ML20235U134
| ML20235U134 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/17/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-83-28, NUDOCS 8707220367 | |
| Download: ML20235U134 (5) | |
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4 BA LTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMCRE. MARYLAND 21203 JOSEPH A.TIERNAN VICE PRtsiotNT NUCLEAR ENERGY July 17,1987 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Reauest for Additional Information Recardine Generic Letter 83-28 I
REFERENCES:
(a) Letter from Mr. S. A. McNeil (NRC), to Mr. J. A. Tiernan (BG&E),
I dated June 1,1987, same subject i
(b) Letter from Mr. A. E. Lundvall, Jr. (BG&E), to Mr. D. G. Eisenhut (N RC), dated February 29, 1984, Generic Letter 83-28, " Required Actions Based on Generic implications of Salem ATWS Events" (c) Letter from Mr. A. E. Lundvall, Jr. (BG&E), to Mr. J. R. Miller j
(NRC), dated June 7,1985, same subject Gentlemen:
This is in response to Reference (a). Enclosure 1 provides the additional information you requested regarding item 2.2.2 of Generic Letter 83-28, " Required Actions Based on Generic Implications of Sale n ATWS Even ts."
This reply supplements our previous responses in References (b) and (c).
Should you have further questions regarding this reply, we will be pleased to discuss them with you.
Very truly yours,
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Document Control Desk July 17,1987 Page 2 i
cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC T. Foley/D. C. Trimble, NRC l
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ENCLOSUREI 1
l A DDITIONAL INFORMATION CONCERNING ITEM 2.2.2 l
OFGENERIC LE' ITER 83-28 l
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NRC Reauest
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1 The licensee should show that for the nuclear steam supply system, procedures current and past vendor techniel information into plant operating, maintenance exist to confirm that vendor technical information is received and to incorporate and test procedures.
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BG&E Response The Baltimore Gas and Electric Company maintains the Plant Operating Experience Assessment Committee (POEAC) which is tasked with reviewing and disseminating pertinent information from the nuclear power industry to appropriate personnel at Calvert Cliffs. This permanent committee is controlled by Calvert Cliffs Instruc-tion 139D, " Organization and Operation of the Plant Operating Experience i
Assessment Committee," which requires POEAC to review many different documents,
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including the Combustion Engineering Availability Data Program (CEADP) Info-i bulletins. Our NSSS vendor, CE, uses the CEADP Infobulletins to disseminate to its customers important information and recommendations pertaining to specific problems. In addition, CE forwards Quarterly Reports to us that lists all CEADP Infobulletins distributed during the quarter. In the future, we will use these i
Quarterly Reports to verify that previous CEADP's have been received.
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Calvert Cliffs Instruction 139D requires POEAC to notify the appropriate system engineer of any faulty or inadequate vendor technical information the committee discovers. The system engineer is responsible to review and integrate the vendor technical information into the plant program. Calvert Cliffs Instruction 122D,
" Control of Technical Manuals," defines the responsibilities and process for reviewing and implementing technical manual changes. We believe these, together with the previous items discussed, provide adequate assurance that NSSS technical information is correctly incorporated.
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2.
NRC Reauest The staff finds the NUTAC/VETIP program acceptable for those instances where a vendor interface cannot be practicably established, e.g., where a vendor has gone out of business. However, the licensee should commit to establish a program to periodically contact vendors of key components (such as ' auxiliary feed pumps, safety-related ~ batteries, ECCS pumps and safety-related valve operators) to facilitate the exchange of current technical information. In the case of the diesel generator and safety-related switchgear vendors, a formal interface such as that with the NSSS vendor should be established if practicable.
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ENCLOSUREI ADDITIONAL INFORMATION CONCERNING ITEM 2.2.2 OFGENERIC LE' ITER 83-28 BG&E Resoonse As stated in Reference (c), we endorse NUTAC's Vendor Equipment Technical Infor-mation Program (VETIP). We have implemented this program at Calvert Cliffs and we feel that it is an efficient and realistic approach to ensure that vendor equipment problems are recognized, evaluated, and corrected.
Any attempt to establish a periodic contact program with vendors of " key" components would require BG&E to examine all components other than those supplied by the NSSS vendor in order to classify certain components as " key" components.
It would be extremely difficult to design a realistic technical approach to address and classify " key" components that have not been defined. Such a program would require the identification of all SR vendors. Contact would then be required with the vendors, causing them to establish a program which ultimately results in additional costs for the utility. In most cases, vendors will have no incentive, other than monetary, to establish and participate in such a program.
We feel that VETIP is a more realistic and efficient approach to your concerns.
However, we agree with the concept that a formal interface program should be established with some vendors (such as the diesel generator, SR switchgear, etc.)
other than the NSSS vendor if practicable. Accordingly, we will consult with and evaluate a potential field of vendors and determine by September 30, 1987, any additional interface programs we will develop similar to that which we currently have with CE.
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NRC Reauest The licensee's responses do not address the control of vendor-supplied services for maintenance work on safety-related equipment. The licensee should provide verification that the responsibilities and instructions for vendor-supplied
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services on safety-related equipment are defined and ccntrolled appropriately.
FG&E Resnonse J
i The control of vendor-supplied services for on-site maintenance work on safety-related (SR) equipment is provided by Quality Assurance Procedure 14, " Plant Maintenance." Maintenance performed on SR equipment is in itself SR, and j
@refore, procurement of vendor-supplied services is SR. The Procurement Quality l
Unit (PQU) reviews all requisitions for SR services in accordance with the Procurement and Storage Manual. During this review it is determined whether or j
not the vendor's activities will be covered by BG&E's Quality Assurance (QA) l Program or that of the vendor's. The majority of SR services are performed under our program which requires vendor personnel to report to the Quality Control (QC)
Supervisor upon arrival on site. All SR and designated NSR maintenance activities are covered by our QC inspectors.
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ENCLOSURE 1 ADDITIONAL INFORMATION CONCERNING ITEM 2.2.2 OFGENERIC LETTER 83-28 For those situations where the SR service will be performed under the vendor's own QA program, the vendor must be on BG&E's Approved Vendor List (AVL). To qualify for the AVL, the vendor's QA program must be approved by the PQU. When vendor personnel arrive on site to provide a service, they bring their own inspectors for QC coverage. In addition, the vendor must prepare and submit a QA Plan for approval by the PQU prior to starting work. During the course of the work, the vendor's activities are audited against the approved QA Plan by BG&E.
A similar situation exists for SR maintenance performed on items at the vendor's facility. In this case, the vendor must be on the AVL to work entirely under its own QA program, subject to surveillance by our PQU. Maintenance may be performed l
by a vendor not on the AVL if the entire project is observed by a BG&E AC/QA inspector and if their procedures are approved by the PQU and the Nuclear l
Engineering Services Department prior to beginning work.
During the procurement package review, the PQU ensures that the requesting organization specifies the scope of work and that all applicable QA requirements are identified. Additionally, the Nuclear Engineering Services Depar tment, with PQU's concurrence, will determine which QA program (vendor or BG&E) will govern 1
the activities.
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