ML20154L755

Insp Repts 50-317/85-22 & 50-318/85-20 on 850909-13.No Violation Noted.Major Areas Inspected:Evaluations of Unit 2 Implementation of Equipment Qualification Corrective Action Commitments Per 10CFR50.49

ML20154L755
Person / Time
Site:	Calvert Cliffs
Issue date:	02/06/1986
From:	Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20154L753	List: ML20154L749 ML20154L755
References
50-317-85-22, 50-318-85-20, NUDOCS 8603120225
Download: ML20154L755 (17)

See also: IR 05000317/1985022

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U.S.. Nuclear Regulatory Commission

Offi'ce of Inspection and Enforcement

Report Nos.: 50-317/85-22; 50-318/85-20

Docket Nos.: 50-317/318

License Nos.: DPR-53/69

Licensee: Baltimore-Gas and Electric Company

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Charles Center

Post Office Box 1475

Saltimore, Maryland 21203

Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 & 2

Inspection at: Baltimore and Lusby, Maryland

Inspection Conducted: September 9-13, 1985

Inspector: .2

G. T. Hubbard, Eouipment Qualification and Test Engineer

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Also participating in the inspection and contributing to the report were:

R. N. Moist, Engineer, I&E

P. Shemanski, Engineer, NRR

M. Schaeffer, Reactor Engineer, RI

'L. Cheung, Reactor Engineer, 91

M. Trojovsky, Consultant, Idaho National Engineering Laboratory

E. Richards, Consultant, Sandia National Laboratory

Approved: %V cA-6%

Uldis Potapovs, Chief,[EQIS, Vendor Pronram Branch, I&E Date

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8603120225 860304

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INSPECTION SUMMARY

Inspection on September 9-13,1985 (Inspection Report Nos. 50-317/85-22;

-30-318/85-20)

Areas Inspected: Announced inspection to review the licensee's' Unit 2

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. The inspection included evaluations of the Unit 2

. implementation of equipment qualification (EQ) corrective action commitments ~

made as a result of deficiencies identified in the December. 16, 1982 Safety

Evaluation Report (SER) and the October 13, 1982 Franklin Research Center

(FRC) Technical Evaluation Report (TER). The inspection also included

followup of Unit 1 findings identified during the October 15-19, 1984 EQ

inspection. The inspection involved 245 inspector hours onsite.

Results: The inspection determined that the licensee has implemented a

program for both Units 1 and 2 to meet the requirements of 10 CFR 50.49

and has taken corrective action on the findings of the previous Unit 1

EQ inspection, except for certain deficiencies listed below. No

deficiencies were found in the licensee's implementation of corrective

action commitments made as a result of SER/TER identified deficiencies.

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. Potential Enforcement / Report item

IInresolved Items Paragraph Number

1. Qualification of Rockbestos 4.A.(9)(b) 50-317/85-22-02;

Coaxial Cable 50-318/85-20-02

2. Qualification of ASCO Solenoid 4.D. 50-317/85-22-07

Valve Model HCX8320A187 .

3. Qualification of Hatfield Cable 4.E.(1) 50-317/85-22-10;

50-318/85-20-09

4. Failure to Comply with Implemented 4.B.(2) 50-317/85-22-03;

Procedures 50-318/85-20-03

5. Failure to Establish Adequate 4.B.(6) 50-317/85-22-06;

Maintenance Procedures for 50-318/85-20-06

Limitorque Motor Valve Operators

Open Items:

1. Adequacy of Manually Maintained 4.A.(5) 50-317/85-22-01;

Equipment Maintenance Tracking 50-318/85-20-01;'

System

2. Depth, Scope, and Technical 4.B.(3) 50-317/85-22-04;

Expertise of QA/QC Audits 50-318/85-20-04

3. Establishment of EQ Training 4.B.(4) 50-317/85-22-05;

Program 50-318/85-20-05

4. Question Relative to How ASCO 4.0. 50-317/85-22-08;

Valve ISV3828 Was Installed in 50-318/85-20-07

Plant Without Being Qualified

5. Dirty / Dusty Reliance Motors 4.0. 50-317/85-22-09;

50-318/85-20-08

6. Revision to Qualification Files 4 E.(2) thru 50-317/85-22-11

4.E.(4) thru 13;

50-318/85-20-10

thru 12

Open Item From Previous Inspection:

