ML20236T696

Advises That Util Intends to Replace All Bolting in Bolt Rings of Code Sys for Which Maint Orders Reveal Use of Commercial Quality Matl.Facility Will Not Change to Mode 4 Until Replacement Accomplished

ML20236T696
Person / Time
Site:	Calvert Cliffs
Issue date:	05/22/1987
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236T694	List: ML20236T692 ML20236T696
References
NUDOCS 8712020026
Download: ML20236T696 (1)

Text

/i%,(t.] 5l2 ff* *)

B ALTIMORE GAS AND -

ELECTRIC i

1 CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 j

j JosEPN A.TIERNAN ed WCE PRESS 0ENT May 22, 1987 wue w a cacao, i

U.-S. Nuclear Regulatory Commission-Region I 631 Park Avenue q

King of Prussia, PA 19406 ATTENTION:

Mr. William F. Kane

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2: Docket Nos. 50-317 & 50-318 Use of Mechanical' Parts Purchased

-Commercial Quality in ASME Section XI Code Class 1, 2,

3 i

Systems Gentlemen:

In late

April, we suspected that some bolting materials purchased Commercial Quality had been inappropriately used in ASME Section XI Code Class 1, 2, and 3 systems.

Both Unit Nos.

1 2

were then currently shutdown.

We initiated a

comprehensive review of maintenance orders which had been worked during the time commercial. Quality bolting had been purchased and used in the plant for both safety-related and i

non-safety related systems.

As a result of that review, it is our intention to replace 'all bolting in bolt rings of Code Systems for which maintenance orders reveal the use of Commercial Quality material.

We will not change to MODE 4 on a Unit until we have accomplished that replacement on the Unit.

should you have any questions regarding this matter, please do-not hesitate to contact us.

Very truly yours, JAT/WJL/gla 8712020026 871125 DR ADOCK 05 g7

UA arWCLLJet LEEULATCMV CDeedisseOh Nec Paren M4 APPA0Vf D OMS ho 31to.010s LICENSEE EVENT REPORT (LER)

DOCati asunselm til PAGI (3 8 ActLITY enAuf sti Calvert Cliffs, Unit 1 o15IoIo1o] I i 1 lorl0 l 3 Use of Fasteners (Bolts, Studs, Threaded Rod 6 Nuts) in ASME Class 1,2,&3 Systems With -

out Proper Certification, Special NDE, or Special Markinc tytNT DAf t Ili Ltm esukset a 161 REPOmf Daft (?)

OTMIR P ACILifitt essV0LvtD 851 MONT M DAv Ytan vlam 58,0 L' '

i f,$ MONTa Dav vtAR Paci6tte nauts Docati nvutt ais, Calvert Cliffs, Unit 2 o 1510101o1 3:1 1 8 Ol 4 2l3 8' 7 8l7 0 \\ 0l 9 0l0 0l5 2l1 81 7 0 is to 1 0 toi i i TM48 REPOaf at SueMITTED PUmsu&NT TO TML atoviatuteTs os to Cra { Ichsca eae e< more e'saw foi,**'as> 01) p g39,,g

=*

5 m. i.i

..)

= noiaH-1 n#u.i 90 J86.H H S0 73eH2Hel 71.716sl pourt a 90 aosisH1Hal

~'

1.

i i 0 m

.inim

.0 m,.Hri

.0 n.Han..

eT i. <s <.,u.m.,,

30 emuH1Hm.,

30.73mit2H4) 30 73eH2He444Hal 384 1 30 4066alf1Hml 30.73telt3plali 3013mH2HeleH81 30 eastein lief to.73eeH2Hel to 73 eH2Hsi LectesSIE CONT &c7 POR TM48 Lim (131 TILf'MO48 huwSED havg amtaCOOt William P. ftCaughey, Jr., Licensing Engineer 31011 21610 1-13 1919 11 COnaPLEf t ONE Lent 80A EACM CCedPO.sENT paiguas ptsCalSID $N TMit R APOAT tt31 CauSE S v8TE W Coed *04t NT y'jC

,T,'y f R

T

,T C

CA6fSE SYSTtw COW'Oht%'

m I

i 1 1 I I I I

I I I I I I 1

1 1 1 I l l l

1 l I I I I MONia Day vlam SUPPLeessetTAL atront tIPICTED 114'

.u..., o -

^ " " ' '

"Y] vu,,< P., - nurernosve-ss,o.ecs, 7e 017 21 3 817 mAc7,t

,,M.

....~.,,~,e.,,,,-,.,n..

On March 29 and 30, with the unitin M 0DE 5, cold shutdown, maintenance personnel were trained on our new ASM E Section XIrepair and rephcement program.

During the trairung design engineers learned that fasteners (bolts, studs, threaded rod and nuts) lacking proper certifirmtion may have been installed in safety syste ms. On April 23 we determined there were instances of uncertified nuts installed in safety syste ms and informed the N R C. The original construction codes of certain safety systems require fasteners to have certification such as a Certified Material Test Report or Certificate of Compliance and to meet non-destructive examination and marking requirements above those required by the ASTM specification. We screened 30,000 to 40,000 Maintenance Requests and found, or expect to find,35 to 50 instances where uncertified fasteners were mistakenly installed in certain safety syste ms. Ourinvestigation is continuing and our results will be provided in a supple mental report.

Maintenance personnel were not aware that those uncertified fasteners were not allowed in certain safety systems.

All uncertified fasteners that were found to be mistakenly installed in safety systems willbe replaced with certified fasteners. Though uncertified, the fasteners are made of the same materialas certified fasteners and are capable of performing their safety function.

We initiated a repair and replace ment program in accordance with ASM E Section XI,1983 Edition with Addendum through Summer 1983. This program ensures replace ments are in accordance with the original construction code or a later edition of the code, and therefore meet all certification requirements.

~

' A

'8705280170 BYO521

{DR ADOCK 05000317 Y

PDR

• • *d *"" **

asIC #sem atea US 8sWCLI&a REGULATO2v COMMIS&sOh LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Amovio ous no s+oiu txmans e svan

'Acative seams su DoCast uvuega(2t ggaesvustaist paGa 13) via=

" C

O*.?:

Calvert Cliffs, Unit 1 o p io lo jo l3l1l7 817 0j0 0l2 or 0l3 0 l 0l 9 f(KT M senswa assa a coeused. ens saammiW 48C #erm W si(th 0n March 29 and 30, with the unitin M 0DE 5,in cold shutdown, maintenance personnel were trained on our new ASM E Section XIrepair and replacement program. Ducing the training maintenance personnelinformed design engineers that fasteners (bolts, studs, threaded rod, and nuts) purchased by our safetysulated com mercial-quality method of procure ment, may have been installed in ASM E Section XI Class 1,2, and 3 systems. On l

April 23 we determined there were instances of uncertified nutsinstalled in safety.

syste ms and informed the N R C. Com mercial-quality fastener purchase orders reference the appropriate ASTM spermiation (ASTM-A193, Grade B7 for bolts, studs, and threaded rod and ASTM-A194 Grade 2H for nuts)and are receiptinspected. Receiptinswetion includes vezifying proper markings on the fastener. However, com mercial qua'ity fasteners do not have certification such as a Certified Material Test Report or Certinen te of Compliance, nor do they meet non destructive exa mination (N DE) or marking require ments above those required by the ASTM speciAcation. The construction code for many ASM E Section XI Class 1,2, or 3 systems requires cerHfication and/or special N DE and/or special markings.

The instances of safetyselated com mercial-quality fasteners installed in AS M E Section XI Class 1,2, or 3 syste ms whose construction codes require cerHfica tion and/or special N DE and/or special markings are listed in Attachment A. These are allinstances identtfied up to May 18,1987. We will be identifying more instances and will be able to provide a complete listin the supple mentary report.

Attachment A includes the original construction code for the component. Use that with Attachment B to determine the specific code requirements not met by com mercial quality fasteners.

This event was caused by the lack of knowledge among maintenance personnelregarding limitationsin the use of com mercial-quality fasteners. The majority of stock material are stored outside the potected area in warehotses. Frequently taed stock material, such as com m ercial quality fasteners, are stored in maintenance shops inside the protected area. Maintenance pesonnel were not aware of daQn restrictions of certain systeas that require installation of fasteners with certification that are stored only in the warehouse.

In allcases, we reference the appropriate ASTM specification when purchasing com mercial<pality fasteners. These fasteners are then receiptinspected to ensure proper ASTM markings are on all bolts. Although 1acking certification regtnred by the original construction code, the fastenersin Attachment A are adequate to perfccm their safety function trxler allanticipated operating and accident conditions because we are confident the correct material has been used in all cases.

g,o. usa

MC Form an6A U S ICUCLEAR REGULATORY COMMi$$ ION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION unmovto oMe ~o sm.c4o4 anines swes F1Cl&tT V esAML (1, DOCKET NueselR (26 gga edunstER 16l PAGE 131 "t!,rt'

';.?

iaa Calvert Cliffs, Unit 1 o is to lo lo l3l1l 7 8l7 0 l019 010 0 13 0F 0 l3 Yt.KT ## mare asses a mewwolf, was esspose WAC Fwm W sI(17)

Soon af ter discovering that maintenance personnel may have been incorrectly installing safety-related com mercial-quality fasteners in certain syste ms we initiated an exhaustive research effort.

All Maintenance Requests (M Rs) involving ASM E Section XI Class 1,2, and 3 systems were reviewed to determine the nature of the work.

Those M Rs thatindtcated a fastener was exchanged were reviewed in detail to determine the means by which the fastener was purchased. -

If purchased through our safety-related com mercial-quality method, the fastener is replaced with one meeting the certification requirements of the original construction code.

This screening is continuing and more com mercial-quality fasteners will be identified than those listed in Attachment A. Thatlist willbe updated in a supple mentalreport.

On Aptill we updated our ASME Section XIcode of recond to the 1983 Edition with Addendum through Sum mer 1983. In accordance with this new edition we initiated a repair and replacement progra m. This progra m requires a detailed review of replacements to ensure a suitability evaluation has been made for allreplacements. This will ensure future replace ments are in accordance with the criginal construction code or a later edition of the code.

A review of previous LERs at Calvert Cliffs revealed no similar events.

