IR 05000317/1984016

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/84-16 & 50-318/84-16.NRC Will Continue to Monitor Adequacy of Completion of post-mod Action Followup Items

ML20128G010
Person / Time
Site:	Calvert Cliffs
Issue date:	06/20/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8507090008
Download: ML20128G010 (2)

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JUN 2 01985 Docket Nos. 50-317 50-318 Baltimore Gas And Electric Company ATTN: Mr. A. E. Lundvall, J Vice President, Supply Charles Center P.O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject: Combined Report Nos. 50-317/84-16 & 50-318/84-16 This refers to your letter dated August 23, 1984, in response to our letter dated July 24, 198 Ve have evaluated your response to Notice of Violation transmitted as Appendix A to our combined Inspection Report 50-317/84-16 and 50-318/84-16 and are withdraw-irg the Notice of Violation. We believe that the inspection did identify certain weaknesses in post modification action followup, while specifically not in viola-tion of NRC regulations, which did require improvement. Based on discussions with our Resident Inspector, we note that you have been taking action to make suc'1 improvements. Our observation of this improvement has been documented in the Systematic Assessment of Licensee Performance (SALP) of Calvert Cliffs, Report Nos. 50-317/84-29 and 50-318/84-29, dated January 18, 1985 which, in part, states, "...significant progress was made in closing out Facility Change Request (FCR's) for work which was complete but action items still remained open (procedure changes, non-critical drawings, training, etc.)...". We will continue to monitor the adequacy of your completion of post modification action follov up items during future NRC inspection Your cooperation with us is appreciate

Sincerely, Cr'Scl

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~'N pr Stewart D. Ebneter, Director Division of Reactor Safety 8507090008 850620 PDR ADOCK 05000317 G PD OFFICIAL RECORD COPY RL CC 1 & 2 84-16 - 0001. /18/85 HN

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I Baltimore Gas And Electric C +

CC: x R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent M. E. Roberson, General _ Supervisor, Operations QA Thomas Magette, Administrator, Nuclear Evaluations R. C. L.' Olson, Principal Engineer J. A. Tiernan, Manager, Nuclear. Power R. E.-Denton, General Supervisor, Training and Technical Services ,

.Public Document Room (PDR) ,'

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2) .j s bcc':

Region I Docket Room (w/ concurrences)

T. Elsasser, Chief, PB #3, Section #3C, DRP

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DRS:RI dk $I DRS:RI Blumbgp/mjh Bettenhausen Ebneter 5/2l/85 5/4)/85 klh/85 0FFICIAL RECORD COPY RL CC 1 & 2 84-16 - 0002. /18/85

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BALTIMORE j-GAS AND ELECTRIC

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CHARLES CENTER.P.O. BOX 1475 BALTIMORE,MARYLAi!D 21203

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August 23,1984 -

ARTHun E. LUNDVALL. J ,e,

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Vecc PatsiDEM SUPPLY j

U.S. Nuclear Regulatory Commission  ; Docket No Region 1 50-318 631 Park Avenue License Nos. DPR-53 King of Prussia, PA 19406 DPR-69 ,

c ATTENTION: Mr. Thomas T. Martin, Director e Division of Engineering & Technical Programs

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Gentlemen:

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The routine safety inspection transmitted by Inspection Report 50-317/84-16;

'r 50-318/84-16, identified one itern of apparentg noncompliance with;tlRC Regulation The apparent noncompliance concerned the control of informal punchlists -used hs an ,

i administrative mechanism for tracking outstanding items associated with.our Auxiliary

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Feedwater System modifications projec A thorough review of our current .

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Modifications Control system indicates that it adequately addresses the criteria of e 10 CFR 50, Appendix Calvert Cliffs Instruction (CCI)-126, Administrative Control of Facility Change Requests, meets the requirements of 10 CFR 50, Appendix B, Criterion V by providing

, the controlling procedures for accomplishing activities involving the modification of safety-related systems. These controls are structured to recognize the fact that certain '

identified deficiencies have an insignificant effect on the operability of a system in its post-modified state.

l CCI-126 meets the goals specified in 10 CFR 50, Appendix B, Criterion V in the following manne A. Prior to turning a mbdified syste.m over to the Operations organization 'h the following actions are take L'-

f Any outstanding Maintenance Requests genErdted against the modification that could affect the operabihty of the system , ,

are verified to be complete.

l l All post-modification testing, (e.g., Pre-Operational Tests, A i

Technical Support Procedures, Functional Tests, Local Leak i

i Rate Tests, Hydrostatic Pressure Tests), _is verified to be complete as these tests relate to an adequate demonstration of operability and acceptability of result , ,

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1 3. All critical drawings (Control Room P&lD's) are verified to l; - reflect the "As-Built" configuratio f l

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Mr. Thomas T. Martin

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August 23,1984 Page 2

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w ( All modifications involving changes to the Technical Specifications are verified to have been completed, reviewed, yg and approved by the NR ,

! All changes affecting the Operating Instructions, Operating Procedures, and Training are identified such that appropriate revisions can be mad Prior to final closeout of the Facility Change Request (FCR)

documentation the following actions are take . All outstanding Maintenance Requests generated against the modification are verified to be complete. These Maintenance Requests typically involve deficiencies, (such as retermination/ repair or painting, etc., of equipment) that do not affect the safety-related function of the modified syste In this way, deficiencies requiring maintenance actions are tracked to completion prior to final closcout of the Facility Change Request documentatio . Attachments to, CCI-126 identified as checklists for documenting completed actions are verified completed by Responsihb Engineers assigned to each FC These attachmenti are imed to document, as an example, the

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> following actions: spare part orders, revisions to Functional c

. Test Procedures, Strveillance Test Procedures, Technical e

Manuals, Calvert Cliffs Instructions, Preventive Maintenance Procedures, Fire Strategy Procedures, the Instrument Index, et ,

! We believe that the formal controls currently implemented by CCI-126 provide adequate assurance that important activities involving modifications to safety-related equipment are accomplished. We preceive no benefit in formalizing an administrative mechanism

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which is used infrequently to track non-significant deficiencies. We, therefore, request

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' that you reconsider the issuance of the subject item of noncomplianc Should you'have further questions regarding this matter, please do not hesitate to contact u Very truly yours, 7

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Mr. Thomas T. Martin August 23, 1984 Page 3 cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire l D. H. Jaffe, NRC !

T. Foley, NRC .

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