1. Inadequate Control and Storage of 4.A.(2) 50-317/84-27-02

. Qualification Files

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DETAILS

1. PERSONS CONTACTED:

1.1 Baltimore Gas and Electric Company (BG&E)

W. McCaughey, Engineer

• R. L. Wenderlich, Senior Engineer

A. B. Anuje, Supervisor, Quality Assurance (QA)

• D. A. Ensor, Senior Auditor, QA

B. S. Montgomery, Senior Engineer

• C. H. Cruse, Manager, Electric Engineering Department

• R. F. Ash, Supervising Engineer

• A. Marion, Senior Engineer

• C. G. Phifer, Jr. , QA Specialist

R. B. Snyder, Supervisor, Electrical and Controls (ESC)

• K. Sabra, Principal Engineer

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• R. Olson, Principal Engineer

• M. S. Eye, QA Auditor

• R. D. Branch, Engineer

S. Parr, Engineering Technician

J. G. Sites, Qualification Maintenance Program (QMP) Coordinator

• J. A. Tiernan, Manager, Nuclear Power

• M. Patterson, Senior Engineer

J. M. Moreira, General Supervisor, ESC

1.2 BG&E Consultants

R. Bell, Engineer, Bechtel Power Corporation, Gaithersburg, MD

1.3 Nuclear Regulatory Commission

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• C Anderson, Chief, Plant Systems Section, RI

• G. Zech, Chief, Vendor Program Branch, I&E

U. Potapovs. Chief Equipment Qualification Inspection Section, I&E

D. Trimble, Resident Inspector, RI

J. A. Schumacher, Peactor Engineer, RI

• Denotes those present at the exit interview on September 13, 1985

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2. PURPOSE:

The purpose of this inspection was to review the licensee's Unit 2

implementation of the requirements of 10_CFR 50.49 with regard to

establishing qualification of electric equipment'within the scope of

10 CFR 50.49 and Unit 2 implementation of comitted corrective actions

for SER/TER ~ identified deficiencies. Also included as a part of the

inspection was a followup review of Unit 1 findings identified during

the October 15-19, 1984 EQ inspection.

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3. BACKGROUND:

On March 16, 1984 the NRC held a meeting with BG&E officials to discuss

BG8E's proposed methods to resolve the EQ deficiencies identified in the

December 16, 1982 SER and October 13, 1982'FRC TER. Discussions also

included BG&E's general methodology for compliance with 10 CFR 50.49

and justification for continued operation (JCO) for those equipment

items for which environmental qualification was not completed. The

. minutes of the meeting and proposed method'of resolution for each of

the EQ deficiencies were documented in May 14 and July 9, 1984

submittals from the licensee. Additionally, BG&E submitted a request

dated February 28, 1985 to extend the operation of Unit I to

1 approximately April 5,1985 and to extend the operation of Unit 2

to the fall 1985 refueling outage. JCOs for specific pieces of

equipment for both units were submitted with the request. The TER

and May 14,1984, July 9,1984, and February 28, 1985 submittals were

reviewed by the inspection team rembers and were used to establish a ,

status baseline for the Unit 2 inspection.

Additionally, inspection team members reviewed Inspection Report No.

50-317/84-27 dated January 29, 1985 to establish what followup actions

were required relative to the findings of the Unit 1 EQ inspection

conducted October 15-19, 1984.

4. FINDINGS:

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A. Followup of October 15-19, 1984 Unit 1 F0 Inspection

The NRC inspectors reviewed the licensee's corrective actions

relative to the Unit 1 findings identified during the October 1984

EQ inspection. Since the licensee's EQ program for compliance with

10 CFR 50.49 co.ers both Calvert Cliffs Units 1 and 2, there was.

some overlap of the followup activities for Unit 1 and the inspection

activities for Ur it 2. Where this overlap existed, discussions in

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the following paragraphs are applicable to the Unit i followup

activities as well as to Unit 2 inspection activities and the

licensee's overall E0 Program.