If2C FOmM 3ssa WI

ATTACHMENT A Fasteners in ASM E Class 1,2, and 3 Syste ms Without Proper Certif2 cation, Special N DE, or Special Marking ORIGINAL U NIT 1 FASTENERS CONSTRUCTION CODE Reactor vessel head vent flange, 3/4" bolting ANSI B31.7, Class 1 Pressurizer vent flange, 7/8" bolting A N SI B31.7, Class I l-RV-469 (SIS), 3/4"in-line bolting A NSI B31.7, Class 1 1-ERV-402 (R CS),1 1/8"in-line bolting A NSI B31.7, Class I l-ERV-404 (R CS),11/8"in-line bolting A NSI B31.7, Class I l-R V-200 (R CS),1 1/8"in-line bolting ANSI B31.7, Class 1 1-R V-201 (R CS),1 1/8"in-line bolting A NSI B31.7, Class I l-CV-5466 (R C Sa epling), 3/4" body nuts ANSI B31.7, Class 2 1-RV-199 (CVCS),1/2"in-line bolting A NSI B31.7, Class 2 1-RV-345 (CVCS), 5/8"in-line bolting A NSI B31.7, Class 2 l

l-FO-4150 (SIS),1/2"in-line bolting A NSI B31.7, Class 2 1-RV-231 (SIS), 5/8"in-line bolting A NSI B31.7, Class 2 1-RV-409 (SIS), 3/4"in-line bolting A NSI B31.7, Class 2 1-CV-4010 (SG Blowdown), 5/8" body bolting ANSI B31.7, Class 2 1-CV-4011 (SG Blowdown), 5/8" body nuts ANSI B31.7, Class 2 i

1-CV-4012 (SG Blowdown), 5/8" body nuts ANSI B31.7, Class 2 1-CV-4013 (SG Blowdown), 5/8" body nuts A NSI B31.7, Class 2 U NIT 2 FASTENERS 2-CV-517 (CVCS),/4" body bolting 3/4" body bolting ANSI B31.7, Class 1 2-51-148 (SIS),1 1 ANSI B31.7, Class 1 2-51-215 (SIS),1" body bolting ANSI B31.7, Class 1 2-SI-225 (SIS),1" body bolting ANSI B31.7, Class 1 2-FO-200(CVCS),7/8"in-line bolting A NSI B31.7, Class 2 f

2-RV-199 (CVCS), 3/4"in-line bolting ANSI B31.7, Class 2 l

2-RV-241 (SIS), 5/8"in-line bolting ANSI B31.7, Class 2 2-RV-431 (SIS), 5/8"in-line bolting ANSI B31.7, Class 2 2-RV-439 (SIS),1/2"in-line bolting A NSI B31.7, Class 2 l

1 l

l

r i E e

e e

a cD n

n E

t e

eN o

o M

a l

p N

N S

m A

c S

y u

n n

f N

o i

s S

i i

rr t

d t

C c

e a

J F

R R"

e n

s H

t r M

M o

s a

o 1

M

• t T

1 T1f p

i I

T a e C

>C 5 n

t t

U MC C

I no d

Q l

c e

E a

r R

u s

e C

g s

n d

N n

e i

o i

V i

s I

i 1.

d

' c a& g t

n K

k R

r t e r

f a

o A

a ap G

M t

c M

M MS T

e V

r e

p r

D 2

r a

N e

A s3 s

e t

d T

l 9 s

ct n

n N

a1 a

l i -

l a

ns i

a AST rA C

iE e

e a e IPN e

cD n

n i T e

3 E

t n r

eN o

o l

v 9

RM a o a

p N

N pc i

1 EE M

l.

e S

mi t

on i

A UN t

l 0I ga c

C o n

I s

i M

l' nc u

t f a f

T

}

N i i T

RI tf or e

S t

d A

AR l i

,C el R

oc R

R" t U n

y T

B e 1

I g

lCS p

• t T

1 T1f a

o b

E yS t r M

M o

c -

i i

d d

t NT r

a e C

>C6 aM MC C

fT e

e i U s

r SE dT FV nS t

a i

FI uA r

b u

I. T o

e.

q C

B o g

Ct e

e l

e s

l r

CU t

n

- e b

d R

e i

1. c a& g T

a e

TT rd k

't e

r f

C t

r RS ue r

EE s r a

a p C

M t

p a.

D s u M

MS f n e

7 V. N T

e c 1

oa c

s AO ro r

c t1 CN P r s

Ct a

n3 P

s e

eB a

T T

n d

m N

l l

P

P

. e e

eI O

C a

T/

T tP r

rS I

iE VTT VTT r

e i N T

r cD MU MU od d

uA A

a eN l

l pi i

q e u s

ey C

e p

l A 1" lA 1" 2

R q n

rb 2

I l

S i

o F

c I

u tL c

gd T

N s

ne R

er g

ir E

To n

ki C

i ru

,C l e t

aq I

1.

R" al l

me t

R 1T1f i c o

r A

't r

T M

o ri b

r T

R a e M

>C5 et eg E

MC C

C t r rn T

aa as ui A

MP i n tk M

D o cr d c i

ae ei

" t f m e

1 it 1i u

d 7

f e d

nn o

9 in Se ao C

1 s

t g mi f

ra rt t

sf eM on d a t

C ti C

f e nc nl u

ai s 7. h B eC f

Cq f

n o1 t m

e ei C3i a et Rr f s d c

.B wd cr T/

ob ae n

a e MT u

rp CM C s C s gI 9 e l v iS6d pl S

rN9d e a E

OA1 A RC TO N1 2

3

a MS NS M

S T

E F

E F

R I

U 3

}T d

S R

n E

e e

a D

n n

G N

o o

N N

N I

2 K

R A

1 M

s D

s N

a A

l r

C K

AS r

T a

IPN e

F s

l XH t

c F F n

u e

N n

WR m

o I

U e

i I

}

t l

J RF E

a AH c

F. T t

i f

r f

CS o

i C

C 6

V UE p

t NT p

r f

f u

e o

o SE S

C FV C

C FI g

l T. T n

a f C i

i CU p

r R

i e

TT P

t RS a

EE M

V. N D

IAO CM NO ITA e

C c

I n

F a

I i

T l

R p

E m

C o

C L

1 A

e 7

f I

d 9

o R

o 1

E c

e t

T A

n C

s a

M o

t c

i B

n i

t e

f c

a m

i u

d e

t r

n c

r t

e as e

s d

lf C

n d

pf o

A ei C 7. h C

C Rl

_ h l1 t a3i t

f nB w r

o i

e C

gI 9 v

iS6 l

S rN9 a

E OA1 C

T O

N 1

B ALTIMORE GAS AND ELECTRIC CHARLES CENTER. P.O. BOX 1475 BALTIMORE, MARYLAND 21203 NUCLEAR OPERATIONS DEPARTMENT catvent CL*Fs Nucitan Powsm PLAwt LU58v. MAmVLAND 30657 May 21, 1987 U. S. Nuclear Regulatory Cmmission Docket No. 50-317 Document Control Desk License No. DPR 53 Washington, D. C.

Dear Sirs:

The attached LER 87-09 is being sent to you as required by l

i 10 CFR 50.73.

Should you have any questions regarding this report, we would be pleased to discuss them with you.

Verytyy ours, W

t J. R. larons Manager - Nuclear Operations Department JRL:

pah cc: William T. Russell Director, Office of Management Information and Program Control Messrs:

J. A. Tiernan W. J. Lippold Il 6

_ J

p ocg'o

$,b LM

]

UNITED STATES 8

NUCLEAR REGULATORY COMMISSION LD s NN.

^

c REGIONI 4

0,,

[

531 PARK AVENUE

,e KING OF PRU$slA, PENNSYLVANIA 19406 Docket / License:

50-317/0PR-53 50-318/DPR-69 l

Baltimore Gas and Electric Company ATTN:

Mr. J. A. Tiernan Vice President I

Nuclear Energy P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject:

Combined Inspection Report Nos. 50-317/87-13; 50-318/87-14 This transmits the findings of the May 11-15, 1987 special, announced operational readiness inspection by Messrs. L. E. Tripp, T. Foley, H. J. Kaplan, 5. A. McNeil, R. J. Paolino, L. Prividy, and C. D. Seller.

The inspection f:ndings were dis-cussed with you and your staff during the course of and at the conclusion of-the inspection.

The purpose of this inspection was to followup NRC concerns with regard to the corrective actions taken for the previously identified environmental y,alification 1

(EQ) deficiencies (Combined Inspection Report Nos. 50-317/87-07; 50-318/87-08) and the improper use of mechanical, commercial quality (MCQ) replacement fasteners J

i l

(UNR 317/87-10-01; 318/87-11-01) prior to permitting restart of Calvert Cliffs, I

Units 1 and 2.

In addition, an overview audit was performed of Quality Assurance I

and of the Engineering Division including its interfaces with the field to assess l

whether the EQ and MCQ deficiencies were indicative of generic organizational 4

problems.

It was determined that the corrective actions for the EQ and MCQ deficiencies were adequate and appropriate.

In addition, no findings were made that would justify the delay of restart for either unit.

However, several significant concerns were identified regarding identified weaknesses in the engineering area primarily with respect to lead and system engineers and in engineering communications interfaces with operations and maintenance.

Though the use of system and lead engineers is a commendable concept, the failure to procedurally define their duties and responsibilities negates many of the bene-fits of such a system.

This lack of definition combined with the informal, inter-divisional communications observed at Calvert Cliffs creates the potential for further instances of inadvertent failure to comply with regulatory or engineering requirements that cut across interdivisional boundaries.

Management should assess the functions of the lead and system engineers and take appropriate action to ensure that their duties and responsibilities are properly defined and that they are provided the appropriate authority to ensure that they can accomplish their respective tasks.

In addition, you should review and assess your communications and tracking methods for tasks which cut across divisional bounds and take action as appropriate.

You are requested to respond to this letter i

h

1. ~

Baltimore Gas and Electric Company 2

,RJL g I ggg7 and discuss what actions will be taken to improve the performance of lead and system engineers and to upgrade the interdivisional communication and implementa-tion of engineering and regulatory requirements.

Your cooperation with us in this matter is appreciated.

Sin ly, 7

/

Edward C. We z ger, Chief Projects Branch No. 3 Division of Reactor Projects

Enclosure:

Combined Inspection Report Nos. 50-317/87-13; 50-318/87-14 cc w/ enc 1:

M. Bowman, General Supervisor, Technical Services Engineering Thomas Magette, Administrator, Nuclear Evaluations Public Document Room (PDR)

Local Public Document Room (LPDR) l Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2) bec w/ enc 1:

Region I Docket Room (with concurrences)

M'anagement Assistant, DRMA (w/o enc 1)

{

DRP Section Chief M. McBride, RI, Pilgrim T. Kenny, SRI, Salem S. McNeil, LPM, NRR Robert J. Bores, DRSS

U. S. NUCLEAR REGULATORY COMMISSION REGION I Docket / Report: 50-317/87-13 License:

DPR-53 50-318/87-14 DPR-69 Licensee:

Baltimore Gas and Electric Company Facility:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted:

May 11-15, 1987 Inspectors:

L. E. Tripp, Team Leader, Chief, Reactor Projects, Section 3A Region I T. Foley, Senior Resident Inspector,Calvert Cliffs, Units 1 and 2 H. J. Kaplan, Reactor Inspector, Region I S. A. McNeil, Project Manager, PDI-1, NRR R. J. Paolino, Lead Reactor. Engineer, Region I L. Prividy, Resident Inspector, Beaver Valley C

D. 5 11ers, Senior Metallurgist, EMTB, NRR Approved:

(-

24])O h[#Th7 L. E. Tripp, Chief, Reactor Projects Section 3A

' Date Inspection Summary:

May 11-15, 1987 (Report Nos. 50-317/87-13; 50-318/87-14)

Areas Inspected:

Special, announced on-site inspection reviewing (1) previously identified environmental qualification deficiencies, (2) licensee identified in-appropriate use of commercial quality mechanical fasteners, (3) post-maintenance testing, (4) interdivisional interface and implementation of engineering require-ments, and (5) a review of quality assurance coverage.

Inspection hours totalled 308.

Results:

No violations or deviations were noted.

However, concerns were raised regarding the use of lead and system engineers and with respect to interdivisional communications between engineering and the field.

--j-p l~ ~0 hg

DETAILS 1.

