ML20215J412

Insp Repts 50-317/87-12 & 50-318/87-13 on 870427-0501. Violations Noted:Danger Tagged Valve Removed from Auxiliary Feedwater Chemical Addition Piping During Mod Work Being Accomplished Under Maint Order 205-234-874A

ML20215J412
Person / Time
Site:	Calvert Cliffs
Issue date:	06/16/1987
From:	Blumberg N, Petrone C, Wallace E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215J384	List: IR 05000317/1987012 ML20215J380 ML20215J401 ML20215J412
References
50-317-87-12, 50-318-87-13, NUDOCS 8706240426
Download: ML20215J412 (11)

See also: IR 05000317/1987012

Text

,

.

'U.S. NUCLEAR REGULATORY COMMISSION

REGION 1-

Report Nos.-- 50-317/87-12:

'

50-318/87-13

Docket Nos. 150-317

50-318'

' License Nos. DPR-53 - <

DPR-69

Licensee: Baltimore Gas'Elecpaic Company

P.O. Box 1475-

Baltimore, Maryland 21203

Facility Name: Calvert Cliffs Nu s ar Power Plant, Units 1 and 2

Inspection At: Lusby, Maryland _

Inspection Condu'cted: ApH1 27-May 1,1987

Inspectors: 6!de

C. Petrone, Lead Reactor Engineer

-

/4[8'7

date

i

8 W u /&

D. Wallace, Red'ctor Engineer-

~~~ Sf/4/f7

date

)

j

Approved by: -

V

' N. Blumberg, Thief,_0perationayPrograms

!/

' dat'e -

h7

Section, Operatior,s Branch, DRS

Inspection Summary: Routine unannounced inspection on April 27-May 1, 1987

(Combined Inspection Report Nos. 50-317/87-12 and 50-318/87-13).

'

Areas Inspected: Mechanical, Electrical, and Electrical and Control (E&C)

maintenance, including procedures, modifications, maintenance in progress,

equipment histories, Transformer maintenance reviews and QA interfaces with

maintenances.

.Results: One violation was identified: Failure to follow Safety Tagging

administrativescontrols during maintenance activity.

.

l

I

< 8706240426

PDR 8706& R  ;

G ADDCK 05000317

PDR;

w ,

,.

'.f.

,

/

't

i

.. i

,

']

r

.

.

] 1

DETAILS i

o

"

..

)

1~. 0 Persons Contacted

Baltimore Gas and. Electric (BG&E):~

'

L .

• J. Lemons, Manager-Nuclear Operations

• L. B. Russell, Manager-Nuclear Maintenance

.

• R..Wenderlich, General Supervisor-Electrical and Controls

• L. Weckbaugh, Supervisor-Planning and Scheduling-  ;

• M. Patterson, Nuclear Engineering Services '

• J. Jeralo,. Supervisor-Instrument Maintenance

• M. Holbrooks, AGS Unit 2 Mechanical Maintenance- l

• J. Wood, Engineer, Quality Audits

.

'

'

• M. Polak,. Senior Engineer-PSEU .  ;

• S. Cowne... Senior Engineer-Licensing i

!

• Denotes _those present at.the. exit meeting on May 1, 1987.

2.0- Control of Maintenance Activities

2.1L Scope and Criteria

The inspector determined by direct observation of licensee activities

and through discussions with BG&E personnel, whether maintenance )

work records and documents are being controlled in accordance with

the following requirements:

--

10 CFR 50, Appendix B

--

ANSI N18.7-1976, Administrative Controls and Quality Assurance

for the Operational Phase of Nuclear Power Plants.

--

.Calvert Cliffs Instruction 214D, Maintenance Records, Oct 18,

1984.

--

Calvert Cliffs Instruction 200J, Nuclear Maintenance System,

June 12, 1986.

--

Calvert Cliffs' Instruction 112G, Safety Tagging, April 29, 1986.

--

Quality Assurance Plan 14, Plant Maintenance, Rev. 29, Jan 1,

1986. l

--

Calvert Cliffs Instruction 201E, Maintenance Procedures,

July 1,1986. <

!

l

i

.

3

i

.

2.2 Review of Mechanical Maintenance j

2.2.1 Component Maintenance History

The inspector randomly selected a sample of maintenance

requests (MR) for safety related components in order.to

determine the following:

-

Maintenance records such as maintenance procedures,  ;

functional test procedure data sheets, weld l

authorization travellers, non-destructive examination j

forms and other administrative forms are retained '

with the MR;

-

Records are retrievable;

-

Maintenance Request Forms (MRs) are correctly filled

out, including; equipment descriptions, statement of

problem, quality control (QC) review, operations

review, and maintenance supervisor review; and,

-

Post Maintenance Testing has been adequately'

performed.

The inspector determined from the review that maintenance  ;

records are being established and maintained according to j

the applicable requirements. j

i

No violations or deviations were identified. j

1

2.2.2 gchanical Maintenance Activities j

The inspector observed the following safety related ,

mechanical maintenance activities:

-

Maintenance Order (MO) #207-100-463A, Repair of #11

Control Room HVAC Chiller Unit;

-