(1)- (Closed) Qualification Files Not Auditable (50-317/84-?7-01)

The NRC inspectors reviewed 20 qualification files relative

to followup of Unit 1 findings and 26 qualification files

for Unit 2. While the inspectors found the files to be

generally adequate and auditable, there were specific file

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problems which are discussed later in this report-(see

paragraph 4.E). The specific file problems were discussed

with the licensee and the licensee agreed to take appropriate

corrective action. In addition to the. specific problems, some-

generic file problems were identified and are discussed in

paragraph 4.B.(1). The inspectors determined that the

licensee's EQ progran, as defined in Electrical Engineering

Department Procedure No.18 (EEDP-18), " Equipment Qualification "

Revision 3, dated September 4,1985, implemented procedures

which establish auditable qualification files. The files

.were found to include completed Qualification Summaries,

Qualification Evaluation Worksheets (QEWs), Qualification

Report Review Summary (QRRS) sheets, Qualification Maintenance

Reouirement sheets and other documentation which supported

qualification of specific equipment items. The files included

references to test reports and other oualification related data

which are maintained in central data files. The qualification

files reviewed, except for specific cases discussed in paragraph

4.E., documented licersee evaluations and analysis performed

relative to specified performance requirements and qualified

life. The files documented the licensee's determinations as to

whether equipment is qualified and to what environmental

parameters it is qualified.

(2) (0 pen) Inadequate Control and Storage of Files in Accordance

with N45.2.9-1974 (50-317/84-27-02)

During the October 1984 inspection, the NRC inspectors determined

that the licensee's electric equipment qualification files and

records were not controlled and stored as described in ANSI

N45.2.9-1974, entitled " Requirements for Collection, Storage and

Maintenance of Quality Assurance Records for Nuclear Power Plants."

A licensee internal audit conducted from September 12-October 9,

1984, had identified similar findings in this area, audit finding

'84-24-01. During this inspection, the NRC inspectors determined

that the equipment files are centrally located and kept locked

during non-working hours. However, discussions with the licensee

disclosed that the audit finding is still open pending file

microfilming and hard copies being sent to plant history. The

licensee further stated that the audit finding would not be

closed until November 30, 1985. This item remains open pending

NRC review of the duplicate filing system and verification that

filing cabinets have the required fire rating to house permanent

plant records.

(3) (Closed) Inadeouate Implementation of Requirements and/or

Procedures for Compliance to 10 CFR 50.49 (50-317/84-27-03)

The NRC inspectors reviewed EEDP-18; EEDP-20, " Control of

Calvert Cliffs Equipment Data Bases," dated July 30, 1985;

and Calvert Cliffs Instruction 208 (CCI-208), " Qualification

Maintenance Program," dated September 9,1985, to determine

that BG&E has implemented procedures to control their

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qualification program in accordance with 10 CFR 50.49. Since

the major area of concern during the October 1984 inspection

related to maintenance procedures, further discussion of

procedure implementation is addressed in paragraph 4. A.(S) on

maintenance.

(4) (Closed) Inherent Characteristics in the Facility Change Request

(FCR) System which Delay Verification of "As-built" Installations

of Qualified 10 CFR 50.49 Equipment (50-317/84-27-04)

During the October 1984 inspection, the NRC inspectors determined

that Electrical Engineering Department (EED) verification of

"as-built" conditions of qualified 10 CFR 50.49' equipment had

a built-in-delay of a minimum of five months that could extend

to over a year. The inspectors found this delay to be of

concern, since a modified or new piece of equipment could be

utilized in a safety-related application for a significant

period of time during which its qualification would not have

been established nor would it have been included on the

10 CFR 50.49 list. During this inspection, the NRC inspectors

determined, through review of qualification files and discussions

with BG&E personnel, that the EED was receiving notification of

"as-built" conditions for new and modified equipment by documented

input from plant site personnel. This documented input is

received by EED within a week of equipment installation or

modification completion and EED then completes documentation

to establish equipment qualification and adds the equipment to

the 10 CFR 50.49 list if required.

Additionally the inspectors learned that the licensee is planning

a' company reorganization (about January 1,1986) that will involve

moving nuclear engineering personnel from corporate offices in

Baltimore to the plant site in Lusby. This move of engineering

• personnel to the plant site is considered an additional step

toward further improvement in the "as-built" time delay problems

of the FCR system.

(5) (Closed) No Maintenance Program which Includes Activities

Necessary to Maintain the Qualified Status of Qualified

Equipment (50-317/84-27-05)

The NRC inspectors reviewed EEDP-18 and determined that section 5.4

requires EQ related maintenance to be included as part of'the

licensee's EQ progran. It requires EQ files to contain the

applicable Qualification Maintenance Requirement sheets (QMRS).

The QMRSs identify equipment tag numbers, manufacturer's name

and model number, required EQ maintenance actions, replacement

parts, and the required implementation dates. Additionally, the

licensee has developed CCI-208 to implement qualification

maintenance requirements. The inspectors reviewed CCI-208

ar.d determined that it addresses procedures for implementing

qualification maintenance requirements.