Persons Contacted Baltimore Gas and Electric Company

• R. R. Allen, Principal Engineer, Performance Engineering, Nuclear Engineering Services Division (NESD)

• A. B. Anuje, Supervisor, Quality Audits, Quality Assurance and Services Division (QASD)

• R. F. Ash, General Supervisor, Design Engineering, NESD

• M. E. Bowman, General Supervisor, Technical Services, NESD J. E. Branyon, Operations Surveillance Coordinator, Nuclear Operations Division (NOD)

• J. T. Carroll, General Supervisor, Quality Assurance, QASD J. B. Couch, Engineer, Fuel Management, NESD

• P. T. Crinigan, General Supervisor, Chemistry, NOD

• G. S. Davis, Principal Engineer, Major Projects, NESD

5. Davis, Senior Engineer, Plants & Projects, NESD

• R. M. Douglas, Manager, QASD

• A. E. Edwards, Assistant General Supervisor, Admin Services, QASD

• R. P. Heibel, General Supervisor, Operations, NOD

• J. R. Hill, Supervisor, Operations Training, QASD M. S. Kostelnik, Engineer, Primary Systems, NESD W. Lange, Engineer, Primary Systems, NESD

• L. S. Larragoite, Licensing Engineer, NESD J. R. Lemons, Manager, NOD

• W. J. Lippold, Manager, NESD

• C. R. Mahon, Principal Engineer, Primary Systems, NESD A. Marion, Senior Engineer, Licensing, NESD

• W. P. McCaughey, Engineer, Licensing, NESD

• R. C. L. Olson, Principal Engineer, Mechanical Engineering, NESD

• M. Roberson, General Supervisor, Quality Control and Support, NMD

• K. Romney, Senior Engineer, Quality Assurance, QASD

• L. B. Russell, Manager, Nuclear Maintenance Division (NMD)

)

L. Salyards, Principal-Engineer, Licensing, NESD i

• X. H. Sebra, Principal Engineer, Electrical Engineering, NESD

• R. P. Sheranko, General Supervisor, Mechnical Maintenance, NMD

• L. A. Sundquist, General Supervisor, Quality Control and Support, NMD

• A. R. Thornton, General Supervisor, Plants & Projects, NESD l

• J. A. Tiernan, Vice President - Nuclear Energy

• E. F. Wasson, Supervisor, Procurement Quality, QASD j

• R. L. Wenderlich, General Supervisor, Electrical and Controls, NMD l

3 NRC C. Y. Cheng, Chief, Materials Engineering Branch, NRR

• J. Durr, Chief, Engineering Branch, Region I M. R. Hum, Materials Engineering Branch, NRR

• D. C. Trimble, Resident Inspector

• E. C. Wenzinger, Chief, Reactor Projects Branch #3, Region I K. R. Wichman, Materials Engineering Branch, NRR

• Denotes personnel present at Exit Interview on May 15, 1987.

2.

Followup of Environmental Qualification Deficiencies a.

Backaround On March 23-27, 1987, an NRC inspection (50-317/87-07; 50-317/87-08) was conducted at Calvert Cliffs Units 1 and 2 to review the status of the.

licensee's EQ program.

During the inspection, the NRC.found that tape splices identified on electrical' leads of certain safety related solenoid valves were not included on the list of electric equipment important to safety required to be maintained in accordance with 10 CFR 50.49, and there was no documentation in a qualification file to indicate that the splices were qualified to perform their intended function under postu-lated environmental conditions.

In response to the NRC findings, the licensee conducted an immediate followup inspection of their EQ program at Unit 2 which was shutdown at the time.

Based on their initial finding of additional unqualified tape splices at Unit 2 the licensee voluntarily commenced a shutdown of Unit.

1 on April 1, 1987 to perform an evaluation of the EQ program at both units so as to determine the magnitude of the problem.

During this-evaluation, the licensee identified several other tape splices, as well as several other items of electrical equipment important to safety, which were either: (1) not included on the list required to be maintained in accordance with 10 CFR 50.49; or (2) not environmentally qualified in that there was no documentation available in a file to support qualifi-cation, or both.

The purpose of this part of the inspection was to review the adequacy of the licensee's ongoing inspection, evaluation, rework, and interim maintenance programs, b.

Inspection and Maintenance Proaram The inspector reviewed the licensee's inspection plan and approach to identification of in plant environmental qualification (EQ) deficiencies.

Design Engineering Section Procedure No. DESP-16, dated April 21, 1987, was developed as an interim procedure for performing reviews.of EQ main-tenance packages and for the control and use of the EQ master list.

All activities associated with the design, procurement, installation, main-

- - - - - - - - - - - - - ~

4 tenance, and replacement of equipment on or affecting the EQ master list are governed by.the requirements of this procedure. The procedure in-cludes checklist attachment B, C, D, and E which identify inspection parameters for splices, motor operated valves, solenoid operated valves, terminal blocks, switches, electrical penetrations, 480 volt motors, and other EQ equipment in the inspection plan.

Using the interim procedures, the licensee inspected all electrical equipment listed on the 10 CFR 50.49 EQ master list with the exception of the reactor vessel level instrumentation which is not yet required to be operational.

A representative sample of EQ cables (26) were in-1 spected from the issuance (cable reel) to circuit use.

The inspection i

of resistance temperature detectors (RTDs) was limited to three RTDs'as the RTD splices were installed by the licensee under a surveillance pro-i gram to ensure proper selection and use of the qualified Raychem splices.

The EQ maintenance package used in maintenance of environmentally quali-fied equipment is controlled through Appendix 200.90 of Procedure No.

CCI-200J. The maintenance package includes the EQ traveler, the quali-fication maintenance requirement sheet (QMRS), the E-406 installation instructions, applicable inspection checklist (DESP-16, Attachment B, C, D, or E), and drawings. Quality Control (QC) reviews and verification ensure that the maintenance package contains the latest document revi-sions. The responsible Maintenance Group Supervisor (RMGS) reviews maintenance packages and assigns personnel to perform the work.

The RMGS signifies his review by signing Section II of the EQ traveler.

Upon completion of the work, the RMGS reviews and signs the completed work package with concurrence of QC and the Equipment Qualification Design Engineer.

Final EQ approval results when the maintenance order and travelers are forwarded to operations as positive indication that the equipment is acceptable and ready for any applicable post-maintenance testing.

The NRC inspector reviewed the following maintenance orders verifying compliance with the established interim procedures:

Maintenance Order Nos.

207-091-106M (#12 Auxiliary Feedwater Room Fan Motor) 207-108-738C (Pressure Switch #1-PS-2085) 207-101-471A (#11 MSIV Close Dump Valve) 207-105-623A (#11 MSIV Pump Air Supply Valve) 207-099-420A (Damper Motor #1-M0-5437) 207-098-343A (Safety Injection Flow Transmitter) 207-111-849A (Junction Box Drain Holes)'

207-113-906A (Junction Box Terminal Block Upgrade)

No violations were identified.

_ -_ _ - _ -- a

i 5

u c.

Training The inspector reviewed records of the licensee's EQ training program f or EQ inspectors.

Training sessions were held on April 9 and 10, 1987 for j

all shift personnel involved in EQ inspection.

Four sessions were held,

]

each consisting of a 45 minute lecture on 50.49 requirements and use.of the EQ master list and a 15 minute question / answer session.

Attendance at these sessions included electrical and control personnel, electrical /

mechanical QC personnel, and planning and scheduling personnel.

1 Additional training was held on April 21 and 22, and May 1, 1987 to dis-I cuss inspection parameters for splices, nut / bolt connections, shims, motor connections, breakouts, and use of installation procedure E-406.

l Training on application of heat shrink tubing was held on October 9, 1986.

j This was a three-hour session for QC and engineering personnel which included hands-on-application for licensee personnel of heat shrink tube i

splices.

J In discussions with craft and supervisory personnel performing the EQ inspections, the NRC inspector found personnel to be knowledgeable and

{

confident in the performance of the work assignments involving EQ in-j spection operations.

J d.

Physical Walkdown The NRC inspector performed a visual inspection of select EQ equipment inside and outside containment to ascertain whether repair and/or re-placement work performed was in accordance with established procedures i

and instructions.

]

The inspector examined the following 50.49 equipment:

Motor Operated Valve No. 2-MOV-626 located in East Penetration, elevation 27'-0", Unit 2.

)

Solenoid Valve No. 2-SV-3832 located in East Penetration, elevation 27'-0", Unit 2.

Solenoid Valve No. 1-SV-5177 located in Component Cooling Room, i

elevation 5'-0",

Unit 1.

No. 11 Charging Pump located in Charging Pump Room, elevation

-10'-0", Unit 2.

No. 21 Charging Pump located in Charging Pump Room, elevation

-10'-0", Unit 2.

a

.______________________m

i l

6

{

Electrical Penetration No. ZF12WE3 located in Containment, elevation 45'-0", Unit 1.

Pressure Transmitter No.1-PT-1013B located in Containment, eleva-tion 45'-0", Unit 1.

Level Transmitter No. 1-LT-1114C located in Containment, elevation 1

45'-0", Unit 1.

Solenoid Valve No. 1-SV-611 located in Containment, elevation 45'-0", Unit 1.

Solenoid Valve No. 1-SV-4150 located in Containment, elevation l

45'-0", Unit 1.

Junction Boxes (containing 50.49 circuits) located in Containment, elevation 45'-0", Unit 1.

No violations were identified.

I e.

EQ Master List j

t The inspector reviewed the licensee's EQ master list noting that the

)

licensee does not differentiate between items important to safety and safety-related equipment. The licensee's policy has been to classify l

items important to safety as safety-related items and includes these items in the master list.

One recent addition (March 5,1987) to the EQ master list is the ECCS Room Fan Cooling System.

Addition of this system has raised a number of questions on the qualification status of cable used, whether the i

cables are run in safety related cable trays and the qualification status of the position switches and pressure switches.

The licensee has pro-vided a Justification for Continued Operation (JCO) to permit operation l

until these concerns are resolved.

1 No deficiencies were noted.

f.

Summary The licensee's programs for resolution of the EQ deficiencies were found to be thorough and provided reasonable assurance that EQ equipment in the plants was properly qualified. A more detailed NRC team inspection of the licensee's EQ program is being planned for later this calendar year.

3.

Followup of ASME Code Replacement Parts Deficiencies As reported in detail 6 of Inspection Report 50-317/87-10; 50-318/87-11, the licensee informed NRC on April 23, 1987 that certain replacement items (principally threaded fasteners) not fully meeting construction code (ANSI a

7 B31.7) requirements had been used in some Class 1, 2, and 3 components.

The replacement parts of concern had been procured for safety related applications as permitted by the licensee's QA program with certain well defined controls, but did not meet code requirements over and above the applicable ASTM mate-j rials specifications.

Such code requirements involved marking, certification, and/or nondestructive examinations.

Unresolved item 50-317/87-10-01; 50-318/

87-11-01 was opened pending licensee resolution of this problem including.

determination of its safety significance.

I The inspectors. reviewed the licensee's identified deficiencies and corrective i

action plans regarding improper use of non-Code fasteners (without proper certification and nondestructive examination (NDE)), and involving the use of the incorrect Code class of tubing materials (Class 2 vice Class 1).

a.

Fastener Screening Program Review The inspectors observed the licensee's. ongoing program for screening approximately 30,000 maintenance requests / maintenance orders.(MRs/M0s) for pressure retaining and support-components-(e.g., flange, fittings, valves & hangers) that potentially were replaced with'new fasteners from commercial quality stock.

The inspectors observed that the reviewers followed a prescribed flow plan featuring two independent review cycles.

The review staff consisted of engineers, operators and engineering tech-nicians. The reviewers were furnished with written guidelines that they were required to read prior to-initiating the review.

During this pro-cess the guidelines were available at all times in the review areas.

The screening process disclosed approximately 80 MRs/M0s that required fastener replacement because commercial quality fasteners were poten-tially used.

The licensee was in the process of replacing all identified and potential commercial quality fasteners that were used improperly in safety-related Class 1, 2, and 3 systems with appropriate Code class fasteners.

