ML20215J412
| 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: |
| References | |
| 50-317-87-12, 50-318-87-13, NUDOCS 8706240426 | |
| Download: ML20215J412 (11) | |
See also: IR 05000317/1987012
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'U.S. NUCLEAR REGULATORY COMMISSION
REGION 1-
- Report Nos.--
50-317/87-12:
50-318/87-13
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Docket Nos. 150-317
50-318'
' License Nos. DPR-53
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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
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Inspection Condu'cted: ApH1 27-May 1,1987
Inspectors:
6!de
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C. Petrone, Lead Reactor Engineer
date
8 W u /&
D. Wallace, Red'ctor Engineer-
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Approved by:
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' N. Blumberg, Thief,_0perationayPrograms
' dat'e -
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)
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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
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administrativescontrols during maintenance activity.
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8706240426 8706& R
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DETAILS
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1~. 0 Persons Contacted
Baltimore Gas and. Electric (BG&E):~
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- J. Lemons, Manager-Nuclear Operations
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- L. B. Russell, Manager-Nuclear Maintenance
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- R..Wenderlich, General Supervisor-Electrical and Controls
- L. Weckbaugh, Supervisor-Planning and Scheduling-
- M. Patterson, Nuclear Engineering Services
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- J. Jeralo,. Supervisor-Instrument Maintenance
- M. Holbrooks, AGS Unit 2 Mechanical Maintenance-
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- J. Wood, Engineer, Quality Audits
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- M. Polak,. Senior Engineer-PSEU .
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- S. Cowne... Senior Engineer-Licensing
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- 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
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work records and documents are being controlled in accordance with
the following requirements:
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ANSI N18.7-1976, Administrative Controls and Quality Assurance
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for the Operational Phase of Nuclear Power Plants.
.Calvert Cliffs Instruction 214D, Maintenance Records, Oct 18,
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1984.
Calvert Cliffs Instruction 200J, Nuclear Maintenance System,
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June 12, 1986.
Calvert Cliffs' Instruction 112G, Safety Tagging, April 29, 1986.
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Quality Assurance Plan 14, Plant Maintenance, Rev. 29, Jan 1,
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1986.
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Calvert Cliffs Instruction 201E, Maintenance Procedures,
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July 1,1986.
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2.2 Review of Mechanical Maintenance
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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,
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functional test procedure data sheets, weld
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authorization travellers, non-destructive examination
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forms and other administrative forms are retained
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with the MR;
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Records are retrievable;
Maintenance Request Forms (MRs) are correctly filled
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out, including; equipment descriptions, statement of
problem, quality control (QC) review, operations
review, and maintenance supervisor review; and,
Post Maintenance Testing has been adequately'
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performed.
The inspector determined from the review that maintenance
records are being established and maintained according to
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the applicable requirements.
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No violations or deviations were identified.
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2.2.2
gchanical Maintenance Activities
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The inspector observed the following safety related
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mechanical maintenance activities:
Maintenance Order (MO) #207-100-463A, Repair of #11
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Control Room HVAC Chiller Unit;
Maintenance Order (MO) #205-234-874A, Relocation of
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Auxiliary Feedwater System Chemical Addition Tie-In;
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and,
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Maintenance Order (MO) #207-119-11A, Install Reactor
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Vessel Head and Remove Alignment Pins, Install Studs.
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During his review, the inspector verified the following:
Safety Tagging was adequate for the job to be
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performed;
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Phoperauthorizationprecededinitiationofwork;-
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Mechanics and Welders were familiar with their tasks -
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and the applicable procedures;
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The procedure's specified in the maintenance package
were technically adequate for the work to be
performed;
Personnel performing the work were properly qualified;
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Parts and materials used were identified in.the Work
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Package;
Appropriate authorization for welding, cutting and
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grinding was posted at the work' site;
Fire safety and other precautions were adhered to, as
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specified in the Work Package;
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Maintenance procedures in use conformed to the
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licensee's administrative requirements for format and
approval; and,
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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
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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
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NRC Inspector.
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~After reviewing the applicable administrative controls for
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= Safety. Tagging. the inspector determined that the work
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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
~ operated o~r removed, nor its status changed in any
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' manner. . ." 'The Red Danger Tag' should have been removed.
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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:
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-The Safety Tagging organization had not received
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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,
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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'
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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.
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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
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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.
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The inspector-reviewed in detail the procedures'for the
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- control of setpoints and acceptance criteria for those
safety related instruments (bistable'and analog) which are
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'not specifically listed in the technical specifications.
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. Procedure CCI-205F, Setpoint Control Procedure, dated
January 8, 1986, establishes administrative controls for
the calibration of plant bistable instrumentation.
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all plantLsetpoints and.provides instructions for adding,
deleting, or changing setpoints-
Based on a review of
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this procedure, and discussions with Electrical and
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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
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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,
review and approve acceptance criteria for these safety
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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
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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
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would provide that schedule to the NRC.
He stated that
their goal would be to complete Phase II of their program
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by the end of 1987.
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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,
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since some licensee representatives had identified the
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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
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licensees procedures for the calibration of safety related
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analog instruments is unresolved pending the establishment,
review, and approval of the acceptance criteria,
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(50-317/87-12-01).
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2.3.2
Electrical and Controls Maintenance Activities
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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
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A/C No. 23 Inverter PM; and,
I-29-2 Unit 2, Auxiliary Feedwater Foxboro Spec 200
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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.
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2.3.3
Findings
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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
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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
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to have the wire repaired.
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The inspector had no further concerns about these two
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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
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Station Service Transformer U-4000-21 for review.
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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
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Operator, states that all transformers are to be checked once per shift
to ensure that:
- All temperatures are below the setpoints;
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- Oil level is satisfactory;
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- No alarms are annunciated; and,
- Fans are operational.
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The inspector examined the U-4000-21 Station Service Transformer using
the above criteria and did not identify any discrepancies.
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- Periodic preventative maintenance.is performed by E&C personnel.
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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
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check operation. cooling fans, pumps, and other associated equipment.
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- addition, oil and temperature gages are calibrated and power factor
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-(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
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-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-
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identified during their review of completed maintenance packages were
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addressed by'the maintenance department in a timely fashion. .No violations
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or deviations were observed.
5.0 Unresolved Items
Unresolved items are matters about which more information is required in
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order. to determine whether they are acceptable, .an item of, noncompliance,
or a deviation. An unresolved item is identified in paragraph 2.3.1
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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
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report and discussions held with licensee representatives during this-
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inspection, it was determined that this report does not contain
information subject to 10 CFR 2.790 restrictions.
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ATTACHMENT 1
Work Packages Reviewed
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MR Numbers
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0-81-3439
'0-82-4559
.M-82-0392
0-83-3132
0-83-5534
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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
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ATTACHMENT 2
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Procedures Reviewed
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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.
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