ML20072M938
| ML20072M938 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/10/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20072M892 | List: |
| References | |
| NUDOCS 8304010406 | |
| Download: ML20072M938 (3) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL. JR.
- ["((7" March 10,1983 s
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 Division of Project & Resident Programs Gentlemen:
This refers to your Inspection Report 50-317/82-3050-318/82-27, 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 February 9,1983.
Should you have further questions regarding this reply, we will be pleased to discuss them with you.
Very truly y
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Vice President - Supply AEL/DWL/gla Enclosure cc:
3.~A. Biddison, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC R. E. Architzel, NRC 83040'10406 830325 PDR ADOCK 05000317 O
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r ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT NO. 50-317/82-30; 50-318/82-27 During the 1982 refueling outage of Calvert Cliffs Unit I and prior to May 3,1982, temporary lead shielding was applied to safety-related systems inside the Containment Building without formal controls. Before May 3,1982, no approved criteria existed for the application of temporary lead shielding at the Calvert Cliffs Nuclear Power Plant.
With the approval of guidelines for temporary lead shielding on May 3,1982, appropriate plant personnel were made aware that no shielding should be installed without formal controls.
We disagree with the violation as noted in Appendix A of NRC Inspection Report 50-317/82-30; 50-318/82-27, and believe that issuance of a Non-Conformance Report (NCR) was inappropriate in this case. However, we acknowledge the need for formal procedures to control the application of lead shielding to safety-related systems. Subsequent to May 3,1982, we refrained from installing additional lead shielding at the Calvert Cliffs plant until a formal procedure had been written and approved to control this activity.
The shielding installed during the refueling outage of Calvert Cliffs Unit I was removed and a visual inspection of the associated piping was conducted by qualified Non-Destructive Examination Inspectors prior to plant start-up with no damage detected.
Later, your concerns caused us to reanalyze the associated piping. This reanalysis demonstrated that no additional stresses were permanently induced in the piping systems. All identified shielding on safety-related pipes / components in the Auxiliary Building has been removed. Any shielding used during the recent refueling outage of Calvert Cliffs Unit 2 (Oct. 82-Jan. 83) was controlled in accordance with Radiation Safety Procedure (RSP) 2-216 entitled, "The Services of the Operational Maintenance Assistance Radiological Team (OMAR)." This procedure was approved on September 29,'
1982, for Calvert Cliffs Unit Nos.1 & 2. The following is a summary of the pertinent information from RSP 2-216 concerning shielding:
1.
Prior to the application of shielding or the addition of shielding to safety-related pipes / components a completed stress analysis is required and must be attached for use to the OMAR Work Request Forms. This is the responsibility of the OMAR Work Leader. (Stress analysis is defined by this procedure as detailing the location, component, maximum allowable weight, and type of shielding being applied).
- NOTE -
This does not apply to shielding which is supported by independent structures such as braces or scaffolding.
2.
The Quality Control Group is notified by the OM AR Work Leader prior to_ the application of shielding, the addition of shielding, or the removal of shielding.
Appropriate QC sign-offs are include on OMAR Work Request Forms.
k ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT NO. 50-317/82-30; 50-318/82-27 3.
Only OMAR applies, adjusts, or removes the subject shielding with the approval of the ALARA Coordinator / Radiological Control Shift Supervisor.
4.
The subject shielding material is secured in a manner that will not shift or move once in place. (Indicator tape has been used to monitor for tampering or shield movement).
5.
When QA/QC requires equipment accountability, each piece of shielding is stenciled or marked numerically for ease of accountability.
6.
Once secured, a sign is attached in a manner so as to be readily visible and not easily removed with the wording {or equivalent}, "DO NOT MOVE OR ALTER THIS SHIELDING WITHOUT RCSS APPROVAL."
7.
All OMAR functions including shielding activities are entered on the OMAR Work Request Issue Log.
- NOTE -
All temporary lead shielding is removed before systems are required for aperation unless specific relief is approved and supported by a safety analysis. Subject shielding is only applied according to the guidelines contained in the stress analysis.
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