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The licensee has identified 658 items of equipment which require

EQ related maintenance. As part of its qualification maintenance

program (QMP), the licensee has a OMP coordinator at the plant

site and has developed a "QMP Equipment List and Status ,

Tracking Chart" to track required EQ maintenance, equipment

maintenance status, and the dates required maintenance activities

are complete for each of the 658 items. The OMP coordinator

manually maintains these EQ status tracking charts which are

contained in eight notebook volumes to cover the 658 items.

The inspectors reviewed the status tracking charts for four items

of equipment (2-SV-618,-628,-638, and -648) and determined that

the individual charts contained sufficient detail to define

maintenance requirements and keep track of item maintenance

status. However, the inspectors did identify a concern relative

to overdue maintenance activities. The inspectors determined

that due to the volume of items, the manual tracking system, and

that there was no simple method (charts, tables, and/or computer

printouts) to identify overdue maintenance, tne licensee could

have difficulty identifying overdue maintenance activities if

they existed. The licensee did state that they were planning

to computerize the tracking system in the future. While the

inspectors did not identify any examples of overdue maintenance

activities, this concern is identified as a new open item which

will be reviewed during a future NRC inspection (50-317/85-22-01;

50-318/85-20-01.)

(6) (Closed) Overall Compliance to 10 CFR 50.49 (50-317/84-27-06)

The NRC inspectors' review and evaluation of 20 qualification

files for Unit 1, 26 qualification files for Unit 2, the

licensee's control and storage methods for E0 records and

qualification files, the licensee's FCR system, and the

licansee's QMP determined that the licensee has implemented

an E0 program in compliance with 10 CFR 50.49, except for

certain deficiencies discussed in this report. The specific

findings described in this report are considered to be isolated

instances of noncompliance with the rule and Appendix B to

10 CFR 50 and do not indicate an overall inadequacy'in the

licensee's program; therefore, this item is considered closed.

(7) (Closed) Resolution of TER/SER Deficiencies (50-317/84-27-07)

The NPC inspectors reviewed 20 qualification files related to

Unit 1 and determined that the licensee had adequately resolved

the concerns identified in the TER/SER; therefore, there are no

outstanding issues remaining relative to the TER/SER (see

discussion in paragraph 4.C. relative to Unit 2).

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(8) (Closed) Establishment of the Qualified Life of 10 CFR 50.49

Equipment Located in the Main Steam Piping Penetration Room

(50-317/84-27-08)

The NRC's concern with this item pertained to the high temperatures

observed in the main steam piping penetration room during the

plant walkdown of the October 1984 inspection. The inspectors

were concerned as to whether the temperatures (reported to be

140 degrees F) were adequately considered in thermal aging

calculations to determine qualified life. During this

inspection, the inspectors reviewed the qualification files for

the equipment located in the piping penetration room and deter-

mined that the high ambient temperatures had been adequately

addressed when the qualified life of the equipment was established.

(9) Specific File Deficiencies Identified In Report for October 1984

Inspection

While the report for the October 1984 inspection did not identify

specific qualification file findings as open items during this

inspection, the NRC inspectors reviewed 20 Unit 1 qualification

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files to determine if adequate corrective actions had been taken

regarding the identified findings. The inspectors determined

that actions taken by the licensee were adeouate except for the

items discussed L. low:

a. While the inspectors' review of Limitoroue motor operated

valve (MOV) qualification packages, TER items 19 and 27

(M0V001 and 002), determined that adequate corrective

actions had been taken regarding the identified deficiencies,

an additional concern was identified relative to MOV

maintenance requirements. This concern is discussed in

paragraph 4.B.(6).

b. The inspectors reviewed the qualification package for

CBLO31 for Pockbestos RSS-6-104 coaxial cable which is

used in the General Atomics high-rarge radiation

monitoring system (HRRMS) and determined that the licensee

had not taken adequate corrective action to establish-

qualificatien of the cable. During the previous EQ

inspection, the licensee was informed that, based on IE

Information Notice (IN) 84-44, their file did not support

qualification. However the only addition 11 information in

the file during this inspection stated that IN 84-44 "is

still under review for final resolution. Presently Rockbestos

is retesting to satisfy NRC concerns en qualification data /

metnods. The expected completion of testing for this cable

configuration is December 1985. Presently BG&E is attempting

to obtain outside test reports providing qualification data,

while monitoring the Rockbestos progress." Since these

statements did not provide additional information to

demonstrate cualification, the licensee was asked to provide

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any other information it might have to support qualification.

