ML20246H121
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| ML20246H121 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/05/1989 |
| From: | Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20246H094 | List: |
| References | |
| 50-317-89-15, 50-318-89-16, GL-82-12, NUDOCS 8907170020 | |
| Download: ML20246H121 (16) | |
See also: IR 05000317/1989015
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4 U.S. NUCLEAR REGULATORY COMMISSION
REGION I-
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50-317 DPR-53
: Docket Nos.: 50-318 - License Nos.: DRP-69
50-317/89-15'
Report'Nos.: 50-318/89-16
Licensee: Baltimore Gas and Electric
Post' Office Box -1475
Baltimore, Marylanci: 21203
Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2
. Inspection at: ' Lusby, Maryland -
Inspection Conducted: May 22-26 and June.9-16, 1989
~ Inspectors: D. Limroth, Project Engineer, RI
G. Nr.puda, Senior Reactor Engineer, RI
, W. Oliveira, Reactor Engineer, RI
J. Cumr u d, DRIS, NRR
J. Ball, DRI , NRR'
P Wil on, sident Inspector, Beaver Valley Powe.' Station
Approved by: /0! - -
M
Lowell' E. TrijpP Chief .
7/[[89
Date
Reactor Projects Section No. 1A .
' Summary: May 22-26 and June 9-16, 1989: Inspection Report Nos. 50-317/89-15
and 50-318/89-16
Areas Inspected: Cnntrol of measuring and. test equipment; Review and control of .
vendor . technical manuals; Control of welding process activities; Control of.
quality control (QC) . inspection activities; Configuration control related to
control of maintenance activities; and Control of overtir..e (IP 92701).
Findings: ~ The inspection confirmed instances of failure to adequately implement
administrative controls related to the control of measuring and test equipment,
. vendor technical manual s, welding process activities, and quality control
inspection activities which are collectively indicative of an apparent failure
, to' implement an. effect 've quality assurance program. Concern regarding uncon-
y , trolled modifications to systems or components as a result of maintenance
activities was not substantiated. Isolated instances of apparent failure 'to ,
approve overtime in excess of Generic Letter 82-12 requirements were noted. i
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8907170020 890710
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PDR ADOCK 05000317
a PDC
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DETAILS
During this inspection, interviews and discussions were conducted with various
licensee personnel including operators, maintenance and surveillance techni-
cians, technical and administrative support personnel, and the licensee's man-
agement staff.
1.0 Overview
During the period February 27 through March 31, 1989, a Special Team
Inspection was conducted at the facility under the direction of the Chief,
Special Inspection Branth, Office of Nuclear Reactor Regulation. (See
Report Nos. 50-317/89-200; 50-318/89-200). During the conduct of that
inspection, fourteen unresolved items and numerous other points of concern
were identified. The purpose of this inspection was to follow up on
selected items identified during that inspection.
2.0 Control of Measuring and Test Equipment (M&TE] (Unresolved Item
50-317/89-200-1)
2.1 Background
The Special Team Inspection determined that the licensee was using
some test pressure gauges for safety related testing that were not in
the M&TE program. In particular, the p. essure gauges in question
were not being verified in calibration following safety related use
as were test pressure gauges within the licensee's M&TE program, were
not subject to procedural controls, were not subject to recall, and
means to verify test data from such gauges could not be relied upon.
2.2 Findings l
The inspector reviewed the circumstances, effects and the licensee's
corrective actions concerning this unresolved item. The inspector
also examined the licensee's M&TE program to determine if it was
being properly implemented. The examination included interviews,
review of the licensee's Quality Assurance M&TE Audit findings and
subsequent corrective action, training records, and review of ue
calibrations of randomly selected M&TE.
10 CFR 50, Appendix B, Criterion XII requires licensees to establish
measures to assure that tools, gauges, instruments and other measur-
ing and test devices used in activities affecting quality are pro- l
perly controlled, calibrated and adjusted at specified periods to
maintain accuracy within necessary limits. The licensee controlled
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measuring and test equipment in accordance with Calvert Cliffs
Instruction (CCI) 1200 " Calibration Program for Measuring and Test i
Equipment" and Quality Assurance Procedure (QAP) 17, " Control and '
Calibration of Measuring and Test Equipment." This instruction and
procedure required the supervisor of each group responsible for M&TE
to ensure that approved calibration procedures for test equipment
were available and used.