The inspectors noted that this deficiency was apparently the result of a misuse of freestock bolting materials when routine work was performed that involved fastener replacement (s) and the correct materials (Mech Nos) were not specifically called out at the planning stage for the Maintenance Order (MO).

It apparently stemmed from a misunderstanding of the term " safety-related" by the site personnel. They thought that items procured for safety related. applications, such'as commercial grade fasteners, were suitable for use anywhere in the plant including ASME-code applications.

This was described by the licensee as a training problem.

b.

Maintenance Order Parts Replacement Review-The inspectors reviewed with the planners (personnel responsible for planning the M0s) three MOs involving replacement of-fasteners and three MOs involving materials and/or welding. The M0s were identified as 207-9

7 8

124-234A, 207-126-301A, 207-041-951A, 206-051-886A, 203-003-396A and 207-031-339A.

The planners appeared to be knowledgeable of and attentive.

to class designations as applied to materials described in the MOs.

Successful completion of the M0 tasks depends upon the planners initial assessment of the work and the materials required.

M0s are initiated by MRs generated by engineers or mechanics.

The pedigree of the mate-rials is established initially in the MR as'either a safety related (SR) or a non-safety related (NSR) class.

This is verified by the planner 4

in the preparation of the M0s using the "Q" List Manual.

The planner then refers to P&I drawings for size, the M-601 manual Bechtel Code de-signations for specific Code class,.the material requirements, and me-chanical numbers (Mech Nos).

The Mech Nos are'a computerized system of material categories that provide a grouping of parts with distinct mate-rial properties and NDE attributes as specified by Code requirements.

The Mech Nos are supported by applicable certified material test reports (CMTRs) or certificates of compliance (C0Cs).

The inspectors found that the replacement parts retained their Mech Nos and traceability through storage, distribution, and final usage through use of tags. After the M0s are prepared by the planners, they are screened prior to and post implementation by a panel of reviewers with significant maintenance expertise as a recent initiative.

The inspectors interviewed a QC inspector who has participated in the review plan.

He was found to be knowledgeable of material classification requirements and demonstrated how this review is guided by GL-32 which provides Guidelines for pre review of NSR and SR M0s.

The inspectors noted that new fasteners being used in the corrective action replacement program were being handled as a special case to ensure traceability and proper material to prevent recurrence of the Mechanical Commercial Quality (MCQ) problem.

The inspector noted in his review of the aforementioned M0s that bolts-and nuts were identified with heat numbers and were traceable to CMTRs furnished by the supplier, A&G Engineering.

A review of the CMTRs indi-cated conformance to bolting and nut specifications and ASME Code Section III Class 1 requirements.

A & G, who holds _on ASME QSC "45J" was audited by BG&E in Oct. 16-17 1986. The inspector reviewed the audit report and found it to be a generally thorough quality assurance audit.

One finding was cited and was closed on 1/16/87.

A warehouse inspection was conducted by randomly selecting six parts identified with-SR Mech Nos to determine if the accompanying CMTRs were retrievable. The inspector found that the CMTRs were readily retrievable.

s 9

The inspector also reviewed three Bechtel material purchase orders with respect to the pedigree of originally installed ANSI B31.7 fasteners.

All three purchase orders correctively specified ASTM A193G7 bolts and ASTM A1941H nuts.

In addition, the purchasing order packages contained-.

CMTRs or COCs as required.

No violations or deviations were noted.

c.

Test Instrumentation Review The inspectors verified the accuracy of various instruments and equipment intended for testing fasteners in-situ or in the laboratory.

These in-cluded instrumentation and equipment for determi_ning chemical constitu 4 ents, hardness and quality. The chemical analyzers used optical emission spectrography and x-ray fluorescence. ~These instruments provided the correct results when tested using known chemistry samples provided by the NRC.

These samples represented three grades of steel. The optical emission instrumentation provided quantitative results yielding results very similar to the NRC spectrographic concentrations.

The X-ray an--

alyses provided semi quantitative results (i.e., it indicated conformance i

or non-conformance when compared to its alloy data bank with permissible ranges of constituents as prescribed by applicable materials specifica--

tions). With regard to hardness, the licensee's stationary Rockwell machine produced hardness results which compared favorably with the NRC

)

results. The licensee's portable hardness tecter (EQUO-TIP) also proved to be accurate.

It produced values that were similar to the NRC results from an A193 B7 sample and with its own calibration sample.

The ultra-sonic procedure, "UT Informative And Pressure Retaining Stud Material" using the longitudinal wave was successfully demonstrated by the licensee using calibration samples of various bolt sizes.

The inspectors con-cluded that the licensee's laboratory equipment and instruments were capable of producing accurate results in the areas of chemical analyses, hardness testing, and quality as determined by ultrasonic testing.

d.

Tubina Review i

The licensee reviewed the application of Class 2 tubir.g vice Class 1 tubing and was able to justify its continued in place use by performing a stress analysis on the fittings to prove that they met applicable requirements.

e.

Summary The inspectors found that the. licensee's use of commercial quality fast-eners was apparently due to the unintentional disregard of the Code (B31.7) by the licensee's staff.

The licensee's decision to categorize fasteners as commercial quality was never challenged by the-licensee's staff possibly due to the lack of. trained personnel knowledgeable of Code requirements.

The problem appears to have been rooted in the myriad of terms and classes which were promulgated by the three Codes (B31.1, B31.7

10 i

I

& ASME Classes 1, 2, & 3) at the time the decision was made.to categorize fasteners as commercial quality.

Although such categories as safety class, non-safety class, safety related, non-safety related and ASME III Class 1, 2, & 3 still persist today, the decision to utilize ASME III Class 1 fasteners for the present replacement' program and the licensee's j

increased attention to Code classification and requirements should pre-clude a recurrence of the fastener. problem.

In addition, the' licensee has established a task committee to develop permanent corrective actions to preclude recurrence of this problem.

These actions will be examined in future routine inspections.

Unresolved item 317/87-10-01; 318/87-11-01 remains open pending. licensee examinations to establish the materials properties'of replaced commercial-quality fasteners.

4.

Post Maintenance Testing Post Maintenance Testing (PMT) is required by Calvert Cliffs Instructions:

(CCI) 200 " Nuclear Maintenance System", specifically 200.50 " Operational Testing".

This instruction permits insertion of test requirements by..the maintenance planners, supervisors, the Operations Maintenance Coordinator, l

and the Control Room Supervisor, to be incorporated into the Maintenance Order Package. Test requirements, however, are not mandated by procedure.. The-l procedure, CCI 200.50,-specifies that the Operations Maintenance Coordinator l

or the Control Room Supervisor determines if a PMT is required and when con-l ditions are appropriate for testing.

No other pertinent direction is~provided by this procedure regarding PMT.

Operations Unit Administrative Policy 65-4, a document provided for use solely by control room operators, provides guid-l ance on Post Maintenance Testing.

The policy provides various maintenance practices and appropriate types of testing.

However, in the tests there are no acceptance criteria, with the exception of portions of surveillance tests l

which are required for Technical Specification related components.

However, l

for work packages utilizing the Field Change Request (FCR) process, the in-l spector found that thorough PMTs were implemented.

~

A review was conducted of about 100 maintenance packages being processed through the Control Room.

About 90% of these MOs required a functional or l

operational test without any further criteria or guidance.

Operations Policy

)

85-4 requires that operators use the guidance to document'the type of func-l tional test to be performed (i.e., for a fan motor - a phase rotation check and running fan and blade direction checks should be performed).

The guidance does not provide the order of phase rotation, conditions to be noted while running the fan, the direction of blade rotation or any other discrete accept-ance criteria.

Additionally, Policy 85-4 itself appears to be inadequate in that it only specifies a functional check of the equipment after maintenance.

For example, after repacking a charging pump a functional test is recommended.

No guidance is given to observe the packing or criteria provided to determine how much leakage is necessary to cool the packing and how much is excessive.

Due to i

I_________.___________._._.____________

J___.

-_ d

11 1

the vageeness of the stated test (i.e., operational test or functional test) both being undefined, the only results obtained are satisfactory or unsatis-factory.

No concrete, usable data is obtained for comparison, reference, trending or equipment history.

Performance data is not recorded.

Because of the lack of discrete tests for each component, and pre established acceptance criteria, the testing performance provides only a low confidence level of general operability.

This lends itself to being quite inefficient I

and inhibits the ability to predict equipment failures, j

Regardless of the deficiencies within the provided guidance, the Contro1' Room Supervisors (CRSs) do not use consistently the guidance that is provided thus 4

resulting in non-uniformity in the performance of the same type tests on I

similar components.

The CRSs provide the last opportunity for input of any.PMT into the mainten-ance package. This provides no review of the proposed test before it is im--

J plemented.

The CRS is one of the busiest positions on site.

It would appear that the responsibility for incorporating appropriate PMT requirements might be better suited to another position.

j 1

This weakness was discussed with the licensee representatives who stated that I

improvements would be made regarding clarity of tests to be performed, accept-ance criteria, and the administration of the PMT program.

Program improve-ments will be reviewed during subsequent resident inspector observations of PMTs; this item is Unresolved Item No 50-317/87-13-01; 50-318/87-14-01.

No violations or deviations were noted.

5.

Interdivisional Implementation of Engineering Requirements The inspectors performed a review of the licensee's methodology for ensuring i

l compliance with engineering requirements of a scope necessitating interdi-i l

visional coordination. The four aspects reviewed were 1) Engineering func-tions and requirements,.2) Engineering interface with the field (Operations, Maintenance and Quality Assurance), 3) field implementation of engineering 1

requirements, and 4) field feedback to Engineering.

a.

Engineering Functions and Reautrements The current Nuclear Engineering Services Division (NESD) was created

-l through a licensee reorganization that became effective on December 30, 1985.

NESD is comprised of three sections: Design Engineering, Plans

& Projects Engineering, and Technical Services Engineering.

The inspectors found that the procedures governing the' functions and l

performance of NESD are the " Quality Assurance Procedures" (QAPs), the "Calvert Cliffs Instructions" (CCIs), the " Design Engineering Section Procedures" (DESPs) and the " Nuclear Engineering Procedures" (NEPs) and

" Nuclear Engineering Operations Guidelines" (NEOGs).

The CCIs and QAPs i

9

12 are generically applicable to NESD, Operations (N0D), Maintenance (NMD) and Quality Assurance (QA). These procedures govern all site functions and activities.

The NEPs and NEOGs control nuclear testing as performed by Technical Services Engineering. The DESPs are applicable only to the Design. Engineering Section.

Apparently, there are no other procedures applicable to NESD functions or to the performance of engineering re-quirements.

During the December 1985 reorganization, the licensee established the role of " system engineer" whose apparent function is to become the system expert with regards to system design basis, function, operation, surveil-lance, testing, modifications / changes, and maintenance.

Also', the system engineer is apparently tasked with responsibility for ensuring system compliance with all regulatory and engineering requirements.

System engineers are generally assigned 2 or 3 systems, which often are un-related in any way.

One may be electrical and the other mechanical.

Similarly, the licensee has lead engineers apparently assigned the re-sponsibility for performance and compliance with respect to requirements that cut across interdivisional boundaries (e.g., environmental qualifi-cation).

The inspectors noted that the aforementioned functions and responsibili-ties of the system engineers and lead engineers are only apparent func-tions and responsibilities as they are not described in any licensee procedure or document or via any programmatic training, though the role of system engineer has existed for well over a year.

The licensee stated during the course of this inspection that they intend to establish a training program for system engineers at some future, un-defined date.

