ML20154L749

Forwards Insp Repts 50-317/85-22 & 50-318/85-20 on 850909-13.No Violations Noted.Five Deficiencies in Program to Implement 10CFR50.49 Requirements Identified in App a Will Be Referred to Region I for Further Action

ML20154L749
Person / Time
Site:	Calvert Cliffs
Issue date:	03/04/1986
From:	Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20154L753	List: ML20154L749 ML20154L755
References
NUDOCS 8603120222
Download: ML20154L749 (4)

See also: IR 05000317/1985022

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D1cket No. 50-317/318

Baltimore Gas and Electric Company

ATTN: Mr. A.' E. Lundvall, Jr.

Vice President - Supply

Charles Center

Post Office Box 1475

Baltimore, Maryland 21203

Gentlemen:

SUBJECT: INSPECTION NOS. 50-317/85-22; 50-318/85-20

This refers to the team inspection conducted by Mr. G. T. Hubbard and other

NRC representatives on September 9-13, 1985 at the Baltimore Gas and Electric

Company (BG&E) headquarters, Baltimore, Maryland, and Calvert Cliffs Nuclear

Power Plant, Units 1 and 2. Lusby, Maryland, of activities authorized by NRC

License Nos. DPR-53 and DPR-69 and to the discussions of the team's findings

with Mr. J. A. Tiernan and other members of your staff at the conclusion of

the inspection. The inspection reviewed your implementation of a program as

required by 10 CFR 50.49 for establishing and maintaining the qualification of

electric equipment within the scope of 10 CFR 50.49 at Calvert Cliffs, Unit 2,

including equipment qualification (EQ) corrective action commitments made as a

result of the December 16, 1982 Safety Evaluation Report (SER) and the

October 13, 1982 Franklin Research Center Technical Evaluation Report (TER).

The inspection also included followup of Unit i findings identified during the

October 15-19, 1984 equipment qualification inspection. . Within this area, the

inspection consistcd of selected examinations of procedures and representative

records, interviews with personnel, and observations by the inspectors.

The inspection determined that you have implemented a program to meet the

requirements of 10 CFR 50.49 and your corrective action commitments relative

to SER/TER deficiencies, except for certain deficiencies which are described

in the attached inspection report. Five deficiencies in your program

implementation, summarized in Appendix A, are classified as Potential

Enforcement / Unresolved Items, and will be referred to the NRC Region I office

for further action. One of these deficiencies, inadequate qualification of

Rockbestos coaxial cable, was identified during the October 1984 inspection.

Since the deficiency remains substantially unresolved, we are concerned about

the tineliness and effectiveness of your corrective actions. The other

deficiencies include failure to adequately establish qualification of Hatfield

cable and an ASCO solenoid valve (plant I.D. #1SV3828); failure to comply with

implemented procedures relative to changes / corrections to qualification files

and review of field change requests (FCRs) for EQ equipment; and failure to

establish plant maintenance procedures which incorporate qualification file

maintenance cycling requirements for Limitorque motor valve operators. Eight

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other deficiencies are classified as open items. Your corrective actions

concerning these items will be reviewed during a future NRC inspection. These

open items include NRC concerns relative to equipment maintenance status, QA/QC

audits, E0 training, equipment installation controls, Reliance motor maintenance,

and qualification file (3) deficiencies. One open item (50-317/84-27-02) dealing

with control of EQ files remains open from the October 1984 inspection. Details

of the deficiencies are discussed in the enclosed inspection report.

In addition to the specific deficiencies discussed above, we are concerned

with the apparent lack of adequate management attention with the establishment

of a viable program to meet the requirements of 10 CFR 50.49. This concern was

discussed during the exit meeting on September 13, 1985, and is evidenced by

BG&E's failure to take appropriate action to establish qualification of

Rockbestos coaxial cable even though the NRC inspectors identified this as a

prcblem during the October 1984 inspection. Additional basis for this

concern is that even after the October 1984 inspection, the NRC inspectors

identified four Potential Enforcement / Unresolved Items (not counting Rockbestos

cable) and eight open items during this inspection. When corrective action is

taken on the deficiencies identified in the attached report these comments on

management involvement should also be considered.

Your corrective actions regarding the identified deficiencies should not be

delayed pending either a future NRC inspection or further action by the NRC

Region I office.

We are available to discuss any questions you have concerning this inspection.

Sincerely,

,

, ,

r- dk

Gary G.' Zedhr ief

Vendor Program Branch

Division of Quality Assurance, Vendor

and Technical Training Center Programs

Office of Inspection and Enforcement

Enclosures:

1. Appendix A

2. Inspection Report Nos. 50-317/85-22

and 50-318/85-20

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APPENDIX A

Potential Enforcement / Unresolved Items

As a result of the equipment qualification (EQ) inspection on September 9-13, 1985,

the following items have been referred to NRC Region I as Potential Enforcement /

Unresolved Items (paragraph references are to detailed portions of the inspection

report).

1. Contrary to paragraph (f) and (j) of 10 CFR 50.49 Baltimore Gas and

Electric Company (BG&E) had not demonstrated and/or documented the

qualification of Rockbestos coaxial cable. (Paragraph 4. A.(9)(b),

Items 50-317/85-22-02; 50-318/85-20-02)

2. Contrary to paragraph (f) and (j) of 10 CFR 50.49. BG&E had not

demonstrated and/or documented the oualification of ASCO solenoid

valve, model HCX8320A187. (Paragraph 4.0., Item 40-317/85-22-07)

3. Contrary to paragraph (j) of 10 CFR 50.49, BG&E did not adequately

demonstrate and/or document qualification of the Hatfield 3

conductor cable. Under the option allcwed by paragraph (k) of

10 CFR 50.49, this deficiency is contrary to section 8.0 of the

DOR Guidelines. (Paragraph 4.E.(1), Items 50-317/85-22-10;

50-318/85-20-10)

4. Contrary to Criterion V of Appendix B to 10 CFR 50.49, BG&E had not

complied with implemented procedures of Quality Assurance Procedure

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No. 7-(QAP-7) when making changes /cnrrections to qualification files.

RG&E also failed to comply with reouirements of procedure QAP-15 when

they failed to perform a required EQ review of a field change request

(FCR) for replacing flow control valve 1CV3828. (Paragraph 4.B.(2),

Items 50-317/85-?2-03; 50-318/85-20-03)

5. Contrary to Criterion V of Appendix B to 10 CFR 50.49, BG&E had not

established plant maintenance procedures which incorporated the

qualification file required EQ maintenance cycling requirements for

Limitorque motor valve operators. (Paragraph 4.B.(6), Items 50-317/

85-22-06; 50-318/85-20-06)