No additional information was provided to the inspectors;

therefore, the qualification of this cable is considered

not established for the licensee's application as of the

time of the inspection. This deficiency is identified as

a Potential Enforcement / Unresolved Item (50-317/85-22-02;

50-318/85-20-02).

(10) Information Notice Recomendation

The NRC inspectors reviewed Calvert Cliffs Instruction (CCil #139,

" Organization and Operation of the Plant Operating Experience

Assessment Committee (POEAC)," dated February 4, 1985, and the

minutes of POEAC Meetings 85-12, 85-14, and 85-17 to evaluate the

licensee's actions relative to the NRC recommendation during the

October 1984 inspection that a closed-loop system be considered

for action items assigned by the POEAC. Based on discussions

with the POEAC secretary and review of the POEAC outstanding item

lists for the above meetings, the inspectors determined that the

licensee was assuring that assigned POEAC action items were being

tracked and the POEAC was assuring adequate completion of assigned

action items.

B. EQ Program Compliance with 10 CFR 50.49

The NRC inspectors examined the licensee's EQ Program for establishing

the qualification of electric equipment within the scope of 10 CFR 50.49.

The licensee's program covers the qualification of all 10 CFR 50.49

equipment for both Units 1 and 2. The program was evaluated by review

of the licensee's corrective actions for findings identified during the

Unit 1 October 1984 EQ inspection, examination of the licensee's

qualification documentation files, examination of procedures which

control the licensee's EQ efforts, and examination of the licensee's

program for maintaining the qualified status of covered electric

equipment.

Based on the inspection findings on the followup of the licensee's

Unit I corrective actions (discussed in paragraph 4.A.) and the

l Unit 2 inspection findings of this inspection the inspection team

determined that the licensee has implemented a prcgram to meet the

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requirements of 10 CFR 50.49, although five Potential Enforcement /

Unresolved Items and eight Open Items were identified.

(1) Qualification Files, General

The NRC inspectors determined that BG&E's implemented program

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provides for the preparation of qualification documentation

files for eouipment within the scope of 10 CFR 50.49. The

licensee's program which is described in EEDP-18 requires

the establishment of qualification files by the EED. These

files are the documents which establish qualification for

all items of equipment at Calvert Cliffs Units 1 and 2 within

the scope of 10 CFR 50.49.

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Each qualification file includes the following:

Qualification Sumary

• Qualification Report Review

Qualification Evaluation Summary (QEW)

Worksheet

• Qualification Maintenance Requirement Sheet

QMRS Master Log

The NRC inspectors' review and evaluation of 20 qualification

files for Unit 1 and 26 qualification files for Unit 2

determined that the files did establish qualification of

10 CFR 50.49 equipment items except for specific cases

identified in this report.

During the review of the files, the inspectors identified many

instances where changes were made to the files by crossouts,

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whitenut, and/or other means without any indication as to

who made the changes and/or when the changes were made.

Qualification files where the above was specifically noted were

PT0006, M0V011, M0V001, SEALO3, SEALOS, SV0026, and ZS0021.

Since these files are covered by the requirements of paragraph

4.4 of QAP 7, " Records Management," dated July 3, 1985, which

requires changes to records identify who makes or approves

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the change, when the correction was made, and to leave the

original information legible, this finding is an example of the

licensee's failure to follow procedures as discussed in paragraph

j 4.B.(2).

(2) EQ Program Procedures

As previously' discussed in paragraphs 4(A)(3) and (5), the NRC

inspectors determined that the procedure concerns identified

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during the October 1984 EQ inspection had been addressed and

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the licensee was implementing procedures to control his EQ

activities. Procedure EEDP-18 provides guidelines for the

uniform assessment, evaluation, review, and implementation of

activities associated with environmental and seismic qualification

of 10 CFR 50.49 equipment at Calvert Cliffs. Procedure EEDP-20

is used to control new inputs and changes to the computerized

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Calvert Cliffs equipment data bases for all electric /instrumen-

tation devices at the Calvert Cliffs plant. Procedure CCI-208

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implements requirements for maintaining the cualified status of

10 CFR 50.49 equipment. In addition to reviewing the above EQ

program procedures, other licensee procedures were reviewed as

they were applicable to the EQ program. These procedures

included:

QAP-7 Records Management

QAP-14 Plant Maintenance

QAP-15 Changes, Tests and Experiments

3 QAP-20 Training

, QAP-28 Control of Items Covered by the Quality Assurance

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Program

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EEDP-2 Control of Changes, Tests and Experiments

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EEDP-8 Nuclear Related Indoctrination Training and

Qualification

EEDP-16 Records Retention

During the inspection activities, the NRC inspectors identified

two instances where the licensee did not comply with its

implemented procedures. The instances of not complying with

procedures are as follows:

The licensee made changes to documentation ,in its

qualification files without complying with the

requirements of paragraph 4.4 of QAP-7 (see

discussion in paragraph 4.8.(1)).