Through discussions'with several system engineers, the inspector found that the system engineers currently perform what they assume are their duties through the use of QAPs and CCIs that'specifically govern sur-veillance testing, maintenance, modifications and other applicable evolu-tions.

However, many of these procedures have not been revised ade-quately to reflect the role of the system engineer and, as such, provide little specific guidance.

There currently exists no firm mechanism or system to ensure that the system engineers are aware of applicable engineering or regulatory re-quirements or of any changes that may occur in these requirements.

Generally, they are informed by Licensing via a Facility Change Request (FCR) or memo that a regulatory requirement has changed and that proce-dural revision may be necessary.

Similarly, they sometimes are routed copies of vendor. technical manual revisions applicable to their systems.

Any other knowledge of engineering or regulatory requirements is achieved through independent study or on-the-job experience.

F,

13 The system engineers do not directly revise operations or maintenance procedures that are performed to ensure compliance with current or new I

engineering and/or regulatory requirements..Rather, they must request that NOD or the procedures revision group.for maintenance procedures up-date these procedures.to reflect the necessary changes.

Generally,.they.

do not review these procedures to ensure that the required changes were actually made in a proper and timely manner.

Conversely, the inspectors noted that the functions and responsibilities of the design engineering staff, as provided in the DESPs generally were better defined, explained and controlled.

Some of the areas controlled by the DESPs include design changes, procurement, equipment qualifica-tion, Q-list control, document and drawing control and seismic qualifi-cation.

It should be noted however, that the EQ deficiencies were partially at-tributable to inadequacies in the DESP procedural guidance as discussed below.

b.

Engineering Interface with the Field The inspectors reviewed the system for communication interfaces between NESD (particularly the system and lead engineers) and the field for en-1 suring full compliance with engineering and regulatory requirements.

The current interface system was found by the inspectors to be rather informal and undefined with potential for the loss of significant in-formation (e.g., the EQ and MCQ deficiencies previously noted).

The method of communication used by the system and lead engineers to ensure compliance by NOD or NMD with requirements or with changes in requirements was usually a memo from one engineer to another requesting that an action be taken.

There is apparently no tracking system to en-sure compliance with or completion of these actions nor is a responding memo to the originator from the recipient required or generally performed.

This system is used by the lead and system engineers to request required operations and maintenance procedural revisions, to provide technical guidance and to provide clarifications to ensure regulatory compliance.

c.

Field Implementation of Engineering Requirements A review was conducted of how the field, particularly NOD and NMD, comply with engineering requiremer.ts that are provided by NESD.

Emphasis was placed upon the areas of EQ and MCQ where specific interface deficiencies had been previously noted.

14 1)

Environmental Qualification Requirements J

Through discussions with electricians and supervisors and through the review of conflicting documents, the. inspector ascertained that information communicated to the field from NESD regarding the ac-ceptability of the use of standard electrical tape in the field for environmental qualification purposes was unclear.

This was clearly.

.j a contributing factor in the use of non qualified tape splices in the field.

A memo dated December 5, 1986 to K. Pickering from J. P. Perkins regarding Non-Conformance Report 3915 clearly indicates that for some applications, use of electrical tape was considered acceptable, yet another memo dated July 19, 1985 from A. Marion to.the depart-ment heads, requires the use of heat shrink tubing on safety related low voltage terminations in harsh. environments.

This memo also acknowledges the use of tape is acceptable "only if the tape compo-sition is known". The memo further indicates that tape would be acceptable "for selected applications".

"However, the E-406 (elec-trical construction standard) would be. revised to detail the re-quirements to utilize Ray Chem shrink tubing as a standard." Sub-sequently, though the' standard was revised in March 1987, the engi-neering requirements were still confusing in that: E-406 11.3 " Ray Chem Installation Standard" (A) Ray Chem for Instrument and Control connections and (B) Ray Chem for motor connections both state " Refer to the Comp. No. versus Qual. No. List-in CCI 208 for the QMR (qualification maintenance requirements) sheet that gives the splice connection method".

Three independent electricians attempted to walk the inspector through the above instructions without success.

Later the inspector determined that (1) a Comp. No. versus Qual. No~. List does not exist in CCI 208; (2) both a Comp. No. and a Qual. No are found in the 50:49 List; and (3) only the QMR sheets are'found in CCI 208.

The instructions would be clearer if worded "use the component number l

found in the 50:49 List to reference the qualification number.

Use this qualification number to find the appropriate QMR sheet in CCI 208 that should provide the appropriate splice connection method."

Further, reviews of several of the QMRs of CCI 208 " Qualification Maintenance Programs", revealed that none had any requirements!fo.-

splicing methods, for the use of Ray Chem heat shrink tubing, or for torquing transmitter covers, junction boxes or other EQ water tight enclosures.

Additionally, though a section for post mainten-ance testing exists, in almost every case no testing was required.

Improvements in this area are needed.

The inspector also noted that past Field Change Request (FCR) re-quirements formulated by NESD with regard to EQ were inappropriate i

to the circumstances in that FCR 83-1033 was written by NESD to up-grade solenoid valves to EQ standards. The FCR's title, " Procedure

15 for Installing Environmentally Qualified Rebuild Kits for In-Con-tainment Solenoid Valves," mislead the electricians into believing that only a kit was to be installed into the existing solenoid valves.

However, a note at the beginning of the procedure stating

" solenoid valve should already be removed from control valve and taken to a suitable work area." was overlooked (possibly due to the apparent simplicity of installation of the upgrade kit).

Instruc-tions were followed during the installation of the kits except that reinstallation of the solenoid was not performed since they had not i

been removed from containment, the kit was installed with the valve in place and, therefore, step 9 of the procedure was not performed.

This step required reinstallation of the solenoid and sealing it with a Ray Chem environmentally qualified seal assembly.

Additien-ally, Ray Chem tubing was not provided with the rebuild kits.

More clarity was necessary in the FCR package to emphasize the need to upgrade the splices as well as the valves.

The licensee acknowledged these problems.

They had previously com-mitted to revise / clarify such procedures before interim measures (DESP-16 as discussed in Section 2.a) are discontinued.

2)

Material Qualification Requirements Engineering requirements in the field regarding material specifica-tions are found on plant drawings and in QAP 15 " Changes, Tests, and Experiments".

In both cases, the requirements are very general and simply reference other drawings where specifications can be found (i.e. M-600 and 601).

Engineering requirements also are found on FCR packages and in the Control Work Package (CWP).

Both clearly define the required specifications.

Only in the Maintenance Order /

Maintenance Request systems do the specifications become vague.

This appears due to the lack of detailed instructions to the main-tenance planners who compile the M0 package.

Previously, maintenance planners for the M0 package would research the type of material required for a particular job utilizing the appropriate system drawings plus the use of the M-600 drawing which provided correct material specifications (e.g., ASTM specification).

However, no instructions or training was provided to make the planners aware of the use of the M-601 drawing in order to find the component ASME class (if appropriate).

Training or instructions vere not provided to maintenance planners to detail the necessary methods to perform their tasks.

In some cases, this resulted in not obtaining the ASME class of the replace-ment component and not seeking out the material number required in order to obtain the correct part from procurement which would in-clude the appropriate certifications.

1

_a

16 1

In this regard, engineering requirements were not fully implemented

)

in the field.

This was a contributing factor to the MCQ problems.

1 Other areas where communications weaknesses similar to those in the EQ and MCQ areas were noted was between engineering and operations depart-ments and between engineering and the PM program and surveillance pro-grams.

j These areas need to be evaluated by the licensee to establish better communication methods.

d.

Field Feedback to Engineering l

The inspectors reviewed the feedback process from the field (particularly NOD) to engineering.

They found that though the system (and lead) engi-neers were responsible for their assigned systems (tasks), very little I

feedback from the field is procedurally prescribed or required.

For example, CCI-104H, " Surveillance Test Program" provides the licensee's guidance and requirements concerning surveillance testing including in-terface with.the system engineer.

This procedure purposefully' excludes the system engineer from involvement with many aspects of the surveil-4 lance program affecting his system.

In reviewing the operations surveil-

]

lance program, the inspectors found that the following information generally was not shared with the responsible system engineer:

concurrence with or knowledge of revisions to operations surveil-lance test procedures scheduling of applicable system surveillance testing parts replacement during surveillance testing temporary changes to surveillance test procedures out of specification test results, components adjustments or mal-functions during surveillance testing unless unable to correct during the performance of the test

]

review of applicable operations surveillance test for system trending justifications for out of specification results including POSRC reviews of surveillance tests The inspectors found that information flow from NMD was better as the system engineers are included in the procedural review process and in the completed surveillance test review process. However, the inspectors did note that there existed a considerable time delay between the per-formance of these surveillance tests and the availability of the results to the system engineer for review.

1 L_________________________.________________._

i 17

)

I e.

Summary The inspectors concluded that though the system and lead engineers ap-parently are accountable for their systems / tasks, they are not provided with appropriate job definitions, training, procedures, information flow, and authority to ensure that their assigned systems perform properly and-are in compliance'with. applicable. engineering and regulatory requirements.

The licensee needs to evaluate and take action to permit better perform-ance of the functions of lead and system engineers.

6.

Quality Assurance Review 1

a.

Review of Quality Assurance Coverage The inspector reviewed the licensee's QA Program with particular emphasis.

]

on Quality Assurance (QA) audits and other overview functions which could l

have identified the EQ and MCQ problems.

In addition, observations were made concerning the overall QA audit program.. Also, the. inspector re -

viewed the development of the QA audit group during the past two years in order to put into proper perspective the recent EQ and MCQ issues.

The inspector noted that prior-to January 1, 1986, the Quality Audits Unit (QAU) was divided in half with basically 6 auditors located on site and 6 auditors located in the Baltimore Office where the Engineering Section was also located.

The off-site auditing' group's primary task was to review the various engineering functions which included engineer-ing activities at Calvert Cliffs and at the licensee's fossil plants.

~

With this background established, the inspector reviewed the following:

Audit personnel qualifications and training.

General conduct of audits by the QAU including audit plans, sched--

ules, reports and findings.

l Specific audit files pertinent to the EQ and MCQ issues.

l l

Finally, the inspector had several observations concerning the overall l

QA audit program.

b.

Audit Personnel Qualifications and Training Licensee management recognized several years ago that additional techni-cal expertise was needed in the QAU.

This fact was-reinforced in a pre-vious NRC inspection where an unresolved item (50-317/85-22-04 and 50 -

318/85-20-04) addressed this issue.

This issue was recently closed based on the licensee's commitment to include in QAU Procedure 3, " Audits",

a provision requiring technical expertise on an as-needed oasis.

The inspector discussed this issue with several QA personnel and determined a

4

18 that the licensee was committed to developing in June, 1987, a firm list of technical consultants requirements of the QAU program.

While the majority of these personnel would be licensee employees, it was recog-l nized that certain audits may require outside consultants such as the EQ area which was probably the weakest technical area within the QAU group.

The inspector reviewed the qualifications and training records of the 13 QAU auditors who conduct the audits.

Only 3 of these auditors are not qualified as lead auditors and these personnel are recent (within the past year) additions to the QAU.

The inspector noted that several personnel from other licensee working groups (Operations and Maintenance) have joined the QAU since the licensee's reorganization of~ January 1, 1986.

This should be a long term positive influence for the QAU.

Also, 8 of the 13 auditors have been in the QAU since only 1984 which basically indicates that the current group is relatively new.

However, it still has retained some valuable experienced personnel.

Training for the auditors both on-site and off-site concerning selected subjer.ts was planned annually.

