ML20154L749
| 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: |
| References | |
| NUDOCS 8603120222 | |
| Download: ML20154L749 (4) | |
See also: IR 05000317/1985022
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UNITED STATES
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liarch 4,1986
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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March 4, 1986
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,
,
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Gary G.' Zedhr
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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
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)