ML20206M325

Notice of Violation from Insp on 850909-13.Violations Noted: Failure to Possess Valid Test Data to Establish Qualification of Rockbestos Coaxial Cable & Identify Personnel or Time of Record Changes

ML20206M325
Person / Time
Site:	Calvert Cliffs
Issue date:	06/25/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206M313	List: ML20206M306 ML20206M325
References
50-317-85-22, 50-318-85-20, NUDOCS 8607010152
Download: ML20206M325 (3)

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APPENDIX A NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket No. 50-317/318 Calvert Cliffs Units 1 and 2 License No. DPR-53/69 As a result of the inspection conducted on September 9-13, 1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified:

A. Paragraph (f) of 10 CFR 50.49 requires that each item of electrical i equipment important to safety be qualified by one of several methods involving testing and/or analysis.

Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Contrary to the above, Baltimore Gas and Electric Company (BG&E) did not have valid test data or adequate analysis to establish qualification of the Rockbastos coaxial cable installed in the plants.

This it a Saverity Level IV violation. (Supplement 1).

B. Paragraph (f) of 10 CFR 50.49 requires that each item of electrical eqaipman- important to safety be qualified by one of several methods involving testing and/or analysis.

I Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Contrary to the above, ASCO solenoid valve, model HCX8320A187, plant I.D.

1SV3828, was installed in a harsh environment and a safety-related system i in Calvert Cliffs, Unit 1, and there was no test data, analysis, or other documentation to establish qualification of the valve.

This is a Severity Level IV violation (Supplement I).

C. Paragraph (f) of 10 CFR 50.49 requires that each item of electrical equipment importalt to safety be qualified by one of several methods involving testing and/or analysis.

OFFICIAL RECORO COPY DL BG&E - 0003.0.0 8607010152 860625 06/24/86 1

PDR ADOCK 05000317 Q PDR

Appendix A 2 Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class 1E Electrical Equipment in Operating Reactors" need not be requalified.

Section 8.0 of the Guidelines states that complete and auditable records must be available for qualification by any of the methods described in Section 5.0 to be considered valid. These records should describe the qualification method in sufficient detail to verify that all of the guidelines have been satisfied.

1 Contrary to the above, the qualification file for Hatfield 3-conductor cable did not contain sufficient documentation to establish qualification of the cable for its plant specific application. Documentation in the files did not adequately establish similarity between tested and installed cables and support a cable qualified life of 40 years at 111.9 degrees centigrade. Additionally, the file indicated that the cable was qualified for submergence application; however, documentation in the file did not support qualification for submergence.

This is a Severity Level IV violation (Supplement I).

D. Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and that the activities be accomplished in accordance with these ;nstructions, procedures, or drawings.

Paragraph 4.4 of Quality Assurance Procedure (QAP) No. 7 requires that changes to records identify who makes or approves the change, when the change was made, and to leave the original information legible.

Paragraph 7.8 of QAP 15 requires that field change requests (FCRs) for "SR-QUAL (environmentally qualified) items" be reviewed by the engineer who has been assigned responsibility for CQ by the manager of the Electrical Engineering Department.

Contrary to the above, BG&E failed to follow their procedures in the instances described below:

1. During review of the qualification files, the inspectors identified a number of instances where changes were made to the files by crossouts, whiteout, and/or other means without any indication as to who made the changes and/or when the changes were made. Files where the above was specifically noted were PT0006, M0V001, M0V011, SEAL 03, SEAL 05, SV0026, and ZS0021.

2. There was no documented evidence that the responsible engineer for EQ had reviewed the FCR for the replacement of control valve ICV 3828 in April 1985. Additionally, the responsible engineer stated that he had not reviewed the FCR.

OFFICIAL RECORD COPY OL BG&E - 0004.0.0 06/24/86

Appendix A 3 This is a Severity Level IV violation (Supplement I). l Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas and Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

OFFICIAL RECORD COPY DL BG&E - 0005.0.0 06/24/86