The licensee's responsible engineer failed to review

an FCR for the replacement of a flow control valve

as required by paragraph 7.8 of 0AP-15 (see discussion

in paragraph 4.0.).

The above instances of not complying with implemented procedures

is identified as a Potential Enforcement / Unresolved Item (50-317/

85-22-03; 50-318/85-20-03).

(3) Quality Assurance / Quality Control

The NRC inspectors' review determined that the quality assurance

(QA) organization for BG&E is comprised of a corporate QA

organization and a site QA organization. The corporate

organization consists of a QA manager who directs the Internal

Audits and Programs Unit. This unit is comprised of lead

auditors and auditors certified to ANSI N45.2.23 who conduct

mostly corporate audits.

At Calvert Cliffs there is an Operation QA General Supervisor

who directs the Senior QA Auditor 0A Specialists, Senior

Quality Control (QC) Inspectors and QC Inspectors. These

personnel perform EQ receipt inspections, maintenance

inspections, and at tines assist the corporate QA organization

in joint audits.

The inspectors reviewed three audits performed by both corporate

and site QA organizations in the EQ area. The first audit

reviewed was QAG 61-85-05 conducted by the Internal Audits and

Program Unit during March-April 1985. This audit was a direct

follow-up to the October 1984 NRC inspectinn. The other two

audits OAG 61-85-20 and EQ-26-85 were conducted simultaneously

from August 20-29, 1985. The corporate audit consisted of a '

review of qualification files, status of FCRs and implementation

of CCI-208. The site audit consisted primarily of assuring

site implementation of CCI-208.

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~The inspectors determined from the review of the audit check--

lists and discussions with the licensee, that the corporate ,

audit (QAG 61-85-20) should have included additional personnel- i

who had expertise in the environmental qualification area, i.e.,

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the inspectors' discussions with the licensee's auditors

indicated the following:

a. EQ files were reviewed for procedural compliance only.

b. The auditors did not verify that correct parameters such

as operating time, temperature, pressure, humidity, and

radiation were in accordance with qualification test

reports and plant specific design bases accident

parameters.

Based on the NRC inspectors' review and evaluation of the three

audits and discussion with the licensee, the inspectors were

concerned with the depth and scope of the audits as well as

the lack of adequate technical assistance during the audit.

This item is identified as an open item which will be reviewed

during a future NRC inspection (50-317/85-22-04; 50-318/

85-20-04).

(4) EQ Training

The NRC intpectors reviewed training requirements for personnel

working with EQ equipment. The inspectors determined that an

EQ training program had not been established. Although most all

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technicians and maintenance personnel have attended a lecture

given by EQ personnel af ter program implementation, personnel

have received most of their training by on-the-job training

(0JT). To date, the licensee has documented the completion of

only a one hour lecture on May 6,1985 in the EQ area relative

to the implementation of CCI-208. The establishment of an EQ

training program and the completion of training for personnel

working in the EQ area is identified as an open item which will

be reviewed during a future NRC inspection (50-317/85-22-05;

50-318/85-20-05).

(5) 10 CFR 50.49 List (EQ Master List)

The NRC inspectors did not review the licensee's 10 CFR 50.49

list as a separate aspect of this inspection since the licensee's

list covers both Calvert Cliffs Units 1 and 2 and the Unit i list

was reviewed during the October 1984 inspection with no major

findings. The inspectors concluded from their various

inspection activities that the licensee's EQ list was comprehensive.

The inspectors observed no changes to the list during the

inspection as was seen during the previous inspection.