,
At Calvert Cliffs, the responsibility for M&TE was delegated to the
supervisor of each group (i.e. , Electrical and Control, Mechanical
Maintenance, etc.). The control of M&TE varied within each group.
Pressure gauges and electronic test equipment were calibrated by the
Equipment Test shop. The control of Qis M&TE was divided oetween
the Electrical and Controls Test equipment cage, Operations, and Per- ,
formance Engineeriq. Torque wrenches, micrometers, etc., were cali-
brated and controlied by the Mechanical Maintenance unit; however,
some of the measuring equipment was issued to certain craft for con-
tinued use between calibrations. Craftsmen maintained useage logs.
There was also an Electric Test group which calibrated and issued
M&TE for switchyard maintenance.
The inspector randomly selected five test instruments from the Elec-
trical and Controls test equipment cage to verify that the licensee's
M&TE program was being properly implemented. Proper storage was ver-
ified. Calibration procedur were reviewed against the vendor tech-
nical manuals and were founc o be adequate.
Review of the calibration reccrds for one of the test instruments
indicated that requirements of the M&TE program were not being met
consistently. Specifically, the inspector determined that a 8600A
series Fluke Multimeter (Serial No. 10273) used for safety related
activities was found to be out of tolerance in the kilohm range on
January 11, 1989, and could not be successfully calibrated without
repairs. The instrument was repaired and calibrated on April 1,1989.
The shop sucervisor reviewed the calibration record sheet two days
later. CAP 17 required that a Nonconforming Report (NCR) be promptly
prepared when M&TE is found to be out of tolerance and used for
safety related applications. Neither the technician nor his super-
visor prepared a NCR as required even though the instrument's usage
card indicated it had been used for a safety-related activity (STP
527A-2 Reactor Vessel Level Indication System). On May 1, 1989, the
same instrument was fcund to be out of tolerance on the same range.
Again, an NCR was not prepared as required although it had been used
for a modification to the nuclear instrumentation system (Field
Change Request 82-150). When this procedural noncompliance was iden-
tified to the licensee by the inspector, NCRs were immediately pre-
pred. The licensee determined that, in both instances, the instru-
ment was used as a go - no go device (i.e., checking state of relays)
and concluded that there was no nuclear safety impact. Further
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reviewiof: the instrument's calibration records indicated that on
'three , previous occasions- (January 88, October 88, . and November 88),
, the kilohm range was found out of allowed : tolerance. American
' National: Standards Institute (ANSI) N18.7-19761 to which the licensee
is; committed requires. that any calibration, testing . or measuring
device that . is consistently- found to be out of calibration be re-
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paired or replaced. The licensee's M&TE program' did not have pro-
visions for trending M&TE performance or requirements to remove unre-
liable M&TE from the program. The licensee subsequently removed the
above instrument from the M&TE program. The licensee acknowledged
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the weakness due to. a lack of trending, ' but made no. subsequent
commitments.
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QAP 17 required that uncalibrated M&TE be physically segregated from
calibr_ated. M&TE to prevent inadvertent use. QAP 17 also required
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that storage conditions protect cleanliness Land meet. suitable
environmental requirements. CCI-120D required that the use of cali-
brated M&TE be controlled. Contrary to the above requirements, the
inspector found that M&TE assigned to the Performance Engineering
section was being stored in an uncontrolled area, was not properly
segregated and was stored in an environmentally unsuitable area. The
Performance Engineering's M&TE was stored in a large equipment cage
on the' 12-foot level in the water treatment building. .There was no
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control ~of the M&TE in that electricians and instrument technicians
had access to the normally unreanned. cage. The inspector found an un-
calibrated ultrasonic ' flowmeter stored along with calibrated M&TE.
The area used to store the calibrated ~ instruments was dirty and very.
humid. The licensee related to the inspector that the Performance
Engineering's M&TE storage area was ' temporary and' that a permanent
air conditioned and clean storage area would soon be made available.
