ML20056E220
| ML20056E220 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/18/1993 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308200307 | |
| Download: ML20056E220 (3) | |
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. BALTIMORE i
GAS AND l
ELECTRIC 1650 CALVERT CUFFS PARKWAY. LUSBY, MARYLAND 20657-4702 i
RoetRT E. DENTON vier Pa[51 DENT j
NuctrAm Ewtaov August 18,1993 U. S. Nuclear Regulatory Commission Washington, DC 20555 NITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & 50-318 Reply to Notice of Violation 50-317(318W3-18-01 i
REFERENCE:
(a)
Letter from L. H. Bettenhausen (NRC) to Mr. R. E. Denton (BG&E), dated july 19,1993, Notice of Violation NRC Inspection Report Nos. 50-317/93-18 and 50-318/93-18 In respon2e to Reference (a), Attachment (1)is provided.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
W ulyyours, W~
I r RED /CDS!bjd Attachment ec:
D. A. Brune, Esquire J. E. Silberg, Esctuire R. A. Capra, NRC i
D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. IL Walter, PSC 9308200307 930818 PDR ADOCK 05000317 i
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A'ITACIIMENT (1)
REPLY TO NOTICE OF VIOLATION 50-317(318)/93-18-01 I.
DESCRIPTION OF VIOLATION.
The subject Notice of Violation (NOV) is concerned with our control of maintenance material / equipment " drop off' areas in accordance with 10 CFR Part 50, Appendix B, Criterion VIII and our corresponding site implementing procedures. The NOV and its accompanying cover letter indicated drop off points had evolved from temporary storage areas into defacto warehouses and therefore fell under, but did not meet, our established warehouse requirements. The cover letter elaborated that the violation was of concern because our Quality Assurance Program should have identified that the drop off areas were not conforming to the requirements of our Calvert Cliffs Instruction (CCI)-162," Procurement and Control of Items and Services for Calvert Cliffs."
II.
HACKGROUND.
Our warehouses are outside the protected area and controlled by CCI-162. The referenced drop off areas are located inside the protected area in close proximity to our Maintenance Shops and are controlled by CCI-207," Control of Safety-Related and Augmented Quality Spare Parts." The drop off areas were established as temporary equipment staging areas to support near term scheduled maintenance and as storage areas for ncn-safety-related consumables. Calvert Cliffs Instruction-207 does not contain the same extensive reqairements for long-term storing, protective packaging, segregation, and storage inspection as CCI-162. Calvert Cliffs Instruction-207 was developed to l
ensure adequate control of parts on a short-term basis and requires that if a part is not used it shall i
be returned to the warehouse as soon as possible. We concur that the evolution of drop off points long-term storage areas is inapprepriate and can be viewed as contrary to CCI-207 or to CCI-162.
Our Quality Assurance organization identified many of these weaknesses in the implementation of i
CCI-207 during audits conducted in early 1993. These audits also found that CCI-207 was weak in control of safety-related (SR) and augmented quality (AQ) parts in accordance with Appendix B j
requirements. At the time of the inspection, responsible line organizations were in the process of planning corrective actions.
i III.
REASON FOR VIDIATION.
The causes of the drop off areas not complying with Appendix B requirements are attributed to the following factors:
1.
A lack of knowledge of drop point inventory requirements by engineering and l
maintenance personnel using the drop off areas.
'2.
Lack of clear guidance in CCI-207 concerning the return of parts to the warehouse.
i 3.
Confusion over responsibility for performing some drop off area inspections.
IV.
CORRECTIVE STEPS TAKEN AND RESULTS AClIIEVED.
We have evaluated our use of drop off points and determined that they fill a necessary role in staging 1
parts to the field. Thus, we have undertaken measures to define the type of materials and duration of storage that is appropriate, and we have initiated measures to upgrade the conditions and inventory i
accountability of materials at the drop points that receive SR and AQ parts and materials.
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ATTACllMENT(1)
REI'lX TO NOTICE OF VIOLATION 50-317(318)/93-18 01 l
Personnel qualified to ANSI 45.2.6 have been assigned to these drop off areas to inspect returned SR and AO parts and ensure packaging and general storage requirements are being met. Our Procurement Engineering staff has inspected SR and AQ part drop off areas and made recommendations for repackaging of parts and evaluated necessary cleaning of parts prior to repackaging. Initial actions are complete. These corrective measures will result in the proper receipt, storage, inspection, packaging, and segregation of SR and AO items in the drop off areas that receive SR and AQ parts and materials.
V.
CORRECTIVE ACTIONS WillCil WIII IlE TAKEN TO AVOID FURTilER VIOLATIONS.
We have begun actions that will assimilate SR and AQ material / equipment drop off areas into the warehouse area of operations. Drop off areas for SR and AO material / equipment will be controlled under applicable CCI-162 requirements and run by personnel with proper training and qualifications on those requirements and responsibility for ensuring they are met. We expect this transition to be completed by the end of the first quarter 1994.
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