ML20211N325

Forwards Responses to Potential Enforcement/Unresolved & Open Items Noted in Insp Repts 50-317/85-22 & 50-318/85-20 Re Equipment Qualification Program.Encl Info Should Address NRC Concern Re Mgt Involvement in Program

ML20211N325
Person / Time
Site:	Calvert Cliffs
Issue date:	06/30/1986
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8607030021
Download: ML20211N325 (5)

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B ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN VicE PRESIDENT NUCLEAR ENERGY June 30,1986 U. S. Nuclear Regulatory Commission Docket Nos. 50-317 Office of Inspection and Enforcement 50-318 Washington, D. C. 20555 License Nos. DPR-53 DPR-69 ATTENTION: Mr. Brian K. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs Gentlemen:

This refers to inspection Report 50-317/85-22;50-318/85-20, which identifies apparent findings in the implementation of our Equipment Qualification (EQ) Program required by 10 CFR 50.49. We have conducted a thorough review of the inspection results and our EQ Program.

Enclosure (1) to this letter is a reply to the specific findings discussed in the inspection report.

Should you have any further questions regarding this reply, we will be pleased to discuss them with you.

Very truly yours, 3AT/SRC/ dim Enclosure cc: D. A. Brune, Esquire

3. E. Silberg, Esquire D. H. Jaffe, NRC T. Foley, NRC B607030021 860630 PDR ADOCK 05'100317.

PDR ,

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ENCLOSURE (1)

REPLY TO NRC INSPECTION REPORT 50-317/85-22; 50-318/85-20 We have thoroughly reviewed the findings identified in the inspection report and have implemented / completed activities which resolve the items identified in Appendix A of the report. These are summarized below. Additionally, we hope the following information will address your concerns regarding management involvement in the EQ program at Calvert Cliffs.

POTENTIAL ENFORCEMENT / UNRESOLVED ITEMS

1. Qualification of Rockbestos Coaxial Cable 317/85-22-02; 50-318/85-20-02 A possible reportable event (PRE 85-6) was issued on September 16,1985 and was determined to be non-reportable. Rockbestos coaxial cable file CBLO31 includes an itemized discussion and resolution of the concerns raised by Information Notice No. 84-44 and NRC Inspection Report 9990277/83-02.

This item is considered complete and the cable is qualified.

2. Qualification of ASCO Solenoid Valve Model HCX8320A187 317/85-22-07 This item was discovered during the plant inspection. A possible reportable event (PRE 85-5) was issued on September 12, 1985, and was determined to be non-reportable. A qualification file was established (QUALNO SV0048)

September 13, 1985, for this model number. This item has also been added to the Qualification Maintenance Program (QMP).

We consider this item to be complete and qualified.

3. Qualification of Hatfield Cable 317/85-22-10; 50-318/85-20-09 h concerns identified in the inspection report regarding submergence, similarity, and qualified life determination have been resolved and documented within the qualification file.

I We consider this item complete and resolved.

4. Failure to Comply with Implemented Procedures 317/85-22-03; 50-318/85-20-03 All changes to the qualification files are being initialed and dated by the

' individual (s) responsible for the file. Additionally, these files will receive one final review before transmitting to our permanent plant records.

We consider the failure to perform an EQ review of FCR 83-1065 to be an isolated case due to personnel error on the part of the Responsible Engineer. He has been counseled. We believe that sufficient administrative controls exist to prevent i programmatic errors.

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,;#. ENCLOSURE (1) p*

REPLY TO NRC INSPECTION REPORT 50-317/85-22; 50-318/85-20

3. Failure to Establish Adequate Maintenance Procedures for Limitorque Motor Operated Valves (MOVs) 317/85-22-06; 50-318/85-20-06 The recommendation to cycle MOVs twice a year has been resolved. A review was conducted of the manufacturer's lubrication and maintenance procedures. This review concluded that an 18-month combined inspection and cycling is acceptable.

This has been verified with Limitorque. The appropriate documentation has been added to each MOV file.

We consider this item to be complete.

OPEN ITEMS

1. Adequacy of Manually Maintained Equipment Maintenance Tracking System -

50-317/85-22-01; 50-318/85-20-01 An improved manual tracking / scheduling system for maintenance of EQ equipment will be in place by December 31,1986. The design for the new system is complete and the system computer is now being programmed. This system will require manual action to call up or retrieve preventive maintenance information. The automatic tracking / scheduling system will be in place by March 31,1987.

2. Depth, Scope, and Technical Expertise of QA/QC Audits 317/85-22-04; 50-318/85-20-04 An audit by BG&E Quality Assurance personnel was conducted during the period March 26 through April 9,1986. This annual audit included a technical review of selected EQ files by an engineer. The audit looked at test acceptance criteria, qualification parameters, qualification procedures, etc. The review has been documented by a QA audit report.

We consider this item to be complete.

3. Establishment of EQ Training Program 317/85-22-05; 50-318/85-20-05 As part of their initial qualification program, maintenance personnel receive indoctrination in EQ requirements through self-study. . ssroom presentations on EQ are administered by maintenance instructors when holding a class is justified by the number of new employees. Additionally, the periodic retraining lessons on plant equipment and systems includes specific EQ program requirements. The lesson plans for this retraining are reviewed and upgraded before class, if necessary, to reflect current CCI-208 EQ requirements.

We are continuing to review our EQ training program for its effectiveness.

ENCLOSURE (1)

REPLY TO NRC INSPECTION REPORT 50-317/85-22; 50-318/85-20 N

4. Installation of ASCO Valve ISV3828 without Qualification 317/85-22-08; 50-318/85-20-07 An administrative system exists that is designed to ensure installed equipment is environmentally qualified. However, in the case of the ASCO valve, the responsible engineer failed to identify the problem and implement the system controls.

A QA audit is performed annually on the qualification maintenance requirement sheets but this audit would not identify a failure to " initially load the system." QA audit functions are performed af ter the fact and are desigr.ed to identify program-matic problems with the system (s) and may not identify the failure of the Responsible Engineer to implement the administrative systems controls. Other than counseling of the Responsible Engineer, no further action is necessary since this is an isolated occurrence.

We consider this item complete.

5. Dirty / Dusty Reliance Motors MTR024 317/85-22-09; 50-318/85-20-08 Preventive maintenance procedures were developed in April 1985, to periodically inspect and clean fan motors. They are usually performed during refueling outages.

However, there are no technical requirements in the EQ Program for cleaning these motors.

We consider this item to be complete.

6. Revision to Qualification Files 317,/85-22-11 thru 13; 50-318/85-20-10 thru 12 The items identified within the inspection report and discussed during the 5eptember 1985 inspection have been reviewed, resolved, and appropriate documentation included in the EQ files. The report for a recently completed QA audit will verify and document the resolution of the noted items.

We consider these items complete.

OPEN ITEM FROM PREVIOtIS INSPECTION

1. Inadequate Control and Storage of Qualification Files 317/84-27-02 The EQ files are currently being transmitted to plant history in accordance with Quality Assurance Procedure (QAP) - 7. This QAP ensures that single storage facilities meet the criteria specified in ANSI N45.2.9 - 1976.

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.*O ENCLOSURE (1)

REPLY TO NRC INSPECTION REPORT 50-317/85-22; 50-318/85-20 Transmittal of all existing EQ files is expected to be complete by July 31, 1986.

New EQ files, developed af ter November 30, 1985, will be transmitted at a later date af ter July 31,1986.

We consider this item to be complete.

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