Another weakness noted by the inspector was that the Equipment' Test
shop supervisor along with many other duties must typically review an
average of more than 30 calibration data sheets per day. It appeared
that the staff in the Equipment Test shop was insufficient to assare
proper reviews were conducted as indicated by the failure to prepare
NCRs. This weakness had been previously recognized by the Group
Supervisor of Electrical and Controls who was reportedly taking
action to increase staffing,
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The inspector also examined the M&TE program controlled by the Mech- l
anical Maintenance unit. The program appeared to be adequate with -
, the exception of timely reviews of (alibration Data Sheets by the
unit supervisor. Calibration data sheets were being reviewed two to
six weeks af ter the calibration was performed. The M&TE program did
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not specify any time requirements for these reviews. ;
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The licensee reviewed the practice of using some test pressure gauges
for i STP's that were not included in ' their M&TE program and teok.
several~ steps to prevent further occurrence. It_was. determined that,
for several years, instrument maintenance technicians were using a
group'of test pressure gauges which did not receive a post-use cali--
bration- check as did similar test ' pressure gauges. issued .via. the
licensee's M&TE program. Immediately prior to issuing a test press-
ure gauge, instrument. maintenance .. technicians would perform a bench
calibration- check using a ten times ( more accurate instrument as' the
standard. 'After use, it would be placed on a shelf until it was.used
again ~ nt which time. another calibration check was performed. .The
licensee .took .several actions to determine safety significance of-
this practice. To ensure the adequacy of the calibrations performed
on the ,above gauges, the licensee was able to trace back each cali-
bration 'to the appropriate National Bureau of Standards calibration
standard. A calibration- check :was . performed on al_1 the gauges in
question and all were found ~ to be properly calibrated. The licensee
also determined which STP's were performed with the. gauges so that if
any of the gauges were. found to be out of tolerance, a determination
of operability of plant equipment could have been made. All . gauges
in question have been removed from use and all test pressure gauges
utilized were incorporated into the licensee's M&TE program.
2.3 Conclusions
The above' examples are indicative of a marginally acceptable M&TE
program. While no direct impact on -nuclear safety wa's determined,
the failure to control the' test pressure gauges within the M&TE pro-
gram; the failure to prepare timely NCRs;'and the improper contrel,
segregation and ' storage of the Performance Engineering's M&TE are
- specific . examples of failure to properly implement the M&TE program
as required _ by CCI 1200 and QAP 17 This is an apparent violation'of
quality assurance program requirements and licensee procedures and
commitments.
3.0 Review and Control of Vendor Technical Manuals (Unresolved Item
50-317/89-200-07)
3.1 Background
The special team inspection identified three concerns related to the
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control of vendor technical manuals. Specifically:
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, Five instances of failure to comply with Calvert Cliffs Instruc- L tion (CCI) 122E, paragraph V.B.2, which required that one who
transmits a technical manual to the technical librarian review
I' the manual and provide as much information as possible using the
technical manual turnover cover sheet.
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Fifty-one instances of failure to comply with CCI 122E, para-
graphs V.B.3f and V.B.4 which require that manuals be forwarded
to the General Supervisor - Plant and Project Engineering (GS- 1
PPE) for technical review and that the . GS-PPE return approved
manuals to the technical librarian within fifteen working days
of receipt.
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The Engineering Department had not been provided detailed guid-
ance regarding the required technical review and engineers.
responsible for the review did not appear to be sure of review
requirements.
3.2 Findings
The inspector reviewed licensee actions taken to rcsolve the above
concerns. The licensee had identified and documented approximately
300 technical manuals which had not been reviewed. An additional 26
manuals were in the review process, the oldest of which had been in
that status since January 1988.
The, inspector noted that, of the 26 unapproved manuals which were
undergoing technical review, 45 copies had been distributed to the
field. Follow-up inspection of this item with holders of the copies
of unreviewed/ unapproved manuals did not reveal any instance of the
manuals having been used in conjunction with operating activities,
i.e., functions associated with normal operation and maintenance of
the plant and technical services routinely assigned to the onsite
operating organization. The licensee representative responsible for
the project of configuration management (including drawing and tech-
nical manual control) committed to immediate recall of all unreviewed
and/or unapproved technical manuals and to the cessation of issuing
technical manuals prior to having been reviewed and approved for
issue and use. The inspector noted through review of administrative
controls and interviews with licensee staff that the primary reason
for document control, i.e., .ssuring that only properly reviewed and
approved documents are ut sized in activities important to safety,
was not fully conveyed in procedures nor understood by many members
of the licensee staff.