Based on these observations, it appears that the licensee's QAU is de-veloping its personnel such that improvements in the audits performed by the QAU should be expected.

c.

General Conduct of Audits The QAU follows the guidelines of QAUP 3, " Audits," for preparing audit plans. This guidance specifies a structured checklist which each auditor must complete prior to performance of the audit.

This checklist contains items such as:

Review previous audit report Incorporate concerns of the Off site Safety Review Committee (OSSRC) reviewer Review Audit Information Book The inspector was advised that the Audit Information Book was one of the mechanisms used to coordinate miscellaneous important issues from various plant sources (e.g., Engineering, Quality Control). Knowledge of these j

important issues by the auditor would enable him to assess performance in this area.

Also, the inspector was advised that the group being audited is usually given the opportunity in advance of the audit to have a particular area audited. These factors enable the auditor to prepare the audit plan with input from outside groups (e.g., OSSRC, audited group, etc.). The general approach by the QAU in preparing audit plans appears to be sound.

19 Theinspectorreviewedthe1986and1987auditschedulesandseveral1986 audit reports with their findings, recommendations and resoluti ms and had the following observations:

Basically, the same audits are being planned for 1987 as were per-formed in 1986 with no change in audit frequency.

Some audits have been eliminated for 1987.

Resolution of audit findings generally occur within agreed time limits but many time extentions were requested.

More substantive recommendations were being generated in 1986 than in earlier audits which were generally well accepted by audited organizations.

This leads to the conclusion that audit depth and quality is improving.

There were isolated cases where unusually high numbers of findings or recommendations occurred.

With this understanding of the general conduct of audits, the inspector reviewed specific audit activities pertinent to the EQ and MCQ issues.

d.

Specific Audit Activities Concerning EQ and MCQ Issues 1)

EQ Audits The licensee had performed annual audits of its EQ activities since 1981 with relatively insignificant audit findings through the 1985 audit.

In 1982, there were 2 findings and in the other 4 years, there wcs I finding each year.

However, Audit 86-15 which was per-formed in March / April, 1986, had 6 findings. The inspector ques-tioned the responsible engineer in the Plant and Project Engineering Group concerning their initial response to these findings.

In par-ticular, one of the findings was quite significant in that 12 of the 65 Qualification Maintenance Requirement Sheets (QMRSs) br.d problems or discrepancies that required correction.

The responsible engineer indicated that he was surprised when 12 QMRSs were found to be deficient as he expected possibly 1 or 2 might have problems.

The inspector noted that the findings of Audit 86-15 supported and supplemented the recent NRC enforcement action concerning EQ.

Fur-thermore, the inspector inquired with the QA Manager and QA General Supervisor concerning why QA had not independently recognized a deep rooted EQ problem after Audit 86-15.

As previously mentioned, the EQ area is the weakest in terms of technical expertise in the QAU and hence, QA felt that they were not in a position to make such a determination in 1986.

r

_~

20 The inspector was concerned that possibly other audits had been performed in 1986 and 1987 which might point to a potential, deep rooted program problem other than EQ.

The inspector inquired with the QA General Supervisor if a structured review of 1986 and 1987 audits had been performed to address this concern.

No such review had been performed and the licensee agreed that such 3 structured review would be done.

2)

MCQ Audits The licensee compiled a new surveillance report (S-87-11) to deter-mine the effectiveness of the corrective action program concerning the MCQ issues.

This surveillance had just begun and was approxi-mately 30% complete at the end of the inspection. Therefore, only preliminary information was available.

No significant findings had been generated.

e.

Observations Concerning Overall 0A Audit Program As previously mentioned, the licensee has made noted progress in the QAU group in developing its personnel.

Also, the licensee noted that it is committed to performing a late 1987 audit of a safety system which will be patterned after the Safety System Functional Inspection (SSFI) tech-j niques conducted recently by NRC at other utilities.

This indicated good 1

initiative and commitment to quality by the licensee. While this SSFI audit is new, the inspector asked the QA General Supervisor if the QA audit program is reviewed annually to determine if new audits are war-ranted in response to noted weaknesses.

For example, several different audits (e.g., corrective Maintenance and EQ) may be performed where two working groups (e.g., Engineering and Maintenance) have problems.

Con-sequently, this situation could warrant a new audit to look at the engi-neering/ maintenance interface on all issues.

1 In response to this question, the licensee indicated that a trend report of QA audit program findings is developed every 6 months for 055RC review but the trend report has not reached the point of recommending that new audits be performed in response to noted weaknesses. The QA General Supervisor agreed that an annual review of the QA audit program would be done to determine if such new audits are warranted.

7.

Exit Meeting The inspectors presented their findings to licensee management personnel at an exit meeting on May 15, 1987. The attendees are listed in Section 1.

At no time during this inspection was written material provided to the licen-see by the inspector.

Based on the NRC review of this report and discussions held with the licensee representatives during this inspection, it was deter-mined that this report does not contain information subject to 10 CFR 2.790 restrictions.

r

,,_J NAC e sem 3bt U $ acuCLE AR E aOWLATOJIT CObedtS$80N Apenovt0 Owa=0 Sieniu

)

LICENSEE EVENT REPORT (LER) 8 " *a ' 5 ' ' 8'

..C.......t...

._E,__...

Calvert Cliffs, Unit 1 opsiciolol31117 1lor!013

' " " " Use of Fasteners (Bolts, Studs,'Ihreaded Rod & Nuts) in ASME Class 1,2,&3 Systems with-j out Prener Certification. Special NDE. or Special Markine j

i tvikT DATEil Ltm huuttaas pePORT Daf t 171 OTMan F AclLITit5 INv'4VID ist MO%To DA.

vias vtan 58[j

,6

• • j'[

MO%Tm DAv vtaR

'acativv hawls DOCalt huwsta s Calvert Cliffs. Unit 2 015101010 l31118 4

0l 4 2l 3 8'7 8l 7 0l0 l9

- 0l1 0l7 2l3 8l7 c isio io, oi i i TMis af PORT is sveWITTED PWA8vaNT TO TMt REQUIREMENTS OF 10 CP R { ICaera eae er me<a e' ne re9e as (116 Opt R ATlhG HOOT W l N aC2tt' M 406ts) to 73mlGHse) 73 71161 l N 406iewille to asisHit 30 73miGHol 73 714sl

,,0

,0 1.

0..H, H.,

.0..,

.0,....H

=,;,..m.

N 406taH1Het 90 73mH2H4 30.73ealGil.nlHAl Js6Al J

[

]

[

u n.iaH.,

n.0.

Hin,

0 n.ian. H..

M 80BieH1H.I to ?3isH2Hdil 30 78talGHal LtCENEtt CONT ACT FOR TMt8 LE A liti Navi 78LEPMO4B hvW9tm Apia CODE William P. McCaughev, Jr., Licensing Engineer 310 11 216101-13191911 ConsPLETE 048 LINE 80A 4 ACM COnd>ONtstT F AILUmf OttCAlttD IN TMit REPORT dist "h 0 Tg,','h I

"$NC meromTA Lt CALSE S *$tt e COM*ONENT CAUlf SY tt t M COMPohtNT I

f i f I ! l l

I f I l I I 1

I I l l l l I

l l l I l I

$UprLlutNT AL mtPos? EXPECTED flal MONTM Day vtaa Sv0Miss'ON vis fH ree remeets fM*$CTRD SV0 MIS $106 DA TRI NO l

l l

A T. AC T u,m,,,,,a -e,. e.

e.

,e,,

.. ~., n.,

On March 29 and 30, with the unitin M ODE 5, cold shutdown, maintenance personnel were trained on our new ASM E Section XIrepair and replacement program.

Durin nuts) g the training design engineers learned that fasteners (bolts, studs, thmaded rod and lacking proper certifimtion may have been installed in safety systems. On April 23 i

we determined there were instances of uncertified nuts installed in safety syste ms and informed the N R C. The original construction codes of certain safety syste ms require fasteners to have certif2 cation such as a Certified Material Test Report or Certificate of Compliance and to meet non-destructive examination and marking requirements above those required by the ASTM spedfiution. We screened 30,000 to 40,000 Maintenance Requests and found 61 instances where uncertified fasteners were mistakenly installed in certain safety syste ms.

The event was caused by inadequate precautions placed on repair and replace m ent planning activities regarding the use of com mercial-quality fasteners.

All uncertif2ed fasteners that were found to be mistakenlyinstalled in safety systems ware replaced with certified fasteners. Though uncertified, we are confident the fasteners are made of the same material as certified fasteners and are capable of performing their safety function.

We initiated a repair and replace ment progra m in accordance with ASM E Section XI,1983 Edition with Addendum through Summer 1983. This program ensures replace m ents are in accordance with the original construction code or a later edition of the code, and therefore meet all certification requirements.

N

-e707m37V~ s70723 b

PDR ADOCK 05000317 S

PDR

\\,i

l I

we. ma u a cuenca novaron co-mwos LICENSEE EVENT REPORT (LER) TEXT CONTINUATION a w ovioowe=o me-om EXPIRis 8'31 se j

uc uv....

n, ooc..,=v-.. m o,, v,,,,,,,

" e =."

03,t:

i.a 1

0 l3 Calvert Cliffs, Unit 1 o ls jo lo lo l 31; 7 8l7 0 l0 ;9 0;1 0;2 or 1

ww-w

- m m uu v or, On March 29 and 30, with the unitin M ODE 5,in cold shutdown, maintenance personnel vere trained on our new ASME Section XIrepair and replacement program. Dtring the traimng, maintenance personnelinformed design engineers that fasteners (bolts, studs, 4

l threaded rod, and nuts) pun:.hased by our safety-related, com m ercial-quality m ethod of procure ment, may have been installed in ASM E Section XI Class 1,2, and 3 syste ms. On April 23 we determined there were instances of uncertified nuts installed in safety i

syste ms and informed the N R C. Com mercial-quality fastener purchase orders reference

(

the appropriate ASTM speriBration (ASTM-A193, Grade B7 for bolts, studs, and threaded I

rod and ASTM-A194 Grade 2H for nuts)and are receiptinspected. Receiptinspection I

includes venfying proper markings on the fastener. However, com mercial quality fasteners do not have cerH Aration such as a CertiSed Material Test Report or Certificate of Compliance, nor do they m eet non-destructive examination (N DE) or marking requirements above those required by the ASTM speri6 cation. The construction code for many ASME Section XI Class 1,2, or 3 systems requires certification and/or special N D E and/or special m arkings.

The instances of safety-related co m m ercial quality fasteners installed in ASM E Section l

XI Class 1,2, or 3 syste ms whose construction codes require cerH ArAtion and/or special N DE and/or special markings are listed in Attachment A.

Attachment A includes the original construction code for the component. Use that with

)

Attachment B to determine the specific code requirements not met by com mercial quality fasteners.

l This event was caused by inadequate precautions placed on repair and replace ment planning activities regarding the use of com merda2-quality fasteners. A consolidated source of code and other design related require ments for systems or components being repaired was not available to the maintenance planner. Also, the overallpurchasing and stores process did not effectively identify parts that were qmliAad for use when completing a maintenance order.

In all cases, we reference the appropriate ASTM spc4Aration when purchasing com merdal-quality fasteners. These fasteners are then receiptinspected to ensure they have proper ASTM markings. Althoughlacking certification required by the original construction code, we are confident the fastenersin Attachment A were adequate to perform their safety function under all anticipated operating and accident conditions because we are confident the correct materini was tsed.

l M*"~ '

1 --

NRC ese st44 U $ NUCLEAR EttGULATORY COMMi&5'ON LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Amovto ove ~o mo-eso.