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(6) E0 Maintenance Program

Since the licensee's maintenance program encompasses Calvert

Cliffs Units 1 and 2, the discussion in paragraph 4.A.(5) concern-

ing maintenance followup of the October 1984 inspection is

applicable to Unit 2 maintenance activities. The NRC inspectors'

review of qualification files MOV-001, MOV-002, avi MOV-011

for Limitorque motor valve operators identified one concern

relative to periodic operator cycling. The abstract of Wyle

Qualification Report 17467 states in part " Continued qualified

operation is maintained with the following provisions:.... A

periodic. cycling of the valve actuator must be performed at

least twice each year to lubricate the operating parts." This

maintenan.ce requirement was not addressed in the qualification

file, nor were any engineering evaluations performed to

determine if this requirement needed to be implemented. The

inspectors determined from discussions with the licensee's

engineering personnel that most of the qualified Limitorque

operators were only operated once per refueling cycle (typically

18 months). Subsequently, the licensee presented the inspectors

with a telephone conversation record dated September 13, 1985,

concerning a conversation between the licensee and Limitorque.

The record stated that "to cycle the Limitorque valve actuators

at least twice a year was a recommendation for actuators in

long term storage, and was not required for actuators in

service." Since this data is in conflict with the Wyle report,

the above conflict is identified as a Potential Enforcement /

Unresolved item (50-317/85-22-06; 50-318/85-20-06).

C. SER/TER Commitments

The NRC inspectors evaluated the implementation of Unit 2 EQ

corrective action comitments made as a result of SER/TER

identified deficiencies. The evaluation was based on the premise

that all corrective action comitments had been completed, except

for the equipment items for which JCOs were submitted in a

February 28, 1985 letter to the NRC. These JCOs were submitted

to allow continued operation of Unit 2 until the fall 1985 outage.

Based on the sample review of the qualification files for which there

were no outstanding JCOs and the plant physical inspection, the NRC

inspectors identified no deficiencies in the Unit 2 implementation

of SER/TER commitments.

D. PLANT PHYSICAL INSPECTION

The plant physical inspection consisted of the examination of six

types of safety-related equipment located outside containment on

either and/or both Units 1 or 2. The inspectors examined charac-

ter':+1cs such as mounting configuration, orientation, interfaces,

model number, environment, and physical condition.

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The NRC inspectors identified several concerns during the physical

inspection. One concern was that Unit 1 ASCO solenoid valve ISV3828

had a different model number than the other inspected valves, which

were qualified by qualification file SV0011. The installed valve,

located in the component cooling outlet shutdown heat exchanger

system, had a model number of HCX8320A187. The other valves

inspected had model numbers HPX8320A26. After the physical

inspection, the inspectors determined that qualification file

SV0011 did not establish qualification of the model HCX8320A187

valve; nor, did the licensee have any other file to establish the

qualification of the HCX8320A187 valve. This failure to establish

j qualification of a valve located in a harsh environment and a safety-

related system is identified as a Potential Enforcement / Unresolved i

Item (50-317/85-22-07).

Additional NRC discusr. ions with the licensec concerning the above

determined that the model HCX8320A187 valve was probably installed

in April 1985 when the control valve (ICV 3828) on which it was

mounted was installed as a replacement for another valve. The

inspectors further determined that the licensee had failed to

follow paragraph 7.8 of QAP 15 which requires that FCRs for  !

"SR-QUAL (environmentally qualified) items" be reviewed by the l

,

engineer who has been assigned responsibility for EQ by the

'

manager of EED. No documented evidence of the review was

identified by the inspectors and the responsible engineer

admitted to the inspectors that he had not reviewed the FCR. i

This is an example of the licensee failure to follow procedures

as discussed in paragraph 4.B.(2).

Additionally the inspectors had questions regarding the HCX8320A187

valve and why the valve was not on the qualification maintenance

requirement sheets of CCI-208 and what role QA/QC should have had

i to prevent the installation of unqualified equipment. Resolution

of these questions is identified as an open item (50-317/85-22-08;

,

50-318/85-20-07) which will be reviewed during a future NRC inspection.

Another concern identified by the inspectors was that the Reliance

'

motors, model P14G408NFV (qualification file MTR024) located in

emergency core cooling system (ECCS) pump rooms 21 ECCS and 22

ECCS were observed to be dusty / dirty. The inspectors were concerned

that the accumulation of dust / dirt could eventually be severe enough

to cause motor winding failure. The inspectors reconnended to the

licensee that the motors be cleaned. This item is identified as an

open item which will be reviewed during a future NRC inspection

50-317/85-22-09; 50-318/85-20-08.