Current licensee practice relies solely on all individuals who may
receive technical manuals, revisions to technical manuals, or other
related technical information, forwarding such documents to the Tech-
nical Librarian (CCI-122E, III.D.3). The inspector noted that per-
sons had " personal copies" of technical information received in ven-
dor training courses and one instance in which an individual was
reportedly on the vendor's (Limitorque) distribution list for main-
tenance-oriented technical reports. This individual had forwarded
copies of these documents to the Technical Library. Again no
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instances of use of such technica1'information was discovered during
the course of the inspection. This practice and the potential ~ for
uncontrolled usage, and methods to strengthen control of unapproved
documentation, including specifying delivery instructions in procure-
ment documents, was discussed with ' licensee supervisory staff mem-
bers. The inspector reviewed a copy of .Section Guideline PPE-1
" Technical-Information Review Checklist", dated June 9,1989, issued
by the GS-PPE to be used when performing' reviews of vendor. technical
manuals or revisions. This document provided a checklist of informa-
tion to be verified including technical data; equipment description; ,
installation, operating,- and maintenance instructions; testing and .i
prevention maintenance; spare parts; and drawings. It was also noted 'l
that this. checklist levied additional requirements.on the Technical
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library above those currently provided in CCI-122E. (The inspector
reviewed a proposed revision to CCI-122 which would, among other
changes,. include this checklist as a revision to the existing Attach-
ment 2,. Technical Manual Review Cover Sheet. It was also- noted dur-
ing the ' review that. a . Note on page 5 stated that if the GS-PPE -
rejects the manual, all copies will be recalled by the~ Technical
Librarian and destroyed, which would infer that the policy of dis-
tributing unreviewed techn4 cal manuals will be condoned.)
A review of; distribution lists indicated that approximately 3000
copies of technical manuals were in the controlled distribution
system.
3.3 Conclusion:
Title 10 CFR 50, Appendix B, Criterion V requires that activities
affecting quality shall be prescribed by documented instructions, .
procedures,...and shall be accomplished in accordance with these
instructions, procedures or drawings. Title 10 CFR 50 Appendix B,
Criterion VI further requires that measures shall assure that docu-
ments, including changes, are reviewed for adequacy and approved for
release by authorized personnel...The practice of distributing un-
reviewed technical manuals to .the onsite operating organization is an
apparent violation of these Criteria.
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4.0 Control of Welding Process Activities (Unresolved Item 50-317/89-200-08)
4.1 Background
During the NRC Special Team Inspection, inspector observations in the
area of weld filler material control gave rise to concern that licen-
see managcment was not providing adequate guidance to workers in this
area. Specifically, requirements for weld filler material control
were being provided through a recently issued shop / lab memorandum No.
M-64 rather than a Plant Operational Safety Review Committee (POSRC)
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approved procedure. In addition, the shop / lab memorandum referenced
welding program procedures, WPP 6.006, Weld Authorization and! Docu-
mentation, and WPP 6.009, Control of -Welding Materials, neither of
which had. received POSRC. review or approval. Moreover, WPP 6.006 and
WPP 6.009 were not available for reference at" stations that issued.
weld filler material. A sketch meant as an aid for the attendant in
locating. weld rod types being heated in a particular weld rod holding
oven was also found at one weld rod issue station but had become out-
dated and no longer accurately- depicted the actual type of weld rod
being-heated. The Special Team inspector also observed the tempera-
ture reading on one rod holding oven to be slightly outside'the tem-
perature band specified by WPP 6.009.
