ML20039F570

Responds to NRC 811127 Ltr Re Violations Noted in IE Insp Repts 50-317/81-22 & 50-318/81-21.Corrective Actions:All Active Facility Change Requests Reviewed & Instructions for Requests Revised for Clarification

ML20039F570
Person / Time
Site:	Calvert Cliffs
Issue date:	12/21/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20039F561	List: ML20039F570
References
NUDOCS 8201130110
Download: ML20039F570 (4)

Text

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• B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BO X 147 5 B ALTIM OR E. M A R YL AN D 21203 AnTMum E. LUNOVALL.Ja.

V<a Potsiossef Sumv December 21, 1981 U.S. Nuclear Regulatory Commission Docket Nos. 50-317 Region I 50-318 631 Park Avenue License Nos. DPR-53 King of Prussia, PA 19406 . DPR-69 ATTENTION: R. W. Starostecki, Director, 4 Division of Resident and Project Inspection '

s Gentlemen: -

This refers to your Inspection Report 50-317/81-22; 50-318/81-21, which transmitted several items of apparent noncompliance with NRC require-ments. Enclosure (1) to this letter is a written statement in reply to those items noted in your letter of November 27, 1981.

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

Very truly yours, ,

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Anct Vice President - Supply AEL/ LOW /gla Enclosure cc: J. A. Biddison, Esquire G. F.-Trowbridge, Esquire D.11. Jaf fe, NRC R. E..Architzel, NRC G

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o R.~W.iStarostecki 2 . December 21,'1981-STATE OF MARYLAND:

TO WIT:

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Arthur E. : Lundvall, Jr., being duly sworn states that he' is Vice President of the Baltimore Gas-and Electric Company,'a: corporation:

of the State of= Maryland; that'he provides the foregoing response for

the purposes therein set forth; that' the statements made are true'and correct to the best of-his knowledge,.information, and belief; and that' he was authorized to. provide the response.on ehalf of'said orporation.-.

WITNESS my Hand and Notarial Seal _

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ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC INSPECTION REPORT 50-317/81-22; 50-318/81-21 Item A. 1 The following corrective actions have been taken:

a) A review of all active Facility Change Requests (FCR's) has been performed. This review verified that conditions adverse to quality identified to date, including specific NRC commitments, are being pursued in an acceptable and timely manner.

b) The Calvert Cliffs Instruction for Administrative Control of Facility Change Requests was revised to more clearly define; (1) FCR transmittal flowpaths and, (2) clerical responsibilities involving timely receipt and routing of FCR's.

c) The FCR Review Committee, consisting of plant management personnel who periodically review the backlog of active FCR's with respect to current applicability and priority has been made aware of the circumstances which initiated this item of noncompliance, such that future delibrations can consider this aspect of FCR administration.

These actions should preclude future violations of this nature.

Item A.2 Corrective steps were taken, as described by your inspection report, to-modify the valve actuation devices to cause both valves in question to fail closed.

In addition to the information provided in your report, it should be noted that certain administrative controls were active during the period in question which would have revealed the deficiency in the Unit 2 valve, notwithstanding the incorrect assumptions made after the first inspection.

The maintenance personnel were initially dispatched to the Unit 2 valve for the specific reason of observing, for comparative purposes, the penumatic configuration of the Unit 2 valve. The results of that comparison were reported to the POSRC immediately. Within the next working day following discovery of the improper failure mode of the Unit i valve, the Unit 2 valve was included in scope with the FCR.

This conscious action by the POSRC provided the mechanism which would have identified the improper failure mode of the Unit i valve. The General Supervisors responsible for ensuring design deficiencies are properly identified and corrected in a timely manner will be routed a A .

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• ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC INSPECTION REPORT 50-317/81-22; 50-318/81-21 Item A.2 (Continued) Y[o$.

copy of this response and associated inspec, tion-report.e This response will be subject to POSRC review, which will~ serve

• to. reiterate the necessity for identifying and correcting design' deficiencies in a' timely manner. The routing and POSRC review will be completed by January 15, 1982.

Item A.3 The Calvert Cliffs Instruction for Administrative Control'of Facility

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Change Requests has been revised to more clearly define the. control procedures for document revisions following physical modifications.

A special review and verification of completed FCR work packages describing the "As-Built" condition of plant modifications'is in progress. The purpose of this task is to expedite the close-out of existing FCR paperwork and ensure "As-Built" information is incorporated into plant documentation.in a timely manner. This special review should be completed by July, 1982.

A Document Control Task Force is currently reviewing the design document revision process regarding timeliness of incorporating "As-Built" information into critical plant documents. The recommendations-of this tack force relative to timeliness of design document revisions will be considered and incorporated into our procedures as appropriate.

These actions should prove beneficial in mitigating future violations of this nature.

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