Maintenance Order (MO) #205-234-874A, Relocation of

Auxiliary Feedwater System Chemical Addition Tie-In; )

and, I

!

-

Maintenance Order (MO) #207-119-11A, Install Reactor I

,

Vessel Head and Remove Alignment Pins, Install Studs. j

l

During his review, the inspector verified the following:

-

Safety Tagging was adequate for the job to be

performed;

L

_

.

4'

<>

,

-

Phoperauthorizationprecededinitiationofwork;-

--

Mechanics and Welders were familiar with their tasks -

and the applicable procedures;

-' The procedure's specified in the maintenance package

were technically adequate for the work to be

performed;

-

Personnel performing the work were properly qualified;

-

Parts and materials used were identified in.the Work

Package;

-

Appropriate authorization for welding, cutting and

grinding was posted at the work' site;

-

Fire safety and other precautions were adhered to, as

~

specified in the Work Package;

-

Maintenance procedures in use conformed to the

licensee's administrative requirements for format and

approval; and,

- '

QC and other Hold Points were observed as specified

in the applicable procedure.

2.2.'3 Findings

During the performance of MO #205-234-874A, relocation of

the Auxiliary Feedwater System Chemical Addition Tie-In,.

the inspector observed licensee personnel cut a danger

tagged valve (#2CA330, #23 AFW Pump Chemical Addition

Header Drain) completely out of the system.

The inspector questioned those personnel performing the

work, and the QC inspector present, whether the practice

of removing danger tagged equipment from systems is a

common practice. These personnel stated that technically

they should not remove danger tagged equipment, but that

.

in this particular case, since the valve was observed not

to be a pressure boundary they assumed it was OK to remove

the valve. The QC inspector stated that such an action

should never occur, and that he had not noticed the tag

during the course of work until it was pointed out by the i

NRC Inspector.

,

-

e

'

f4?

5'

..g

'

~After reviewing the applicable administrative controls for

= Safety. Tagging. the inspector determined that the work

.

mentioned above, violated Calvert Cliffs Instruction 112G,

which states in part: " Red Danger Tags... when attached

to' operating devices, denoted that the device is not to be

L-

'b

~ operated o~r removed, nor its status changed in any

>

' manner. . ." 'The Red Danger Tag' should have been removed.

prior' to the approval to perform the valve modification.

Upon further investigation, the inspector determined

through discussions with personnel, and review of

administrative procedures, that:

.

-

-The Safety Tagging organization had not received

adequate information from the planning organization

to determine exactly what work was to be accomplished,

as required by CCI-112G, Paragraph VII A.4. As a

result, Safety Tagging did not know precisely where-

.to establish the tagging boundary.

-

The tagging boundary established-by the Safety Tagger,

was verified for adequacy by a reviewer. The

reviewer apparently did not fully comprehend the

scope of the: work either, as.a' result-the incorrect

tagging boundary was approved.

-

The Lead Person for performance of the actual'

-

work reviewed the tag out boundaries with a Safety

Tagger and then signed the Safety Tagging. Clearance

Form but failed to notice the tagging boundry was

incorrect.

~

Collectively, these factors al-lowed a Danger Tag to remain

on the' valve which was to be removed from the system.

Neither the Safety Tagger, Tagging Reviewer, Lead Person,

personnel performing the job, nor the QC inspector

identified the problem or initiated corrective action.

The failure to implement Administrative Procedure 112G,

is considered a violation (50-317/87-12-02).

2.3 Electrical and Controls Maintenance

,

2.3.1 Calibration of Plant Instrumentation

The inspector reviewed the licensee's program for the

calibration of safety related plant instrumentation. This

instrumentation includes'both ana~1og and bistable

devices. The setpoints and acceptance criteria for some of

these devices are specified in the technical specifications.

, ,

--

-

-n

-

6

.

}

The inspector-reviewed in detail the procedures'for the

,

- control of setpoints and acceptance criteria for those

safety related instruments (bistable'and analog) which are 1

'not specifically listed in the technical specifications.

~

j

'

!

. Procedure CCI-205F, Setpoint Control Procedure, dated