E. DETAILED REVIEW 0F QUALIFICATION FILES

The NRC inspectors examined in depth 26 qualification files for

selected Unit 2 equipment types and one new file for Unit 1 equipment '

to verify the qualified status of equipment within the scope of

10 CFR 50.49. In addition to comparing plant service conditions

I with qualification test conditions and verifying the bases for

these conditions, the inspectors reviewed areas such as required

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a ..

post-accident operating time compared to the duration of time the

equipment has been demonstrated to be qualified, similarity of

tested equipment to that installed in the plant (e.g., insulation

class, materials of components of the equipment, test configuration

compared to installed configuration, and documentation of both),

evaluation of adequacy of test conditions, aging calculations for

qualified life, and replacement interval determination, effects

of decreases in insulation re'sistance on equipment performance,

adequacy of demonstrated accuracy, evaluation of test anamolies,

and applicability of EQ problems reported in IE ins / Bulletins and

their resolution.

(1) The NRC inspectors' review of file CBLO11 for a 14AWG, Hatfield

3 conductor cable determined that while the licensee was able

tn resolve (after much discussion) all the inspectors' concerns

regarding the file and support cable qualification, the file

itself was deficient in some areas. Examples where the file was

deficient are:

a. The QEW in the fil. indicated the cat'ie was qualified

for submergence aw lications, however, the file did not

support qualification for submergence. The licensee was

able to demonstrate, to the inspectors' satisfaction,

that the cable was not used in a submerged application;

therefore, the cable was qualified for its plant

application.

<

b. The file did not document proof of similarity between the

installed and the tested cables. The licensee was able to

l demonstrate similarity with documentation not referenced

I in the file.

c. A reference contained in the file stated that the Hatfield

cable was cualified for 40 years at 111.9'C; however, no

data, calculations, or specific references were found in

the file to support this qualified life. The licensee

eventually was able to justify the above qualified life by

recalculating thermal aging using material properties given

in qualification file CBLO12.

The licensee stated that it would revise this qualification

file to resolve all the questions identified by the

'

inspectors; however, this lack of documentation in the

file is identified as a Potential Enforcement / Unresolved

l

Item (50-317/85-22-10; 50-318/85-20-09).

2. The NRC inspectors review of file CBLO29 for Brand-Rex

coaxial cable identified three areas that were not

addressed adequately in the file. These areas were as

follows:

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(a) Data and/or specific references were not identified

in the file to provide a comparison between qualifi-

cation test parameters and actual plant requirements.

This item was resolved by additional licensee data

provided the inspectors during the inspectian.

(b) The file did not address plant performance requirements

of the cable. The licensee resolved this item by

referencing qualification file VT0001 for the

acoustical monitoring system. File VT0001 documented

that the cable was part of the system tested during

the acoustical monitoring system qualification tests;

therefore, demonstrating adequate performance of the

cable in its only safety-related application at

Calvert Cliffs.

(c) The file did not adequately address margins; however,

the licensee resolved this issue by data in the

VT0001.

The licensee agreed to revise file CBLO29 to resolve the above

identified file inadequacies. The revision of this file is

identified as an open item (50-317/85-22-11; 50-318/85-20-10)

which will be reviewed during a future NRC inspection.

3. The NRC inspectors review of file HRRMS1 for the General

Atomic high range radiation detector (model RD-231 determined

that the file did not adequately address performance require-

ments and margins as in file CBLO29. The licensee was able

to resolve the NRC concerns in these areas and agreed to

revise the file to reflect resolution of these concerns.

The revision to this file is identified as an open item

(50-317/85-22-12; 50-318/85-20-11) which will he reviewed

during a future NRC inspection.

4 The NRC inspectors' review of files SEAL 01 for Paychem heat

shrink tubing and SEALO3 for Raychem NE!S conduit sealing

kits determined that data in the file supported oualification

of the equipment items; however, the files were not finalized

pending notification of completion of field work under FCRs

84-1075 and 84-134 Finalization of these qualification

files by the licensee is identified as an open item (50-317/

85-22-13; 50-318/85-20-12) which will be reviewed during a

future NRC inspection.

4.F. IE informatinn Notices and Bulletins

The NRC inspectors did not review the licensee's system for the review

of ins / Bulletins as a separate aspect of this inspection since the

licensee's system covers both Calvert Cliffs Ifnits 1 and 2 and this

system was reviewed during the October 1984 inspection. Paragraph

4.A.(10) of this report discusses NPC findings relative to one NRC

l

recommendation provided the licensee during the previous E0 inspection.

!

this inspection

i

The NRC one

identified inspectors' review

finding (see of qualification

discussion files during(9)(b)

in paragraph 4.A. on

Rockbestos cable) relative to inadequate licensee action on one

information notice.

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