EXPint$ 9:312

• LCitif v hawn lis Docetti Nunnet a (21 Lan wunesta loi pact tas "t',Wt'. c'1*,7:

saa 0l q 9 0l1 0l3 oF 0 l3 Calvert Cliffs, Unit 1 o is Io lo lc l3l1l 7 8l 7 vm - -.. - -..c % =.., t:1, Soon after discovering that maintenance personnel may have been incorrectly installing safety-related com m ercial quality fasteners in certain systems we initiated an exhaustive research effort.

All Maintenance Requests (MRs) involving ASME Section XI Class 1,2, and 3

)

systems were reviewed to determine the nature of the work (30,000 to 40,000).

{

Those M Rs that indicated a fastener was exchanged were reviewed in detail to determine the maans by which the fastener was purchased.

If purchased through our safety-related com mercial-quality method, the fastener was replaced with one meeting the cerHfntion requirements of the original construction code (61 cases listed in Attachment A).

1 On Aprill we updated our ASME Section XI code of record to the 1983 Edition with 1

Addendum through Sum mer 1983. In accordance with this new edition weinitiated a repair and replacement progra m. This program requires a detailed review of replacements to ensure a suitability evaluation has been made for a11 replacements. This j

will ensure future replacem ents are in accordance with the origina1 construction code or J

a later edition of the code.

Also, we are conducting a comprehensive review of our repair and replace ment planning activities and will make changes as appropdate. One change we intend to make is to j

consolidate pertinentinformation for the maintenance planners. This review, and appropriate changes, are planned for completion at the end of 1988.

A review of previous 1.ERs at Calvert Cliffs revealed no similar events.

• enu sees

l ATTACH MENT A Fastenen in ASM E Class 1,2, and 3 Systems Without Proper Certification, Special N DE, or i

Special Marking

)

ORIGIN AL U N1T 1 FASTENERS CONSTRU CTION CODE Reactor vessel head vent flange, 3/4" bolting ANSI B31.7, Class 1 Pressurizer vent flange, 7/8" bolting A NSI B31.7, Class 1 1-RV-469 (SIS), 3/4"in-line bolting ANSI B31.7, Class I l-ERV-402 (R CS),1 1/8" in-line bolting A NSI B31.7, Class 1

]

1-ERV-404 (R CS),11/8"in-line bolting ANSI B31.7, Class 1 1-R V-200 (R CS),1 1/8" in-line bolting A NSI B31.7, Class 1 1-R V-201 (R CS),1 1/8" in-line bolting ANSI B31.7, Class I l-CV-519,1/2" support bolting A NSI B31.7, Class 1 1-CV-5465 (R C Sampling) 1/2 support u-bolts ANSI B31.7, Class 1 1-CV-5466 (R C Sa mpling)) 1/2" support u-bolts A NSI B31.7, Class 1 1-CV-5467 (R C Sampling 1/2" support u-bolts ANSI B31.7, Class I l-CV-5466 (R C Sa mpling), 3/4" body nuts A NSI B31.7, Clas 2 1-RV-199 (CVCS),1/2"in-line bolting ANSI B31.7, Class 2 1-RV-345 (CV CS),/2"in-line bolting 5/8"in-line bolting A NSI B31.7, Class 2 1-FO-4150 (SIS) 1 ANSI B31.7, Class 2 1-RV-231 (SIS) 8"in-line bolting A NSI B31.7, Class 2 1-RV-409 (SIS) 3/4"in-line bolting

. ANSI B31.7, Class 2 l

1-CV-4010(SG Blowdown) 5/8" body bolting A NSI B31.7, Class 2 l-CV-4011(SG Blowdown) 5/8" body nuts ANSI B31.7, Class 2 1-CV-4012 (SG Blowdown) 5/8" body nuts A NSI B31.7, Class 2 1-CV-4013 (SG Blowdown) 5/8" body nuts ANSI B31.7, Class 2 1-5I-221, 5/8" body bolting A NSI B31.7, Class 2 Containment Spray Pump, inlet & outlet bolting ANSI B31.7, Class 2 l

Charging Pump 13, support bolting A NSI B31.7, Class 2 1-SI-407, body bolting ANSI B31.7, Class 2 1-SI-430, body bolting ANSI B31.7, Class 2 Charging pump 12, body bolting ANSI B31.7, Class 2 C

mp 2, support bolting ANSI B31.7, Class 2 '

H C-3-1004 SIS, support bolting ANSI B31.7, Class 2 Spent Fuel Pool Heat Exchanger, head bolting A NSI B31.7, Class 3 1-CVC-311, body bolting ANSI B31.7, Class 3 Spent Fuel Pool Pump 11, flange bolting A NSI B31.7, Class 3 0-YS-2001, bonnet capscrews ANSI B31.7, Class 3 Charging Pump suction stabilizer, body bolting A NSI B31.7, Class 3 Pipe Support (SIS), support bolting

. ANSI B31.7, Class 3 Pipe Support (SIS), supoort bolting A NSI B31.7, Class 3 i

l

i ATTACH MENT A Page 2 0 RIGIN AL UNIT 2 FASTENERS CONSTRU CTION CODE 2-CV-517 (CVCS), 3/4" body bolting ANSI B31.7, Class 1 2-51-148 (SIS) 11/4" body bolting ANSI B31.7, Class 1 2-51-215 (SIS) 1" body bolting ANSI B31.7, Class 1 2-5I-225 (SIS) 1" body bolting ANSI B31.7, Class 1 2-CVC-188, suppot bolting ANSI B31.7, Class 1 2-FO-200 (CV CS), 7/8" in-line bolting ANSI B31.7, Class 2 2-RV-199 (CVCS), 3/4"in-line bolting ANSI B31.7, Class 2 l

2-RV-241 (SIS) 5/8"in-line bolting A NSI B31.7, Class 2 2-RV-431 (SIS) 5/8"in-line bolting ANSI B31.7, Class 2 2-RV-439 (SIS 1/2"in-line bolting ANSI B31.7, Class 2 2-CV-5464 (R C sa mpling), support bolting ANSI B31.7, Class 2 2-AFW-4535,in-line bolting A NSI B31.7, Class 2 2-51-468, body 61 ting ANSI B31.7, Class 2 2-SI-211, body bolting A NSI B31.7, Class 2 l

Refueling Water Pump, flange bolting ANSI B31.7, Class 2 2-5W-1583, body bolting A NSI B31.7, Class 2 Charging Pump 21, suction flange bolting ANSI B31.7, Class 2 Charging Pump 22, suction flange bolting A NSI B31.7, Class 2 Charging Pump 23, suction flange bolting ANSI B31.7, Class 2 Refueling Water Tank, manway bolting ANSI B31.7, Class 2 2-51-417, body bolting ANSI B31.7, Class 2 2-SI-430, body bolting A NSI B31.7, Class 2 2-FE-305, flange bolting ANSI B31.7, Class 2 2-SI-221, body bolting A NSI B31.7, Class 2 Charging Pump suction stabilizer, body bolting ANSI B31.7, Class 3 l

l l

l 1

l

C I

r a E e

e e

r i

a cD n

n E

t e

eH o

o M

a l

p N

N S

m A

c S

y u

n n

f M

o i

s S

i i

T t

d t

N C

c e

a F

R R*

e n

s M

l.

t T

1 T1 f p

i F

't R

r M

M o

s a

o I

a e C

>Cs n

t t

MC C

I n

I P

o d

U l

c e

a r

R u

e e

s n

d G

g N

n e

i o

i V

i s

d T

i I. c a&g t

n K

k

't R

r e

r f

a o

A e

ap B

N t

c M

M MS T

e V

r e

p r

D

?

r a

N e

A s3 s

e t

d T

l 9 s

ct n

n N

a1 a

l ns i

a AS i -

l a

T rA C

i E e

e a e IPN e

cD n

n i T e

3 F

t n r

eH o

o l

v 9

RI e o a

p M

N pc t

1 F

t Mi e

S mi t

D on i

A Ul t

l C o n

ga c

l l

M f

s i

Pi nc u

f a f

T F

N i i I

2F tf or e

S t

d A

AR t l

.C el F

oe R

R" t

n y

i 1 T R e l

t t

T 1 T1 f a

o b

r S.

p

't g

r M

o c-y F

yS f

f t

t i

d d

i MT r

a e C

>C$

aM MC C

fT e

e U

s r

SE dT i

FV nS t

a i

FI uA r

b u

i T o

e.

q C

R o g

Ct e

e l

e s

l r

Ct t

n f

- e b

i l.

d R

e c

a& g T

a e

TT rd k

't r

f C

t r

RS ue r

e EE s r a

a p C

M t

p a.

D s u M

MS f n e

7 V. N oa c

s T

ec 1

AO ro r

c t1 CN P r s

Ct a

n3 P

s e

eR a

T T

.n d

m l

l

P

F e

e eI NO C

a T/

T tP r

rS I

iE VTT VTT r

e iN T

r cD MU Nt od d

uA I

A n

eH l

l pi i

q C

e p

l " "

l " "

eu s

e y I

i S

A12 A12 Rq n

rb F

c t.

o I

u t1 c

gd T

M s

ne er g

i r RF To n

ki i

ru C

.C l e t

e q I

l.

R" al l

me t

R 1 T1f ic o

r A

't r

T f

o ri b

r T

R e e M

>lC5 et eg E

MC C

C t r rn T

a a ae oi A

MP i n tk M

De er d e t

se et

• t f m e

1 l t 1i u

d 7

f e d

nn o

9 t n

$e ao C

1 s

t g mi f

ra rt t

sf eM on d a C

f e nc t

C t i nl u

ai s 7.h B Cq f

T n

eC e

el e

o1 t m

C3i a et RP f s d e

.B wd cr T/

ob ee n

ae MT u

rp CM Cs C s gI 9 e l v iS6l pl S

e rN9l e a E

i OA1 A RC I

n P1 7

3

>:?6M~ P 1i 3

g n

t 1. c t

' c

't k

t e e

a p a p te Hs MS N

ST N

EM F

N I

U 3

)U d

R n

E e

e a

D n

n C

N o

o N

H N

I 2

KR A

1 M

s D

s N

a A

l r

C K

AS r

T a

I l' M e

F s

l

..=

~

RM t

c EE n

u e

N n

MN m

o I

B I t e

i

}

t l

i RE E

a AM c

E. T t

i r

f f

N S o

i C

C e

E p

t

\\

HT p

r f

f t

u e

o o

SE S

C TV C

C S t g

l 1 T, n

a i

i f

M Ct p

r t

i e

1 T1 P

t RS a

EE M

D V. N I

AO CM NO ITA e

C c

I n

F a

I i

T l

R p

E m

C oC 1

IA e

7 f

I d

9 o

R o

1 E

C e

t TA n

C s

a N

o t

c i

B n

i t

e f

c a

m i

u d

e t

r n

c r

t e

as e

s d

lf C

n d

pf o

A ei C 7.h Rl C

C l1 t a3i t

f nB w r

o i

e C

gI9 v

iS6 l

S rN9 a

E OA1 C

T O

N 1

BALTIMORE GASAND I

ELECTRIC CHARLES CENTER. P.O. BOX 1475 BALTIMORE, MARYLAND 21203 NUCLEAR oPERATloNs DEPARTMENT j

CALVERT CLIFFS NUCLE AR POWE R PLANT Lul0Y. MARvLAND 20657 July 23,1987

)

U. S. Nuclear Regulatory Comnission Docket No. 50-317 Document Control Desk License No. DPR 53 Washington, D. C.

20555

Dear Sirs:

The,sttached revision to LER 87-09 is being forwarded to you for your information.