January 8, 1986, establishes administrative controls for

the calibration of plant bistable instrumentation. It c

- establishes the setpoint file as the master reference for '

all plantLsetpoints and.provides instructions for adding,

deleting, or changing setpoints- Based on a review of

.

this procedure, and discussions with Electrical and

y Control (E&C) personnel, the inspector concluded that-

these controls, which include reviews by maintenance,

engineering, operations, and-approval by'the Plant

Operations Safety Review Committee (POSRC), were adequate

to ensure that the correct setpoints and acceptance

criteria are used for the calibration of bistable

' instruments.

There are not, however, similar controls in place to

establish the acceptance criteria for the calibration of

analog; instruments. These setpoints are-not established,

approved and maintained, either in a file or included in

calibration procedures. The acceptance criter_ia',~or

calibration requirements, are e'stablished by each

a_ technician as he performs the calibration'of'each

instrument.

The only independent review of the acceptance criteria is

performed by the E&C supervisor during his review of the

completed calibration procedure. The technicians are

expected to establish the acceptance criteria by reference

to other documents such as generic vendor manuals, design

documents, or the record of the most recent calibration.

In practice technicians usually use the same acceptance

criteria used the last time the same calibration was

performed. As a result the acceptance criteria are not

review d by engineering, E&C supervision, or POSRC prior

' to the calibration activity. Incorrect acceptance

criteria could be used repeatedly.

The E&C supervisor, recognizing the need to pre-establish,

4- review and approve acceptance criteria for these safety

related analog instruments, prepared a draft procedure and

began work on the preparation of the needed data.

However, due to limited resources, and the lack of

commitment by station management, the project is only

partially complete after nearly two years of work. Much-

of the initial work (Phase I), performed by E&C

i

.

7

.

personnel ard contract personnel, is essentially

complete. Hawever, a significant amount of work (Phase II)

remains to be done by the engineering department.

At the exit meeting the inspector emphasized that

maintenance and calibration of safety related equipment

must be perfortaed using written procedures which include

appropriate acceptance criteria. The inspector requested

that licensee's management establish a realistic schedule

for the completion and approval of these procedures, and

that the necessary resources be provided to meet the

schedule. The Manager-Nuclear Operations stated that his  ;

staff would establish a schedule by August 31, 1987, and l

would provide that schedule to the NRC. He stated that

their goal would be to complete Phase II of their program l

by the end of 1987.  !

Failure to properly establish and review acceptance

criteria for safety related instruments is considered a

violation of R. G. 1.33-1978, Appendix A, Paragraph 8; and

ANSI N 18.7-1976, paragraphs 5.3.7 and 5.3.10. However, '

since some licensee representatives had identified the l

deficiency and corrective action was in progress, this is

considered a self identified violation which meets the

criteria of 10 CFR 2, Appendix C. The adequacy of the

licensees procedures for the calibration of safety related

,

'

analog instruments is unresolved pending the establishment,

review, and approval of the acceptance criteria, ,

(50-317/87-12-01). l

2.3.2 Electrical and Controls Maintenance Activities

i

The inspector observed the following safety related

maintenance activities:

- Maintenance Order (MO) 207-107-714A EQ upgrade of 23

Component Cooling Pump Motor;

-

Preventive Maintenance (PM) 2-18-R-6, Vital Instrument

A/C No. 23 Inverter PM; and,

-

I-29-2 Unit 2, Auxiliary Feedwater Foxboro Spec 200

Controller Functional Check.

During his review, the inspector verified that safety

tagging, and the other criteria listed in paragraph 2.2.2

of this report, were met satisfactorily.

..

8

-

\

2.3.3 Findings  !

The above activities were performed by well qualified

personnel in accordance with the procedures. No violations

or deviations were identified. However, during observation

of the EQ upgrade of the 23 Component Cooling Pump Motor,