4.2 Findings
During this inspection, the inspector followed up on these concerns
and reviewed corrective actions taken by the licensee since the
Special Team Inspection. The inspector reviewed additional records
associated with the control and documentation of weld filler mate-
rials and weld rod holding oven temperature calibrations. Additional-
observations of weld filler material control activities were also
made.in the field. From these reviews and observations, the inspec-
tor concluded that there did not appear to be pervasive problems with
the control .'of weld filler materials at the site. .The inspector
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noted that the licensee had taken immediate corrective action subse-
quent to the Special Team Inspection to assure that at each weld rod
issue station, copies of WPP 6.006 and WPP 6.009 and shop / lab memor-
andum No. M-64 were available to the attendant for reference. A pro-
posed Calvert Cliffs instruction,. CCI-226, " Filler Material Control",
l which would replace the currently in-use shop / lab memorandum was
being reviewed. The inspector's review of the draft CCI-226 .indi-
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cated that the new procedure would more appropriately delineate the
requirements for the control and issuance of weld filler materials.
The new procedure would also provide for an increased frequency of
conducting oven temperature calibrations and checks of oven tempera-
ture by the rod attendants prior to issuance of any weld rod thereby
reducing the chances of deviations in oven temperatures going unde-
tected. The inspector also inspected a number of different weld rod
holding ovens; in all cases, the rod inside each oven was properly
identified by type, purchase order number, and heat or lot number.
The licensee had discarded the attendant aids as being unnecessary
and potentially confusing.
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4.3 Conclusions
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Immediate corrective actions taken to date by the licensee to address
the concerns identified by the special team inspection in this area
appeared appropriate. However, the inspector did determine that the
licensee had failed to maintain appropriately approved procedures for
control of weld fi'w material subsequent to cancellation of
CCI-222, "Calvert Cliffs Control of Welding Activities" on
February 14, 1989. This is considered an example of apparent failure
to maintain adequately reviewed and approved procedures for the con-
duct of safety related activities related to special processes.
5.0 Control of Quality Control (QC) Inspection Activities (Unresolved Item l
50-317/89-200-09)
5.1 Background
The Special Team Inspection identified a significant weakness in that
the licensee did not have approved administrative procedures or writ-
ten instructions for controlling, implementing, and documenting QC
inspections. Inspections of activities affecting quality were repor-
tedly routinely waived due to inspector unavailability, apparently
precipitated by lack of effective planning and scheduling. Further,
it appeared that the licensee relied on the QC inspector's judgement
to ensure that required inspections were performed, that appropriate ,
acceptance criteria were met and that inspections were adequately (
documented.
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5.2 Findings ;
The inspector reviewed the activities of the Quality Control Unit
(QC), a part of the Quality Assurance organization, and associated
administrative controls and implementing procedures. QC inspectors
were accompanied, interviewed and observed during their monitoring of
maintenance work being performed in accordance with selected Mainten-
ante Orders (MOs). Selected M0 packages were reviewed for recently
completed work and tasks scheduled to be worked on during the course
of this inspection.
The QC inspector assigned to monitor work performed under MO 209-025-
756A, Circuit Breaker Pole Shaft Replacement, and the maintenance
electricians doing the job were observed at various stages of the
task. The MO had been reviewed by QC when it was initially issued;
it contained instructions to notify QC prior to the start of any
work. The governing procedures (CCI-201G and FTE 53) had been
obtained and previously reviewed by the QC inspector. The scope of
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work was essentially 'a - refurbishment of one of a number of like
breakers and. FTE 53 was' a comprehensive step by step instruction to
accomplish. the job. This procedure included post maintenance test
requirements and provided for entry of as-found/as-left data and
technician signatures, but no specific QC hold / witness points. The
QC inspector and QA/QC supervision stated that maintenance work
selected for overview' was, for the most part, monitored in its
entirety,
y Portions of the repair work being done on Charging Pump 13 breaker p under M0 209-50-559A were observed including QC monitoring of this H task. The M0 instructions included only' eight steps that were (1) a
- tagout requirement, (2) four general work statements, and (3) three
l . references. One of the references was Procedure FTE 53- and the two
maintenance electricians were using those steps of that comprehensive
procedure (see above) that they determined were necessary for the
task. It was noted that the workers had- appropriate electrical dia-
grams at the ~ job site in addition to the other referenced documents
( e . g' . , vendor technical manual- 12-410-120 02-1). The QC overview
l again was of the e'ntire task.
