IR 05000317/1986010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/86-10 & 50-318/86-10

ML20214U721
Person / Time
Site:	Calvert Cliffs
Issue date:	11/25/1986
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8612090373
Download: ML20214U721 (1)

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NOV 2 51986 Docket No. 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mr. J. A. Tiernan Vice President-

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

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Subject: Inspection Nos. 50-317/86-10 and 50-318/86-10 This refers to your letter dated September 25, 1986, in response to our letter dated August 12, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely,

.Origim_13;7 e w...

ZeeH.Bettenh Stewart D. EbWet'er, Director Division of Reactor Safety cc:

Public Document Room (PDR)

Nuclear Safaty Information Center (NSIC)

State of Maryland bcc: -

Region I Docket Room (w/ concurrences)

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Y GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTl* TORE, MARYLAND 21203 JOSEPH A.TIERNAN VH:E PRESIDENT NucLEAn ENERGY September 25,1986 U. S. Nuclear Regulatory Commission Docket No Region 1 30-318 631 Park Avenue License Nos. DPR-53 King of Prussia, PA 19406 DPR-69 ATTENTION: Mr. Stewart D. Ebneter, Director Division of Reactor Safety Gentlemen:

This refers to inspection Report 30-317/86-10,50-318/86-10; which transmitted one item of apparent noncompliance with NRC requirements. Enclosure (1) to this letter is a written statement in reply to that item noted in your letter of August 12,198 Should you have further questions regarding this reply, we will be pleased to discuss them with yo Very truly yours,

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J. A. Tiernan JAT/SRC/gla Enclosure cc: D. A. Brune, Esquire 3. E. Silberg, Esquire i S. A. McNeil, NRC )

T. Foley, NRC '

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ENCLOSURE (1)

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REPLY TO APPENDIX A OF NRC INSPECTION I REPORT 50-317/E10; 50-318/E10 We have reviewed the circumstances that led to the apparent violation of Technical Specification 6.8.1 referred to by the subject inspection report. These events were reviewed individually as well as generically to determine the appropriate corrective measures. Those events which involved a failure to follow procedure are being addressed individually because of their somewhat unique circumstances and lack of commonalit However, strong measures will be taken in the future if similar events continue to occur. Two examples of the violation did disclose procedure weaknesses. Programmatic measures are being taken as described belo In response to the first example cited in Appendix A, we are making a programmatic change to the procedures administratively maintaining the environmentally qualified (EQ)

equipment to explicitly highlight the EQ requirements for the equipment items identified. These changes will be accomplished by October 27, 1986. All Technicians have been retrained on the EQ requirements contained in Functional Test Instruction (FTI)-104. They have been instructed to place the Qualification Number in the remarks section of the FTl data sheet. Additionally, the Technicians have been instructed to perform this same action on all applicable functional tests. The Technicians have also been given further training that emphasizes post-maintenance documentation especially for EQ maintenance action Regarding example No. 2, we believe that the maintenance on #11 Steam Generator level transmitter 1-LT-1124C was conducted properly, however, we agree that the item was not correctly identified in the Qualification Maintenance Program. Accordingly, we will revise Calvert Cliffs Instruction 208 and the IE Equipment List (contained in the Q-List)

by December 31, 1986, to ensure that the transmitters are properly identifie The third example indicates an apparent failure to submit Non-Conformance Reports (NCR) on three occasions for Digital Volt Meters (DVM) that were found to be out-of-calibration. We reviewed the calibration sheets for Item #8731 DVM and item #10273 DVM, and found NCRs issued for each on June 27, 1986. In addition, we have reviewed the calibration cheet for Item #10278 DVM and we have found no problems with the data sheet. We fei1 that no further action is warranted in this area. From a programmatic standpoint, we have instructed our Test Equipment Technicians to assure that they take

"as-found" readings on the test equipment prior to making any adjustment Concerning the fourth example, our Electrical & Controls (E&C) Technicians have been instructed to comply with all written instructions contained in plant maintenance and surveillance test procedures. Our follow-up observations and inspections indicate that procedures are currently being followed correctly, however, if deficiencies are detected in the future appropriate personnel actions will be executed by management. We believe that the observed instance referred to in the subject inspection report was an isolated cas l

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I ENCLOSURE (t)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT %317/410 %318/E10 With respect to example five, an E&C Section Standard Practice has been implemented to supplement Quality Assurance Procedure No. 7. This standard practice specifies the proper method for making procedural changes. Additionally, all E&C Technicians have been instructed on this practic ,

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