the inspector noted that the nearby pressure gage (2-SW-5206-PI)

for the 21 Component Cooling Heat Exchanger Outlet was

damaged. The inspector reported this to the E&C supervisor

who issued a work request to have it repaired.

While in the control room observing the functional check  ;

of the Auxiliary Feedwater Foxboro controller, the '

inspector noted that a wire on another system was partially

cut. The wire is connected to J-3 on the back of the

Metrascope which provides backup control rod position

information to the control room operators. The J-3

connector provides input to the power dependent insertion

limits. The wire appears to have been inadvertently

pinched. The E&C supervisor issued a Maintenance Request ,

to have the wire repaired.  !

The inspector had no further concerns about these two i

minor deficiencies.

3.0 Station Service Transformer Maintenance

The inspector reviewed the licensee's program for the maintenance and

surveillance of large station power transformers. The inspector selected ,

Station Service Transformer U-4000-21 for review. '

Based on discussions with operations personnel, the inspector determined

that the Station Service Transformers are checked each shift by an

"Outside Operator" during his rounds. Although there are no specific

checkoffs or signoffs that this is performed, the Operations

Qualification Manual, Section C, Watchstander Checklist for Outside i

Operator, states that all transformers are to be checked once per shift

to ensure that:

- All temperatures are below the setpoints; ,

- Oil level is satisfactory; i

- No alarms are annunciated; and,

- Fans are operational.

.

The inspector examined the U-4000-21 Station Service Transformer using

the above criteria and did not identify any discrepancies.

,

l

I

1

i

,,

t

..

.

Periodic preventative maintenance.is performed by E&C personnel. PM .-

il-4-E-Q-1 is performed quarterly to check the operation of cooling. fans

.and oil cooling recirculation' pumps. PM 1-4-E-R-13 is performed every:

, refueling _ outage to inspect, clean, test relays, test annunciators and

F

check operation. cooling fans, pumps, and other associated equipment. In

- addition, oil and temperature gages are calibrated and power factor

! -(Doble) winding l tests are also performed. The inspector reviewed the

' records'of these maintenance activities and did not identify.any

violations or discrepancies.

'4.0 Quality Control / Maintenance Interface

l

-The inspectors verified QC's involvement during maintenance activities by.

observing the QC inspectors at several work sites. QC personnel were

knowledgeable of the work being done, and ensured the proper completion of

procedures and Hold Points. Maintenance personnel were observed to be

receptive to the QC inspectors concerns regarding work practices, cleanli -

ness, and quality concerns. The inspector verified that the QC' concerns- 1

identified during their review of completed maintenance packages were i

addressed by'the maintenance department in a timely fashion. .No violations "

or deviations were observed.

5.0 Unresolved Items

Unresolved items are matters about which more information is required in

~

i

order. to determine whether they are acceptable, .an item of, noncompliance,

or a deviation. An unresolved item is identified in paragraph 2.3.1  ?

6.0 Exit Meeting

The inspectors presented their findings to licensee management personnel

at an exit meeting on May 1,~1987. The attendees are listed in paragraph

1.0.

' At no time during this inspection was written material provided to the

licensee by the inspector.' Based on the NRC Region I review of this ,

report and discussions held with licensee representatives during this- i

inspection, it was determined that this report does not contain

information subject to 10 CFR 2.790 restrictions. j

,

. -

.

1

i

l

i

~,

ATTACHMENT 1 I

Work Packages Reviewed j

MR Numbers l

j

0-81-3439

'0-82-4559

.M-82-0392

0-83-3132

0-83-5534 l

E-84-00006

0-84-4440A

M-81-0227

M-81-0323

M-83-00157

M0 Numbers

205064563A

206063184A

205056274A

203002583A

205162640A

205284566A

207119111A

205234874A

i

,

,

'

)

!

.;

)

l

o ,.

ATTACHMENT 2

l

Procedures Reviewed ]

CCNPP Maintenance Procedure, RV-78, Reactor Vessel (RV) Flange Protection Ring

Removal and Closure Head Installation. Rev. O, January 28, 1987.

CCNPP Maintenance Procedure, RV-79, Reactor Vessel Alignment Pin Removal, Stud

Hole Cleaning, and Stud Installation. Rev. O, December 10, 1986.

1

i

I

.,

i