MO 209-137-252G work package for the disconnection, repair and recon-
. nection of eight Unit 1 pressurizer heaters was reviewed and dis-
cussed with QA/QC and maintenance personnel. The M0 steps contained
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general statements such as megger all- heaters and check' resir.tance.
.with a digital megger meter (DMM) or volt-ohm meter (V0M). One ste.p
gave criteria to reconnect cable leads to L shaped lugs and a maximum
torque value of 65 inch pounds. There were no other acceptance cri-
teria or QC hold / witness points specified or referenced in the M0.
Licensee management stated that the QC Critical Characteristics
Inspection Program (see below) was being implemented for' this task
and provided a partially completed inspection procedure. This pro-
cedure was completed prior to the conclusion of the inspection and
contained appropriate acceptance criteria and parameters for impor-
tant work steps. However, it was noted that the same task for Unit 2
will have at least six detailed procedures provided in the M0 pack-
age. This difference in philosophy between essentially identical
work was discussed with licensee management. Prior to the conclusion
of this inspection, licensee management decided to provide the same '
level and type of instructions / procedures for the Unit I work.
Work package MD 209-142-369G under which two solenoid valves were
replaced on a Service Water heat exchanger was reviewed. The M0 sheet
was a general statement of work scope; however, the package included
specific special step-by-step instructions. Although there were no
QC hold / witness points on the instruction, the QC inspector had writ-
ten a short paragraph on what had been witnessed.
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MO 209-31-001A package, a pressurizer level modification, was re- I
viewed. The package contained detailed work and functional test pro-
cedures that included specific QC hold / witness points. In addition
! to properly executed entries and signoffs, the package contained l cable pull slips, daily action sheet writeups, etc. The QC inspector
had signed all the hold / witness points.
l MD 209-114-542A package for removal of old and installation of new
- straps on an instrument air header was reviewed. The package con-
l tained appropriate prints and a welding procedure. The procedure w&s
annotated as required, the worker had written a short description of
work done and an NDE data sheet was also in the package.
MO 209-058-345A package for a snubber changeout was reviewed. The
package contained a traveller in addition to a specific work proced-
ure. The lead worker and the supervisor had entered their signatures
where required. Although no QC hold / witness points had been entered
in the procedure or traveller, the QC inspector had initialed the
worker written short description of work done.
A review of QA/QC administrative procedures found no descriptions of
the . methodology or process followed by the QC Unit in implementation
of their inspection and overview responsibilities. A similar review
of 16 plant implementing procedures (Calvert Cliffs Instructions)
identified that they did include statements of QC notifications,
requirements, actions, inspections, etc. The licensee was aware of
the lack of administrative type procedures as a result of the Special
Team Inspection and a series of suih procedures were being developed.
Two new procedu:es were in draft form and an existing procedure was
being modified / revised in an inithl effort to correct this condi-
tion. A number of CCIP inspection procedures that had been completed
were in a validation process.
Discussions with QA/QC management determined that the licensee had
identified several areas where steps need to be taken to correct /
enhance the QA program and its implementation and the organization is
in a transitional phase. During this inspection a realignment of the
QC Unit was effected and experienced craf t people were appointed to
newly established supervisory positions. Licensee management stated
that the effectiveness of the new QC structure will be closely mon-
itored and any needed changes would be made in addition to those
already planned to enhance the remainder of the organization.
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Licensee management outlined their plan for enhancing QC overview of
maintenance work that has been designated as the Critical' Character-
istics Inspection Program (CCIP). This approach is based on verifi-
cation.of attributes / characteristics that are most important to qual-
ity and the CCIP is currently under development. An'interdiscipli-
nary team (engineering, operations, maintenance, etc.) has been
established to develop QC inspection procedures using the new
approach. The inspector attended a meeting of this team during the
course of this inspection.
The licensee's initiative to develop the methodology for QC overview
of ongoing maintenance and receipt inspection activities that would
enhance the use of QC resources is commendable. However, the neces-
sity of this undertaking by the QA/QC organization itself is indica-
tive of a lack of engineering and technical support in the past.
