ML20154L755
| 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: |
| 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
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:
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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:
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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
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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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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
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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
approximately April 5,1985 and to extend the operation of Unit 2
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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
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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
the following paragraphs are applicable to the Unit i followup
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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
N45.2.9-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.9-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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
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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
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Unit 2 inspection findings of this inspection the inspection team
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determined that the licensee has implemented a prcgram to meet the
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 Summary (QEW)
Qualification Evaluation 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,
whitenut, and/or other means without any indication as to
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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
the change, when the correction was made, and to leave the
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original information legible, this finding is an example of the
licensee's failure to follow procedures as discussed in paragraph
4.B.(2).
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(2) EQ Program Procedures
As previously' discussed in paragraphs 4(A)(3) and (5), the NRC
inspectors determined that the procedure concerns identified
during the October 1984 EQ inspection had been addressed and
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the licensee was implementing procedures to control his EQ
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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
Calvert Cliffs equipment data bases for all electric /instrumen-
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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
QAP-20
Training
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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
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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
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audit (QAG 61-85-20) should have included additional personnel-
who had expertise in the environmental qualification area, i.e.,
the inspectors' discussions with the licensee's auditors
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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
technicians and maintenance personnel have attended a lecture
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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
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qualification of a valve located in a harsh environment and a safety-
related system is identified as a Potential Enforcement / Unresolved
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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
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"SR-QUAL (environmentally qualified) items" be reviewed by the
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engineer who has been assigned responsibility for EQ by the
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manager of EED.
No documented evidence of the review was
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identified by the inspectors and the responsible engineer
admitted to the inspectors that he had not reviewed the FCR.
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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
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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.
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Another concern identified by the inspectors was that the Reliance
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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
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10 CFR 50.49.
In addition to comparing plant service conditions
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with qualification test conditions and verifying the bases for
these conditions, the inspectors reviewed areas such as required
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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.
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b.
The file did not document proof of similarity between the
installed and the tested cables.
The licensee was able to
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demonstrate similarity with documentation not referenced
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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
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file is identified as a Potential Enforcement / Unresolved
Item (50-317/85-22-10; 50-318/85-20-09).
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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.
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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
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recommendation provided the licensee during the previous E0 inspection.
this inspection
The NRC inspectors' review of qualification files during(9)(b) on
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identified one finding (see discussion in paragraph 4.A.
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Rockbestos cable) relative to inadequate licensee action on one
information notice.
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