ML20096E581
| ML20096E581 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/23/1984 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8409070125 | |
| Download: ML20096E581 (3) | |
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BALTIM ORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475. BALTIMORE,MA51YLAND 21203
- Amum E. LUNDVAu JR.
' Vict PeerstDENT
. Supply U.S. Nuclear Regulatory Commission Docket Nos.'
50-317 50-318 Region I.
License Nos.
DPR-53 631 Park Avenue King of Prussia, PA 19406 DPR-69 ATTENTION:
Mr. Thomas T. Martin, Director Division of Engineering & Technical Programs Gentlemen:
The. routine - safety inspection transmitted by Inspection Report 50-317/84-16; 50-318/84-16, identified one item of. apparent noncompliance with NRC Regulations.
The apparent noncompliance concerned the control of informal punchlists used as an administrative mechanism for tracking oestanding items associated with our Auxiliary Feedwater. System modifications project.
A thorough review of our - current Modifications Control system indicates that it adequately addresses the criteria' of
Calvert Cliffs Instruction (CCI)-126, Administrative Control of Facility Change
' Requests, meets the requirements of 10 CFR 50, Appendix B, Criterion V by providing the controlling procedures for accomplishing activities involving the modification of safety-related systems. ' These controls are structured to recognize the fact that certain identified deficiencies have an insignificant effect on the operability of a system in its post-modified state.
CCI-126 meets the goals specified in 10 CFR 50, Appendix B, Criterion V in the following
- manner.
. A. Prior to turning a modified system over to the Operations organization the following actions are taken.
- 1. - Any outstanding Maintenance Requests generated against the modification that could affect the operability of the system are verified to be complete.
- 12. ' All post-modification testing, (e.g., Pre-Operational Tests, Technical Support Procedures, Functional Tests, Local Leak Rate ' Tests, Hydrostatic Pressure Tests), is verified to be complete as these tests relate to an adequate demonstration of
. operability and acceptability of results.
'3. ~ All critical drawings '(Control' Room P&ID's) are verified to reflect the "As-Built" configuration.
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Mr. Thomas T. Martin.
.- August 23,1984
- Page 2} -
3.~. All ' 1 modifications involving changes to the Technical
. Specifications are verified to have been completed, reviewed,'
- and approved by the NR.C.
- 5. ' All changes affecting the'. Operating Instructions, Operating Procedures, and Training are identified such that appropriate -
revisions can be made.
' B. Prior to final closeout of the Facility Change Request (FCR) documentation the following actions are taken.
- 1. ' All outstanding Maintenance Requests generated against the modification are verified to.be complete. These Maintenance-Requests typically involve deficiencies, (such.
as retermination/ repair or painting, etc., of equipment) that do not affect.the. safety-related. function of the modified-system; In this way,1 deficiencies ' requiring t maintenance actions are tracked to completion prior to final closeo'ut of the -
Facility Change Request documentation.
'2.
Attachments to,CCI-126 > identified: Jas checklists - for documenting _ completed ' actions are' verified completed by Responsible ' Engineers assigned to each FCR.
' These-attachments - are ~ used : to document,' as an example, the -
following actions: spare part orders, revisions to Functional
~
Test Procedures,- Surveillance Test Procedures, Technical
~
Manuals, Calvert Cliffs Instructions,- Preventive Maintenance Procedures, Fire Strategy Procedures, the Instrument Index,-
etc.'
We believe that the formal controls currently implemented by CCI-126 provide adequate-7 assurance that important activities involving modifications to safety-related equipment are accomplished. ' We preceive no benefit in formalizing an administrative mechanism which is used infrequently to track non-significant deficiencies. ' We, therefore, request that you. consider the issuance of the subject item of noncompliance.
Should you have further questions regarding this matter, please do not hesitate to -
contact us.
Very truly yours,--
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Mr. Thomas T. Martin August 23,1984
-Page 3 cc:
D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC l
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