5.3 Conclusions
Ongoing work was being independently monitored and subjected to over-
view by QC personnel. Audits and surveillance (i.e., monitoring of
ongoing activities) were being conducted. Implementing plant proced-
ures contained statements of QC overview and involvement. However,
most of the controls, methodology, and process by which QC was to
conduct its routine activities were not described in administrative
type procedures. This is an example of an apparent failure to have
such procedures as required by 10 CFR 50, Appendix B, Criterion V.
The lack of adequate work details that was identified in the M0
packages discussed above and in section 6.0 are additional examples
of apparent violations of the requirements of 10 CFR 50, Appendix B,
Criterion V.
6.0 Configuration Control Related to Control of Maintenance Activities
(Unresolved Item 50-317/89-200-14)
6.1 Background .
!
The Special Team Inspection raised concern regarding the possibility
of loads having been added to busses and piping systems or components
having been modified without engineering evaluation or approval, and
without the alterations having been reflected in drawings or manuals.
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. 6.2 Findings i
The inspector specifically reviewed selected maintenance activities
to determine whether modifications might have been done to equipment
during maintenance work without appropriate engineering involvement
including technical evaluations in accordance with 10 CFR 50.59.
The corporate computerized data base of maintenance work completed
since 1985 was scanned and approximately 60 Maintenance Orders (M0s) 1
were selected for further review based on the summary statements of '
work done. It was determined that 30 M0 packages would be reviewed
in depth because of the type of tasks involved, e.g., troubleshoot-
ing, use of jumpers, repairs and time needed to complete the work.
The M0 packages represented twelve systems, e.g., Reactor Protection
System, Service Water, Containment Isolation and Main Feedwater.
Further followup was conducted on 17 M0 packages with respect to
replacement of equipment, associated procurement, QA/QC requests for
corrective actions and other such significant work evolutions. Ad-
ditionally, the electrical panels associated with the Emergency
Diesel Generators (Control Room and local) were compared against
engineering drawings. Interviews were conducted with two individuals
who had commented to STI inspectors that they were aware of una' th-
orized plant modifications.
The work associated with the reviewed M0s ranged from no work being
done to modification or replacement. of equipment. Troubleshooting
MOs included a trip indicator light that was found to be operational
-( there fore , no work was done), cleaning steam generator pressure
indicator slide links, reso1dering a link to a terminal in the
reactor protection system (RPS) and replacement of a 5-vDC power sup-
ply ' for the peak detector in the RPS. Repair MOs included work on
damaged insulation, butt splicing cable, cleaning resistors and
replacement of transmitters. When work associated with either a
troubleshooting or repair MO indicated equipment replacement was '
necessary, a new MO was generated and processed in accordance with
established requirements. Examples of replaced equipment were charg-
ing pump valves and switches in the N2 supply system. M0s were also l
issued to replace component parts such as emergency trip springs in
l feedwater throttle valves. l One example of a repair MO that resulted in what might be described
as a modification was the replacement of controllers on Feed Regula-
tor Valves FIC-1111 and 1121. During installation of the spare con-
trollers purchased from the original vendor, it was discovered they
had arrived missing a wire necessary for the DC power supply. This
was brought to the attention of Engineering who issued oral permiss-
ion to install a permanent jumper. Followup indicated that the draw-
ings in existence at the time of this work had been subsequently
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consolidated and the current applicable drawing shows the permanent
jumper. Although there was documentation of engineering involvement
(e.g., notification of jumper installation and drawing rew . J.3), a
-documented safety evaluation could not be located. The: lack e 'ocu-
menting safety evaluations for modifications to equipment important j
to ' safety was .the subject of a previously scheduled May 26, 1989, NRC l
Enforcement Conference with the licensee. I
While' reviewing the sampled M0s, it was noted' that a Provisional !
Modification process had been in use for a number of. years. This-
method of performing modifications was reviewed and discussed with
cognizant technical personnel. The Provisional Modification process
was used whenever- a need arose for a minor modification to be com- ,
pleted in an urgent fashion. The details of the process had changed .
a number of times during the past few years, so particular attention '
was directed at the current methodology and controlling procedures.
