methods of

documenting Conditions Adverse to Quality, in QAP 26.

In reviewing the process for documenting NDE corrective actions, it was noted

that although the NDE procedures ensured tracking and closcout of deficient welds

before closing out an MR, other aspects such as documentation of repair

deficiencies not corrected after the final NDE process, assessment of preventive

actions, and trending required improvement. Revisions to the NDE procedures to

correct these deficiencies will be completed by July 27, 1990.

QAP 26 is also being revised to clarify the interface between NCRs and other

corrective action proens.

Part 1

1.

DESCRIPTION AND CAUSE OF THE EVENT

The second item contained in Violation A Appendix A, of the Inspection Report

describes two examples of poor radiographic work practices as a result of failing

to follow procedures. Specifically, thirteen weld radiographs were accepted with

density readings outside the allowable range and read points were not marked on

welds that were not part of the Inservice Inspection Program. These practices,

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affecting the quality of work, resulted in violations of code requirements.

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ENCLOSURE (1)

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REPLY TD A NOTICE OF VIOLATION

INSPECTION REPORT 50-317/90-01: 50-318/90-01

II.

CORRECITVE STEPS TAKEN AND RESUL'IS ACHIEVED

The review of radiographic film requires the use of numerous Codes and Standards

to establish the acceptance or rejection of a radiograph. To ensure complete and

accurate reviews, new directions regarding film interpretations were issued to

all certified radiographers at Calvert Cliffs, via a controlled memo on April 13,

1990. As of April 13, 1990, a second review of all Calvert Cliffs radiographs

has been required to ensure applicable Codes and Standards are used.

The individual performiw the second party review must be a Baltimore Gas and

Electric (BG&S) . ' M i * vel 11 or !!! radiographer, if no discrepancies in

the initial interv E

m 0 .snd, and no problems with the film quality are

enecentered, th'

v

mh reviewer will initial the data sheet, indicating

his neceptance. 4

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be resolved by the NDE Unit Supervisor.

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III.

CORRECITVE STLH .jQZ y .LL BE TAKEN TO AVOID FURTHER

VIOLATIONS

in addition to the second party review, more detailed and specific directions for

radiography will be incorporated into the radiography procedures within our NDE

program. These changes will be made by August 31, 1990.

IV.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

Full compliance will be achieved by August 31, 1990, after the radiography

procedures are changed.

VIOLATION B

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DESCRIPTION AND CAUSE OF THE EVENT

Violation B, Appendix A, of the inspection Report indicates that BG&E's NDE

Control Procedure 5.020 does not conform to the requirements of ANSI N45.2.6.

The ANSI standard is invoked by Subarticle IWA-2300 of ASME Section XI,1983

Edition through Summer 1983 Addenda. Specifically, these sections of the Code

recommended the necessary qualifications for non-destructive examination

personnel that are certified to perform visual inspections (Type VT2, VT3, and

VT4). The standard recommends a Level 11 Inspector acquire 3 years of experience

before being certified whereas BG&E only requires 3 months.

Section 3.5 of ANSI N45.2.6, the standard referenced by the ASME code for

qualificetion of inspection, exarr.ination and testing personnel for nuclear power

plants, is titled * Education and Experience-Recommendations".

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ENCLCEURE (1)

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REPLY TO A NOTICE OF VIOLATION

INSPECTION REPORT 50-117/90-0l! 56-31g/90-01

The stardard ecommends a Level II inspector acquire 3 years of experience before

being certified. The standard also recognizes equivalent methods for

demonstrating competency may be substituted for experience. Sectioa 3.5 of the

standard states,

"These education and experience recommendations should be treated to

recognize that other factors may provide reasonable assurance that a

person can competently perform a particular task. Other factors which

may demonstrate capability in a given job are previous performance or

satisfactory completion

of capability testing."

Interpretation of this section has been provided in two ASME Boiler and Pressure

Vessel Code Cases. N-448 and N-449. These Code Cases have been determined by the

NRC to be suitable for use and are listed in NRC Regulatory Guide 1.147. Both

Cases provide alternatives to IWA-2300 % paragraph (c). Sub-paragmph (c) is

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where the ASME Code states personnel shN J be qualified in accordanct with ANSI

N45.2.6Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. The alternatives to Sub-paragraph (c) are the provisions prc.vided in

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Sub-paragraphs (a) and (b) of IWA-2300.

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Sections (a) and (b) of IWA-2300 reference guidelines set forth in The American

Society for Nondestructive Testing's (ASNT) procedure SNT-TC-1 A.1980 Edition.

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According to Code Cases N t48, and -449, providing a training program that is

consistent with the guidelines of SNT-TC-I A to qualify examinetion personnel, is

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an acceptable alternative to ANSI N45.2.6.

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CONCLUSION

We believe the NDE Program at BG&E complies with the wording and intent of the ASME

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code.

Our training program, which includes general and specific written examinations. -

as well as practical examinations, is consistent wi6 the guidelines in SNT-TC-l A. We

therefore believe we are in compliance with Title .1, Paragraph 50.55a of the Code of

Federal Regulations.

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VIOL ATION C

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QESCRIPTION AND CAUSE OF THE EVENT

Violation C Appendix A, of the laspection Report states that BG&E practices for

the identification of weld center lines does not conform with the ASME Section

XI,1983 Edition through Summer 1983 Addenda, requirements of IWA-2600 and

Appendix 111, Supplement 2. Specifically, welds were identified during the

inspection that did not have center line reference maikings.

ASME Section XI states, in IWA-2610, that "A reference system shall be

established for all welds subject to surface or volumetric examination. Each

such weld and area shall be located and identified

b'> a system of referena

points. The system shall permit identification of e; .1

weld, location of each

weld center line, and designation of regular intervals along the length or the

weld."

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ENCIA5URE II)

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REPLY TO A NCyl' ICE OF YlOLATION

INSPECTION REPORT 50-317MS-41: 50-318/90-01

The ultrasonic examination procedures at Calvert Cliffs und a Jystem which

permits the identification of weld center lines through the use of weld profiles

and indication mapping. The pro.:edures did not require the permanent marking of

centerlines.

II.

CORRECTIVE STEPS TAKEh AND.RESULTE ACHIEVED

Our Inservice Inspection (ISI) Program will be improved by the use of permanent

markins. On April 24, 1990, a memo was issued to all NDE examiners to require

pennanent weld zero and center line identification prior to any ASME XI surface

or volumetric exp.mination of piping welds.

III.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOfD FURTHER

VIOLATIONS

A procedure fo. identifying weld center lines will bis issued which will address

permanently marking tne zero reference and the weld 2 enter line. This procedure

will be in place by July 27, 1990.

IV.

DATE WHEN FULL COMPLIANCE Wrt.t. BE ACHIEVED

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Full compliance was achieved on April 24,199(

• 'nemo requiring permanent

markings was issued to all examiner *. Additionai .. enw will be provided in

the procedure to be issued by July 27, 1990.

EXTENSION

The original due date for this response was May 9,1990. A one-week extens.on was

granted by Region 1 on May 8,1990. The extension was requested to allow sufficient

time to resolve comments received on the first internal draft.

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