ML20078N524

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Responds to NRC Re Violation Noted in Insp Repts 50-317/94-25 & 50-318/94-25.Corrective Actions:Dg Project Instruction DGPI-050, Cleanliness & Work Area Housekeeping Requirements Issued 941026
ML20078N524
Person / Time
Site: Calvert Cliffs  
Issue date: 02/10/1995
From: Denton R
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9502150386
Download: ML20078N524 (3)


Text

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M Ro:Eur E. DENTON Baltimore Ga and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 586-2200 Ext. 4455 local 410 260-4455 Baltimore February 10,1995 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION.

Document Control Desk SUILIECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 piesel Generator Proicct Eauipment Protection Notice of Violation REFEllENCE-(a)

Letter from Mr. W.11. Ruland (NRC) to Mr. R. E. Denton (BGE), dated January 11, 1994, Notice of Vic,!4on, Combined Inspection Report Nos. 50-317/94-25 and 50-318/94-25 In response to Rekrene (a), Attachment (1) is provided.

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

Very truly yours,

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for R. E. Denton Vice President - Nuclear Energv RED /DWM/ dim cc:

D A. Brune, Esquire J. E. Silberg, Esquire L B. Marsh, NRC D. G. Mcdonald, Jr., NRC T T. Martin, NRC P. R. Wilson, NRC R.1. Mel.can, DNR J.11 Walter, PSC

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8 ATTACIIMENT 0)

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NOTICE OF VIOLATION 50-317(318)/94-25-01 Notice of Violation 50-317(318)/94 25-01 describes a non-conformance involving packaging, protection, and cleaning activitics associated with safety-related equipment in the safety-related diesel building not maintained in accordance with our Quality Assurance Policy Manual. Installed and in-place safety-rclated j

equipment and component surfaces and moving parts were not protected from the construction environments of: (1) grinding and cutting of stect; (2) construction dirt, which contained metal fdings, grease, and concrete materials; and (3) construction equipment such as ladders, tools and equipment boxes testing on unprotected safety-related louver mechanisms.

1.

DESCRIPTION AND CAUSE OF EVENT While a great deal of management attention had been given to housekeeping and cleanliness during the Diesel Generator Project construction phase as it relates to personnel safety, standards were not established at a sufficiently high level to ensure that all aspects of equipment protection and storage requirements were consistently met as installation of safety-related equipment proceeded. In addition, the specific construction activities in progress at the time (e g., fire retardant application) required special protection measures which were not diligently maintained. Management action initiated as a result of recent selfidentified housekeeping inspections failed to fully correct the situation.

11.

CORRECTIVE STEPS TAKEN AND RESUI.TS ACillEVED Diesel Generator Project management, upon being informed of the condition, immediately applied additional resources to ensure that safety-related equipment was properly protected against the construction environment. In particular, Project management ensured that appropriate inspections, cleaning activities, and subsequent actions were implemented to climinate concerns regarding the potential degradation of safety-related equipment.

Guidelines on equipment protection requirements were immediately implemented and training conducted for all personnel. The Diesel Generator Project documentation hierarchy, including appropriate contractor procedures, was reviewed m ensure that the lowest-tier procedures contain the applicable requirements. The immediate result of these actions produced a baseline evaluation of the entire project and ensured that conditions were established to meet the requirements of 10 CFR Part 50, Appendix B, Cnterion Xill.

III, CORRECTIVE STEPS WillCil WII 1, ilE TAKEN TO AVOID FURTIIER VIOL. ATIONS Diesel Generator Project instruction DGPI-050, " Cleanliness and Work Area llousekeeping j

Requiremerts." was issued October 26, 1994 to assign area inspections to cognizant personnel, defme minin.um acceptable equipment condition standards, and provide process guidance. The procedure also includes documentation requirements and provision for escalating management actions m response to inspection results, if required. Increased emphasis has been placed on open electrical enclosures and uncovered equipment openings, including weekly cleaning of control I

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ATTACilMENT (1) i i

NOTICE OF VIOI.ATION 50-317(318)/94-25 01 pancis. Appropriate personnel have received training on placement of protective covers when performing overhead or close-proximity work.

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DATE WilEN Fill,1, COMPI, LANCE Wil,l., IIE ACillEVED j

Full compliance was achieved on October 26, 1994, when all affected ar~ts were cleaned and DGPI-050 was issued.

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