Should you have any questions regarding this report, we would be pleased to discuss chem with you.

Very truly yours, h!-

1 J. R. Lenons '&

& nager - Nuclear Operations Department JRL:

h l

cc: William T. Russell Director, Office of Management Information and Program Control Messrs:

J. A. Tiernan W. J. Lippold l

l l

E f

$P

, \\

l 1

(

B A LTIMORE GAS AND l

ELECTRIC l

CHARLES CENTER P. O. BOX 1475 BALTIMOAE. MARYLAND 21203 JosepN A.TIERNAN I

vics Picsiotut Nyct:4aCaracy August 27, 1987 I

I i

1 U. S. Nuclear Regulatory Commission j

Washington, DC 20555 s

ATTENTION:

Document Control Desk

'l

SUBJECT:

Calvert Cliffs Nuclear Power Plant i

1 Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318

{

Withdraw Request for Relief from ASME Section XI and Request for Exemption from 10 CFR 50.55a(g) Regarding Documentation Requirements i

for Mechanical Fasteners l

l

REFERENCES:

(a) Letter from Mr. J. A. Tiernan (BG&E), to NRC Document Control l

Desk, Request for Relief from Replacement Requirements in Section XI of the ASME Boiler and Pressure Vessel Code, Articles IWA-7210, l

IWC-7600, IWD-7600, and IWF-7600, dated May 11,1987 (b) Letter from Mr. J. A. Tiernan (BG&E), to NRC Document Control Desk, Request for Exemption from Inservice Inspection Requirements in 10 CFR 50.55a(g), dated May 11, 1987.

1 Gentlemen:

We hereby withdraw our request for relief (Reference a) and our request for exemption (Reference b). We regret any inconvenience our requests may have caused.

When we made our requests we estimated there may have been up to several hundred fasteners (nuts, bolts, and threaded rods) installed at Units I and 2 without proper documentation.

If our estimates were correct, then we would have desired to conduct a sampling and testing program to ensure those fasteners were adequate and could remain in place.

This formed the basis for our requests.

Subsequent to our requests, we completed the review of over 30.000 Maintenance Requests and found only 61 cases of fasteners installed without proper documentation. The sampling and testing program outlined in our requests could not apply to such a small number of cases. Instead, we replaced each fastener with one that had proper documen-tation. Licensee Event Report 87-09 Revision I provides more detailed information.

l

[

1

4 Document Control Desk August 27, 1987 Page 2 Should you have further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, q

1 JAT/ WPM /dtm cc:

D. A. Brune, Esquire J. E.

Silberg, Esquire R. A. Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC T. Foley/D. C. Trimble, NRC 4

g e

B ALTI M O RE' GAS AND ELECTRI CHARLES CENTER. P. O. BOX 1475 BALTIMOR E, MARYLAND 21203 W. JAMES LIPPOLD MANAGEm NUCLEAR ENomeggm6NO Sg8MCtB DgpAprtugNT September 30, 1987 U. S. Nuclear Regulatory Commission Washington, DC 20555 l

ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Commercial Ouality Meehanical Fastener Evaluation R EFERENCE:

(a) Letter from Mr. J. A. Tiernan (BG&E) to NRC Document Control Desk, dated May ll,1987, Use of Mechanical Parts Purchased Commercial Quality in ASME Section XI Class 1, 2 and 3 Systems (b) Teleconference between Mr.

A.

R.

Thornton (BG&E) and Mr. L. E. Tripp (NRC), on September 15, 1987, same subject Gentlemen:

In Reference (a) we stated our intentions to remove, test and evaluate specific mechanical fasteners in ASME Section XI Code Class Systems. Since that time, we have worked steadily and committed considerable resources to complete the testing and evaluation in a timely manner. This !ctter provides the results of our evaluation and the actions we have taken and plan to take as discussed in Reference (b).

]

Evaluation Results We have tested individually 1539 fastener components or pieces, where a piece is a stud, nut or bolt. Each has received a surface examination, a hardness test and a chemical analysis. Approximately 150 pieces we removed from the plant which we do not plan to test. Of these, 50 pieces were misplaced or mislabeled -when they were removed from the plant. Approximately 100 pieces cannot be decontaminated without the expenditure of significant additional resources and radiation exposure. We do not believe the information we would receive from testing those 100 pieces would justify the resources and exposures that would be required. We also feel the remaining 1539 fasteners are representative of those not tested.

' ~ ~

bY

=

se

,s

1 Document Conteo1 Desk e

September 30, 1987 Page 2 All 1539 pieces have been compared to the applicable chemistry and ' hardness material specifications to determine whether they were adequate to have performed their design function. Initially, 399 pieces yielded test results that were out of specification.

The chemical composition-for 174 cf the 399 pieces differed slightly from the material requirements, but the hardness was within specification. For these it was clear that the pieces were of the correct material and that the critical property - strength as was adequate. We therefore determined that determined from hardness measurements these were adequate to have perfotmed their design function.

A number of other pieces had the chemical compositions within. the specification range or only slightly out of range, but the hardness was just beyond the specified range.

Based upon engineering judgment, we determined that fasteners with hardness within 10%

of the specified strength were adequate. This meant reducing the minimum hardness for B7 studs from 26 HRC to 23 HRC and,2H nuts from 24 HRC to 22 HRC. We found 40 pieces were acceptable with this criteria. This engineering judgment was substantiated by the evaluation performed on the rems.ining 185 pieces.

The remairaing 185 pieces corne from 26 different locations within the plant. An evaluation specific to each location was performed to determine if the pieces had adequate strength. We analyzed each of these 185 pieces in a manner consistent with the class of each item and found that in all cases the actual material properties were adequate to ensure the structural integrity of the system. Data relating to. these results are listed in A:tachment 1.

Conclusion From the above, we conclude that although a significant number of pieces.did not meet their originally specified requirements, all would have functioned to ensure the structural integrity of their system. Because our testing and evaluations of the 1539 3

fasteners yielded adequate results, we are confident that the use of commercial quality -

)

fasteners in our Class 1, 2 and 3 systems never posed an unreviewed safety question.

Immediate Preventive Actions In early June 1987, BG&E initiated a comprehensive investigation to identify the root cause of the mechanical fastener traceability situation that had arisen at Calvert Cliffs. Several issues were identified for which corrective action was felt to be prudent, but the primary causes were found to be (1) inadequate awareness of the material quality and traceability requirements for mechanical fasteners used in the maintenance of ASME Class 1, 2 and 3 systems, and (2) the absence of formal easy-to-use documentation to assist our personnel in the identification of code boundaries during maintenance planning activities.

To correct these problems, maintenance personnel and quality control inspectors were given special training and instruction on the code requirements that apply. to fasteners in Class 1, 2 and 3 systems. In addition, formal guidance' documents were provided to maintenance personnel to facilitate the identification of code boundaries during routine maintenance planning activities.

These-actions ensure that present-day -

maintenance activities affecting Class 1, 2 or 3 systems are identified as such when

_0-

i

+

c

~

Document Control Desk September 30, 1987 Page 3 k

the maintenance order is written and that eproprbte replacement fastener materials are specified accordingly on the maintenance order form. To monitor the performance of l

individual maintenance work activities in.the field, quality control inspections are conducted in accordance with existing QA program requirements.

Sunclemental Actions The immediate actions described above provide reasonable assurance that all applicable l

material quality and traceability standards will be maintained in current and future j

maintenance activities at Calvert Cliffs.

Nonetheless, a number of supplemental j

actions are presently under consideration which would simplify and further improve i

procedures for controlling the procurement, storage, and use of mechanical fasteners.

]

The objective of these supplemental initiatives is to make the overall maintenance process more effective and thereby less prone to error. Examples of these initiatives include:

i o

Replacement of the commercial quality (72/78 series) fastener stock

{

inventory with Nuclear Class 1 fasteners-d I

o Implementation of a fastener standardization program for all fastener l

applications in the plant; f

o Development of a comprehensive computer database for use by engineers, maintenance planners, and purchasing personnel in identifying specific code requirements and allowable procurement methods for each piece of mechanical equipment ; and o

Upgrade of the material descriptions in the material management system (MMS) computer database to improve consistency in stock item descriptions and to provide more flexibility in the types of computer sorts that can be performed.

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

Very truly yours, 4/

.(

WJL/SRC/dlm Attachment cc:

D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil,NRC W. T. Russell, NRC T. Foley/D. C. Trimble, NRC

______..__.____m_m________

~

ATTACHMENT I MCQ FASTENER STRENGTH EVALUATION MO#

Piece #

Desc.

Spec.

Hardness Strength (KSi)

Comment I

590A 1

S B7 22 HRC 112 Chemistry OK 2

494A 6

N 2H Forging Lap 651A 6

N 2H 10.3 HRC 90 Chemistry OK 564A 1-7 S

B7 90 HRB 89 StainlessSteel 3 564A 14,15,16 N

2H 90 HRB 89 StainlessSteel 4

78]A 1-12 B

SAE 2.5 HRC 80 Low Carbon Steel Grade 5 781A 15-20 B

SAE 5.0 HRC 86 Low Carbon Steel Grade 5 781A 21-40 N

2H 5.4 HRC 86 Low Carbon Steel 667A 21-52 N

2H 88 HRB 85 Low Carbon Steel 598B 6

N 2H Forging lap 585A 9-24 N

2H 10 HRC 90 Low Carbon Steel 607A 3

B B7 88 HRB 85 Low Carbon Steel 607A 4

B B7 80 HRB 72 Low Carbon Steel 607A 5

N 2H 72.7 HRB 65 Low Carbon Steel 646B 3

N 2H 20 HRC 108 Chemistry OK 302A 21 N

2H 20 HRC 108 Chemistry OK 850A 9-24 N

2H 88 HRB 89 Low Carbon Steel (o22) 797A 2,4 S

B7 22 HRC 112 Chemistry OK 646A 3

S B7 75 HRB 68 Low Carbon Steel 850A 9,10,12 N

2H 10.3 HRB 90 Low Carbon Steel (c21) 14-23 670A 2

N 2H 15 HRC 94 Low Carbon Steel

~

ATTACHMENT 1 MCQ FASTENER STRENGTH EVALUATION t

MO#

Piece #

Dese.

Spec.

Hardness Strength (KSi)

Comment 761A 1,2,4,5 S

B7 90 HRB 89 Low Carbon Steel 761A 6

S B7 22 HRC 112 Chemistry OK I

j 761A 10-16,19-21 N

2H 92 HRB 93 Low Carbon Steel l

I 718A 1

B B7 16.5 HRC 95 Chemistry OK 588A 4

B B7 71.4 HRB 62 Low Carbon Steel 588A 8

N 2H 86 HRB 81 Low Carbon Steel i

771A 17 S

B7 21HRC 110 Chemistry OK 601A 5

S B7 21HRC 110 Carbon Slightly Low 850A 4

S B7 21HRC 110 Chemistry OK (o23) 850A 9-24 N

2H 90 HRB 89 Low Carbon Steel 237A 4

B SAE 19.5 HRC 106 Chemistry OK Grade 5 837A 10 N

2H 90 HRB 89 Low Carbon Steel i

768A 1

B A325 Forging Lap

}

696A 4,5,10-13 N

2H 70 HRB 62 Stainless Steel 757A 21 N

2H Forging Lap l

1 i

N = Nut S = Stud B = Bolt r

I Chemical composition was in specification.

2 Indications that were found by NDE.

3 Piece was composed of stainless steel.

4 Piece was composed of Low Carbon Steel..

_ _ _ _..... _ _ _