The ' process appeared not to have consf stent engineering involvement
if the equipment was not safety related. The most recent practice - ;
appeared to be that when a need for an urgent modification was iden-
tified: (1) QC. initiated a Nonconformance Report (NCR); (2) a Field
Change Request (FCR) was initiated; (3) work could commence under
oral direction from engineering; (4) evaluations, reviews, require-
ments, approvals, etc. flowed through the normal modification pro-
cess; (5) a documentation package was routed through the modification
review process; (6) the as installed modification was verified to be ;
in accordance with the modification package; (7) the modification .)
package was reviewed by QC, additional corrective actions- taken if l
necessary and the NCR closed when everything is determined to be ;
satisfactory; and, (8) the equipment was then returned to operations. 'i
Discussions with the two individuals previously interviewed during i
the STI identified that the unauthorized modifications had been to a
house services bus and the plant sewage system, both of which are not
safety-related or important to safety. The power supply to welding
'
machine receptacles had been connected to the non safety related bus,
located in what was then the chlorine treatment building. Subse- .
quently, that building was converted to a welding shop and authorized ]
modifications were done to electrical power panels to make them suit- a
able for their intended use. The welding shop was visited and it was ,
apparent that the panels were newer than the building and remaining !
contents. Visual examination indicated that the installation was l
exclusively for welding shop use.
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E
6.3 Conclusions
~
Based on the inspector's onsite followup, . interviews with workers,
-
and. review of maintenance and modification records, no immediate
- safety concern was identified. Unresolved: item _50-317/89-200-14 is
considered ' closed. The ' modification area will continue to be 're-
viewed in conjunction with NRC_. followup of the licensee's Performance
Improvement Program (PIP) initiatives.
7.0 Control of Overtime
7.1 Background
During the Special Team Inspection conducted from February 27 through
March 31, 1989, the team identified 20 instances in which licensee-
employees had exceeded the overtime guidelines delineated in Calvert
Cliffs instruction CCI-140E, " Shift' Staffing and Overtime Controls."
7.2'. Findings
To verify that licensee employees ware not working excessive overtime
and that- the administrative requirements delineated in CCI-140E were
being complied with, the NRC inspector reviewed randomly selected .
timekeeping records .for licensee employees in the' areas of opera-
tions, maintenance, and quality control . The records reviewed ~were
from April through May 1989. During this review, the NRC inspector-
identified seven_ instances in which licensee employees worked more
4
than 72 hours in a 7-day period without ' Attachment (1) to CCI-140E
being submitted by appropriate licensee personnel. The number of
hours worked in these 7 instances ranged from 76 to 84.5 hours. Sec-
tion XIV. A.3 of CCI-140E required that deviations from the above
guidelines'be authorized in writing by the Manager-CCNPP or the indi-
viduals General Supervisor by use of Attachment (1) to CCI-140E.
7.3 Conclusions
I
Based on the NRC inspector's review of the timekeeping records, it
!
'did not appear that the use of overtime was excessive since most
records reviewed indicated that licensee employees were getting at
least one day off in any seven day period. However, failure to com-
ply with the review and documentation requirements of CCI-140E is
considered an apparent violation.
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8.0 Overall Conclusions
The above findings indicate apparent violations in programs controlling
measurement and test equipment (10 CFR 50, Appendix B, Criterion XII);
document control (Criterion VI): welding, i.e. , special process (Criterion
IX); procedural control, i .e. , the failure to properly prescribe activ-
ities affecting quality in appropriate written form or to accomplish such
activities in accordance' with written directions (Criterion V); and qual-
ity control activities (Criterion II). Individually, no findings of im-
rrediate safety concern were identified; however, taken collectively, it
was concluded that aspects of the quality assurance program were either
weak, absent, or not followed or enforced. This weakness which pervades a-
number of quality assurance program criteria may be better characterized
and combined as a failure to effectively implement a quality assurance
program. In addition, there was an apparent violation of internal over-
time administrative requirements.
9.0 Exit Meeting
At the conclusion of this inspection, the inspection team presented the
above findings to licensee management personnel. At no time during this
inspection was draft material provided to the licensee.
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